Sustainability

Namibia’s Fisheries Management System

Namibia’s coastline stretches about 800 nautical miles (1,500 kilometres), and being a desert country, there is virtually no pollution runoff into the sea. Namibia benefits from the exceptionally high biological productivity of the Benguela Current System, one of four eastern boundary coldwatercold-water nutrient upwelling systems in the world.

Prior to Namibian Independence in 1990, uncontrolled fishing on a massive scale by foreign fleets greatly reduced the abundance of all the major fish stocks. Following Independence, the Namibian Government drastically cut total allowable catch levels for key commercial species to allow fish stock recovery to maximum sustainable levels.

The Constitution of Namibia, Section 95(l) states that the Government of Namibia must maintain:

“...... ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future”.

Namibia is committed to observing the principles of optimum sustainable yield in the exploitation of marine resources, in accordance with the Namibian Constitution. The Government is therefore obliged to promote and regulate responsible and sustainable development and management of all harvesting activities that target marine resources, including:

Ensuring that it conducts the planning, management and development of the marine fisheries sector in accordance with international best practise.

1. Ensuring that all flag state obligations are complied with by vessels flying the Namibian flag, whether operating in Namibian waters, international waters or waters of other sovereign states.
2. Applying the precautionary approach to fisheries management.
3. Ensuring that the marine resources sector is self-sustaining and is not supported through public sector subsidies.
4. The Namibian fishing industry is not subsidised. Namibia is strongly opposed to the subsidy policies pursued by other nations due to a belief that subsidies cause over-capitalisation, distort trade unfairly and ultimately lead to over-fishing and the encouragement of illegal, unreported and unregulated (IUU fishing) fishing practices.

In addition, Namibia is a party to a number of regional and international fisheries legal instruments and agreements, including:

• the United Nations Convention on the Law of the Sea, 1982;
• the United Nations Fish Stocks Agreement, 1995 relating to the conservation and management of fish stocks and highly migratory fish stocks;
• the Food and Agriculture Organisation (FAO) Compliance Agreement, 1993 relating to promoting of compliance with international conservation and management measures by fishing vessels on the high seas;
• the Code of Conduct for Responsible Fisheries and its associated International Plans of Action;
• the Southern African Development Community (SADC) Regional Protocol on Fisheries;
• the 2001 Reykjavik Declaration on Responsible Fisheries in the Marine Ecosystem;
• and the Rio (1992) and Johannesburg (2002) declarations on sustainable development.

Direct Government revenues collected from the fisheries sector include: quota fees; the Marine Resource Fund levy (a levy on all landed species, used to fund research and training); a by-catch levy on non-target fish caught (all of which must be landed – discarding is prohibited) with charge rates per tonne set on a species-specific basis; as well as licence fees for vessels and processing facilities.

Namibian hake fishery achieves “Marine Stewardship Council (MSC) Certification”

The Namibian hake fishery, comprising 90% trawl quota and 10% longline quota, achieved the milestone of MSC Certification on 17 November 2020, and Seawork Fish Processors has MSC Chain of Custody.

Global inspection and certification contractor Control Union independently assessed the Namibian hake fishery, and confirmed that the fishery meets the three principles of the MSC Fisheries Standard, which includes stock health, environmental impacts and effective management. The fishery scored an average of 80 percent in the 28 performance indicators within the three principles. Ongoing assessment will occur to further improve the sustainability of the fishery, with updates trackable on the MSC website.

MSC Senior Programme Manager for Africa, stated that during the assessment for certification, the Namibian hake fishery exhibited resilience and strong performance backed by “availability of data for hake stock assessment and harvest strategies, having in place measures to minimize bycatch, a ban on discarding commercial species, presence of measures to minimize impacts on demersal habitats, and an established and transparent rights allocation process.”

Seawork is pleased to have MSC Certification, as this helps endorse the Namibian hake fishery in the eyes of buyers, as sustainability and traceability are becoming increasingly important for fish and seafood, as many consumers trust certified products more.

