After a substantial amount of work my friends at PEW published yesterday a very good report: “Transshipment in the Western and Central Pacific - Greater understanding and transparency of carrier vessel fleet dynamics would help reform management”. This is very good insight (disclaimer I was honoured to be one of the external reviewers) on the realties and shortcomings of the longliners high seas transhipment management in the WCPFC.
And a usual, as this report proves, the main beneficiaries of the status quo are the ones opposing any changes every-time the issue of transhipment at sea is raised at the WCPFC meetings, because are the ones doing most of the transhipments: Taiwan, China, Panama, South Korea, Liberia and Vanuatu… being the last one very disappointing as it a member of FFA.
And while the knee jerk reaction is to blame RFMOs, reality is that the can only go as far as the members allow them too, so if you get upset by what you read here… act at your government level to put pressure during the meeting discussions, or just don’t buy fish caught by any operators related to those countries.
I just quote key parts of the report, and the well substantiated recommendations… yet have a go at the original as is very well illustrated and with rock solid references.
As a ex fisherman for big part of my life, I can tell you that as a regulator, if you don’t know the facts and figures… you can claim ignorance, but if you know the facts and then ignore them, then you are just incompetent.
The complex world of transshipment in the WCPFC Convention area
RFMOs are administrative bodies made up of governments that share interests in managing and conserving fish stocks in a region. These include coastal States, whose waters are home to the managed stocks, and “distant water fishing nations,” whose fishing fleets travel to areas where those stocks are found. At least 13 RFMOs actively manage fish stocks on the high seas, and some of their areas overlap. Of these, five (including the WCPFC) are tuna RFMOs, which manage fisheries for tuna and other large, tuna-like species such as swordfish and marlin. Together, these five manage fisheries in about 90 per cent of the Earth’s oceans.6
The WCPFC is the largest tuna RFMO, covering about 20 per cent of the planet’s surface. It comprises 26 member governments, seven cooperating non-members and seven participating territories (collectively referred to as CCMs). Decisions are binding on the CCMs and require unanimous consent. Article 1(e) of the WCPFC Convention7 defines fishing vessels as “any vessel used or intended for use for the purpose of fishing … including carrier vessels.” Therefore, carrier vessels operating outside the jurisdiction of the nation whose flag they fly in the WCPFC Convention area must be authorized and listed on the WCPFC Record of Fishing Vessels (RFV).
The WCPFC defines transshipment as “the unloading of all or any of the fish on board a fishing vessel to another fishing vessel either at sea or in port.” Notably, the Commission asked CCMs to encourage their vessels to transship in port. It then developed procedures for CCMs to obtain and verify data on the quantity and species transshipped both in port and at sea in the Convention area, and procedures to determine when transshipment covered by this Convention has been completed.
A large proportion of potential at-sea transshipment events appear to have taken place involving carrier vessels flagged to Panama. This was followed by South Korean-flagged carrier vessels. Chinese Taipei, Liberia, Vanuatu, and China also had carrier vessels that appeared to have been involved with at-sea transshipments. Five of these six flag States had carrier vessels that reported high seas transshipment events in 2016, with China the only CCM whose flagged carrier vessels did not report any. Unfortunately, China did not provide any information in its Annual Report Part 1 that could be used to corroborate the number of its carrier vessels involved with high seas transshipments.
This study found that the WCPFC’s management of transshipment in its Convention area is compromised by a lack of reported information on transshipment, coupled by non-compliance with reporting requirements and non-standardized reporting responses by CCMs on carrier vessels and their activities. This is exemplified by the following findings related to transshipment monitoring based on analysis of AIS data and publicly available reports:
At least five times as many carrier vessels operated in WCPFC Convention area waters in 2016 than the 25 vessels that submitted high seas transshipment reports to the secretariat. Very little information is available on the remaining vessels’ activities.
A strong possibility exists that more at-sea transshipments occurred than were reported to the WCPFC by carrier vessels themselves or relevant flag and coastal State authorities.
Unauthorised carrier vessels probably carried out transshipment activities in WCPFC-managed waters that included, in part, the transfer of WCPFC-managed species.
These findings are reinforced by the following findings related to transshipment reporting and data sharing:
Data gaps, anomalies, and non-standardized responses by CCMs in their reports on transshipments by carrier vessels provided to the WCPFC impede accurate auditing, increasing the risk that transshipment activities go unreported and unverified.
The WCPFC “fished/did not fish” reporting metric must be linked to and consistent with VMS data and verified by the WCPFC secretariat to provide any kind of reporting and auditing value.
Transshipment reporting requirements by the WCPFC, IATTC, and NPFC lack lack consistency and effectiveness, increasing the likelihood that this activity will not be reported and tracked.
The absence of a data-sharing agreement between the WCPFC and the IATTC on transshipments by carrier vessels heightens the likelihood that unreported transshipments occur, especially by those operating in the IATTC/WCPFC overlap area or in both Convention areas during the same voyage.
The lack of a data-sharing agreement between the WCPFC and the NPFC increases the risk that transshipments by carrier vessels authorized by both RFMOs may go unreported. This could cause both to inaccurately count species caught in waters they manage, affecting their stock assessments.
As such, the entire regulatory framework requires significant strengthening, standardization, and harmonization, regardless of whether current reporting requirements are being complied with.
This study identifies several pronounced monitoring and control issues associated with transshipments in the WCPFC Convention area. The Commission should prioritize addressing these findings to ensure that its management of these activities is not compromised. Given the gaps and anomalies in reports by the five fleets that conducted the most transshipments in WCPFC waters and their flag States—and the yellow cards the EU has issued to these States—the Commission should also consider implementing the best-practice guidelines below.
