1 THE FAO PRECAUTIONARY APPROACH AFTER ALMOST 10 YEARS: HAVE WE PROGRESSED TOWARDS IMPLEMENTING SIMULATION-TESTED FEEDBACK-CONTROL MANAGEMENT SYSTEMS FOR FISHERIES MANAGEMENT? ANDRÉ E. PUNT School of Aquatic and Fishery Sciences, Box 355020 University of Washington, Seattle WA 98195-5020 E-mail address: aepunt@u.washington.edu ABSTRACT. It is almost ten years since the FAO Technical Consultation on the Precautionary Approach to Capture Fisheries took place in Lysekil, Sweden. One outcome from this Technical Consultation was a set of guidelines on the precautionary approach to capture fisheries and species introductions. These guidelines include the need to incorporate harvest control rules in management plans. Harvest control rules should specify what action is to be taken when specified deviations from the operational targets and constraints are observed. The specification should include minimum data requirements for the types of assessment methods to be used for decision-making. Combinations of harvest control rules, assessment methods and data collection schemes are referred to as management procedures. It is now well-recognized that using management procedures is likely to lead to improved conservation of fishery resources, and that they should be evaluated to assess whether they are likely to achieve the goals for fishery management given the types of uncertainties that are likely to frustrate this venture. In general, evaluation of management procedures has been based on simulation modeling. This paper reviews the progress that has been made in various fisheries jurisdictions in terms of implementing management procedures, and why and where it has proved difficult or even impossible to implement management procedures. KEY WORDS: Management procedure, precautionary management, fisheries, uncertainty. 2 1. Introduction. Fisheries management involves developing and implementing regulations that aim to achieve fishery management goals. These goals are as diverse as the fisheries themselves, but generally include conserving the resource (for future generations), achieving high long-term catches and minimizing socio-economic dislocation. The goals for fisheries management are usually in conflict to some extent so that fisheries management decisions inevitably attempt to achieve some socially-desirable trade-off among these goals. Making fisheries management decisions would not be difficult if the decision makers had perfect information about the resource, the users and the marine environment, but this is never the case. As a result, these decisions need to take uncertainty into consideration. Uncertainty can be used to argue for lower exploitation rates (to protect the resource) or for higher exploitation rates (to avoid unnecessary economic hardship in the face of uncertain information that may point to a concern about the status of a resource). The well-known failures to achieve conservation-related management goals can be traced to either a choice by the decision makers to manage for a trade-off that places too little emphasis on resource conservation, or to forgo management actions until the evidence that there are resource conservation concerns becomes very strong. The difficulty when choosing an appropriate balance between resource conservation and exploitation has often led scientific management advice to focus on “biological (or fisheries) reference points”. A variety of biological reference points have been developed (e.g. Sissenwine and Shepherd [1987]; Hildén [1993]; Leaman [1993]; Rivard and Maguire [1993]; Quinn and Deriso [1999]). Biological reference points tend to be based either on catch (e.g. MSY – Maximum Sustainable Yield), spawning or fishable biomass (e.g. BMSY – the biomass at which MSY is achieved), or the level of fishing-induced mortality (e.g. FMSY – the fishing mortality rate at which at which MSY is achieved; Fmax – the fishing mortality rate at which yield-per-recruit is maximized; and F0.1 – the fishing mortality rate at which the slope of the yield-per-recruit function with respect to fishing mortality is 10% of that at F=0). While it is now recognized that several of the commonly used fishing mortality-based reference points lead, in fact, to unsustainable use for some species (e.g. Dorn [2002]; Punt [2000]), reference points continue to provide a means of guiding fisheries management decisions in many jurisdictions. Unfortunately, most of the conventional biological reference points (e.g. FMSY, F0.1, FMAX) fail to take account of uncertainty, specifically that associated with the data used for their calculation. The FAO Technical Consultation on the Precautionary Approach to Capture Fisheries which took place in Lysekil, Sweden in 1995 (FAO [1996]) can be considered one of the most important fisheries meetings of the 20th century. One outcome from this Technical Consultation was a set of guidelines on the precautionary approach to capture fisheries and species introductions. These guidelines include (but are not restricted to) the following principles: a level of precaution commensurate to risk should be applied at all times to all fisheries; potentially irreversible changes should be avoided (to maintain options for future generations); 3 undesirable outcomes should be anticipated and measures be taken to reduce their likelihood; corrective measures should be applied immediately and be effective within an acceptable time; precautionary limits should be placed on fishing capacity on highly uncertain