Pre-Assessment of Longtail Tuna FIP Tok Bali - Report (Draft)

This first draft report was
submitted on 15 May 2023

and reviewed by Project
Manager by 2 June 2023.
Chitra Devi
Marine Programme Leader
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Indonesia. The report shall note that a pre-assessment does not attempt to duplicate a full
assessment against the MSC Fisheries Standard. A full assessment involves a group of
assessment team members and public consultation stages that are not included in a
pre-assessment. A pre-assessment provides a provisional assessment based on a limited set of
information provided by the client. The CAB may add other details specific to this pre-assessment
as appropriate. The CAB should outline any limitations placed on this pre-assessment e.g.
inaccessibility of the fishery or paucity of key data. MSC Pre-Assessment Reporting Template
Version 3.3 is used to develop this reporting document.
Design and layout by Fadzliee Asmat (WWF-Malaysia).
Suggested citation:
Fachri, F.R., Jaenudin, A., Damora, A. (2023). Pre-Assessment of Longtail Tuna Fishery Improvement
Project. East Java: Blue Seed Indonesia.
i
PRE-ASSESSMENT OF LONGTAIL TUNA
FISHERY IMPROVEMENT PROJECT
IN TOK BALI
A REPORT PREPARED BY
Faridz Rizal Fachri, Agus Jaenudin, Adrian Damora
FROM BLUE SEED INDONESIA FOR PROJECT STAKEHOLDERS
30 JUNE 2023
ii
CONTENTS
CONTENTS iii
EXECUTIVE SUMMARY v
RINGKASAN EKSEKUTIF vi
GLOSSARY vi
LIST OF FIGURES ix
LIST OF TABLES x
INTRODUCTION 1
Aim and Constraint of the Pre-Assessment 1
UNIT OF ASSESSMENT (UoA) 3
TRACEABILITY WITHIN THE FISHERY 4
PRE-ASSESSMENT RESULTS 5
Pre-Assessment Result Overview 5
Overview 5
Recommendations 5
Summary of Potential conditions by Principle 9
Summary of Performance Indicators Level Scores 10
PRINCIPLE 1 14
Background 15
STOCK STATUS 17
Catch Profiles 23
Total Allowable Catch (TAC) and Catch data 26
Performance Indicator Scores and Rationales 26
PRINCIPLE 2 36
Background 37
Primary Species 39
Secondary Species 40
ETP Species 41
Habitat 45
Ecosystem 45
iii
PRINCIPLE 3 67
Background 68
APPENDICES 91
Evaluation Process and Techniques 91
Site Visits 91
Recommendations for Stakeholders Participation 93
Risk-Based Framework Outputs 94
Productivity Susceptibility Analysis (PSA) 94
Consequence Spatial Analysis (CSA) 115
Scale Intensity Consequence Analysis (SICA) 116
REFERENCES 117
iv
EXECUTIVE SUMMARY
Blue Seed Indonesia is an independent entity expertised on environmental issues, both

marine and forestry works, e.g. biodiversity conservation; sustainable utilisation of natural
resources; blue carbon and rehabilitation; community empowerment; and building transparent
partnerships. The pre-assessment of longtail tuna/LOT (Thunnus tonggol) fishery led by Faridz
Rizal Fachri as associate MSC technical consultant on behalf of Blue Seed Indonesia. The
pre-assessment of LOT fishery in Tok Bali, Kelantan, Malaysia assessed against MSC standard
v2.0. The availability of the data and information sourced from both field visits and secondary
observation via interviews with the stakeholders in the targeted areas during May 15th-20th, 2023.
Several stakeholders have participated and shared their concerns, including LKIM/Lembaga
Kemajuan Ikan Malaysia, Department of Fishery (DOF) - Malaysia, WWF Malaysia, and other related
researchers. The report was arranged using MSC pre-assessment report template V.3.1.
The Unit of Certification (UoC) under the pre-assessment is LOT purse seine fishery in the
East Coast of Peninsular Malaysia (ECPM) waters, as part of South China Sea’s stock (Western,
and Central Pacific Fisheries Commission/WCPFC region). The LOT purse seine vessels capacity
varies from 40 to 70 GRT that fishing in zone C-C2 (12 to > 30 nm). This fishery constitutes a
significant portion of multispecies fisheries for small neritic tuna that are utilised by small-scale
commercial and artisanal fishing. The fisheries management of Malaysia is mandated and
declared through provisions of the Fisheries Act 1985 (317).
The LOT fishery on the ECPM waters is highly likely identified as a transboundary fishery. In
addition, WCPFC has not covered LOT as a focus of work in this region. The stock status of LOT
has high uncertainty due to insufficient data coverage, impacting the absence of harvest strategy
and fishery specific management. The LOT purse seine fishing in ECPM producing multispecies
catch which dominated by scad (Decapterus spp.), kawakawa/KAW (Euthynnus affinis), LOT
(Thunnus tonggol), frigate tuna/FRI (Auxis thazard), unwanted and low value fishes. No primary
species identified, and rarely ETP species probably caught by the fishing gears. Furthermore, the
monitoring and information to understand the key ecosystem elements is not clearly defined,
although LOT is mainly at the higher trophic levels, but their impact on the fungsional composition
is undescribed.
The Regional Fishery Body (RFB) for neritic tuna management within the Southeast Asia
Waters region doesn't exist. This condition affects the absence of a legal dispute framework as a
mechanism for the resolution in the region. Nevertheless, the quality of the Monitoring, Control, and
Surveillance (MCS) implementation is unconvincingly executed, due to unclear evidence and
reports to monitor the transboundary happened within the fishery. In addition, the evaluation and
review mechanism for specific fisheries management measures for LOT in the UoA is not in place.
Eventually, the pre-assessment of the LOT purse seine fishery in Tok Bali, Kelantan,
Malaysia failed against the MSC standard, not recommended to proceed full assessment, unless
specific improvement actions are addressed, i.e. stock management, partial strategy for secondary
species and ecosystem, and execution of effective fishery specific management, involving its MCS,
review and evaluation. The implementation of these corrective actions is expected to change the
low performance indicators within LOT fishery toward sustainable use of LOT resources in the
future.
v
RINGKASAN EKSEKUTIF
Will be filled up by Fadzliee once BlueSeed Indonesia has completed the English draft.
>text
vi
GLOSSARY
CAB Conformity Assessment Bodies
FIP Fishery Improvement Project
MSC Marine Stewardship Council
TAC Total Allowable Catch
UoA Unit of Assessment
UoC Unit of Certification
ETP Endangered, Threatened, and Protected
ECPM East Coast of Peninsular Malaysia
IOTC Indian Ocean Tuna Commission
WCPFC Western Central Pacific Fisheries Commission
ASEAN Association of Southeast Asian Nations
FMP Fisheries Management Plan
RPOA Regional Plan of Actions
RFB Regional Fisheries Body
MCS Monitoring, Control and Surveillance
IUU Illegal, Unreported and Unregulated
EEZ Exclusive Economic Zone
LOT Longtail Tuna
FRI Frigate Tuna
KAW Kawakawa
IQS Individual Quota System
CNP Central North Pacific
RBF Risk-based Framework
CA Consequence Analysis
PSA Productivity, Susceptibility Analysis
CSA Consequence Spatial Analysis
vii
1
SICA Scale Intensity Consequence Analysis
MSY Maximum Sustainable Yield
PRI Point of Recruitment Impairment
HCR Harvest Control Rules
viii
LIST OF FIGURES
Figure 1. Longtail tuna (LOT) 15
Figure 2. Two areas (Pacific Ocean side and Indian Ocean side in the SE Asian 17
waters) used for stock and risk assessments of LOT
Figure 3. FAO Fishing Area 57 and 71 17
Figure 4. Status of LOT in the Pacific Ocean in 2013 and 2018 based on Kobe 18
Plot
Figure 5. Risk assessment of LOT in the Pacific Ocean 2018 18
Figure 6. Fishing grounds of LOT fisheries in the ECPM 22
Figure 7. Percentage of tuna species and tuna-like species production of 24

Southeast Asia in 2019 by quantity and Historical catch of LOT in the
Pacific Ocean side (South China Sea) by country (1979-2018)
Figure 8. CPUE (Mt/Unit) of LOT caught by purse seiners in the ECPM 25
Figure 9. LOT landings in Kelantan from 2010 to 2020 25
Figure 10. The length frequency distribution of LOT landed in Tok Bali 26
Figure 11. The catch composition group of LOT purse seine fishing in ECPM 37
during 2017- 2018
Figure 12 The distribution of the 26 species of LOT purse seine’s catch 38

composition in ECPM during 2017-2018 in several identified fishing
zone
Figure 13. The secondary species identified from purse-seiner in ECPM during 40
2017-2018
Figure 14. The migration pathways of Chelonia mydas through satellite tracking 44
within the South China Sea
Figure 15 Sighting and Stranding Location of Various Marine Mammals in 44

Peninsula Malaysia
Figure 16. The food web in the pelagic ecosystem of CNP 46
Figure 17. The purse-seiner of Tok Bali trajectory in 2013 and the distribution of 70
purse-seiner fishing vessels operation in zone C & C2, ECPM in 2018
Figure 18. Standard Operational Procedure (SOP) for Malaysia’s entities to prevent 75
IUU fishing within Malaysia waters
ix
LIST OF TABLES
Table 1. Unit of Assessment (UoA) 3
Table 2. Traceability within the fishery 4
Table 3. Recommendations for Performance Indicators 6
Table 4. Summary of Performance Indicator level scores <60 9
Table 5. Summary of Performance Indicator level scores 10
Table 6. Total Allowable Catch (TAC) and Catch Data 26
Table 7. Information of Principle 2 39
Table 8 ETP species are probably caught by the LOT purse seine fisheries under 41
UoA
.Table 9. The classification of the fishing zone and utilisation in Malaysia waters 70
Table 10. The list of relevant stakeholders for LOT fishery management in 72
Malaysia
Table 11. Site Visit Agenda 91
Table 12. Recommendation of Stakeholders 93
Table 13. Productivity Susceptibility Analysis (PSA) elements of fish and 94

invertebrates
Table 14. PSA productivity and susceptibility attributes and scores for fish and 95
invertebrates
Table 15 Productivity Susceptibility Analysis (PSA) elements of sea turtles and 109
cetacean
Table 16 PSA productivity and susceptibility attributes and scores for sea turtles 110
& cetacean, PI 2.3.1 ETP Species
Table 17 CSA justification table for PI 2.4.1 Habitats 115
Table 18 SICA scoring template for PI 2.5.1 Ecosystem 116
x
INTRODUCTION
The development of the seafood demand is changing globally due to issues of

