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RE: Comments on the Recommendations of the Presidential Task Force on Combating Illegal, Unreported and Unregulated Fishing and Seafood Fraud January 19, 2015 Mark Axelrod, Associate Professor Department of Fisheries and Wildlife & James Madison College Mark Gibson, PhD Researcher in Conservation Criminology School of Criminal Justice Meredith Gore, Associate Professor Department of Fisheries and Wildlife & School of Criminal Justice John Spink, Director and Assistant Professor Food Fraud Initiative We commend the Presidential Task Force for its release of a comprehensive set of recommendations that, if appropriately implemented, will effectively combat illegal, unreported and unregulated (IUU) fishing and seafood fraud. Pursuant to the Task Force’s request for comments on how to implement these recommendations, we provide the following advice for the implementation of recommendations #6, 11, and 12. Recommendation #6: Direct the Secretaries of Commerce, Defense, Homeland Security, State, the Administrator of USAID, and the Attorney General to coordinate with donors, multilateral institutions and foreign governments and prioritize building capacity to sustainably manage fisheries, combat IUU fishing and seafood fraud. 1. Overview
The central challenges to building state capacity to combat IUU fishing in the developing world are three-‐fold: increase the total resources available for management activities, lower the costs of enforcement, and increase the overall effectiveness of compliance programs. A subsidiary challenge is supporting compliance reforms, particularly when those reforms may pose adverse consequences to law-‐abiding small-‐scale fishers that lack political representation. We therefore advise the Task Force to coordinate with donors, multilateral institutions and foreign governments to jointly invest in the promotion, advocacy, and implementation of cost recovery mechanisms; fishery compliance surveys; risk-‐based assessment methods; intelligence-‐led policing tools; UAV surveillance technologies; compliance programs that incorporate
voluntary compliance measures; professional training for law enforcement and court personnel; and temporary fisher assistance programs. This advice is further detailed below.
2. Cost recovery mechanisms
It is widely recognized that developing countries have fewer resources to enforce their fishery management rules. By one estimate, public investments by developing countries in monitoring and control represent just 0.7% of the total landed values of fishery resources, but 8.6% for developed countries.i Given the limited public funds available to developing country fisheries managers, it is likely that cost recovery mechanisms, which include fees for services, fishery taxes proportional to quota allocations, and landings royalties, will need to be implemented in at least some fisheries to increase overall fishery management capacity. Though such cost recovery mechanisms are used to a limited extent in the United States, they are central to funding the management of many fisheries in both New Zealand and Australia, as well as other natural resource management regimes in the United States, such as those in place for the timber and petroleum industries. For instance, the Australian Fisheries Management Authority (AFMA), which manages fisheries that lie beyond the coastal waters under state jurisdiction, annually recovers approximately $14 million, from its budget of around $42 million, via taxes on the fishing industry.ii Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should promote the use of cost recovery mechanisms for fisheries through the development of a guide that provides best-‐practice strategies for the implementation of cost recovery mechanisms for fisheries management. Such a guide could be modeled on the Catch Share Design Manual published by the Environmental Defense Fundiii and include case studies of both developed and developing world fisheries that incorporate such mechanisms, as well as an overview on the lessons learned from implementing cost recovery mechanisms in other natural resource regimes, such as timber concessions, in the developing world. Additional content could also assist authorities in identifying cost-‐recovery opportunities that do not significantly impact coastal livelihoods and food security.