resources; all fishing activities should be subject to prior authorization and periodic review; the burden of proof should be appropriately (realistically) placed; standards of proof commensurate with the potential risk to the resource should be established; and the approach should be formalized in a comprehensive legal and institutional framework. The precautionary approach has now been adopted widely, including by a number of fishery management organizations (CCAMLR, IPHC, IWC, ICES, NAFO, NASCO, ICCAT, MHLC, SEAFO) as outlined by FAO [1996]. One of the elements of the precautionary approach to fishery management is “A management plan must indicate which management measures are to be applied, and the circumstances under which the measures are to be varied. This should involve the formulation of decision rules, which specify in advance what action should be taken when specified deviations from the operational targets and constraints are observed. The specification should include minimum data requirements for the types of assessment methods to be used for decisionmaking”. The precautionary approach further notes that “To be precautionary, decision rules are required for responding to unexpected or unpredictable events with minimum delay. All foreseeable contingencies should be considered when developing the plan” and “The precautionary approach is made more effective by development of an understanding of the sources of uncertainty in the data sampling processes, and collection of sufficient information to quantify this uncertainty. If such information is available it can be explicitly used in the management procedure to estimate the uncertainty affecting decisions and the resulting risk. If such information is not available, a precautionary approach to fishery management would implicitly account for the unknown uncertainty by being more conservative”. Decision (or harvest control) rules have often formed an integral component of the way in which fisheries management advice has been developed. For example, the Canadian Atlantic Fisheries Scientific Advisory Committee (CAFSAC) based TAC recommendations on a target fishing mortality rate of F0.1, given Canada’s adoption of F0.1 as its target fishing mortality rate in 1977 (Rivard and Maguire [1993]). This is a very simple example of a constant effort-based harvest control rule. Nevertheless, implementation of even this harvest control rule requires that an age-structured stock assessment can be conducted. Although this policy was in operation for many years, Rivard and Maguire [1993] report that fishing mortality off eastern Canada seldom dropped as low as F0.1 in actuality due to the socio-economic impact to which this would have lead. A somewhat more conservative constant effort-based harvest control rule than F0.1 was applied to develop TAC recommendations for the Cape hakes (Merluccius 4 capensis and M. paradoxus) from 1977-95 (Payne and Punt [1995]; Geromont et al. [1999]). The harvest control rule used to provide recommendations for the management of groundfish resources off the U.S. west coast includes several precautionary elements. For example, there is a population size below which there is a requirement to develop a rebuilding plan that will return the spawning output to a proxy for BMSY within a prespecified number of years. Perhaps the major problem with this, and several similar, harvest control rule relates to the general inability to FMSY. Initially, a proxy for FMSY for west coast groundfish of F35% (the fishing mortality rate at which spawning output-perrecruit is reduced to 35% of its unfished level) was adopted, based on analyses by Clarke [1991]. However, this fishing mortality rate over-estimates FMSY for many of the low productivity rockfish (Sebastes spp.) species off the U.S. west coast (Dorn [2002]) with the result that a number of west coast rockfish species have been depleted to alarmingly low levels (Ralston [1998]). There are many reasons for failure of harvest control rules to prevent depletion to undesirably low levels. Amongst these are that most harvest control rules were never evaluated formally to determine whether they are sufficient to achieve the goals for which they were designed, given the uncertainties inherent in the system being managed. As noted by Kirkwood and Smith [1996] “Even though a management strategy may incorporate elements that are intended to make it precautionary .. it does not follow that it will actually be precautionary in practice”. Simulation has been suggested as the means to determine the extent to which candidate harvest control rules can satisfy management goals (Kirkwood and Smith [1996]; Cooke [1999]; McAllister et al. [1999]). Butterworth et al. [1997] define a management procedure as a set of rules which utilize pre-specified data to provide recommendations for management actions, where the performance of the rules has been evaluated using simulation. Management procedures therefore appear to be a way to implement harvest control rules in a manner that satisfies the requirements of FAO’s precautionary approach to fisheries management. This paper provides an overview of how management procedures are evaluated using simulation and then reviews the extent to which the use of management procedures for fisheries management has increased from 1993 (prior to the Technical Consultation which led to the FAO precautionary approach), to 1999 (the year in which a special issue of the ICES Journal of Marine Science on including uncertainty in management systems (Stokes et al. [1999]) was published), to the present. It then considers the reasons for the adoption (and non-adoption) of management procedures and hence highlights the challenges that will need to be overcome if management procedures are to be adopted more widely for fisheries management. 