sustainability towards food security in the future. The FAO (2022), pointed out that about 65-80%
end consumers believe that buying sustainable fish has a positive effect on the oceans. In North
America and Europe, top ‘retailers’ commitments to sustainable wild-caught seafood showcase
industry leadership. Japan is showing emerging buyer demand for sustainable seafood (Packard
Foundation, 2020).
This condition has been leading the global-seafood producer to shift their seafood product
to be more sustainable or responsible. The Marine Stewardship Council (MSC) - certified seafood
engaged with 539 fisheries units globally (59 countries) during 2021-2022 and predicted an
increase in the recent and upcoming years. The retail sales value generated up to US $ 12.28 billion
(MSC, 2022). The MSC is an independent, global, non-profit organisation which has established a
third-party certification for sustainable fishing. The detailed and specific indicators within the MSC
standards need special attention to achieve the full-assessment in the future through the
implementation of Fishery Improvement Project (FIP) by involving fishery stakeholders i.e.
government, fishers community, processors, NGO, and other stakeholders who are related to this
issue.
FIP is emerging as a popular market-based means to improve fisheries sustainability by

creating measurable changes to meet the MSC standard and to ensure the long-term sustainability
of a fishery (WWF-US Fisheries Program, 2013: Travaille et al., 2019) . During these processes, the
FIP implementers need to tackle some preparations and steps i.e. pre-assessment (as initial
reference or gap assessment), action plan development, also implementation and tracking
progress. These processes are valuable to make sure that every addressed-action is within the
scope of MSC standard. The growth of the fisheries under FIPs are growing fast and reached 153
FIPs in 2019 (239 FIPs in 2023), where more than doubling of the number of FIP implementers is
driven by growth in regional implementers in Mexico, Indonesia, China, Japan, Chile, and Peru.
Moreover, the total landings of fishery engaged with FIP and MSC certified is inclining up to 26% in
2019 (18,642 tonnage estimated) (CEA, 2020).
Aim and Constraint of the Pre-Assessment
The major LOT utilisation in the Western Central Pacific Ocean (WCPO) operate in
Southeast Asia, primarily the Gulf of Thailand and the South China Sea are primarily caught by
purse-seine and drift gillnet, and to a lesser extent by hook and line (primarily trolling, but also
includes handline and small longlines), particularly in Malaysia, Thailand, Vietnam, and Indonesia
(Raja Bidin and Rumpet, 1990; Kamarruddin and Raja Bidin, 1991; Chullasorn, 1995; Yonemori et al.,
1995, Lewis, 2006; Nootmorn, 2015; Siriraksophon, 2017). Since LOT is regarded as a single unit
stock for Indo Pacific Ocean region (Willey et al., 2016; Griffiths et al., 2020; (Ghani & Asmat, 2022)
and highly likely transboundary occurs within the fishery (Siriraksophon, 2017), its apparent
challenge to leveraging the management authority into the stock unit coverage.
The LOT fishing in the ECPM, mostly landed in Tok Bali and increased significantly since
1988. The targeted fishing ground (zone C-C2), ECPM waters is part of WCPFC, but at the moment,
page 1 of 120
WCPFC has not covered LOT as focus of work in this region. The reason is WCPFC does not
consider LOT as a highly migratory species (referred to Annex I lists, UNCLOS 1982). This fishing
activity potentially led to overfishing and overfished conditions if adjustment actions were not
carried out. The resilience of fishing pressure for LOT is categorised as medium where minimally 4
- 4.4 years is needed for the population to double their biomass. Moreover, LOT's vulnerability to
extinction is moderate to high vulnerability (Fishebase, 2023).
The aim of this pre-assessment is to provide the management authority to have a good
understanding of the LOT fishery within the UoA against MSC standard. This is necessary as a
basis for FIP action plan developments to address the issues that may arise, and adjust the
management action toward sustainability of the LOT fishery resources against the MSC standard
in the future. There were no specific constraints encountered in the pre-assessment process. The
WWF Malaysia team has been providing reference materials, and coordinating with the key
stakeholders for discussion and interviews sessions.
page 2 of 120
UNIT OF ASSESSMENT (UoA)
Table 1: Unit of Assessment (UoA).
UoA Description
Species Longtail Tuna (Thunnus tonggol)/ LOT

Stock South China Sea - Western and Central Pacific Ocean (WCPO)
Geographical Malaysian fishing zone C/C2 in the East Coast of Peninsular Malaysia (ECPM)
area
Harvest method Purse seine
/ gear
Client group Department of Fisheries Malaysia, Malaysian Fisheries Development Authority,
Malaysian Maritime Enforcement Agency of Kelantan, Fisheries Research
Institute (FRI), Universiti Malaysia Terengganu, MHC COLDSTORAGE Sdn. Bhd.,
WWF Malaysia
Other eligible - Terengganu commercial fishers
fishers - Johor commercial fishery *)
- Pahang commercial fishers
- Hooks and line fishers (artisanal)
Justification for The LOT in the targeted area is considered a single-unit stock within the WCPO
choosing the (South China Sea). It strongly indicates that transboundary fishing happened
Unit of where several vessels outside the country utilise the fishery in the same stock.
Assessment
1
1
*) Identified commercial purse seine fisheries exist under QL Resources Berhard that utilise LOT in the ECPM waters
page 3 of 120
TRACEABILITY WITHIN THE FISHERY
The LOT purse seine fishery that landed in Tok Bali is fishing at the C-C2 zone of the ECPM
waters area. The vessel's capacity varies from 10 GRT up to 40-70 GRT. Regarding the workers,
there are 231 local fishers, 1,057 fishers employed from Thailand (90%), and the remaining were
from local communities. The capacity and skill gap is a major issue for a large number of workers
from Thailand. In addition, reportedly 95% of the LOT landings were exported to Thailand (Ghani &
Asmat, 2022), and currently, there are no MSC-certified fisheries in Malaysia. It is convinced that
the Thailand supply chains also have a main role in this circumstance. Detailed information related
to LOT fisheries traceability is shown in Table 2 below.
Table 2: Traceability within the fishery.

Factor Description
Will the fishery use gears No, the targeted purse-seiner vessels that landed in Tok Bali are
that are not part of the Unit single and specific fishing gear used. Low risk.
of Certification (UoC)?
Will vessels in the UoC also Yes, based on some evidence, the trajectory and distribution of the
fish outside the UoC purse-seiner vessel (C/C2 licence) in ECPM are widely distributed in
geographic area? the central or even northern part of the ECPM waters, indicating that
rarely transboundary fishing exists as well. Surveillance and
enforcement data important to understand the risks mitigated.
Do the fishery client No, at the moment none of the LOT fisheries are certified within UoA.
members ever handle
certified and non-certified
products during any of the
activities covered by the
fishery certificate?
Does transhipment occur No, transhipment of catches from a foreign fishing vessel to any
within the fishery? vessel and vice versa in Malaysian fisheries water is not allowed
unless it is authorised to do so by the Director General of Department
of Fisheries Malaysia as stipulated under section 15(2) and 20 of the
Fisheries Act 1985.
But mixing identified for the landed catch may occur within the supply
chain, both transported domestically or to Thailand. This rising
conviction shows that the risk of mixing is medium to high.
Are there any other risks of No, at the moment none of the LOT fisheries are certified within UoA.
mixing or substitution
between certified and
non-certified fish?
page 4 of 120
PRE-ASSESSMENT RESULTS
Pre-Assessment Result Overview
Overview
The LOT fishery in the UoA is operating in the South China Sea as part of Indo-Pacific
waters. LOT as neritic-pelagic fishery has middle to high migration within the stock, as their
connection and roles within the ecosystem are strongly affected by the ocean circulation and
dynamic in the region. The LOT is mostly utilised by the small-scale purse-seine vessels and gill
net operation both commercially or artisanal in the Gulf of Thailand and South China Sea. ECPM as
part of Malaysia waters contributed the national neritic tuna production to provide domestic
nutrition and revenue. Transboundary is highly likely to happen within the fishery, but unfortunately
the LOT is not under WCPFC’s concern. It has been reflected in the absence of RFB in the region as
a legal framework to design, agree and implement management measures toward sustainability
use of the resources.
The existing information is available but indicating uncertainty due to the data quality
issues unconvincing to produce adequate stock assessment and information. The other key
challenges arise regarding the purse seiner resulting in multispecies from low to moderate trophic
level. Scad and trash fishes are two-top commodities of the catch which are LOT and KAW
thereafter. Secondary and ETP species monitoring is required in accordance with the
strengthening evidence to confirm the fishing impact does not harm the ecosystem.
Legislative framework and long term objective toward sustainable fisheries mandated
through provisions of the Fisheries Act 1985 (317), despite specific fishery management for LOT in
the UoA is not in place. “Resolution and Plan of Action on Sustainable Fisheries for Food Security
for the ASEAN Region Towards 2030” adopted by ASEAN Senior Officials and Ministers was yet
more general than LOT specifically, in the same with “Strategic Plan Tuna Industry Development -
South China Sea, Sulu Sea and Sulawesi Sea 2021 - 2030”. At the moment, DOF Malaysia is
developing the specific neritic tuna management for ECPM waters. The specific objectives should
be well defined and measurable through transparent decision-making and evaluation. MCS
mechanism has to be well reported and accessed to the public. Improvement action required to
shift the underperform-indicators to be more closely with the MSC standard.
Recommendations
The following recommendations proposed to move the fishery towards a more sustainable
and closer to the MSC standard. These recommendations could be used as reference to produce a
proper FIP action plan of LOT fishery in ECPM waters. Regular review might be encouraged to track
the progress and accuracy of the recommendations to answering the findings (Table 3).
page 5 of 120
Table 3. Recommendations for Performance Indicators
Performance Indicators Recommendations
Outcome
1.1.1 Stock Status Recommendation 1. Strengthen robust catch and effort data
collection for LOT fishery through mandatory log books, this
include other eligible fisheries that fishing on the same stock
(1.1.1; 1.2.3).
Recommendation 2. Conduct an adequate LOT stock assessment

as reference of population structure and biomass at high degree of
confidence at the unit of the stock (1.1.1; 1.2.4).
Recommendation 12. Strengthen the neritic tuna scientific working

group in the UoA with relevant regional body(s) (1.1.1; 3.2.1).
1.1.2 Stock Rebuilding Recommendation 3. Determine and set the target reference point
based on the appropriate proxy(s) indicators as reference for HCR
development involving the review and evaluation toward its
effectiveness in order to ensure the harvest strategy is working
within the unit of the stock. (1.2.1; 1.1.2; 1.2.2; 3.2.4).
Harvest Strategy
1.2.1 Harvest Strategy Recommendation 3. Determine and set the target reference point
based on the appropriate proxy(s) indicators as reference for HCR
1.2.2 Harvest Control Recommendation 3. Determine and set the target reference point
Rules and Tools based on the appropriate proxy(s) indicators as reference for HCR
1.2.3 Information and Recommendation 1. Strengthen robust catch and effort data
Monitoring collection for LOT fishery through mandatory log books, this
include other eligible fisheries that fishing on the same stock
(1.1.1; 1.2.3).
1.2.4 Assessment of Stock Recommendation 2. Conduct an adequate LOT stock assessment

Status as reference of population structure and biomass at high degree of
confidence at the unit of the stock (1.1.1; 1.2.4).
Primary Species
2.1.1 Outcome N/A
2.1.2 Management N/A
page 6 of 120
2.1.3 Information N/A
Secondary Species
2.2.1 Outcome Recommendation 4. Develop the management measure to

minimise the unwanted and to manage retained catch by improving
the fishing gear selectivity and bycatch reduction (2.2.1; 2.2.2;
2.5.1; 2.5.2).
2.2.2 Management Recommendation 4. Develop the management measure to

