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ACIAR PROJECT FIS/2006/142 SUMMARY REPORT ON THE CONTROL AND MANAGEMENT OF ILLEGAL, UNREPORTED AND UNREGULATED (IUU) FISHING IN INDONESIAN FISHERIES MANAGEMENT AREA 573 FINAL REPORT

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Page 1: summary report on iuu fishing - aciar project fis/2006/142

ACIAR PROJECT FIS/2006/142

SUMMARY REPORT ON THE CONTROL AND MANAGEMENT OF ILLEGAL, UNREPORTED AND UNREGULATED (IUU) FISHING IN INDONESIAN

FISHERIES MANAGEMENT AREA 573

FINAL REPORT

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ACIAR PROJECT FIS/2006/142

SUMMARY REPORT ON THE CONTROL AND MANAGEMENT OF ILLEGAL, UNREPORTED AND UNREGULATED (IUU) FISHING IN

INDONESIAN FISHERIES MANAGEMENT AREA 573

FINAL REPORT This report is an extension output from ACIAR Project FIS/2006/142, Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) Fishing. This project was a collaboration between Agency of Marine and Fisheries Research and Development (Indonesia), Directorate General of Capture Fisheries (Indonesia), University of Wollongong (Australia) and Commonwealth Scientific and Industrial Research Organisation (Australia). Suggested citation: West, R.J., Palma-Robes, M.A., Satria, F., Wudianto, Purwanto, Sadiyah, L., Prasetyo, A.P., Faizah, R. and Setyanto, A. (2012). The Control and Management of Illegal, Unreported and Unregulated (IUU) Fishing in Fisheries Management Area 573. Report prepared for ACIAR Project FIS/2006/142, Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) Fishing. Australian National Centre for Ocean Resources and Security (ANCORS), University of Wollongong, Australia. 56 pp. ISBN: 978-1-74128-225-2 (hardcopy) ISBN: 978-1-74128-226-9 (ebook)

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CONTENTS

1. EXECUTIVE SUMMARY .................................................................................................... 5

1.1 Background ................................................................................................................ 5

1.2 Summary of IUU Fishing Issues .................................................................................. 5

1.3 Summary of Fishery-Specific IUU Fishing Issues ........................................................ 6

2. PROJECT STAFF ................................................................................................................ 8

3. INTRODUCTION ............................................................................................................... 9

4. DATA COLLECTION METHOD......................................................................................... 11

5. NATIONAL FRAMEWORK TO MANAGE FISHERIES AND COMBAT IUU FISHING IN INDONESIA ......................................................................................................................... 12

5.1 Indonesian Fisheries Management Areas and Fishing Zones .................................. 12

5.2 Registration and Licensing of Fishing Vessels .......................................................... 17

5.3 Fisheries Data Collection and Logbook System ....................................................... 18

5.4 Port State Measures ................................................................................................ 19

5.5 Trade Regulations .................................................................................................... 20

5.6 Other Fisheries Policies and Regulations ................................................................. 20

5.7 Institutions Involved in Fisheries Management....................................................... 20

6. LOCAL FISHERIES MANAGEMENT FRAMEWORK ......................................................... 22

6.1 Palabuhanratu, Sukabumi (West Java) .................................................................... 23

6.2 Cilacap (Central Java) ............................................................................................... 24

6.3 Muncar, Banyuwangi (East Java) ............................................................................. 25

6.4 Pacitan, Pacitan (East Java) ...................................................................................... 26

6.5 Kedonganan (Bali Province) ..................................................................................... 28

6.6 Pengambengan, Jembrana (Bali Province) .............................................................. 28

6.7 Gunung Kidul (Yogyakarta) ...................................................................................... 28

6.8 Baron, Gunung Kidul (Yogyakarta) ........................................................................... 29

6.9 Sadeng, Gunung Kidul (Yogyakarta) ......................................................................... 30

6.10 Tanjung Luar, Lombok (NTB) .................................................................................. 31

7. SUMMARY OF IUU FISHING IN LOCAL PORT AREAS .................................................... 33

8. SYNTHESIS OF THE IUU FISHING STUDY ....................................................................... 45

8.1 IUU Fishing in the Lobster Fishery ........................................................................... 45

8.2 IUU Fishing in the Lemuru Fishery ........................................................................... 45

8.3 IUU Fishing in the Shark Fishery .............................................................................. 46

9. SOME RECOMMENDATIONS AND FUTURE CONSIDERATIONS ................................... 47

10. ACKNOWLEDGMENTS ................................................................................................. 49

11. REFERENCES ................................................................................................................. 50

12. FURTHER INFORMATION ............................................................................................ 52

13. ATTACHMENT: INTERVIEW QUESTIONS (IUU FISHING STUDY)................................. 53

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List of Tables

Table 1. Fishing Gears and Vessels Allowed in Indonesian Fishing Zones ............................... 14

Table 2. Description of IUU Fishing in Palabuhanratu, Sukabumi (West Java) ....................... 33

Table 3. Description of IUU Fishing in Cilacap, (Central Java) ................................................. 34

Table 4. Description of IUU Fishing in Muncar, Banyuwangi (East Java) ................................. 35

Table 5. Description of IUU Fishing in Watukarung and Pacitan (East Java) ........................... 37

Table 6. Description of IUU Fishing in Kedonganan (Bali) ....................................................... 38

Table 7. Description of IUU Fishing in Pengambengan, Jembrana (Bali) ................................. 38

Table 8. Description of IUU Fishing in Gunung Kidul (Yogyakarta) .......................................... 39

Table 9. Description of IUU Fishing in Baron, Gunung Kidul (Yogyakarta) .............................. 40

Table 10. Description of IUU Fishing in Sadeng, Gunung Kidul (Yogyakarta) .......................... 41

Table 11. Description of IUU Fishing in Tanjung Luar, Lombok (NTB) ..................................... 41

Table of Figures

Figure 1. Fisheries Management Areas of Indonesia ............................................................... 13

Figure 2. Stock Status in Indonesia’s Fisheries Management Areas......................................... 14

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1. EXECUTIVE SUMMARY

1.1 Background This Final Report is an extension output of ACIAR Project FIS/2006/142: “Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) Fishing”. The project was a collaboration between the Agency of Marine and Fisheries Research and Development (AMFRD) and Directorate General of Capture Fisheries (DGCF), both of Indonesia’s Ministry of Marine Affairs and Fisheries, together with Australian partners University of Wollongong and Commonwealth Scientific and Industrial Research Organisation (CSIRO). The project commenced in 2008 with three principle objectives: 1. To develop new, fishery-specific stock assessment processes. 2. To develop new, innovative fisheries policy and management frameworks. 3. To develop improved scientific and policy frameworks for sustainable management of Red Snapper stocks within Indonesian waters. Phase 1 of the project included a survey of all marine fisheries at ten fishing ports in six provinces: Tanjung Luar (West Nusa Tenggara), Kedonganan (Bali), Pengambengan (Bali), Muncar (East Java), Pacitan (East Java), Sadeng (Yogyakarta), Gunung Kidul (Yogyakarta), Baron (Yogyakarta), Cilacap (Central Java), and Pelabuhanratu (West Java). In March 2009, three fisheries were chosen for in-depth study: Lobsters of south coast Java, sardines (lemuru) of Bali Strait, and the shark fishery of East Lombok. These fisheries became the focus for objectives 1 and 2 above during Phase 2. This required as complete as possible assessments of these selected fisheries through collation of existing information, field investigations, interviews with fisheries officers at all levels (National, Provincial, District and Sub-district), interviews with port authorities, fishers associations, fishing companies, and from consultations with all relevant stakeholders in workshops. Key issues were identified for each fishery and draft recommendations formulated to address the needs for improved fisheries statistics, seasonal market sampling, biological research, stock assessments, improved fisheries laws, regulations and management, and also addressing IUU fishing problems.

1.2 Summary of IUU Fishing Issues A number of IUU fishing concerns have been highlighted in the provinces of East Java, Central Java, West Java, Bali, Yogyakarta, and West Nusa Tenggara particularly in the ten fishing ports identified above. The most common illegal fishing activities identified by respondents in all provinces include illegal fishing by migrant (andon) fishers and to a lesser extent by foreign fishing vessels; fishing without registration and licences, particularly for small fishing vessels; use of fishing gears or methods which are prohibited in specific fishing zones; non-compliance with port requirements; and landing of fish outside designated landing areas. Unreported fishing includes non-reporting or misreporting of catch, as well as the lack of recorded fisheries data as a result of landing fish outside home ports. The non-implementation of the logbook system is also a major factor contributing to unreported fishing in the six provinces. Another factor that causes

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unreported fishing is the incompatibility of data collection systems between the local and national governments. Some data collected in the sub-district, district and provincial ports are inadvertently lost in the process of data aggregation for purposes of national fisheries statistical reporting. Unregulated fishing also occurs in the project areas in various forms, such as the absence of adequate regulations for small fishing vessels, lack of specific regulations adopted for the lobster fishery, lack of adequate regulations for the management of small scale fishing vessels, lack of adequate implementation of management measures and fisheries regulations, particularly in respect of mesh sizes and fishing in rumpons (fish aggregating devices), and non-application of sanctions to fisheries violations. The absence of strict port arrival and clearance requirements are also considered as examples of unregulated fishing which may further encourage illegal and unreported fishing. Other issues were raised by the local fishing communities and fisheries and port authorities, some of which are relevant for the control of IUU fishing. These issues include the decline of some fish stocks such as lemuru, which impact on the supply of domestic and overseas markets; environmental and habitat degradation; lack of legal limit for fish catch; lack of coordination between authorities undertaking fisheries functions; lack of effective enforcement; and the lack of adequate socialisation on rules and regulations. Other issues include the lack of government support for fishers during lean months and inadequate port facilities.

1.3 Summary of Fishery-Specific IUU Fishing Issues Among the three fisheries investigated, the lobster fishery was deemed to be the most unregulated and unreported. As previously highlighted, there are no specific regulations on the size of lobsters which may be caught, as well on allowed gears. Fishers rely on traditional practices and knowledge in catching lobsters. Fishing vessels targeting lobsters are also relatively small compared to vessels targeting other stocks; hence most of lobster fishers using cliff krendet do not land their catch in PPI (Pangkalan Pendaratan Ikan or Fish Landing Place). Lobster fishers land and deliver their catch directly to fish collectors, without any legal requirement to submit any record to fisheries or port authorities. In certain districts such as in Pacitan, catches of species bound for export are exempted from being landed in designated ports, although some export data may be recorded before the lobster products leave the country. Such limited regulations on lobster fisheries may be seen as encouraging unreported fishing. Similarly, lobsters are also not classified suitably in national fisheries statistics. The key illegal fishing concerns for the lobster fishery in the provinces of West Java, Central Java, Yogyakarta, East Java and Bali include the use of poison (i.e. potassium cyanide) and compressors particularly by migrant fishers, as well as the negative impact of abandoned gears that trap lobsters (ghost fishing), stunt their growth and increase their mortality. The IUU fishing issues in the lemuru fishery are slightly different than those in the lobster fishery. The lemuru fishery is generally regulated under national and local fisheries regulations, as well as the agreement between East Java and Bali provinces on fishing in East Java waters. A draft Management Plan was also prepared for the lemuru

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fishery in the Bali Strait 30 years ago; however, this plan has not been fully implemented and requires updating. Illegal fishing appears to be the main problem in the lemuru fishery. For larger vessels targeting lemuru, unregulated fishing occurs mostly in the form of conflict between the use of fishing gears and methods. There have also been reports on illegal fishing by vessels without proper registration documents or licences. For smaller fishing vessels targeting lemuru, the key issue is non-reporting of catch. Additional purse seine vessels have also been operating in the Bali Strait beyond the number of fishing vessels agreed in the management plan. These IUU fishing activities impact on the seasonal availability of lemuru fishery in the Bali Strait, which in turn affect domestic and overseas trade. Environmental changes have also been cited as a factor that impact on the sustainability of lemuru fishery. In the course of the research project, potential issues related to the lack of proper classification of sardine species in fisheries statistics were also raised. Shark fishery in Indonesia may be generally considered as a regulated fishery, with the National Plan of Action for Shark and Ray Management (NPOA-Sharks), adopted in 2010 consistent with the FAO International Plan of Action for the Conservation and Management of Sharks. It is noted however that not all components of the NPOA-Sharks are implemented in the Tanjung Luar fishery; however the fishery is governed largely by a community-based or traditional form of management called awig-awig which is also recognised under Indonesian law as integrative to fisheries management plans. This management system based on local wisdom is considered a ‘living law’ and provides a list of fishing activities which are generally accepted by the community. In the Tanjung Luar shark fishery, data collected through the ACIAR project market sampling have been found to be very similar to the data gathered through regular enumeration activities by fisheries authorities, which may indicate a low level of unreported fishing in port. However fisheries authorities have indicated that there may be some discrepancies between the data collected by TPI, PPI and Dinas kabupaten on sharks. Data collection in Tanjung Luar can be contrasted from that in other ports such as Palabuhanratu and Cilacap where sharks are also a target species. In these ports unreported fishing is a major issue caused by a lack of proper identification of shark species. There are also inaccurate data in areas where sharks are a bycatch. Despite the lack of government regulations and conservation measures on sharks in Tanjung Luar (e.g. legal size of sharks to be caught and landed), stakeholder interviews reveal that the key issues for the fishery focus more on the need to improve port and post-harvest infrastructure, marketing of sharks and dissemination of information, rather than the presence of IUU fishing. The perception of the fishing community is that the current traditional framework based on awig-awig is sufficient to effectively manage the shark fishery in the area.

