Illegal, Unregulated & Unreported Fishing:Illegal, Unregulated & Unreported Fishing:Drivers, Consequences for Scientific Advice & Drivers, Consequences for Scientific Advice &

Management of Fisheries, & MitigationManagement of Fisheries, & MitigationPresentation to:

EUROSAI Working Group on Environmental Auditing (WGEA)7-9 October 2008. Kyiv, Ukraine

Chris HopkinsChris Hopkins

AquaMarine AdvisersAquaMarine Advisers

Åstorp, SwedenÅstorp, Swedenchris.hopkins@aquamarine.sechris.hopkins@aquamarine.se

Hans LassenHans Lassen

ICESICES

Copenhagen, DenmarkCopenhagen, Denmarkhans@ices.dkhans@ices.dk

‘‘Unaccounted Fishing Mortality’ is a Unaccounted Fishing Mortality’ is a significant source of error in Stock significant source of error in Stock AssessmentsAssessments

Two sources of particular concernTwo sources of particular concern

- - Illegal, unreported and Illegal, unreported and unregulated fishing (IUU)unregulated fishing (IUU)

- Discarding- Discarding

Unaccounted Fishing Mortality (UFM)– Unaccounted Fishing Mortality (UFM)– ICES Study Group on UFMICES Study Group on UFM

What is IUU?What is IUU? Complex definition: FAO / International Plan of

Action to Prevent, Deter, and Eliminate Illegal, Unreported and Unregulated Fishing (IPOA-IUU)

Essentially is ‘Catches taken within an EEZ which are both illegal (contravene rules & regulations) and retained, and which are usually unreported, and all unreported catches taken in high seas waters subject to a Regional Fisheries Management Organization’s (RFMO) jurisdiction’ (MRAG 2008).

Includes a ‘multitude of sins’.

Where & at what costs?Where & at what costs? A global problem - Occurs in most regions. Not only in EEZs of developing world & high-seas

areas, but also in EEZs of major developed countries.

Total value IUU losses worldwide are ca. 11 – 26 million tonnes, worth USD 9 – 25 billion (Pauly et al. 2002, MRAG 2005, EC 2007, Agnew et al. 2008).

Products from IUU imports into the EU conservatively estimated at EUR 1.1 billion (EC COM/2007/0601).

European Court of Auditors has criticized fisheries control within EU waters & proposed measures to tackle the problem (ECA 2007).

Drivers of IUU fishing mortalityDrivers of IUU fishing mortality Ineffective management (inc. unregulated Ineffective management (inc. unregulated

fisheries).fisheries). Fleet overcapacity & restrictive management Fleet overcapacity & restrictive management

measures (e.g. TACs, effort limitation, gear measures (e.g. TACs, effort limitation, gear types / configuration).types / configuration).

Poor enforcement / controls at sea & on land.Poor enforcement / controls at sea & on land. Tax benefits, subsidies & investment incentives Tax benefits, subsidies & investment incentives

from ‘Flag of Convenience’ States.from ‘Flag of Convenience’ States. Extraordinary economic pressures (e.g. Extraordinary economic pressures (e.g.

increasing fuel costs).increasing fuel costs). De-stigmatized perception of IUU activities by De-stigmatized perception of IUU activities by

society due to under-estimation of society due to under-estimation of environmental & social impacts.environmental & social impacts.

IUU exacerbates current IUU exacerbates current sustainability problemssustainability problems

IUU compounds overfishing risk.IUU compounds overfishing risk.• It adds to ‘decision overfishing’ (i.e. politically It adds to ‘decision overfishing’ (i.e. politically

agreed regulatory overfishing) when agreed regulatory overfishing) when negotiated TACs are set in excess of negotiated TACs are set in excess of sustainable levels of exploitation.sustainable levels of exploitation.

• For exampleFor example: EU fisheries ministers agreed : EU fisheries ministers agreed TACs in 2006 on average 45% higher than the TACs in 2006 on average 45% higher than the catches recommended by ICES scientific catches recommended by ICES scientific advice. Science-based advice has often formed advice. Science-based advice has often formed the basis for ‘talking-up quotas’ (Aps et al. the basis for ‘talking-up quotas’ (Aps et al. 2007).2007).