3. Fishery compliance surveys
By one estimate, over 80 percent of marine catches come from “data poor” fisheries, meaning that they lack a formal stock assessment and therefore a sound scientific basis for setting management targets.iv Similarly, it is likely that the vast majority of the world’s landings also
come from fisheries that lack meaningful information on the state of fisher compliance with management rules. The weakness of official law enforcement statistics is widely acknowledged and can be attributed to the widespread lack of resources for fisheries management, high cost of traditional compliance surveillance methods, and ease with which fishers can evade detection by many surveillance methods.v For instance, the average cost per at-‐sea boarding by the U.S. Coast Guard in the Northeast Groundfish Fishery is an estimated $61,700 to $97,100, a cost that many countries would find prohibitive, and it is believed that such at-‐sea patrols have resulted in an overly optimistic official compliance rate.vi GPS tracking through automatic identification systems (AIS) and vessel monitoring systems (VMS) are also unreliable due to the ease with which the systems may be deactivated during illegal fishing operations.vii In fisheries where observer programs, electronic monitoring systems (EMS), or comprehensive landings inspections programs are impractical or cost-‐prohibitive – a group likely constituting the majority of the world’s fisheries – a meaningful alternative would be to employ surveys to evaluate the state of compliance with fishery management rules. Contrary to initial skepticism in the field of criminology, half a century of research efforts have revealed that surveys are a valuable tool for the monitoring of a variety of criminal behaviors in that they reliably provide valid “self-‐report” data at a relatively low-‐cost.viii Surveys have been used to meaningfully evaluate such activities as the illegal killing of terrestrial wildlifeix, tax evasionx, intimate partner violencexi, juvenile delinquencyxii, and illegal drug usexiii. Research scientists have also recently begun to use surveys to evaluate noncompliance with both fishery and marine protected area (MPA) management measures.xiv Furthermore, since 2009, Australia has deployed compliance risk perception surveys among fishery stakeholders as a central component of its biennial compliance risk assessment for Commonwealth fisheries.xv Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should develop and implement pilot projects to demonstrate to the governments of developing countries that fishery compliance surveys can effectively fill key knowledge gaps with regards to the nature and occurrence of noncompliance with management rules at a relatively low cost, and in turn, support the development of targeted fishery compliance interventions. Such pilot projects could be modeled on, if not incorporated into, fishery improvement projects (FIPs), which are now widely deployed around the world to assist fisheries in meeting the standards of leading ecolabel certification organizations.xvi For
instance, the Honduran Spiny Lobster FIP – a joint initiative of the Honduran government and WWF-‐US – has identified noncompliance as a key challenge to the management of the Honduran Spiny Lobster fishery and has prioritized a comprehensive compliance assessment.xvii If a relatively small amount of funding were made available, it is likely that this or other FIPs could quickly integrate and demonstrate the benefits of periodic fishery compliance surveys.
4. Risk-‐based compliance assessment Risk-‐based compliance assessment is quickly emerging as a best-‐practice approach to the design of fisheries enforcement interventions. The Australian Fisheries Management Authority perhaps best demonstrates the approach. Since 2009, AFMA has employed a risk-‐based methodology to assess compliance in Australia’s Commonwealth fisheries. The results of the most recent independent audit of the national compliance program for fisheries indicates that such an approach has been highly effective in identifying and developing effective, targeted responses to key compliance threats.xviii
Figure 1: AFMA’s risk assessment process AFMA’s methodology entails the identification and classification of compliance risks for Commonwealth fisheries according to their likelihood and consequence, and it occurs in two stages (see figure 1). First, AFMA conducts an internal assessment of the “inherent” risks, or the likelihood and consequences of compliance risks in the absence of current enforcement efforts. Second, AFMA, industry, and other stakeholders jointly assess the “residual risk”, or the likelihood and
consequence of identifiable risks given current enforcement efforts, to produce a risk rating that is then modified in the event there exists a clear history of risk occurrence. Through this, AFMA is able to prioritize the most pressing risks to fisheries management. As a result of risk-‐based compliance assessment, AFMA has been able to clearly justify targeted investments to address a number of key risks to Commonwealth fisheries. The two risks that were prioritized by the most recent assessment in 2013 were the failure to have a Vessel Monitoring System (VMS) operating at all times (risk rating: moderate/high) and quota evasion (risk rating: moderate/high). These risks now being addressed by special compliance risk management teams (CRMTs). In the past, the CRMT approach has succeeded addressing other prioritized risks, including lowering logbook reporting noncompliance from 5.5% to just 1.4% of required submissions, reducing suspected illegal fishing in closed areas by 94%, and developing various intelligence-‐led policing tools (see below).xix Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should promote risk-‐based compliance assessment through the development of informational materials on the approach and by investing in demonstration projects for developing countries that show interest in the approach and a need to better understand how to approach the problem of illegal fishing in their waters. Furthermore, the United States could demonstrate the utility of the approach by adopting it for the identification of major compliance risks for federally managed fisheries.
