October 17, 2017 — Seafood News — The Head of NOAA Fisheries, Chris Oliver, has called for a major paper on IUU fishing published in Marine Policy to be retracted in its entirety due to egregious factual errors and misreporting as regards US fisheries.
The paper, Estimates of Illegal and Unreported Seafood Imports to Japan, was funded by the Walton Family Foundation (WFF).The lead author, Ganapathiraju Pramod conceived the design, conducted the study, analyzed information and drafted the paper. He has made a career out of constructing a model of trade in illegal fisheries, and has previously published a paper claiming up to 32% of US Fisheries Imports are from IUU fish.
He used the same basic methodology in both papers. First, he develops estimates for trade flows, including fish processed in 3rd countries. Then he searches for all possible indications of IUU fishing from news accounts, literature citations, government and fisheries association reports, consultants reports, NGO reports, Oral or Written interviews, and finally, peer reviewed academic papers.
He takes the mishmash of sources and assigns a weight to IUU fishing in each major sourcing area.
In the Marine Policy paper, he concluded that 24% to 36% by weight of seafood imported into Japan in 2015 came from IUU fishing.
The reasons NOAA called for the complete retraction of the paper can be seen in his estimates of IUU catches of Alaska Pollock, Crab, and Salmon.
He estimates that out of the 122,280 tons of US Alaska pollock products exported to Japan in 2015, from 15% to 22% (26,901 tons) came from IUU fisheries.
To put this in perspective, his estimate would mean about 20% of surimi destined for Japan is produced from IUU fish. Since US surimi is produced by vessels with 100% onboard observer coverage, or in plants that are meticulously inspected and required to pay tax on all fish landed in Alaska, it seems that the authors are living in some alternate universe where their own perspective replaces hard facts.
So how does the paper get from the fact that the US Alaska pollock fishery is one of the cleanest, most transparent, industrialized, and most highly regulated fisheries in the world, to a claim that 20% of their exports are illegal fish.
He does so through the murky process of conflating all his sources where ever 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.
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.”
On Salmon, Oliver says “The authors’ suggestion that sockeye and coho salmon taken as bycatch in trawl fisheries makes its way to Japan as IUU product is a particularly egregious example of inadequate research and flawed conclusions. Easily accessible and publically available reports indicate that Chinook salmon in Alaska and along the West Coast of the U.S. and chum salmon in Alaska are the predominant species taken incidentally in trawl fisheries. Bycatch of sockeye and coho across all trawl (and for that matter, most other gear types) is de minimis, and occurs primarily in the highly-monitored pollock fishery.”
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.
It is quite likely that the authors have confused US 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.
The authors make a similar mistake with US crab fisheries, 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.
In short, this paper has sullied the reputation of all associated with it, because it is such an egregious example of constructing a fantasy world and then justifying it with a numeric model.
There has been a problem of IUU fish imports to Japan, especially in the crab and tuna fisheries.
if the authors had looked at the real world instead of just models, they would have seen that since the Russia-Japanese agreement on documentation for crab vessels, illegal live crab landings in Japan have dwindled to nearly zero. In fact, plants closed, the supply chain shifted, and the market felt a huge impact in the collapse of IUU crab fishing to Japan. But none of this makes it into the paper.
The problem here is that papers such as this one are based on fantasy but they become the basis for NGO claims about generalized IUU fishing, and they take away resources, attention and commitments from actions that actually address some of the problems. These include the Port State Measures agreement, universal vessel registration in the tuna fisheries, US, Japanese, and EU import traceability requirements, all of which have served to dramatically reduce the marketability of IUU fish products.
NOAA is right to demand Marine Policy retract this paper and submit it to additional peer review, if it is ever to be published again.
The Walton Family Foundation also needs to think about its own reputation. Although they do fund many important fishery projects, allowing a paper as misguided as this to result from their funding actually undermines their efforts to promote sustainable seafood, because it sows doubts about their competence and understanding of fisheries issues.
This story originally appeared on Seafoodnews.com, a subscription site. It is reprinted with permission.