EU fight against IUU fishing: more transparency is needed

On this 5 June, the International Day against Illegal, Unreported and Unregulated (IUU) fishing is celebrated by the European Union. While the EU can boast of having an ambitious legislation for fighting against IUU fishing, transparency in the implementation of this legislation needs to be improved.

When the European Commission notifies a third country that it could be considered a non-cooperating country in the fight against IUU fishing, it provides that country with an action plan which it considers should be put in place to avoid a 'red card', - the final notification which entails significant sanctions, such as a ban of EU imports of fishery products from that country. The notification procedure is stopped when the EU considers that the third country has implemented the necessary measures. But on what basis does the EU stop the procedure? Hard to say since these elements remain confidential. Therefore, is it guaranteed that the third country has implemented all the necessary measures to effectively combat IUU fishing? In view of what happened in South Korea early 2019, it’s far from certain.

The case of South Korea
On 26 November 2013, the European Commission notified South Korea that it could potentially be considered a non-cooperating country in the fight against IUU fishing. This decision[1] exhaustively and thoroughly describes Korea's failure to comply with the IUU Regulation, including illegal fishing operations off the coast of Africa.

A year and a half later, on 29 April 2015, the Official Journal publishes a short notice of just one page stating that the European Commission is putting an end to the procedure because "The Republic of Korea has introduced the necessary measures for the cessation of IUU fishing activities in question and the prevention of any future such activities, rectifying any act or omission leading to the notification of the possibility of being identified as non-cooperating countries in fighting IUU fishing." (JO C 142).

But in February 2019, a group of NGOs announced that the Korean government had failed in its obligations to fight IUU fishing: "The South Korean government has failed to sanction two vessels found fishing illegally in Antarctic waters, instead allowing the owner to sell this valuable catch on the global seafood market."[2].

Is this a sign that Korea, contrary to what was announced by the EU in 2015, had not implemented all the necessary measures to combat IUU fishing?

Our request for access to documents

To find out for sure, on 20 February 2019, CFFA asked the Commission to communicate the action plan it had proposed Korea to implement in order to avoid being identified as a non-cooperating third country, as well as the report drawn up by DG Mare on the basis of which the Commission had put an end to the notification procedure regarding Korea.

DG MARE replied on 13 March 2019 that the requested documents contained very sensitive information which is at the heart of bilateral relations with Korea to combat IUU fishing and that the success of the formal dialogue with Korea depended on the confidentiality of their exchanges. As a result, these documents could not be disclosed. As for the report prepared by DG MARE which, in our opinion, had necessarily served as a basis for taking the decision to end the process, DG MARE simply replied that it did not exist!

This answer was not acceptable. Why should the publication of the action plan jeopardize bilateral relations with Korea, except to hide from the public elements that would be inconsistent with the decision to end the procedure vis-à-vis this country? And how to believe that this decision would have been adopted without any evaluation report having been drawn up, showing that the deficiencies had been fully addressed?

Therefore, in accordance with Regulation 1049/2001 on public access to EU institutions documents, we decided to confirm our request for information with the General Secretariat of the European Commission, on 25 March 2019.

The General Secretariat replied on 8 May 2019, sending us the following documents, - de facto acknowledging that the categorical rejection by DG MARE of our first request was unfounded.

1) the letter sent on 26 November 2013 to Korea with the action plan attached to this letter
2) three documents, corresponding, according to the General Secretariat, to our demand for the report which formed the basis for the decision to end the procedure regarding Korea:

(i) the "Note to file" established on 10 March 2015, at the end of a mission carried out by a team of DG MARE in Korea on 24 and 25 February 2015,

(ii) the DG Mare note of 17 March 2015 to the Commissioner responsible for fisheries

(iii) the letter of 21 April 2015 from the Commissioner responsible for fisheries to Korea Minister of Oceans and Fisheries

What do we learn from the documents provided?

Many essential passages of the documents sent are hidden. This prevents us from knowing the details of the reasons which led to the Commission decision to end the procedure regarding Korea.

The letter addressed to the Minister of Oceans and Fisheries of Korea only underlines that Korea has revised its legal framework for fisheries by adopting a law on the development of distant water fisheries, by updating the fisheries management system and by strengthening respect for the port State obligations, but it does not describe the evidence leading to that assessment.

One thing is clear though: the position of the Commission lacks coherence.

Indeed, the letter of 26 November 2013 was explicit: all measures proposed in the plan of action should be implemented, without exception[3]. The notice published in the Official Journal in 2015, announcing the end of the procedure, also indicated that Korea had taken “the necessary measures to stop IUU fishing activities and prevent new ones”, and that it had “rectified any act or omission leading to the notification of the possibility of being identified as non-cooperating countries in fighting IUU fishing”.

But then, why, in the response from the General Secretariat of the Commission that we received on 9 May 2019, is it mentioned that "… the evaluation under Regulation (EC) No 1005/2008 is fully ongoing.”[4]?

Either the action plan has been fully implemented or it has not been. Since the evaluation is still ongoing, this means that the second hypothesis is the most probable.

It suggests that the procedure of notification of Korea as a non-cooperating country in the fight against IUU fishing was stopped although the plan of action proposed by the Commission was not fully implemented, contrary to what was required.

Beyond this, it is very unfortunate that the Commission refuses to provide us with the elements that would have allowed us to develop our own opinion of Korea's real - or not - willingness to fight IUU fishing.