5. Intelligence-‐led policing tools In many developing countries, the efficiency and effectiveness of fisheries enforcement programs are limited due to time-‐intensive data analysis and entry. This situation could be greatly improved upon through targeted investments in data analysis and collection tools. In particular, analytical tools are now readily available to facilitate the targeting of vessels and processors at a higher risk of offending. In the management of Commonwealth fisheries, AFMA has developed a Multiple Risk Aggregation Index (MRAI) to better target vessel inspections, and has implemented business intelligence software that audits logbooks and receiver reports to detect quota evasion. The MRAI incorporates a variety of risk criteria, but most importantly relies upon a cash flow estimate for each Commonwealth fishing vessel, assuming that vessels with lower estimated net cash flows are at a higher risk of breaking the rules to turn a profit.xx The business intelligence software, meanwhile, was developed in response to the most recent national compliance risk assessment and now permits enforcement officers to
audit catch reports and processor receiver reports at the “push of a button”.xxi Meanwhile, terrestrial wildlife management offers numerous tools to improve data collection in fisheries enforcement. For instance, the Management Information System (MIST), a tool that provides a structured, computerized form for recording patrol information, has been successfully deployed among patrol officers in tiger reserves to streamline data collection and facilitate reporting and analysis.xxii A more sophisticated tool for terrestrial wildlife management surveillance, the spatial monitoring and reporting tool (SMART), has since been developed and is now promoted and made freely available by a broad coalition of NGOs, including WWF and the Wildlife Conservation Society.xxiii With little additional investment, this tool could be modified for use in fisheries and MPA management.
Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should leverage existing intelligence-‐led policing tools to improve fisheries enforcement by investing in projects to adapt analytical and data collection tools for developing country fisheries and their enforcement contexts, where appropriate. This could be further facilitated through the development of a knowledge document that draws together case studies of existing tools and the lessons learned from Australian fisheries management and the SMART conservation initiative.
6. UAV surveillance technologies As discussed above, it is likely that the vast majority of the world’s fishery landings come from fisheries that lack meaningful information on fisher compliance with management rules. To overcome some of these problems, a concerted effort should be made to deploy unmanned aerial vehicles (UAVs) for fishery surveillance. Many newer models of UAVs can be deployed in coastal fisheries at a fraction of the cost of at-‐sea patrols, airplanes, and helicopters. Furthermore, due to their small-‐size and lack of noticeable noise, it is likely that illegal fishers would be unable to effectively evade detection, such as by disposing of illegal catches and gears or leaving a prohibited area before being identified. UAVs could also be used to construct estimates of fishing vessels and effort in poorly regulated fisheries, such as coastal small-‐scale fisheries, and evaluate how fishing effort is deployed across both time and geography for improved dockside and at-‐sea patrol targeting. Recently, pilot projects using UAVs for fisheries surveillance and marine resource monitoring have been initiated in Belize, Australia, and Palau, among other countries.xxiv In spite of the promise of UAV technologies
for compliance monitoring in fisheries and other resource management regimes, their deployment remains limited due to a lack of knowledge and training among enforcement agencies as well as associated policies that support the use of UAV imagery for prosecution. Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should develop and implement pilot projects to demonstrate the opportunity presented by UAVs for fisheries surveillance and enforcement and assist in the development of supportive laws and enforcement policies. Additionally, the U.S. government and its partners should develop a guidebook and set of case studies for countries seeking to implement UAV surveillance programs.
7. Voluntary compliance measures
In most countries, the standard approach to achieving a high rate of fisher compliance is to deter rule violations through investments in enforcement activities, including at-‐sea patrols, dockside monitoring, and observer programs (see figure 2). This is built upon the assumption that fishery offenses are a function of the likelihood and penalties of detection, and the perceived costs and benefits of an offense. However, modern criminology recognizes that many people often comply with laws not because they fear the risks of getting caught, but because they believe it is the right thing to do.xxv This normative theory of compliance suggests that the costs of obtaining a particular level of compliance through enforcement activities could be reduced through complementary investments in activities that increase voluntary compliance.
Figure 2: Hypothetical depiction of the deterrence functionxxvi
With respect to figure 2, normative theory would predict that the red and black curves shift downward as voluntary compliance increases. Given the decreasing marginal returns to enforcement investments, it is likely that an optimal level of compliance would be achieved most cost-‐effectively through a combination of both enforcement and voluntary compliance measures. The experience of the Australian Fisheries Management Authority (AFMA), an organization utilizing a compliance strategy that incorporates both voluntary compliance and rational deterrence, suggests that voluntary compliance measures will relate to:
• Education (e.g., informing fishers as to the nature and content of the rules with presentations, educational materials, and timely communications);
• Transparency (e.g., communicating with fishers regularly on the management authorities actions via newsletters and other media);
• Participation (e.g., ensuring that fishers have some opportunity to provide input to the management process);
• Recognition (e.g., publically identifying fishers for both good and bad behaviors); and
• Responsiveness (e.g., periodically surveying fisher satisfaction with management and responding accordingly).xxvii
Meanwhile, fisheries research literature indicates that fishers are far more willing to comply when they believe the rules were created through a legitimate process.xxviii Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should advocate for the widespread adoption of voluntary compliance measures by developing and implementing voluntary compliance improvement projects in developing world fisheries, carefully monitoring project outcomes with fishery compliance surveys, and disseminating the results through the development of a best-‐practice guide.