Addressing these findings and implementing the guidelines would also help the WCPFC’s science provider, the Secretariat of the Pacific Community, obtain more complete information on transshipments, which its members could use to improve fisheries management. The Commission should consider placing a ban, or at least a short moratorium, on transshipment at sea in WCPFC waters until it can take these actions.
Best-practice guidelines for transshipment reporting
To make transshipment reporting more complete and uniform, WCPFC and CCM national authorities should:
Require all transshipments to be reported to the relevant flag State, coastal State, and port State, as well as the WCPFC secretariat, in a standardized format, using IMO numbers as each vessel’s primary identifier.
Update WCPFC transshipment notification, declaration, and reporting forms to include the type and format of data in standards to be developed by the FAO. At a minimum, the WCPFC should require that reporting include details on the amount and type of by-catch that vessels transship, consistent with the information outlined in Annexes A and C of the FAO’s Port State Measures Agreement.
Mandate that all WCPFC-authorized carrier vessels intending to transship in the Convention area provide electronic notification of their entry into WCPFC waters to the relevant flag State and the secretariat. That notification should include confirmation of the vessel’s compliance with near-real-time VMS reporting and observer requirements.
Require that all authorized fishing vessels intending to transship—offloading as well as receiving vessels— submit electronic notifications at least 24 hours beforehand and that they post declarations within 24 hours after the event to the relevant flag State, port State and coastal State, and the RFMO secretariat. They should send the notification before reaching the first point of landing for the catch, regardless of where the transshipment occurred.
Mandate that observers on board the offloading and receiving vessels submit electronic reporting forms to the relevant flag State, coastal State, and port State, and the RFMO secretariat within 24 hours after each transshipment.
Task the secretariat to conduct periodic audits of transshipment and carrier vessel activities, including CCM reporting, using a combination of the public and non-public data it holds.
Best-practice guidelines for transshipment monitoring
To make monitoring more effective, WCPFC and relevant CCM national authorities should:
Require an observer (human, electronic or a combination) on board both the fishing vessel and the carrier vessel for all at-sea transshipments. Also, minimum standards must be set for what information the observer collects.
Ensure that all carrier vessels authorized to transship in WCPFC waters have access to trained and certified carrier observers from either a national program of CCMs or the Pacific Islands Regional Fisheries Observer program. The WCPFC Regional Observer Program should certify these national carrier observer programs and give them a clear mandate to collect information and data for scientific and compliance purposes.
Require that all vessels authorized to engage in transshipping activities have an operational VMS on board that relevant flag and coastal State authorities and the secretariat can use to monitor the vessel’s movements in near-real time.
Mandate that carrier vessels have a backup VMS unit in case their primary VMS malfunctions or fails and require that vessels return to port immediately if the primary VMS unit continues to malfunction or has failed.
Given the complexity of transshipments in the WCPFC Convention area, consider requiring that vessels use AIS as an additional monitoring tool, which would make their activities more transparent and close gaps in overall vessel monitoring.
Best-practice guidelines for transshipment information sharing
To ensure effective data sharing, the WCPFC should:
Establish and harmonize transshipment data-sharing procedures among relevant flag, coastal and port States with the WCPFC secretariat.
Revise information-sharing memorandums of understanding between the WCPFC and IATTC secretariats to require the sharing of all transshipment-related information, including declarations and carrier observer reports. The agreement should also allow the IATTC to send the WCPFC secretariat reports from IATTC observers on carrier vessels who witnessed transshipments on the high seas in the WCPFC Convention area involving WCPFC-managed and caught species.
Establish an information-sharing memorandum of understanding with the NPFC secretariat to require the sharing of all transshipment-related information, including declarations and observer reports, especially when carrier vessels on a single voyage transship species managed by both organizations.
Transshipment of catch between vessels plays an enormous role in the WCPFC tuna fishery. As this study described, the WCPFC authorized 625 carrier vessels in 2016 to transship inside the Convention area. At least 140 carrier vessels—flagged to 11 different CCMs—operated in a manner consistent with taking on tuna and other catch from fishing vessels either in port or at sea. However, only 25 vessels reported this activity on the high seas in Convention waters.
This discrepancy reflects insufficient reporting by carrier vessels, a problem that is exacerbated when data in vessel transshipment reports don’t match what is submitted by States. Not only is it likely that more at-sea transshipments occurred that year than authorized vessels or flag States and other CCMs reported to the WCPFC, but unauthorized carrier vessels also probably transshipped in the Convention area, taking on WCPFC-managed species.
This finding, through Pew’s review of public WCPFC reports and AIS data, makes clear that the Commission’s monitoring of transshipments in its waters is inadequate, especially when they occur at sea. Improving this function of the Commission is critical: Misreporting or non-reporting catches results in the laundering of millions of dollars’ worth of illegally caught fish each year.
Enhanced monitoring is also necessary to thwart the illegal activities associated with transshipment, including drug and human trafficking and violations of labour standards for fishing crews. Vessels that transship at sea often stay away from port for months, and their crews have reported substandard working conditions and even slavery.
Establishing clear rules for transshipment in the Convention’s waters can help ensure a strong, legal, and verifiable seafood supply chain for the species it manages and reduce the likelihood that illicit activities will occur. Likewise, if all WCPFC flag, coastal and port States implement the best-practice guidelines, then all the Convention’s stakeholders—including the fishing industry and consumers—can be assured that transshipment is an effective and secure way to transfer fish from the sea to land.
It is hoped this initial study represents just a starting point for making vessel operations in the WCPFC more transparent. With continued research, analysis, and action, the WCPFC could become a model for effective transshipment management for other regions of the globe.