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Chairperson’s response to an appeal for transparency

On the 2nd of December 2013 as the Chairperson of Stop Illegal Fishing, I received a letter from the Coalition for Fair Fisheries Arrangements (CFFA) endorsed by 14 individuals with the title ‘Appeal for government transparency in fisheries management in the context of regional efforts to combat IUU’.

The letter responds to a presentation that I gave last month in Nairobi, Kenya at an INTERPOL Environmental Compliance and Enforcement Event.‚ My talk was about one of Stop Illegal Fishing’s projects named FISH-i Africa. While I am delighted that this presentation has drawn so much interest to the work of Stop Illegal Fishing and FISH-i Africa, I would like to correct some inaccuracies that CFFA have presented in their appeal letter.

Stop Illegal Fishing is a Working Group of the NEPAD and a not-for-profit organisation with the purpose "to strengthen cooperation and coordination between governments and partners and to support the African Union’s and the NEPAD Planning and Coordination Agency’s agendas and other community, national, regional and international processes to stop IUU fishing in African waters."

FISH-i Africa is facilitated by Stop Illegal Fishing, the FISH-i Africa Task Force consists of national fisheries enforcement agencies from seven countries ‚Comoros, Kenya, Madagascar, Mauritius, Mozambique, Seychelles and Tanzania. The Task Force is supported by technical experts and institutional partners that work together to coordinate the analysis and use of fisheries intelligence and information to lead to targeted enforcement actions against illegal fishing operators.

I can confirm that Stop Illegal Fishing is strongly committed to encourage greater transparency with respect to making public certain fisheries related information. This commitment is demonstrated in numerous articles on our website such as: in April 2012 – Greater transparency for Liberia’s fisheries – an article where SIF reports ‘ Liberia, in another move towards improving the governance of their fisheries has launched ‚the Bureau of National Fisheries website ‚Stop Illegal Fishing is pleased to cooperate with Liberia in the fight against illegal fishing in West Africa and encourages more countries to make their fishery information, and in particular fishing vessel licence lists public.’

A year later in April 2013 SIF reported – Seychelles sets a good example for fisheries governance in Africa ‚’Following their commendable actions with regards to denial of port access to the suspected IUU fishing vessel F/V Premier, the Seychelles has again displayed exemplary conduct in the management of their fisheries by publicising detailed information on Seychelles flagged fishing vessels for 2013 and a list of licensed fishing vessels on the Seychelles Fishing Authority (SFA) webpage. The sharing of this information is in line with regional fisheries agreements, and supports the objectives and results of the FISH-i Africa initiative. ‚¦..Countries are now able to verify information pertaining to vessels in a swift and easy manner, and this move by the Seychelles is a large step towards greater regional cooperation and information sharing and will make it more difficult for vessels to engage in IUU fishing by using fraudulent or corrupt practises. A similar initiative was adopted by Liberia last year, and has proved vital in the protection of the country’s fishery resources; hopefully this will also prove true for the Seychelles, and be an encouragement to other African countries to collaborate and share information.’

In July 2012 members of Stop Illegal Fishing supported the African Members of COFI to prepare an Africa Group Statement on IUU fishing that was presented by the Minister of Natural Resources of the Seychelles, the Hon. Peter Sinon. The Statement included‚¦. ‘The Group of African Countries support global efforts to address IUU fishing a problem that plagues our countries.‚ We note that in the last years African countries have been working in partnership with international players to curb IUU fishing and we have had some level of success that we will continue to build on.‚  However, we also note the need to continue our joint efforts to bring an end to IUU fishing‚¦.We are also closely following work towards the development of a Global Record of fishing and fishing support vessels. The creation of a Unique Vessel Identifier will assist all actors in the identification and regulation of fishing vessels in all jurisdictions and we support this. We call on our partners and the FAO to support developing countries to develop the information gathering and sharing mechanisms that will ensure the effectiveness of the Global Record. Lastly, we welcome the increasing efforts across the African continent to coordinate efforts and develop cooperation mechanisms to prevent, deter and eliminate IUU fishing.’

As demonstrated above, and available on the public www.stopillegalfishing.org website, Stop Illegal Fishing has clearly demonstrated its commitment to greater transparency in fisheries and further more is actively assisting governments to achieve this.

The appeal letter sent by CFFA appears to have quoted me out of context ‚which is a great shame considering the excellent work of Stop Illegal Fishing and FISH-i Africa. I must stress that I was speaking at an INTERPOL compliance and enforcement event that was dealing with the very serious issue of fisheries crimes, it was not a general meeting on governance in fisheries.‚ I also note, that I was speaking about one of Stop Illegal Fishing’s initiatives ‚that of FISH-i Africa, which was established to support fisheries enforcement actions, a domain that by necessity and due to national legislation may require confidentiality.

Stop Illegal Fishing is aware of the complexity around cases and issues of IUU fishing and we actively encourage dialogue and cooperation with all partners with a genuine interest in supporting countries to fight IUU fishing.

I have circulated the appeal letter to all FISH-i Africa countries as requested.

Mr Geofrey Nanyaro

Stop Illegal Fishing Chairperson

4 December 2013

Text from the appeal letter sent on 2nd December by CFFA:

To: Mr. Nanyaro, Chairperson FISH-I and Stop Illegal Fishing.