8. Training for law enforcement and court personnel
Perhaps due to the limited funding for marine law enforcement in developing countries, many enforcement agencies lack the basic training necessary to effectively deter noncompliance and encourage voluntary compliance. This includes training in boarding procedures, on-‐scene assessment and violations recognition, officer safety, command presence, interview techniques, exercising interpretive justice, evidence handling, report writing, case package preparation, communicating
fisheries rules and regulations, and developing public message documents to share on agency activities. Similarly, many courts in the developing world demonstrate a lack of concern with the prosecution of illegal fishers, or the application of penalties that might deter future noncompliance, even when such penalties are permitted by law. Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should collaborate in the creation of a standard training program and manual for fisheries enforcement officers, an assessment of training needs among fisheries management agencies in low-‐capacity countries, and the implementation of targeted training workshops for both law enforcement officers and court prosecutors and judges. Furthermore, in countries where illegal fishing is found to be a serious problem deserving specialized attention, the U.S. government and interested partners should advocate and assist in the funding of legislative reforms and temporary special courts and prosecutors to effectively deter noncompliance in fisheries.
9. Temporary fisher assistance programs
In some cases, the imposition of anti-‐IUU fishing policies in developing countries will create an excessive burden for law-‐abiding fishers, particularly for small-‐scale fishers who tend to lack political representation and the resources to meet new legal requirements. In other cases, the sudden enforcement of existing regulations could significantly impact subsistence fishers. Because of licensing fees and a lack of enforcement, many subsistence fishers around the world operate in violation of vessel registration and fishing license requirements, even though their fishing does not contribute substantially to fisheries depletion. An excellent example of the unintended consequences of IUU policies comes from Indonesia, where President Joko Widodo has decided to take action against the estimated 5,000 foreign fishing boats operating illegally in Indonesian waters, which costs the local fishing industry an estimated US$24bn.xxix In order to protect the local fishing industry from these losses, the government has since instituted a six month moratorium on issuing new fishing licenses and banned at-‐sea transshipments of catches. Yet as noted by Andrew Harvey, a sustainable fisheries adviser for USAID, these policies threaten to significantly impact small-‐scale fishers who require a renewal of their licenses, or whose business model is dependent on at-‐sea transshipments. Rational noncompliance theory would also suggest that at least some of these impacted fishers will now resort to illegal fishing by engaging in unlicensed fishing and/or illegal at-‐sea transshipment, meaning that the new IUU policies will be somewhat counter-‐productive. Indeed, research
indicates that resource users, including fishers, are often willing to accept the risk of punishment when they perceive that they have no livelihood alternative.xxx In sum, this example suggests that when there is a risk of detrimental impacts to small-‐scale fishers, new anti-‐IUU fishing policies should be implemented along with temporary fisher assistance programs. Advice: U.S. government agencies, donors, multilateral institutions, and foreign governments should make available special funds to assist fishers in adapting to new anti-‐IUU fishing laws in the event that they can demonstrate a clear impact to their fishing operations, or in the development of alternative livelihoods in the event that adaptation is not possible. Assistance should also be considered for subsistence fishers in the event that they will be subject to new enforcement activities.
Recommendation #11: Direct the Secretaries of Agriculture, Commerce, Health and Human Services, and Homeland Security, and the Attorney General to work with state and local enforcement authorities to expand information sharing and develop tools that address illegal fishing and seafood fraud at the state and local level. 10. The challenges to addressing illegal fishing at the state and local level
are the same as those challenges facing developing countries. State and local governments must obtain additional resources, lower the costs of enforcement, and increase the overall effectiveness of compliance programs. Given this, some of the advice provided for implementation of Recommendation #6, specifically sections 2 through 7, should also be considered for implementation of Recommendation #11.