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2. PROJECT STAFF Staff of the project’s partner organisations who participated in the surveys for the investigation of IUU fishing in the project areas and/or contributed to relevant workshops and/or to this Final Report are as follows: Indonesia Australia RCFMC/RIMF: UOW: Dr Purwanto Dr Ron West Dr Wudianto Dr Mary Ann Palma Dr Fayakun Satria Mr Arief Setyanto Mr Mohammad Fauzi Mr Andria Ansri Utam a CSIRO Dr Lilis Sadiyah Dr David Milton Mr Andhika Prima Prasetyo Dr Craig Proctor Ms Tri Ernawati Dr Cathy Dichmont Ms Retno Andamari1 Dr Rik Buckworth

Mr Gary Fry DGCF: Mr Darren Dennis Mr Agus Budhiman Dr Steve Blaber Dr Besweni Ms Sri Indrastuti Ms Riana Handayani Mr Diding Sudira Efendi

RCFMC = Research Center for Fisheries Management and Conservation RIMF = Research Institute for Marine Fisheries DGCF = Directorate General of Capture Fisheries CSIRO = Commonwealth Scientific and Industrial Research Organisation UoW = University of Wollongong

1 Ms Retno Andamari is staff of the Mariculture Research Institute at Gondol, Bali, but participated as part

of the RCFMC/RIMF team.

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3. INTRODUCTION Illegal, unreported and unregulated (IUU) fishing may be defined generally as an activity conducted in areas under national jurisdiction and on the high seas against domestic laws, conservation and management measures adopted by relevant regional fisheries management organisations, and general international obligations. Paragraph 3 of the International Plan of Action to Prevent, Deter, and Eliminate Illegal, Unreported and Unregulated Fishing provides the scope and nature of each of the components of IUU fishing. For Indonesia, illegal fishing means fishing in the archipelagic waters, territorial sea, and exclusive economic zone (EEZ) contrary to sub-district, district, provincial, and national laws and regulations. It also means fishing by Indonesian vessels in areas managed by regional fisheries organisations to which Indonesia is a member or cooperating non-member such as the Indian Ocean Tuna Commission (IOTC), Commission for the Conservation of Southern Bluefin Tuna (CCSBT), and the Western and Central Pacific Fisheries Commission (WCPFC). Unreported fishing includes non-reporting or misreporting of catch contrary to Indonesian regulations and relevant regional conservation and management measures. Lastly, unregulated fishing is conducted in areas where, or for fisheries in which, there are no regulations in place. Using the definition provided under the IPOA-IUU, the control of IUU fishing in Indonesia is clearly a shared responsibility of the government and the fishing industry. The economic losses to IUU fishing in Indonesia are estimated at $2 billion dollars annually. This value does not include the long-term impact on fish habitats and the marine environment, as well as the negative social effects on fishing communities. Some examples of IUU fishing in the country include illegal fishing by foreign vessels, use of poisonous substances and explosives in coral reef areas, use of prohibited gears in fishing zones, and fishing without proper documents and licences. Some of the factors that contribute to the increase in IUU fishing activities include the lack of effective regulations and inadequate monitoring, surveillance and enforcement capacity. This Report provides an assessment of the various types of IUU fishing for three fisheries, namely lemuru fishery, shark fishery, and lobster fishery, in relevant ports of the provinces of East Java, Central Java, West Java, Bali, and Yogyakarta. These port-based project sites are Palabuhanratu (West Java), Cilacap (Central Java), Muncar (East Java), Pacitan (East Java), Kedonganan (Bali), Pengambengan (Bali), Sadeng (Yogyakarta), Gunungkidul (Yogyakarta), Baron (Yogyakarta), and Tanjung Luar (Nusa Tenggara Barat). It addresses a component of the ACIAR Project which aims to gain an improved understanding of IUU fishing and its impact on the sustainable management of the three fisheries in these areas. The Report is composed of four parts. The first part (Section 5) provides a summary of applicable national laws and regulations for the management of fisheries in Indonesia. The second part (Section 6) presents regulations on fisheries in local jurisdiction. The third part (Section 7) summarises the scope of IUU fishing in each port. Based on the examination of IUU fishing in each jurisdiction, the fourth part of this Report (Section 8) provides an assessment of the IUU fishing in lemuru, lobster, and Tanjung Luar shark

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fishery. A detailed analysis of IUU fishing in each port is also available in a separate Port Report published for this ACIAR project.

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4. DATA COLLECTION METHOD Data collection through field visits and interviews were conducted in ten ports: Palabuhanratu (West Java), Cilacap (Central Java), Muncar (East Java), Pacitan (East Java), Kedonganan (Bali), Pengambengan (Bali), Sadeng (Yogyakarta), Gunung Kidul (Yogyakarta), Baron (Yogyakarta), and Tanjung Luar (Lombok). The field visit included interviews with boat owners, operators, marketers, as well as fisheries and port officials. Fisheries statistics and pertinent local regulations were also collected during the port visits. The main purpose of this survey and interview is to increase understanding on the management of lemuru, lobster, and Tanjung Luar shark fisheries in the project sites, by examining the socio-economic factors influencing such fisheries, as well as specific fisheries management measures and governing regulations on fishing vessel registration, licensing, marketing, trade, fisheries data collection, port control, fisheries enforcement, and socialisation. The perception and awareness of the fishing industry and Dinas fisheries and port authorities on IUU fishing were also investigated. Key members of the fishing industry, including leaders of fishers groups, fishing vessel masters and owners, fishers, and fish processors, were interviewed separately. Similarly, Dinas officials responsible for policy development, data collection, and enforcement, as well as harbour masters and their staff were consulted. Appendix I contains the interview questions used to guide the consultations with the fishing industry and government authorities, in both English and Bahasa Indonesia.

Stakeholder interviews and investigation of IUU-related activities

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5. NATIONAL FRAMEWORK TO MANAGE FISHERIES

AND COMBAT IUU FISHING IN INDONESIA The framework for the management of fisheries in Indonesia, including to prevent, deter and eliminate IUU fishing, may be summed up into two: a national fisheries framework which provides for the management of all types of fisheries in Indonesian waters, and a local fisheries management framework implemented at the district and provincial levels. This Part describes in brief the national fisheries management framework in Indonesia and measures to address IUU fishing, particularly the registration and licensing of fishing vessels, fisheries data collection, application of sanctions, port State measures, and other regulations. The national management framework for fisheries comprises national policies, laws, and regulations. The primary law governing fisheries is Law No 31/2004 Concerning Fishery, as amended by Law No 45/2009. Other national laws also apply such as the Law No 5/1983 on the Indonesian Exclusive Economic Zone, Law No 32/2004 on Shipping, Law No 22/1999 Regarding Regional Autonomy, and Law No 27/2007 on Coastal and Small Islands Management. Apart from these national laws, there are Governmental Regulations, Ministerial Decrees, and Ministerial Decisions which regulate various aspects of fisheries such as fishing vessel registration and licensing, fisheries business licensing, logbook system, transshipment of fish, fish aggregating devices (rumpons), fish marketing, vessel monitoring system, fisheries monitoring and surveillance, and fish ports and port state measures. These laws and regulations also implement Indonesia’s obligations under international instruments such as the United Nations Law of the Sea Convention (LOSC), United Nations Fish Stocks Agreement, FAO Compliance Agreement, and the FAO Code of Conduct for Responsible fisheries and its associated international plans of action on fishing capacity, seabirds, sharks, and IUU fishing. Law No 31/2004 Concerning Fishery, as amended by Law No 45/2009 provides for the conservation, management, and utilisation of fisheries resources in Indonesian waters. It contains specific provisions on fisheries information and statistical data system, fisheries licensing, research and development of fisheries, education, training and fisheries extension, small scale fishers and fish farmers, fisheries enforcement, establishment of fisheries tribunals, investigation and prosecution of fisheries violations, and fisheries penalties. The fisheries law is consistent with Law No 5/1983 which provides for the sovereign rights of Indonesia to explore, exploit, and manage natural resources in the EEZ.

5.1 Indonesian Fisheries Management Areas and Fishing Zones A key component of Law No 31/2004 is the development of fisheries management areas. Indonesia has established 11 fisheries management areas (WPP), the most relevant for this ACIAR project of which is the WPP 573 on Southern Java and a part of the Indian Ocean. Figure 1 presents the fisheries management areas of Indonesia.

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The objective of Indonesia is to develop fisheries management plans for each area, as well as stock specific fisheries plans at the national level. Except for a national plan of action for sharks and rays, and a management plan for lemuru in the Bali Strait, there are no other stock specific fisheries management plans formally adopted in Indonesia.

Figure 1. Fisheries Management Areas of Indonesia (Ministerial Regulation No PER.01/MEN/2009)

In Ministerial Decision 45/2011, the level of fish stock exploitation in each of the fisheries management areas has been determined. For WWP 573, shrimps, lemuru, bigeye tuna and southern bluefin tuna are overexploited; and small pelagic, red snapper, trevally, yellowfin tuna, and albacore tuna are fully exploited; while other types of demersal and tuna species are medium exploited. Figure 2 summarises the status of stocks for the different fisheries management areas.

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Figure 2. Stock Status in Indonesia’s Fisheries Management Areas (Ministerial Decree No KEP.45/MEN/2001)

Based on Government Regulation No 8/2011, the Indonesian waters are further divided into fishing zones as follows:

Fishing Zone IA: 0-2 nautical miles from the baseline

Fishing Zone IB: 2-4 nautical miles from the baseline

Fishing Zone II: 4-12 nautical miles from the baseline

Fishing Zone III: 12 up to the 200 nautical mile limit of the EEZ Indonesia has also issued Ministerial Regulation No 2/2011 which provides for the use of different fishing gears, fish aggregating devices (rumpons) mesh sizes, and size and types of fishing vessels which are allowed in each of the fishing zones. Table 1 presents a matrix summarising allowed gears and vessels in various fishing zones and fisheries management areas in accordance with Ministerial Regulation No 2/2011.

Table 1. Fishing Gears and Vessels Allowed in Indonesian Fishing Zones

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Note: Yellow marks indicate prohibited gears.

In addition to regulations on fishing zones and corresponding use of fishing gears, Indonesia has also adopted Agricultural Ministerial Decree No 51/KPTS/IK.215/1/1997 on Rumpons (Fish Aggregating Devices). This decree provides the classification of rumpons into demersal, deep sea, and shallow water rumpons. It regulates the location of rumpons and the distance that they can be deployed from navigation areas. Shallow and demersal rumpons can be deployed within 3 to 12 nautical miles with the permission of the district government. Deep sea rumpon can be deployed upon the permission of the Directorate General of Capture Fisheries, and can only used by fishing companies and not individual fishers. Government agencies and educational and research institutions may also deploy deep sea rumpons. Fishing corporations with licenced deep sea rumpons are required to report their catch every six months to the Directorate General of Capture Fisheries. The decree provides for the revocation of licences if reporting requirements are not obeyed.

5.2 Registration and Licensing of Fishing Vessels Fisheries and shipping law in Indonesia requires prior approval for vessel construction and import, admeasurement of vessels engaged in fishing, and registration of fishing vessels. A number of documents are required in applying to fly the Indonesian flag, including a proof of ownership in the form of a letter of agreement for the construction of the vessel, proof of identity of the owner, specification of the vessel, agreement from the shipyard for vessel registration, and information regarding size and vessel tonnage. For foreign vessels intending to change their flag into Indonesia, a deletion certificate from the authorities of the previous flag State is required. Although regulations on the registration may be clear for large fishing vessels (e.g. greater than 10GT), there are different practices in the district and provincial governments in this regard. Some district governments require vessels below 7GT to obtain Pas Kecil (Registration for Small Vessels) with the district government, vessels between 7-30GT to register and obtain Pas Tahunan (Annual Vessel Registration) with the provincial government, and those above 30GT to register with the Directorate General of Sea Communication in Jakarta. Some district governments do not require vessels smaller than 5GT or 7GT to register at all. These different practices in registering vessels create non-uniform rules inconsistent with regulations issued by the national government.