RE: Appeal for government transparency in fisheries management in the context of regional efforts to combat IUU

We, the undersigned, write to request that governments participating in the Fish-I project commit to improving transparency and public access to information on commercial fisheries management.

FISH-I was launched this year as a regional initiative among governments, based on information sharing, to counter illegal, unreported and unregulated fishing. In our understanding, it is a project that is being run by the Stop Illegal Fishing Working Group established through the Partnership for African Fisheries, which in turn is a NEPAD program. Participating governments in FISH-I include Kenya, Tanzania, Mozambique, Comoros and the Seychelles, with plans to extend this to other governments, including in West Africa.

In your presentation as Chairperson of FISH-I at the Interpol and UN organized meeting on IUU fishing, held on the 6th of November 2013 in Nairobi, you described that FISH-I is a highly effective new initiative designed to share information between countries on the activities of fishing vessels, in order to reduce IUU fishing.

During this presentation you also responded to a question on whether information on access agreements, private licenses and other forms of fisheries access arrangements should be made publically available. However, you said that improving transparency was not necessary in the fight against IUU, although FISH-I and the Stop Illegal Fishing Working Group have access to this information. We note that apart from the Seychelles, participating governments in FISH-I chose to keep information on fisheries access confidential, including information on access agreements, which companies are licensed to fish, how much money is paid for these licenses and what are the conditions of the license.

However, we consider transparency to be a vital part of addressing IUU fishing and moving towards responsible and equitable fisheries management. Indeed, a characteristic of unregulated and unreported fisheries is secrecy and the denying of public access to information and participation. This is a view shared by many other organisations, and was most clearly stated in the 2010 State of World Fisheries & Aquaculture Report by the FAO:

"Lack of basic transparency could be seen as an underlying facilitator of all the negative aspects of the global fisheries sector‚€illegal, unreported and unregulated (IUU) fishing, fleet overcapacity, overfishing, ill-directed subsidies, corruption, poor fisheries management decisions, etc. A more transparent sector would place a spotlight on such activities whenever they occur, making it harder for perpetrators to hide behind the current veil of secrecy and requiring immediate action to be taken to correct the wrong‚.

Improving transparency is now accepted by several regional fisheries management bodies, including the IOTC, of which FISH-I members belong, it is an ambition for the work of multilateral organisations including the World Bank and it is also supported by fishing companies, as evident by the launch of the Tuna Fisheries Transparency Initiative by European fishing firms. Improving public access to information in fisheries is also contained in the Open Government Partnership, which both Kenya and Tanzania have signed on to.

We appreciate that some information held by fishing authorities might be sensitive and should be kept confidential in order not to prejudice ongoing investigations or criminal trials. However, basic information of fisheries access arrangements and related revenues needs to be made public and the arguments against this are not valid. We also think that FISH-I, as a working group of the PAF programme that is intended to be a platform for multi-stakeholder engagement on IUU fishing, should actively promote transparency. It is not clear why this initiative should provide governments with intelligence against IUU fishing and has access to confidential information, when citizens and companies involved in the sector do not.

We therefore request that FISH-I recognizes the importance of public access to information in the management of commercial fisheries and as a collaborative project among government agencies, those member countries of this initiative commit to necessary reforms. At a minimum, we recommend that governments publish information on which fishing companies they sell licenses to, what is the fee paid for this license and what is the conditions of the license. All access agreements should also be made public, as is the case with the EU‚„s Fisheries Partnership Agreements. We further recommend that members of FISH-I consider contacting those responsible for the Tuna Fisheries Transparency Initiative to explore how this can be implemented in East Africa. In doing so, fishing authorities in East Africa will provide a strong example that can help influence other countries, including in West Africa, where public access to information in fisheries is also highly restricted.

We support the overall aim of FISH-I and thank you in advance for sharing this letter with participating government agencies involved in FISH-I.

Yours sincerely,

Bĩatrice Gorez
CFFA Coordinator

This letter is endorsed by:
Gaoussou Gueye, General Secretary, African Confederation of Artisanal Fishing organisations ‚CAOPA (Senegal)

Chandrika Sharma, Executive Secretary, International Collective in Support of Fishworkers- ICSF (India)

Saskia Richardz, EU Oceans Policy Director Greenpeace European Unit Greenpeace (Belgium)

Alfred Kawreh, President Liberia Artisanal Fishing Organisations ‚LAFA (Liberia)

Dr Ahmed Mahmoud Cherif, President PĻchecops (Mauritania)

Kajsa Garpe, Policy Officer Tropical Marine Ecosystems and Fisheries, Swedish Society for Nature Conservation ‚SSNC (Sweden)

Becha Hadley, Community Action for Nature Conservation – CANCO, (Kenya)

Doreen Simiyu, Tuna Fisheries Alliance of Kenya

Michel Goujon, Juan Pablo Rodriguez Sahagun, Julio Moron, Tuna Transparency Initiative, (France/Spain)

Frederic Le Manach, PhD Student at UBC, Sea Around Us Project (Canada)

Andrĩ Standing, Transparentsea (Kenya)

Christian Connaulte, President, Encre de Mer (France)