This decision is unfounded in law. Since the decision to take action has been the subject of a reasoned decision published in the Official Journal, the decision to terminate the action must, in all legal logic, be the subject of a similar reasoned decision published in the Official Journal. The simple information note that has been published does not correspond to what was required.

The Commission justifies its attitude by the fact that the disclosure of the information contained in the hidden parts of the documents provided to us would undermine the protection of the public interest as regards international relations[5].

This position of the Commission is surprising.

Indeed, while the decision to initiate the procedure, published in the Official Journal, contains very harsh assessments of Korea, on the other hand, the publication of elements which are supposed to show the progress made by that country to fight IUU fishing would undermine the EU relations with this country? This is rather contradictory.

By not disclosing these elements, the Commission is actually acting as if the real progress made is actually much less significant than what was officially announced.

The case of South Korea shows the need for the European Commission to publish the action plans proposed to third countries that are in the process of being notified as non-cooperating parties, as well as the publication of actions taken by these third States, particular when those actions result in the termination of the procedure.

This is essential to guarantee the efficiency of the EU IUU regulation, and, when the notification procedure concerns illegal distant water fishing activities by third countries, to contribute to the protection of developing countries fishing communities who are often the first victims of these illegal activities.  

[1] Published in EU Official Journal OJ C 346 of 27 November 2013 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32013D1127(02)&from=EN

[2] https://ejfoundation.org/news-media/2019/korean-government-allows-illegally-caught-fish-onto-global-seafood-market-1

[3] It reads: « As a consequence, the Commission invites the Republic of Korea : 1. to take all necessary measures to implement the actions contained in the action plan. … »

[4] Page 7

[5] « The EU main interest is to encourage the Republic of Korea (as well as other third countries) to comply with the relevant international obligations in a smooth and peaceful manner without recourse to more onerous international dispute settlement procedures and without any further interference that might aggravate the dispute.

In this context, an atmosphere of trust and confidentiality is a prerequisite for a successful completion of the dialogue with the country concerned in the perspective of inducing them to comply with their conservation and cooperation obligations. The breach of the trust would jeopardise the relations between the EU and the countries concerned. Disclosure of information included in the internal documents and concerning the assessment of the compliance of third countries with their international obligations would compromise the EU objective of resolving this matter with these countries in a cooperative manner and in a climate of mutual trust and in a long standing perspective.

Disclosure of the information relating to internal national reform processes could also be detrimental to legitimate trade flows between the parties and put at stake the credibility of the Republic of Korea as fish supplier at global level. » (cf. p. 6)

African artisanal fishers and NGOs jointly complain to the EU against Italy turning a blind eye to its trawlers’ illegal activities in West Africa

The Coalition for Fair Fisheries Arrangements (CFFA), the African Confederation of Artisanal Fisheries Professional Organizations (CAOPA), The Regional Partnership for Coastal and Marine Conservation (PRCM), Danish Living Seas and Bloom have jointly lodged a complaint to the EU, asking the European Commission to launch an infringement procedure against Italy. They argue that the Italian fisheries authorities have failed to comply with their obligations, under the Common Fisheries Policy (CFP), to sanction the illegal activities of Italian trawlers in the waters of Sierra Leone. These vessels have been making incursions in the inshore zone reserved for artisanal fisheries, catching species which they were not allowed to catch and transshipping without authorization.

These Italian vessels have a history of illegal operations, documented by Greenpeace, Oceana and CFFA[1]: catching sharks and infringing rules on finning, making illegal incursions in neighboring West African countries waters, fishing with the wrong fishing gear in The Gambia.

Gaoussou Gueye, President of the CAOPA states that ‘when they come to our countries, the EU people are always talking about how important it is to fight illegal fishing. They always argue that EU fleets fish legally and sustainably. Still, some EU vessels are involved in operations that are far from sustainable, some downright illegal, like the activities carried out by these Italian trawlers over many years in West Africa. If the EU wants to have credibility and be trusted by African countries, then it should not accept such behavior by one of its Member States’ fleet. These Italian trawlers have to be monitored and properly sanctioned when they don’t respect the laws of our countries or the Common Fisheries Policy’.

These Italian trawlers, owned by two Sicilian companies, have never been sanctioned by Italy for their unlawful activities. In December 2016, an infringement procedure was opened by the European Commission against Italy related to some of these illegal activities in the Gambia and Guinea Bissau but, to this day, more than two years later, this infringement procedure has not been followed up by the Commission.

At a time when the European Union is championing sustainable fisheries globally and claims to be leading the fight against IUU fishing, it is unacceptable that it lets some EU-flagged vessels conduct IUU activities in the waters of African countries with total impunity. The EU must take action now.

For more information, you can contact

CFFA Secretariat

cffa.cape@gmail.com

[1] Greenpeace, “Four illegal fishing cases found in Sierra Leone in four days”, April 20, 2017: http://www.greenpeace.org/africa/en/Press-Centre-Hub/4-illegal-fishing-cases-found-Sierra-Leone/.

Oceana, “Fishing the Boundaries of Law: How the Exclusivity Clause in EU Fisheries Agreements was Undermined”, Sept. 2017 https://usa.oceana.org/publications/reports/fishing-boundaries-law-how-exclusivity-clause-eu-fisheries-agreements-was.

