1. Problems with the traditional management of fish resources
It is clear to all involved in the management of fish resources that the requisite scientific knowledge will always be lacking. Although some of these knowledge deficits can be addressed, others have to be accepted, since they are either the result of limited data about the past, or a consequence of now accepted limits to knowledge of ecological systems. Nevertheless for resources managed by an annual global allocation (TAC), a precise quantitative decision has to be made each year. In other words a precise number has to be produced from the scientific process, regardless of the imprecision of scientific knowledge.
In addition to the scientific uncertainty, there is a large scope for political interference in the process. Different users have conflicting interests, control and enforcement are less than perfect, there is often unrecorded fishing, and there is a high degree of climatic and environmental variability. Some argue that there is also a need to reduce the amount of scientific time and effort spent on annual TAC deliberations in order to make research resources available for “more important” issues.
2. The utopian solution
It is therefore not surprising that fisheries resource managers around the world are looking for a management approach that will be safe, workable and acceptable even under such diverse and troubled circumstances. What should such a management program consist of?
- It should have a very specific target, for example, a biomass level 30% larger than at present, or alternatively, a biomass which is 20% larger than the biomass which produces maximum sustainable yield.
- It should have a timespan over which the target should be achieved, for example 10 years.
- It should include a TAC setting mechanism which allows this target to be reached in the specified timespan.
- The TAC setting mechanism should be self-correcting or include a self correcting component, such that if incoming resource abundance indices perform in an unexpected way, indicating that previous assumptions about resource productivity and/or size were incorrect, the TAC will adjust to keep the resource biomass on track towards its eventual target.
- Interannual changes in TAC should be not too large. Relative stability in annual allocations ensures the efficient utilisation of existing fishing and processing resources, and prevents over-capitalisation.
The above five points are term together operational management procedures or OMP in short. Indeed in the new South African Marine Living Resources Bill Chapter 2 6c it is say “ The forum (the Consultative Advisory Forum - CAF ) shell advise the Minster on any matter referred to it by him or her, and in particular…(c) The establishment and amendment of operational management procedures including management plan;” .
3. How OMP works?
An important impetus behind the development of the OMP concept is the uncertainty inherent in biological systems. Uncertainty means that any trend in the data has to be dealt with carefully, because it could be misleading. Errors will be made if one either over responds or under responds to the incoming data. Coping with uncertainty like this involves intelligent hedging. In the development of an OMP one has to be explicit about exactly how this hedging is done.
The OMP itself is relatively simple formula or model which are self-correcting by adjusting the annual TAC in response to changes in resource indices in a way that keeps the resource biomass on its desired path. Examples for such indices can be: the commercial catch rate, survey biomass estimates, catch age or size structure, tagging data and catch sex ratios.
Although the OMP is as was said above is often represented by a relatively simple formula, the rational behind its development is complex both in concept and in its numerical sophistication. There is a close relationship between the OMP and its underlying development and rationale. Optimally the development of an OMP should follow a process which was proposed at the time by the International Whaling Commotion and which include the following steps:
- Obtain an estimate of resource dynamics and current size from the best available interpretation of the available data. This will be chosen as “reality” for the purpose of evaluating different OMPs.
- Obtain estimates of uncertainty in the available data (i.e. extent of fluctuations around true values and trends).
- Identify promising candidate OMP formulae.
- Adopt the model in (1) as a description of reality, and use this model to project forwards. Use the ‘uncertainty’ information in (2) to generate typical data on resource performance used in management. This is like throwing the dice.
- Run the model ahead for a large number of ‘throws of the dice’, and summarise the performance of different candidate OMP formulae with respect to measures like average catch, % change in the “true” biomass, variability in the TAC.
- Explore the implications of certain radical future events, e.g. recruitment collapse, using different OMPs.
- Explore the implications of different ‘realities’ using different OMPs.
- Choose the OMP which performs ‘best’. The term ‘robust’ is applied to a formula that achieves goals in the face of the range of uncertainty that one has to deal with.
- Use the ‘best’ OMP to calculate the TAC over the next 3 to 5 years, hereafter a new OMP will be developed and implemented.
