The objective of Part 2 of the questionnaire, “The Extent and Effects of IUU Fishing in the Area of Competence”, was to seek information that will assist in identifying global trends and activities in relation to IUU fishing. RFBs were requested to comment on: the main types of IUU fishing in their areas of competence; the main perceived causes of IUU fishing; the intensity or gravity of the activities; and the extent or impact of fishing in terms of volumes, percentage of TAC, values or other. Each RFB was invited to provide this information on three main types of IUU fishing, or more or less as appropriate.
Eleven RFBs responded to Part 2,[221] including four with a mandate concerning tuna, four with a multispecies mandate, two with a mandate over salmon or anadromous fish and two that do not have a management mandate. The combined areas of competence of the respondents cover the Antarctic, Atlantic and Pacific Oceans, the Mediterranean Sea and, for the Indian Ocean, the northwest areas covered by an advisory RFB and the area where southern bluefin tuna occurs.
The eleven responding RFBs collectively described twenty-one main types of IUU fishing that occur in their respective areas of competence. Fifteen of these were described in terms of species, including Dissostichus spp., various species of tuna,[222] North Pacific and Atlantic salmon, reef-associated shark, mackerel and oceanic redfish. Nearly half of the fifteen references to species - a total of seven - concerned tuna.
Ten types of IUU fishing were described in terms of gear, with some referring also to species. These included seven references to longlining (five connected with a species of tuna,[223] and one each referring to Dissostichus spp.[224] and reef-associated sharks[225]), two to purse seining (for species of tunas),[226] two to trawling (including one for oceanic redfish);[227] and one to driftnet fishing (for salmon).[228]
Six types of IUU fishing, in addition to those referring to species and/or gear, were described by respondents as shown below. Two of these refer specifically to IUU fishing by Contracting Parties or authorized vessels, and one by non-Members. (One RFB that had described IUU fishing in terms of gear and species, noted above, also referred to IUU fishing by vessels of members and non-members, including flags of convenience.[229]) Two respondents referred to fishing in closed areas, and one to unlicensed fishing.
authorized fishing vessels which catch species not allowed by the terms of their permits;[230]
unreported catches of Atlantic salmon by Contracting Parties;[231]
fishing for salmon in international waters by Non-contracting parties;[232]
fishing for salmon in the St. Pierre and Miquelon fisheries zone;[233]
unlicensed fishing;[234]
fishing in closed areas and closed seasons.[235]
The types of fishing described underline the global nature of the problem. For tuna RFBs, which constitute the greatest number of species-related RFBs, the collective responses indicate that IUU fishing for tuna is carried out for all species of tuna and in all oceans,[236] primarily by longlining but also by purse seining. The fact that the tuna organizations constitute nearly half of the number total RFBs that have adopted resolutions, recommendations and other decisions in the recent past to address IUU fishing shown in Appendix 2, reflects not only the high proportion of RFBs with a tuna mandate, but also the global concern over the IUU activity in respect of tuna. However, other species are also at risk as described below in terms of the intensity and impact of IUU fishing.
Respondents were requested to state the intensity and gravity of IUU fishing in terms of numbers of vessels, trends or other factors. Information was also requested on the extent and impact of IUU fishing in terms of volumes, total allowable catch (TAC) percentage, values or other factors. Because these areas are related, they are reported and assessed together below.
In general, the respondents were unable to provide specific information on the intensity/gravity or extent/impact of IUU fishing. Of the twenty-one IUU fisheries identified, estimated vessel numbers were reported for only five, with other responses indicating that the intensity of fishing is unknown, or is at a low/medium background level. Three RFBs estimated the intensity in terms of volumes caught, and one RFB pointed to the difficulty of evaluating the intensity of IUU fishing.
Estimates of the extent or impact of IUU fishing - in terms of volumes, TAC percentage, values or other - were similarly difficult for RFBs to supply. This information was given in terms of estimated tons of catch for only seven of the twenty-one fisheries, with respondents indicating for ten of the fisheries that it is very difficult to evaluate, or no information was available. Other estimates were made in terms of low or moderate impact.
