In early October, Chris Oliver, NOAA Assistant Administrator for Fisheries, sent a letter to the Editor-in-Chief at Marine Policy, Dr. Hance Smith, requesting the retraction of a paper titled “Estimates of illegal and unreported seafood imports to Japan” authored by Pramod, Pitcher, and Mantha earlier this year. The paper claims that 15–22% of Alaska pollock, 10–20% of Alaska salmon, 10–18% of Alaska crabs by volume exported from the U.S. and entering Japanese markets are of illegal and unreported origin. These are “fisheries that are among the best managed and closely monitored in the world,” writes Chris Oliver. As proof of the well-managed nature of these fisheries, Mr. Oliver cites extensive management and monitoring procedures including observers, satellite-based monitoring systems, certified catch monitoring and weighing procedures, and electronic reporting.
NOAA’s NMFS “strongly objects to the authors’ claims regarding U.S. seafood exports to Japan and doubts the validity of the methodology used to makes such estimates,” continues Mr. Oliver. Specifically, he calls into question the data sources, the assumptions supporting them, and the methodologies applied, mainly because these information sources are not readily disclosed in the report. The authors arrived at these IUU estimates by first developing estimates for trade flows (including fish processed in third countries), then searching for all possible indications of IUU fishing (sources include news accounts, literature citations, government and fisheries association reports, consultants reports, NGO reports, oral or written interviews, and finally, peer reviewed academic papers), and finally using this mishmash of sources to assign a weight to IUU fishing in each major sourcing area.
An article on seafoodnews.com puts this into perspective using Alaska pollock as an example. The authors of the Marine Policy paper estimate that 15% to 22% (26,901 tons) of U.S. Alaska pollock products exported to Japan in 2015 came from IUU fisheries “through the murky process of conflating all sources wherever any source has mentioned a fisheries problem. So for example, if a source wrote about high grading Alaska pollock, or roe stripping (both activities which would be impossible to hide from the 100% observer coverage), he then applies this to the export numbers and assumes a certain percentage of the charge must be true.” “It seems that the authors are living in some alternate universe where their own perspective replaces hard facts,” writes John Sackton, the author of the seafoodnews.com article.
Writing to Marine Policy, Chris Oliver said “the Bering Sea pollock industry has long-established and contractually binding requirements among all vessels to share all catch data with an independent third-party. Discard of pollock is prohibited. Were it to occur, discard and high-grading of pollock would be detected by the numerous monitoring and enforcements provisions in place, and would result in a significant enforcement action.”
As demonstrated with the pollock example above, there is no empirical evidence of the authors’ general insinuations or quantitative estimate of illegal and unreported catches. Looking to their estimates of salmon bycatch as a second example, the paper claims that between 2200 and 4400 tons of illegal salmon are caught in Alaska and exported to Japan. “The authors likely don’t realize that monitoring of salmon bycatch by trawl fisheries is highly developed in Alaska, with vessels reporting bycatch down to the individual fish. These fish cannot be legally sold,” writes John Sackton. “It is quite likely that the authors have confused U.S. practices where bycatch is highly regulated with those in Russia, where the pollock fleet is allowed to keep whatever salmon they catch, and that salmon is subsequently sold in the commercial market. The Russian system does not require that pollock vessels identify the species of salmon; and it assumes all pollock vessel bycatch of salmon is legal,” he says. Additionally, including unreported subsistence and sport fishing catches in the salmon IUU estimate and unreported catches in artisanal fisheries in the pollock IUU estimate is irrelevant considering these products are not sold into market and thus are not part of either supply chain.
“The authors make a similar mistake with U.S. crab fisheries,” continues Mr. Sackton, “once again assuming that because they have heard people talk about IUU crab in some instance, therefore up to 18% of the US crab exports to Japan represent illegal fishing. As anyone in the crab industry will tell you, this is simply laughable, given the regulatory oversight and close inspection of the Bering Sea snow crab and king crab fisheries. Furthermore, most of the crab exports to Japan are made by very large exporting companies. None of these major companies would allow their business or their markets to be jeopardized by engaging in illegal behavior. The fact that the authors accept their model output without thinking twice about the real-world implications is the key reason they should withdraw their paper,” concludes Mr. Sackton.
Shortly afterwards, Jim Gilmore, Director of Public Affairs at At-sea Processors Association (APA), sent a letter to Pitcher, one of the authors of the paper in question. APA is a trade association representing six U.S. seafood companies that operate U.S.-flag catcher/processor vessels in the Bering Sea Alaska pollock fishery. He highlights the assertions made by the Pramod et al. paper claiming that IUU fishing accounts for 15-22% of Alaska pollock harvests and that as much as 26,901 metric tons of U.S. Alaska pollock products exported to Japan annually are produced illegally, representing the second largest source of IUU seafood in the Japanese market. He calls these assertions “surprising and concerning.”
Mr. Gilmore then outlines current federal fishery management practices in the Bering Sea Alaska pollock fishery (in particular, monitoring and enforcement practices including the annual allocation of a set tonnage per vessel that reflects an established percentage of the Alaska pollock Total Allowable Catch (TAC) as well as the presence of a NOAA Fisheries-trained observer onboard at all times while fishing to monitor and record catches of target and non-target species and video monitoring in the factories) to highlight his surprise. “What deficiencies in the comprehensive NOAA Fisheries North Pacific Groundfish Observer Program and federal fisheries enforcement programs did you uncover in determining that up to 22% of Alaska pollock is illegally harvested?” Mr. Gilmore asks. “How is the federal management system not accounting for nearly 300,000 metric tons of illegal harvests with 100% federal observer coverage on vessels and at processing sites, scales at processing facilities, and video surveillance?”