2.3.1; 2.5.1).
2.2.3 Information Recommendation 5. Conduct adequate catch composition

monitoring, and provide evidence that the fishery does not hinder
ETP species through on-board observer or camera deployment for
purse seine vessels operated in zone C-C2 (2.2.3; 2.3.1; 2.3.3).
Endangered, Threatened, and Protected (ETP) Species

2.3.1; 2.5.1).
2.3.2 Management Recommendation 6. Develop methods of mitigation and handling

of ETP species to avoid ETP bycatch and increase the survival rate
of ETP species caught or encircled by purse seines (2.3.2).
2.3.3 Information Recommendation 5. Conduct adequate catch composition

monitoring, and provide evidence that the fishery does not hinder
ETP species through on-board observer or camera recorder
deployment for purse seine vessels operated in zone C-C2 (2.2.3;
2.3.1; 2.3.3).
Habitats
2.4.1 Outcome N/A
2.4.2 Management N/A
2.4.3 Information N/A
Ecosystem

2.3.1; 2.5.1).
2.5.2 Management Recommendation 7. Develop the strategy to minimise the impact
page 7 of 120
of neritic tuna or purse seine fishery to prevent irreversible harm to
ecosystem structure and function (2.5.2).
2.5.3 Information Recommendation 8. Conduct quantitative study to ascertain the

effects of LOT purse seine fishery on the trophic level of target
species involving the potential risk arising within the ecosystem
(2.5.1; 2.5.3).
Governance and Policy
3.1.1 Legal and Customary Recommendation 9. RFB or management authority as a legal

Framework framework at the regional level is established and in place (3.1.1).
3.1.2 Consultation, Roles Recommendation 10. Enhance the consultation platform and
and Responsibilities comprehensive decision-making system for management actions
is available, transparent, and effective, responding to disputes
(3.1.1; 3.1.2; 3.2.2).
3.1.3 Long-Term N/A

Objectives
Fishery-Specific Management System
3.2.1 Fishery-Specific Recommendation 11. Strengthen the implementation of neritic

Objectives tuna or LOT management plan in ECPM/Malaysian waters that
integrated into the relevant neritic tuna management framework in
the regional level (3.2.1)
Recommendation 12. Strengthen the neritic tuna scientific working

group in the UoA with relevant regional body(s) (1.1.1; 3.2.1)
3.2.2 Decision Making Recommendation 10. Enhance the consultation platform and
Process comprehensive decision-making system for management actions
is available, transparent, and effective, responding to
disputes/issues as well (3.1.2; 3.2.2).
Recommendation 13. Strengthened collaboration for MCS

implementation actions under RPOA IUU Fishing to convince
monitoring (VMS) and to deter the transboundary fishing in the UoA
with clear evidence (3.2.2; 3.2.3).
3.2.3 Compliance and Recommendation 14. Conduct risk-assessment for the

Enforcement infringement and/or compliance of LOT fishing vessels under UoC,
further clear evidence collected to make sure MCS executed
effectively (3.2.3).
Recommendation 13. Strengthen collaboration for MCS

implementation actions under RPOA IUU Fishing to convince
monitoring (VMS) and to deter the transboundary fishing in the UoA
with clear evidence (3.2.2; 3.2.3).
page 8 of 120
3.2.4 Management Recommendation 3. Determine and set the target reference point
Performance Evaluation based on the appropriate proxy(s) indicators as reference for HCR
within the unit of the stock. (1.2.1; 1.2.2; 3.2.4).
Recommendation 15. Ensure the fisheries specific management
performance within UoA is reviewed and evaluated both internally
and occasionally-externally as responsiveness of the management
measure (3.2.4).
Summary of Potential conditions by Principle
The pre-assessment results showed there are 4 performance indicators under Principle 1
that do not meet the minimum level of SG 60 related to harvest control rules, harvest strategy,
information and monitoring, also assessment of stock status. There are also similar conditions
with the 8 performance indicators under Principle 2, and 4 performance indicators under Principle
3 that do not meet the MSC standard. The main concerns under Principle 2 are interventions
needed to maintain the secondary - ETP species, and ecosystem function, while fishery specific
objectives, decision-making processes, effective MCS, and management performance evaluation
for LOT within UoA are main findings under Principle 3, therefore unqualified to pass the minimum
level of SG 60. Overall, 16 performance indicators identified as >60, 5 indicators scored 60-79,
and 7 indicators passed the SG 80 of MSC standard. Detailed information about the summary of
the pre-assessment scores is shown in Table 4 and graphs below.
Table 4: Summary of Performance Indicator level scores <60.

Principle of the Fisheries Standard Number of PIs with draft scoring ranges <60
Principle 1 – Stock status 4
Principle 2 – Minimising environmental impacts 8
page 9 of 120
Principle 3 – Effective management 4
Summary of Performance Indicators Level Scores
Table 5: Summary of Performance Indicator level scores.