Notwithstanding the difficulties in estimating the intensity and extent of IUU fishing for many of the fisheries identified, the responses provide estimates for some species that are of clear concern to the relevant RFBs. The greatest intensity and extent of IUU fishing on a regional basis was reported for the species Dissostichus spp. and bigeye tuna fisheries, as described below. Although the vessel numbers are reported to be decreasing or low at present for bluefin, relevant RFBs are cautious, noting a wide range of potential threats and the fact that this does not prove a declining trend.[237] A moderate to steady background level was reported for yellowfin tuna.[238] Estimates were also provided for some other species of fish, as described below, but in most cases estimates were not made because of lack of information as indicated by the respondent RFBs.
Dissostichus spp.
CCAMLR reports that there is an extensive IUU longline fishery, expanding in area, for Dissostichus spp. About 30 IUU vessels are sighted and reported annually and the location of IUU fishing has progressed from the Atlantic Ocean into the Indian Ocean and later the Pacific Ocean sectors of the Convention Area. Estimates of IUU catches continue to be in an order of magnitude comparable with the legal reported catches.
Tuna
For tuna species, relatively intense activity in respect of bigeye tuna, and moderate to low activity in respect of other species were reported as shown below. In most cases, the impact - if known - was assessed as moderate or with no proof of a declining trend, including for yellowfin, bluefin and skipjack. In one case the political impact of IUU fishing was reported as severe, since it affects the willingness of other States to agree to management measures.
IATTC: 166 large-scale longline vessels targeting bigeye, whose flag State is not reporting to IATTC, have been identified, and the impact is probably moderate. Measures for regulating longline fishing do not take effect until 2004, and it is unclear how these flags will comply with them. Eight purse seine vessels have been identified fishing tropical tunas as a result of non-compliance with management measures in 2002 by Bolivia and Columbia. The conservation impact is moderate, with about 5,000 tons of yellowfin, bigeye and skipjack taken contrary to conservation measures. However, the political impact affecting the willingness of other States to agree to management measures is severe.
ICCAT: Estimates of the number of IUU vessels longlining for bigeye and bluefin tunas are lower now than 2-4 years ago, but this is no proof of a declining trend. For bigeye tuna, unreported catches were estimated to be as high as 25,000 t in 1998-99 (almost one-third of the total longline catch). Current estimates are one order of magnitude lower.
CCSBT: For southern bluefin tuna, vessel numbers and impact are believed to be low at present. However, there is a wide range of potential threats.
FFA: There is a medium, steady background level of IUU longlining for bigeye and yellowfin tuna, and a low, steady background level for IUU longlining for southern albacore and purse seining for yellowfin and skipjack, but no information is available on the extent and impact of any of these fisheries.
Salmon
IUU fishing for salmon reported by NASCO (Atlantic salmon) and NPAFC (Pacific salmon) is generally low or eliminated, except for unreported catches of Atlantic salmon by NASCO Contracting Parties. The estimate of the 2002 unreported catch was 838 - 1158 tonnes, almost half the reported catch of 2621 tonnes. NASCO reports that progress is being made in minimizing unreported catches. The other salmon fisheries identified by these two RFBs are as follows.
NASCO: Fishing for salmon in international waters by non-Members has been problematic, but is reported as eliminated. The peak catch was estimated to be 180-350 tonnes in 1990. No sightings have taken place since 1994 following diplomatic actions by NASCO and its Contracting Parties. In the period 1989-1994 approximately six vessels were thought to be involved.
NASCO: Fishing for salmon in the St. Pierre and Miquelon fisheries zone (a subsistence and recreational fishery for salmon originating in the waters of the US and Canada) is estimated at about two tonnes. However, it is not consistent with the scientific advice provided by ICES. NASCO and its Contracting Parties have expressed concern to France (in respect of St. Pierre and Miquelon) about harvest levels and is seeking to cooperate with St. Pierre and Miquelon on a sampling programme for the fishery.
