Tuesday, June 10, 2014



American Admiralty Books Safety & Privacy Policies (Attention EU Visitors , possible "cookie" encounter ahead) 

                                                 Dissostichus mawsoni the Antarctic toothfish         (Image : Photograph by Paul Cziko, supported by US-NSF through the DeVries-Cheng Lab at the University of Illinois, Urbana-Chamnpaign. License: GNU Free Documentation License. 
The Antarctic tooth fish has a close cousin that lives a bit farther north , the "Chilean Tooth Fish". You've never heard of them?  No, you probably haven't. That's because in the market and on the menu both species are called "Chilean SeA Bass". These fish can grow to 300 pounds and live as long as 50 years. But they take 10 years to reach sexual maturity and that age coincides with the preferred "market size". So common sense tells us that the international commercial fishing fleets that pursue and market these two species are literally harvesting the next breeding generation. No fishery can long sustain that kind of pressure. Our best available research indicates that both species are in serious trouble. For the Antarctic waters around the Ross Ice Shelf this is especially troubling. Few large fish can live in these waters. The Antarctic Toothfish literally has blood that acts like antifreeze. Not all of the sea and amphibious life of the Antarctic lives on krill  (shrimp like critters) numerous species like the Leopard Seal and the Okra need larger protein sources and the fish depicted above is about it when the sea mammals aren't eating each other.  

in 2011-12, the last season for which we could find records; apparently 15 ships from 6 nations participated in the legal catch and took 3,500 metric tons of Antarctic tooth fish from the Ross Ice Shelf, a level of catch that scientists are starting to say is unsustainable. Unfortunately perhaps as much as 80 % of the catch reaching market for both species marketed as "Chilean Sea Bass" is illegally caught. This is a deep sea fishery conducted in international waters and very tough to regulate. The catch per hook weight has nearly been reduced by half just in the last two seasons. As the fish being landed shrink in numbers and size the price per pound has climbed ( last figure we had was about $25 per pound). As usual, governments are barely aware of the issue but help for the species is coming from an unexpected quarter, U.S. Chefs.

 U.S. Chefs are urging their customers to by pass "Chilean Sea Bass" until science has shown the populations are on the rebound and regulations and real workable enforcement programs are in place to assure that Chilean Sea Bass can be a sustained yield fishery. Sport fishermen can help the species recover by educating your non fishing friends, family, neighbors and co workers about the danger to this fish population and the danger its low population poses to other Antarctic species including sea mammals. We have many sport fishermen readers around the world and perhaps they could help start an EU, Latin American, and Asian Chef boycott of the species until the population has recovered and an effective regulatory program is in place. Yes, such a boycott will hurt the legal fishermen who are obeying the current rules, but the hook weight data tells us the population is in serious trouble. The law abiding fishermen will only be in worse trouble if the fishery disappears. Join the U.S. Chefs Campaign and avoid consumption of "Chilean Sea Bass". Sport fishermen are by nature fish conservationist and have saved more than one game fish species from the brink of extinction before. Give the environmentalists a hand and help save this commercial species. 

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  1. Your article is seriously incorrect and I would advise you to look into your 'research' a little further.

    As it stands, 6 separate fisheries, accounting for over 56% of the world's toothfish catch have been independently certified as sustainable & well managed by the Marine Stewardship Council (www.msc.org). A 7th fishery accounting for a further 16% is currently under full assessment. To add to that, the Monterey Bay Aquarium Seafood Watch Program (MBASWP) rates 63% of the world's toothfish as coming from a 'Best Choice' or a 'Good Alternative' fishery (www.seafoodwatch.org).

    So you have some accurate information, I will break down these fisheries that are certified as sustainable:

    1. South Georgia. Certified by the MSC in 2004. In 2013 it was rated as a ‘Good Alternative’ by the MBASWP. To protect sensitive marine environments, fishing in key areas has been banned as a precautionary measure with the specific intention of protecting benthic habitats. Fisheries management in South Georgia waters is based directly on the annual scientific advice and recommended management measures from CCAMLR (www.ccamlr.org) - an international 25 Member body that governs all fishing in the Antarctic.

    2. Ross Sea. Certified by the MSC in 2010. In 2013 it was rated as a ‘Good Alternative’ by the MBASWP. Vessels fishing in the Ross Sea apply to CCAMLR annually and are permitted to fish for the season. Daily reporting from all vessels ensures the Total Allowable Catch (TAC) is not breached. Significant areas of the Ross Sea are closed to all fishing in order to preserve biodiversity. Bird mitigation in the Ross Sea has been outstandingly successful with vessels not having caused any seabird mortality for over a decade.