The Ministry of Fisheries and Marine Resources (MFMR) consults extensively with the stakeholders on matters before action is taken to adjust any aspect of policy or management strategy. A number of consultative mechanisms are in place, including

• Direct face to face meetings with individual companies or through the various sector specific fishing associations;
• Consultation and peer review of research undertakings is facilitated through a number of working groups such as the Hake Working Group. Industry representatives are members of these working groups.
• Industry vessels collaborate with MFMR scientists each year in undertaking stock assessment surveys for Namibia’s key commercial fish species.
• Under the Marine Resources Act (2000), a Marine Resources Advisory Council (MRAC) has been established to provide advice to the Minister on fisheries policy, management and development issues.
• The Ministry has also established a Liaison Group with the Fisheries Observer Agency, to facilitate compliance operational efficiencies and effective cooperation.

The Ministry has also established a Liaison Group with the Fisheries Observer Agency, to facilitate compliance operational efficiencies and effective cooperation.

International recognition of the success of Namibia’s fisheries management system and leadership includes awards received by the Ministry of Fisheries and Marine Resources:

• The FAO Margarita Lizarraga Medal in 2009, for distinction in the application of the Code of Conduct for Responsible Fisheries through implementation of responsible fisheries science, policies and management.
• The Kungsfenan Swedish Seafood Award in 2009 for establishing an effective research-based administration within a short time frame in Namibia.
• The World Future Council 2012 Silver Award for Namibia’s fisheries management policy as a testimony to over 20 years of Namibia’s efforts to rebuild the stocks of its marine resources and manage the fisheries on a sustainable basis into the future.

Conservation and Responsible Management of Marine Resources

Through Namibia’s Marine Resources Policy, the Ministry of Fisheries and Marine Resources emphasises conservation of stocks so as to

• Maintain and/or rebuild the biomass of each marine resource to levels where they can each support long-term sustainable yields.
• Develop and implement fishery management plans, which determine reference points, management strategies and research priorities for major commercial resources.
• Develop and implement national plans of action in support of the various FAO international plans of action relating to seabirds, illegal, unreported and unregulated (IUU) fishing, fishing capacity, and sharks.
• Continue to control fishing effort through the existing system of fishing rights, total allowable catches, quotas, effort restrictions, spatial and temporal closures, and other management measures.
• Allow stocks to be exploited on a sustainable basis applying the precautionary approach as appropriate, in general below that estimated to give maximum sustainable yields.
• Protect juvenile fish through management measures such as minimum allowable net mesh sizes, minimum allowable fish sizes in catches, closed areas and seasons and selectivity devices.
• Develop and implement an ecosystem-wide approach to fisheries management, including multi-stock management where research reveals stock interdependence, and including shared and straddling stocks with countries that share borders with Namibia, and relevant international fisheries management organisations.
• Implement management measures to protect marine fish stocks and fisheries from possible negative effects of other activities impacting on the sea or the seabed.
• Implement management measures to reduce incidental by-catch species on all fisheries.
• Ensure a high level of compliance with fisheries management and control measures through a system of monitoring control and surveillance including satellite-based vessel monitoring systems.
• Implement measures to constrain marine pollution.

Management Measures

The main management measures for commercial fisheries including hake, in Namibia are:

1. Limitation of effort – through access rights and vessel licensing. The backbone of Namibian fisheries management is the right of exploitation. The main purpose of fishing rights is to limit entry to the fisheries sector in order to protect the fisheries resources and maintain sustainable operations. Anyone not holding an exploitation right is strictly forbidden from commercially fishing in Namibian waters. All vessels are required to obtain a license in order to fish within Namibia's 200-mile exclusive economic zone – this way a vessel can only target the fish species it is licensed for, limiting by-catch of other species.
2. The management of the commercial fisheries in Namibia consist of a combination of: exploitation rights; total allowable catches (TACs); individual quotas (IQs) issued to fishing concessionaires with a right to only catch that specific seafood species; quota fees; by-catch fees; and a comprehensive monitoring and control (MCS) and observer system.
3. Limitation on the catch – through setting of total allowable catches. These are determined annually and are based on the best scientific evidence available on the size and structure of stocks as determined by the fisheries scientists employed by the Ministry of Fisheries and Marine Resources. TACs aim to ensure sustainable fishing operations; that the level of fishing effort does not undermine the status of each stock.
4. Research Fund levies are applied to all fish caught, the amount for each species is set based on the final market value for the species. This money is utilised to finance fisheries research by the Government.
5. By-catch levies are applied to fish caught which is not part of the specific commercial exploitation right being utilised. By-catch levy rates are based on the value of the fish, and are set at a punitive rate to stop any targeting of species other than those associated with the exploitation right.
6. The 200 metre depth restriction, inside which trawl and longline vessels may not fish along the whole of the Namibian coast, is to protect juvenile and spawning parts of the fish stock.
7. All vessels must be fitted with automatic location communicators as part of the vessel monitoring system (VMS).
8. There is a ban on transhipment at sea. All commercial species caught by industrial fisheries are only offloaded at two ports, Walvis Bay and Luderitz, and therefore catch landings are tightly controlled.