Performance Indicator Draft scoring range Data deficient?
1.1.1 – Stock status 60-79 No
A recently conducted stock assessment for LOT in the South China Sea identified the stock as not
overfished and not subject to overfishing. Using ASPIC results, the Kobe plot was created and risk
assessments were conducted for total biomass (TB). The size of the confidence surface around
the 2018 point is much smaller than normal. The reason is that the data fit ASPIC very well as
shown in the QQ plot. Based on the risk assessment results, it is suggested that the stock status
of LOT in 2018 is very healthy as it is in the green zone of the Kobe plot with 100% probability. It is
also suggested that the current catch (124,000 tons) can be increased to the MSY level (167,000
tons), in which case the probability of TB and fishing mortality (F) violating their MSY levels is less
than 50%. In contrast, the latest LOT stock status only used the nominal CPUE from two fisheries,
Thai Purse Seine (Gulf of Thailand) and Malaysia Purse Seine (Sarawak). CPUE data from the
other member countries are categorised as not plausible data. This condition causes the
estimation of total biomass to have uncertainty. In fact, LOT fisheries in ECPM and Indonesia, for
example, have a high contribution to exploitation in the South China Sea. SG 100 is not met.
1.1.2 – Stock rebuilding 60-79 Yes
Based on the latest LOT status in 2018, the LOT stock is not overfished and is not subject to
overfishing, so a stock rebuilding strategy is not required. However, the data sources used to
determine stock status do not include all fisheries catching LOTs, causing the estimation of total
biomass and fishing rate to have quite high uncertainties. SG 100 is not met.
1.2.1 – Harvest Strategy <60 Yes
There is no harvest strategy for Malaysia or other regional fisheries. SG 60-79 is not met.
1.2.2 – Harvest control rules and tools <60 Yes
There are no harvest control rules in place in the South China Sea and ECPM. In Malaysia, an
individual quota system (IQS) is used as an output control, although its implementation is not
based on the stock status of the fishery and applies to all fish species equally. So, the HCR is not
robust enough to reach SG 60, because they are not expected to reduce the exploitation rate as
the point of recruitment impairment (PRI) is approached. SG 60-79 is not met.
1.2.3 – Information and monitoring <60 Yes
Malaysia, Indonesia, Thailand, and Brunei Darussalam are the countries in Southeast Asia that
routinely provide catch data for LOT, but only Malaysia and Thailand that contributed the effort
data. Other countries, such as the Philippines, Vietnam, Myanmar, and Cambodia have no
evidence of contributing their catch data to the calculation of stock status. This would qualify for
some relevant information related to stock structure, stock productivity and fleet composition. SG
60-79 is not met.
page 10 of 120
1.2.4 – Assessment of stock status <60 Yes
For the South China Sea, a stock assessment has been conducted. With the use of only national
statistics only from four countries as well as the lack of a peer review the score will not meet SG
80. SG 60-79 is not met.
2.1.1 – Primary Outcome ≥80 No
No primary species identified, pass by default.
2.1.2 – Primary Management ≥80 No
2.1.3 – Primary Information ≥80 No
2.2.1 – Secondary Outcome <60 Yes
The LOT purse seine fishing in the ECPM waters firmly indicated multispecies catches, dominated
by scad, LOT, KAW, FRI, low value and unwanted catch (small pelagic fishes), even the C2 - LOT
purse seiners tend to be dominated by the neritic tuna species. Unfortunately, not all species are
clearly defined at the UoA. Due to lack of adequate data, PSA applied in this circumstance (fail,
<60) (page 95 -107). SG 60-79 is not met.
2.2.2 – Secondary Management <60 Yes
The secondary species management and strategy is not in place. SG 60-79 is not met.
2.2.3 – Secondary Information 60 – 79 Yes
Some and/or partial data and information about the secondary species is available but likely not
adequate to estimate the impact of the LOT purse seine fishery for the bycatch, both retained or
unwanted fishes, as well as its changes in every season and periode. SG 100 is not met.
2.3.1 – ETP Outcome <60 Yes
Anecdotal information indicates that interactions of the fishing gear with ETP biota rarely
happens, but this findings has not been supported with sufficient data to ascertain the fishery
does not hinder recovery of ETP species. Therefore, PSA used to address this performance
indicator (fail, <60) (page 110- 114). SG 60-79 is not met.
2.3.2 – ETP Management <60 Yes
ETP species that are potentially found in the fishing ground within ECPM waters are protected by
the Fisheries Act 1985, except for Tursiops aduncus. There are the Regional and National Plan of
Action for ETP marine species conservation in the region. Unfortunately, the adequate
information or report as evidence that effective ETP species management in place is unavailable.
SG 60-79 is not met.
2.3.3 – ETP Information <60 Yes
There is no clear information to assess the ETP caught and their mortality whether the fishery is
potentially a threat to recovery of the ETP species in the region. SG 60-79 is not met.
2.4.1 – Habitats Outcome ≥80 Yes
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There is no interaction between the fishing gear with the sea bed. The CSA used in this
circumstance showed its operation has a low-risk impact on the habitat (≥80) (page 115). Pass
by default.
2.4.2 – Habitats Management ≥80 No
There is no specific strategy to address. Pass by default.
2.4.3 – Habitats Information ≥80 No
No information required. Pass by default.
2.5.1 – Ecosystems Outcome <60 Yes
The lack of information on the LOT to represent their position within the food web in the pelagic
ecosystem raises doubts that key ecosystem elements are unaffected by existing fishing
activities. SICA used in this circumstance (fail, <60), due to potential high-risk for functional group
composition (page 116). SG 60-79 is not met.
2.5.2 – Ecosystems Management <60 Yes
The management measures (design, implementation, and evaluation) to prevent ecosystem
structure and function from irreversible harm by purse-seine fishing both at ECPM waters and at
the unit of the stock are not in place. SG 60-79 is not met.
2.5.3 – Ecosystems Information <60 Yes
Sufficient data is unavailable for the ecosystem as impact of the fishing, including the information
on key elements, impact on UoA, and component functions, to detect any risk to be inferred. SG
60-79 is not met.
3.1.1 – Legal and customary framework 60 – 79 Yes
Malaysia has a clear legal framework for fishery management authority under DOF as stated
within Fisheries Act 1985 (317). The absence of LOT as focussed-commodity under WCPFC
arising challenges on how to address and manage the LOT in the UoA. The national legal system
in Malaysia and existing framework initiated by SEAFDEC in ASEAN likely have not been applied
effectively to address the LOT management in the region. This condition is also affecting the
absence of a legal dispute framework as a mechanism for the resolution in the region. None of
the information and measures has been implemented demonstrating that the fishery has an
effective multi-lateral management framework. SG 100 is not met.
3.1.2 – Consultation, roles and responsibilities 60 – 79 Yes
The roles and responsibilities for fishery management in Malaysian waters are explicitly defined,
well understood, and in place for all areas of responsibility and interaction. The consultation
process provides an opportunity for the fishers or the community to join the forum through Majlis
Perundingan Industri (MPI) and fishers association. However, no clear evidence or measure is
documented to prove the consideration of the information obtained and explained to the public
from the consultation process applied. SG 100 is not met.
3.1.3 – Long term objectives ≥80 No
The fisheries management of Malaysia has clear long-term objectives explicitly stated through
several acts and enactments, mainly Fisheries Act 1985 (317) that appointed the fishery
management should be developed and decided based on the scientific information available
page 12 of 120
consistent with sound conservation and management principles and with the avoidance of
overfishing, and by the overall national policies, development plans, and programs. SG 100 is met.
3.2.1 – Fishery specific objectives <60 No
The Fisheries Management Plan (FMP) for tuna (including neritic tuna) developed by DOF in early
2010. However this FMP is no longer available for access after it ends in 2020. Otherwise,
currently the DOF is developing the specific neritic tuna management for ECPM waters. The
detailed information about those previous achievements and current progress is unavailable, i.e.
the scopes, objectives, actions, and progress, also how it will be reviewed and monitored. In
addition, the “Strategic Plan of Tuna Industry Development - South China Sea, Sulu Sea and
Sulawesi Sea 2021 - 2030” by DOF tend to focus on oceanic tuna management, which doesn't
really address the LOT management that comply with principle 1 and principle 2 of MSC standard
in the Malaysian waters.
At the regional level, the Regional Plan Of Action (RPOA) neritic-tuna was already proposed by
SEAFDEC in 2015, however, it seems not enough to cover LOT stock management within UoA,
including how it is reflected and synchronised within the ASEAN countries’ fishery management
plan. High criteria for the fishery-specific objective both to be broadly consistent with MSC
principles 1 and 2, or even achieving well-defined and measurable short and long-term objectives
is not met. SG 100 is not met.
3.2.2 – Decision making processes <60 Yes
Fishery-specific management for LOT in the UoA is not in place, a precautionary approach within
the fishery management explicitly endorsed, but the absence of the RFB in the region level affects
the clarity of appropriate-authority as decision maker to achieving and to agreeing the
management objective transparently with the stakeholders. This is also relevant with how the
dispute appearing within the LOT fishery in the UoA is precautionarily resolved. SG 60-79 is not
met.
3.2.3 – Compliance and enforcement <60 Yes
The MCS instrument and cooperation in Malaysia and regional waters (RPOA-IUU) are
quite-complete. However, the quality of the MCS implementation does not yet exhibit that the
system is comprehensive and consistent, supported by convincing evidence and reports that LOT
fishery complies with the regulations. These include how the fishery is managed and enforced
through robust harvest strategy and control rules. Without this circumstance, the fishery is going
to fail. SG 60-79 is not met.
3.2.4 – Management performance evaluation <60 Yes
The Monitoring and evaluation mechanism/system to assess the performance of the
fishery-specific management system against its objectives is not in place. SG 60-79 is not met.
page 13 of 120
PRINCIPLE 1
page 14 of 120
Background
The East Coast of Peninsular Malaysia (ECPM) is part of the South China Sea, which on a
broader scope, is part of the Pacific Ocean. The Unit of Assessment (UoA) in this study was the
species of longtail tuna (LOT) (Figure 1) caught using purse seines in Tok Bali, Kelantan, Malaysia.
The UoA includes fishers based in Tok Bali and catch LOTs in ECPM.
Fishers in Tok Bali began to catch this species intensively in the 2000s. LOT is a neritic or
shallow water tuna species that lives less than 200m deep. LOT has slimmer physical
characteristics and shorter pectoral fins than other tuna types. LOT generally has a length of 70 cm
FL and weight 35.9 kg (Collette & Nauen, 1983) with a maximum length of 145 cm FL (IGFA, 2017).
Figure 1. Longtail tuna (LOT) (source: FishBase/Hermosa)
There is no information on the fertilised eggs on LOT. Chayakul and Chamchang (1988)
described the morphological development of LOT larvae captured in the Gulf of Thailand. Larvae of
this species have been collected in the Gulf of Thailand in January, February, April, May, and June
(Chayakul and Chamchang, 1988) and off the west coast of Thailand in February, March, and April
(Boonragsa, 1987). Larvae have also been reported from Malacca Straits (Wilson, 1981) and the
South China Sea (Chen and Wei, 1981). There are relatively few reported collections of LOT larvae;
the paucity of larval and postlarval specimens of this species may be due either to the fact that its
distribution is restricted to the neritic regime or to misidentification as a more common,
better-known species.
Immature LOT, as small as 20 cm, are captured by luring purse seines off the west coast of
Thailand. Preadults were also captured during exploratory fishing cruises by pole and line and troll
line off this coast. The smallest fish captured by these gears were 24 and 28 cm, respectively.
Immature with the mode at 30 cm was captured during exploratory fishing cruises in March 1980
and February 1981 (Yesaki, 1982). Many schools of immature fishes were sighted during these
months but were fished only for samples because of the small size of the fish (Lee, 1982).
Twenty-two-cm immature are recruited to the purse-seine fishery in the Gulf of Thailand
(IPTP, 1985) and slightly larger fish (26 cm) enter the troll fishery off the east coast of Peninsular
Malaysia (IPTP, 1986). Preadults are captured in drift gillnets at Cochin in February (Silas et al.,
1986) and at Mangalore in October (Muthiah, 1986).
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Throughout the Southeast Asian region, tunas are commonly found and abundant,
including several species of oceanic and neritic tunas. While the oceanic tunas migrate over larger
areas, the neritic tunas such as longtail tuna (Thunnus tonggol), kawakawa (Euthynnus affinis),
frigate tuna (Auxis thazard), and bullet tuna (Auxis rochei) are more common within the economic
zones and sub-regional seas of Southeast Asia. However, there are still uncertainties on the
distribution, migration utilisation of neritic tuna stocks in the waters and sub-regions of
Southeast Asia. Without further clarification and dialogue, it would be difficult to develop
appropriate tuna management plans at national and sub-regional levels.
While management efforts with regards to the exploitation of oceanic tunas in the Pacific
Ocean is covered by recommendations provided by the West Central Pacific Fisheries Commission
(WCPFC), there are important work to be done within the Southeast Asian Region to promote
common approaches to management of the utilisation of neritic tunas. To ensure the sustainable
use of available regional resources, it is crucial to seek collaborative management plans for neritic
tuna fisheries in the region and sub-regions. Regional collaboration has been, and will continue to
be, crucial for the sustainability of these rich and important trans-boundary resources. This was
also emphasised by the 45th SEAFDEC Council Meeting in 2013 that called for the development of
a plan of action regional cooperation on neritic tunas in the Southeast Asian Region (paragraphs
65, 66 and 70 of the SEAFDEC Council Report).
DNA samples acquired from the South China Sea, Andaman Sea, and Semporna-Sulu Sea
were used to examine the LOT population. Five dominant haplotypes discovered by DNA analysis,
however statistical analysis revealed no significant genetic difference across the twelve sample
places. As a result, LOT in the South China Sea, Andaman Sea, and Sulu Sea are all part of the
same stock (Jamon et al., 2021; Syahida et al., 2020). Furthermore, genotyping of microsatellite
markers to analyse the genetic structure of LOT in the Southeast Asian region revealed that the
region's LOT is a single stock (Kunal et al., 2014; Willette et al., 2016; Kasim et al., 2020).
It was proposed that the LOT population be managed as a single stock. The Scientific
Working Group (SWG) 5 of SEAFDEC then suggested using the study results as a reference since
genetic stock and fisheries stock may be separated in light of the management issue. Under these
conditions, SEAFDEC/MFRDMD implemented this recommendation and conducted stock and risk
assessments of LOT in two areas (stocks): Pacific Ocean side and Indian Ocean side. (Figure 2).
page 16 of 120
Figure 2. Two areas (Pacific Ocean side and Indian Ocean side in the SE Asian waters)
used for stock and risk assessments of LOT
Figure 3. FAO Fishing Area 57 and 71

