1. The good, the bad and the ugly: Management and governance in Pacific Island Country sea cumber fisheries

2. Sea cucumber fishery management plans
Fiji (2018) draft
Kiribati (2013) draft
Papua New Guinea (2016)
Papua New Guinea (2018)
Republic of the Marshall Islands (2012)
Samoa (2015)
Solomon Islands (2014)
Tonga (2007)
Vanuatu ( )
We reviewed the following sea cucumber fishery management plans, ideally we wanted to identify which management measures have worked and which have not. However not everything that makes its’ way into a management plan gets turned into action and some of these plans are still drafts.
Steven Lee - comparative review: identify good and questionable management measures.

3. Good ideas: inclusive committees
Including relevant NGOs and CSOs/fisher representation in management committees, and differentiating between these organisations
Local or subnational rules can only be stricter than national ones
Non-Governmental Organisations and Civil Society Organisations play different but equally important roles. The SC fishery tends to operate at the community or village level, therefore this fishery often has direct impacts on these groups.
Unfortunately, most management plans tend to focus solely on environmental NGOs only which leaves community needs and concerns uncatered.
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Just about every Plan that includes community or local level government management has wording to the effect that the National Plan acts as a baseline but I think this should be made very clear - that these groups can only increase or strengthen controls, not weaken them. Allowing groups to weaken controls in their particular area can lead to a race to the bottom.

4. Good ideas: Limiting access
Short open seasons
Give priority to local businesses to participate in the fishery
Where quota is used, the fishery closes once x% (e.g. 70%) of the quota has been reached = cut off points and triggers
Short term open seasons can be used to the benefit of both fishers, authorities, and the fishery’s sustainability.
BDM price tends to increase just prior to Chinese New Year (the new moon between January 21st and February 20th), an open season can be timed to take advantage of this price hike, or it could be timed prior to the school year weeks before fees are due. For authorities it allows them to concentrate efforts on certain times of the year. For sustainability of the fishery the open season can be placed outside of spawning seasons.
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Giving priority to citizens and locally registered businesses in the fishery, especially with issuance of licences helps to keep the economic benefits of the fishery within-country.
The sea cucumber fishery is rife with corruption, and it is a fact IUU fishing occurs. Precautionary measures such as closing the fishery before a quota has been reached is a pragmatic approach to things.
What are some challenges with triggers and cut off points? How quickly can this information get spread?

5. Good ideas: Harvest controls
Wet and dry minimum size limits (based on biological information)
A list of permissible species
Restrict harvesting methods
“Fishing for sea cucumber shall be restricted to hand picking or collecting either free diving or wading (reef walking) and during daylight hours, all other methods are prohibited.” “Any person found in possession of sea cucumbers in a boat that carries underwater breathing apparatus will be guilty of an offence” - Tonga
Fishers need wet minimum size limits, exporters need dry limits. Aligning national minimum size limits with regional size limits makes monitoring the fishery a lot easier, a lot of work has gone into working out what these regional size limits should be. Exports from Pacific Islands tend to go to a hub which are often Melanesian countries.
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A list of permissible species is much easier to manage than a list of prohibited species. It can make monitoring and inspection easier as authorities only have to focus on a select list of species, and this avoids issues where a new species for which there are no regulations is targeted.
* It is difficult to say if size limits have worked because for the most part they have not been properly enforced, Exports from Fiji and Vanuatu show roughly 50% of exports are undersized *
The points in quotation marks are because the wording is very practical - it is very clear and because of that enforcement of these regulations are easier. Tonga’s Plan prohibits sea cucumbers and UBA being present in the same boat, this is one of the most practical ways to enforce the fishery’s UBA ban. Many Caribbean countries do the same for spearfishing. When making regulations it is important to question how it would play out if a case is taken to court.

