1. The SPC Report - the 2006 National Fisheries Assessment, consistent with various other regional scientific reports, does in fact allude to overfishing of certain key fish stocks, more particularly bigeye tuna, in the WCPO (Western and Central Pacific Ocean) region. The information referred to in that particular SPC report was part of a general overview, and has been taken out of context with respect to the Cook Islands situation.
2. It is a well established fact that the heaviest fishing occurs far across to the west of the Cook Islands, in the PNA country waters (such as PNG, FSM, Gilbert Islands, and Marshalls), and in the Philippines/Indonesia. It is also recognised that this is an area where management action urgently needs to be taken, and the Cook Islands is doing its part to support all initiatives at the Tuna Commission level to ensure proper and sustainable management of these important stocks, including targeted reductions in both catches and fishing effort.
The Cook Islands Fishery
3. Yellowfin and bigeye catches in Cook Islands waters have increased moderately over the last decade, but still remain at very low levels. There is no indication whatsoever that stocks are declining due to overfishing in our waters, quite simply because that is not happening. We are not catching these species of tuna at levels anywhere near the regional average.
4. The point to note is that whatever exploratory (i.e. limited) fishing activities that occurs in the Cook Islands are highly unlikely to have any major impact of these fish stocks, which are mostly taken in the Western Pacific. Conversely, any strong position taken by the Cook Islands, such as simply electing not to catch bigeye or yellowfin, is also unlikely to have any real conservation value on these stocks – because again, all the major fishing grounds and spawning areas are located in the Western Pacific. The key point to recognise is that the Cook Islands take of bigeye, yellowfin and skipjack, including all projected catches, will (always) remain a very small fraction of that which is taken across the entire region. We are, if you like, a very small part of a very big picture, sitting as we do on the geographic margins of all these major fisheries.
Conservation & management vs the rights of Pacific Islands Countries
5. The Convention on the Conservation and Management of Highly Migratory Fish Stocks in the Western and Central Pacific Ocean specifically recognises that the small island countries “should not bear a disproportionate burden of conservation and management action with respect to these and all other fish stocks”. In this case, it is neither a reasonable nor rational argument to have the Cook Islands bear all of the conservation and management costs in place of those who have been enjoying the benefits of these resources for the last 50 years. Not only is there no scientific basis for the notion that the Cook Islands would or could ever be some kind of effective ‘marine reserve’ for the rest of the region, but it ignores what is clearly stated in the Convention, which expressly recognises our right to develop our fishery. This right is something that all Pacific Island countries have fought long and hard over many years to achieve. Again, the appropriate place to ensure real conservation and management of these stocks is at the Commission (in other words at the regional level), where work is being done right now to address overall catch and effort reductions, while at the same time addressing the rights of small island states to participate in these fisheries in their own waters.
Catch allocations & the right to Fish
6. All around the world, pelagic fisheries are coming under increasingly tighter regulatory control - through regional fisheries commissions and multilateral arrangements (such as our own Western and Central Pacific Fisheries Commission – the WCPFC). Access to and benefit from these ‘commons’ fishery resources are becoming more and more restricted. The typical pattern is therefore one in which those who have fished the most heavily (and one could argue have contributed the most to problems of overfishing) are rewarded, while the others (typically developing countries) miss out, because they had not already established themselves in the fishery. This region is no exception to that general rule. This is why it is also strategically important the Cook Islands places a marker in these fisheries, if only to secure our place ‘at the table’ under any future allocatory regime. It has been the experience of the Cook Islands that it is very difficult to arrive later and argue for a right to fish with no prior history of fishing. This is despite international efforts to legally recognise the rights of developing states, and in particular the small islands developing states to participate in these fisheries. This, as one reader correctly pointed out, was also the bitter experience of many coastal African countries - who up until recently were unable to take fish in their own waters, because of catch allocations awarded to European countries through historical catches taken on the high seas.
7. Therefore, and under current WCPFC (the ‘Tuna Commission’) rules, the Cook Islands, as a small island developing state with otherwise very limited opportunities for economic development - and having an economy extremely vulnerable to external global influences, is seeking to take up its right to develop its fishery resources in a sustainable and precautionary manner. This right is afforded to the Cook Islands under CMM 2008 – 01, a Conservation and Management Measure agreed by all members of the WCPFC. At the same time, the Cook Islands will continue to work with other members of the Commission to ensure sustainability of these stocks into the future.