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Under the current fisheries management framework, the main purpose of the fisheries licensing system is to prevent or control the exploitation of fisheries resources beyond sustainable levels, as well as to collect fees for fishing activities. Similar to the process of registration, fishing vessel licensing falls under the jurisdiction of the central government, the provincial governments, and the district governments, depending on the capacity of the vessel. The central government is responsible for issuing licenses to fishing vessels greater than 30GT, vessels which use foreign employees and capital, or foreign vessels. Vessels less than 10GT are registered in the district government and vessels 10-30GT are registered in the provincial government. There are different types of fishing licences, namely fisheries business license (Surat Izin Usaha Perikanan or SIUP), fishing vessel and gear license (Surat Izin Penangkapan Ikan or SIPI), and a license for fish transporting vessels (Surat Izin Kapal Pengangkut Ikan or SIKPI). Indonesia has currently placed a moratorium on issuing licences to foreign fishing vessels and is yet to enter into new bilateral access arrangements with other States for fishing within the Indonesian EEZ. While the requirements to obtain SIUP, SIPI, and SIKPI for large vessels are straightforward, there are different practices in the local governments on the issuance of licences for small vessels. Some vessels below 5GT or 7GT are only required to obtain Pas Kecil and not fishing licences.

5.3 Fisheries Data Collection and Logbook System In brief, fisheries data collection and analysis system in Indonesia involves a process of gathering, collating, and aggregating data gathered in villages, sub-districts, and district ports. Fisheries-related data collected by enumerators include the number of boats, catch per boat, and catch per species. Fisheries extension officers also visit villages and districts on separate occasions to collect catch and socio-economic data from fisheries households. This serves as a form of verification for data collected in port. The weekly, monthly, and quarterly fish catch is aggregated and computed with a raising factor to take into account catches which have not been sampled by the enumerators. The total catches from sub-districts and districts are aggregated per province and the total catches for the province are combined per region. The sums for all the regions represent the total catch and effort for the entire country and are published in an annual fisheries report. It is acknowledged that some details in catch and effort data are lost in the process of aggregation. For example, some species caught in villages, sub-districts, and districts may not be necessarily reflected in the annual fisheries statistical report because they are not categorised as the main species caught in Indonesian waters. A good example is lobster. While it is reported that there are six lobster groups in Indonesia, they are all classified as “spiny lobster” in national statistics. For some provinces and districts, the catch of lobster may not be reflected at all in the annual reports. In recognition of this problem, the Ministry of Marine Affairs and Fisheries is currently revising its fisheries data collection system and classification of fish species. There are also no other known procedures for verifying data collected in ports apart from the census conducted in

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villages (e.g. fisheries data is not compared with the data obtained from fish processing plants or those reported by fishing businesses). To assist in data collection, Indonesia has also adopted a logbook system where three logbook forms are required to be filled out by vessel masters and fisheries control or extension officers, in order to record details of fishing activities, including the transshipment of fish. However, the logbook system is yet to be implemented because most fishers deem it unnecessary or cumbersome to fill out logsheets. Some also believe logbooks translate to additional work for the crew and interfere with fishing operations. Most fishers are also unfamiliar with the logbook system. The only time that logbooks are accomplished is when fisheries extension officers interview the fishers and fill out the logsheets for them.

5.4 Port State Measures Indonesia recognises the critical role that ports play in the development of the fishing industry and in support of data collection. Ministerial Regulation 16/2006 on Fishing Ports classifies Indonesian ports into four:

Fish Landing Centre (Tempat Pelelangan Ikan or TPI, or Pelabuhan Pelelangan Ikan or PPI): The TPI or PPI are ports for vessels at least 3GT fishing in inshore and archipelagic waters. This type of ports should be able to accommodate about 20 vessels with a total capacity of 60GT. Amongst the various ports visited for the ACIAR project, the ports of Baron (Yogyakarta) and Kedonganan (Bali) are classified as TPI.

Coastal fishing port (Pelabuhan Perikanan Pantai or PPP): Coastal fishing ports are for vessels at least 10GT fishing inshore, archipelagic waters, and territorial sea. PPP ports should be able to accommodate about 30 vessels with a total capacity of 300GT. Sadeng (Yogyakarta) and Pacitan (East Java) are classified as coastal fishing ports or PPP.

Archipelagic fishing port (Pelabuhan Perikanan Nusantara or PPN): Archipelagic fishing ports are for vessels of at least 30GT fishing in the EEZ. PPN ports should be able to hold 275 vessels with total capacity of 2,250GT. Gunung Kidul (Yogyakarta), Muncar (Bali), Pengambengan (Bali) and Palabuhanratu (West Java) are PPN ports.

Oceanic fishing ports (Pelabuhan Perikanan Samudera or PPS): Oceanic fishing ports are for vessels at least 60GT fishing in the EEZ and on the high seas. About 100 vessels with a total capacity of 6,000GT should be able to land their catch in PPS. Amongst the project sites, Cilacap is classified as a PPS or an oceanic fishing port.

Each port has specific but similar regulations issued by the Harbour Master, including port clearance requirements, inspection of vessels and documentation, health and quarantine clearance, and collection and compilation of fisheries landing data. It could be noted that although the Ministerial Regulation on fishing ports provide the optimal capacity for fish ports in terms of vessel number and capacity, observations from port

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visits suggest that the TPI, PPP, PPN, and PPS in the provinces of West Java, East Java, Bali and Yogyakarta mostly exceed their vessel number limits and capacity.

5.5 Trade Regulations A number of regulations also apply in the trade of fishing activities, particularly those bound for export. These regulations include Hazard and Critical Control Points, Halal certificate requirements, ISO certificate compliance, and other food safety regulations based on Codex Alimentarius. Catch certification providing the origin of fish and a validated statement that the catch has been obtained legally also accompanies certain fish bound for international trade such as tuna.

5.6 Other Fisheries Policies and Regulations One relevant policy for the study of IUU fishing in Indonesia is the National Plan of Action for the Management of Sharks and Rays which was adopted consistent with the United Nations Food and Agriculture Organization (FAO) International Plan of Action for the Conservation and Management of Sharks (IPOA-Sharks). Six specific actions are identified in the Indonesian NPOA-Sharks: (1) Review status of shark and ray fisheries in Indonesia; (2) Compilation of methods and data collection process; (3) Development of shark and ray research; (4) Improving the management of sharks to make it sustainable and protect its habitats; (5) Enhance understanding on shark and ray fisheries; and (6) Institutional strengthening. Indonesia has also adopted a National Plan of Action on Fishing Capacity which provides measures in relation to licensing, surveillance and control, as well as data collection and reporting on fishing vessels and use of fishing gears. There are other fisheries regulations adopted in Indonesia which help address IUU fishing. These regulations include satellite-based vessel monitoring system for large fishing vessels conducting activities in Indonesian EEZ and on the high seas, regulations on the transshipment of fish, collection of fees or “retribution”, and application of sanctions for fisheries violations. Indonesian fisheries regulations provide for the payment of “retribution”, or fees for the landing and sale of fish, which are collected in port and often re-distributed to fisheries stakeholders for various purposes, such as the management of landing sites and ensuring the welfare of fishers. Law No 31/2004, as amended by Law No 45/2009, also provides penalties for various violations, ranging from 200 million to 2 billion rupiahs and imprisonment between one to ten years. Imprisonment of foreign crew caught conducting unlicensed fishing activities in the Indonesian EEZ is prohibited unless authorised under a bilateral agreement between Indonesia and the State flying the flag of the vessel with the foreign crew.

5.7 Institutions Involved in Fisheries Management The main government authority responsible for the conservation and management of fisheries resources is the Ministry of Marine Affairs and Fisheries (MMAF or KKP). In order to undertake its functions in all fishing areas, the Ministry has established satellite

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provincial and district fisheries offices. Apart from MMAF, there are other authorities undertaking different fisheries-related functions such as the Ministry of Sea Communication for the safety inspection and registration of fishing vessels, the Harbour and Fish Port Authority responsible for inspecting fishing vessels and documents in port and the landing of fish catch, and the Indonesian Navy and Police which are responsible for enforcing fisheries laws and regulations. The fishing industry and coastal and fishing communities are also considered as partners of the Government in the implementation of fisheries laws and regulations in Indonesia. Fisheries groups (kelompok nelayan) are active in most fish ports, particularly in their management and collection of retribution. Community based enforcement (POKMASWAS) are also formed in many districts to assist in the enforcement of fisheries regulations in local fishing areas.

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6. LOCAL FISHERIES MANAGEMENT FRAMEWORK Indonesian Law No 22/1999 provides for regional autonomy in Indonesia, or the decentralisation of certain governmental function to local governments, including villages (desa), sub-district (kecamatan), district (kabupaten), and provincial (provinsi) governments. The province (provinsi) is the highest tier of local government headed by a governor with its own legislative body. There are currently 33 provinces in Indonesia, grouped into seven geographical units, including West Java, Central Java, East Java, Bali, and the Yogyakarta Special Region. A province is divided into districts or kabupaten (also referred to as called districts or municipalities), and cities (kota). In general, districts have larger areas than cities and have agricultural economic activities. A district head is called a regent (bupati) and cities are headed by mayors (wali kota). There are currently 405 districts and 97 cities comprising the 33 provinces of Indonesia. Each district is divided into sub-districts or kecamatan, with a camat as the head of the sub-district. There are 6,543 sub-districts in Indonesia. The smallest political division in the country is called a village (desa). There are a total of 75,244 villages in the country. In relation to fisheries management, this legislation provides that the marine area of 12 nautical miles measured from the shore shall be under provincial authority for the purposes of exploring, exploiting, and managing resources, administrative and spatial arrangement, and law enforcement. From this provincial authority follows certain fisheries functions devolved to the district (kabupaten) and sub-district (kecamatan) governments. The administrative division of the five provinces investigated in this ACIAR Project, with reference to the port-based project sites for the IUU study, is explained as follows:

West Java is composed of nine cities and 17 districts, 598 sub-districts, and 5,708 villages. Sukabumi is one of the districts of West Java and Palabuhanratu is its capital.

Central Java has 29 districts and six cities. Cilacap is one of its districts, the capital of which is Cilacap.

East Java is divided into nine cities and 29 districts. The districts include Banyuwangi and Pacitan. Banyuwangi has 19 sub-districts, one of which is Muncar while Pacitan has 12 sub-districts, one of which is the Pacitan sub-district.

The Bali Province comprises one city and eight districts. Jembrana is one of its districts where Pengambengan is situated. Kedonganan is also a village found in Bali.

The Yogyakarta Special Region has four districts and one city. Gunung Kidul is one of its districts and Sadeng and Baron are two of its sub-districts.

The province of Nusa Tenggara Barat (NTB) has two cities and eight districts, one of which is East Lombok. Mataram is the capital of NTB province. Tanjung Luar is one of the coastal villages in the sub-district of Keruak, East Lombok.

These provinces and districts have local fisheries offices (Dinas Fisheries) while all sub-districts have port authorities. Some of the fisheries-related regulations in these local areas are discussed in the succeeding section.

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To encourage further development of local areas, Indonesia decided to implement integrated capture fisheries development program in order to promote fisheries industrialisation in a number of fishing ports. This program promotes regional development, particularly the development of leading commodities with fisheries as its economic base. It also aims to increase fishery productivity and value added products. The development program aims to empower coastal areas by encouraging self-reliance, local economic growth, and job creation. There are currently nine established development programs, including project sites such as Palabuhanratu (West Java), Muncar (East Java), and Cilacap (Central Java). Development programs are also planned in 2011 for 15 additional areas including Pengambengan (Bali) and Sadeng (Yogyakarta). These programs are expected to contribute to the development goals of the country in the marine and fisheries sector, particularly in contributing to increase in national gross domestic product, fisheries production, and value of fisheries exports. The objectives and specific plans under the development program for these areas are presented below. This part of the Report provides applicable regulations in each sub-district, district, and province, as made available to the Project.