    3 and 4. Heard Island & McDonald Islands and Macquarie Island. Both certified by the MSC in 2012 and in 2013 rated as ‘Best Choice’ by the MBASWP. These Australian fisheries operate over and above the strict environmental rules and regulations set by CCAMLR, and fall under Australia’s leading Harvest Strategy Policy to set conservative TACs. The fisheries are monitored by port-to-port VMS tracking as well as Australian Government observers on every trip.

    5. Kerguelen Islands. Certified by the MSC in 2013. In 2013 it was rated as a ‘Good Alternative’ by the MBASWP. French operators must adhere to strict rules and regulations that are set by French administrators, including a mandatory observer for each trip. Quotas for each vessel are set after determination of its history regarding protection of the resource and the environment, efficiency in reducing seabird mortality, respect of regulations, ability to fish the allocated quota, and respect of social and economic standards.

    6. Falkland Islands. Certified by the MSC in 2014 and in 2013 was rated as ‘Best Choice by the MBASWP. Regulations on fishing methods and effects have mirrored CCAMLR requirements, leading to zero bird mortality as a result of fishing activities over the last few years. Dedicated observers are on board throughout the year. The zone is well patrolled by air and sea, safe-guarding the fishery against illegal operations.

    To finish, your comment about illegal fish entering the United States has not occurred for several years, as all toothfish shipments must be accompanied by special CCAMLR catch documentation. Without it, the fish cannot enter the USA. The total legal catch of toothfish is around 24,000t, with the CCAMLR estimate for IUU (illegal, unregulated and unreported) toothfish being caught in international waters around 2000t - less than 10% of the world's catch.

    If you would like any further clarification on any of these points I would be more than happy to point you in the right direction

  2. In the interest of full disclosure you represent the Coalition of Legal Toothfish Operators Inc.
    PO Box 42, Mt Hawthorn,
    Western Australia 6915, Australia ,and your interest is in avoiding any complete closure of any one of the six fisheries that you describe and show on your web site.
    That's understandable, but that doesn't mean that your view makes ours "seriously incorrect". Good forensic practice requires serious caution in accepting data from a party at interest. You maintain that the six fisheries served by your members are certified well managed and sustainable by the organization that you name. The relevant fisheries are two, named in the post. There are economically disinterested ichthyologists who disagree with these organizations about the management and sustainability of two specific fisheries based on research data that indicates over fishing, reduced "average "hook size" or individual fish size, and the specific most desirable market size in relation to the species breeding cycle. You maintain that your fisheries account for 56% of the world's toothfish catch and that the CCAMLR estimates the illegal catch at about 10% that leaves 44% of the catch unaccounted for based on your numbers. Our point is simply this as Mark Twain said; "there are lies, damn lies, and statistics. We continue to laud the U.S.Chef's boycott based on reports of average hook size etc. We ceased automatically believing industry associations and government regulators long ago and certainly wouldn't be following good forensic practice if we went to your organization for "further clarification". Indeed your organization may well have a great deal of knowledge on the subject, and well it should, but in the end you are a "party at interest", not neutral experts. We have to look with the same jaundiced eye at various industry associations and regulatory bodies. Bureaucracies, in our experience, often make mistakes and are loath to admit it. The sources we examined included your own web site and the information published by other "parties at interest". But we also researched findings of academics with no economic interest. What we found convincing was two fold; the declining average "hook weight" as a sign of a fishery that is becoming unsustainable, and variously contrasting estimates of the global total catch and percentage of the catch illegally landed. We continue to back the U.S. Chef boycott of "Chilean Bass" based on our best forensic efforts. However we would never be so adversarial as to call your claims "seriously incorrect", we just note that some of your "facts" are immaterial to the two fisheries examined since they deal with an additional four fisheries, and that good forensic practice requires us to consider the source, and you are a "party at interest". As such you are entitled to a say and we thank you for writing and invite you write again if you like, keeping in mind that your opponents may respond in these pages as well. We did note that the legal and law abiding operators would be the ones to suffer from this boycott and we still think that is a shame, but unavoidable. All sides have a stake in a sustainable fishery and that can't be achieved by political pressure on the regulators to ignore science, or declaring every opinion that doesn't conform to your own economic interest "Seriously incorrect" and presenting your organization, an obvious party at interest and advocate, as the sole source of "clarification" and "right direction". Still, thank you for writing, write to us anytime.

