Last month we introduced you to the concept of management procedures in fisheries management, often referred to as Operational Management Procedures (OMPs for short). We informed you that OMPs are the latest scientific invention in the war against human imperfection and the natural volatility of biological and ecological systems. OMPs, the quantitative scientists tell us, will deal with the inherent uncertainty in fisheries data and in associated biological and/or ecological projections. This is achieved, we are told, by incorporating negative feedback into the formula, such that once the target is locked on, the formula takes us there by automatically and dynamically self-correcting catches in response to changes in resource abundance indices.
A few years ago a leading fisheries scientist compared an OMP to an automatic pilot in which, in addition to routing information, additional information is fed in to make it possible to adjust to a wide range of unexpected events during the flight. In fisheries terms such events might include, inter alia, substantial fluctuations in recruitment, natural mortality, growth rates and levels of poaching. At the same meeting, we asked this same scientist whether he would be willing to be a passenger on such an aeroplane if there was no human pilot available to take over if and when the autopilot encountered a situation which was not included in the list of pre-programmed eventualities, or if the autopilot software simply malfunctioned.
The answer was no. This, in a nutshell, is our main concern with the concept of OMPs. How much can one safely leave to a purely formulaic process to replace management decisions, and when, if at all, is it appropriate to take over from the formula. This question lies at the heart of our next article, but to tackle it we need a deeper understanding of the difference between OMPs and traditional approaches to fisheries management.
The OMP concept arose partly out of frustration with traditional management approaches 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. The questions one should ask him/herself when comparing traditional management approaches to an OMP based approach should be:
- Is the traditional approach to fisheries management 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.
One should bear in mind that the OMP, in its extreme form is a relatively new concept. Although applied in a number of South African fisheries, in international terms it is an untested procedure. Its effectiveness has therefore not been proven, and it seems to be as much politically as scientifically motivated. It seems that the motive behind the introduction of OMPs may include, in addition to “pure” scientific objectives, the following non-scientific desires:
- 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 to OMPs, in practice there are a number of problems:
- OMPs may not really save time because of the high risks of long term commitments – this forces much greater pressure on technical deliberations at the OMP selection stage.
- There is a lower degree of scientific vigilance during the period of implementation of the OMP, i.e. less pressure to remain scientifically critical. In some cases this may retard the formulation of innovative and paradigm breaking management solutions.
- In addition OMPs often focus only on a single management device, e.g. TACs, whereas in reality many other critical management issues have to be addressed – e.g. minimum size and gear regulations.
- Our experience has been that commonsense issues are frequently lost in the complexity of the OMP philosophy. TACs calculated from the OMP are often counterintuitive and there is no room for common sense or human input during their implementation.
- The evaluation of the merits of different OMPs is often based on subjective and hence political judgements.
- No changes in the OMP are allowed during the implementation period unless there are ‘exceptional circumstances’. This means, for example, that short term changes in fishing strategy due to changing market conditions with implications for the interpretation of CPUE data cannot be discussed while an OMP is in place.
- For example, we would argue that if at the time of the crises in the South African West Coast rock lobster resource (early 1990’s), the management of this fishery was governed by an OMP, it is unlikely that the radical reduction in the legal size of lobsters caught, which effectively saved the industry and greatly benefited the resource, would have been permitted. This suggests 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.