6. Good ideas: Export restrictions
Defining export points “Airport x and Port y”
Restricted number of export licences
Standardised labelling and packaging:
One species per package
Packaged according to grade
Labels must display the exporters licence number, number of species in the package, total weight, grade, and FAO species code
Wet and dry size limits and permissible species
Pacific island’s sea cucumber fisheries are primarily for export, therefore it makes sense that it’s fishery management plan focuses on monitoring and controlling exports.
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Defining export points also helps to bottle neck the fishery. Require all consignments due for export to be brought to a central inspection area or have several that can be well staffed, Fiji has the King’s and Queen’s wharf as well as the Nadi and Nausori airports. From here a system should be put in place in order to verify that a consignment has been inspected at one of these central locations.
Standardised labelling and packaging makes the jobs of the authorities easier, and this should be standardised across the region as consignments tend to transit through the region before making its way to the final destination, and a step in the right direction for this would be standardised FAO species codes rather than species/local/common names.

7. Possibly good ideas
Involve customs, Central Bank, tax authorities in export permiting, inspections, data collection and cross-checking
Minimum Price guide for buyers
Minimum Price guide for export declarations/export levies
Export quotas
Auctions
Compliance bonds
Export consignments must be inspected before an export permit is approved and authorities should collect data on the species, grade, and size during their inspections. In-water surveys are costly and time consuming, here the animals come to you and the information collected is still very useful.
A system is needed in which the true FOB value of consignments are captured in order for the state to collect revenue in the form of taxes on the exploitation of this natural resource.
The Solomon Islands are unique in this aspect in that they involve their central bank in this process. A key aspect of this involvement is that the exporter must pay the taxes due or provide a letter of credit for this before they are permitted to export.
It is important that the issuance of an export permit is contingent on the approval of Customs or tax authorities, and that these organisations operate independently from Fisheries.
FOB - Freight On Board, the buyer bears the cost of freight

8. The 'not so good’
Unclear structure of management and advisory committees
Undefined time frames e.g. “must review the quotas and size limits from time to time as it deems necessary”
Lack of definitions for terms used in the management plan e.g. “ranching”
Promotion of unproven approaches e.g. quotas and aquaculture
The structure of the various committees and boards that manage the fishery is important to specify. In this regard PNG and Fiji’s 2018 plan does a good job. This is important for transparency and accountability, these groups are making decisions that affect a very important fishery therefore it should be made clear who are the people on these committees, who they represent, and how many representatives there are of each. Who, why, and how many? These are the questions that should be answered when detailing management structures and roles.
Time frames - the open/closed season period, the validity of licences, how often different management groups will meet, how often should reports be produced, how often will the management plan be reviewed?
According to Tonga’s plan it will be reviewed “from time to time as it [the Fisheries Division] deems necessary”. Tonga’s plan has not been reviewed or updated since PNG’s states it will be reviewed every 2 years, which it was in 2016 and Reviewing the plan is necessary to take into account lessons learnt and new information that may affect the fishery.
If a term is used in the Plan it must be defined clearly, this is particularly true of “ranching”. Almost every plan reviewed allows for “ranching” but only two (Kiribati and PNG) actually define ranching.

9. E.g. Quota Papua New Guinea* 223% over harvest Tonga+
TAC 350 mt dry weight
2017
223% over harvest
Tonga+
TAC mt dry weight
2008
201% over harvest
2009
177% over harvest
Vanuatu*
TAC 21 mt dry weight
2016
240% overharvest
Quotas are often included as a management measure
Every country barring RMI rely on quotas of some form whether a total allowable exports (TAE) or total allowable catch (TAC), some of which have area and or seasonal restrictions.
Quotas are a good output control in theory, however given the reality of the SC fishery and the limited resources of management bodies, quotas (particularly TAC) might not be more than wishful thinking.
The experience with them in Pacific SC fisheries has not been a positive one.
Judging by the management plans alone, implementing a quota system would require substantial resources and bureaucracy on branches of government that are already poorly staffed and under-funded. Finally the figures that TAE/TACs are based on are arguable. As such, quotas should receive low priority when these management plans are implemented. To this regard the wording of Fiji’s plan is a reasonable alternative, according to it a quota system is to be given “consideration” after consultations with the SC fishery advisory committee.
Govan, A review of sea cucumber fisheries and management in Melanesia SPC, Tonga Sea Cucumber Fishery Advisory Note
* Govan, SPC, 2015