These measures are enforced by a team of Fisheries Observers and Fisheries Inspectors, employed by the Fisheries Observer Agency and the Ministry of Fisheries and Marine Resources respectively.

Hake Specific Management Measures

Research

The Ministry of Fisheries and Marine Resources (MFMR) undertakes fisheries and environmental research with the objectives of providing advice and information on all matters relating to the potential of the various resources, their spatial and temporal distribution, their catchability, appropriateness of fishing gear and vessels, and facilitating a system for the collection of data and other information. Included in these tasks is advising on and recommending total allowable catches for the various stocks, and other measures relating to fishery regulations.

During January and February of each year a swept-area hake research survey is undertaken by scientists from the Ministry of Fisheries and Marine Resources along the Namibian coast by using an industry vessel. During this survey the relative abundance of both hake species is determined from the trawl information. The method of abundance estimation from these swept-area surveys is based on depth stratification (100 – 600 metres). Biological data; length, weight, gender ratios and reproductive proportions are also being collected from each trawl. Industry contributes to research as well via the levy on every kilogramme of fish caught, which is utilised via the MFMR Marine Resources Research Fund.

Stations layout of the entire Namibian coastal waters covered during the 2013 hake swept-area biomass survey (with depth contours of 200, 1000 and 3000 m).

Further information is obtained from the individual fishing vessels. Each trawl done by the fishery is being logged with positional and catch information, which is compulsory. Hake commercial bottom trawl catches are extrapolated to estimate the catches by size of the whole fleet. The extrapolations are made possible by defining strata (depth zones and latitude). This data is then used to investigate the catch-per-unit effort (CPUE) in space and time. The basic assumption in using commercial catch and effort data in stock assessment is that CPUE is proportional to stock abundance. Annual standardized catch rates are estimated from averaging areas and monthly catch rates in order to remove fluctuations due to seasonality and fleet strategy. Also, the catches recorded are split between the two hake species in their length distributions. This data is collected by the fisheries observers on board the commercial fishing vessels.

All the collected data is then collated to be used as input for an age-structured production model. This model integrates all the available reliable information from both the commercial fishery and the research surveys on the state of the resource: historic catches; indices of abundance; age and length composition data; and seal scat (faeces) information which provides an index of hake recruitment as seals eat juvenile hake. This statistical assessment method has been internationally reviewed and provides for advice on the total allowable catch recommended by fisheries scientists by considering the following:

1. Maximize average annual catch
2. Minimize annual catch variation
3. Recovery in spawning biomass to at least the maximum sustainable yield (MSY) level
4. Acceptable risk.

The Ministry of Fisheries and Marine Resources also conducts environmental-monitoring surveys to gather information on important oceanographic parameters and processes as they relate to fish stocks such as sea temperature, salinity, dissolved oxygen, hydrogen sulphide, nutrients, chlorophyll-a, phytoplankton and zooplankton, as well as upwelling and frontal movements.

MFMR research vessel “RV Mirabilis”

Total Allowable Catch Recommendation Process

Section 38 of the Marine Resources Act, 2000, provides for the Minister of Fisheries and Marine Resources to determine total allowable catches (TAC’s) for quota species such as hake, on the basis of the best scientific evidence available and having requested the advice of the Marine Resources Advisory Council comprising: the Permanent Secretary of the Ministry and one other Ministry representative; five people who in the opinion of the Minister have knowledge in matters relating to marine resources, or other relevant expertise; and five people who fairly represent the fishing industry or its employees.

The recommendation process involves:

1. Working group meetings with the participation of industry members, government scientists and consultants are held to discuss the available data and the assessments.
2. The government scientists responsible for providing scientific advice on hake then prepare recommendations for the annual hake TAC and related issues, and these are discussed internally with all other government scientists.
3. The recommendations are discussed with the Minister and the Ministry of Fisheries senior research management officials, and may be changed as appropriate.
4. The recommendations are then put to the Marine Resources Advisory Council, which formulates its own recommendations for the Minister by also taking account of socio-economic considerations.

