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 a friend 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 particular ports are associated with IUU fishing and labour abuse ("bad" ports). Clearly, it all depends on how well the specialists understand what is going on at practically every port.
Based on this, they identify the vessels that frequent the "bad" ports, as well as the fishing grounds they use. However, the designation of "bad ports" is typically based purely on whether or not the PSMA has been ratified.
Along with the essential prudence surrounding AIS data, as someone involved in risk analysis of incoming vessels, I've noticed that in recent years, fishing vessels have turned their AIS off as soon as they leave port. This is because, unless AIS is required by national legislation owing to the vessel type (e.g., carriers), they are hesitant to continue using public AIS databases.
There is also the issue that the poll is typically performed in European languages, and I feel that a few well-publicized incidents can have a considerable impact on respondents, particularly if they do not work in a specialised field.
There also appears to be a tendency for everyone to blame China for all IUU fishing (which may be justified), and experts have identified "flagged to China" as the lone national-identity risk factor.
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 say about the new research is that most of its conclusions seem to come from a computation of "landed fishing effort." I didn't look closely at the methods, but it looks like this is a calculation of the amount of hours between port calls times engine power.
As I said before, this can be deceiving because a small purse seiner (or trawler in other fisheries) with a 10-day range may have far more engine power than a massive longliner that remains out for months. This is because purse seiners and trawlers are active gears, whereas longliners and P&Ls are passive gears.
There would have to be some big assumptions to explain transhipment (such, does all catch get transhipped in every case?), and I'm not sure how they even figure out if the port entrance is for landing or for crew change, repair, emergency, etc.
In short, their metric doesn't seem like a good way to count real landings.
They get to some rather clear and fundamentally logical conclusions based on their evidence, 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 requires more attention. However, under PSMA 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, id doea oblige them to iclude foreing but talk of equivalent measure for domestic ones…
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.
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.
They also talk about a confusing group called "closed loops," which means that the port, the transhipment vessel, and the fishing vessel all have the same flag or country. This isn't clear to me because the PSMA classifies a ship based on its flag when it enters the port, not the flag of the ship that caught the fish. So, the idea of a "closed loop" doesn't seem to be needed. Most of these closed loops are Russian, while China generally lands fish from different places and accepts it.
Lastly, they say that some overseas territories might not have to follow PSMA. But this only affects a small part of their data and is mostly related to Denmark and the US, which aren't exactly IUU hotspots.
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 PSMA, regardless of whether it is has followed 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 (who also has a PhD)
So my apologies in advance if my ignorance causes offence