MaltaToday asked Roberto Mielgo Bregazzi, CEO of consultancy firm ATRT, SL., to analyse figures provided by the rural affairs ministry’s Fisheries Division in response to last week’s cover story on tuna farming
On Wednesday July 30, MaltaToday published an exclusive cover story entitled: “Where did all this tuna come from?” We at ATRT believe that both the facts and the analysis of such story are timely, correct and appropriate.
According to the SCRS, ICCAT’s scientific body, bluefin tuna may well be on the brink of its stock collapse. The industry, both fishing and ranching, are also on the brink of financial collapse.
Both factors are no doubt due to years of relentless and shameless over-fishing, over-penning and thus over-saturating a gargantuan Japanese market, which is only too happy to squeeze first-purchase prices paid to tuna ranchers across the Mediterranean, while its tuna-trading cartel built up a year-rolling national strategic reserve of over 20,000 tonnes of deep-frozen bluefin tuna.
The issue of the survival of the fish and its fishery has become a moral and political issue, at least in the European Union, Malta being now a member state.
Public opinion and civil constituencies at large have thus now embraced the battle to save bluefin tuna from extinction and are legitimately exercising their right to scrutinise fisheries authorities across the Mediterranean Sea. ATRT is a private and independent consultancy company that enjoys a well-deserved international reputation, among other things because of the thoroughness of its published bluefin tuna fishery analysis.
So much that during the opening speech of a seminar which discussed the theme ‘Preventing, Deterring and Eliminating Illegal, Unreported and Unregulated Fishing (IUU)’ held in Malta on 17 April 2008, Minister for Resources and Rural Affairs, the Hon. George Pullicino, reiterated Malta’s commitment to fight against IUU activities.
Yet MaltaToday’s latest story on bluefin tuna uncovers some rather disturbing facts related to Malta’s involvement in what is known as “IUU tuna laundering”. The figures provided by Dr Anthony Gruppetta to MaltaToday’s Wednesday July 30 2008 cover story are even more troublesome.
We at ATRT believe the facts uncovered by MaltaToday to be true. The severe nature of these allegations thus call for an immediate special inquiry by the European Commission’s DG-Mare and the Community Fisheries Control Agency (CFCA) in order to shed some much needed light over such an unacceptable controversy.
What are the facts?
1. During the course of the 2007 summer BFT fishing season, ATRT carried out a survey on Malta’s BFT ranches. The results of that survey were published and widely distributed as part of ATRT’s report ‘The Plunder of the Bluefin tuna in the Mediterranean Sea & NE Atlantic 2006-2007’.
At the time of ATRT Malta survey (August 2007), ATRT’s estimation of Malta’s total BFT live biomass inside its tuna ranches’ cages, amounted to some 6,400,000 kgs. This figure, though somewhat higher than those of the industry at the time, has subsequently never been contested or challenged, either by the industry itself or by the Maltese government.
2. During the course of ICCAT’s 20th Regular Meeting held in the Turkish city of Antalya, November 9 to 18 2007, the Japanese delegation circulated amongst all attending Contracting Parties, a document (CoC 317) and entitled “Amount of Bluefin tuna caged for Farming – Submitted by Japan – Based on Industry Information, Source: Suisan Times 10/15/2007”.
According to that document, Malta had caged 5,900,000 kgs of live bluefin tuna during 2007.
This data was not contested by Maltese government officials attending that meeting as members of the EU delegation.
3. The Fisheries Department would now have us believe that the total amount of live bluefin tuna caged inside Maltese tuna ranches during 2007, amounted to a staggering 7,983,435 kgs and that Malta’s 2007 over-carry of live tuna onto 2008 would amount to some 1,346,639 kgs! This is indeed highly incorrect and can be easily demonstrated by checking Malta’s BFT caging declarations to the EC Fides database.
4. Malta’s declared BFT caging capacity to ICCAT back in 2007, amounted to 9,650,000 kgs. Again, this was an incorrect figure by the Maltese government to ICCAT.
