A report on iUU fishing of Baltic Sea cod - Fisheries Secretariat

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which it has undermined their ability to providescientific advice.Also, the fact that national experts and advisorsare not willing to go public, because they mightloose their jobs, confirms the highly politicalnature of Baltic Sea fisheries management and,more specifically, IUU fishing.There is a danger that continuing to attempt toaccount for mis<strong>report</strong>ing will contribute to a declinein the quality of the data and, therefore, inthe quality of the resulting stock assessment. Inaddition, accounting for mis<strong>report</strong>ing in the assessmentcould also create incentives for furthermis<strong>report</strong>ing, as a higher estimated catch is likelyto lead to a higher estimate of stock size and thusincreased catching opportunities in the future.The Working Group has provided estimates ofunallocated quota since 1993. The continuedneed to do so and the apparent stability in itsestimates over the last 5 years suggests that BalticStates are unable, unwilling or not seriouslycommitted to effectively reducing the IUU fishingproblem.Worldwide Fund for Nature (WWF) <strong>report</strong>The WWF European Policy Office commissioneda <strong>report</strong> on IUU fishing in the Polish Baltic Seacod fishery in 2005. WWF chose not to publishthe <strong>report</strong> but allowed access to it for the purposeof this project. Poland was chosen as thefocus owing to common and consistent allegations,made by people within or associated withthe Baltic Sea cod fishing industry, of non-complianceby the Polish cod fleet.Having spoken with the authors, the <strong>report</strong> providedthem with a significant challenge, primarilydue to difficulties in gathering credible andsubstantiated evidence. Despite this, the <strong>report</strong>highlights two pieces of work, one of which isreferenced, which provide additional insight intothe potential IUU problem.The Marine Institute in Gydnia, Poland, producesa quarterly publication called “WiadomosciRybackie” (Fisheries News) which is aimedat the fishing industry and those with an interestin the fishing industry. In the March-April 2005edition 4 , an article compares import and exportfigures for cod and cod products with <strong>report</strong>edlanding and national consumption figures. Theresults show a discrepancy in export figuresequivalent to 49,000 tonnes of whole cod.The inference is that this discrepancy was causedby un<strong>report</strong>ed landings which, if it were true,would be over 3 times the <strong>report</strong>ed national annuallandings. Table 3 below shows the figuresthat appear in the article. The WWF <strong>report</strong> attemptedto analyse import and export data butfound that detailed information on whole cod orcod products was difficult to obtain. The <strong>report</strong>recommends that further information needs tobe gathered before a definite conclusion can bedrawn.The un-referenced work that was mentionedrefers to a study carried out by the Swedish fishingindustry in 2002. Using non-scientific comparisonbetween like-for-like fishing vessels andinformation on working practices provided byPolish crew working aboard Swedish and Danishfishing vessels, the study speculates that in 2003all the Baltic States and Russia could potentiallyhave exceeded their combined quota by as muchas 4 times, and that Poland could have exceededit by as much as 8 times. This would suggest anunbelievable and unrealistic figure in excess of350,000 tonnes.Table 3. Showing the <strong>report</strong>ed import, export, landing and nationalconsumption figures of cod for Poland in 2003Reported Figures for 2003Reported landings of codImported quantities of codPolish national consumption of codExported quantities of processed cod(Estimated live weight equivalent)DifferenceComment and analysis5,100 tonnes8,000 tonnes18,000 tonnes23,000 tonnes65,000 tonnes49,000 tonnesThe <strong>report</strong> provides a wide-ranging estimateof the levels of un<strong>report</strong>ed cod landings, whichserves to show the difficulties in accurately estimatingthe scale of the problem. The analysis ofofficial statistics is considered to be a good wayof highlighting discrepancies; indeed, this is usedto inform some of the ICES estimates. However,uncertainty as to which sources of informationare likely to be the most appropriate and calculating“whole cod equivalent” from the variety ofcod products (e.g., frozen filets, steaks, etc.) aretwo significant problems with this approach.– 12 –
