IPNLF IOTC Position Statement 2022

IOTC Commission Meeting, 16-20 May, 2022, Seychelles 


Effective Rebuilding of the Yellowfin Tuna Stock

The International Pole and Line Foundation (IPNLF) continues to be concerned by the poor condition of the Indian Ocean yellowfin tuna stock, the consequences of which are felt most acutely by communities in developing coastal states. Yellowfin tuna is the second most important IOTC species, but its stock has been overfished and subjected to overfishing since 2015. An interim stock rebuilding was adopted in 2016 that was activated in January 2017, and that was revised several times, but it has so far not proven effective. A precautionary approach should have driven IOTC contracting parties to significantly reduce their fishing pressure in this situation, but catches actually increased by over 10% between 2014 and 2019

While many CPCs have maintained reduction targets stipulated in the rebuilding plan, some CPCs have been unable to comply, some have objected to the measures and others have changed fishing strategies to actually harvest more juvenile tuna at the cost of stock productivity. The most recent stock assessment showed that this stock is still under too much fishing pressure, it is still overfished and it is also subjected to continued overfishing. A substantial catch reduction of at least 30% from 2020 levels (capping catches at 301,700 tonnes) is now essential to recover the Indian Ocean yellowfin tuna stock within a reasonable timeframe of two generations (about 15 years). 

The upcoming 26th Session of the IOTC provides an opportunity to finally resolve Indian Ocean yellowfin tuna stock concerns, securing nutrition and livelihoods for millions of people in the process. We urge the IOTC to take into account the downfalls of previous approaches which have featured a lack of precaution or consideration for stock productivity and longevity. At minimum, the latest advice from the IOTC Scientific Committee should now be followed and reflected in the outcomes of this Session. 


Effective Management of Drifting Fish Aggregating Devices (dFAD) 

An important consideration for improving the Indian Ocean yellowfin tuna stock condition is improving the management of drifting Fish Aggregating Devices (dFADs). Together with their many other impacts in the Indian Ocean and elsewhere, over 90% of the yellowfin tuna harvested by industrial purse seine fleets around dFADs are juveniles. Those tuna not being able to reproduce before being harvested has severe impacts upon both stock productivity and the relative yield each fish provides for food security, nutrition and trade. 

The industrial purse seine fleets deploying and using dFADs have also recently had their compliance with IOTC dFAD management measures brought into question, through a submission by Kenya to the IOTC Compliance Committee. Within that submission, anecdotal evidence from opportunistic dFAD retrievals suggests that systemic non-compliance with dFAD regulations is taking place in the Indian Ocean. Under the current requirements of Resolution 19/02, dFADs need to be constructed from non-entangling materials. All of the dFADs encountered during the survey referred to in the Kenyan paper continued to use entangling netting in their designs and also did not conform to the IOTC’s requirements on the marking of dFADs.   These findings may reflect the continued misuse and regular abandonment of now prohibited dFAD designs. A further submission to the recent IOTC Compliance Committee also highlighted that there is scant evidence of biodegradable dFAD designs being adopted by purse seine fleets operating in the Indian Ocean, despite such design being successfully used in other ocean areas. There is therefore no reason why biodegradable designs should not also be used in the Indian Ocean to comply with current management requirements. Prevailing non-transparent and seemingly non-compliant use of dFADs is detrimental not only to tuna stocks, but also to broader marine ecosystems and the millions of livelihoods that depend upon the Indian Ocean for food and nutrition on a daily basis.

The IOTC have developed and strengthened dFAD management measures in recent years with the adoption of the most recent Resolution 19/02, which requires the exclusive use of non-entangling dFAD designs as of 2020, and transitions to biodegradable dFADs by 1 January 2022. Adequate dFAD marking with the unique vessel identifier is also now required, but compliance with this aspect also remains to be evidenced. In 2021, the Blue Marine Foundation developed a set of minimum requirements for dFAD management, presented to the IOTC ad-hoc Working Group on FADs in October, 2021 and endorsed by over 120 businesses and organisations, including the IPNLF. These requirements include the prohibition of dFAD abandonment with greater oversight and management measures to hold vessels accountable for the marine pollution, ghost fishing and other damage caused by dFADs. Adequate FAD marking is also required on the dFAD buoy and raft, so both can be traced back to owner vessels, while making all FAD operational data available within a public FAD Registry that would enable critical scientific analysis and compliance monitoring. A polluter pays mechanism is also suggested while IPNLF would support growing calls for an annual dFAD fishing closure period within the Indian Ocean, as has been implemented in some form or other by all other RFMOs in their efforts keep the juvenile tuna catches and other impacts of drifting FADs within sustainable levels. 

We urge the IOTC to strengthen implementation of compliance with regulations designed to protect ocean ecosystems and fish stocks. We encourage the IOTC to address this by outlining clearer regulations which improve transparency and accountability while implementing consequences for repeat offenders.