ATRT’s 2007 survey of Maltese tuna ranches conclusively determined that the real caging maximum capacity of these farms back in 2007 amounted to a staggering 11,700,000 kgs.
a. On one hand, 350,000 kgs maximum capacity tuna ranch Mediterranean Tuna Ltd., registered with ICCAT under number ATEC1MLT00005 and allegedly located off Benghajsa, was not operative that year.
b. AJD Tuna Ranch, located at Comino Channel, registered with ICCAT under number ATEC1MLT00002 (total maximum caging capacity declared to ICCAT amounts to 800,000 kgs) held 20 empty 50-metre diameter cages with a total real maximum capacity of 3,000,000 kgs! This is proven by aerial photographic footage of such site, taken by ATRT on 19 July 2007.
c. Moreover, the Maltese government has and still is erroneously declaring to ICCAT that AJD Tuna ranch at St. Paul’s Bay has a maximum capacity of 2,500,000 kgs. How can this possibly be when the standard maximum ranching capacity for nine 50-metre diameter tuna cages is 1,350,000 kgs, that is 150,000 kgs per cage?
5. According to Japan’s Bi-annual Statistical Export and re-export Declaration (ICCAT Circular 0500-08, corresponding to Japan’s imports of BFT either fished and/or ranched by or in Malta during the period July to December 2007) Malta would have exported to Japan some 5,306,762.20 kgs of processed fresh and frozen BFT during the period July to December 2007. The equivalent live-weight of that fish, once all official conversion factors are applied to previously mentioned exports, would amount to 5,321,621.74 kgs.
Previously mentioned Japanese statistics are expressly detailed in terms of who the fishing and primary exporting country was, who the re-exporting country was, where was the point of export or last point of re-export, whether the tuna was wild-caught or ranched, thus allowing avoiding any misinterpretation of those given figures.
Out of those equivalent live-weight 5,321,621.74 kgs of bluefin tuna, 4,556,463.39 kgs corresponded to ranched bluefin tuna, all of it, again according to Japan, ranched at Maltese tuna ranches during 2007.
The Fisheries Department’s figures would have us now believe, among other things, that 476,951 kgs (processed weight) of that fish were ranched in Morocco and transhipped in Malta!
But there were no operative tuna ranches in Morocco back in 2007. As a matter of fact, that fish was indeed ranched inside Maltese tuna ranches. It was allegedly caught in international waters adjacent to Malta under Moroccan ICCAT BFT quota, by Moroccan flagged purse-seiner FV/LE MARSOUIN on or around 20 June 2007. Photographic evidence obtained by ATRT, confirms such information.
The fish was then transferred live into Maltese tuna cages, ranched and exported. Strangely enough, none of these exports appear on Japan’s Bi-annual Statistical Export and Re-Export Declaration corresponding to its imports of BFT during the period July to December 2007. The only recorded exports of Moroccan caught bluefin tuna via Malta to Japan, correspond to wild purse-seined BFT with an equivalent live fish weight of 54,500 kgs. That fish was then re-exported to Korea.
Where the alleged 476,951 kgs of bluefin tuna were exported to, is yet to be known; what is clear is that it was purchased live, ranched, slaughtered and re-exported by a Maltese tuna ranch during the third and fourth quarters of 2007. This is so much true that the fishing net used by LE MARSOUIN was in fact lent to it in Valletta, as proven again by photographic evidence obtained by ATRT.
Incidentally, Morocco declared to ICCAT back in 2007, having purse-seined some 600,000 kgs inside the Mediterranean and under its national ICCAT 2007 BFT quota.
6. To the left are the official Fisheries Division stats detailing a number of cases in which foreign ranched bluefin tuna has been transhipped at Malta .
After carefully reviewing such data, we conclude that not one of such transhipments of bluefin tuna at a Maltese port during the third and fourth quarters of 2007 has in any way or form been contemplated or wrongfully recorded as a Maltese re-export to Japan in that country’s Bi-annual Statistical Export and Re-Export Declaration (Reference: ICCAT Circular 0500-08, corresponding to Japan’s imports of BFT either fished and/or ranched by or in Malta during the period July to December 2007).