Mr. Gilmore also references the fact that the Alaska pollock fisheries were among the first dozen fisheries certified as sustainably managed under the Marine Stewardship Council (MSC) program, and that “both the Bering Sea and Gulf of Alaska pollock fisheries have been recertified twice since their original 2005 certification.” Mr. Gilmore points out, rather wryly, that “if the assertions in your paper are verifiable, we need to bring this information to the attention of the assessment team” because, as the fishery client for the Alaska pollock fisheries, APA is required to report to MSC any meaningful change in the management of the fishery. “What information did you and your colleagues uncover about the presence of IUU fishing in the Alaska pollock fishery in the publication of your paper that contradicts the Alaska pollock assessment team’s conclusions that fishery landings are very well monitored and that enforcement is rigorous?” he asks.
Soon after, Pitcher responded to Mr. Gilmore’s inquiries and criticisms. He agreed that the Alaska Pollock fishery is among the best managed fisheries in the world, highlighting that this report “is in no way meant to prejudice that deserved reputation.” Rather, “it highlights the importance of considering the whole supply chain when estimating the extent of IUU seafood imports,” writes Pitcher.
Pitcher makes two points in his response that are worth addressing. He first discusses Mr. Gilmore’s point about this report appearing to call into question the comprehensive U.S. fishery observer and enforcement programs based on their claim that up to 22% of Alaska pollock is illegally harvested. Pitcher claims that products leaving Alaska were assumed to be at risk of being “Unreported discards” rather than falling under the “Illegal” category. However, as Mr. Gilmore stated previously, NOAA Fisheries-trained observers are onboard at all times while fishing to monitor and record catches of target and non-target species, so it is highly unlikely at-sea discards would occur, let alone be reported.
Pitcher then goes on to discuss what happens when the product moves through other countries in Asia-Pacific – namely, that “the product is vulnerable to mixing of legal, illegal and unreported catches sourced from other batches and other countries in the supply streams (either during processing or distribution) before the product enters and is sold in Japan.” This is the second point worth addressing. Pitcher writes that “the risk provided in our study reflects the IUU estimate for the whole supply chain.” While this is indeed important to evaluate, what the authors have essentially done is assign an “overall IUU score” to each fishery supply chain, and in doing so have potentially lumped good actors in with the bad. In other words, they have assigned a blanket score to the entire fishery supply chain rather than pinpointing specific nodes along the supply chain where IUU takes place. Taking a closer look their methods helps to elaborate on this point.
First, the authors collected and analyzed information regarding illegal and unreported (IU) practices for the 27 country/species combinations and their source fisheries. They then determined the proportion of illegal and unreported fish through all the points in the supply chain from the time it was caught in one country as it passes through third countries as well as various reprocessing destinations before it finally enters the Japanese market. They do so using multiple data sources including interviews to estimate quantitative estimates of IU fishing. Next, they identified and pooled a range of IU estimates for each of the 27 products for top 9 countries. Pooling these ranges identifies the entire supply chain as being at fault rather than highlighting specific insertion points for IUU products. Because the authors tracked IUU estimates for the whole supply chain for all the 27 products, they could and should be able to clearly identify where along the chain IUU takes place.
In other words, reporting IUU estimates for each node along the supply chain would demonstrate where and in what capacity IUU infiltrates the fishery. This would not necessarily require naming names so as to protect their confidential government and industry informants – a concern that Pitcher expressed in his response to Mr. Gilmore. “We have to protect our confidential informants and we cannot be completely transparent about our sources,” writes Pitcher. “Obviously these sources are reluctant to talk to us unless we can ensure the confidentiality of the information provided by them.” Rather, the authors could simply highlight nodes along the supply chain (e.g. harvester, primary processor, exporter, secondary processor, distributor) containing different IUU estimates to demonstrate where, how much, and what type of IUU is taking place at each point along the supply chain.
Instead, the authors have labeled the entire supply chain as being at fault as opposed to recognizing that there are good and bad actors in any supply chain, and they must be individually identified and their actions brought to attention accordingly. Using Alaska pollock as an example, it is possible that the highest IUU estimates that contribute to the illegal and unreported 15–22% of Alaska pollock imported into Japanese markets come from the secondary processing in Asia or during the manufacturing of imitation crab meat sold in Japan – where unreported/illegal mixing has been reported within this reprocessed trade. Calling out these points in the supply chain would be useful in understanding the nodes that are problematic and known for IUU, while simultaneously highlighting those points in the supply chain that are compliant. In short, blanket statements should not be used when discussing IUU because it lumps compliant actors in with those who are acting illegally.
The problem here is that papers such as this one are based on theoretical models that ignore reality, resulting in distorting information and disparaging fisheries management systems (such as those in the U.S.) that stand as world-class models for sustainable management and effective enforcement. This undermines collective efforts that actually address some of the problems, including the Port State Measures agreement, universal vessel registration in tuna fisheries, and U.S., Japanese, and EU import traceability requirements, all of which have served to combat IUU fishing and improve stewardship of global fisheries.