(source: www.fao.org/fishery/docs/maps/)
STOCK STATUS
The two series of stock assessments of LOT was conducted by SEAFDEC in cooperation
with the Member Countries in February 2020, with the conjecture that these species inhabited
Fishing Areas 57 and 71 (Figure 3). The results of the second assessment were compared to the
previous assessment in 2016 which was conducted using A Stock-Production Model Incorporating
Covariates (ASPIC), Kobe Plot I-II, and risk assessment (MFRDMD, 2021).
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Figure 4. Status of LOT in the Pacific Ocean in 2013 and 2018 based on Kobe Plot
(source: SEASOFIA, 2022).
Figure 5. Risk assessment of LOT in the Pacific Ocean side (South China Sea) 2018 (source:
SEASOFIA, 2022).
In the Pacific Ocean side (South China Sea), the stock status of longtail tuna in 2013 was
in the green zone (safe) as shown in Figure 4, indicating zero probability of uncertainties to be in
red, orange, and yellow zones. It was then suggested to increase the catch and fishing pressure
but it should be less than their MSY and FMSY levels, at 200,000 mt and 1.07, respectively. Since the
2018 Kobe plot also showed that the stock status of LOT remained healthy with a 100% probability
of being in the green zone (safe), it is therefore suggested that the current catch at 124,000 mt
could be increased to the MSY level of 167,000 mt because the probability of total biomass and
fishing mortality violating their MSY levels is less than 50% as shown in Figure 5.
However, the data sources used to determine stock status do not include all fisheries
fishing the LOT. The stock status only used the nominal CPUE from two fisheries, Thai Purse
Seine (Gulf of Thailand) and Malaysia Purse Seine (Sarawak). CPUE data from the other member
countries are categorised as not plausible data. This condition causes the estimation of biomass
stocks to have uncertainty. In fact, LOT fisheries in ECPM and Indonesia, for example, have a high
contribution to exploitation in the South China Sea.
page 18 of 120
Stock Rebuilding
The data sources used to determine stock status do not include all fisheries catching LOTs,
causing the estimation of total biomass and fishing rate to have quite high uncertainties. Even
though stock rebuilding is not required for this case, due to the uncertainty that exists, the
effectiveness of rebuilding strategies in rebuilding the stock is hard to be achieved.
Harvest Strategy
The harvest strategy sets out the management actions necessary to attain defined
ecological and sometimes economic objectives in a particular fishery, including achieving the
management objectives expressed in the target and limit reference points. Malaysia has long
implemented management measures for its multispecies fisheries. Malaysia was the first country
in the Association of Southeast Asian Nations (ASEAN) to develop a plan of action for the
management of fishing capacity as a model for ASEAN member states (Department of Fisheries
Malaysia, 2015a). The implementation of multiple management measures has led to valuable
progress for Malaysian fisheries. Input controls to limit fishing efforts were established and are
now combined with technical controls for marine-resource conservation and recovery (Department
of Fisheries Malaysia, 2015b).
The implementation of output controls through an individual quota system (IQS) also was
planned (Department of Fisheries Malaysia, 2008). A feasibility study of the IQS for the purse-seine
fishery in the East Coast of Peninsular Malaysia (ECPM) has been initiated, but no assessment of
the measure and feasibility of its implementation has been confirmed (Department of Fisheries
Malaysia, 2015a). The IQS is set for the total catch, since the data collected are not categorised by
species (Jamaludin et al., 2017), as a consequence of the multispecies characteristic of the
fisheries (Kato, 2008).
The neritic tuna management in ECPM waters is under development by DOF Malaysia,
therefore specific management of LOT in Malaysia waters or ECPM is not ready yet, likewise the
harvest strategy of LOT in the UoA. The clarity needed to make sure whether the harvest strategy
for LOT (IQS) is updated and included in the management plan as a measurement tool and
approach to maintain the stock in the green zone (healthy stock).
In conclusion, there are no elements that make up the current harvest strategy and no
current stock status is considered as evidence that the harvest strategy has been effectively
implemented by the fisheries authorities. There was also no evidence that alternative measures
were in place to reduce the mortality resulting from the unwanted catch of the target stock. In
contrast, almost 41% of LOT In UoA had reached or exceeded the length of the first maturity.
Harvest Control Rules and Tools
HCR is available to manage the LOT catch, but it has yet to be formally agreed upon. The
LOT stock in ECPM is currently above a level where reduced effort or other control is required
page 19 of 120
(B>BMSY and not expected to decrease). Evidence suggests that the HCR used for LOT effectively
controls exploitation as all indicators have been within the desired range in recent years, well
above the PRI. The 2013’s stock status of LOT in the Pacific side of Peninsular Malaysia is in the
green (safe) zone of the Kobe plot, i.e., TB/TBMSY=2.22 and F/FMSY=0.18 implying that TB is 122%
higher than the MSY level and F is 82% lower than the MSY level. As a consideration, these
waters have no new Kobe plot of LOT stock. Thus, a suitable HCR is considered 'unavailable’ for
the fishery.
There is no evidence that uncertainties were recognized and accounted for in the HCR.
Uncertainties may include incorrect assumptions in stock estimation, uncertainty about the effects
of environmental changes, uncertainty about the attributes of life history parameters of the target
species, data and reporting errors, uncertainty about stock limits, fishery mortality which is not
considered such as from IUU, and others. Other odd evidence also shows that the LOT catches in
ECPM are dominated by fish that have not yet matured, contrary to the stock status in 2013,
which was in the green zone (healthy stock) category.
The HCR was prepared with high uncertainties, and the means to control the rate of
exploitation were not found in any documents. Control includes restrictions through quotas and
supporting measures, such as permits and fishing logbooks.
Information/ Monitoring
Basic information about stock structure (geographical range and size composition) is
available. In addition, data on catch and composition of fishing efforts are also available to provide
information for stock estimation; however, these data are only partially available, so they cannot be
said to be comprehensive.
page 20 of 120
A
B
Figure 6. Fishing area of LOT fishery based in Tok Bali (A) and the worldwide distribution of LOT
and the four putative stocks based on best-available information from genetic, morphometric and
tagging studies (B)
page 21 of 120
Although data is available, fishery authorities do not actively monitor CPUE within key
fishing grounds. Furthermore, there is no information about fishery removal activities from other
locations. There may be LOT caught by other fishing fleets outside Tok Bali who fish in the same
UoA, for example, purse seiners from Thailand (Figure 6).
Assessment of Stock Status
The LOT stock assessment in the Pacific Ocean side (South China Sea) did not specify the
type and source of data and the parameters used in estimating stocks, such as the growth rate.
The stock assessment is not only relative to reference points but also the reference points used
have yet to be estimated from the appropriate estimates for fishery stocks. Furthermore, it has yet
to identify significant uncertainty sources, such as recruitment variability. Stock status is also not
evaluated relative to reference points on a probability basis.
The stock assessment has yet to go through a comprehensive assessment of the

alternative hypotheses. Fishery authorities do not carry out internal and external reviews of stock
assessment. Stock assessment reports submitted are not reviewed by independent external
entities, such as regional scientific bodies or other independent external reviewers.
Catch Profiles
Tuna and tuna-like species, small pelagic fishes (e.g., scads, mackerel, anchovies,
sardines), demersal fish species, crabs, mollusks, and seaweeds are among the economically
important marine species that contributed significantly to Southeast Asia's overall fisheries
production in 2019. These species, which are in high demand not only in the Southeast Asian
region but also in other parts of the world, dominate Southeast Asian countries' fishery exports.
The tuna and tuna-like species include the most economically important species referred
to as principal market because of their global economic importance and the intensive international
trade generated for canning and sashimi production. SEAFDEC (2022) reported Southeast Asia's
tuna and tuna-like species production in 2019 accounted for around 14.06% of the region's overall
marine capture fisheries production. Oceanic tuna accounted for roughly 50.7% of total tuna and
tuna-like species production in the region, while tuna-like species accounted for approximately
27.2% of total tuna and tuna-like species production in the region. In 2019, Indonesia, the biggest
tuna producer in Southeast Asia, provided around 68.60% of the region's total tuna production,
followed by the Philippines (22.55%), Malaysia (4.88%), Thailand (2.50%), Vietnam (1.35%), and
Brunei Darussalam (0.12%). Skipjack tuna (Katsuwonus pelamis) contributed the most production
volume (44.27%), followed by yellowfin tuna (Thunnus albacares) at 20.15% and longtail tuna
(Thunnus tonggol) at 11.80% (Figure 7).
In 2019, the region produced 320,052 mt of neritic tuna for FAO Major Fishing Area 71
(Pacific, Western Central), valued at USD 380,575,000. The region's production for LOT was
158,273 mt, with a value of production of USD 101,462,000. LOT production accounts for
approximately 50% of regional production and 27% of value production.
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The SEAFDEC supported a proposal to strengthen regional cooperation to promote
conservation and management for sustainable neritic tuna fisheries in the Southeast Asian
Waters. Through regional and sub-regional cooperation the countries – and producers – need to
be able to show and verify the sustainability of targeted neritic tuna fisheries. Malaysia, Indonesia,
Thailand, and Brunei Darussalam are the countries in South East Asia which routinely provide
catch and effort data for neritic tunas, including LOT. The historical catch of LOT has also been
compiled from 1979 to 2018 as shown in Figure 7.
Tok Bali is located in the northeastern part of Kelantan, a state in Malaysia. Tok Bali is 48
km from the centre of the state city, namely Kota Bharu. Tok Bali is locally known as a fishing
district with a fishing port managed by the Lembaga Kemajuan Ikan Malaysia (LKIM). The fishing
port is in Sungai Semerak, with several port facilities, such as an ice factory and warehouse (Ghani
& Asmat, 2022).
Figure 7. A) Percentage of tuna species (left) and tuna-like species (right) production of
Southeast Asia in 2019 by quantity. B) Historical catch of LOT in the Pacific Ocean side (South
China Sea) by country (1979-2018) (source: Jamon et al., 2021).
page 23 of 120
The Department of Fisheries (DOF), a government agency that also deals with fisheries,
collects and manages data to produce fisheries statistics. Since 2008, DOF has collected landing
LOT data at ECPM to calculate stock abundance through catch-per-unit effort (CPUE) analysis.
From 2008 to 2017, CPUE analysis showed an increasing trend in ECPM but decreased in 2018 to
<10 mt/vessel (Figure 8).
Figure 8. CPUE (Mt/Unit) of LOT caught by purse seiners in the ECPM

(source: Jamon et al., 2021)
DOF Tok Bali and LKIM saw the opportunity of establishing Tok Bali as a fisheries hub with
a stable increase of landings (Figure 9) recorded between 2014 (2,066 mt) to 2020 (22,735 mt).
This hike was encouraged due to the demand from Thailand, mostly for food processing plants, as
reported by the DOF Tok Bali.
Figure 9. Longtail tuna landings in Kelantan from 2010 to 2020

(source: DOF Kelantan in Ghani & Asmat, 2022)
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The slight falls of landings from 2018 to 2020 (an average of 21,077 mt of these 3 years)
from its peak in 2017 (27,239 mt) were caused by the regulation that was enforced to reduce the
employment of foreign workers in vessels, as notified by the officer in DOF Tok Bali. Local workers
who were employed lacked the skill to operate the fishing activity in the large scale sector,
however, due to the advancement of fleets in recent years, the landings were still considered as
high-yielding compared to the landings in the early 2010.
Figure 10. The length frequency distribution of LOT landed in Tok Bali (source: DOF Tok Bali, 2017)
Apart from collecting catch landing data, DOF Tok Bali also collects biological LOT data for
length frequency analysis at Tok Bali. Almost 41% of LOT had reached or exceeded the length of
the first maturity. This analysis shows that LOT catch is still dominated by the juvenile category,
which is predicted to have never spawned during its lifetime.
Total Allowable Catch (TAC) and Catch data
Table 6: Total Allowable Catch (TAC) and Catch Data.