Therefore the figure of over 11 million kgs mentioned in MaltaToday’s article, rightfully does not include bluefin tuna ranched in other EU Member States or third countries’ tuna ranches during Q3+Q4 2007 that was transhipped in Malta for containerized re-export to Japan during that same period. Having done so would have wrongfully increased Malta’s Q3+Q4 2007 ranched bluefin tuna exports to Japan by as much as 2,940,731 kgs!
7. According to Eurostat, Malta would have exported to other countries than Japan, some 7,700 kgs of processed fresh BFT (therefore caught during 2007) during the period January to December 2007. The equivalent live-weight of that fish, once all official conversion factors are applied to previously mentioned exports, would amount to 8,932 kgs. Eurostat not identifying such fish as wild-caught or as having been ranched, such figure is therefore not computed.
8. According to Japan’s Ministry of Finance-Customs, Malta would have exported to Japan an extra 3,793,988 kgs of processed fresh and frozen BFT during the period January to April 2008.
All of such fish is to be considered as having been ranched, since there was simply no bluefin tuna fishery at sea during those months. In other words, such tuna was caught during 2007 but harvested in 2008. Once all official conversion factors are applied to previously mentioned exports, the equivalent live-weight of that fish, would amount to some 5,647,521 kgs.
According to the Fisheries Division’s statement, 1,699,064 kgs of Libyan and Turkish processed ranched bluefin tuna was transhipped at Malta between January 8 and January 31, 2008. Of these, 469,600 kgs on January 8, 2008 would correspond to bluefin tuna declared under Turkish ICCAT 2007 quota, and 1,229,464 kgs on January 31, 2008 to bluefin tuna declared under Libyan ICCAT 2007 quota.
Libya not having operated a single ICCAT registered tuna ranch inside its territorial waters during 2007 and the first semester of 2008, the entirety of such fish would have therefore allegedly been ranched at Turkish facilities.
In essence, Mr Gruppetta is claiming that for such fish, having been transhipped at a Maltese port onto containers bound to Japan, Malta would have not validated the original statistical documents issued by the flag countries of the fishing vessels having caught such fish, but rather issued re-export certificates thus confounding Japanese customs as to the exact origin of the commodity being imported into Japan! Such a suggestion is simply preposterous.
How is it possible for anyone to issue a re-export certificate for a merchandise that was never imported and was thus in mere transit?
Frozen processed bluefin tuna transhipped at a Maltese port is just that: a transhipped commodity. It is not reprocessed in Malta, therefore no added-value is locally produced by Malta on such commodity. Malta could have therefore only validated the original Turkish and Libyan statistical documents pertaining to the fishing vessels having caught such fish, issued by their respective flag countries.
Furthermore, according to Turkey’s Bi-annual Statistical Export and Re-export Declaration (Reference: ICCAT Circular 1429-08, corresponding to Turkey’s re-exports of BFT ranched in Turkey, during the period January 1 to June 30 2008), the total amount of Libyan ICCAT quota Bluefin tuna having been ranched in Turkey and re-exported during Q1+Q2 2008 was 1,062,649.42 kgs, that is 166,814.58 kgs less than what Mr Gruppetta is claiming as having been transhipped in Malta on 31 January, 2008!
Therefore, the figure of over 11 million kgs mentioned in Malta Today’s article, rightfully does not include Bluefin tuna ranched in Turkey, exported or re-exported during Q1+Q2 2008 and transhipped in Malta for containerized export to Japan during that same period. Having done so would have wrongfully increased Malta’s Q1+Q2 2008 ranched Bluefin tuna exports to Japan by as much as 1,699,064 kgs!
9. Finally, Mr. Gruppetta states that the total amount of Bluefin tuna lost at the Mare Blu tuna ranch located at the Aquaculture Zone off Xrobb I-Ghagin, during the third week of October 2007, amounted to 1,253,189 kgs. The extreme accuracy of such figure nevertheless raises the legitimate question as to how that figure could have possibly been obtained. Was all of the dead fish recovered? How were the escaped tunas accounted for? According to industry reports, the loss would have amounted to some 1,600,000 kgs.
