The International Pole & Line Foundation (IPNLF) is a global charity that promotes the effective management of tuna stocks, while also safeguarding the local livelihoods they support. IPNLF promotes sustainable development through the responsible use of the marine environment and the empowerment of local coastal communities to conserve biodiversity, safeguard food security, support their livelihoods, build climate resilience and eradicate poverty. IPNLF’s mission is to empower responsible fisheries, which give back to the seas and the people that depend on them. We work across science, policy and the seafood supply chain to achieve this.
Despite the unusual circumstances imposed by COVID this year, progress on rebuilding the overfished Indian Ocean yellowfin tuna stock cannot be delayed any longer. The consequences of Resolution 19/01 - On an interim plan for rebuilding the Indian Ocean yellowfin tuna stock in the IOTC area of competence - continuing to be ineffective will be felt most critically by small-scale tuna fisheries, especially those in developing coastal states that provide critical livelihood support to coastal communities.
The United Nations Fish Stock Agreement (UNFSA) recognises the application of the precautionary approach as a general principle for sound fisheries management, and the IOTC acknowledged the importance of applying the precautionary approach  to the management of tropical tuna in the Indian Ocean with the adoption of Resolution 12/01.
As such, in the interest of swiftly progressing the vitally important revision and effective implementation of Resolution 19/01, IPNLF suggests the following improvements:
1. All CPCs should urgently agree, at a minimum, to the total catch reduction of 20% for yellowfin tuna. Such an approach would be aligned with current recommendations from the IOTC’s Scientific Committee and support the precautionary approach as is required under Resolution 12/01.
2. Revision of the Resolution should focus on developing and agreeing on robust management issues. Delaying the implementation of management measures further by solely focusing on non-compliance issues instead of first putting a framework in place, only serves to worsen the current stock situation, contradicts the collaborative and inclusive global pursuit of managing shared fisheries resources with principles enshrined under UNCLOS, and hampers alignment with the UN Sustainable Development Goals (SDGs)
3. All contracting parties and stakeholders should recognise that not all aspects of 19/01 require revision. Amendments to 19/01 should strategically focus on key shortcomings of the interim measure, while at the same time acknowledging the urgency of resolving the consistent overfishing of this valuable shared stock. As such, the already agreed catch reduction ratios by different fishing gears, and the relative contributions theses gears make to the overfished stock status of yellowfin, should still form the basis of a new agreement as they represent an agreed precedent which is based on an equitable framework. Ignoring critically important context while pushing for equal cuts across the board is irresponsible, unfair and will only delay the process.
4. The most pragmatic way of achieving the required minimum total catch reduction of 20% is to simply double all of the currently agreed catch reductions by fishing gear as stated in 19/01, while only allowing exemptions as set out in paragraph 6 below.
5. This will result in a total annual reduction of 80,000 tonnes, which is equivalent to a 20% reduction of total catch based on the 2014 level for all fleets other than the Seychelles purse seine fleet where 2015 catch applied. In the case of Small Island Developing States, IOTC members that contributed less than 4% of the total yellowfin catch of the Indian Ocean in 2017 shall reduce their purse seine catch by 15% of 2018 levels.
6. Noting that more than half of the yellowfin catches taken in the Indian Ocean where exempted from catch reductions under Resolution 19/01, IPNLF is of the opinion that all fleets should play their part in rebuilding the yellowfin stock and that exemptions should only apply to artisanal fleets catching less than 2,000 tonnes per year. However, should their catches exceed 2,000 tonnes in any year, then the incremental catch of these artisanal fleets should also be subject to reductions as proposed in paragraph 4 above.
7. IPNLF considers the mechanism for paying back any over-catch as adequate, and that it should thus be maintained as an already agreed precedent within the interim Measure.
8. Noting that supply vessels contribute to the increase in effort and capacity of purse seiners, that the number of supply vessels has increased significantly over the years and that they assist purse seiners in the deployment and retrieval of dFADs, further contributing to the current overfished status of the yellowfin stock, IPNLF calls on the Commission to also phase out all supply vessels by the end of 2021.
Whilst noting that the impact of FADs on yellowfin stocks is currently not fully considered under 19/01, IPNLF are of the firm opinion that it should be for the reasons set out below:
1. It has been recognised that drifting FADs (dFADs) deployed in the Indian Ocean purse seine fishery are major contributors to the overfished state of yellowfin tuna due its high catches of juveniles. The IOTCs Working Party on Tropical Tuna (WPTT) noted that in order to meet their yellowfin catch level targets, purse seine vessels have in recent years significantly increased their fishing effort associated with dFADs, leading to a further substantial increase of juvenile yellowfin tuna mortality while the stock was already overfished. It is therefore crucial that revised measures also consider the stock productivity implications of excessive harvests of juvenile yellowfin tuna by purse seine vessels using dFADs.
2. To enable suitable quantification of these impacts, full transparency in dFAD operations should be required, including submission of all data transmitted by operational buoys to an independent third party in near real-time. dFAD management measures should be adopted that require full independent verification of FAD ownership, numbers, positions, tracks and the details of the retrieval and disposal of all dFADs.
3. Following the precautionary approach, IPNLF proposes a further reduction from 300 to 200 as the maximum number of operational buoys that can be assigned to any purse seine vessel at any one time. The number of instrumented buoys that may be acquired annually for each purse seine vessel should be set at no more than 400 – a reduction from the 500 specified under Resolution 19/02. No purse seine vessel should have more than 400 instrumented buoys (buoy in stock and operational buoy) at any time. As per Resolution 19/02, an instrumented buoy shall be made operational only when physically present on board the purse-seine vessel to which it belongs or its associated supply or support vessel, and the event shall be recorded in the appropriate logbook, specifying the instrumented buoy’s unique identification number and the date, time and geographical coordinates of its deployment.
4. dFADs are further also associated with other negative environmental impacts such as the bycatch and entanglement mortalities of endangered, threatened and protected (ETP) species, deployments which can sometimes be considered as IUU fishing and significant contributions to marine plastic pollution. dFAD management measures should therefore also require purse seine vessels to deploy and retrieve their FADs within the relevant international legal framework, including the United Nations Convention for the Law of the Sea (UNCLOS), the London Convention and Annex V of the MARPOL Convention which seeks to eliminate and reduce the amount of garbage being dumped into the sea from ships.
5. To minimise their impacts on ETP species and broader ghost fishing impacts, no netting should be permitted in dFAD designs and all the materials used in the construction of dFADs should be fully biodegradable by the end of 2021.
 UNFSA Article 6, Paragraph 2 states: “States shall be more cautious when information is uncertain, unreliable or inadequate and that the absence of adequate scientific information shall not be used as a reason for postponing to take conservation and management measures”
Contact: Dr. Shiham Adam – IPNLF Director of Science and the Maldives