2. Management procedures and their evaluation. The process of evaluating management procedures by means of simulation involves a number of steps (Fig. 1). These steps have been summarized and discussed by several authors (e.g. Kirkwood and Smith [1996]) and so only an overview is provided here. 5 Specifying the management goals and representing them quantitatively is amongst the most difficult steps in the process. This is because the management goals that can be derived from fisheries and other environmental legislation are often very broad (Sainsbury et al. [2000]) and because managers often have difficulty making explicit statements regarding their goals (Kirkwood and Smith [1996]). The difficulty defining management goals quantitatively is compounded when goals not related to maintaining (or enhancing) single species stocks and fisheries are involved. The operating model (the model that represents the truth for the simulations) needs to be sufficiently complicated (in general much more complicated than that used as the basis for management advice) to capture all of the key biological processes and uncertainties to which an ideal management procedure would be robust. Several operating models rather than just one are usually developed so that the extent to which the set of candidate management procedures are robust to uncertainties can be examined. The operating model must also be able to generate the types of data available for use by the management procedures in a realistic manner. The first management procedures are conventionally considered to be those developed for anchovy (Engraulis capensis) off South Africa (Bergh and Butterworth [1987]; Butterworth and Bergh [1993]). The evaluation of these management procedures considered a narrow range of uncertainties (primarily process and observation error). Subsequent evaluations have considered a much broader range of uncertainties (see, for example, the review by Butterworth and Punt [1999]). The number of uncertainties considered in operating models is increasing, with observation, process, model and implementation uncertainty (Francis and Shotten [1997]) all now included regularly when evaluating management procedures. However, most of the operating models upon which management procedures have been based have not considered multi-species interactions and spatial factors (Schweder et al. [1998]; Punt et al. [2005] and IWC [2004a] being noteworthy exceptions). In most cases, a small set of factors that are likely to impact the performance of the candidate management procedures to the greatest extent (e.g. the extent of sampling error when conducting surveys; the value for key parameters such as natural survival), and specific levels for those factors, are selected and these used to a create a “base case” set of simulation trials. The levels of the factors that make up the base-case simulation trials are often those that are “most plausible” and are consequently given greatest weight when a management procedure is selected. The sensitivity of the results to alternative (often less plausible) specifications for the operating model is examined to determine the extent of robustness to unlikely, but highly consequential, factors. Although this base-case-andsensitivity test approach has been used most commonly, some evaluations of management procedures (e.g. Schweder et al. [1998]; Polacheck et al. [1999]) have been based on a more balanced design of factors and levels to enable the impact of interactions among factors to be determined quantitatively. A management procedure consists of a combination of the data to be collected, how those data are to be analyzed, and how the results of the analyses are be used to determine a management action. As a result, the management procedures developed to date have 6 tended to be very case-specific. Two basic classes of management procedures exist: those based on fitting population dynamics models to data and those that involve a more empirical approach to determining management actions. The bulk of management procedures implemented to date are model-based. This is primarily because model-based approaches have been shown to outperform more empirical approaches in terms of reducing variability in catch levels (IWC [1992]). Empirical approaches (based primarily on following trends in abundance) have, however, also been adopted fairly extensively because they tend to be simpler, and hence easier to explain to decision makers. 