Monitoring, Control and Surveillance

Namibia currently exercises its rights as a coastal State and signatory to the 1982 Law of the Sea in regard to conservation and management of the living marine resources under its jurisdiction. Current policy, legislation and management measures have been effective in reducing illegal, unreported, and unregulated (IUU) fishing within the Namibia EEZ to a low level.

Namibia ensures that:

• monitoring, control and surveillance (MCS) and enforcement activities continue to ensure compliance with national laws and licence conditions by all vessels that are authorised to fish in Namibia’s exclusive economic zone (EEZ);
• no vessel fishes in Namibia waters (or outside, in the case of Namibia flag vessels) without a valid authorisation (licence);
• only vessels that are duly recorded on a vessel register are authorised to fish;
• transhipment occurs only in Namibia ports, as authorised by the Ministry of Fisheries and Marine Resources (MFMR);
• no vessel with a history of IUU fishing is given an authorisation to fish, or is able to become registered to fly the Namibia flag.

The Directorate of Operations within the Ministry, which includes fisheries inspectors, is responsible for monitoring, control and surveillance of all fishing and or harvesting activities along the coast and EEZ. This includes stopping and boarding vessels, search and inspection, hot pursuit, seizure and arrest.

While inspectors monitor catch landings in port, all catch data at sea are to be entered into log sheets by vessel captains. The Fisheries Observer Agency (FOA) is mandated by the Marine Resources Act to place observers on all fishing vessels. These observers monitor compliance of fishing vessels with fisheries legislation. Their duties include monitoring fish by-catch rates, checking gear specifications, checking on illegal dumping, compiling data on catches and operations and collecting some biological data as specified by MFMR.

The Namibian MCS fisheries operation is based on the deployment of fisheries patrol vessels, patrol aircraft, vessel offloading of fish in Namibia’s two harbours of Walvis Bay and Luderitz, and a further check through inspections of onshore fish processing plants where all fish going through the processing plants is again weighed.

Fisheries sea surveillance activities are undertaken by two patrol vessels to strengthen the fisheries control function through regular monitoring, control and surveillance.

Two fisheries patrol aircraft also undertake air surveillance of Namibia’s exclusive economic zone, detecting and deterring unlicensed fishing vessels and monitor the movement and operations of the licensed fishing fleet. All vessels have their radio call signs printed in large letters on the side of the vessels’ hulls.

Namibia has a national satellite –based Vessel Monitoring System (VMS)to provide for real time monitoring of vessel movement and activities, and to assist in curbing IUU fishing activities within and outside the EEZ by Namibian flagged vessels. The introduction of the VMS is intended also to enable Namibia to comply with requirements by international fisheries management organisations to which Namibia is a contracting party.

Namibia does not allow transshipment of fish at sea, which has been a successful strategy in controlling illegal fishing and maintaining sustainability of the resource.

Namibia deploys Ministry of Fisheries and Marine Resources fisheries inspectors from Walvis Bay and Luderitz Inspectorate Offices, the two commercial fishing ports in Namibia, to monitor and inspect fishing vessel activities in harbours, particularly monitoring fish landings to fish processing factories is the same as the vessel records. This is to ensure compliance with quota limits and fee payments. In some cases fish is transhipped, but this is only allowed within port limits, with fisheries inspectors’ onboard monitoring transhipment quantities.

The Fisheries Observer Agency, established under the Marine Resources Act, has been the watchdog of the Ministry of Fisheries and Marine Resources, monitoring compliance to marine legislation as it has first hand information obtained while fishing vessels are at sea.

All Namibian fishing vessels must carry a fisheries observer on board when fishing. The primary role of the observer is to monitor that the at-sea provisions of the Marine Resources Act and Regulations are adhered to. For instance, it is forbidden by law to discard fish, so all fish caught must be landed and it is the observer’s role to report any discarding that may take place. The observers also play an important role in collecting scientific information for MFMR scientists of the National Marine Information Research Centre (NatMIRC), comprising primarily length frequency data of catches.

Section 52 of the Marine Resources Act provides for offences and penalties for violations of the Act. Unauthorised fishing or contravention of licence conditions by Namibian or foreign flag vessels attract a fine of up to Namibia $2 million.