  3. Hi there,
    Thanks for writing back and happy to chat further on this:

    1. Could you clarify which are the 'two specific fisheries' you are referring to? And which fishery is it you are referring to the average size/ average hook weight, so we are on the same page - as each of these toothfish fisheries are their own separate entities, and it is unfair to label all toothfish/Chilean seabass under the one umbrella.

    2. You said: 'You maintain that your fisheries account for 56% of the world's toothfish catch and that the CCAMLR estimates the illegal catch at about 10% that leaves 44% of the catch unaccounted for based on your numbers.'
    To clear that up: COLTO Members account for around 80% of the world's toothfish catch. The 56% that I mention, is that which is certified as sustainable by the MSC. Of the 44% that is not certified as sustainable by the MSC - 16% (Argentina EEZ) is currently under full assessment for certification, which leaves 28%: About 9% of this is caught within the Chilean EEZ; About 5% is caught within Crozet Islands (French) and Prince Edward & Marion Islands (S.African) EEZs - these 2 fisheries were significantly affected by illegal fishing in the 90s-2000s. Their quotas have been significantly cut as a result and scientific data is being gathered to further understand where these fisheries are at. That then leaves around 6% that is taken from CCAMLR New & Exploratory fisheries from high seas areas (which are still regulated by CCAMLR), and then around 8% that is unaccounted for and part of the illegal, unregulated and unreported fishing that we are trying to stamp out. Of note - there were 2 arrests of IUU toothfish vessels in Malaysia just last month, which is great news for all.

    3. Initially, you said: 'Unfortunately perhaps as much as 80 % of the catch reaching market for both species marketed as "Chilean Sea Bass" is illegally caught.'
    I hope my explanation above clears up that the figure of 80% is far from true, and as legal operators selling our fish into the market we would notice purely from supply and demand and therefore price, if there was such a large quantity of illegal fish entering the market place.

    1. http://www.colto.org/ Thanks for writing again. Your web site is in the left hand corner for reader reference. Can you identify any organization (s) that you consider your "opposition". We reported on the U.S. Chef's boycott after the fact. We base our support on our own independent examination of scientific literature. U.S. Chefs aren't into routine research into ichthyologist's issues. Someone had to have made a presentation to them. That organization (s) is the other, as yet silent in this forum, "party at interest" and "original source." We will try to respond to your latest in a separate comment (s) a little later. We have spent over 4 hours this morning to try and get our response to fit into the 4,096 character limit. So far its isn't working. We'll make as many separate responses to your last as we need to address your issues. For the time being we still don't find your responses adequate to refute the science we are looking at. More on that later. We'll clearly mark the end of our response to your second response. We invite you to use the multiple comment method as well when you feel you just can't respond in 4,096 characters.

    2. Please, don't believe us. Like you said, we have a direct conflict of interest here.

      But you should look at the scientific information that comes out of CCAMLR - the 25 nation conservation commission who set the precautionary TACs for all fisheries within the CCAMLR zone. This science is peer reviewed and not approved until consensus is reached. www.ccamlr.org

      Believe the Marine Stewardship Council, who have independently certified around 56% of toothfish as sustainable and well managed. A link to their toothfish fishery reports can be found here: http://www.msc.org/search?facet=true&fq=portal_type%3A%22Fisheries%22&SearchableText=toothfish

      Believe the Monterey Bay Aquarium Seafood Watch Program, who last year undertook an independent review of around 78% of toothfish catch, and changed their rating of 'Avoid' for all toothfish fisheries, to now 63% of world catch to be either 'Best Choice' or 'Good Alternative'. A link to their toothfish report can be found here: http://www.seafoodwatch.org/cr/SeafoodWatch/web/sfw_factsheet.aspx?gid=11