NPAFC: No estimates are given for either the intensity or extent of the illegal large scale driftnet salmon fishery.[239]
Reef-associated sharks
IUU longline fishing for reef-associated sharks in the Western Central Pacific is reported by FFA to be rapidly increasing from a low background level. However, no information is available on the extent or impact of the activity.
Oceanic redfish, mackerel in the Northeast Atlantic
NEAFC reports that twelve IUU vessels were involved in pelagic trawling for oceanic redfish. The total TAC is 120,000 tonnes, and the estimated IUU catch is 15,000 tonnes. Two IUU vessels were reported to be fishing for mackerel, but the extent is not known.
Shrimp, lobster
RECOFI reports unlicensed fishing for lobster in Oman, estimated to be six times greater than reported catches. In Iran, the shrimp fishery is problematic. It is believed that IUU fishing takes the form of non-compliance with closed seasons and illegal exports to other RECOFI States.
Some RFBs with multispecies mandates referred to other types of IUU fishing, but information was not known about the intensity or extent of such fishing or, in the case of fishing in closed areas, was not relevant. They are:
CTMFM: Fishing in closed areas, illegal fishing gear, authorized fishing vessels that catch species not allowed by the terms of the fishing permits;
GFCM: Trawling.
These responses illustrate some forms that IUU fishing takes, in addition to the species-targeted examples noted in the previous section.
The responses indicate that trends in concerns about the intensity and extent of IUU fishing do not relate to regions as much as they concern IUU fishing for relatively high-value species, including Dissostichus spp. all species of tuna (with most frequent reference to bigeye, bluefin, and yellowfin) and Atlantic salmon. This could be partly a reflection of the species-related mandates of many of the responding RFBs, but the existence of those RFBs can be seen as a reflection of the need for such species to be managed on a regional basis.
There did not appear to be any discernable trends in relation to the RFBs with a multispecies mandate. Irrespective of region, their responses indicated concern about various forms of IUU fishing, such as use of specified gear.
RFBs were unable to estimate the extent or impact of IUU fishing activities in terms of volumes or TAC percentages for over half of the types of IUU fishing that were identified. However, the reference by one RFB regarding the severity of the political impact (as it affects the willingness of other States to agree to the management measures) introduced an important consideration into the responses.
In general, responses underlined the difficulty of quantifying the intensity and extent of IUU fishing activities. This result suggests that there may be scope for some RFBs to strengthen mechanisms for identifying and estimating the extent or impact of IUU fishing. Such activities could build on current trends and initiatives: for example, seven RFBs have adopted presumptions as to when IUU fishing is taking place;[240] and RFB activity is generally high or increasing in implementing various aspects of the IPOA-IUU relating to MCS.[241]
RFBs were asked to describe the main perceived causes of IUU fishing, and responses were given for nineteen of the IUU fisheries identified.[242] The causes most often indicated were no effective flag State control (thirteen fisheries) and profit (nine fisheries), and it is likely that these causes could also be applicable to many other fisheries. These two perceived causes were cited by all the respondent tuna organizations, which collectively represent the greatest intensity and extent of IUU fishing that was reported. The two perceived causes were also cited indirectly in respect of Dissostichus spp. where IUU fishing was reported to be carried out by vessels of Members and non-Members, including flags of convenience.[243] Three other RFBs also pointed to one or both of these factors.[244] Two RFBs referred to open vessel registries as a main perceived cause of IUU fishing.[245] This is distinguishable from the lack of effective flag State control for two principal reasons: some open registries exercise flag State control over fishing vessels; and vessels reflag in some open registries to avoid being bound by the rules of an RFMO to which their flag State may belong. A third RFB referred specifically to the problem of reflagging.[246]
Profit or economic motivation appeared to be the underlying cause of some IUU fishing practices reported such as such as suppression of information thought to be unfavourable, or local sale or consumption.