Purse seining & exploratory fishing
8. With regard to impact of purse seining and the impact on juvenile bigeye and yellowfin – again the arguments stated here hold true. The reality is that what is being proposed is a very limited access exploratory fishery of 2-3 vessels, operating in an area of 2 million square kilometres, fishing far from any sport-fishing or artisanal fishing activities of any island in the group. The vessels themselves will be subject to all regional conservation and management measures, such as imposing limits on ‘floating object’ sets – the number one contributor to mixed catches of skipjack and juvenile bigyeye/yellowfin. The fisheries will be closely monitored, with 100% observer coverage to determine their performance and any impact on fish stocks. They will also be subject to a comprehensive review at the end of each fishing year. A few quick facts about purse seining: it is now the major source of canned tuna in the world – 99% of all canned fish comes from this kind of fishery. It is the major fishery in our region, providing 1.8 million tonnes of fish to the global markets. With the exception of the well documented problems associated with floating fad/log sets, the operation itself is very concentrated activity (the ‘pursed’ net having a diameter of approximately 300 metres). And because it primarily targets surface swimming schools of skipjack, bycatches of other non-tuna species is relatively limited, especially when compared with other commercial fishing methods. Skipjack, the primary target species, is also a very resilient fish stock, with a very short time to breeding maturity (2-3 years) and can sustain high exploitation rates, some regional fisheries advisers suggest as high as seventy per cent of standing stocks.
9. Even if the Cook Islands were to undertake very low levels of skipjack harvesting, in the order of 15,000 mt/yr, this would only account for 0.8% of the total skipjack fishery being caught in the region. The value of this catch (15,000mt) is in the order of $38 million dollars, and if we take the regional average license fee of 5% of the gross value of this catch, then this represents a direct injection of $1.8 million dollars to the Crown - money which could be spent on economic development, health, and education. Therefore, each year we do not fish these stocks is a lost opportunity of $1.8 million dollars of revenue to the country. This applies similarly to other highly valuable fish stocks, such as bigeye tuna and swordfish, and why it is being proposed that we at the very least, assess the potential of these fisheries through our exploratory fishing programmes.
Impact on small scale domestic fisheries
10. If there was ever to be an impact of this kind of fishery to be felt in the Cook Islands, it would more likely be the result of ‘downstream’ effects from intensive fishing activities in the west. Scientists theorise that the stocks may begin to slowly contract westwards as a result of overfishing (Sibert. pers comm. 2009), where paradoxically, the overfishing is most likely to occur.
11. In the case of sportfishing and artisanal fishing activities in the Cook Islands - in the unusual event that a bigeye tuna were actually caught on a rod/reel - it is likely that the fish would be mature (4-5 years of age), and would already have travelled great distances across the ocean before finding its way into Cook Islands waters. Bigeye tuna however, are not commonly caught by anglers because of their unique physiological characteristics and deep swimming/feeding behaviour. Longliners target bigeye tuna by either setting hooks at night, or by setting in waters of considerable depth (up to 300m). Because of this, the larger tuna are not typically caught in seine nets and so this fishing activity within Cook Islands waters is unlikely to have any direct impact on the domestic small scale fisheries of the Cook Islands.
Understanding what is meant by a ‘highly migratory fish stock’.
12. The final point is that the vessels in all these fisheries are targeting a stock which migrates through Cook Island waters – i.e. they are not residential. Furthermore, all planned exploratory fishing, being very restricted activities, will be required to remain outside 24-50 nautical miles from any island, however in reality fishing activities will be limited primarily to the upper part of the northern EEZ and high seas areas directly above the Cook Islands.
We think that while many people have valid and real concerns about this resource which is so important to all of us, it is important to try and place the proposed limited access exploratory fishing activities in the proper perspective. Sustainable development of these potential fisheries is the prime consideration of the Ministry. We hope our response here will provide the proper context for the kind of decisions we ultimately take with these fisheries.