Recommendation #12: Work with Congress to the extent necessary to broaden agency enforcement authorities, including those to (1) search, inspect and seize seafood, both at the point of entry into U.S. commerce (whether from foreign or domestic sources) and throughout the supply chain; and (2) pursue a full range of judicial enforcement options for trafficking and other violations related to IUU fishing and seafood fraud. 11. More pragmatic evidentiary standards and increased governmental
responsiveness for the Moratorium Protection Act
The Moratorium Protection Act requires NOAA Fisheries to produce a biennial report to Congress that identifies countries whose vessels are engaged in IUU fishing. If NOAA Fisheries determines after a two-‐year consultation period that a country has not taken necessary measures to address the issues for which it was identified, the country can be
negatively certified in the following report. A negative certification may result in import restrictions on fish products from the certified country. A number of countries have been identified in these reports to Congress since they first began in 2009 (see figure 3).
2009 2011 2013 France Colombia Colombia Italy Ecuador Ecuador Libya Italy Ghana Panama Panama Italy China Portugal Korea Tunisia Venezuela Mexico
Panama Spain Tanzania Venezuela
Figure 3: Countries listed by NOAA in past reports
Surprisingly, Italy and Panama have been listed for all three reports, and three countries (Ecuador, Colombia, and Venezuela) were listed for the last two reports, but not a single country has yet received a negative certification under the U.S. anti-‐IUU policy. In stark contrast, the EU’s seafood trade sanction system – which has only been in place since 2012 – has identified numerous countries as supportive of IUU fishing and has resulted in trade sanctions being applied to Belize, Cambodia, Guinea, and Sri Lanka for their lack of responsiveness. This disparity in identification and follow-‐through sanctions is at least partly due to the fact that the U.S. employs a violation-‐by-‐violation approach, while the EU looks for patterns of behavior. This means that countries with habitual IUU enforcement failures can obtain “positive certifications” (and thus avoid sanctions) so long as it resolves the individual cases cited in NOAA’s report. It also means a country with just a few unresolved violations but otherwise relatively good anti-‐IUU practices may be identified alongside countries with much weaker laws or a very poor record of enforcement. Furthermore, the biennial reporting period likely limits NOAA from appropriately addressing countries with IUU supportive behavior in a timely manner. Advice: the U.S. government should work with Congress to alter relevant legislation such that the evidentiary standard for negatively certifying countries is the “demonstration of a clear pattern of behavior supportive of IUU fishing” and that negative certifications may be submitted to Congress on an “as needed” basis.
i U.R. Sumaila, A.S. Kahn, A.J. Dyck, R. Watson, G. Munro, P. Tyedmers, and D. Pauly. 2010. A bottom-‐up reestimation of global fisheries subsidies. Journal of Bioeconomics 12: 201-‐225. ii Australian National Audit Office. 2013. Administration of the Domestic Fishing Compliance Program. Commonwealth of Australia. Available at: http://www.anao.gov.au/~/media/Files/Audit Reports/2012 2013/Audit Report 20/Audit Report No 20.pdf; For additional information, see AFMA. 2010. AFMA Cost Recovery Impact Statement. Available at: http://www.afma.gov.au/wp-‐content/uploads/2010/06/AFMA-‐Cost-‐Recovery-‐Impact-‐Statement-‐20101.pdf. iii EDF. 2010. Catch Share Design Manual. Available at: http://catchshares.edf.org/sites/catchshares.edf.org/files/CSDM_Vol1_A_Guide_for_Managers_and_Fishermen.pdf. iv Christopher Costello, Daniel Ovando, Ray Hilborn, Steven D. Gaines, Olivier Deschenes & Sarah E. Lester. 