A Response to Carl Walters

Recently on CFOOD we started a new series where we talk to fishery biologists and let them steer the conversation. We post one per week (typically on Wednesdays!) and invite anyone to comment or respond to whatever statements our interview subjects make. Our first conversation was with Carl Walters who spoke strongly on the precautionary principle. Here, Kevern Cochrane of Rhodes University, South Africa responds.

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A Response to Carl Walters by Kevern Cochrane

Carl raises some important points and concerns about applications of the precautionary approach in fisheries management, in particular that risk aversion is often taken to unnecessary extremes to the detriment of fishers. I share that concern, which is captured in the title of this interview – misuse of the precautionary approach. I also agree with much of what he suggests as the solution to the problem, in particular his recommendations that we need balanced policies that represent the long term interests of the general public and the interests of fishers and that harvest control rules (or, by extension, any set of management measures) can be developed on the basis of some form of utility maximizing policy that maximizes the utility for the set of stakeholders. During his career, Carl has frequently led the way in developing approaches for achieving such goals and in promoting and facilitating their implementation.

There are, however, aspects of his point of view as expressed in his interview, that I disagree with. These can be simplified down to two basic points. The first point is that he blames the concept of the precautionary approach for the problem, whereas the real problem, as reflected in the title of the interview, is the misuse of the approach, rather than the approach itself. There are strong parallels between this argument of Carl’s and another one in which I recently found myself embroiled, which was a proposal by another stock assessment icon, Doug Butterworth, that it was time to drop the term ‘ecosystem approach to fisheries’ (EAF). I would have hoped that the need for even considering such a proposal was at least a decade behind us but agreed to oppose the proposal at an informal debate held in Cape Town last November. There were several points of difference in our respective opinions but a key difference was that I argue that the frustrations and complexities that have been experienced in implementing EAF and that drive Doug to wanting to drop the term are not the result of the concept itself, but that implementation of the concept requires recognizing and confronting the diverse goals and perspectives of the different stakeholders who are competing for scarce resources. It is those differences, which exist independently of any terms and concepts that we may adopt, that lead to the often exasperating conflicts and challenges in achieving sustainable and productive use of marine resources.

In my view, the precautionary approach, as with EAF, is simply common sense packaged in a way that, in an attempt to be precise, probably makes it sound more complicated and scientific than it is or needs to be. The FAO Guidelines on the Precautionary Approach summarise the precautionary approach as follows, omitting a few less relevant bullet points given there (Para 6., FAO, 1996):

The precautionary approach involves the application of prudent foresight. Taking account of the uncertainties in fisheries systems and the need to take action with incomplete knowledge, it requires, inter alia:

a. Consideration of the needs of future generations and avoidance of changes that are not potentially reversible;

b. Prior identification of undesirable outcomes and of measures that will avoid them or correct them promptly;

c. That any necessary corrective measures are initiated without delay, and that they should achieve their purpose promptly, on a timescale not exceeding two or three decades;

d. That where the likely impact of resource use is uncertain, priority should be given to conserving the productive capacity of the resource;

e. That harvesting and processing capacity should be commensurate with estimated sustainable levels of resource, and that increases in capacity should be further contained when resource productivity is highly uncertain

…and

h. Appropriate placement of the burden of proof by adhering to the requirements above.

With the possible exception of the specification of a generic time frame for recovery measures (two to three decades), I doubt whether there is anything there to which the majority of experienced fisheries scientists and managers would take particular exception. They would probably hold the view that all of that is simply part of sensible management, which is certainly my view too. In practice, the precautionary approach, as described above, should be firmly embedded in management, perhaps to the point where it is no longer required to be seen as an explicit component – as long as it is in there and working.

The problem, however, is that several of the terms in those bullet points, as with details of the ecosystem approach, are wide open to different interpretations: for example, what are undesirable outcomes (point b.), how uncertain is uncertain (point d.) and what is ‘appropriate’ placement of the burden of proof (point h.)? The specific answers to those questions will vary from case to case and it would be impossible to give precise guidance applicable to all fisheries. This gives rise to opportunities for stakeholders or interest groups to argue for their own interpretations, including the risk averse biologists that bear the brunt of Carl’s criticism. However, the precautionary approach has not created these sources of conflict, it has simply recognized that they are out there and attempted to make them explicit. In theory at least, putting those conflicts up front and confronting them should make it easier for them to be dealt with in a rational and science-based manner. The real problem, however, is that rationality and science-based reasoning are all too frequently not a priority of many of those with vested interests, unless they help them to achieve their own pre-determined goals (see e.g. Cochrane 2015 on the use and misuse of CITES in fisheries).

The second major point of difference, which I can address more briefly, is the perspective that fisheries management is mainly about meeting the needs of the fishers (in the text accompanying the interview, this is reflected in the alternative that Carl proposes for the precautionary approach, which is to identify ‘harvest control rules that maximize expected utility for a risk-averse community of fishermen’. What is missing from here, although Doug Butterworth may disagree, is all the other stakeholders that are competing for space, fish, other dependent species or other marine resources. These include conservationists, competing fishing sectors using the same or overlapping fish resources, the tourist industry, coastal development and others. In nearly all fisheries at least some of those competing groups need to be included in the utility function, amongst which the fishing sector and conservation concerns are often the most prominent. This is where all the conflicts and differing perspectives on objectives and risks come into play. Again, these conflicts are not generated by the precautionary approach, or the concept of EAF, but come more clearly to the surface when these approaches are implemented.

In my view therefore, the problem is not the precautionary approach itself, but the way it can be misused by any stakeholder group intent on pursuing its own objectives to the exclusion of others. Human behaviour is notoriously difficult to manage but the solution is not to abandon attempts to provide a common sense framework for balanced and sustainable management but to put measures in place to restrict misuse as far as possible, such as ensuring balanced stakeholder participation in decision-making and utilising truly independent peer-review of all aspects of management and decision-making.

Kevern Cochrane is a professor in the Department of Ichthyology and Fisheries Science at Rhodes University, South Africa

 

 

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