27th Regular Meeting of the Commission

13. November, 2021

Position Statement from Sharkproject International to the Plenary

We acknowledge the current and past challenges for the Commission in face of the COVID pandemic to fulfil its mission for a sustainable management of ICCAT stocks and for driving urgently needed improvements over these last two years. However, as recognized at UNFCCC COP26 the ocean crisis has to be in the centre of the discussion when talking about the climate crisis and therefore actions to restore ocean resilience are indeed vital. Healthy marine ecosystems are inevitable for long-term food security from sustainable use of marine resources. Therefore, we sincerely hope seeing major improvements and agreements at this year’s Meeting, setting a path forward for restoring ocean health and ending the loss of biodiversity.

At the start of this 27th Commission Meeting we therefore call to all delegations and nations to stop protecting the economic interests of their national fishing industries but to jointly work towards a common vision to stop overfishing, to reduce the bycatch of threatened species, to restore overfished stocks as quickly as possible, to improve transparency and monitoring, and to combat IUU, forced labour and all kinds of unsustainable exploitation; applying a precautionary approach in face of existing or upcoming uncertainties and consistently following scientific advice, using the best available science for decision-making, and swift implementation of improved management and conservation measures are needed.

Sharkproject specifically would like to highlight the following topics calling for urgent attention:

Shortfin Mako: The Commission must urgently implement a retention ban in the North Atlantic and a TAC in the South Atlantic, applying a precautionary approach in line with scientific advice from SCRS.
Despite the clear scientific advice from the SCRS for an immediate retention ban for Northern Shortfin Mako as an immediate measure followed by additional measures to avoid interaction and reduce mortality, ICCAT has failed since 2017 to implement effective measures to stop overfishing and start the rebuilding of this stock. A recently published legal opinion concludes: "a precautionary approach in line with the UNFSA would require a temporary retention ban at least until 2035, preferably until 2045. Such a measure would account for many of the current uncertainties and increase the chances for successful implementation and rebuilding of the NA-SMA stock in accordance with the best available scientific information."

The new proposal PA4-809 demonstrates the willingness of CPCs to work towards a solution, but it still falls substantially short of a workable plan for rebuilding of this stock to BMSY by 2070 with a high probability of success and at least a probability of 50% by 2045, the shortest possible timeframe projected by SCRS. Planning for retention and calculating potential allocation scenarios via complicated equations as suggested by one of the CPCs instead of focusing on improved data collection, effective measures to reduce total mortality and improved monitoring for compliance with a temporary retention ban will not deliver on the required outcome. Therefore, the proposed alternative from another CPC proposing a complete retention ban for 2022 and 2023 and to restart discussions based on verified total mortalities in 2024 is certainly the better alternative, but still falls short of the precautionary approach needed for a stock that will continue to decline at least until 2035 even at a fishing mortality of zero. Only by then will we be able to really evaluate whether the implemented measures have been effective and will allow rebuilding of this stock within our lifetime, or within the next 50 years at all.

Landings from the South Atlantic have increased by more than 500 t in 2020 compared to 2019 figures and almost no data on discards have been provided by CPCs for the South Atlantic. Therefore, the Commission should at least agree on a TAC of not more than 2001 t as advised by the SCRS to stop overfishing in order to avoid a similar development as in the North Atlantic.

Blue Sharks: In 2019 Rec 19-08 for the first time has defined a TAC for blue sharks at ICCAT. However, in 2020 landings exceeded the defined TAC for the South Atlantic by more than 4500 t. Therefore, we do not consider the postponement to 2023 for the review of a new TAC and the discussion on the development of HCRs as proposed in PA4-805 to be sufficiently precautionary for this shark species; especially since blue sharks are one of the major target species in the Atlantic and have been exploited massively over the last decades by many of ICCAT’s CPCs without appropriate management measures in place.