6.1 Palabuhanratu, Sukabumi (West Java) Capture Fisheries Development Planning for Sukabumi Sukabumi Development Program focuses on capture fisheries for both marine and freshwater fish. There are three main objectives to this development program: (1) to increase production, productivity, and quality of fish products; (2) to increase revenue for fishers, fish farmers, fish processors; and (3) to promote the area as a centre of development in Sukabumi. One of the specific goals of Sukabumi Development Program is to increase production of tuna and tuna like species, other pelagic species, and shrimp/prawns from 8,759 tons to 9,187 tons a year, as well as fisheries export from 2,098 tons to 2,180 tons a year in volume terms. The program also aims to increase revenue for both fishing vessel owners (from 3.5 million rupiahs to 3.59 million rupiahs per month) and fishers (from 1.5 million to 2.2 million rupiahs per month). On the other hand, Sukabumi does not want to increase its fishing capacity in terms of vessel number. It also aims to decrease the number of fishing ports from six to five TPI or PPI, develop one new PPP, and upgrade one PPN to PPS by 2014.

Palabuhanratu fishing vessels using multi-gears

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6.2 Cilacap (Central Java) Local Regulation No 16/2001 on Fisheries Management in Segara Anakan This local regulation aims to promote the sustainable management of fisheries in Segara Anakan conservation area in Cilacap waters. It also divides this conservation area into zones, particularly for closed areas, limited access, and marine culture, including provisions on permitted fishing gears in such zones. Other provisions of the regulation include fishing seasons for crab, limitation on the number of fishing permits, concession rights for fishing, monitoring and surveillance, and penalties for violating provisions of the regulation. Local Regulation No 17/2001 on Mangrove Management of Segara Anakan The objective of this regulation is the sustainable management of Segara Anakan environment, habitats, and resources. It prohibits activities such as illegal logging and farming. There is no specific provision in this regulation on fishing activities. Local Regulation No 6/2001 on Master Plan for the Segara Anakan This local regulation provides for the use of Segara Anakan conservation area in Cilacap, such as housing, transportation, port development, use of jetties, and reserve areas (closed, culture, limited access). It also provides some guidelines on industrial developments around Segara Anakan. Fishing activities are generally allowed in this conservation area, but only with the use of environmentally friendly fishing gears. The local regulation also provides sanctions for activities contrary to the provisions of the regulation. Capture Fisheries Development Planning for Cilacap The Cilacap Fisheries Development Planning focuses on capture fisheries for both marine and freshwater fish. There are three main objectives to this program: (1) to increase production, productivity, and quality of fish products; (2) to increase revenue for fishers, fish farmers, fish processors; and (3) to promote the area as a center of development in Cilacap. One of the specific goals of Cilacap Development Program is to increase production of tuna and tuna like species, and demersal species from 9,727.8 tons to 13,388 tons a year, as well as fisheries export from 2,098 tons to 2,180 tons a year in volume terms. The program also aims to increase revenue for both fishing vessel owners (from 4.25 million to 5.90 million rupiahs per month) and fishers (from 1.5 million to 2.75 million rupiahs per month).

Cilacap port servicing longline vessels fishing in IOTC area

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Under the development program, Cilacap also aims to increase its fishing capacity in terms of the number of medium and large fishing vessels (e.g. for vessels 5GT-10GT, increase from 245 to 265); for 10GT-30GT, from 229 to 257; for 30GT-50GT, from 43 to 66 vessels); and for vessels more than 50GT, from 10 to 51 vessels. It also aims to increase the number of fishers and fish workers and encourage diversification of fishing businesses and additional investment. Lastly, Cilacap intends to increase the number of fishing ports, particularly the small landing sites (TPI) from ten to 13 ports.

6.3 Muncar, Banyuwangi (East Java) Agreement between East Java and Bali on Fishing in East Java Waters There is an existing agreement (Surat Keputusan Bersama) on the vessel number limit between the provinces of East Java and Bali with respect to fishing in East Java waters. The limits are 190 vessels for East Java and 83 vessels for Bali. Governor Decree No 9/1983 Regulating Migrant Fishers Migrant fishers (nelayan andon) are defined as fishers who fish in a different fishing ground outside their local area within a certain period of time. Fishing responsibilities of migrant fishers include planning their fishing activities within certain times and seasons and maintaining the sustainability of fisheries resources. In order to fish in a local area, migrant fishers need letters of permit from the local village or authority, and Dinas district and provincial offices responsible for the fishing area; fishing licence (SIPI); fishing business licence (SIUP); surat kapal (vessel registration); membership letter from KUD (fishers cooperative); and a notarised letter guaranteeing to obey local laws. Migrant fishers can fish outside the agreed fishing area only if they have permission from the Dinas province of their origin. Apart from this document, they also need permission from their home port or TPI/PPI. Migrant fishers are not allowed to use destructive fishing gears nor conduct fishing activities that have a damaging impact on the environment. They are also prohibited from selling their catch at sea and from operating purse seine gears in the Bali Strait. Non-compliance with the regulations would result in the revocation of the fishing licence. Governor Instruction Letter No 6/1983 on Migrant Fishers This provincial regulation mandates socialisation of the above decree on migrant fishers to the district level. It provides a list of documents required of migrant fishers from local authorities, as well as a schedule of fees to be paid by the migrant fisher. Capture Fisheries Development Planning for Banyuwangi The Banyuwangi Capture Fisheries Development Program focuses on capture fisheries for both marine and freshwater fish. There are three main objectives to this program: (1) to increase production, productivity, and quality of fish products; (2) to increase revenue for fishers, fish farmers, fish processors; and (3) to promote the area as a centre of development in Banyuwangi. One of the specific goals of Banyuwangi Development

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Program is to increase production of snappers, groupers, and prawns from 41,332 tons to 45,179 tons a year, as well as fisheries export from 16,901 tons to 17,726 tons a year in volume terms. The program also aims to increase revenue for both fishing vessel owners (from 1.68 million to 2.38 million rupiahs per month) and fishers (from 1.02 million to 2.08 million rupiahs per month). Under the development program, Banyuwangi intends to increase its fishing capacity in terms of the number of medium and large fishing vessels (e.g. for vessels 5GT-10GT, increase from 938 to 1,055); for 10GT-30GT, from 302 to 314; and for 30GT-50GT, from 474 to 475 vessels). It also aims to increase the number of fishers and fish workers and encourage diversification of fishing businesses and additional investment. Detailed Planning for Muncar as part of Banyuwangi Capture Development Program This Plan divides Muncar into fishing zones:

Fishing Zone I: Fishing Zone I further divided into two areas. The area between 0 to 3 nm is for passive fishing gears without modification. Fishing area between 3 to 6 nm is reserved for vessels using active gears with modification, non-powered vessel or powered vessel less than 5GT, purse seines with 150 meters length of net, and drift gillnets with 1,000 meters length of drift.

Fishing Zone II: The area between 6 to 12 nm is for vessels with maximum capacity of 60GT; fishing gears including purse seine of up to 600 meters length for one boat system and 1,000 meters length of seine for two boat system, and drift gillnet with maximum length of 2,300 meters.

6.4 Pacitan, Pacitan (East Java) Governor Decree No 9/1983 Regulating Migrant Fishers Migrant fishers (nelayan andon) are defined as fishers who fish in a different fishing ground outside their local area within a certain period of time. Fishing responsibilities of migrant fishers include planning their fishing activities within certain times and seasons and maintaining the sustainability of fisheries resources. In order to fish in a local area, migrant fishers need letters of permit from the local village or authority, and Dinas district and provincial offices responsible for the fishing area; fishing licence (SIPI); fishing business licence (SIUP); surat kapal (vessel registration); membership letter from KUD (fishers cooperative); and a notarised letter guaranteeing to obey local laws. Migrant fishers can fish outside the agreed fishing area only if they have permission from the Dinas province of their origin. Apart from this document, they also need

Fish drying business in Muncar

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authorisation from their home port or TPI/PPI. Migrant fishers are not allowed to use destructive fishing gears nor conduct fishing activities that have a damaging impact on the environment. They are also prohibited from selling their catch at sea and from operating purse seine gears in the Bali Strait. Non-compliance with the regulations would result in the revocation of the fishing licence. Governor Instruction Letter No 6/1983 on Migrant Fishers This provincial regulation mandates socialisation of the above decree on migrant fishers to the district level. It provides a list of documents required of migrant fishers from local authorities, as well as a schedule of fees to be paid by the migrant fisher. District Regulation No. 5/2002 on Retribution for Fish Auctions This regulation provides the tariff or payment of retribution for sellers and buyers during fish auction. It requires the payment of 5% retribution: 3% from the buyers and bakul, and 2% from fishers, farmers, or sellers. The income from collected retribution is divided between the local government, operations of the TPI/PPI and the maintenance of auction areas. This regulation also provides the process of auction. It requires all catch to be auctioned and sold in the TPI/PPI, except catch used for household consumption, research and recreation. Some fish bound for export may not have to be landed in TPI/PPI subject to the permission of the district regent or bupati. Furthermore, only buyers who have obtained permission from the bupati may transact business in TPI/PPI. Punishment for violation of this regulation is three months in jail or payment of five million rupiahs. Capture Fisheries Development Planning for Pacitan The Pacitan Fisheries Development Planning focuses on capture fisheries for both marine and freshwater fish. There are three main objectives to this program: (1) to increase production, productivity, and quality of fish products; (2) to increase revenue for fishers, fish farmers, fish processors; and (3) to promote the area as a centre of development in Pacitan. One of the specific goals of Pacitan Development Planning is to increase production of tuna and tuna like species, hairtails, and lobsters from 4,651 tons to 5,084 tons a year, as well as fisheries export from 1,969 tons to 2,065 tons a year in volume terms. The program also aims to increase revenue for both fishing vessel owners (from 1.59 million to 2.13 million rupiahs per month) and fishers (from 954,000 to 1.95 million rupiahs per month).

Pacitan Fishing Port

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Under the development program, Pacitan intends to increase its fishing capacity in terms of the number of medium and large fishing vessels (i.e. for vessels 5GT-10GT, an increase from 139 to 190 vessels); for 10GT-30GT, from 10 to 16 vessels; and for 30GT-50GT, from 6 to 30 vessels). It also aims to increase the number of fishers and fish workers and encourage diversification of fishing businesses and additional investment.

6.5 Kedonganan (Bali Province) Provincial Regulation No 17/1991 on Fisheries Business Permits This regulation provides the authority of the Governor to grant business permits. Before any business activity can takes place, the following documents need to be submitted: business tax number, certificate of business registration, vessel documents, location permit, and environmental impact assessment. The regulation also contains a schedule of retribution for each type of fishing gear, fishing vessel, and marine or aquaculture activity.

6.6 Pengambengan, Jembrana (Bali

Province) Agreement between East Java and Bali on Fishing in East Java Waters There is an existing agreement (Surat Keputusan Bersama) on the vessel number limit between the provinces of East Java and Bali with respect to fishing in East Java waters. The limits are 190 vessels for East Java and 83 vessels for Bali. Provincial Regulation No 17/1991 on Fisheries Business Permits This regulation provides the authority of the Governor to grant business permits. Before any business activity can takes place, the following documents need to be submitted: business tax number, certificate of business registration, vessel documents, location permit, and environmental impact assessment. The regulation also contains a schedule of retribution for each type of fishing gear, fishing vessel, and marine or aquaculture activity.

6.7 Gunung Kidul (Yogyakarta) Provincial Regulation No 6/2005 on Marine and Fisheries Business This regulation pertains to marine and fisheries business activities and provides for the need to state the origin of the fish in the trade of fish products. It contains a general provision on the payment of retribution for different types of marine and fisheries

Two-boat system in Pengambengan

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business activities. The regulation provides that small scale businesses are exempted from paying fees for capture and aquaculture related businesses. Provincial Regulation No 7/2005 on PPP (Coastal Fishing Ports) or Fishing Port Class C/Type III This provincial regulation provides the functions, responsibility, operations and maintenance of fishing ports, as well as their monitoring and control, application of sanctions, and payment of retribution. Provincial Regulation No 8/2005 on Retribution for Certain Permits and Provincial Regulation No 9/2005 on Retribution for All Types of Businesses Provincial Regulation No 8/2005 requires the payment of retribution for certain activities such as health services, tourism, housing, transportation, and fisheries business. It also applies sanctions for failing to pay the scheduled retribution. Provincial Regulation No 9/2005 provides the schedule of retribution for different types of services. Local Regulation No. 5/2007 on Retribution in Fish Auctions This regulation provides the payment of tariff or retribution by sellers and buyers during fish auction. It requires the payment of 5% retribution: 3% from the sellers and 2% from the buyers. This regulation also provides the process of auction. It requires all catch to be auctioned and sold in Gunung Kidul sub-districts. Furthermore, only buyers who are registered with the TPI/PPI can land their catch in port. Punishment for violation of this regulation is three months in jail or payment of five million rupiahs.