4. ‘Traditional’ management practice versus an OMP as it is defined in the new Bill
The OMP concept arose partly in frustration with the traditional management approach where, frequently, no new scientific insights are placed on the table each year, but the same issues are debated over and over again, with no real benefit for resource management. In the end a quantitative decision has to be made, and this must normally be based on the same limited set of data with one annual update.
The OMP cuts out these “meaningless” debates. This is a benefit if you accept the deeper philosophical argument that fisheries science does not really advance meaningfully on an annual time scale, only on a decadal scale. With OMPs the short, medium and long term risks of a particular management approach are quantified. This is not possible when any ‘ad hocness’/ human intuition/ compromise/ negotiation/ or ‘management by committee’ takes place.
As such one cannot perceive an OMP as being a simply more scientifically comprehensive but nevertheless conventional management approach. Indeed in the new South African Marine Living Resource Bill, OMP is defined as:
“a scientifically evaluated process defining the manner in which the available data on a resource is used to determine the level of control measures to be detailed in fisheries regulations to manage such resource in terms of sustainable harvesting, rebuilding strategies, etc. The procedure must therefore set the rules which specifies the data to be collected, the analysis of such data, the management actions to be taken as a result of such analysis, and the means of analysing the results of such actions”
A superficial reading of the above does not suggest anything very different from previous ‘traditional’ management practice. This is not true. Very few people (scientists or industry) seem to actually understand the intent of the OMP. The questions one should ask him/herself when comparing traditional management approach to an OMP approach should set by careful examination of the OMP as it was define in the new Bill.
- Is the traditional approach to fisheries management is a “a scientifically evaluated process”?
- Does the traditional approach define “the manner in which the available data on a resource is used to determine the level of control measures to be detailed in fisheries regulations to manage such resource in terms of sustainable harvesting, rebuilding strategies, etc.” ?
- Does the traditional approach “set the rules which specifies the data to be collected, the analysis of such data, the management actions to be taken as a result of such analysis, and the means of analysing the results of such actions”?
This is to illustrate that a more careful consideration of the definition suggests a more profound departure from traditional practice. For example during the implementation period (3 to 5 years):
- There can no longer be annual scientific debates about resource status and appropriate management action.
- One can no longer exercise any common sense in management decision making.
- The TAC may run counter to any intuitive feelings about resource performance.
5. Potential problems with the OMP philosophy
One should bear in mind that the OMP, in its extreme form is a relatively new concept. In international terms it is an untested procedure. To date South Africa is the only country in the world where this new and untested approach is already written into the fisheries policy. Its effectiveness has therefore not been proved elsewhere in the world, and in South Africa it seems to be as much politically as scientifically motivated. It seems that in South Africa the motive behind the introduction of an OMPs includes in addition to “pure” scientific objectives also none-scientific objectives such as the desire to:
- to reduce the amount of time and effort and debate required for the determination of the TAC.
- to reduce the industry’s options for participating in annual TAC decisions either politically or technically.
- to impose more conservative management regimes
Although on paper, there are many theoretical and practical benefits of OMPs, in practice there are a number of problems:
- OMPs may not really save time because the high risks of long term commitments forces greater pressure on technical deliberations.
- Short-circuiting of the OMP development process then becomes a problem. There is a lower degree of scientific vigilance during the period of implementation of the OMP – no pressure to remain scientifically critical. This in some cases could prevent innovative solutions which could potentially change the entire scientific paradigm, from being given sufficient consideration.
- In addition OMPs only deal with the TAC, but many other critical management issues have to be addressed (minimum size and gear). OMPs draw attention and technical resources away from these issues. TACs calculated from the OMP are often counterintuitive and there is no room for common sense or human input during their implementation.
- Evaluation of the merits of different OMPs is often based on subjective and hence political judgements.
- Commonsense issues are lost in the complexity of the OMP philosophy.
- In the new Bill the minister has the power to ignore the OMP produced TAC and to set a different TAC. These minstrel powers if it be use are basically nullify the entire OMP philosophy.