Other concerns were expressed as follows:
Displacement from other fisheries;[247]
Ineffective implementation of coastal State fisheries management plans;[248]
Limited resources for effective control by flag State or coastal State;[249]
For unreported catches of Atlantic salmon by Contracting Parties:[250]
- absence of a requirement for catch statistics to be collected;
- suppression of information thought to be unfavourable;
- local sale or consumption;
- inaccuracy in making returns;
For pelagic trawling of oceanic redfish and for mackerel:[251]
- provisional licences;
- inadequate legal framework.
In summary, the predominant perceived cause of IUU fishing by respondents was lack of effective control by flag States by both members and non-members of RFBs, and through the operation of relevant open registries. However, as one RFB noted, this could be due in part to limited resources of the flag State. An inadequate legal framework could also be relevant to ineffective flag State control in many cases, especially where flag States have not adopted laws such as providing catch statistics or fishing beyond areas of national jurisdiction. Effective control would also include adequate MCS to address inaccurate returns.
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[221] CCAMLR, CCSBT, CTMFM,
FFA, GFCM, IATTC, ICCAT, NASCO, NEAFC, NPAFC AND RECOFI. [222] Southern bluefin, yellowfin, bigeye, southern albacore, skipjack. [223] CCSBT - southern bluefin tuna; FFA - yellowfin and bigeye, southern albacore; IATTC - bigeye; ICCAT - bigeye and bluefin. [224] CCAMLR. [225] FFA. [226] FFA - purse seine for skipjack and yellowfin tuna; IATTC - purse seine for tropical tunas, non-compliance with measures in 2002 by Bolivia and Columbia. [227] GFCM; NEAFC - for oceanic redfish. [228] NPAFC - illegal large scale driftnet salmon fishery in the Convention Area. [229] CCAMLR. [230] CTMFM. [231] NASCO. [232] NASCO. This is a subsistence fishery and recreational fishery in St. Pierre and Miquelon for salmon originating in rivers in the US and Canada. [233] NASCO. [234] RECOFI. [235] RECOFI. [236] This includes input from four of the five major RFBs, covering relevant areas of the Atlantic, Pacific and Indian Ocean in which the species occur. However, there was no input from the IOTC, which has addressed IUU fishing in its area of competence in recent years (see Appendix 2). [237] CCSBT, ICCAT. See text below. [238] FFA, IATTC. See text below. [239] However, the NPAFC website (www.npafc.org), to which NPAFC referred, reports that between 1993-2002, the cooperative enforcement efforts of the NPAFC Parties resulted in the detection of 39 vessels conducting directed driftnet fishing operations for salmon in the Convention Area. Of those vessels, 14 were apprehended. However, there have been no apprehensions since 2000. The website also notes that despite the decline in illegal fishing operations within the Convention Area in recent years, the threat of illegal high seas fishing activities contrary to the provisions of the Convention continues, requiring the international community to remain vigilant in improving monitoring and enforcement efforts in the North Pacific. [240] CCAMLR, CCSBT, IATTC, ICCAT, IOTC, NAFO, NEAFC. See Appendix 2: while many of these are relatively recent resolutions, some were adopted prior to the adoption of the IPOA-IUU. [241] As indicated in responses to Part 1 of the questionnaire. [242] The two fisheries where no response was given were identified as national fisheries by RECOFI. [243] By CCAMLR. [244] CTMFM cited profit in respect of authorized vessels which catch species not allowed by the terms of their fishing permits. GFCM pointed to no effective control by flag State for IUU trawling. NPAFC named both for the illegal large scale driftnet salmon fishery in the Convention Area. [245] CCSBT. Longlining for southern bluefin tuna; ICCAT - longlining for bigeye and bluefin tunas. [246] NASCO. Fishing for salmon in international waters by non-Members. [247] CCSBT. Longlining for southern bluefin tuna. [248] FFA. Longlining for yellowfin and bigeye tuna, longline for reef-associated sharks. [249] CTMFM. Fishing in closed areas, illegal fishing gear. [250] NASCO. [251] NEAFC. |