Fins Naturally Attached: Sharkproject requests that all sharks and all other cartilaginous fish (rays, chimaeras) should be landed with Fins Naturally Attached and that all at sea trans-shipment of sharks in full or parts should be prohibited with all trans-shipment activities always requiring 100% monitoring by observers and an established electronic monitoring system.

We welcome proposal PA4-807 and urge the Commission to adopt this call for CPCs “to prohibit the removal of shark fins at sea and require that all sharks be landed with their fins naturally attached (fully or partially) through the point of first landing of the shark.” We support the proposed ban of trans-shipment or landing of separate fins and the request for improved gear specificity to avoid shark bycatch and improved data recording on shark bycatch, but would appreciate a more detailed requirement including increased observer coverage at ICCAT and at increased scrutiny for at port inspections. ICCAT should finally introduce the globally acknowledged best practice and only effective measure to stop finning. This step has been long time overdue, especially in view of the dramatic conservation situation of sharks at a global level and the major shark fishing activities of many CPCs in the ICCAT convention.

Improvements in Monitoring and Transparency: Sharkproject expects that all industrial fishing fleets should demonstrate high to very high levels of transparency and monitoring. This could be accomplished by a combination of human observers and a functional and proven electronic monitoring system to document both, catch and bycatch, the condition of the bycatch upon release, and to ensure compliance with all conservation measures and regulations without putting observers at risk when seen as law enforcement bodies instead of scientific observers. Furthermore, all fishing activities should be transparently traceable at all times and all vessels must transmit their position via AIS and VMS systems at all times in line with existing regulations. Also, artisanal fisheries should be supported to provide more data and transparency.

Illegal, Unreported and Unregulated (IUU) fishing must be effectively combated via international cooperation between all Regional Fisheries Management Organizations by imposing severe penalties for violations and increasing transparency and data exchange between RFMOs. The submitted proposals PWG-415, PWG-408, PWG-411, PWF-416, and especially proposal PWG-418 are a welcome start into this direction and should therefore be adopted by the Commission.

Transformation towards improved Selectivity of Fishing Gear and continuous Bycatch Reduction: Sharkproject considers the progressive reduction of all bycatch, whether observed or unobserved bycatch, as well as the impacts from ghost fishing, via improved bycatch avoidance strategies and by testing and subsequent implementation of technical improvements as an essential improvement step. All fishing gear and practices should demonstrate improved selectivity and to reduce any negative impact on the marine ecosystem to the absolute minimum possible. PA4-811 recommends the introduction of large circle hooks and/or finfish bait to reduce the bycatch and increase post release survival of sea turtles in surface longing. We welcome these technical improvements, especially as they may also be able to reduce shark bycatch and increase the post release survival of sharks. For all bycatch classified as threatened and/or protected by national, international, or multilateral agreements, effective management plans should be established to maintain or if already overfished, to rebuild these populations at least to pre-1970 population levels. The adopted measures should allow the recovery of the stock with a high probability and within the shortest possible period of time, accounting for species-specific characteristics and uncertainties. In the absence of scientific reference points or significant projection models, the precautionary principle should always be applied, assuming a "worst case" scenario for the species and mandating the most effective measures. Maximum mortality limits should be defined for each of these species when caught as bycatch in an ICCAT fishery. Appropriate management regulations need to be in place to ensure such mortality limits are not exceeded, including but not limited to timely or spatial closures of the fishery or the suspension of certain fishing gear to ensure agreed mortality limits are not exceeded.

Improvements for Purse Seine Fisheries using drifting FADs are outlined in the joint statement PA1-408 from IPNLF. Sharkproject re-emphasises the importance of a swift transition to lifetime non-entangling and biodegradable FAD designs without further delays, and to intensify research and implementation of improved avoidance measures. The high bycatch rates of juvenile silky sharks are of great concern due to the association patterns of these animals with dFADs and can’t be resolved by improved release handling alone. Due to the high vulnerability and high post release mortality rates of these juvenile sharks, measures to avoid setting on them in the first place are urgently required.

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