For the purpose of this <strong>report</strong>, an analysis of thelatest trade statistics 5 and attempts to comparelanding and national consumption were undertakenfor all the Baltic Member States. The attemptonly proved to confirm the difficulties thatthe authors of the WWF <strong>report</strong> experienced andit was decided that this was a study in its ownright.Rather than concluding a likely figure and furthercontributing to the uncertainty of how muchcod is being caught and landed, a safer conclusionfrom the WWF <strong>report</strong> is that the Polish codfishery appears to be a significant contributor tothe overall IUU fishing problem in the Baltic Sea.Institute for Fisheries Management (IFM) studyIn 2003, two researchers – Jesper Raaker Nielsonand Christoph Mathiesen – from the Institute forFisheries Management and Coastal CommunityDevelopment (IFM) published a research paper 6 :“Important Factors Influencing Rule Compliancein Fisheries – Lessons from Danish Fisheries”.Their research focused on three Danish fisheries,one of which included the Baltic Sea cod fishery.They undertook a quantitative and qualitativesurvey asking fishers opinions and views on theiracceptance of imposed fisheries regulations andtheir respect for the management system. Ofthose questioned in the Baltic fishery:• 98% said that the profit from the allocatedquota has a major or medium impact on theircompliance behaviour, i.e., when profits fromlegitimate fishing are good the incentive forIUU fishing is reduced. However, there was anadded caveat that some fishers (2–5%) wouldcontinue to fish after catching their quota ifthe probability of detection was low;• 90% said that the risk of detection comparedto the economic gain from IUU fishing hasmajor or medium impact on their compliancebehaviour, giving a strong indication thateconomic incentive is the driving force behindnon-compliance in the Danish fishery;• 88% considered it morally wrong to discarddead fish even if they had exceeded theirquota;• 85% said it was morally wrong to violateminimum landing sizes;• 20% said it was wrong to land more thantheir allocated quota;• 77% completely or partially agreed with closedareas to protect fish from overfishing;• 57% completely or partially agreed thatdays-at-sea regulation is a better measure toregulate the fishery than closed areas; and• 90% said that practical difficulties to complywith regulations have a major or mediumimpact on their compliance behaviour.The <strong>report</strong> concludes that, in Danish fisheries,the following factors have a major impact oncompliance:• the economic gains to be obtained;• the risks of being detected and the severity ofthe sanction;• compatibility between the content of the regulationand fishing patterns/practices;• “norms” 7 , in particular, the behaviour ofother fishers and the moral of the individualfisher; and• co-management is important for rule compliance.Comment and analysisUnfortunately, this paper was not found andreviewed until the very late stages of the studyand so it was not possible to discuss the work indetail with the authors.While this research did not aim to describe orquantify the IUU problem within the Baltic codfishery, it did attempt to look at factors thatinfluence the behaviour of fishermen and highlightsome important attitudes and behaviouralreaction to rules and regulations.Only 56 fishers were interviewed in the courseof the study and there is no indication as to howmany of these represented fishers from the BalticSea cod fishery. With nine nationalities and theirdifferent economic, social and cultural differences,a similar study across the Baltic could providesome interesting comparisons and potentiallyinformative results that may contribute to betteror more informed management approaches anddecisions.“Gazeta Wyborcza” – Polish newspaperIn the May 4 th 2006 edition 8 of the Polish newspaper“Gazeta Wyborcza”, an article appearedunder the headline “Big Cod Fraud”. Representativesfrom the Polish Fishermen’s Association and– 13 –
Page 1 and 2: A report on IUUfis
Page 3 and 4: A report on IUUfis
Page 5 and 6: Part II 21Policy and regulatory fra
Page 7: Executive summaryThe cod fisheries
Page 10 and 11: Part IDescribing and quantifying IU
Page 14 and 15: the Association of Fish Processors
Page 16 and 17: or close to fishing communities was
Page 18 and 19: Fishing in closed areasEU fisheries
Page 20 and 21: the fishing industry and, therefore
Page 22 and 23: very active on the issue and, at th
Page 24 and 25: that were adopted within the IBSFC
Page 26 and 27: Table 5. An analysis of the 11 Poin
Page 28 and 29: Action Point and its Aim6. Working
Page 30 and 31: failings in the process (see page 3
Page 32 and 33: of cod and hake. The Commission wil
Page 34 and 35: adopted in the North Sea, the Balti
Page 36 and 37: Table 6 Showing the indicators used
Page 38 and 39: Policy areas Policy theme Indicator
Page 40 and 41: Table 7. The list of types of behav
Page 42 and 43: of this Regulation is to streamline
Page 44 and 45: appeared to bear out that significa
Page 46 and 47: General headings/Sub-headingsDetail
Page 48 and 49: Notes1ICES. 2005. Report of the Bal
Page 50 and 51: ReferencesAnderson, J.L., 2002. Rea
Page 52 and 53: DENMARKThe Baltic is the third most
Page 54 and 55: highest allowable level of dioxin i
Page 56 and 57: duction are Iceland, Norway, Japan
Page 58 and 59: The processing sectorAt the beginni
Page 60 and 61: Annex IIMembers of the Administrati
Page 62 and 63:
Annex IVSummary of the European Com
Page 64 and 65:
Department of Fisheries and Game (k
Page 66 and 67:
InspectionsThe Fisheries Control De
Page 68 and 69:
this was to exceed the maximum, the
Page 70 and 71:
Theme/ PolicyareaInspection andcont
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A report on iUU fishing of Baltic Sea cod - Fisheries Secretariat

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