Fish By-catch and Seabird Protection Measures

During a fishing trip, a vessel can only carry a quota for one species. Any other species that is caught is labelled by-catch and a penalty fee must be paid on any such harvest. By-catch fees are applied in order to deter right holders from targeting species other than those for which they have been issued a quota. This is a unique feature of the Namibia fisheries management system that is not seen in many other countries. Such fees provide an incentive to avoid catching non-target species. The levels of by-catch fees are carefully balanced to discourage the capture of non-target species, but are also not so punitive as to encourage dumping of fish. A certain percentage of by-catch in the hake-directed fishery is not levied, since a reasonable amount of by-catch cannot be avoided.

Another form of unintended by-catch can be seabirds. When fishing vessels are trawling, seabirds may be accidentally injured or killed if they collide with trawl warps, the wire ropes used to tow the trawl net. Following the “warp strike”, the bird is then pulled underwater by the drag of the fishing vessel or by rough seas, resulting in them drowning.

In Namibia the main birds at risk are gannets, and to a lesser extent albatross and petrels. The birds supplement their normal diet by foraging on fish stolen from the trawl codend, or fish offal in the sea, and as a result sometimes strike the trawl warps while doing so.

A National Plan of Action (NPOA) for seabirds has been developed by Namibia. Seawork is complying with the permit conditions on seabird by-catch mitigation on hake bottom trawl vessels, by flying “tori lines” on its vessels and scaring the birds away from danger.

The tori line consists of two ropes that are deployed parallel to the trawl warps. Brightly coloured streamers hang from these ropes, fluttering in the wind and scaring birds away from the stern of the fishing vessel. While tori lines are a simple and effective device, it takes commitment by the vessel crew to ensure they are deployed at every trawl, and this is reinforced through Seawork’s sustainability policy.

Seawork vessels head and gut the fish in their onboard processing plants as this helps to keep the fish fresher when it is then stored on ice. Also in compliance with the bird mitigation permit conditions, Seawork vessels do not discard the resultant fish offal during the shooting of gear unless bird scaring lines are deployed (i.e. no discarding may occur from when the net enters the water up until the trawl doors are deployed). Macerated fish offal is also not allowed to be released near foraging birds. These mitigation practises are very effective in solving the bird by-catch problem.

It is also believed that seabirds, cetaceans and seals populations are negatively impacted through becoming entangled or by ingesting plastics, or by becoming entangled in lost trawl and longline gear. Seabirds are also known to become oiled from small chronic spills and deliberate disposal of oil and fuel at sea from fishing vessels. Again, as part of Seawork’s sustainability policy, no plastics or other rubbish is thrown overboard, being returned to shore for disposal, and deliberate disposal at sea of oil or fuel is not allowed. Seawork’s vessels are also all mechanically well maintained, so as to ensure no chronic oil spills.

References

• Marine Stewardship Council. Namibia Hake Trawl and Longline Fishery.
  https://fisheries.msc.org/en/fisheries/namibia-hake-trawl-and-longline-fishery/
• Marine Stewardship Council. 17 November 2020. A sustainable and bright future for Namibian hake
  https://www.msc.org/media-centre/news-opinion/news/2020/11/17/a-sustainable-and-bright-future-for-namibian-hake
• Ministry of Fisheries and Marine Resources. Hake: Conditions Applying to Holders of Rights of Exploitation. Republic of Namibia.
• Ministry of Marine Resources, 27 December 2000. Marine Resources Act, 2000 (Act 27 of 2000). Republic of Namibia.
• Ministry of Fisheries and Marine Resources, 7 December 2001. Regulations relating to the Exploitation of Marine Resources. No. 241, 2001. Republic of Namibia.
• Ministry of Fisheries and Marine Resources, August 2004. Namibia’s Marine Resources Policy – Towards Responsible Development and Management of the Marine Resources Sector. Republic of Namibia.
• Ministry of Fisheries and Marine Resources, January 2007. National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing. Republic of Namibia
• Ministry of Fisheries and Marine Resources, 2010/11. Annual Report, Republic of Namibia
• Ministry of Fisheries and Marine Resources – Directorate of Resource Management, October 2012. Draft National Plan of Action – Seabirds for Reducing Incidental Catch of Seabirds in Longlining and Trawl Fisheries. Republic of Namibia

International Featured Standards (IFS) Food Certification

Seawork Fish Processors, in its quest to satisfy client requirements, has now also obtained International Featured Standards Food Certification, a global standard for certifying the safety and quality of food products and production processes. See https://www.ifs-certification.com/index.php/en/