CFFA, “EU Common Fisheries Policy External Dimension: Improving sustainability through an ambitious revision of the Fishing Authorization Regulation”, Sept. 2016:

“Round sardinella, key for food security in West Africa, is further declining”

by Ad Corten, Coordinator of the Dutch/Mauritanian cooperation in fisheries research

Limited data already show further drop in abundance of round sardinella

Round sardinella is the most important species of small pelagics for the national fleets both in Mauritania and in Senegal. Given the importance of the stock for job creation and food security, and the serious threats to which it is exposed at the moment, it is surprising that the two main fishing nations (Mauritania and Senegal) have so far been negligent in collecting sufficient scientific data for stock assessment. Sampling of artisanal catches in Mauritania has been at a very low level in 2016 and 2017, despite strong recommendations from the FAO Working Group on Small Pelagic Fish in Northwest Africa to improve the situation. For Senegal, little information is available on the actual level of sampling.

Although only limited data on round sardinella are currently available, all these data point to a further decline of the stock. The catches of round sardinella in Mauritania decreased from 292,000 tons in 2016 to 172,000 tons in 2017; a drop of 41%. But these figures may have been affected to some extent by misreporting. As a result of new regulations concerning the maximum quantity of round sardinella that may be used for fishmeal (10,000 t/year/factory), some fishmeal plants have probably reported part of the landings of sardinella as bonga. Indeed, the reported catch of bonga increased by about 40,000 t in 2017, and it is likely that this increase in reality consisted of round sardinella. However, even if we make allowances for this misreporting, the catch of round sardinella in 2017 still dropped by 80,000 tons compared to 2016…

For Senegal, On the other hand, catches of round sardinella seemed to have remained stable in 2017 compared to 2016, around 190,000 tons. However, these figures do not include the catches used for fishmeal, therefore the actual landings of round sardinella in Senegal in 2017 may have been higher than in 2016. It should be noted, however, that according to fishermen’s organisations, round sardinella were very scarce in the waters north of Dakar during the 2017-2018 season. The high catches of round sardinella in 2017 were presumably taken south of Dakar, and must have consisted mainly of young fish.

In Mauritania, the catch per unit of effort (CPUE) in the canoe and coastal purse seine fishery substantially dropped between 2016 and 2017. The CPUE of the Russian-type trawlers in Mauritania also showed a strong drop in 2017. This sharp drop in CPUE is a strong indication that the decline of round sardinella catches in 2017 was due to a drop in fish abundance, and not to a reduction of the fishing effort.

An acoustic survey by the Norwegian R/V Dr Fridtjof Nansen in May-July 2017 in the area from Morocco to Senegal produced the lowest stock estimate for round sardinella in NW Africa since the start of these surveys in 1995. In summary, it may be concluded that all available information points to a substantial drop in abundance of round sardinella in 2017.

The effect of the fishmeal industry

During a meeting with representatives of Senegalese fishermen’s organisations CONIPAS, FENAGIE and APRAPAM in January 2018, all the organisations expressed their concern about decreasing round sardinella catches, particular in the area north of Dakar (the “Grand Côte”). According to these fishers organisations, many fishermen were leaving the industry because of low catches. In fact, the fisheries in Mauritania and Senegal exploit different components of the round sardinella stock. It is known that the Senegalese fishery south of Dakar mainly exploits the younger fish, whereas the fishery in Mauritania and in the northern part of Senegal depends on the adult fish that perform the seasonal migration from Senegal to Mauritania and Morocco. A depletion of the adult stock component will therefore have a stronger impact on catches in Mauritania and northern Senegal than on catches in the south of Senegal.

Data collected in Mauritania over the past 19 years indicate that fishing mortality has been gradually increasing. In the period 1999 – 2013 this was due to the exploitation of sardinella by foreign trawlers in Mauritania, and probably also by a gradual increase in effort by the Senegalese artisanal fleet. After 2012, the place of the foreign trawlers in Mauritania was taken over by the fishmeal industry. The development of this industry in Mauritania has been well documented. More recently, a fishmeal industry also developed in Senegal and Gambia. For these countries, little or no information is available on the amounts of fish used for fishmeal nor on their species composition. Most likely, the bulk of the catches used for fishmeal consisted of sardinella (round and flat). This was echoed by a representative of the Seneglese women engaged in the sardinella smoking industry (“transformatrices”), who explained that their activity was threatened because of the competition from fishmeal factories that bought all the sardinella.

Whereas the effort by artisanal fleets in earlier years was restricted by the demand from the human consumption market, this restriction no longer exists at the moment. The fishmeal plants can absorb large quantities of fish, which stimulates artisanal fishermen to increase their effort. Mauritanian fishmeal plants have even brought in a completely new fleet of efficient Turkish purse seiners to supply them with fish. Senegalese fishermen from Casamance are now landing catches at fishmeal plants in Gambia. Sometimes these landings are so big that even the fishmeal plants cannot absorb them. As a result, considerable quantities of sardinella have to be dumped at sea or on the land.

To conclude, the limited data available show that the stock of round sardinella in NW Africa has been further reduced in the most recent years by an increase of fishing effort. The main cause of this increased effort is the development of a fishmeal industry in the region. This development has increased the outlet possibilities for the artisanal fleets, and even brought in an entire new fleet in Mauritania to catch the fish for the fishmeal factories.

The older age groups in the round sardinella population have been depleted and the fishery now depends largely on the youngest fish. Fleets that exploit the adult part of the population, such as the ones in northern Senegal and in Mauritania, are hardest hit by the absence of older fish. The overexploitation of the stock presents a serious threat for the employment of many thousands of fishermen and women fish smokers  in Senegal, and for the food security of millions of people in West Africa.