- No changes in the OMP are allowed during the implementation period unless there are ‘exceptional circumstances’. This means that short term changes in fishing strategy due to ever changing market requirements or due to oversupply of fish which might effect CPUE cannot be discussed while an OMP is in place.
- This is also the case with regard to desirable changes in fishing gear such the effective codend mesh size in case of trawling or desirable changes in fishing regulations such as the minimum legal size of lobster caught. For example it is safe to assume that if at the time of the crises in the west coast rock lobster resource in the early 1990’s the management of this fishery was govern by an OMP it is unlikely that the radical reduction in the legal size of lobsters caught, which effectively saved the industry and greatly benefit the resource, would be allowed. This might mean that under certain circumstances the industry would have to accept a reduced TAC even though other management options might prevent the need for such a reduction.
6. What is reality?
The complexity of the OMP concept, can be abused to bypass important scientific debates with substantial implications for the industry. Consider the situation where there are two unresolved views on resource dynamics:
View 1: The pessimistic view which assume that resource biomass is small and resource production is low and there little or no potential for resource biomass or TAC growth under the TAC.
View 2: The optimistic view which assume larger and more productive resource with more potential for growth in resource biomass or TAC.
Let say that the management objective is to achieve a resource rebuilding of 50% over ten years. The advocate of the pessimistic view argues for an OMP that on average achieves 50% growth in resource biomass, when View 1 (the pessimistic one) is chosen as “reality”. The same OMP would however achieve 65% growth over 10 years if the View 2 the optimistic one is to believe. The argument of the pessimists will be that their OMP is fairly robust to the uncertainty about View 1 or View 2 and stick with a TAC based on the OMP launched under the pessimistic view.
What the pessimists do not show is what the TAC could be if View 2 is chosen as reality which is an additional 1.5% of TAC every year (~(65%-50%)/(10 years). This can be translated, for example, to about extra 300 tons per year in the case of the West Coast rock lobster resource.
In the reality of South Africa the government agency is more often then not the advocate of the more conservative view (this is probably a good thing). But this allow them to give higher political weight to View 1. As such even that the basic argument is that the proposed OMP is robust to any of the above views they insist that View 1 will be the formal view and do not prepared to shift to using View 2 as reality – which one should be prepared to do if the OMP is truly robust.
The above argument might sound complex to the lay person but in reality this is a very critical issue which often get lost in the complexity of the OMP deliberations. As a result industry people often denied the opportunity to meaningfully effect the TAC setting process which is solely driven by adopted or the “formal” reality rather then on range of possible realities as the case should be. Under the OMP philosophy they losing this ability for the entire implementation period which is considerable.
7. IWC examples regarding the OMP development process
It is relevant to this article to review the process followed by the International Whaling Commission (IWC) in the development of the Revised Management Procedure (RMP), which is where the OMP concept originated
a) Time scale
In 1979, serious doubts were expressed about the efficiency and reliability of the management program at the time, the New Management Procedure (NMP).
At a meeting in 1982 the IWC agreed to stop commercial whaling for a period of 10 years with effect from 1986. As part of this agreement, the IWC undertook to make a “comprehensive assessment of the effects of this decision (the moratorium on whaling) on whale stocks and to consider modification of this provision and the establishment of other catch limits”.
This led to a process in which the scientific committee considered alternative management procedures for whaling, culminating eventually in the RMP.
The RMP was finally adopted by the IWC in 1994 (some 12 years later, or 8 years after 1986 when the management procedure idea was first mooted).
The RMP has not been implemented because of strong political disagreements and it is not clear if it will ever be implemented. No field results from the implementation of the RMP are available and its workability is still untested in the real world.
b) Development process
(extracts from an article by G P Donovan 1995 – the scientific editor of the IWC).
At the start of the development process five procedures were proposed and subjected to thousands of trials to ‘test their robustness’ – to see if they worked.
Of course, initially the testing was relatively simple – to see if they worked when they had the information they thought they would have at the levels of accuracy they expected. However, the procedures had also to work when knowledge was not perfect and data were limited i.e. the procedures had to be realistic in terms of likely scientific knowledge and take into account scientific uncertainty.