TAC / Catch Data Year Amount (mt)
TAC 2018 167,000
UoA 2018 167,000
Total catch by UoA (most recent year) 2019 219,400
Total catch by UoA (second most recent year) 2018 124,000
Performance Indicator Scores and Rationales
PI 1.1.1 - Stock Status

Because the
PI 1.1.1 The stock is at a level that maintains high productivity and has a low probability of recruitment
page 25 of 120
overfishing
Scoring Issue SG 60 SG 80 SG 100
Stock status relative to recruitment impairment
It is likely that the stock is There is a high degree of

It is highly likely that the stock
Guidepost above the point of recruitment certainty that the stock is
is above the PRI.
impairment (PRI). above the PRI.
Met? Yes Yes No
The fishery has limited data and there are no recent stock assessment results
that explicitly provide information on estimated biomass in relation to PRI
levels. The CPUE for purse seine on the ECPM showed an increasing trend
Rationale
from 2014 to 2017, then slightly decreased in 2018. There was fluctuation
around the level of 6 mt/vessel/year in the last 10 years (2008-2017) after
recovering from levels lower than 2 mt/vessel/year in 2010.
Stock status in relation to achievement of maximum sustainable yield (MSY)
There is a high degree of

certainty that the stock has
The stock is at or fluctuating
been fluctuating around a
Guidepost around a level consistent with
level consistent with MSY or
MSY.
has been above this level over
recent years.
Met? Yes No
In the latest conducted stock assessment for the South China Sea (Pacific
Ocean side), SEAFDEC conducted a LOT stock assessment, using the ASPIC
method and Kobe plots with data gathered from SEAFDEC member countries.
The current stock status (2018) of LOT in the Kobe plot remained healthy with
Rationale
a 100% probability of being in the green zone (safe), it is therefore suggested
that the current catch at 124,000 mt could be increased to the MSY level of
167,000 mt, because the probability of total biomass and fishing mortality
violating their MSY levels is less than 50%.
Stock Status
Current Stock Status Relative
Relative to Type of Reference Point Value of Reference Point
to Reference Point
Reference Points
Reference point
used in scoring
CPUE 2 mt/vessel/year 6 mt/vessel/year
stock relative to
PRI (SIa)
Reference point
used in scoring
BMSY 167,000 mt 124,000 mt
stock relative to
MSY (SIb)
page 26 of 120
Draft Scoring 60-79
Range
Determination of the latest LOT stock status only used the nominal CPUE from
two fisheries, Thai Purse Seine (Gulf of Thailand) and Malaysia Purse Seine
Information (Sarawak). CPUE data from the other member countries are categorized as not
Gap Indicator plausible data. This condition causes the estimation of biomass stocks to have
uncertainty. In fact, LOT fisheries in ECPM and Indonesia, for example, have a
high contribution to exploitation in the South China Sea.
Data-Deficient? No
PI 1.1.2 - Stock Rebuilding
PI 1.1.2 Where the stock is reduced, there is evidence of stock rebuilding within a specified timeframe
Rebuilding timeframes
A rebuilding timeframe is
specified for the stock that is The shortest practicable
shorter by 20 years or 2 times rebuilding timeframe is
Guidepost its generation time. For cases specified that does not
where 2 generations is less exceed 1 generation time for
than 5 years, the rebuilding the stock.
timeframe is up to 5 years.
Met? Yes Yes
Rationale N/A
Rebuilding evaluation
There is strong evidence that

There is evidence that the
the rebuilding strategies are
rebuilding strategies are
Monitoring is in place to rebuilding stocks, or it is
rebuilding stocks, or it is likely
determine whether the highly likely based on
based on simulation
rebuilding strategies are simulation modelling,
Guidepost modelling, exploitation rates,
effective in rebuilding the exploitation rates, or previous
or previous performance that
stock within the specified performance that they will be
they will be able to rebuild the
timeframe. able to rebuild the stock
stock within the specified
within the specified
timeframe.
timeframe.
Met? No No No
The data sources used to determine stock status do not include all fisheries
catching LOTs, causing the estimation of total biomass and fishing rate to
Rationale have quite high uncertainties. Even though stock rebuilding is not required for
this case, due to the uncertainty that exists, this sub indicator cannot be
achieved.
page 27 of 120
Draft Scoring 60-79
Range
Based on the latest LOT status in 2018, the LOT stock is not overfished and is
not subject to overfishing, so a stock rebuilding strategy is not required.
Information
However, the data sources used to determine stock status do not include all
Gap Indicator
fisheries catching LOTs, causing the estimation of total biomass and fishing
rate to have quite high uncertainties.
PI 1.2.1 - Harvest Strategy
PI 1.2.1 There is a robust and precautionary harvest strategy in place
Harvest strategy design
The harvest strategy is

responsive to the state of the The harvest strategy is
The harvest strategy is
stock and the elements of the responsive to the state of the
expected to achieve stock
harvest strategy work stock and is designed to
Guidepost management objectives
together towards achieving achieve stock management
reflected in PI 1.1.1/PI 1.1.1A
stock management objectives objectives reflected in PI
SG80.
reflected in PI 1.1.1/PI 1.1.1A 1.1.1/PI 1.1.1A SG80.
SG80.
Met? No No No
There are no elements that make up the current harvest strategy that is
Rationale considered evidence that the harvest strategy has been effectively
implemented by the fisheries authorities.
Harvest strategy evaluation
The performance of the

harvest strategy has been
The harvest strategy is likely The harvest strategy may not fully evaluated and evidence
to work based on prior have been fully tested but exists to show that it is
Guidepost
experience or plausible evidence exists that it is achieving its objectives
argument. achieving its objectives. including being clearly able to
maintain stocks at target
levels.
Met? No No No
There is no evidence that the harvest strategy was implemented so the

Rationale
evaluation activities must also not work.
Harvest strategy monitoring
Guidepost Monitoring is in place that is
page 28 of 120
expected to determine
whether the harvest strategy
is working.
Met? No
There is no evidence that the harvest strategy was implemented so the

Rationale
monitoring activities must also not work.
Harvest strategy review
Monitoring is in place that is

expected to determine
Guidepost
whether the harvest strategy
is working.
Met? No
There is no evidence that the harvest strategy was implemented so the review
Rationale
activities must also not work.
Shark finning
There is a high degree of There is a high degree of

It is highly likely that shark
Guidepost certainty that shark finning is certainty that shark finning is
finning is not taking place.
not taking place. not taking place.
Met? Not Relevant Not Relevant Not Relevant
Rationale N/A
Review of alternative measures
There is a regular review of There is a biennial review of

There has been a review of
the potential effectiveness the potential effectiveness
the potential effectiveness
and practicality of alternative and practicality of alternative
and practicality of alternative
measures to minimise measures to minimise
Guidepost measures to minimise
UoA-related mortality of UoA-related mortality of
UoA-related mortality of
unwanted catch of the target unwanted catch of the target
unwanted catch of the target
stock and they are stock, and they are
stock.
implemented as appropriate. implemented, as appropriate.
Met? No No No
There was no evidence that alternative measures were in place to reduce the
mortality resulting from the unwanted catch of the target stock. In contrast,
Rationale
almost 41% of LOT In UoA had reached or exceeded the length of the first
maturity.
Draft Scoring <60

Range
Information The implementation of the individual quota system (IQS) as a harvest control
Gap Indicator in ECPM is still within the multi-species framework so it cannot be ascertained
page 29 of 120
whether LOT stocks have improved or not. IQS determination also cannot be
traced to the model used in the calculation. There is no evidence that a harvest
strategy is implemented and alternative measures are implemented to reduce
the mortality resulting from unwanted catches of target stocks. This concludes
that the fisheries authority has not prepared the harvest strategy for LOT in the
UoA.
PI 1.2.2 - Harvest Control Rules and Tools
PI 1.2.2 There are well-defined and effective HCRs in place
HCRs design and application
Well defined HCRs are in

place that ensure that the The HCRs are expected to
Generally understood HCRs exploitation rate is reduced as keep the stock fluctuating at
are in place or available that the PRI is approached, are or above a target level
are expected to reduce the expected to keep the stock consistent with MSY, or
Guidepost
exploitation rate as the point fluctuating around a target another more appropriate
of recruitment impairment level consistent with (or level taking into account the
(PRI) is approached. above) MSY, or for key LTL ecological role of the stock,
species a level consistent most of the time.
with ecosystem needs.
Met? No No No
HCR is available to manage the LOT catch, but it has yet to be formally agreed
upon. The LOT stock in ECPM is currently above a level where reduced effort
or other control is required (B>BMSY and not expected to decrease). Evidence
suggests that the HCR used for LOT effectively controls exploitation as all
indicators have been within the desired range in recent years, well above the
PRI. The latest stock status (2018) of LOT in the South China Sea remained
Rationale
healthy with a 100% probability of being in the green zone (safe), it is therefore
suggested that the current catch at 124,000 mt could be increased to the MSY
level of 167,000 mt because the probability of total biomass and fishing
mortality violating their MSY levels is less than 50%. As a consideration, the
fishery has no new Kobe plot of LOT stock. Thus, a suitable HCR is considered
'unavailable’ for the fishery.
The robustness of HCRs to uncertainty
The HCRs take account of a

wide range of uncertainties
The HCRs are likely to be including the ecological role
Guidepost robust to the main of the stock, and there is
uncertainties. evidence that the HCRs are
robust to the main
uncertainties.
page 30 of 120
Met? No No
There is no evidence that uncertainties were recognized and accounted for in

the HCR. Uncertainties may include incorrect assumptions in stock estimation,
uncertainty about the effects of environmental changes, uncertainty about the
attributes of life history parameters of the target species, data and reporting
Rationale
errors, uncertainty about stock limits, fishery mortality which is not considered
such as from IUU, and others. Other odd evidence also shows that the LOT
catches in ECPM are dominated by fish that have not yet matured, contrary to
the stock status in 2018, which was in the green zone (healthy stock) category.
Evaluation of HCRs
Available evidence indicates

There is some evidence that Evidence clearly shows that
that the tools in use are
tools used or available to the tools in use are effective
appropriate and effective in
Guidepost implement HCRs are in achieving the exploitation
achieving the exploitation
appropriate and effective in levels required under the
levels required under the
controlling exploitation. HCRs.
HCRs.
Met? No No No
The HCR was prepared with high uncertainties, and the means to control the
rate of exploitation were not found in any documents. Control includes
Rationale
restrictions through quotas and supporting measures, such as permits and
fishing logbooks.
Draft Scoring <60

Range
HCR is available to manage LOT fishery in ECPM but has not been formally
agreed. Existing HCR also have high uncertainties because the type of data
used for stock evaluation and other assumptions needed in stock assessment
Information
cannot be explained. In addition, there is no evidence of input or output control
Gap Indicator
as a tool to limit the exploitation of target fish, such as catch quotas and
supporting measures (permits and fishing logbooks). The implementation of
the IQS as an output control in ECPM is still within the multi-species approach.
PI 1.2.3 - Information and Monitoring
PI 1.2.3 Relevant information is collected to support the harvest strategy
Range of information
Guidepost Some relevant information Sufficient relevant information A comprehensive range of
page 31 of 120
related to stock structure, related to stock structure, information (on stock
stock productivity, and fleet stock productivity, fleet structure, stock productivity,
composition is available to composition, and other data fleet composition, stock
support the harvest strategy. are available to support the abundance, UoA removals,
harvest strategy. and other information such as
environmental information),
including some that may not
be directly related to the
current harvest strategy, is
available.
Met? Yes No No
Basic information about stock structure (geographical range and size

composition) is available. In addition, data on catch and composition of catch
Rationale effort are also available to provide information for stock estimation; however,
these data are only sometimes available, so they cannot be said to be
comprehensive.
Monitoring
All information required by the

Stock abundance and UoA
harvest strategy is monitored
removals are regularly
with high frequency and a
Stock abundance and UoA monitored at a level of
high degree of certainty, and
removals are monitored and accuracy and coverage
there is a good understanding
at least 1 indicator is available consistent with the harvest
Guidepost of the inherent uncertainties
and monitored with sufficient strategy, and 1 or more
in the information (data) and
frequency to support the indicators are available and
the robustness of
harvest strategy. monitored with sufficient
assessment and
frequency to support the
management in dealing with
harvest strategy.
this uncertainty.
Met? Yes No No
Although data is available, fishery authorities do not actively monitor CPUE

Rationale
within key fishing grounds.
Comprehensiveness of information
There is good information on

Guidepost all other fishery removals
from the stock.
Met? No
There is no information about fishery removal activities from other locations.