The assessment of the stock is seriously hampered by the lack of sampling in Mauritania and by the poor data provided by Senegal to the FAO working group. Considering the social and economic importance of sardinella to Mauritania and Senegal, it is absolutely vital that appropriate investment is made in research on small pelagics, round sardinella in particular, in both countries, and in cooperation between the countries, in order to get the best scientific data possible.

Madagascar agrees to a 10 year fisheries agreement with Chinese consortium

At the beginning of September, Hery Rajaonarimampianina, the president of Madagascar, attended the Beijing Summit of the Forum on China-Africa Cooperation. It was announced during this visit that the two countries had finalised a 10 year investment agreement, entered into between the Malagasy Agency for Economic Development and Promotion of Enterprises, and the Chinese business consortium, Taihe Century Investments Developments Corporation. It is an agreement that has been presented as part of Madagascar’s blue economy initiative.

Published details of the investment agreement remain limited. According to sources in Madagascar, the President had negotiated the deal with almost no input from administration, parliament or civil society, and the country’s main development partners, including the World Bank and the EU were not aware of the deal either. Yet what we know so far suggests the investment agreement could be disastrous for the country, particularly for the artisanal fisheries sector.

A sustainable blue economy?

According to a press release, the 10 year agreement comes with a promise of investment by the Taihe corporation of up to 2.7 billion USD. It is not clear precisely how this money will be used, although it is described that the funds will go towards building fisheries infrastructure, support for fisheries management and the fight against IUU fishing. Part of the investment will also go towards a bamboo forestation project. In return, the Chinese consortium will be allowed to deploy up to 330 vessels in coastal fisheries. The press release makes a bold claim that the agreement will see 10,000 new jobs created.

A representative of the artisanal fishing sector emphasized that "the state is robbing coastal fishermen of their livelihood". Not only he is concerned about the number of boats to come, but he also points out that the 3,600 jobs promised in the short term represent only 3% of the number of artisanal fishermen who live on these fisheries resources and who are already having great difficulty in making ends meet. "Bringing several hundred ships would mean the disappearance of the 100,000 small scale Malagasy fishermen and their families! This will create unemployment, insecurity and increased risk of conflict between communities. Depending on the type of boats that come, there is a fear of fish habitat degradation and overexploitation. Indeed, we only have one or two operational coast guard boats ". He also fears that this agreement will benefit only a handful of people, with corruption jeopardizing the future of entire fishing communities.

The signing of this agreement comes also as the country moves near to the Presidential elections—starting in November. The deal may be a bid to show the country that the President, who is standing for re-election, is bringing in much needed foreign investment—Madagascar remains one of the poorest countries in the world.

Yet news of the agreement has already caused protest among fishing communities. Most fish stocks have been heavily exploited for years, including valuable crustaceans and demersal fishes, not only caught by local small-scale fishers, but also also targeted by foreign owned semi-industrial and industrial trawlers. Indeed, according to a review of fisheries undertaken by Smartfish in 2014, almost all commercial fisheries have been fully exploited, or are being overfished. Conflict between local artisanal fisheries—thought to number over 100,000, and foreign owned trawlers (and commercial prawn farms) has been reported for many years.

Whether Chinese firms will actually bring the full quota of new boats to the country remains uncertain, and no one is sure what type of vessels will be involved and what type of species will be targeted. Nevertheless, a framework agreement that permits 330 vessels represents an enormous addition to the overall fishing capacity in the fisheries sector.

It is also unlikely that the 2.7 billion USD will materialise in full. Similar commitments were made when Mauritania agreed to a 100 million USD investment by Chinese state corporation, Poly Hon Don in 2011. This again was negotiated by the President without consultation, and the investment agreement only became public when it was leaked in the press. While the company has brought its full quota of 100 vessels to Mauritania, evidence that this deal has created new jobs for locals or massive investment for local fisheries is lacking. Indeed, information on the activities of the Chinese company remains closely guarded by the Mauritanian authorities, who have also consented to special rules for the company to export fish without the usual government oversight. It is an example that those protesting the new deal in Madagascar should consider carefully.

Implications for development partners and the EU

For development partners, who have provided Madagascar with millions over the years to improve fisheries management, the announcement must be considered deeply worrying. Similar events have happened in other countries. In addition to Mauritania, a few years ago the President of Mozambique concluded a secret billion dollar investment in the tuna fishing sector, leading to its development partners temporarily suspending aid to the country.

For the EU, the situation in Madagascar is highly sensitive. Development aid and trade deals were suspended in 2009 due to the unconstitutional removal of the democratically elected President by the ruling party. Sanctions were lifted in 2014 and the EU has subsequently committed over 500 million Euros to the country to 2020, as well as funding fisheries development programmes including Smartfish.

At the same time, the European Commission is beginning negotiations for a renewal of its sustainable fisheries partnership agreement with Madagascar. The previous protocol agreement, covering the period of 2014 to 2018, was worth over 6 million Euros, with nearly half of this money being directed to improving fisheries management. Yet the finalisation of a new protocol will have to be based on full transparency by the Malagasy government, including on its existing fisheries agreements with other foreign countries and companies.