The various suggested procedures had to 'pass' a series of trials of increasing difficulty…. The competition among the alternative procedures led to dramatic improvements in their ability to cope with the trials and some procedures were improved by incorporating elements from other procedures…..In the end, after several years of work …..matters were narrowed down to just two essential parameters….
However, we have not yet discussed one very important aspect of any management procedure - by what criteria do you judge if it 'works’ and given that it works how do you select among alternatives? In other words we must define the objectives of the procedure. To some extent it is relatively easy to arrive at 'extreme' objectives for any natural resource:
that the resource is not driven to extinction;
that the maximum sustainable harvest is achieved…..
The setting of objectives and the relative weight given to those objectives (the trade-offs) require political rather than scientific decisions, although the scientist clearly has an obligation to explain the implications of any decisions that might be taken to the politicians, for example by providing them with a range of specific options.
c) Conclusions from the above examples
From the above it seems that 12 years have passed between the time that the management procedure concept was first proposed and its adoption by the IWC.
It initially involved five different procedures which were subjected to thousands of robustness tests. There was also a clear understanding that the weight given to different trade-offs was political rather than scientific.
In addition, the final procedure was submitted for international peer review by nine North American scientists who were not connected to the IWC or to the whaling debate.
It seems that in South Africa there is an attempt to short circuit the OMP development process compared with the development of an OMP for whales. Although a direct comparison might be unfair since the IWC deals with many whales species, spread over many oceans at extremely politically and emotionally loaded environment it interesting to note to what pain the committee went before selecting an OMP. The reason is that the IWC recognise the large risk involve in a management concept it that prevents any possibility of revision for a considerable period of time. Indeed the IWC interpretation of an OMP is far less stricter then the one proposed in South Africa and it include many mechanism for in-period revisions if this found to be necessary.
8. General recommendations regarding OMPs
- Complex problems require, more often then not, complex solutions. An attempt to provide what might seems to be a simple TAC setting mechanism in a very complex and variable biological and political environment although very attractive in concept carry many risks.
- Nevertheless there is a clear need to remove some of the unnecessary wrestling often involve in the setting TAC. It is also useful that fishermen, individuals and companies will appreciate and accept the need to manage fish resource on a medium and long term basis and to remove the level of “ad-hocness” often associate with the determination of TAC. As such we support in principle the implementation of a medium term management plan which includes an OMP as an important component.
- Saying the above the OMP process should be link to higher level of securities of fishing rights. It is inconceivable that fishing companies and fishermen will be require to assume long term approach into management of fish resources while they enjoy very little or not at all long term security of their fishing rights.
- Members of the fishing industry should also be presented with clear biological objectives for the OMP which are distinct from economic and political objectives. In cases where the OMP objectives are define in economic terms such as bigger resource in order to improve catch rate rather then to reduce biological risk members of the fishing industry should have the last say about the OMP target.
- There are many very technical elements in the development of an OMP this is not say that input from members of the fishing industry should be limited to setting up the OMP targets. As was demonstrated above the assumed reality on the basis of which OMP is develop is often more critical then the OMP formula which was selected. The development of such reality should be done through intensive consultation with industry members. The industry experience and knowledge is indispensable and cannot be replace by mathematical models and simplistic computer simulations.
- OMP shouldn’t be linked to the elimination of the process of critically re-examining base data and the stock assessment model each year, and accommodating new scientific findings where this is justified. This critical process should be the duty of both, industry representatives and government scientists. This does not means reopening of the debate every year since the ground rules and TAC setting formula can still be use of no fundamental findings which make the present OMP redundant are presented.
- The notion that if an OMP is to be change the “burden of proof” is lie on the fishermen shoulders is wrong. The critical process as suggested above is the duty of the people involve in the fishery management process including government scientists, academics and industry representatives.
- An OMP approach shouldn’t become a ‘push of the button’ management of the resource over the next five to ten years, or even the next three years. Such an approach will inventible leads to the overlooking of alternative.
- In cases where views about the resource and/or the propose OMP are drastically differ an outside (preferably international) peer review can be useful. Such panel of reviewers can bring new ideas and knowledge without being tented with the local politics and diversion of interests.
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