6.8 Baron, Gunung Kidul (Yogyakarta) Provincial Regulation No 6/2005 on Marine and Fisheries Business This regulation pertains to marine and fisheries business activities and provides for the need to state the origin of the fish in the trade of fish products. It contains a general provision on the payment of retribution for different types of marine and fisheries business activities. The regulation provides that small scale businesses are exempted from paying fees for capture and aquaculture related businesses. Provincial Regulation No 7/2005 on PPP (Coastal Fishing Ports) or Fishing Port Class C/Type III This provincial regulation provides the functions, responsibility, operations

Krendet vessels in Baron

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and maintenance of fishing ports, as well as their monitoring and control, application of sanctions, and payment of retribution. Provincial Regulation No 8/2005 on Retribution for Certain Permits and Provincial Regulation No 9/2005 on Retribution for All Types of Businesses Provincial Regulation No 8/2005 requires the payment of retribution for certain activities such as health services, tourism, housing, transportation, and fisheries business. It also applies sanctions for failing to pay the scheduled retribution. Provincial Regulation No 9/2005 provides the schedule of retribution for different types of services. Local Regulation No. 5/2007 on Retribution in Fish Auctions This regulation provides the payment of tariff or retribution by sellers and buyers during fish auction. It requires the payment of 5% retribution: 3% from the sellers and 2% from the buyers. This regulation also provides the process of auction. It requires all catch to be auctioned and sold in Gunung Kidul sub-districts. Furthermore, only buyers who are registered with the TPI/PPI can land their catch in port. Punishment for violation of this regulation is three months in jail or payment of five million rupiahs.

6.9 Sadeng, Gunung Kidul (Yogyakarta) Provincial Regulation No 6/2005 on Marine and Fisheries Business This regulation pertains to marine and fisheries business activities and provides for the need to state the origin of the fish in the trade of fish products. It contains a general provision on the payment of retribution for different types of marine and fisheries business activities. The regulation provides that small scale businesses are exempted from paying fees for capture and aquaculture related businesses. Provincial Regulation No 7/2005 on PPP (Coastal Fishing Ports) or Fishing Port Class C/Type III This provincial regulation provides the functions, responsibility, operations and maintenance of fishing ports, as well as their monitoring and control, application of sanctions, and payment of retribution. Provincial Regulation No 8/2005 on Retribution for Certain Permits and Provincial Regulation No 9/2005 on Retribution for All Types of Businesses Provincial Regulation No 8/2005 requires the payment of retribution for certain activities such as health services, tourism, housing, transportation, and fisheries business. It also applies sanctions for failing to pay the scheduled retribution. Provincial Regulation No 9/2005 provides the schedule of retribution for different types of services.

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Local Regulation No. 5/2007 on Retribution in Fish Auctions This regulation provides the payment of tariff or retribution by sellers and buyers during fish auction. It requires the payment of 5% retribution: 3% from the sellers and 2% from the buyers. This regulation also provides the process of auction. It requires all catch to be auctioned and sold in Gunung Kidul sub-districts. Furthermore, only buyers who are registered with the TPI/PPI can land their catch in port. Punishment for violation of this regulation is three months in jail or payment of five million rupiahs.

6.10 Tanjung Luar, Lombok (NTB)

The management framework for fisheries in Tanjung Luar is consistent with the national legislation on fisheries, Law No 31 of 2004 on Fisheries, as amended by Law No 45 of 2009, as well as applicable regulations. Although there are generally no specific local regulations on sharks and rays, the Tanjung Luar sharks and ray fisheries are under a traditional form of management called awig-awig which primarily relies on local wisdom. Community Guidelines on Awig-Awig Awig-awig refers to rules agreed by a local community to manage shark and ray fisheries in Tanjung Luar and may be considered as a form of community-based fisheries management. These rules, considered a ‘living law’ include a management system for the community which provides a list of fishing activities that may be undertaken by fisherfolks and those which are considered forbidden. Based on awig-awig for Lombok, the waters in the province are divided into fishing zones. Zone 1 is up to three nautical miles from the coast which is reserved for traditional fishing. Zone 2 is from three to six nautical miles which also accommodates traditional fishing. Zone 3, from six to nine nautical miles, may be used for commercial fishing. The rules of the awig-awig include prohibition from taking dolphins, turtles, dugong, Napoleon wrasse, and egg-bearing lobsters. Fishers are encouraged not to catch juvenile fish and egg-bearing squid. Fish bombing, use of cyanide, and use of electricity and destructive fishing methods are strictly prohibited. Similarly, businesses are also not allowed to buy fish from those who have conducted illegal activities. The awig-awig system applies a reverse burden of proof where the evidence needs to be presented by

Landing of rays in Tanjung Luar

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the company or person involved that he or she did not conducted any prohibited activity.

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7. SUMMARY OF IUU FISHING IN LOCAL PORT AREAS

The following tables summarise the various IUU fishing concerns identified by local respondents in each port of study. A more thorough assessment of IUU fishing issues in each local area is provided in individual Port Reports published for this ACIAR Project.

Table 2. Description of IUU Fishing in Palabuhanratu, Sukabumi (West Java)

Species caught: Sharks, lobsters with crab as bycatch, and other fish

Illegal Fishing

Some small boats do not have fishing licences. Some fishers of small vessels do not renew their fishing licences because they do not see the benefits of obtaining a licence.

Unreported Fishing

Recording of catch is not a common practice amongst fishers. Fish collectors do not report their catch to the authorities because there is no requirement to do so. Lobster fishing is unrecorded and unreported. Logbooks are carried onboard vessels of over 24m LOA, but port officials accomplish the forms for the fishers.

Unregulated Fishing

Although there are regulations on the registration of small vessels, there is a perception among some fishers that there are no specific in place. There are no specific regulations on the marketing of fish, creating unequal opportunities amongst fishers. Very few fisheries regulations implemented in Palabuhanratu. The main reason for obeying regulations is the safety of fishing vessels. Some of the rules on the use of fishing gears are only agreed collectively by fishers, especially those using lift nets, troll lines, and drift gill nets. Inadequate enforcement of fisheries regulations. Penalties are generally not applied to fisheries violations. The Government only pursues or encourages the fishers to obey rules, rather than giving direct penalties. Sanctions are only applied to foreign fishing vessels.

Other Issues There are no catch limits set by the Government. Some fishers capture

juvenile fish due to the perception that if they do not do so, such fish will be caught by other fishers anyway. Conflict between gill-net and troll-line vessels, as well as troll-line and purse seine vessels. Some gill-net fishers change their boat to fit troll-lines. There are some observations that the subsidies provided by the government are not received by fisherfolks who need them the most. Inadequate socialisation of fisheries rules. Some POKMASWAS are inactive. It was raised that monitoring, control and surveillance need to be

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improved in order to increase the level of compliance.

Table 3. Description of IUU Fishing in Cilacap, (Central Java)

Species caught: Lemuru, sharks, lobster, tuna, and other fish

Illegal Fishing

Illegal fishing in Segara Anakan area, particulary fishing using jaring apong which targets demersal fishes, but catch juvenile fish. The use of purse seine vessels in Cilacap waters is perceived as illegal by local fishers, although the use of such gear is not prohibited under the law. This is a common problem when new fishing gears are introduced in a local area. Illegal fishing by foreign vessels in Cilacap waters. Illegal fishing by Indonesian trawl-like gears. About ten percent of the total number of fishing vessels is believed to be operating without SIPI and SIUP.

Unreported Fishing

No requirement to report catch, particularly by small scale fishing vessels. Apong, which is one of the main fishing gears used in Segara Anakan is categorised under “Other” types of gears in fisheries data record. This affects the accuracy of data collected and reported for Cilacap and nearby fishing areas. Fishing logbooks are not implemented effectively because fishers are either unable or indifferent in filling out forms. Logbooks are filled out by port authority staff by interviewing the fishing master. Fisheries statistics do not include impuns (juvenile fish).

Unregulated Fishing

There is currently conflict between gillnet and rumpon fishers due to lack of appropriate regulations. Lack of regulations on FAD deployment. No requirement to obtain licence for using apong since this is considered a fishing gear used traditionally by small scale fishers. No sanctions are applied to some illegal fishing activities. Only one fishing violation case was prosecuted in 2003. The vessel was impounded due to the lack of necessary documents to conduct fishing activities. The fishing master was sent to jail for three months and the owner was fined and required to sign a notarised letter stating compliance with fisheries requirements for future activities. No formal regulatory basis for the collection of retribution by KUD. The national policy on limiting licences to promote the sustainability of fisheries resources is not socialised adequately to the local governments. As a result, fishing licences are continuously issued by local provincial

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and district governments in order to increase local government income. Lack of regulation on the trade activities of fish collectors.

Other Issues Sedimentation in Segara Anakan due to illegal logging in mangrove areas.

Difficulty in obtaining new or renewing fishing licence for large vessels. Fishing vessels of more than 30GT which land their catch in Cilacap port are required to obtain their licences from national authorities, which proves to be a tedious and expensive process; however some assistance is provided by fishing port authorities for large vessels to obtain fishing licences. Lack of effective rules to encourage fishers to participate in fish auctions. Lack of effective measures for the distribution of fuel subsidy among Cilacap fishers. Validation of vessel size to fit classification of provincial vessel size data. There is a general perception among Cilacap fishers that regulations do not have an impact on their activities. Dinas fisheries officials help fishers comply with government requirements rather than reprimanding them. Inadequate fisheries enforcement capacity.

Table 4. Description of IUU Fishing in Muncar, Banyuwangi (East Java)

Species caught: Lemuru and other fish; lobsters and sharks (as bycatch)

Illegal Fishing

Some migrant or andon fishers have been operating in Muncar waters without proper documentation. It was noted that there were 20 migrant purse seine vessels from Tuban who applied for fishing licences in Muncar. As of January 2011, 13 of these vessels have already obtained the necessary licences to operate in Muncar waters. Local fishers demanded that the remaining seven fishing vessels stop their fishing activities and leave the Bali Strait immediately. The remaining vessels are now owned by local businessmen. Not all local vessels have the required documents for fishing. Some fishers believe that since their home port is in Muncar, they do not necessarily need to obtain formal licences or permission to fish. Some small vessels do not normally obtain or renew their fishing licences, especially those affected by long periods of off-season in fishing. Some owners mark their fishing vessel capacity down to obtain licence from a province or a district. Use of explosive devices and poisonous substances in fishing in some coral reef areas.

Unreported Fishing

A significant amount of catch goes to the bakul or middlemen without proper catch record or documentation. The common practice is to record catch using daily dockets for business purposes. No weighing of fish

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occurs in TPI, preventing the collection and record of accurate fisheries data. The fisheries and port authority only estimates the weight of the catch per vessel through sampling or enumeration. However, not all of the data collected from sampling activities are recorded. TPI officers also collect data by interviewing the boat master about the volume and price of their catch. Some lemuru catch which goes directly to processing plants are weighed and recorded by officers in the establishments. No lobster catch recorded, unlike in sharks and lemuru fisheries. The logbook system is not implemented. There are no port officers responsible for issuing port clearances on Saturdays and Sundays, so such documents are not obtained on these days.

Unregulated Fishing

No specific regulations or management plans for fishing using the two-boat system. No sanctions are applied to fisheries violations. Lack of implementation of the management plan for the lemuru fishery in the Bali Strait, which was agreed by East Java and Bali provinces.

Other Issues Conflict between bagan (liftnet) and payang fishers targeting the same

catch (lemuru) and fishing in the same area. Conflict between local fishers and migrant fishers (nelayan andon). The latter operate in Muncar waters and land their catch in Muncar port. They use different fishing methods (e.g. gardan or line hauler) and local fishers use two boats with auxiliary. Migrant fishing (andon) vessels use one-boat equipped with line hauler and commonly operate using lamps to attract fish school. One-boat operations by migrant fishers are deemed as more efficient compare to two boat operations. Another difference between the fishing methods by local and nelayan andon vessels is with respect to the use of nets. Local fishers deploy nets in rectangular shape while andon fishers operate nets that take the shape of a trapezoid. In 2004, there was an andon vessel that was burnt down for illegally fishing in Muncar waters in the early phase of introducing this method. After some years, local fishers-businessmen have preferred to operate one boat method rather than two boat system; eventually abating earlier conflicts. Muncar used to apply a vessel marking system based on colour codes. However, some fishing vessels did not want to be assigned certain colours because of the belief that some colours are “unlucky”. Conflict in jurisdiction between Dinas Fisheries and Dinas Forestry, particularly with respect to the management of coral reef areas. Permission to conduct activities in coral reefs, including fishing for reef fish, was given by the Dinas Forestry prior to 2000. After 2000, Dinas Fisheries was given the mandate to regulate coral reef fishing. Despite limitations to fish in coral reef areas, some fishers continue their practice of gathering corals and catching reef fishes and other organisms on the

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basis of old regulations issued by Dinas Forestry. Marine pollution caused by the lack of wastewater processing facilities in Muncar. Lack of effective fisheries enforcement.

