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shortening the spawning seasons (as it was done in the proposal) are elements able to negatively affect the
theoretic reproduction capacity of the East Atlantic stock in the assessment.

The full vision of the status of Atlantic bluefin tuna is heavily negative, without considering several factors, able
at least to raise strong doubts about the pessimistic assessments, like, for example, this points raised by SCRS in
its 2008 Report:

“In summary, available indicators from small fish fisheries in the Bay of Biscay did not show any consistent
trend since the mid-1970s. This result is not particularly surprising because of strong inter-annual variation in
year class strength. Indicators from longliners and traps targeting large fish (spawners) in the East Atlantic and
the Mediterranean Sea displayed a recent increase after a general decline since the mid-1970s. The Group
found it difficult to derive any clear conclusion from fisheries indicators in the absence of more precise
information about the catch composition, effort and spatial distribution of the purse seine fisheries (which
represent more than 60% of the total recent reported catch). Fisheries-independent indicators and a large scale
tagging program in the Mediterranean Sea are also strongly needed to fill major gaps of scientific information.”

It is a fact that the CPUE data from the Japanese longliners are increasing in the last five years, mirroring the
relevant increase in recruitment since 2003. But both these facts are not assessed.

Another important point raised by the proposal is that the bluefin tuna are “affected by trade”. As a matter of
fact, bluefin tuna are affected by international trade since the Roman times and maybe even from the Phoenician
times. Whenever we consider that the total catch level in the 16th century in the Mediterranean was estimated to
be close to 60,000 t (with tuna traps only)7, than we can easily realise that there is something wrong in the
present outlook and in the common understanding of this species. Even the market motivations are wrongly
stated, because the fishery is not only driven by the Japanese market and Mediterranean inhabitants do not only
consume fresh tuna meat. Of course, it is well known that many problems were recently caused by the
international trade, particularly that promoted by the Japanese market, and by the trade of IUU products, but
these are the result of weak controls, and not by the trade itself.

The proposal by Monaco includes large parts of descriptions about the bluefin tuna natural history, the biology
and ethology, but there is a lot of misleading information. About recruitment, the effects of environmental
factors remain obscure, particularly if nobody analyses them. At the same time, while it is well stated in the
proposal that the ecological extinction of bluefin tuna would result in an unpredictable effect on the prey
populations, it is simply not taken into account what the effect was on bluefin tuna of the heavy fisheries on its
prey species that is happening since decades. This approach is scientifically not the most adequate. It is again a
clear demonstration that the field knowledge is very poor and the scientific literature considered is limited to the
most recent papers, independently from well established scientific knowledge.

A lot of attention is given to the fact that the bulk of the fishery is targeting spawners and this fact heavily
affected the SSB in the last 10 years. The problem is again the poor knowledge of the history of this fishery,
because most of the historical catches over the centuries (at least in weight!) have been always spawners,
apparently without creating many problems for the bluefin tuna population. It is always a problem of balancing
the catch with the availability of the resource and among age classes. When the proposal reports that ICCAT set
quota levels well over those indicated by the assessment, it doesn’t make any reference to the unreliable data
used for it. Besides other considerations, this was taken into account by the Commission in assigning the quota
under a management plan.

If we consider the SCRS assessment as true, having between 25 to 35% overfishing of the MSY, then it should
be necessary to explain why, after more than 10 years of this situation, bluefin tuna are still alive and the purse
seine fleets are able to catch almost the full quota each year in less than 10 days! It is clear, again, that the
outlook is based on unreliable data and even less reliable assessments, as stated many times by SCRS. This
should be taken into account, together with the fact that bluefin tuna (even if it is overfished at an unknown
level) are still largely present in all the Mediterranean Sea and in the Atlantic, while the enforcement of the
ICCAT regulation is seriously becoming effective and very strict measures were adopted by the EC in 20098.

7 This estimated level, obtained by extrapolating the known catch from several traps to the total number of the traps known in the
Mediterranean Sea, is very close to the maximum estimated catch obtained by SCRS for the East Atlantic bluefin tuna stock in recent times.
8 The fishing season in 2009 was conducted with a 100% observer coverage of the EU purse seine fleet and 20% observer coverage of the
longline fleet, while many inspections have been conducted at sea by national and international patrol vessels. The tuna cages in EU
countries had 100% observer coverage. Many tuna vessels were blocked at the harbours for compliance issues and the effective EU fleet was
largely reduced. The 2009 purse seine fishing season was limited by bad weather situations, but vessels were able to catch the individual
quota in a very short time, due to the availability of the resource at sea.

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