3. Reasons for the adoption of management procedures. The reasons for adopting management procedures have varied, but generally include the ability to address uncertainty in all aspects of the management and assessment process, and consequently to identify the data and analyses needed to be robust to uncertainties. These reasons also usually include that adoption of management procedures forces decision makers to define management goals clearly and quantitatively, that an evaluation of alternative management procedures leads to a clearer representation of the trade-offs inherent in managing any natural population, that all parties are forced to take a long-term view of managing the system, and that all stakeholders have greater certainty/transparency regarding the future. Management procedures provide certainty to different stakeholders in different ways. For example, industry consider that one of the advantages of using management procedures is that management arrangements will not be changed arbitrarily given a slight drop in, for example, an abundance index. Conservation stakeholders on the other hand are given greater certainty that reductions in, for example, TACs will occur if there are signs of resource depletion (or lack of sufficient increase in biomass for depleted resources). The use of management procedures replaces the “default” of “no change” by a pre-specified reduction in, for example, TAC if there are signs of reductions in abundance, but there is no scientific consensus on whether abundance has really declined. Use of management procedures to determine management actions is therefore pro-active rather than the norm for fisheries management decisions which has generally been reactive and is clearly consistent with the FAO Precautionary Approach. In some jurisdictions (South Africa, Namibia, and New Zealand), management procedures are seen as a way to reduce the need for annual formal assessments and the annual debates on recommendations for management actions because a management procedure can operate on “auto-pilot” for several years. There appears to have been a reduction in the need for formal stock assessments in New Zealand, while routine annual assessments of hake, sardine, anchovy and west coast rock lobster in South Africa are simpler because, rather than each annual assessment involving many runs of the assessment model, annual assessments now usually only involve a single “reference case” run, in particular to check that the resource remains within the bounds for which the management procedure was tested. The time for assessments in South Africa to be conducted has been reduced further because there has been no need to “haggle” over how the results of any assessment pertain to the size of the TAC. 7 Management procedures that include specified data requirements provide some leverage to ensure that management agencies and stakeholders commit to consistent methodology and funding to provide the information needed to apply the management procedure. The focus on data requirements can, however, have negative consequences in that funding could increasingly be focused towards the data needed to apply the management procedure and less on the basic science needed to qualitatively change the understanding of the system (and hence possibly the design of the management procedure). One feature of an evaluation of management procedures that has perhaps not been used as extensively as might have been expected is the ability to comment on the ‘value of research’ to reduce uncertainty in achieving management goals. Some studies (e.g. Bergh and Butterworth [1987]; Punt et al. [2001]) have examined the ‘value of research’ in the context of the data requirements for management procedures, but there is no evidence that the results of these studies have influenced funding of research and monitoring. One of the major concerns that industry often have with management systems is that they result in fluctuations in TACs from one year to the next that are disruptive economically. Fluctuations in TACs can be caused by the management system “following noise in the data”, and can be reduced by imposing limits on how much TACs can be varied from one year to the next and by setting minimum (and maximum) limits on the TAC. However, setting limits on inter-annual TAC variability that are too rigid can result in TACs not being reduced quickly enough if, for example, a recruitment failure occurs. The simulation framework used to evaluate candidate management procedures allows the relative merits of alternative specifications for these limits to be compared properly through quantitative evaluation (e.g. De Oliveira and Butterworth [2004]). 4. Examples of management procedures. Management procedures have been implemented in several fisheries jurisdictions. Table 1 lists the stocks / species for which management procedures have been developed and implemented. Table 1 examines how the use of management procedures has changed from 1993 to 1999, and to the present. The information on which Table 1 is based was obtained from the literature, the web, and from discussions with the scientists who were tasked with developing (and revising) the management procedures concerned. The bulk of the implementations have occurred in the southern hemisphere, although there are some noteworthy exceptions on the west coast of North America, in Iceland, as well as in the management of whaling. Table 1 is restricted to cases where management procedures have been implemented. There are many studies in which the basic approach used when evaluating management procedures (Fig. 1) has been used to examine the properties of a management system, but the results have not been used in practice. For example, Eggers [1993], Punt [1997, 2002], Kell et al. [1999], Polacheck et al. [1999] and Hilborn et al. [2002] all evaluated the performance of management procedures, but the results were not used as the basis for actual management decisions. These studies did, however, inform decision makers and scientists regarding the relative merits of different feedback-control approaches to fisheries management. Management procedures have been used in South Africa for several resources (Table 1), including