• Then one adds on IUU amounts / percentages Then one adds on IUU amounts / percentages which may be substantial….which may be substantial….

• This causes ‘This causes ‘double troubledouble trouble’.’.

Problems of IUUProblems of IUU One doesn’t know how much fish is One doesn’t know how much fish is extractedextracted in total (Fishing in total (Fishing

mortality) relative to Quotas.mortality) relative to Quotas. Results in incorrect fish stock assessments: Poor data quality Results in incorrect fish stock assessments: Poor data quality

& model outputs.& model outputs. Erodes accuracy & credibility of the scientific advisory, Erodes accuracy & credibility of the scientific advisory,

management & political decision-making systems. ‘Quotas management & political decision-making systems. ‘Quotas don’t work’ (Alternative - regulate fishing effort: e.g. days at don’t work’ (Alternative - regulate fishing effort: e.g. days at sea, closed areas).sea, closed areas).

Distorts economics, markets, livelihoods, etc. Acts against Distorts economics, markets, livelihoods, etc. Acts against those who ‘follow the rules’.those who ‘follow the rules’.

Try to manage a bank account where the ‘balance’ of credit & Try to manage a bank account where the ‘balance’ of credit & debit is ‘unknown’, due to not knowing who is removing the debit is ‘unknown’, due to not knowing who is removing the ‘debits’ & what ‘interest’ is needed for asset conservation‘debits’ & what ‘interest’ is needed for asset conservation..

STOCK SIZERECRUITMENT

FISHINGMORTALITY

NATURALMORTALITY

ICES ‘precautionary flag’ reference pointsICES ‘precautionary flag’ reference points

Fishing mortality (F) is related to Fishing mortality (F) is related to Fishing EffortFishing Effort. . Excessive F reduces the spawning stock (B).Excessive F reduces the spawning stock (B).

Conserving a substantial spawning stock biomass Conserving a substantial spawning stock biomass (B) is vital for good recruitment. Also a beneficial (B) is vital for good recruitment. Also a beneficial environment secures recruits.environment secures recruits.

Keep below F pa & above B pa! IUU increases risk Keep below F pa & above B pa! IUU increases risk & uncertainty.& uncertainty.

Quality of stock assessmentsQuality of stock assessments

Depend on Depend on • Model (Natural Mortality, Abundance Model (Natural Mortality, Abundance

indices)indices)• DataData (Landings, logbooks, fisheries (Landings, logbooks, fisheries

sampling, Vessel Monitoring Systems, sampling, Vessel Monitoring Systems, abundance indices)abundance indices)

Catch data are problematic for many fish Catch data are problematic for many fish stocks (unreported landings, unaccounted stocks (unreported landings, unaccounted removals)removals)

[Changes in natural mortality and [Changes in natural mortality and distribution]distribution]

[Recruitment difficult to estimate[Recruitment difficult to estimate]]

IUU Incidence ICES Area (IUU Incidence ICES Area (SGUFM 2005SGUFM 2005))All stocks ca. 150 stocks. Critical stocks in All stocks ca. 150 stocks. Critical stocks in

ecosystem ca. 37 stocksecosystem ca. 37 stocks

Mis- or non- reported LandingsMis- or non- reported Landings

When recognizedWhen recognized• Landings are Landings are

corrected or ignored corrected or ignored in assessmentin assessment

• Unbiased advice and Unbiased advice and prognosesprognoses

• Assessment and Assessment and prognoses uncertainprognoses uncertain

• Advice and prognoses Advice and prognoses include non-reporting include non-reporting (exception North East (exception North East Atlantic mackerel)Atlantic mackerel)

When not recognizedWhen not recognized• Biased advice and Biased advice and

prognosisprognosis• Misleading Misleading

information and information and adviceadvice

• Assessment often Assessment often internally inconsistentinternally inconsistent

• Over/Over/underestimation- underestimation- unpredictableunpredictable

• Investigate on a case-Investigate on a case-by-case basisby-case basis

Possible Effects of Possible Effects of unrecognizedunrecognized non-reportednon-reported Catches Catches

Recruitment and SSB most often underestimatedRecruitment and SSB most often underestimated• Method dependentMethod dependent• Misreporting may add fish to a stockMisreporting may add fish to a stock• Status quoStatus quo prognosis: below the actual catches prognosis: below the actual catches