It is therefore paramount that the government of Madagascar responds to calls for publishing all details of this new investment agreement, and that there is the opportunity for this agreement to be given full scrutiny by parliament, civil society and development partners, before it is allowed to progress further. Without this commitment, the notion that the country’s leaders support a sustainable ‘blue economy’ must be considered dubious.

The AKWAABA spirit: the key role of women in Ivory Coast artisanal fisheries

Alexandre Rodriguez, Executive Secretary of the EU Long Distance Fishing Fleets Advisory Council (LDAC) shares with us his personal reflexions after a visit to the wompen fish processors in Abidjan.

Abidjan, 28 August 2018

This week, I had the occasion to travel to Cote d´Ivoire invited by one of our partner organisations in Africa, the Ministerial Conference on Fisheries Cooperation among African States Bordering the Atlantic Ocean (ATLAFCO-COMHAFAT). It was a fruitful and intensive 2.5 days where we were able to agree on the plan of action for African Atlantic States for sustainable fisheries in 2019 and 2020.

I spoke to Mr. Gaoussou Gueye, the President of the African Confederation on Artisanal Fisheries (CAOPA) who was also attending the proceedings, on the possibility of meeting our common friend Micheline Dion, responsible of CAOPA Women's Programme, at her workplace to see some “real action in the field”.

I could not be any luckier as the president of CAOPA, apart from being an excellent human being with a big heart, is as well respected professional and widely known for his work amongst West African fishing communities. So it was not very difficult for him to contact Micheline and arrange a short visit to the port to see the work of the  women´s fish processors cooperative she is running.

We took a local taxi and arrived at Locodjro Miami, a quiet suburb 12km off Plateau. We arrived at a little dock surrounded by a beautiful scenery with the tall skyscrapers and the foreign industrial tuna purse seiners moored in the Port of Abidjan, on the other side of the bay.

As soon as we stepped out of the taxi, we were received with a big smile and a warm welcome by Micheline and her fellow women who gave us the classical “bonne arrivée” greeting. I start suddenly feeling this subtle sensation of heartwarming hospitality which is embedded in the Akwaaba spirit, a word that comes from Twi, a language of the Ashanti people of the neighboring nation Ghana, and carries the same meaning in the Ivorian dialect.

Micheline was one of the founders and main architects behind the creation of the Women's Processors Cooperative in Locodjro with the aim to improve revenues and working conditions for the local community living from the processing of fish, particularly tropical tuna but also other species such as langoustine.

Gaoussou and Micheline seemed to know every single person and they both talked cheerfully to any worker with whom we crossed paths, listening carefully to each of their concerns and hopes. Through cleverly posed questions , they adeptly managed to introduce me into the dialogue so I felt part of the community and also could start asking my own questions regarding daily conditions at work.

The activity was quite small when we arrived as most of the pirogues that catch the tunas were out at sea. They all leave early in the morning and come back at sunset. I could see la pirogue du chef, who was moored on that day. I asked how much fish they usually got from the pirogues, and they say that it varies from day to day but ranges from 200 kg up to 1 tonne per day.

Micheline explained that the work is very much dependent on the supply of raw tuna. Overall, she estimated that they work in total about 2-3 months a year overall. In terms of employment, the Cooperative currently employs 902 pêcheurs (fishers), 305 transformatrices (women processors), 173 découpeurs/ses (fish cutters) and 283 chargeurs (loaders), mostly locals from the Abidjan area. In the words of Micheline, “chaque élément de la chaîne de valeur est important et joue un rôle clé du fonctionnement”. This includes also some volunteers which have offered their help for different tasks such as cleaning the premises or doing the basic accounting.

I had been really impressed so far by what I was seeing together with the clarity of thought and explanations from Micheline on how the Cooperative should work. This is why I asked her to draw me a sketch on the value chain so I could understand well the whole economic cycle. She patiently explained me that their work can be summarised in 5 basic steps:

1. Débarquement: The fresh daily catch from pirogues is landed or transported at the designated landing site (PDA in French), at the little embarcadère.

2. Triage: The catch is sorted, separated and labelled on a separate area, and allocated to each of the fishermen and their wives and families for sale at the auction. The women are also present at the market´s auction through a reserved space where they can oversee the whole process.

3. Conservation: The prime fish goes to a frigorific chamber for being sold to restaurants and local markets. The remaining tuna is conserved either in salt and ice and put into tanks made of wood and filled with ice and sealed with salt so it makes a crust and the fish can be conserved outside at least for 2-3 days.

4. Découpage: This is where the fresh tuna is cut normally in three pieces and separated in different buckets, with the head decoupled and given to the women. The tail and the trunk/loin are set in different cubes.

5. Transformation: I was amazed to see the old style ovens made of iron and ignited with charcoal for the poisson fumé.

There are also a number of ancillary services under development such as a medical room (salle de soins), changing rooms, a canteen for workers, a multipurpose training room, a kindergarten and a storeroom.

Micheline explained that they have also accountants recording all income and expenses and doing the bookkeeping work. They also coordinate the provision of all necessary supplies including 25k bags of salt, that the Cooperative is able to purchase at a more competitive price than for individual fishers as they have a concerted power of negotiation.

My personal reflection of this visit is that all the foundations for setting a professional organisation in place are there. However, their activity was hindered by two major factors: the lack of financial resources for both the maintenance of the premises and the improvements required for meeting the health and sanitary standards for conservation and selling of fish; and the shortage in regular fish supply for ensuring jobs and provide economic returns to the activities. This initiative is an example of how added value can be given to fishing activities by creating a collaborative economy that helps to improve living conditions and fix the local population through decent jobs.