Rationale Still, there may be LOT caught by other fishing fleets outside Tok Bali who fish
in the same UoA, for example, purse seiners from Thailand.
Draft Scoring <60

Range
Information Reports on the results of data collection on the LOT in the UoA are minimal.
page 32 of 120
Gap Indicator Only SEAFDEC that published some reports on LOT showing the bio-population
information and the catch profiles in the South China Sea. Data collection is
not carried out continuously as a comprehensive stock monitoring effort.
PI 1.2.4 - Assessment of Stock Status
PI 1.2.4 There is an assessment of the stock status
Appropriateness of assessment to stock under consideration
The assessment takes into

The assessment is account the major features
Guidepost appropriate for the stock and relevant to the biology of the
for the harvest strategy. species and the nature of the
UoA.
Met? No No
A stock assessment has been conducted for the South China Sea. However,
the actual stock structures are unknown, catch data is based on FAO, IOTC and
data coordinators of the SEAFDEC neritic tuna project. This means that almost
all data are national statistics which has wide range of uncertainties, CPUE are
Rationale
based on Thailand PS and Malaysia-Sarawak PS informations only, as other
plausible CPUE are not available, thus the results are mainly driven by two LOT
fisheries and the series may not be long enough for reliable stock
assessments. There is also no evidence of a stock assessment peer review.
Assessment approach
The assessment estimates The assessment estimates

stock status relative to stock status relative to
Guidepost generic reference points reference points that are
appropriate to the species appropriate to the stock and
category. can be estimated.
Met? No No
The stock assessment is not only relative to reference points, but also the
Rationale reference points used have yet to be estimated from the appropriate estimates
for fishery stocks.
Uncertainty in the assessment
The assessment evaluates

The assessment identifies The assessment takes stock status relative to
Guidepost
major sources of uncertainty. uncertainty into account. reference points in a
probabilistic way.
Met? No No No
page 33 of 120
The stock assessment has not identified significant uncertainty sources, such
Rationale as recruitment variability. Stock status is also not evaluated relative to
reference points on a probability basis.
Evaluation of assessment
The assessment has been

tested and shown to be
robust. Alternative
Guidepost
hypotheses and assessment
approaches have been
rigorously explored.
Met? No
The stock assessment has yet to go through a comprehensive assessment of

Rationale
the alternative hypotheses.
Peer review of assessment
The assessment of stock The assessment has been

Guidepost status is subject to peer internally and externally peer
review. reviewed.
Met? No No
Fishery authorities do not carry out internal and external reviews of stock
assessment. Stock assessment reports submitted are not reviewed by
Rationale
independent external entities, such as regional scientific bodies or other
independent external reviewers.
Draft Scoring <60

Range
There is only one report related to estimating LOT stocks at South China Sea,
released in 2013 and 2018, and there are no subsequent reports on estimating
Information
stocks. The stock assessment method in the report is not explained in detail,
Gap Indicator
so it cannot be understood whether the life history of LOT parameters is
considered when estimating the stock.
page 34 of 120
PRINCIPLE 2
page 35 of 120
Background
The main objective of Principle 2 is to state that the fishing operations should allow for the
maintenance of the structure, productivity, function, and diversity of the ecosystem (including
habitat and associated dependent and ecologically related species) on which the fishery depends.
The LOT purse seine fishing in the UoC comes from varying fishing fleet capacity from 40-70 GT
(capcity: 10 tonnage) up to >70 GT (capcity: 30 tonnage). These middle to huge dimensions of
purse seine exhibit the capacity and variation of the fishing techniques and catches. The purse
seiners in ECPM used to operate all day both daylight or night, by using lure light as attractor. The
purse seine vessels that operate in zone C2 (landed in Tok Bali) specifically operate without any
FAD (based on the interview), surely this practices minimise the impact of the fishing for habitat.
However, the various purse seine operations led to the diversity of the catch compositions based
on their fleet capacity and the fishing ground.
In general, The LOT purse seines fishing in the ECPM waters firmly indicated multispecies
catches. Harlyan et al., (2021) collected and analysed the LOT purse seine’s catch composition
from 137 sites (zone B, C and C2) within ECPM waters during 2017-2018, including: LKIM Tok Bali,
LKIM Pulau Kambing, LKIM Kuala Besut, LKIM Kuantan, LKIM Endau, and QL Resources Berhard in
Johor. Identified there are 26 species, which are categorised into eleven (11) main groups,
including: a) Decapterus spp (34%), b) trash fishes (20%), c) Thunnus tonggol (13%), d) Euthynnus
affinis (10%), e) Sardinella spp (5%), f) Selar crumenophtalmus (5%), g) mixed fishes (4%), h)
Rastrelliger kanagurta (3%), i) Amblygaster spp (2%), j) Atule mate (2%), and k) Selaroides leptolepis
(2%) (Figure 11). The C2 - LOT purse seiners that landed in Kelantan (2016-2021) have more
specific catches than smaller purse seiners in zone B and C, it showed from the catch
composition dominated by Thunnus tonggol (76%), Auxis thazard (22%), and Euthynnus affinis (2%)
(DOF, 2023). This relates with the fishing ground in C and C2 as part of the pelagic waters
ecosystem.
Figure 11. The catch composition group of LOT purse seine fishing in ECPM during 2017 -
2018
page 36 of 120
The 26 species are distributed widely within ECPM, whereas LOT tends to concentrate in
the middle to the north part of ECPM in the zone of C and C2 (blue box in Figure 12). Otherwise,
the southern part is dominated by the small pelagic (mesopelagic and/or epipelagic fishes) that
are mostly included as trash fishes (low-value fishes). These results could be challenges to
minimising the impact on the fishery for the unwanted catch, and/or immature catch within the
fishery. In order to prevent the risk to the ETP species, purse seine fishing indicated probably
risked. Based on the anecdotal information during the field visit, it is highly indicated that the LOT
purse seine operation rarely caught the ETP species, even if it happened, they were released back
into the waters. But the evidence to prove this good practice is unavailable.
Figure 12. The distribution of the 26 species of LOT purse seine’s catch composition in ECPM
during 2017-2018 in several identified fishing zones (Harlyan et al., 2021).
In addition, there are four species of Sea Turtle (leatherback, green turtle, hawksbill, and
olive ridley) found in Malaysia. It was also reported that various marine mammals were sighted
and stranded on the east coast of the Malaysian peninsula. The overlapping of migration pathways
of sea turtles and marine mammals with the LOT fishing ground convincingly happened within the
operation in ECPM waters (Chan, 2006). As part of the pelagic ecosystem, the interaction within
the food web for every single organism has a potential impact or risk to the trophic level
composition. Understanding the key functional element in the ecosystem helps the authority to
design and implement kind of management actions toward establishing a sustainable ecosystem.
The detailed information on Principle 2 indicators which are assessed available in Table 7 below.
page 37 of 120
Table 7. Information of Principle 2
Component Scoring Elements Designation Data-Deficient
Primary Species - - -
Decapterus spp (Scad) Main Yes
Euthynnus affinis (KAW) Main Yes
Sardinella spp Main Yes
Selar crumenophthalmus
Main Yes
(Bigeye Scad)
Secondary Species
Rastrelliger kanagurta
Minor Yes
(Indian Mackerel)
Amblygaster spp
Minor Yes
(small genus of sardinella)
Atule mate (Yellowtail Scad) Minor Yes
Auxis thazard (FRI) Main yes
Dermochelys coriacea
- Yes
(Leatherback turtle)
Lepidochelys olivacea
- Yes
(Olive Ridley Turtle)
ETP Species Chelonia mydas (Green Turtle) - Yes
Eretmochelys imbricata - Yes
Tursiops aduncus
(Indo-pacific bottlenose - Yes
dolphin)
Habitat Tropical; pelagic-neritic - -
Ecosystem South China Sea (native) - Yes
Primary Species
The primary species is defined as the other species caught in the fishery in which the
management tools and measures are in place. The aim of this performance indicator is to ensure
that these other species caught by the fishery are either not depleted, or that there is an assurance
that the fishery under assessment is not hindering the ability of those stocks to recover. The catch
composition of LOT purse seine fishery in ECPM (as shown in Figure 11) have no specific
management action. Therefore, no primary species identified, all of the performance indicators
are passed by default.
page 38 of 120
Secondary Species
Secondary species defined as the unmanaged species identified caught by the LOT purse
seine in the UoA. Identified main and minor secondary species assessed in this assessment based
on the total landings data (Harlyan et al., 2021 & DOF, 2023) and combined with their resiliency
ability in response to the environmental pressure. Decapterus spp, Euthynnus affinis (Kawa
Kawa/KAW), Auxis thazard (Frigate Tuna/FRI), Sardinella spp, and Selar crumenophthalmus are
considered as main due to unless resilient and dominating the landings (≥5%), therefore
Rastrelliger kanagurta, Amblygaster spp, and Atule mate as minor secondary species (Figure 13).
Considering the lack of data to represent their stock, PSA used to score the secondary species
performance and resulted in >60 (fail) (page 95-107).
Auxis thazard Euthynnus affinis
Sardinella spp. Selar crumenophthalmus
Rastrelliger kanagurta Amblygaster spp.
Atule mate Decapterus spp.