Stock status may be assessed wrongly - Stock status may be assessed wrongly - Depending on type of mis- or non- reportingDepending on type of mis- or non- reporting• Which Period Which Period • Which fleetsWhich fleets• Which size classesWhich size classes• Which areas (misreporting)Which areas (misreporting)• Overall exploitation pressureOverall exploitation pressure• Quality of abundance indices (commercial and research Quality of abundance indices (commercial and research

vessel Catch Per Unit Effort) vessel Catch Per Unit Effort)

Possible effects of Possible effects of unrecognizedunrecognized non-reportednon-reported catches catches

Equally spread over fleetsEqually spread over fleets• F is correctF is correct• Underestimation of stock (Recruitment Underestimation of stock (Recruitment

and SSB)and SSB) Unequally spread over fleetsUnequally spread over fleets

• F incorrectF incorrect• Recruitment and SSB can be either over- Recruitment and SSB can be either over-

or underestimated - mostly or underestimated - mostly underestimatedunderestimated

ICES policy for Stock AssessmentICES policy for Stock Assessment

Where IUU is indicated decide betweenWhere IUU is indicated decide between1.1. Ignore data influenced by IUU fishing (e.g. North Sea Ignore data influenced by IUU fishing (e.g. North Sea

demersal fish) demersal fish) 2.2. Correct for IUU fishing and incorporate in Stock Correct for IUU fishing and incorporate in Stock

assessment (e.g. Eastern Baltic Cod)assessment (e.g. Eastern Baltic Cod)

• Base decision on investigation of how sensitive the Base decision on investigation of how sensitive the stock assessment is to reasonable estimates of IUU stock assessment is to reasonable estimates of IUU fishingfishing

IUU estimates IUU estimates • Available in the Assessment and Advisory ReportAvailable in the Assessment and Advisory Report• In the Stock database available from the ICES website In the Stock database available from the ICES website

Examples of Illegal, Unreported & Examples of Illegal, Unreported & Unregulated Fishing (IUU) – ICES EstimatesUnregulated Fishing (IUU) – ICES Estimates

Eastern Baltic CodEastern Baltic CodTrue catch 35-45% greater than True catch 35-45% greater than reportedreported

NE Arctic CodNE Arctic CodSince 2002: 90 – 115 Kt of catch per Since 2002: 90 – 115 Kt of catch per annum transhipped to Russia (~20% annum transhipped to Russia (~20% total catch)total catch)

Irish Sea CodIrish Sea Cod2005: Catch ~25% over quota.2005: Catch ~25% over quota.RedfishRedfish

True catch underestimated by 25%True catch underestimated by 25%

Northeast Atlantic MackerelNortheast Atlantic Mackerel2003 Scottish fleet: 60% over quota2003 Scottish fleet: 60% over quota1998-2002 Irish fleet: 70% over quota1998-2002 Irish fleet: 70% over quota

North Sea Demersal stocksNorth Sea Demersal stocks““IUU – seriously compromising Stock IUU – seriously compromising Stock Assessments”Assessments”““But no reliable estimates”But no reliable estimates”

Deep water fisheriesDeep water fisheries ““IUU – seriously compromising Stock IUU – seriously compromising Stock

Assessments”Assessments” “ “But no reliable estimates”But no reliable estimates”

Status example: Eastern Baltic CodStatus example: Eastern Baltic Cod

Spawning Stock BiomassSpawning Stock Biomass: well below B: well below Blimlim (160,000 t) (160,000 t) Fishing mortalityFishing mortality: high (~1) and clearly above F: high (~1) and clearly above Fpa pa (0.6)(0.6) Recent recruitmentRecent recruitment: low and relatively constant: low and relatively constant Stock statusStock status: Large changes unlikely in the short-term : Large changes unlikely in the short-term Recovery above BRecovery above Bpapa (240,000 t) (240,000 t)

• Significant reduction in fishing mortality (to about 1/3 of present)Significant reduction in fishing mortality (to about 1/3 of present)• Substantial reduction of landings in the short term relative to recent levelSubstantial reduction of landings in the short term relative to recent level • Recovery cannot be achieved by a TAC in the absence of effective Recovery cannot be achieved by a TAC in the absence of effective

enforcement and controlenforcement and control Recovery to stock levels observed in the 1970s and 1980sRecovery to stock levels observed in the 1970s and 1980s