2012. Status and Solutions for the World’s Unassessed Fisheries. Science 338(6106): 517-‐520. v For example, see discussion on estimating illegal fishing in the Combatting IUU Fishing LinkedIn Group, available at: https://www.linkedin.com/groups/Is-‐there-‐Global-‐Illegal-‐Fishing-‐4153219.S.5936140479652450305. vi Dennis King, Read D. Porter, & Elizabeth W. Price. 2009. Reassessing the Value of U.S. Coast Guard At-‐Sea Fishery Enforcement. Ocean Development and International Law 40:350-‐372. vii For example, see industry report: Windward. 2014. AIS Data on the High Seas: An Analysis of the Magnitude and Implications of Growing Data Manipulation at Sea. Available at: http://windward.eu/press/AIS_Executive_Summary-‐Windward.pdf. viii John V. Pepper & Carol V. Petrie (eds). 2004. Measurement Problems in Criminal Justice Research: Workshop Summary. National Research Council. The National Academies Press. Available at: http://www.nap.edu/catalog/10581/measurement-‐problems-‐in-‐criminal-‐justice-‐research-‐workshop-‐summary. ix P. Cross, F.A.V. St. John, S. Kahn, & A. Petroczi. 2013. Innovative Techniques for Estimating Illegal Activities in a Human-‐Wildlife-‐Management Conflict. PLOS ONE DOI: 10.1371/journal.pone.0053681; F.A.V. St. John, A.M. Keane, G. Edwards-‐Jones, L. Jones, R.W. Yarnell & J.P.G. Jones. 2011. Identifying Indicators of Illegal Behavior: Carnivore Killing in Human-‐Managed Landscapes. The Proceedings of the Royal Society B. doi:10.1098/rspb.2011.1228; F.A.V. St. John, C.H. Mai & K.J.C. Pei. 2014. Evaluating deterrents of illegal behaviour in conservation: Carnivore killing in rural Taiwan. Biological Conservation doi:10.1016/j.biocon.2014.08.019; V.L. Wright. 1980. Use of Randomized Response Technique to Estimate Deer Poaching. Wildlife Society Bulletin 8(4). x M. Korndorfer, I. Krumpal & S.C. Schmukle. 2014. Measuring and explaining tax evasion: Improving self-‐reports using the crosswise model. Journal of Economic Psychology 45: 18-‐32. xi C. Garcia-‐Moreno, H.A.F.M. Jansen, M. Ellsberg, L. Heise & C.H. Watts. 2006. Prevalence of intimate partner violence: findings from the WHO mutli-‐country study on women’s health and domestic violence. The Lancet 368(9543): 1260-‐1269. xii T.P. Thornberry & M.D. Krohn. 2000. The Self-‐Report Method for Measuring Delinquency and Crime. In : Duffee, D. (ed), Measurement and Analysis of Crime and Justice: Criminal Justice 2000, vol. 4, US Department of Justice, Office of Justice Programs, Washington, DC, 2000, pp. 33 – 83. Available at: https://www.ncjrs.gov/criminal_justice2000/vol_4/04b.pdf.
xiii L. Harrison. 1997. The validity of self-‐reported drug use in survey research: an overview and critique of research methods. NIDA Research Monograph 167: 17-‐36. xiv For example: A. Arias & S.G. Sutton. 2013. Understanding Recreational Fishers’ Compliance with No-‐take Zones in the Great Barrier Reef Marine Park. Ecology and Society 18(4): 18; Brock J. Bergseth, Garry R. Russ & Joshua E. Cinner. 2013. Measuring and monitoring compliance in no-‐take marine reserves. Fish and Fisheries DOI: 10.1111/faf.12051; Sarah G. Blank & Michael C. Gavin. 2009. The randomized response technique as a tool for estimating non-‐compliance rates in fisheries: a case study of illegal red abalone (Haliotis rufescens) fishing in Northern California. Environmental Conservation 36(2): 112-‐119; F.A.V. St. John, G. Edwards-‐Jones, J.M. Gibbons, J.M., Jones, J.P.G., 2010. Testing novel methods for assessing rule breaking in conservation. Biological Conservation 143, 1025-‐1030. xv AFMA. 2013. National Compliance 2013-‐15 Risk Assessment Methodology. Australian Government. Available at: http://www.afma.gov.au/wp-‐content/uploads/2010/06/2013-‐15-‐RA-‐Methodology-‐accessible-‐version.pdf. xvi For additional information: Sustainable Fisheries Partnership. 2014. The Seafood Industry Guide to FIPs. Available at: http://cmsdevelopment.sustainablefish.org.s3.amazonaws.com/2014/04/28/SFP FIPS Guide 2014-‐1722c02f.pdf. xvii Information on the Honduran Spiny Lobster FIP and other FIPs supported by WWF at is available at: https://sites.google.com/site/fisheryimprovementprojects/home. xviii Audit Office. 