Table 5. Description of IUU Fishing in Watukarung and Pacitan (East Java)

Species caught: lobster, sharks, squid, lemuru (seasonal), tuna, and other fish

Illegal Fishing

Some rumpons are un-registered. Some fishers do not want to register their rumpons for fear that other fishers will obtain knowledge on their fishing areas. Use of compressors and cyanide in fishing, particularly by migrant fishers. This activity is sometimes punished not by the law, but by the local community.

Unreported Fishing

Lobster catch landing of cliff krendeters do not go through the TPI/PPI. Fisheries extension officers visit cliff krendeters three times a month to record their catch. Logbook system is not implemented, and forms are sometime filled out by fisheries extension officers for the fishers.

Unregulated Fishing

Lack of local regulations for rumpons. There have also been conflicting regulations as to the number of rumpons that may be deployed in Pacitan waters. Penalty system for fishing violations is not implemented. Lobster fishing vessels are not registered because their size is less than 5GT. There are no specific regulations on lobster fishing; however, as a matter of practice, brooding (egg-bearing) lobsters are released immediately when caught. No specific guidance on how to regulate vessels between 8-10GT. A new regulation at the district level exists requiring all vessels between 5-7GT to obtain Pas Kecil.

Other Issues Change of name of fishing vessels is common depending on whether or

not the vessel owner associates luck with that name. This causes difficulty in monitoring the registration and licensing of fishing vessels. Confusion in jurisdiction with respect to issuance of licences by district and provincial governments. Very few lobster catch for two years might be due to changed environmental conditions. Limited government support for the community-based enforcement group (POKMASWAS). Lack of awareness on the need for sustainable fisheries.

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Lack of adequate basic port facilities such as power supply.

Table 6. Description of IUU Fishing in Kedonganan (Bali)

Species caught: Lemuru, lobsters, tuna, snappers, and other fish

Illegal Fishing

Fishing by purse seine vessels within three miles off the coast of Kedonganan is perceived as illegal by local fishers because they conflict with the use of gillnets. Use of cyanide in fishing for ornamental fish. Some cases of vessels fishing without proper documents. Lack of compliance with the agreement between East Java and Bali on lemuru fisheries. The current number of fishing vessels is greater than the number allowed under the agreement.

Unreported Fishing

No reporting requirement or logbooks required for small vessels, so the only data collection conducted is in port. Lobster catch cannot be recorded accurately because they go directly to fish collectors who in turn sell the fish trade to the local market or exporters.

Unregulated Fishing

Very little regulations on fisheries in Kedonganan. Apart from the agreement between East Java and Bali on fishing in the Bali Strait, there are no other local regulations cited which apply in Kedonganan and Jembrana waters. No regulation implemented on fish auction.

Other Issues Lack of coordination between the different entities of government in

registering and licensing fishing vessels. Concern of local authority and community on environmental degradation and climate change issues. Difficulty by Dinas Fisheries to socialise regulations on licensing, registration, and the safety of fishing vessels. Local communities in nearby tourist areas have complained about water leaks from trucks transporting lemuru.

Table 7. Description of IUU Fishing in Pengambengan, Jembrana (Bali)

Species caught: Lemuru, lobsters and other fish

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Illegal Fishing

Illegal fishing is believed to be very minimal and mainly involves non-compliance with licensing requirements.

Unreported Fishing

Unreported fishing is considered to be the biggest problem in Pengambengan. There is a perception from some processing plant operators that recorded catch landing data in PPN Pengambengan are not accurate and that there is lack of transparency in recording catch. There are known discrepancies between the catch recorded in the landing site and those collected from processing plants. In 2007 the port authority tried to improve data collection requiring port officers to collect fisheries data from processing plants.

Unregulated Fishing

No specific regulations on lobster fishery. No legal size of lemuru catch, which is a concern for the sustainability of stocks. Low level of surveillance and enforcement. No sanctions applied on fishing violations. The local government only provides guidance to fishers on how to obey regulations.

Other Issues Conflict between local and migrant fishers, particularly with the use of

lamps in fishing. In recent year, the lemuru fishery has experienced low productivity and as a consequence, there was lack of adequate supply of lemuru for fish processing plants. Hence some fish processors import lemuru from other countries such as China and Oman to meet the supply requirements. Not all vessels obtain port clearance documents because they conduct daily fishing operations. Hence some fishers consider it unnecessary to apply for port clearance on a daily basis. Destruction of fishing habitats due to coastal reclamation.

Table 8. Description of IUU Fishing in Gunung Kidul (Yogyakarta)

Species caught: Lobsters and other fish

Illegal Fishing

Small fishing vessels of less than 5GT do not have SIUP and SIPI, as agreed by DINAS and relevant stakeholders. There are unintentionally lost gillnets and krendets during operations fishing in Gunung Kidul waters which become marine debris and potentially cause issues of ghost fishing.

Unreported Fishing

No reporting requirements for fishers. Lobster catch from cliff krendet cannot be recorded accurately because the catch goes to fish collectors who trade directly with exporters or the

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local market.

Unregulated Fishing

Dinas Gunung Kidul registers vessels but does not issue SIUP or SIPI because they believe that fishers in the area only fish for subsistence. However, some of these fishers trade and sell fish landed in Gunung Kidul port. No regulations exist prohibiting the disposal of unwanted fishing gears in Gunung Kidul waters. No sanctions are applied to illegal fishing activities.

Other Issues No measures to clean up the marine debris caused by lost fishing gears.

Lack of adequate fisheries enforcement.

Table 9. Description of IUU Fishing in Baron, Gunung Kidul (Yogyakarta)

Species caught: Lobsters and other fish

Illegal Fishing

Illegal fishing in Baron mainly comprises fishing without obtaining Pas Kecil (Small Vessel Registration). No other types of illegal fishing have been described by the fishers and port officials of Baron.

Unreported Fishing

There are no reports of unreported fishing by Baron fishers. It was noted that forms used by TPI to record fisheries landing are those facilitated by the district fisheries service. Records of fish species landed and their associated gears are aggregated in national fisheries statistics. Lobster catch from cliff krendet cannot be recorded accurately because the catch goes immediately to fish collectors who trade directly with exporters or the local market.

Unregulated Fishing

Lobster fishing may be characterised as largely unregulated in that there are no regulations adopted specifically for this fishery. Fishers are generally aware that there are prohibitions in fishing such as catching of turtles, dolphins, or taking of corals and sand. Fishers culturing seaweeds are not allowed to use tanco, a fishing application that destroys seaweed habitat. Lobster fishers are prohibited from using potassium, cyanide, compressors, and explosives. Fishers have obtained their knowledge on which activities are prohibited from Dinas Fisheries and other fishers. However, they are not fully aware whether such prohibitions are included in government regulations. No sanctions apply to fisheries violations.

Other Issues Socialisation conducted by the government is deemed to be not very

effective.

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Limited port facilities affecting some of their functions such as fisheries data collection.

Table 10. Description of IUU Fishing in Sadeng, Gunung Kidul (Yogyakarta)

Species caught: Tembang/sardinella fimbriata, lobsters, tuna, sharks, and other fish

Illegal Fishing

No reported illegal fishing activities. Fishers are willing and able to follow regulations with the guidance of the government.

Unreported Fishing

No reporting requirement or logbooks required for small vessels, so the only data collection conducted is in port. Lobster catch cannot be recorded accurately because the catch goes straight to fish collectors who trade directly with exporters or the local market.

Unregulated Fishing

No regulations for lobster fishing, although Dinas Fisheries in Sadeng encourages fishers not to catch small lobsters. No punishment applied for fisheries violations. There is hesitation to apply strict regulations for fear that fishing vessels might not land their fish in Sadeng.

Other Issues None.

Table 11. Description of IUU Fishing in Tanjung Luar, Lombok (NTB)

Species caught: Sharks and ray

Illegal Fishing

Illegal activities or continuous fishing activities of migrant fishers.

Unreported Fishing

Discrepancy in the data collected by TPI, PPI, and DINAS kabupaten. Lack of implementation of the logbook system.

Unregulated Fishing

No specific regulation on the legal size of sharks to be caught and other restrictions.

Other Issues Lack of implementation of the national plan of action on the

management of sharks and rays. Lengthy fishing vessel registration and licensing process. Lack of effective socialisation program. Resistance of certain fishers to change which is perceived by some as

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In summary, a number of IUU fishing concerns have been highlighted in each port. The most common illegal activities among all ports include illegal fishing by migrant fishers and to a lesser extent by foreign fishing vessels; fishing without registration and licences, particularly of small fishing vessels; use of fishing gears or methods which are prohibited in specific fishing zones; non-compliance with port requirements; and landing of fish outside designated landing areas. Unreported fishing includes non-reporting or misreporting of catch, as well as lack of recording of fisheries data as a result of landing fish outside ports. Non-implementation of the logbook system also contributes to unreported fishing. Unregulated fishing also occurs in the provinces in various forms, such as the absence of specific regulations adopted for the lobster fishery, lack of adequate regulations for the management of small scale fishing vessels, lack of implementation of management measures and fisheries regulations, and non-application of sanctions to fisheries violations.

The main issue related to illegal fishing in all five provinces is illegal fishing by migrant fishers (nelayan andon). Local fishers are generally not amenable to fishers from other areas conducting activities in their fishing grounds. While there are laws regulating fishing by migrant vessels, none restricts fishing activities of local fishers. This appears to be the most persistent problem for local fishers, particularly because most migrant fishers introduce fishing methods and gears which are not commonly used in local areas and are often more efficient. Hence, there have been reports that migrant fishers conduct illegal activities using certain types of gears which are actually not prohibited under the law. Furthermore, local communities believe that such activities need to be punished under the law. The perception of local fishing communities on illegal fishing by migrant fishers is different from the way they respond to illegal fishing conducted by local fishers. It may be posited that the level of tolerance for illegal fishing by local fishers is higher than when local communities are faced with the problem of migrant fishing. During the interviews, reports on illegal fishing by local fishers were very minimal, and if there were

Gutted pregnant sharks

Pregnant shark being gutted in port

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Vessels using small mesh size nets

Small fishing vessels using different gears

such activities, no penalties were imposed. Both the fishing industry and the government maintain that it has not been a common practice to impose penalties for fisheries violations because it is seen as detrimental to the livelihood of local fishers. Illegal fishing by local fishers is generally addressed by the government through socialisation, or by raising their awareness on the damaging impact of such activities. The authorities only encourage and assist the local fishers to comply with regulations rather than reprimanding them, as fishing is the last resort for most coastal communities. The second issue is the lack of adequate regulations with respect to small fishing vessels, particularly with respect to registration, licensing, and reporting requirements. Different districts and sub-districts subscribe to different regulations with respect to small scale fisheries, with some deeming it unnecessary to impose conditions to small vessels of less than 5GT or 7GT. Some small vessels also do not land their catch in designated ports because there are no legal requirements as such. The lack of compliance with

registration, licensing, and port requirements for small fishing vessels cannot be simply reduced to fishers opting to disobey the law. Rather, this problem is mostly a result of the lack of dissemination of the legal requirements, as well as the necessity and benefits of complying with licensing and reporting requirements in support of sustainable fisheries. The lack of adequate and uniform regulations regarding these types of fishing vessels makes small scale fishery an unregulated fishery, and contributes

significantly to unreported fishing in Indonesia. Other types of unregulated fishing include the lack of specific regulations for lobster fishery, which is further explained in the next section. The lack of implementation of fisheries regulations with respect to mesh sizes, fishing in rumpons, and port arrival and clearance requirements is also an example of unregulated fishing, which further encourages illegal and unreported fishing. The third key issue in IUU fishing in Southern Java waters is unreported fishing. Non-reporting and misreporting of catch are a common problem in all ports for a number of reasons. First, the logbook system is not implemented. Unless a fisheries officer

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accomplishes logsheets for the fishers, such forms are not filled out. Second, there is a significant number of small fishing vessels which do not always land their catch in designated landing sites, but along coastal areas. This is particularly true for the lobster fishery. Third, the landing and trading system for fish in the various ports make it difficult to record all catch. The catch for some fishery goes straight to the bakul (middlemen) or the fish collectors. Enumerators and fisheries extension officers are therefore unable to monitor all these activities. Fourth, there are no sanctions for failing to report catch in an accurate and timely manner. Fifth, fishers are free to land their catch in any port, subject only to the permission of officials in the landing site. This implies that some catch may not be directly attributed to the appropriate fishing ground and may affect the accuracy of collected data in terms of origin of catch. Lastly, fisheries data collected in sub-district, district and provincial ports are aggregated in accordance with national procedures. Some of the details of such fisheries data, such as the breakdown of volume of catch per species are omitted in the process of data aggregation. Hence, the national statistics may not necessarily reflect the true nature of fisheries in the local areas. Other issues were raised by the local fishing communities and fisheries and port authorities, some of which are relevant for the control of IUU fishing. These issues include the decline of some stocks such as lemuru, which impact on the supply of domestic and overseas markets; environmental and habitat degradation; lack of legal limit for fish catch; lack of coordination between authorities in undertaking fisheries functions; lack of effective enforcement; limited government support to community-based enforcement; and the lack of adequate dissemination on rules and regulations. Other issues include the limited government support for fishers during lean months and inadequate port facilities.