hake, anchovy and rock lobster (the nation’s three most valuable fisheries) and the use of management procedures is now considered “standard” for the major fish 8 resources of that country. For example, since the late 1990s, there have been no cases where the decision makers have modified recommendations for TACs based on management procedures, unless scientists have provided advice that new information justifies the revision of the procedure. These management procedures tend to be updated every 3-5 years based on new information that indicates the need for an appreciable refinement of perceptions concerning resource status or productivity (Bergh and Butterworth [1987]; Butterworth and Bergh [1993]; Butterworth et al. [1997]; Geromont et al. [1999]; De Oliveira and Butterworth [2004]; Johnston and Butterworth [2005]). Management procedures have been developed for Namibian hake and the component of the Cape fur seal, Arctocephalus pusillus pusillus, population off Namibia, but have not been adopted formally as a basis for formulating management decisions. The seal management procedure is in need of revision, but this is currently on hold while a management plan is being developed. In any case, harvests of pups are currently below sustainable levels. A management procedure for hake off Namibia (Rademeyer [2003]) was used as the basis for TAC recommendations in 2002 and 2003, but in 2004 the output from this management procedure was not accepted as the basis for setting the TAC for hake for the 2004/05 season. This was, in part, because of concerns by decision makers about whether to use a management procedure for hake in Namibia, and also a possible need to revise this management procedure as the key data inputs (CPUE and survey abundance indices) may be conflict, a possibility that was not envisaged during the development of this procedure. Management procedures have been evaluated for a wide range of species in Australia, and are used in various ways to determine management actions. They have, however, not been adopted in a formal sense (in that they have been included in fishery management plans). A key reason for this is that it would be difficult (slow) to amend a management procedure that is part of a fishery management plan if new information were to show that it is flawed (or that a better management procedure exists). Therefore, practice in Australia tends to be that Fishery Assessment Groups and Management Advisory Committees will select methodologies (including data collection schemes, assessment methods, management reference points, and harvest control) as being appropriate, but not formally adopt them. At the Federal level, the Board of the Australian Fisheries Management Authority also makes such decisions. Thus, while there is no formal adoption of management procedures, there is a relatively strong commitment to use of what amount to management procedures, but with the caveat that changes to management procedures can be made as deemed necessary. Evaluations of management procedures for the two target species in Australia’s southern shark fishery (school shark, Galeorhinus galeus, and gummy shark, Mustelus antarcticus) have been undertaken (Punt et al. [2005]). These evaluations led to agreements on assessment methods and goals for recovery, but not on specific rules for setting TACs. Management procedure evaluations were conducted for the orange roughy, Hoplosthesus atlanticus, stocks off eastern Australia and a set of harvest control rules was devised. However, these harvest control rules, which involved closure of the fishery at low stock size, were never formally agreed to, and were implemented only when stocks had fallen to much lower levels than originally intended. 9 The management procedure evaluations for the swordfish fishery off the east coast of Australia (Campbell and Dowling [2003]) formed the basis for setting an initial Total Allowable Effort level for this fishery, but no management procedures (or even assessment methods) are agreed for this fishery. Similarly, management procedure evaluations are being conducted for the key target species of the Northern Prawn Fishery (C.M. Dichmont, CSIRO Marine Research, Cleveland, pers. commn), but while the results of these evaluations are likely to guide decisions regarding data collection, assessment methods, and the process for determining the annual level of fishing effort, they are not likely to lead to management procedures that are adopted formally. The rules used to set the TACs for the fishery for Patagonian toothfish, Dissostichus eleginoides, at Macquarie Island use catch rates to suggest whether the fishery is operating on a stock that is resident to Macquarie Island or on the resident stock as well as a transient stock. These rules were evaluated using scenarios in which there was a single stock, a single stock with poor recruitment, and two stocks (Tuck et al. [2003]). Polacheck et al. [1999] conducted an initial evaluation of management procedures for the southern bluefin tuna, Thunnus maccoyii, resource which accounted for uncertainty in the methods for estimating the size of the plus-group, the interpretation of CPUE for areas with no fishing effort data, rates of natural mortality, actual catch levels in recent years, and the age-at-sexual maturity. While this effort did not lead to agreements regarding the management of the fishery for southern bluefin tuna, a subsequent effort is currently underway within the Commission for the Conservation of Southern