  4. We haven't answered your previous post yet. But this partially responds to both your last post and the immediate one above. By your own admission the Marine Stewardship Council has independently certified around 56% of toothfish as sustainable and well managed. Clarification: 56% of Toothfish "Fisheries" they found to be sustainable and well managed. The U.S. Chef's "Chilean Sea Bass" Boycott is about two species and two FISH POPULATIONS. Independent Ichthyologists have studied two populations of fish used to supply the U.S. "Chilean Sea Bass" market. Many agency and trade association "Fisheries" studies relate to fish populations within defined geographical regulatory units. Fish don't respect regulatory agency lines drawn on navigation charts. We have only mentioned two fish POPULATIONS directly involved in a particular market segment. You continue to flood us with sources on data on your organization's six regulated and geographically specific "fisheries". Again we don't think that your data is necessarily immaterial, but its impossible to relate it to the relevant populations and market segment.right now. One task that has us busy at the moment is relating the POPULATION studies as closely as we can to the nearest, and possibly over lapping FISHERIES of your organization. Once we have done that then a comparison of your data with the POPULATION studies that we think drive the boycott could be useful. One area that is part of the Population studies we are looking at is in the area of the Ross Shelf. Concerning that area you have already stated that it is rated a "good alternative" by MBASWP and that total allowable catch has not been breached. However the Ross Shelf is included in the studies we looked at and it is one of the places where "average hook size" ( average size of the individual fish making up the catch) is reduced which Ichthyologists perceive as a sign of a declining fishery, no longer long term sustainable. Do you contest that reduction in average hook weight is a sign of a declining fishery? Do you have data from the Ross Shelf that indicates increasing average hook weight?
    You say we should "believe" the Monterey Aquarium Seafood Watch Program. According to your own post above they recently changed their toothfish advisory has changed from "avoid" to "Best Choice" or "Good Alternative" for 63% of the world catch. That's fine but you have not established that the two populations and market segment that are the subject of the Boycott don't come from the 47% of the catch that the Seafood Watch program finds to be of concern. More to follow

  5. Now what exactly is it that we are to "believe" from the organizations you list? If we were to over simplify a bit, these organizations all publish public pronouncements that indicate more than 51% of the world's tooth fisheries are sustainable. OK, how does that demonstrate that the population studies that apparently drive the U.S. Chef's Boycott of the fish marketed as "Chilean Sea Bass" come from sustainable fisheries? At issue are two fish populations and one market segment. We see your type of argument so far all of the time in maritime personal injury cases in admiralty court. Its called the "war of the experts". The side with a real cause for correction hires an expert witness who states that the practice that caused the seaman's injury was a violation of regulations, codes, standards, authoritative literature, and verifiable good marine practice and provides citations to specifics. The defending side then goes out and hires an older expert with more credentials who asserts that the practice that caused the seaman's injury was the custom of the industry and widely accepted, and in fact intrinsically safe. The defense expert of course can't refute that the practice was illegal (violated regulations), ill advised (violated training standards etc.) because the other expert has already documented these facts and provided citations. Most often the argument for "custom of the industry" trumping regulatory requirements and training standards is a loser. But Admiralty barristers keep offering such experts because sometimes a tired and bored jury or an inattentive judge actually buys the bogus argument. We often offer opinionated posts on maritime issues without offering all of our home work. Our readers appreciate short humorous or pithy posts, not long scientific diatribes. But our long time readers know that we do our our home work and can defend our positions. More over, offered real proof that we have assumed a position in error, we have changed positions in the past after a period of public exchange of RELEVANT FACTS. Nothing that you have offered so far addresses the relevant issue whether or not we should continue to back the U.S. Chef''s boycott of "Chilean Sea Bass". One fish marketing name or "brand", from two studied fish POPULATIONS (vice "FISHERIES") believed to be in decline. We have stated that we don't believe that all facts in your possession are immaterial, or irrelevant but so far you haven't presented any relevant facts. Even if we accept your interpretation of all of the regulatory bodies and industry associations assertions that somewhere between 63% and 78% of the toothfish fisheries are sustainable and well managed that is irrelevant unless you can show that the particular sources of the "U.S. Chilean Sea Bass" supply are from sustainable sources, and that the arguments that they in fact are under regulated are false.

  6. We repeat, we back the U.S. Chef's boycott of fish labeled "Chilean Sea Bass" because the best scientific evidence is that it comes from a pair of declining fish populations of a species important to over all Antarctic biological diversity. If you can't actually refute that in accordance with a reasonable standard of evidence we suggest that you change tactics and find a new source for the supply from the 63% or so reliable fisheries and a cooperative system for our understaffed, inefficient, and generally clueless U.S. border control systems to rely on to insure that the U.S.supply is in fact and in truth from verifiable sustainable populations and well regulated fisheries. Be on point and be specific. We are not fools nor school children but hard boiled maritime experts well schooled in investigative techniques, forensics, and rules of evidence, as well has having collectively and individually many decades of at sea experience. So far you have come on like an industry association that opposes anything that disturbs your members quarterly bottom line such as a particular market boycott for any and all reasons, simply because it disturbs the bottom line. You obviously have an interest in suppressing illegal operators but based on your own various statistics offered you haven't exactly driven the illegals off the seas yet. So in response to the news of a boycott of a certain "brand" in a large but particular market driven by concern that the fish source is from a non sustainable population and some illegal fishing pressure undetected by our inept border controls you blast us with generalist, irrelevant, off point pleas to "believe" your "reliable sources" who aren't addressing the actual issue either. In their case that isn't deliberate. They have published and you are using them in a manner that lawyers call "useful language argument" where the advocate quotes from off point sources language that seems to support his position. Like the war of experts this only works on on inattentive jurors and judges. We don't mean to make you feel like you're being cross examined but you came in asserting that we were "seriously incorrect" and asserting that you had factual information. We are giving you the public opportunity in front of tens of thousands of readers to prove us "incorrect" and your facts not only true, but relevant. So far frankly, all you have offered is the standard trade association PR. Can you name your opponents? Would you like to see them subjected to the same level of scrutiny in these pages? Could you please get on point.