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8. SYNTHESIS OF THE IUU FISHING STUDY Based on the preceding sections of the Report, as well as the results of market sampling, data collection, stakeholder workshops, and other activities conducted under the ACIAR Project, the IUU fishing concerns may be summarised for the three selected fisheries of lemuru, lobster and Tanjung Luar sharks.

8.1 IUU Fishing in the Lobster Fishery Amongst the three fisheries investigated, lobster fishery is the most unregulated and unreported. As previously highlighted, there are no specific regulations on the size of lobsters which may be caught, as well on the gears that may be used. Fishers rely on traditional practices and knowledge in catching lobsters. Fishing vessels targeting lobsters are also relatively small compared to vessels targeting other stocks; hence most of these vessels do not land their catch in TPI or PPI, nor comply with general registration and licensing requirements. Lobster fishers land and deliver their catch directly to fish collectors, without the legal requirement to submit any record to fisheries or port authorities. In certain districts such as in Pacitan, catches of species bound for export are exempted from being landed in designated ports, although some export data may be recorded before the lobster products leave the country. Such limited regulations on lobster fisheries may be seen as encouraging unreported fishing. Similarly, lobsters are also not recorded and classified suitably in national fisheries statistics. The key illegal fishing concerns for the lobster fishery in the five provinces include the use of poison and compressors particularly by migrant fishers, as well as the negative impact of abandoned gears which trap lobsters, stunt their growth and increase their mortality.

8.2 IUU Fishing in the Lemuru Fishery The IUU fishing issues in lemuru fishery are slightly different than those in the lobster fishery. The lemuru fishery is generally regulated under national and local fisheries regulations, as well as the agreement between East Java and Bali on fishing in East Java waters. A Draft management Plan was also prepared for the lemuru fishery in the Bali Strait 30 years ago; however, such plan has not been fully implemented. Illegal fishing appears to be the key problem in this fishery. For larger vessels targeting lemuru, illegal fishing occurs mostly in the form of conflict between the use of fishing gears and methods. There have also been reports on illegal fishing by vessels without proper registration documents or licences. For smaller fishing vessels targeting lemuru, the key issue is non-reporting of catch. These illegal fishing activities impact on the sustainability of lemuru fishery, which in turn affect its domestic and overseas trade. Environmental changes have also been cited as a factor that impact on the sustainability of lemuru fishery. In the course of the research project, potential issues related to the lack of proper classification of sardine species in fisheries statistics were also raised.

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8.3 IUU Fishing in the Shark Fishery Shark fishery in Indonesia may be generally considered as a regulated fishery, with the National Plan of Action for Shark and Ray Management (NPOA-Sharks) serving as a general policy framework adopted in 2010 consistent with the FAO International Plan of Action for the Conservation and Management of Sharks. It is noted however that the NPOA-Sharks is not implemented in the Tanjung Luar fishery and is instead governed by a community-based form of management called awig-awig. This management system based on local wisdom is considered a ‘living law’ and provides a list of allowed and forbidden fishing activities generally accepted by fisherfolks. In the Tanjung Luar fishery, data collected through the ACIAR project market sampling have been found to be very similar to the data gathered through regular enumeration activities, which may indicate a low level of unreported fishing in port. However fisheries authorities have indicated that there may be some discrepancies between the data collected by TPI, PPI and Dinas kabupaten on sharks. Data collection in Tanjung Luar can be contrasted from that in other ports such as Palabuhanratu and Cilacap where sharks are also a target species. In these ports unreported fishing is a major issue which arises from the lack knowledge on the proper identification of shark species. There are also inaccurate data in areas where sharks are a bycatch. Despite the lack of government regulations and conservation measures on sharks in Tanjung Luar (e.g. legal size of sharks to be caught and landed), stakeholder interviews reveal that the key issues for the fishery focus more on the need to improve port and post-harvest infrastructure, marketing of sharks and socialisation, rather than the presence of IUU fishing. The perception of the fishing community is that the current traditional framework based on awig-awig is sufficient to effectively manage the shark fishery in the area.

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9. SOME RECOMMENDATIONS AND FUTURE

CONSIDERATIONS There are a number of recommendations offered by the respondents in the IUU fishing field investigation, most of which are discussed more specifically in individual Port Reports for this ACIAR Project. For the purpose of this Summary Report, recommendations with more general and national impact are highlighted. Continuous improvement of fisheries data collection and research The Ministry of Marine Affairs and Fisheries has made revisions and significant improvement to the fisheries data collection system of Indonesia, particularly in the classification of species, sampling of data, and data verification process. As effective data collection and management is an important factor in the sustainability of fisheries in Indonesia, there is a need to continuously improve data collection, particularly at the local level. This includes studies and research on key fisheries and management areas. Socialisation to eradicate IUU fishing and related conservation and management issues For Indonesia, socialisation on the negative impact of IUU fishing and the relevant fisheries laws and regulations is just as crucial as fisheries enforcement. Socialisation, or raising of public awareness and dissemination of information, enables self-compliance by fishing communities and industries and will contribute to the decrease of IUU fishing in Indonesian waters. An example of an area where socialisation may be necessary is in small scale fisheries, where it may be clarified what obligations exist for smaller vessels (i.e. registration and reporting requirements). Conservation issues may also be addressed through public education such as on the importance of ecologically related species (e.g. sharks, dolphins and associated species). Publicising IUU fishing vessels on the MMAF Website A number of regional fisheries management organisations publicise lists of vessels that have engaged in IUU fishing in their areas of competence in their websites. Members and cooperating non-members of such organisations ensure that their flagged vessels do not participate in any activities with such vessels until such a time that they are deleted from the list. This has proven to be an effective way to promote collective action against IUU fishing. A similar measure may be adopted by Indonesia as a public campaign against illegal fishing, specifically for foreign fishing vessels that have conducted IUU fishing in its exclusive economic zone. A list of such vessels may be posted on the website of the Ministry of Marine Affairs and Fisheries, including advice to authorities, fishing companies, and vessel operators on what to do if they encounter such vessels. Application of the FAO Port State Measures Agreement, pending the ratification of this international agreement by Indonesia The FAO Port State Measures Agreement to Combat IUU Fishing was adopted in 2009 and is increasingly being ratified by port States. It generally applies to foreign fishing

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vessels, with some exemptions for container vessels and traditional vessels fishing in neighbouring waters. Amongst the ports studied for this ACIAR project, only Cilacap allows foreign vessels, particularly longliners fishing in the IOTC area, to call into its port. Hence in order to facilitate compliance with this global agreement, the Cilacap port authority, in collaboration with the Ministry of Marine Affairs and Fisheries, would need to establish appropriate port State measures, including regulations relating to advanced notice of entry, inspection of vessels, departure of vessels, and investigation and reporting procedures to be undertaken if a vessel is believed to have conducted IUU fishing. There also needs to develop clear regulations on the application of port enforcement actions against IUU activities such as denial of port access and denial of landing and transshipment of fish. Other requirements include cooperation with the flag State of the foreign vessel and relevant regional fisheries management organisations. Possible adoption of catch certification system, especially for shark fishery Catch certification schemes have been adopted in a number of regional fisheries management organisations and recognised globally as a measure to ensure that only catch coming from sustainable fisheries may enter international trade. Most of these catch certification systems are applied to tuna resources. However, because of the importance of conserving sharks and the need to protect similar species such as dolphins which are commonly used as bait for shark fishing, it is recommended that studies be conducted to extend the application of catch certification systems to the Indonesian shark fishery. This measure will also allow Indonesia to participate and lead in the international debate on the conservation of sharks in IUCN and CITES. It will also allow the country to comply with strict fisheries conservation and management requirements of developed trading partners such as the US and the EU. Establishing regulations for the market chain In order to address gaps in the trade of certain species such as lobsters in Indonesian waters, it is proposed that regulations and transparent processes be developed to control the marketing chain of high value, low volume species such as lobsters and crabs. One measure that may be set within the regulations is the requirement for buyers and middlemen to report catch they have acquired to their fishing associations and relevant government authority.

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10. ACKNOWLEDGMENTS The participating partners of ACIAR Project FIS/2006/142 wish to thank the many people who provided information for the IUU fishing field investigations. This includes staff of the DINAS Provinsi and Kabupaten Fisheries, Port authorities, and fish auction places TPI), as well as fisher groups and representatives. Without the cooperation of the industry this study would not have been possible. All the individuals who provided information and data during the field investigation are further acknowledged in the Port Reports published for this project. The findings and analysis, as well as all shortcomings of this Report remain the sole responsibility of the authors.

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11. REFERENCES Local and National Laws, Policies and Regulations Agreement between East Java and Bali on Fishing in East Java Waters Bali Province, Provincial Regulation No 17/1991 on Fisheries Business Permits Banyuwangi, Minapolitan Program 2007 Banyuwangi, Peraturan Daerah Kabupaten Banyuwangi 22/2004 on Fisheries

Surveillance and Monitoring. Baron, Local Regulation No. 5/2007 on Retribution in Fish Auctions Buku Saku, Kumpulan Awig-awig tentang Pengelolaan Sumberdaya Perikanan dan

Pengeloalaan Suaka Perikanan di Kabupaten Lombok Timur, Kersajama Co-fish Project dengan Fakultas Perikanan, Universitas 45 Mataram Tahun 2003

Cilacap, Local Regulation No 16/2001 on Fisheries Management in Segara Anakan Cilacap, Local Regulation No 17/2001 on Mangrove Management of Segara Anakan Cilacap, Local Regulation No 6/2001 on Master Plan for the Segara Anakan Development Planning for Banyuwangi as a Minapolitan Detailed Planning for Muncar as part of Banyuwangi Minapolitan Development Planning for Pacitan as a Minapolitan East Java, Governor Decree No 9/1983 Regulating Migrant Fishers East Java, Governor Instruction Letter No 6/1983 on Migrant Fishers East Lombok, Pemerintah Kabupaten Lombok Timur, Badan Pelayanan Perizinan

Terpadu, Info Pelayanan Umum, Izin Usaha Perikanan, 2009. East Lombok, Pemerintah Kabupaten Lombok Timur, Peraturan Daerah Kabupaten

Lombok Timur Nomor 12 Tahun 2010 tentang Reteribusi Golongan Jasa Usaha Government Regulation No 2/2011 Government Regulation No 8/2011 Gubernur Nusa Tenggara Barat Keputusan Gubernur Nusa Tenggara Barat Nomor 193

Tahun 2012 tentang Pembentukan Forum Koordinasi Penanganan Tindak Pidana Perikanan di Wilayah Provinsi Nusa Tenggara Barat

Gunung Kidul, Local Regulation No. 5/2007 on Retribution in Fish Auctions Law No 31/2004 Concerning Fishery, as amended by Law No 45/2009 Law No 5/1983 on the Indonesian Exclusive Economic Zone Law No 21 of 1992 on Shipping Law No 22/1999 Regarding Regional Autonomy Law No 27/2007 on Coastal and Small Islands Management Ministerial Decree No 51/KPTS/IK.215/1/1997 on Rumpons (Fish Aggregating Devices) Ministerial Regulation 16/2006 on Fishing Ports classifies Indonesian ports Ministerial Decision 45/2011 National Plan of Action for the Management of Sharks and Rays in Indonesia, 2004. Pacitan, District Regulation No. 5/2002 on Retribution for Fish Auctions Yogyakarta, Provincial Regulation No 6/2005 on Marine and Fisheries Business Yogyakarta, Provincial Regulation No 7/2005 on PPP (Coastal Fishing Ports) or Fishing Port Class C/Type III Yogyakarta, Provincial Regulation No 8/2005 on Retribution for Certain Permits Yogyakarta, Provincial Regulation No 9/2005 on Retribution for All Types of Businesses

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Other References ACIAR (2012). Rapid Assessment Protocol for Market Surveys. Appendix to FINAL Report.