To address these shortcomings, some actions could be considered:

• The hiring of teachers and caretakers for the kindergarten would allow women which have to carry all day their babies on their shoulders while working to better perform their tasks while having peace of mind that their kids are well looked after under a safe environment. This initiative would also serve to prepare children to enter  primary school and would also avoid exposing small kids to smokes and chemicals from the fumage de poisson or to infections and diseases related to poor evacuation systems for fish waste.

• Despite having managed to sign an agreement with Spanish private tuna operators from OPAGAC landing a share of their catches for a regular supply when landing or refueling/loading their vessels at Abidjan port, the Cooperative is encountering difficulties and restrictions due to internal problems with local administrations and private agents operating in the fish trade in the port of Abidjan. A system from Ivorian authorities to guarantee that direct supply is available to this women free of charge without administrative or de facto blockages is required with immediate action.

• The techniques and conditions used to preserve the fish are very precarious to say the least, with very old tanks placed outdoors and no doors. The fish is sunk in ice in tanks made of wood or old plastic materials which not fit for the purpose of ensuring the cold chain. The use of improved ovens (FTT) should be generalised.

• There is a lack of a proper sewage and water drainage system in the sheds to evacuate the dirty oil and water discarded when processing fish at the transformation space; The cutting area space has to be done outdoors due to the small space and lack of maintenance and small size of the room that has been kindly funded by the Government of Morocco. Proper investment should be further devoted to improve these infrastructures.

All the above shortcomings could be addressed with political and administrative goodwill as well as support from donors. Adequate resources and ongoing support must be provided by relevant local, national and international organisation using for example existing funds related to sectorial support under SFPAs or projects on development for cooperation by the EU or sponsored by international organisations such as the World Bank or the African Bank for Development.

I would like to end up this article with a quote from Pope Francis wrote in its Encyclical from 2015 Laudato Si, very linked with the UN Sustainable Development Goals and addressed not only to Christian people but to all religions and peoples from the world: An “ethical economy must serve all people without exclusion that endows any person with dignity, opportunity and basic resources”.

The International Fight Against IUU fishing: Moving from criminal to social justice?

To mark the first International day for the fight against IUU fishing, CFFA's brief paper looks critically at the concept of IUU fishing and the policy ideas on how best to fight it. We argue that popular images of IUU fishing are misleading and fail to reflect the nature of the most serious  threats to coastal communities. A key aspect lies with the corrupt relationships between governments, political elites and businesses exploiting marine and coastal resources. Because of this, we argue that relying on 'criminal justice' as a solution is insufficient for coastal communities and small-scale fishers. 

Blue Bond…Saving your fish or bankrupting the oceans?

Read our new report...

To save the oceans and reform unsustainable fisheries, we need the help of private investors - and on a huge scale. This is an idea that many international conservation organisations and investment banks have been promoting for years, including the likes of Credit Suisse, who now hosts an annual conference on ‘conservation finance’ from its New York offices.  

Many reports have been written on the business case for private capital markets to finance ocean conservation and fisheries reforms. The arguments are very simple: governments don’t have the resources to fund conservation, and the traditional sources of extra finance (coming from donors and philanthropists) are completely inadequate. Conservation and fisheries reform should therefore be more open to private investors - who have a great deal of money. Investing in conservation and fisheries reforms is lucrative - sustainable fisheries will increase the wealth potential from the seas, and therefore can give investors a good return on their money.

There are many proposals on how to attract millions of dollars for marine conservation from private investors. One of them is for governments and companies to issue blue bonds. This is in fact a well established strategy - the World Bank and the European Investment Bank started issuing ‘green bonds’ in 2007/8. These raise money from private financial markets which is then ring-fenced for specific green projects and activities. The green bond market has done exceptionally well - last year, governments, multilateral development banks and companies raised 130 billion USD through green bonds - nearly twice as much as they did in 2016. 

This year, the concept of a “blue bond” has finally become reality. The Seychelles has announced its intention to issue the world’s first blue bond, with the help of the World Bank and the UN’s Global Environment Facility. It is likely that the Seychelles blue bond will be quite small - 15 to 20 million USD. But the importance is that Seychelles is being used as ‘proof of concept’. The hope is that other developing and small-island coastal states will follow its example. Indeed, last year Fiji issued the first national green bond for a small-island developing state, and Nigeria also issued its first green bond. NatureVest - a US based organisation set up by JP Morgan and The Nature Conservation to specialise in leveraging private capital for conservation - thinks that in 10 years they will be selling a billion USD of blue bonds. 

The dangers of the blue bond market? 

 Raising funds through international capital markets could end up delivering the promised “triple win outcomes”: good for the environment, good for poorer communities, and good for the investors. But is this model safe to replicate?

So many organisations are supporting conservation finance in general, and the concept of green or blue bonds specifically. There are many reports describing how these are vital if we are to save the planet. Yet hardly any of these consider what might go wrong. In CFFA’s publication on blue bonds, we set out the reasons why the blue bond market are not attractive for small-scale fishers, and why the claims made about blue bonds are dubious.