• Increased productivity dependent on environmental conditionsIncreased productivity dependent on environmental conditions

IUU –Estimation techniquesIUU –Estimation techniques

Estimate & Include in AssessmentsEstimate & Include in AssessmentsWhen Catch Effort Data thought to be biasedWhen Catch Effort Data thought to be biased

Various estimation techniques availableVarious estimation techniques available

Statistical AccountingStatistical Accounting• Compare Trade Estimates & Reported CatchCompare Trade Estimates & Reported Catch• Estimate catch from Discard observer dataEstimate catch from Discard observer data• Raise Research Vessel abundance estimates to catchRaise Research Vessel abundance estimates to catch• Comparing catch rates between countriesComparing catch rates between countries• Comparing Landed Catch Per Unit Effort (LCPUE) of Comparing Landed Catch Per Unit Effort (LCPUE) of

fishing between inspected and non-inspected landingsfishing between inspected and non-inspected landings• Estimate IUU Effort (e.g. from Satellite imagery – VDS)Estimate IUU Effort (e.g. from Satellite imagery – VDS)

Unaccounted Industry/Authority estimatesUnaccounted Industry/Authority estimates Model Based EstimatesModel Based Estimates

IUU Behaviour & Surveillance Encounter ProbabilityIUU Behaviour & Surveillance Encounter Probability

Estimating TechniquesEstimating TechniquesSupply BalanceSupply Balance

Landings = Export – Import + Local ConsumptionLandings = Export – Import + Local Consumption

ProblemsProblems• Trade Statistics are Trade Statistics are

in product units, in product units, e.g. filletse.g. fillets

• ““Local Local Consumption” is Consumption” is estimated from the estimated from the same relation at a same relation at a time with no IUU time with no IUU fishingfishing

ProvidesProvides• Landing estimates Landing estimates

by Countryby Country• Indicates that IUU Indicates that IUU

fishing overall is fishing overall is significantsignificant

• Indicates country Indicates country specific problemspecific problem

Overall, the estimate is lower than provided by ICESOverall, the estimate is lower than provided by ICES

Estimating TechniquesEstimating TechniquesRaise Research Vessel abundance estimates to catchRaise Research Vessel abundance estimates to catch

ProcedureProcedure• Total mortalityTotal mortality from from

comparing abundance comparing abundance indices for the same year-indices for the same year-class in two consecutive class in two consecutive yearsyears

• Subtracting an amount of Subtracting an amount of mortality to account for mortality to account for mortality causes other mortality causes other than fishingthan fishing

• Converting abundance Converting abundance indices to indices to absolute absolute abundanceabundance based on based on years without IUU fishingyears without IUU fishing

• Mean weight per age Mean weight per age groupgroup in the catches in the catches

• Estimate total landingEstimate total landing for for the entire stockthe entire stock

ProblemsProblems• Total mortalityTotal mortality estimated estimated

impreciselyimprecisely• Mortality other than Mortality other than

fishing not knownfishing not known preciselyprecisely

• Data extrapolated Data extrapolated from from years without IUU fishingyears without IUU fishing

Conversion factor Conversion factor from abundance index from abundance index to populationto population

Mean weightMean weight per age per age group in the catchesgroup in the catches

•Eastern Baltic Cod: Estimates Eastern Baltic Cod: Estimates suggest IUU amount may be as suggest IUU amount may be as much as reported landingsmuch as reported landings

Estimating TechniquesEstimating Techniques Estimate catch from discard observer dataEstimate catch from discard observer data

ProblemsProblems• Observer sampling is Observer sampling is

directed at estimating directed at estimating discards – not discards – not representative for IUU representative for IUU fishingfishing

• Vessels with observers Vessels with observers show different fishing show different fishing strategy compared to strategy compared to those without observersthose without observers

Results not availableResults not available

Landing = catch rate (observer sampling) * Total Landing = catch rate (observer sampling) * Total efforteffortCatch rate: Observer programmes. Effort: Satellite, logbooks, etc.