  7. OK, we have found at least one element of organized opposition to your opinion:
    "This assessment is contentious". by Greenpeace International Seafood Red list. We admit that we did not read this argument because as our record shows we do not trust the Green Peace organization, based on their tactics used for at sea and in harbor civil protest. However, we have to admit that we have never before examined one of their supposedly science based papers. We will have a critical look at this paper. Meanwhile in the interest of full disclosure here is a small partial list of some of the scientific papers on the subject of alleged ineffective regulation and flawed pronouncements of sustainability that we did rely on:

    Christian, C.; Ainley, D.; Bailey, M.; Dayton, P.; Hocevar, J.; LeVine, M.; Nikoloyuk, J.; Nouvian, C.; Velarde, E.; Werner, R.; and Jacquet, J. (2012). Questionable stewardship: A review of formal objections to MSC fisheries certifications. Biological Conservation, in press.

    CCAMLR (2012). Statistical Bulletin, Vol. 24. Hobart, Australia.

    Knecht, G.B. (2006). Hooked: Pirates, Poaching and the Perfect Fish. Rodale, Inc.

  8. We are not quite done responding to your previous comments yet but now would be a good point to provide your own views of who your organized opposition is so that we can examine their writings with the same critical eye that we are applying to your own right now.

  9. We've completed our examination of the Green Peace position. Like your position we can not rely on it. Green Peace basically cites many of the same sources you do but with a focus on the percentage of the global fishery that is not sustainable or well managed. We acknowledge that somewhere between 37% and 22% of the global fishery by the very authorities you cite is not sustainable or well managed. We have our reasons for suspecting these "authorities" of favoring the more optimistic view but we happen to think that humans have to eat.and what such figures indicate is that better regulation , enforcement, and research into the global fishery is needed, not that all commerce in the toothfish fishery should stop which appears to be the Green Peace position. While we're certain that Green Peace backs the U.S. Chef's boycott of "Chilean Sea Bass" none of their routinely available published data was on point in addressing the actual relevant fish populations, and the particular market sector. So basically we reject your (COLTO) position that illegal fish never entered the U.S. market and could not have as unsupportable, and we reject the Green Peace position that the Global fishery should be outlawed. We continue to believe that it is more probable than not that the U.S. supply of fish marketed under the name "Chilean Sea Bass " included some illegal catch and that much of it came from two studied, specific declining populations. The U.S Chef''s boycott appears reasonable and targeted, and a temporary measure designed to draw attention to a specific management problem in two specific fish populations. It is a measure that can be easily lifted when the problems are addressed instead of being excused and denied. We will publish a new post on our position tomorrow. We suggest that COLTO, Green Peace or anyone else who would like to comment do so in the comment section of that next post. The new post will also have a link to this post so that the interested reader may review the entire correspondence string easily.

  10. Noted that one of your studied fish populations/fisheries is the Ross Sea. Could you please advise on the second fishery you are referring to so we can attempt to respond.

  11. We opened a new Post on this as the comments were getting pretty long and involved.The second fish population described in the studies appears to be the EEZ of Chile or parts there of and adjacent international waters ( scene of some of the alleged illegal fishing). We also published more on your organized opposition, as we rejected their findings as being off point and like yours dealing with the entire fishery instead of two specific populations, marketed under one particular name. We back the Chilean Sea Bass boycott of the U.S. Chefs, not any kind of total band on tooth fishing. Your opposition actually quotes many of the same sources you do but where you focus on the regulators claim that a majority of the fisheries are sustainable fisheries, your opponents focus on the large percentage that even the regulators indicate are problematic. There are certain groups of environmentalists who simply don't want people on the planet, much less eating fish. We're not in that group. But your group seems satisfied with a 63 to 78% sustainable fisheries and willing to fight tooth and nail to avoid any spot closures. Both sides hurl the same statistics at each other, slanted differently. We still believe the Chefs have been reasonable and the independent data supports their position. We suggest that you read our entire Saturday June 14th post before responding.