Since I don’t work in academia, I don’t often get involved in the “need” to publish. I enjoyed every time I was invited to co-author papers, and generally my role is to validate assumptions and provide an operational filter or critique to the analysis, especially when it involves desk-based satellite conjecture on AIS.
I have previously critiqued papers based on distant analysis, which is not something I particularly enjoy when I know some of the authors personally... However, this is how science advances. I hope the colleagues I know who authored this paper view my comments as a contribution.
I acknowledge in this blog the contribution of Shelley Clarke, whom I visited at her beautiful home in Japan, where we discussed this paper.
There is a clear trend in producing numerous papers by combining GFW AIS data, which primarily shows where vessels go and when, with other data to perhaps 'sketch in' a fuller picture.
Sometimes, this additional data includes expert survey information on whether various ports are connected to IUU fishing and labour abuse (“bad” ports). Clearly, it all depends on how knowledgeable the experts are about what is happening in nearly every specific port.
Based on this, they identify the vessels visiting the “bad” ports and the fishing grounds utilised by these vessels. Yet this classification of “bad ports” is usually based solely on whether they have ratified the PSMA or not.
Along with the necessary caution regarding AIS data, as someone involved in risk analysis of incoming vessels, I have observed that over the past few years, fishing vessels tend to turn their AIS off as soon as they leave port. This is because, unless AIS is mandated by their national legislation due to the vessel type (e.g., carriers), the use of public AIS databases has made them reluctant to keep it on.
There is also the fact that the survey tends to be conducted mainly in European languages, and I believe a few highly publicised events can significantly influence respondents, especially when they do not work specifically in one area.
There also seems to be a tendency for everyone to blame China for all IUU fishing (perhaps justified), and indeed, “flagged to China” is the only national-identity risk factor identified by the experts.
Based on my 25 years of experience in over 15 countries in the WCPO, Korea and Taiwan have a similar level of non-compliance once fleet size and types of infringements are considered… in other words, China may have 100 vessels with a high non-compliance index out of 1000, while Korea may have 20 out of 100.
The first thing to note about the new paper is that most of its conclusions appear to be based on a calculation of “landed fishing effort”. As far as I can tell (I did not examine the methods in detail), this is a calculation of the number of hours between port calls multiplied by engine power.
As I criticised before, this can be misleading because a small purse seiner (or trawler in other fisheries) with an autonomy of 10 days may have much more engine power than a large Longliner that stays out for months, as they are active gears whereas a longliner or a P&L are passive gears.
There would need to be some major assumptions to account for transhipment (e.g., all catch transhipped in every event?), and it’s not clear to me how they even determine whether the port entry is for landing rather than crew change, repair, emergency, etc.
In simple terms, their metric seems very vague as a way to measure actual landings.
They use their data to make some rather obvious and basically logical findings, such as:
As the number of PSMA parties has expanded, the distance vessels have to travel to get to a non-PSMA port has increased
As the number of PSMA parties has expanded, more “landings” take place in the ports of PSMA parties
To me, the main finding of interest is that non-PSMA parties are increasingly “landing” more domestically; however, this can also be related to the process of “domestication” of the fleet that many countries are going through. Yet, many countries in the Pacific do not differentiate between foreign and nationally flagged vessels, especially if the nationally flagged vessels have operated outside their EEZ.
Needless to say, and somewhat predictably, there is a discussion about how the PSMA doesn’t cover these domestic landings, and this “loophole” requires more attention.
Another issue I have is that although they mention many different factors influence the use of ports, they interpret the data only in terms of PSMA adoption and implementation, which are inherently non-binary (all or nothing) factors (i.e., a State could adopt but not be implementing well, or a State may not adopt but be implementing anyway).
For example, in 2019, there were nearly 500 vessel entries in Majuro, and for PSM, we do not differentiate between foreign and national vessels. From the PSMA perspective, we were implementing the same rigorous PSM system as we are now, but we had not yet ratified it. Since then, the focus has shifted to the waters of PNG and the Solomon Islands. The various phases of the ENSO cycle also influence the distribution of skipjack tuna in the Western and Central Pacific Ocean – the fish migrate further east during El Niño events and further west during La Niña episodes (I wrote about this here and here).
So, if you look at the data without context, it appears we have fewer entries since signing, but the reasons are unrelated to PSMA. We also have fewer vessels now because one sank and two reflagged to FSM, not due to signing an agreement, and so on.
And I’m sure that a specific explanation like this applies to almost every port, which leads to further problems. For a “scientific” paper, there is no statistical analysis, and some of the so-called trends may simply be annual variation or patterns in AIS data availability.
And this lack of local knowledge or ground truthing seems to continue; they describe three ways that vessels can [legally] avoid PSMA. I find this interesting from an academic perspective. However, under PSMA t is up to the port state to decide whether to separate national vessels from foreign ones; the PSMA does not “oblige” them to exclude national vessels.
So the first method is what I would call “flagging in”, that is, a vessel changes its flag and then begins landing in the ports of the new flag, thereby exempting itself from PSMA. They found this mainly for New Zealand, Russia and Namibia.
While I don’t know the cases of Namibia and Russia, but for New Zealand, as part of the changes in relation to labour abuses in foreign-flagged vessels that fish chartered to NZ companies, New Zealand requires that all vessels fishing in its EEZ be flagged in New Zealand. Hence, NZ labour standards apply on board. So at least 8 big vessels flagged to NZ in the last years… Again, this had nothing to do with PSMA, particularly since NZ was a very early ratifier.
Now these three countries are parties to FSMA, so I don’t understand why they conclude (as described above) that non-Parties are increasingly landing domestically — this seems to be the opposite.
They also found the reverse trend for PNG, Chinese Taipei, and the Marshall Islands
For PNG, there was a mass migration of vessels to the FSM and Nauru a few years ago, as they had more favourable licensing conditions… the same can be said for the RMI ones… and I’m sure that part of the TW strategy is to flag as many vessels in their few diplomatically friendly countries as possible.
Additionally, they mention a confusing category called “closed loops,” which suggests that the fishing vessel, transhipment vessel, and port all share the same flag or country. I find this unclear because PSMA classification depends on the vessel's flag when entering the port, not the flag of the vessel that caught the fish. Therefore, the 'closed loop' concept seems unnecessary. Most of these closed loops are Russian, while China usually lands and accepts fish from various sources.
Finally, they note that overseas territories might be exempt from PSMA; however, this accounts for a very small portion of their data and is mainly linked to Denmark and the US, which are hardly hotspots for IUU activity.
While I acknowledge that they state something like “of course, there are other factors that influence port use,” yet their analysis relies on port use solely in terms of the PSMA.
When I finished reading the paper, it felt like the point was to publish something containing the word PSMA, regardless of whether it is a valid and ground-truthed analysis.
So, yeah… that is my take, which, of course, can be wrong. The paper has 11 authors, mostly academic (most with PhDs) and a couple of NGO staff, while my views are based only on my understanding of the realities of the WCPO, SE Asia and the PALOP countries and my conversations with my friend Shelley (who also has a PhD)
So my apologies in advance if my ignorance causes offence