Estimating TechniquesEstimating TechniquesCorrect catch from Inspection dataCorrect catch from Inspection data

ProblemProblem• Inspections directed at Inspections directed at

“problem areas” may “problem areas” may not be a random not be a random sample of the fisheriessample of the fisheries

• Effort on a “per trip” Effort on a “per trip” basisbasis

• Confounded byConfounded by Inspection efficiencyInspection efficiency National policiesNational policies

Mainly useful for identifying Mainly useful for identifying whether IUU fishing occurswhether IUU fishing occurs

ProvidesProvides• Landing estimates by Landing estimates by

CountryCountry• Indicates that IUU Indicates that IUU

fishing overall is fishing overall is significantsignificant

• Indicates country Indicates country specific problemspecific problem

Landing = Landing Landing = Landing (reported)(reported)**Catch rate Catch rate (inspected landings)(inspected landings)/ Catch rate / Catch rate (non-inspected landings)(non-inspected landings)

Overall, the estimate is lower than provided by ICESOverall, the estimate is lower than provided by ICES

Eastern Baltic CodEastern Baltic CodOfficially reported & estimate of non-reported Officially reported & estimate of non-reported

landings (t) 1993-2005landings (t) 1993-2005

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

Unallocated

Official

Eastern Baltic CodEastern Baltic CodComparing SSB estimate with and without Comparing SSB estimate with and without

correction for non-reportingcorrection for non-reporting1990-20041990-2004

0

50,000

100,000

150,000

200,000

250,000

1990 1992 1994 1996 1998 2000 2002 2004 2006

SSB No Correction SSB Corrected

Example Baltic CodExample Baltic CodSummarySummary

Strong Indications of IUU fishingStrong Indications of IUU fishing Estimates vary depending on:Estimates vary depending on:

• Trade statisticsTrade statistics• Abundance surveysAbundance surveys• Inspection samplingInspection sampling• Unaccounted industry estimatesUnaccounted industry estimates

ICES provides for Eastern Baltic Cod an overall ICES provides for Eastern Baltic Cod an overall estimate of about 15,000 tonnes p.a. or more in estimate of about 15,000 tonnes p.a. or more in recent years of landings not reportedrecent years of landings not reported

What must be done to tackle IUUWhat must be done to tackle IUU

There are few technical impediments to obtaining the necessary data.

Policy, legal and institutional arrangements, particularly at the international level, need to be more firmly established & actively implemented, in particular flag State duties & responsibilities.

Implement at national level the duties & responsibilities in the FAO Code of Conduct on Responsible Fisheries, UN Fish Stocks Agreement & FAO Compliance Agreement, EU instruments, etc.

Specific actions to tackle IUUSpecific actions to tackle IUU Adoption of mandatory Adoption of mandatory

systems for Port State systems for Port State control & trans-shipment control & trans-shipment inspections, set-up inspections, set-up common databases in common databases in countries in Regional countries in Regional Fisheries Management Fisheries Management Organizations (RFMOs). Organizations (RFMOs).

Improved control of vessel Improved control of vessel licensing /permits & control licensing /permits & control at sea for compliance. at sea for compliance. Inspection for under-sized Inspection for under-sized fish, by-catch / discards, fish, by-catch / discards, fishing gears, catch on-fishing gears, catch on-deck & in holds, vessel deck & in holds, vessel tracking devices (VMS, tracking devices (VMS, VDS), catch log-book, etc.VDS), catch log-book, etc.

Better control at landings Better control at landings for compliance. Landings for compliance. Landings declaration/sales note.declaration/sales note.

Traceability of fish Traceability of fish standards: harvested from a standards: harvested from a legitimate source /manner, legitimate source /manner, through ‘chain of custody’ through ‘chain of custody’ to consumer.to consumer.

Open, objective & verifiable Open, objective & verifiable certification schemes certification schemes rewarding fishers & fisheries rewarding fishers & fisheries with good standards.with good standards.

Include fisher & Include fisher & environmental organizations environmental organizations with market-representatives with market-representatives in strategies for tackling in strategies for tackling IUU.IUU.

Extended international Extended international cooperation between cooperation between national authorities (e.g. national authorities (e.g. tax, customs, police & tax, customs, police & prosecutors). Link these prosecutors). Link these closely with scientists & closely with scientists & managers. managers. Task Force?Task Force?

Thank you for your attention!Thank you for your attention!