Bluefin Tuna (CCSBT) which should lead to a management procedure to determine catch limits for southern bluefin tuna for all CCSBT member nations, also taking account of likely catches by non-members (e.g. Anon [2003]). There were no management procedures in use in New Zealand in 1993 although harvest control rules were in place for several species. By 1999, a management procedure had been put in place for red rock lobster, Jasus edwardsii, off southern New Zealand (Starr et al. [1997]). This management procedure was developed collaboratively by scientists employed by the New Zealand government and by the fishing industry. It was revised in 2003 based on consideration of a broader range of uncertainties and a revised management goal (Bentley et al. [2003a]). Harvest control rules that have been evaluated using simulation are used to determine the harvest guidelines for Pacific Mackerel, Scomber japonicus (Parrish and MacCall [1978]; MacCall et al. [1985]) and Pacific sardine, Sardinops sagax caerulea (Anon [1998]). The harvest control rule for Pacific sardine is unique in that the target level of fishing mortality depends on an environmental variable (temperature). Note that, as in Australia, the method of analyzing the data collected from the fishery to calculate the information needed to apply the harvest control rule is not pre-specified although the same assessment method has been used to conduct assessments of both Pacific sardine and Pacific mackerel for the last several years. Harvest control rules are used to provide management advice for many other stocks in the U.S. However, except for those for Pacific mackerel and Pacific sardine, these harvest control rules have not been formally evaluated using simulation. 10 Europe has been progressing towards formal harvest control rules (e.g. for North Sea herring, Irish Sea cod, West Scotland cod, Kattegat cod, North Sea cod and Northern hake) and discussions are taking place to implement harvest control rules for several other species / stocks in European waters. These harvest control rules are better considered formal ways of implementing recovery programs rather than long-term approaches to management, and have not been tested using simulation. There are, however, two exceptions; cod, Gadus morhua, off Iceland and Northeast Atlantic cod. The harvest control rule used to set TACs for Icelandic cod was evaluated by means of simulations that considered both biological and economic factors (e.g. Baldursson et al. [1996]; Danielsson et al. [1997]). The rule was implemented in 1995 and replaced in 2000 after it was discovered that the fishable biomass had been overestimated substantially. The 1995 harvest control rule included a minimum TAC. This minimum TAC was eliminated, and a constraint on inter-annual variation in catches imposed, during the 2000 revision to the harvest control rule. The harvest control rule for Northeast Atlantic cod is based on a fixed harvest rate (0.4yr-1) when spawning output is high, reduced fishing mortality if spawning output is below a threshold, and a limit on the extent of inter-annual variation in catches. It should be noted that the analyses used to evaluate alternative harvest control rules for Northeast Atlantic and Icelandic cod did not simulate the application of the types of assessment method used in actuality. Management procedures have been developed by the International Whaling Commission (IWC) for baleen whales subject to commercial harvest on their feeding grounds (Cooke [1995]; IWC [1999]) and for the subsistence harvest of bowhead whales in the Bering-Chukchi-Beaufort Seas and gray whales in the eastern North Pacific (IWC [2003, 2005a]). Catch limits for whales exploited commercially were based on the results of stock assessments and a pre-specified harvest control law (see IWC [2004b] for the specifications of the harvest control rule) prior to the declaration of a moratorium on commercial whaling in 1982 by the IWC. The reasons for moving from (the then) conventional methods of providing management advice for stocks of whales subject to commercial harvest to an approach based on a management procedure related in large part to the difficulty that the Scientific Committee of the IWC had experienced in reaching consensus on stock status and other parameters needed to apply the agreed harvest control law given uncertainties about data and their interpretation (Kirkwood [1997]; Kirkwood and Smith [1996]). The testing of candidate management procedures for whaling involved a very large number of scenarios to examine the impacts on performance of, for example, bias in estimates of abundance (and how that bias may change over time), the precision of the estimates of abundance, uncertainty about the magnitude of historic catches, and changes over time in the values for key biological parameters of the population. The management procedure eventually selected (the “Revised Management Procedure”, RMP) was generic in that it can be applied to any stock of baleen whales on their feeding grounds. It includes rules to handle situations when stock structure is uncertain. Although the RMP is generic, prior to recommending that the RMP be implemented for any species in a region, case-specific simulations are conducted by the Scientific Committee of the IWC to examine the performance of the RMP for that species and region, and to recommend which of the rules used to handle 11 stock structure uncertainty should be applied. To date, case-specific simulations have been developed for the north Atlantic, southern Hemisphere and western North Pacific minke whales (IWC [1993, 2004a]), with a similar exercise for western North Pacific Brydes whales in progress. Although the Revised Management Procedure is undoubtedly the most thoroughly tested of the management procedures developed to date, it has yet to be used by the IWC to set catch limits. This is because, although the scientific aspects of the management regime are complete, the procedures for ensuring compliance are not yet agreed. Norway, which lodged an objection to the moratorium (IWC [2004b]), has used a less conservative variant of the RMP when setting catch limits for its fishery for minke whales in the eastern North Atlantic. 