Credit Suisse and the first tuna bond

The report includes a case study from Mozambique. Mozambique raised 850 million USD to finance the launch of its national tuna fishing company, dubbed by others as the world’s first ‘tuna bonds’. At first glance, this has nothing to do with blue bonds. However, just like a blue bond, the issuer claimed the money would be spent on sustainable fishing and the funds will have an enormously positive outcome on the national economy. The bond was financed and arranged by Credit Suisse, in collaboration with other European and Russian banks, some of whom also support conservation finance and green bonds. In fact, in 2013 - when Credit Suisse was finalising the arrangement for Mozambique’s tuna bonds, the bank was working with WWF and other conservation organisations on initiatives such as 50in10 and the Global Ocean Partnership. It is a bank that was - and still is - at the forefront of a global campaign to raise ethical financing to save the ocean. 

The tuna bonds did bankrupt Mozambique. They also provided millions of dollars in fees for Credit Suisse and other banks, accounting firms and lawyers. The tuna bonds were issued in secrecy and have led to a range of concerns about high level corruption and conflicts of interest. The prospectus for the bonds - sent out to investors but kept confidential - was deceitful and it massively overvalued the business proposal. Mozambique’s tuna fishing company and the expensive fishing vessels it bought from France, do not generate enough income to pay off the investors or pay its workers. Mozambique has defaulted on its repayments, and is struggling to get a bailout from the IMF. Remarkably, the case of Mozambique does not seem to be discussed at Credit Suisse’s annual conferences in New York, when the network of bankers and conservation organisations come together to plan how to promote blue bonds and other innovative financial instruments. 

Mozambique is an extreme example of the risks of ‘sovereign bonds’ - whereby governments raise money through international capital markets. But Mozambique is not the only example. In the last decade, more and more African governments have decided to raise cash through the bond markets. Before 2006, only South Africa had done so. But by last year, African governments accounted for 40 billion USD in bond debts; meaning bonds have become almost as important for African governments as development aid. The Seychelles, Ghana, the Democratic of Congo and Mozambique have been the first countries to default on these debts, but there is a growing concern that others will follow. 

So why should we be concerned about a growth in the blue bond market? Our report raises the following issues: 

Countries can easily raise too much cash through bonds - leading to unsustainable debt. 

This is a risk made more likely where valuations on potential returns lack credibility. This is an aspect that characterises fisheries - there are now many reports that claim the wealth from the oceans is massively under appreciated, and if developing countries could impose better management and deal with illegal fishing (and sell blue carbon credits) - then governments could make millions of dollars in extra taxes and levies. The trouble, however, is that these projections on the enormous wealth potential of the oceans have often been based on dodgy statistics, and they rely on a fantasy, whereby African governments can easily develop their ‘blue economy’ into a sustainable cash cow that will then fund pro-poor and environmentally friendly development. 

As it is, exaggerated and simplistic reports on the wealth potential of the oceans could easily be used in the prospectus sent to investors, who end up believing that the government is in a good position to earn enough money to pay back the debts, when they are clearly not. 

In fact, deciding how much money to raise in bonds is not always based on the likely economic returns for the bond issuer. In Mozambique, Credit Suisse originally raised 500 million USD for the tuna company. But they found there was a strong demand among investors, so a further 350 million USD was issued. The case is much worse than that - Credit Suisse ended up issuing 2 billion USD in bonds for Mozambique, which included raising cash for two other companies that were set up to provide monitoring and control of the country’s EEZ. There was no information made available to investors that might convince them 2 billion USD was not a viable investment, although because the government of Mozambique had guaranteed the loans, investors were probably not too worried. 

Overvaluing bonds means the country may default on repayments, which means it is forced into debt restructuring (as is the case in Ghana and Mozambique), which tends to harm service delivery for the poor. Alternatively - and possibly more likely for ethical bonds - the government relies on other income streams to make up the shortfall. In Africa, by far the largest source of foreign cash available to governments is from the export of primary commodities, such as from oil, gas and mining, or fish. Blue bonds - as with green bonds - may not be very sustainable debt, meaning there is pressure to promote other polluting industries to compensate.  

This risk of bonds may seem similar to other forms of government borrowing, such as concessional loans from development banks. However, bonds are far more expensive for developing countries - they have much higher interest rate payments, and also much higher fees for the bank managers. Unfortunately, the drive to encourage developing countries to raise more money on private capital markets, which is a policy promoted by so many aid agencies often under the guise of ‘blending private and public finances’, may be causing a reduction in concessional loans and aid grants. 

Bonds are at risk of corruption and fraud

The ease in which governments can raise too much money from bonds makes them vulnerable to corruption. This is also facilitated by the lack of transparency that seems to be a characteristic of bonds. Again, Mozambique is possibly the stand out example, but there have been others. Tanzania raised 600 million USD in 2013 from issuing a sovereign bond. Yet investigations found that the lead bank manager - Standard Bank - colluded with Tanzanian authorities to increase the bank fees for the bond, which was then used as money to pay a kick back for being awarded the deal. 

National bonds are not normally used to fund a specific project, but are rather sums of money that are distributed to a range of projects based on an eligibility criteria. There is a great deal of discretion in how the proceeds are used. Conflicts of interests and kick-backs are therefore inherent risks. In theory, ethical bonds may come with higher standards for accountability and transparency than other types of bonds. Indeed, voluntary standards on green bonds focus on ensuring that there is reporting on how the bonds were used. But generally bond issuers are expected to self-report, and there is no requirement for external auditing. 