ACIAR Report FIS/2006/142, Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) fishing. Australian Centre for International Agricultural Research (ACIAR), Canberra, Australia. 23pp.

ACIAR (2012). South Coast Java Lobster Fishery. Appendix to FINAL Report. ACIAR Report FIS/2006/142, Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) fishing. Australian Centre for International Agricultural Research (ACIAR), Canberra, Australia. 46pp.

ACIAR (2012). Tanjung Luar (East Lombok) Longline Shark Fishery. Appendix to FINAL Report. ACIAR Report FIS/2006/142, Developing new assessment and policy frameworks for Indonesia’s marine fisheries, including the control and management of Illegal, Unregulated and Unreported (IUU) fishing. Australian Centre for International Agricultural Research (ACIAR), Canberra, Australia. 53pp.

Banyuwangi, Tempat Pelabuhan Ikan, Buku Laporan Statistik Perikanan Tangkap Tahun 2010 (Statistical Report of Banyuwangi 2010).

Buchany, Eny Anggraini, “In Search of Viable Policy Options for Responsible Use of Sardine Resources in the Bali Strait, Indonesia (Thesis, University of British Columbia, 2010).

Data Kelompol Masyarakat Pengawas (POKMASWAS), Provinsi Nusa Tenggara Barat Sampai Tahun 2101116 POKMASWAS 2 in Tanjung luar

Direktorat Jenderal Perikanan Tangkap, Departemen Kelautan dan Perikanan (2011), Buku Laporan Tahunan Statistik Perikanan Tangkap Tahun 2011 (Annual Statistical Report of Kedonganan Fishing Port 2010).

Merta, I Gede Sedana ‘A Review of Stock Assessment of Ikan Lemuru (Sardinella lemuru) in the Bali Strait, (1995) 14(4) IARD Journal 71-76.

Merta, IGS, et al, ‘Status of the Lemuru Fishery in Bali Strait; Its Development and prospects,’ Papers Presented at the Workshop on the Fishery and Management of Bali Sardinella (Sardinella lemuru) in Bali Strait, Denpasar, Bali, Indonesia, 6-8 April 1999, FAO/Norway Government Cooperative Programme, GCP/INT/648/NOR Field Report F-3 Suppl (FAO, Rome: 2000) 1-42.

Pelabuhan Perikanan Nusantara Palabuhanratu, Direktorat Jenderal Perikanan Tangkap, Departemen Kelautan dan Perikanan (2011), Buku Laporan Tahunan Statistik Perikanan Tangkap Tahun 2011 (Annual Statistical Report of Palabuhanratu National Fishing Port 2010).

Proctor, C et al (2011), ‘Initial Compilation of Fisheries Information for Landing Sites’, Report Prepared for FIS/2006/142, Developing New Assessment and Policy Frameworks for Indonesia’s Marine Fisheries, including the Control and Management of Illegal, Unregulated and Unreported (IUU) Fishing, Australian Centre for International Agricultural Research (ACIAR).

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12. FURTHER INFORMATION

For further information, please contact: Contact Email Professor Ron West, ANCORS [email protected] Dr Mary Ann Palma, ANCORS [email protected] Dr Fayakun Satria, RCFMC [email protected] Dr Lilis Sadiyah, RCFMC [email protected] Mr Andhika Prima Prasetyo [email protected]

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13. ATTACHMENT: INTERVIEW QUESTIONS (IUU

FISHING STUDY)

GUIDE QUESTIONS FOR BOAT OWNERS/OPERATORS The main purpose of this survey and interview is to increase understanding on the management of lemuru, lobster, and Tanjung Luar shark fisheries in the project sites, by looking at some of the socio-economic factors influencing such fisheries as well as the governing regulations. 1. What types of regulations are you required to follow as a boat owner or operator?

a. For the fishing boat? b. For the masters and crew? c. Fishing gears? d. Fish catch? e. Fishing area?

2. What types of documents or forms do fill out and submit to the government? Are you

required to carry a logbook?

3. Where do you register (district, provincial, national government)?

4. What port regulations exist for the landing and transport of your catch?

5. Is there any fishing activity that you can do that does not require a permit or a licence?

6. How much fish are you allowed to catch? (e.g. How many lobsters can you catch per trip?)

7. Can you land your catch in any nearby port of your choice?

8. Does all the fish go to the market? How much is taken home by the fishermen? Do you need to record the catch that does not go to the market?

9. Do you take your fish to canneries or processing plants?

10. Are your fish sold locally or overseas?

11. What regulations exist for the trade of fish?

12. What do you think are the advantages and disadvantages of these fishing regulations? Are some of these regulations onerous or too difficult to follow?

13. Are there closed areas or seasons or other fishing restrictions in the area where you fish?

14. Do the government publicise fishing regulations so that you are fully aware of and can comply with them?

15. Are there community based management arrangements that exist in the area? How beneficial is this arrangement for your fishing activities?

16. What advice do you give your fishermen before they go fishing?

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17. How do you think the government can improve the manner it is managing your fisheries? BAHASA INDONESIA VERSION:

PANDUAN PERTANYAAN UNTUK PEMILIK/OPERATOR/JURAGAN KAPAL Tujuan utama survey dan wawancara ini adalah untuk meningkatkan pemahaman tentang pengelolaan perikanan lemuru, lobster, dan hiu Tanjung Luar di lokasi penelitian dengan melihat beberapa faktor sosial dan ekonomi yang mempengaruhi jenis perikanan tersebut sekaligus pengaruhnya terhadap peraturan-peraturan yang mengaturnya. 1. Peraturan perikanan jenis apa yang berlaku bagi anda dan harus anda penuhi sebagai

pemilik/operator/juragan kapal? a. Apakah untuk kapal penangkap ikan? b. Apakah untuk nahkoda dan anak buah kapal? c. Apakah untuk alat tangkap? d. Apakah untuk hasil tangkap? e. Apakah untuk daerah penangkapan ikan?

2. Dokumen atau daftar isian jenis apa yang harus diisi dan diserahkan kepada pemerintah?

Apakah anda di haruskan membawa logbook (buku laporan kegiatan penangkapan ikan)? 3. Dimana anda terdaftar/mendaftarkan ijin kegiatan penangkapan ikan anda (di kabupaten,

propinsi, pusat)? 4. Peraturan pelabuhan apa yang berlaku untuk pendaratan dan pengangkutan hasil tangkap

ikan anda? 5. Adakah kegiatan penangkapan ikan yang anda lakukan yang tidak butuh surat ijin? 6. Berapa banyak ikan/lobster/hiu yang boleh anda tangkap? (contoh: berapa banyak lobster

yang dapat anda tangkap tiap kali melaut/trip?) 7. Bolehkah anda mendaratkan hasil tangkap ke pelabuhan manapun sesuka anda? 8. Apakah semua hasil tangkap dijual ke pasar? Berapa banyak hasil tangkap yang dibawa ke

rumah oleh nelayan? Apakah anda harus mencatat/melaporkan semua hasil tangkap baik yang dibawa ke rumah maupun yang dijual ke pasar?

9. Apakah anda kirim hasil tangkap anda langsung ke tempat pengalengan atau pengolahan? 10. Apakah hasil tangkap anda dijual di pasar lokal atau luar negeri? 11. Adakah peraturan yang berlaku untuk perdagangan hasil tangkap? Kalau ada peraturan

tentang apa? 12. Menurut anda apakah manfaat dan kerugian dari peraturan penangkapan ikan tersebut?

Apakah peraturan-peraturan itu sulit diikuti/dijalankan? 13. Apakah ada larangan menangkap ikan di daerah dan waktu/musim tertentu? Ataukah ada

jenis larangan lainnya yang berlaku di daerah anda biasa menangkap ikan?

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14. Apakah pemerintah menyebarluaskan/mengumumkan peraturan penangkapan ikan yang ada sehingga menjadi perhatian anda dan kemudian anda dapat mematuhinya?

15. Apakah ada perangkat pengelolaan perikanan yang berasal dari masyarakat yang masih

berlaku?Apakah manfaat dari perangkat pengelolaan masyarakat itu bagi kegiatan perikanan anda?

16. Saran atau nasehat apa yang biasa anda sampaikan kepada kru kapal sebelum mereka pergi

menagkap ikan? 17. Menurut anda bagaimana agar supaya pemerintah dapat meningkatkan kemampuan dalam

mengelola perikanan yang anda lakukan?

GUIDE QUESTIONS FOR DINAS OFFICIALS

The main purpose of this survey and interview is to increase understanding on the management of lemuru, lobster, and Tanjung Luar shark fisheries in the project sites, by looking at some of the socio-economic factors influencing such fisheries as well as the governing regulations. 1. What types of regulations do you require in each fishery (lemuru, lobster, shark)?

a. For the fishing boat? b. For the masters and crew? c. Fishing gears? d. Fish catch? e. Fishing area?

2. What types of documents or forms are fishermen required to fill out and submit to the

government?

3. Where do the fishing vessels register (district, provincial, national government)?

4. What are the terms and conditions of a fishing licence?

5. What port regulations exist for the landing and transport of fish?

6. Is there any type of fishing activity that does not require a permit or a licence?

7. Are fishermen required to report their catch? Do they carry a logbook?

8. Are there closed areas or seasons or other fishing restrictions in the fishing areas?

9. What do you think are the advantages and disadvantages of these fishing regulations? Do fishermen complain about any of these regulations?

10. How does the government publicise fishing regulations so that the fishermen are fully aware of and can comply with them?

11. Are there community based management arrangements that exist in the area? 12. How do you ensure that fishing regulations are implemented and followed by fishermen?

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13. How do you think the government can improve the manner it is managing the fisheries?

BAHASA INDONESIA VERSION Tujuan utama survey dan wawancara ini adalah untuk meningkatkan pemahaman tentang pengelolaan perikanan lemuru, lobster, dan hiu Tanjung Luar di lokasi penelitian dengan melihat beberapa faktor sosial dan ekonomi yang mempengaruhi jenis perikanan tersebut sekaligus pengaruhnya terhadap peraturan-peraturan yang mengaturnya.

1. Peraturan seperti apa yang anda butuhkan untuk jenis perikanan (lemuru, lobster, hiu)? a. Peraturan khusus untuk kapal penangkap ikan? b. Peraturan khusus untuk nahkoda dan anak buah kapal? c. Peraturan khusus untuk alat tangkap ikan? d. Peraturan khusus untuk hasil tangkap? e. Peraturan khusus untuk daerah penangkapan ikan?

2. Dokumen atau daftar isian apa yang harus diisi dan diserahkan oleh nelayan kepada

pemerintah?

3. Dimana kapal penangkap ikan harus terdaftar/didaftarkan (kabupaten, propinsi, atau pusat)?

4. Apa saja yang diatur dalam surat ijin usaha penangkapan ikan (SIUP) dan surat ijin

penangkapan ikan (SIPI)? (Apakah jenis alat tangkap, daerah penangkapan, berapa banyak tangkapan, kapan boleh beroperasi, dll).

5. Peraturan pelabuhan apa saja yang berlaku untuk pendaratan dan pengangkutan hasil tangkap?

6. Apakah ada jenis perikanan yang tidak membutuhkan ijin atau surat ijin?

7. Apakah nelayan diharuskan untuk melaporkan hasil tangkapan mereka? Apakah mereka membawa logbook (buku laporan kegiatan penangkapan ikan)?

8. Apakah ada larangan menangkap ikan di daerah dan waktu/musim tertentu? Ataukah

ada jenis larangan lainnya yang berlaku?

9. Menurut anda apakah manfaat dan kerugian dari peraturan penangkapan ikan yang berlaku? Apakah ada nelayan yang merasa keberatan tentang peraturan tersebut?

10. Bagaimana pemerintah mengumumkan dan menyebarluaskan peraturan penangkapan

ikan itu sehingga menjadi perhatian nelayan dan kemudian nelayan itu mematuhinya? 11. Apakah ada perangkat pengelolaan perikanan yang berasal dari masyarakat yang masih

berlaku? 12. Bagaimana cara anda memastikan bahwa peraturan penangkapan ikan yang ada akan

bias diterapkan dan dipatuhi oleh nelayan?

13. Menurut anda bagaimana agar supaya pemerintah dapat meningkatkan kemampuan dalam mengelola perikanan?