10. E.g. Minimum sizes Solomon Islands 76% below Fiji 31% below 67% below
(legal sizes)
76% below
Fiji
2014 (‘flat’ legal size)
31% below
2014 (recc. sizes)
67% below
Vanuatu
2016 (legal sizes)
>80% below
Quotas are often included as a management measure
Every country barring RMI rely on quotas of some form whether a total allowable exports (TAE) or total allowable catch (TAC), some of which have area and or seasonal restrictions.
Quotas are a good output control in theory, however given the reality of the SC fishery and the limited resources of management bodies, quotas (particularly TAC) might not be more than wishful thinking.
The experience with them in Pacific SC fisheries has not been a positive one.
Judging by the management plans alone, implementing a quota system would require substantial resources and bureaucracy on branches of government that are already poorly staffed and under-funded. Finally the figures that TAE/TACs are based on are arguable. As such, quotas should receive low priority when these management plans are implemented. To this regard the wording of Fiji’s plan is a reasonable alternative, according to it a quota system is to be given “consideration” after consultations with the SC fishery advisory committee.
Govan, A review of sea cucumber fisheries and management in Melanesia SPC, Tonga Sea Cucumber Fishery Advisory Note
MFMR 2018, Tabunakawai et al. 2017, Leopold et al. 2016

11. Some species would have gained up to 91% more biomass and 144% more value if left to MSL (MSG)
And would have also been likely to breed
AND would have fulfilled their ecosystem function for longer/more

12. Some species would have gained up to 91% more biomass and 144% more value if left to MSL (MSG)
AND would have also been likely to breed
AND would have fulfilled their ecosystem function for longer/more
And would have also been likely to breed
AND would have fulfilled their ecosystem function for longer/more

13. MSG Fisheries Technical Advisory Committee (2017) and subsequently leaders endorsed upgraded BDM MSL in February 2018.
BUT So far not adopted into any country management plan or regulations

14. Advice: Seriously enforcing Size Limits
In conjunction with very intense public awareness
Strong and exemplary enforcement at exporters
Allow at least 2-3 seasons for the message to sink in
In conjunction with short harvest season
Leading to:
Substitute the “I better take it or someone else will” mentality for one of “fattening our sea cucumbers” for the harvest

16. From bad to ugly: Governance failure in sea cumber fisheries

17. Status of management Good: management plans are good enough
Good: highly competent and (initially) motivated fisheries staff
Bad: sea cucumber management plans are not implemented effectively
Bad: Communities and countries do not get the value they so desperately need from their resources

19. For MSG countries alone the average yearly export value of USD 14 million could exceed USD million every year  

21. Why is management failing?
Technical
Political/External
Quota
(exceeded)
Survey and estimates carried out in several countries
Undermined indirectly or directly?
Size limits
(not enforced)
Biologically correct in most countries
No funding?
Licencing
(too many or criteria unclear)
Calculated value of licences increased
Interference in number and allocation of licences
Limit season / moratoria
(opened early or extended)
All countries
Political resistance to technical closure / pressure to open
Ban gears
(exemptions)
UBA banned
Political decision to exempt
Penalties
(rare penalties and prosecutions)
MCS active in all
Lack of will or obstruction of prosecution

22. Guide to undermining a good management plan
Interfere with enforcement of regulations or prosecution
Lift moratoria before stocks are recovered
Lift moratoria before regulations and management systems are operational
Exempt certain people from some regulations (e.g. UBA)
Influence licencing procedures
Avoid enforcing or implementing (e.g. minimum size limits, exporter monitoring and control).
Interfere with minimum buyer prices or export values
Don’t share information on prices or regulations with the public
Forget data collection and reporting
Deprioritize funds or staff for enforcement / MCS

23. Who benefits from undermining management?
All management plans aim to sustain or increase catches and value – management failure means:
Catches and value are decreasing.. maybe towards commercial extinction
Communities earn less and may have to live without that income
Exporters / traders (funders) move around/away or change business
Politicians?

24. Final thoughts (again)
National fisheries management efforts for sea cucumber have not been able to control a sharp decline in landings and the value generated by the fishery for communities and national government
High value sea cucumber species are experiencing decline and local extinction in many cases.
The sharp decrease in BdM is aggravated by the long period of time it takes the resource to recover.
There is little opportunity for recovery of BdM populations without major political commitments and interventions.
Lack of high level political will and in most cases the interference of poorly informed politicians overriding fisheries advice to ensure short-term gain for their constituents.