The possibility that bank managers and governments abuse blue bonds for personal gain should be considered a risk in the emerging blue bond market. The fact that Credit Suisse and other European banks have been caught up in corruption related to bonds is further proof. Yet this is not mentioned in any of the promotional material for conservation finance. This contrasts to funds provided by donors and multilateral banks, for they have made attempts to introduce anti-corruption guidelines and safeguards. Private financial markets are much more relaxed on this. 

The same is true on human rights. Donors and multilateral banks generally have grievance mechanisms and social and environmental safeguard mechanisms. They may not work very well in all cases, but there is no such framework in place for bonds, ethical or not. 

Aligning marine conservation to ‘profit maximisation’ 

It is an explicit objective of conservation finance is to make sure that investments in conservation are profitable. For blue bonds, choices on how money will be used are therefore likely to be influenced by profit maximisation. This is worrying for groups who depend on the ocean but don’t generate a lot of money, such as subsistence and small-scale fishers. Generally the promotional material for conservation finance tells us that the benefits of these investments will be shared well, and that they will have a pro-poor impact. That seems unlikely.

A fundamental problem with relying on private capital markets to fund conservation is that the only measure of success is money. Non-monetary values do not translate well into financial instruments. The policy of encouraging governments in developing countries to raise funds through private capital markets has been strongly criticised for encouraging the privatisation of public goods and promoting the interests of multinational firms, and at the expense of local economies and businesses. 

The spectre of blue washing

One of the main criticism of ‘green bonds’ is that they are not always very green. We don’t know yet what the concept of blue in blue bonds is, but we should assume it includes environmental sustainability. 

Governments or companies can call their bond whatever they like. However, voluntary standards and labelling schemes have been integral to the growth of the green bond market. The standards are vague, and encourage bond issuers to pay for a third party assessment that demonstrates the ‘greenness’ of the proposal. The actual definition of ‘green’ is left open to interpretation. 

Four international companies have cornered the market in providing these assessments. This is a weak system - companies providing assessments and labels have a vested interest in providing favourable assessments - as this will lead to more business and a better market standing.  One of the key dilemmas facing these assessments is flagging the ‘rebound effect’. A simple example is a scheme to reduce the energy consumption of transport, which leads to savings. However, cheaper transport means people travel more, meaning the net impact of the investment was unsuccessful in reducing energy consumption and the release of carbon.  These rebound effects of green financed projects are thought to be common, but it can take time to measure and detect. Third party assessments of green bonds often raise these issues, but it is not considered sufficient to give a bond a negative assessment. We therefore have green bonds passed as green by third party assessors for oil companies.

A further weakness of the green bond market is that the focus is on the use of proceeds. A key risk is that governments issue green bonds, but continue to invest and promote other polluting industries. Assessments of green bonds do not consider ‘policy coherence’, meaning a country such as Nigeria can raise a green bond while continuing to be heavily dependent on the export of fossil fuels. 

The same problem manifests with investors and banks. Institutions like Credit Suisse or JP Morgan  are enthusiastically promoting green bonds, but have much larger investments in dirty bonds. The same has been true for the World Bank Group, who has promoted the green bond market while generating more funds for the establishment of new coal plants. 

Unlike other types of financing, green bonds also lack discipline. That is, money is provided upfront for green investments, but there is no way to return money if the impact of the investment was disappointing, even if there was interest in undertaking end of project assessments, which does not appear as a feature of green bonds at all. 

A dilemma: dealing with the risks of the blue bond market

Organisations worried about these risks presented by conservation finance and the growth of blue bonds are confronted with a dilemma. A pragmatic approach could be to focus on mitigating the risks, including campaigning for stronger voluntary guidelines, commitments from banks to be transparent, and for social and environmental safeguards to be put in place by governments and financial institutes. Civil society organisations may also decide to invest time and resources in monitoring blue bonds and undertaking their own independent assessments. 

But mitigating risks will be time consuming and may be unsuccessful. Indeed, the logic behind conservation capital is dubious. The underlying argument put forward that private financial markets will save the planet is unconvincing. 

The ‘financing gap’ is ideological. The inability of governments to ensure marine ecosystems are used in a sustainable way is not simply down to a lack of resources and money; the root causes in most places is political in nature. We should not imagine that somehow governments will become responsible stewards of marine ecosystems simply by ensuring they have access to more funds through debt instruments. Indeed, given what we know about international debt markets in Africa, relying on these further will most likely lead to a growing funding gap for African governments.  

Estimates of the financing gap for conservation are also a fabrication. There are many different ways in which changes could be achieved to support sustainable fishing and marine conservation, such as prioritising sustainable small-scale fisheries over other commercial industrial fishing companies. If funding is an issue, then other more sustainable sources of funds should be encouraged, such, raising taxes on polluting industries, or reducing government spending on other areas, such as the military.  But there is no reason to believe that the only source of financing left for the ocean comes from private capital markets. There is also good reason to believe that following this path will provide disproportionate benefits for wealthier sections of society. 

Ultimately conservation finance requires blind faith in the fairy tale that the only way we can achieve sustainable marine ecosystems is by making vast amounts of profits in the process, for ever. The move towards sustainable use of marine ecosystems will also require difficult choices to reduce growth and limit consumption. Sadly, there is a distinct possibility that the push for increased private financing is being made by a coalition of organisations that all have vested interests; investors seeking to display their social and environmental credentials, NGOs looking to increase their own funding, banks that charge lucrative fees, and governments looking for additional short-term cash.