2013. Administration of the Domestic Fishing Compliance Program. Commonwealth of Australia. Available at: http://www.anao.gov.au/~/media/Files/Audit Reports/2012 2013/Audit Report 20/Audit Report No 20.pdf xix AFMA. “The Domestic Compliance Program.” Accessed 1/3/2015. Available at: http://www.afma.gov.au/managing-‐our-‐fisheries/compliance-‐activities/the-‐domestic-‐compliance-‐program/. xx Australian National Audit Office. 2013. Administration of the Domestic Fishing Compliance Program. Commonwealth of Australia. Available at: http://www.anao.gov.au/~/media/Files/Audit Reports/2012 2013/Audit Report 20/Audit Report No 20.pdf. xxi AFMA. 2014. National Compliance and Enforcement Program 2014-‐2015. Available at: http://www.afma.gov.au/wp-‐content/uploads/2012/10/PUBLIC-‐National-‐Compliance-‐and-‐Enforcement-‐Program-‐2014-‐15-‐final.pdf; Anon. 2014. “New software to detect fraud.” World Fishing and Aquaculture. Available at: http://www.worldfishing.net/news101/industry-‐news/new-‐software-‐to-‐detect-‐fraud. xxii E.J. Stokes. 2010. Improving effectiveness of protection efforts in tiger source sites: Developing a framework for law Enforcement monitoring using MIST. Integrative Zoology 5(4), 363-‐377. xxiii Additional information may be found at smartconservationtools.org. xxiv Brian Clark Howard. 2014. “Can drones fight illegal ‘pirate’ fishing.” National Geographic. Available at: http://news.nationalgeographic.com/news/2014/07/140718-‐drones-‐illegal-‐fishing-‐pirate-‐belize-‐ocean/; Luke Hopewell. 2011. “UAVs to patrol Queensland waters.” ZDNet. Available at: http://www.zdnet.com/article/uavs-‐to-‐patrol-‐queensland-‐waters/; Sean Dorney. 2013. “Palau ends drone patrol tests to deter illegal fishing.” ABC News. Available at: http://www.abc.net.au/news/2013-‐10-‐04/an-‐palau-‐drone-‐patrol-‐tests-‐to-‐deter-‐illegal-‐fishing-‐ends/4999344.
xxv See for example: Tom R. Tyler. 1990. Why Do People Obey the Law? Yale: New Haven. xxvi T.J. Green & J.P. McKinlay. 2009. Compliance Program Evaluation and Optimisation in Commercial and Recreational Western Australian Fisheries Final FRDC Report – Project Number 2001/069. Fisheries Research Report No. 195, 2009. Government of Western Australia, Department of Fisheries. Available at: http://www.fish.wa.gov.au/Documents/research_reports/frr195.pdf. xxvii These elements are derived from the information provided by the following documents: AFMA. National Compliance and Enforcement Program 2014-‐2015, Available at: http://www.afma.gov.au/wp-‐content/uploads/2012/10/PUBLIC-‐National-‐Compliance-‐and-‐Enforcement-‐Program-‐2014-‐15-‐final.pdf; AFMA. National Compliance and Enforcement Policy 2014. Available at: http://www.afma.gov.au/wp-‐content/uploads/2010/06/National-‐Compliance-‐and-‐Enforcement-‐Policy-‐2013.pdf; Australian National Audit Office. 2013. Administration of the Domestic Fishing Compliance Program. Commonwealth of Australia. Available at: http://www.anao.gov.au/~/media/Files/Audit Reports/2012 2013/Audit Report 20/Audit Report No 20.pdf. xxviii J.R. Nielsen & C. Mathiesen. 2003. Important factors influencing rule compliance in fisheries: Lessons from Denmark. Marine Policy 27: 409-‐416; J.M. Novak & M. Axelrod. (in review). Multi-‐level Fisheries Governance and Its Impact on Fishers’ Adaptation Strategies in Tamil Nadu, India. Revised and resubmitted to Environmental Policy & Governance; S. Gezelius & M. Hauck. 2011. Toward a Theory of Compliance in State-‐Regulated Livelihoods: A Comparative Study of Compliance Motivations in Developed and Developing World Fisheries. Law & Society Review, 45 (2), 435-‐470. xxix Johnny Langenheim. 2015. “Indonesia’s new marine laws threaten sustainable fisheries.” The Guardian. Available at: http://www.theguardian.com/environment/the-‐coral-‐triangle/2015/jan/14/indonesias-‐new-‐marine-‐laws-‐threaten-‐sustainable-‐fisheries. xxx Katherine Groff & Mark Axelrod. 2013. A Baseline Analysis of Poaching Incentives in Chiquibul National Park, Belize. Conservation and Society 11(3): 277-‐290.
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