5. Why have management procedures not been adopted more extensively? The selection of a particular management procedure from a set of candidate management procedures remains the most difficult part of implementing the approach. As noted by Butterworth and Punt [1999], a management procedure should be sufficiently robust to all plausible scenarios regarding the future state of the system, but what constitutes “sufficiently robust” and “plausible” is not easy to decide. While some guidelines for assigning plausibility to scenarios have been developed (Butterworth et al. [1996]; IWC [2005b]), these have yet to be adopted widely. Most management procedure evaluations consider future performance over 10-25 years (100 years in the case of baleen whales). The projection period therefore considerably exceeds the tenure of most decision makers. Many politicians will have little incentive to make decisions, the benefits of which will only be realized well after their terms are completed (Daw and Gray [2005]). Therefore, there is likely to be a tendency to avoid adopting management procedures that will lead to short-term reductions in catch. A related issue is that changes in government may lead to changes in fisheries management goals. This could lead to recommendations from management procedures being ignored because the goals on which the management procedures were based do not reflect those of the government presently in office. The scientists polled informally provided a number of other reasons why management procedures had not been adopted more extensively. Specifically, some noted that it would be more difficult to develop and implement management procedures for stocks for which: a) there is no credible index of abundance, b) there is substantial inter-annual variability (although others remarked that many of the applications have, in fact, been to species such as sardine, anchovy and mackerel which do vary substantially from one year to the next), c) there are substantial non-fishing related perturbations, and d) the data available for assessment purposes are in conflict to some extent. Implementing management procedures in the face of multi-species interactions (both biological and technical) is challenging because, in addition to the trade-off between risk and reward, there is a need to trade-off the harvest of one species against that of another. 12 Situations in which there are biological interactions tend to be more complicated than those in which there are only technical interactions owing to the difficulties associated with quantifying such interactions. Although dealing with multi-species interactions is difficult, it is not impossible (Sainsbury et al. [2000]; Butterworth and Punt [2003]). For example, De Oliveira et al. [1998] developed management procedures for sardine and anchovy off South Africa in which the amount of bycatch of sardine in the anchovy fishery depended on the form of the management procedure adopted for anchovy. The analyses used to select the anchovy and sardine TACs explicitly examined the trade-off between catches of anchovy and those of sardine. Management goals are not generally sufficiently well quantified in legislation, and the cost of developing a consensus regarding management goals may take much time and be costly. This is because the process of identifying quantitative management goals may require a series of workshops with key stakeholder groups (e.g. Bentley et al. [2003b]). The technical requirements of implementing management procedures are very substantial, particularly for fisheries for which the scenarios that need to be represented in the operating model are complicated (involving, for example, spatial structure and / or multispecies interactions). The computer programs needed to evaluate a management procedure can often be several orders of magnitude more complicated than that needed to implement the management procedure itself. This complexity is compounded by a lack of population modelers in most management agencies. The ability to communicate effectively with a broad range of stakeholders and the time needed to iterate with stakeholders regarding management goals and when selecting among candidate management procedures is another challenge for the scientists who are tasked to provide advice regarding potential management procedures. Except for the IWC’s Revised Management Procedure, the management procedures referred to in this paper were designed in a case-specific manner (because the key uncertainties for any one fishery are unlikely to be those for any other fishery). The need for case-specific management procedures will almost certainly prevent widespread adoption of management procedures for the reason discussed in the previous paragraph. One way to overcome this problem is for “generic” management procedures to be implemented. Such management procedures would need to be robust to a wide range of uncertainties and could be used “off the shelf”. Unfortunately, any “generic” management procedure would have to be very conservative to be robust to all key uncertainties. Management procedures are generally no more complicated than the traditional tools used to provide management advice (e.g. the use of Sequential Population Analysis to estimate population size) and are often much simpler. Unfortunately, stakeholders tend to see the management procedure and the approach used to test it as a single “package”, which appears much more complicated than the traditional approach. 6. The future. The level of effort directed towards evaluating management procedures is clearly increasing (e.g. Europe, Australia and South Africa) and there is clear evidence for increased use of management procedures in many parts of the world 13 (Table 1). However, the response of management authorities to the results of management procedure evaluations differs among regions. In Europe and Australia, the results inform decisions (through an improved basis for selecting assessment methods and data collection schemes, and by identifying ways of making decisions that do not work) rather than determining a particular decision. In contrast, South Africa and the U.S. have tended to mimic the IWC’s process of more formal adoption. Decision makers in Namibia are currently indicating that they would prefer implementations which admit some flexibility, rather than providing only a single TAC recommendation. The types of calculations and processes used to evaluate management procedures may have substantial benefits even if they do not lead to an agreed formula for determining management actions in response to the data collected from a fishery. They force scientists to avoid thinking that is focused on determining the “best” appraisal of stock status and is focused instead on uncertainty (in the dynamics of the resources, the implementation of management actions, and the data). This is because the results of management procedure evaluations always highlight that it is the combination of these uncertainties that determines the ability (or inability) to satisfy the management goals. Also, the processes that lead to agreed management goals and quantifiable management objectives have benefits that may be much more long-lasting than the management procedures themselves. The use of simulation-tested feedback-control management systems is an ideal, and represents the endpoint of a process which started with the identification of what are now known as target reference points (e.g. F0.1), harvest control (or decision) rules, and limit reference points. Development of reference points and harvest control rules outside of the context of the process of evaluation by means of simulation still occurs (e.g. Caddy [2004]; Smith and Rago [2004]) although the value of this development process will be enhanced if it is possible to evaluate these tools in terms of how likely they are to achieve the management goals. The future will undoubtedly likely see more applications. However, paucity of formal adoption of management procedures within, for example, Management Plans, seems likely to continue outside of international fisheries management bodies (such as IWC and CCSBT). Finally, it would be unfortunate if management procedures do not focus more on a broader range of uncertainties than is presently the case, for example, by paying more attention to ecological interactions and spatial management strategies. Acknowledgments. Funding for this work was provided by NMFS Grant NA07FE0473. 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Williams [2003], Abundance estimation and TAC setting for Patagonian toothfish (Dissostichus eleginoides) at Macquarie Island: a synpopsis, Paper presented to 1 May 2003 meeting of the Sub-Antarctic Fisheries Assessment Group (http://www.afma.gov.au/fisheries/macquarie/reports/toothfish03.pdf) 17 Table 1. Overview of the use of management procedures. “No” denotes that a management procedure was not in use for the species concerned and “yes” that this was the case. Region / stock Australia School and gummy shark Northern prawn East coast tuna 1993 1999 Present (2004) No No No No No Testing Yes * No No Eastern stock of gemfish Patagonian toothfish No No Yes No N/A Yes Iceland Cod No Yes Yes Revised in 2000 Namibia Cape fur seals Cape hakes No No Yes Yes In abeyance In review Revised in 2002 New Zealand Rock lobster No Yes Yes Revised in 2003 Norway Minke whales No Yes Yes No Yes Norway-Russia Cod South Africa No Comments Testing underway Used as the basis to set a TAE Directed fishery is closed 18 Anchovy Yes Yes Yes Sardine Yes Yes Yes Cape hakes Yes Yes Yes West coast rock lobster No Yes Yes USA Pacific sardine Yes Pacific mackerel Yes * TAC rules not formally adopted. Yes Yes Yes Yes Revised in 1999, 2002, and 2004 Revised in 1999, 2002, and 2004 Revised in 1999; currently under revision Revised in 2000 and 2003 19 Specify Qualitative Management Goals Specify Quantitative Management Goals (Performance Measures) Develop and Parameterize the Operating Model Generate Annual Data Develop Management Procedures Data Stock Assessment Model Apply Management Procedure Update Population Dynamics Management Action Harvest Control Rule Calculate Performance Meausures Figure 1. Flowchart of the approach used to evaluate management procedures.