Figure 13. The secondary species identified from purse-seiner in ECPM during 2017-2018 (Harlyan
et al., 2021) and 2016 - 2021(DOF, 2023). (source: fishbase)
page 39 of 120
KAW stock in South China Sea waters indicated highly likely in the safe stock (2013 and
2018 data), even if it's indicated in the green zone, but the current catch is higher than the MSY
level in 2018, the catch should still be reduced in order to maintain the stock is remains in a safe
condition. The exploitation rate (E=F/Z) of Decapterus macrosoma, and Decapterus maruadsi in
Malaysia (landed in Tok Bali) in the range of 0.59-0.75 (2003 and 2005 data). In addition, the
exploitation rate of Rastrelliger kanagurta 2003-2005 and 2016-2020 in a row: 0.65 and 0.64, and
there is no exploitation rate information about the rest of secondary species found (SEAFDEC,
2022). Adequate monitoring needed due to lack of data and specific management plan, as long
as it is not in place. The availability of the data to describe the impact of the LOT purse seine
fishing to the bycatch is fundamental to be conducted as reference for management authority to
design and to implement partial strategies.
ETP Species
Endangered, Threatened or Protected (ETP) species are in scope species that are
recognised by national threatened species legislation or species that are listed in binding
international agreements such as the Convention on International Trade in Endangered Species
(CITES). Reflecting on the LOT purse seine fishery in ECPM waters, as stated in the previous
chapter, identified ETP species rarely caught within the LOT fishery operation, but there is no
evidence to prove and clarify that the fishery is not hindering the ETP species. Based on the
available scientific researches about the ETP migration pathways in Malaysia, identified there are 5
ETP species as concerns under this performance indicator (Table 8). In this term, refer to the ETP
species recognized by the national threatened species legislation or species that are listed in
binding international trade in endangered species (CITES). ECPM and South China Sea as part of
the migration path of sea turtles in the region, and identified several nesting-beach area for the
green sea turtle Chelonia mydas (in huge numbers >1000), the hawksbill Eretmochelys imbricata
with more moderate nesting numbers (low 100s). Malaysia used to host one of southeast Asia’s
largest leatherback Dermochelys coriacea populations with upwards of 10,000 nests deposited in
the 1950s at Rantau Abang, Terengganu. Solitary nesting olive ridley turtles Lepidochelys olivacea
has been nesting extremely infrequently in Malaysia (Piltcher et al., 2019). All of those species are
fully prohibited by the Malaysian government under International Trade in Endangered Species
Act 2008 (Act 686), therefore all of the utilisation of these species is unpermitted.
Table 8. ETP species are probably caught by the LOT purse seine fisheries under UoA.
Scientific Malaysia
Image (Source: NOAA Fisheries) and Common Name IUCN Status
Name Status
Dermochelys
Vulnerable Prohibited
coriacea
page 40 of 120
Leatherback Turtle
Lepidochelys
Vulnerable Prohibited
olivacea
Olive Ridley Turtle
Chelonia
Endangered Prohibited
mydas
Green Turtle
Eretmochelys Critically
Prohibited
imbricata Endangered
Hawksbill Turtle
page 41 of 120
Tursiops Near
Prohibited
aduncus Threatened
Indo-pacific bottlenose dolphin
The certain information about the potential catch rate for the ETP species of the LOT
purse seine in the UoA is unclearly defined. The PSA (page 95-107) used to score this
circumstance and indicated high risk (>60) for the ETP species impacted. Moreover, Pilcher et al.,
(2019), revealed the migration pathways of Chelonia mydas through satellite tracking within the
South China Sea (Figure 14). A total of 27 species of marine mammals from 21 genera and seven
families have been recorded in Malaysia. These comprise species known solely from stranding
records, live sightings, or both (Ponnampalam, 2012). Some were recorded on the east coast of
peninsular Malaysia, indicating their migration route may include being in the South China Sea
(Figure 15). It is convincing that the LOT purse seine operation at ECPM has probably encountered
the migration of sea turtles and marine mammals.
Yet its impacts are poorly understood, may include entanglement, direct capture,
behavioural, mortality or migration patterns. These include less understanding of ETP species
treatment and handling by the vessel’s crew applied or not, even retained. Based on the anecdotal
information, shark finning does not happen under the LOT purse seine operation in the UoA,
however, adequate information was used to confirm the uncertainty and state that the fishery
does not hinder ETP species to recovery. Although the impacted ETP species is caught as rarely,
no partial strategies have been implemented to measure the compliance, mitigation action and
proper ETP handling on board. Despite the national plan of action for ETP species in Malaysia
being available, how it effectively implemented and deterred any risk of fishing to the ETP species
is unavailable. In addition, the available information about ETP is broadly separated, and no regular
monitoring to assess the impact of LOT fishing on ETP species within UoA is applied effectively.
page 42 of 120
Figure 14. The migration pathways of Chelonia mydas through satellite tracking within the South
China Sea (Pilcher et al., 2019).
Figure 15. Sighting and Stranding Location of Various Marine Mammals in Peninsula Malaysia
(Ponnampalam, 2012).
Habitat
The fishing operations managed to maintain the structure, productivity, function, and
diversity of the ecosystem on which fishing depends, including other species caught and habitat.
page 43 of 120
The management authority seeks to ensure that the LOT fishery in the targeted UoA does not
cause harmful impacts on habitats and is appropriate to what kind of management is in place to
ensure the quality of the habitat.
The purse seine fishing in Tok Bali and surrounding water operates in an inner-shelf zone
(C and/or C2) without any interaction with the sea bed. Moreover, no FAD used by the LOT purse
seine vessels landed in Tok Bali. No irreversible harm appeared, nor were a specific management
strategy and information or monitoring required. The fishery is default 100 passes. To
corroborate the justification, CSA (page 115) was conducted to measure and did result low-risk.
Ecosystem
The inner shelf zone creates a unique ecosystem for aquatic organisms within pelagic
waters, such as zooplankton, finfish, cephalopods, charismatic species / ETP, etc. They interact
intensely and form a complicated food web system. The ocean circulation dynamic contributes to
nutrient richness and supports primary productivity in the ecosystem. The MSC standard requires
the fishery not to cause irreversible harm to the key elements of the ecosystem or the underlying
ecosystem structure and function pointed to hinder the ecosystem's resilience or recovery ability
from the impact. The role of LOT in the food web is shown by the trophic level in the range of 4.5
± 0.6 (Fishbase, 2023). It represents a high position in the food web, although its actual function in
ecosystem structure is unclear due to lack of evidence.
One of the ways to understand the roles of the LOT within the ecosystem is through diet
habits. The LOT diet studies revealed prey to several organisms such as anchovy, shrimp, squid,
and other epipelagic and mesopelagic fishes. Anchovy dominated the forage up to more than 80%
of their diet (Risti et al., 2019; Saraswati et al., 2020). The characteristics between coastal and
pelagic waters impact the dynamic of the diversity within the ecosystem that led and influence
the types of forage resources eaten by the higher trophic level fish species. Forage fishes are key
energy conduits that transfer primary and secondary productivity to higher trophic levels. As novel
environmental conditions caused by overlapping fishing alter ecosystems and prey-predator
dynamics, it is critical to understand how forage-fish control the bottom-up forcing of food web
dynamics (Grant et al., 2014).
Otherwise LOT, the associate species, such as Euthynnus affinis, Auxis thazard, Atule mate,
and Scomberomorus spp, that prey on small-pelagic (epipelagic fishes). Figure 16 below exhibits
the food web in the pelagic-neritic ecosystem of Central North Pacific (CNP), as referenced for
ECPM cases whereas LOT's role as an intermediate to top predator due to high trophic-level.
Highly-likely that the LOT was not too harmful to the predators (higher trophic level), but the
availability of the forage resources potentially led to determine the sustainability of the LOT.
page 44 of 120
Figure 16. The food web in the pelagic ecosystem of CNP as reference (Hinke et al., 2004)
Hinke et al., (2004), stated that the impact of the purse seine fisheries have had the
strongest effects in upper trophic level in Central North Pacific (CNP), but that lower trophic levels
may respond more strongly to purse seine fisheries. In the South China Sea, small-pelagic fisheries
are one of target commodities, part of important components of the marine ecosystem and
pelagic fishery resources.
The lack of information on the LOT to represent their position within associated fisheries
in the pelagic-environment and how it is impacted by the unwanted species (as bycatch) raises
doubts that key ecosystem elements are unaffected by existing fishing activities. Furthermore,
the analysis to understand and to account the important roles of LOT and the impact of the fishery
to the pelagic ecosystem within the ECPM waters needed to discover the relationship among
them. Moreover, Figure 17 showed there was uncertainty that those operations were consistent.
The absence of management measures (design, implementation, and evaluation) to

prevent ecosystem structure and function from irreversible harm by purse seine fishing in ECPM
waters has become a challenge. Indicating insufficient information for the ecosystem to
understand the component functions, the authorities did not yet prioritise the ecosystem's system
other than regulating the thing above the waters. The existing condition made some of the
indicators under this circumstance going to fail.
PI 2.1.1 - Primary Species Outcome
PI 2.1.1 The UoA aims to maintain primary species above the point where recruitment would be impaired
page 45 of 120
(PRI) and does not hinder recovery of primary species if they are below the PRI
Main primary species stock status
Main primary species are

highly likely to be above the
Main primary species are PRI.
likely to be above the PRI.
OR
OR There is a high degree of
If the species is below the certainty that main primary
Guidepost If the species is below the PRI, there is either evidence of species are above the PRI and
PRI, the UoA has measures in recovery or a demonstrably are fluctuating around a level
place that are expected to effective strategy in place consistent with MSY.
ensure that the UoA does not between all MSC UoAs which
hinder recovery and categorise this species as
rebuilding. main, to ensure that they
collectively do not hinder
recovery and rebuilding.
Rationale N/A
Draft Scoring ≥80

Range
Information Pass by default

Gap Indicator
Data-Deficient? N/A
PI 2.1.2 - Primary Species Management Strategy
There is a strategy in place that is designed to maintain or to not hinder rebuilding of primary
PI 2.1.2 species, and the UoA regularly reviews and implements measures, as appropriate, to minimise
the mortality of unwanted catch
Management strategy in place
There is a partial strategy in

There are measures in place
place for the UoA, if
for the UoA, if necessary, that
necessary, that is expected to
are expected to maintain or to There is a strategy in place for
maintain or to not hinder
Guidepost not hinder rebuilding of the the UoA for managing main
rebuilding of the main primary
main primary species at/to and minor primary species.
species at/to levels which are
levels which are likely to be
highly likely to be above the
above the PRI.
PRI.
page 46 of 120
Rationale N/A
Management strategy evaluation
There is some objective basis

The measures are considered Testing supports high
for confidence that the
likely to work, based on confidence that the partial
measures/partial strategy will
plausible arguments (e.g. strategy/strategy will work,
Guidepost work, based on some
general experience, theory or based on information directly
information directly about the
comparison with similar about the fishery and/or
fishery and/or species
fisheries/species). species involved.
involved.
Rationale N/A
Management strategy implementation
There is clear evidence that

the partial strategy/strategy is
There is some evidence that
being implemented
the measures/partial strategy
Guidepost successfully and is achieving
is being implemented
its overall objective as set out
successfully.
in scoring issue Management
Strategy in Place.
Met? Not Relevant Not Relevant
Rationale N/A
Shark finning

It is likely that shark finning is It is highly likely that shark
Guidepost certainty that shark finning is
not taking place. finning is not taking place.
not taking place.
Rationale N/A
Review of alternative measures

There is a review of the
potential effectiveness and
practicality of alternative
measures to minimise measures to minimise
Guidepost measures to minimise
UoA-related mortality of UoA-related mortality of
UoA-related mortality of
unwanted catch of main unwanted catch of all primary
unwanted catch of main
primary species and they are species, and they are
primary species.
Rationale N/A
page 47 of 120
Draft Scoring ≥80
Range

Gap Indicator
PI 2.1.3 - Primary Species Information
Information on the nature and extent of primary species is adequate to determine the risk posed
PI 2.1.3
by the UoA and the effectiveness of the strategy to manage primary species
Information adequacy for assessment of impact on main primary species
Some quantitative
Qualitative information is
information is available and is
adequate to estimate the
adequate to assess the
impact of the UoA on the
main primary species with
main primary species with
respect to status.
respect to status. Quantitative information is
available and is adequate to
OR
OR assess with a high degree of
Guidepost
certainty the impact of the
If RBF is used to score PI
If RBF is used to score PI UoA on main primary species
2.1.1 for the UoA:
2.1.1 for the UoA: with respect to status.
Some quantitative
adequate to estimate
information is adequate to
productivity and susceptibility
assess productivity and
attributes for main primary
susceptibility attributes for
species.
main primary species.
Rationale N/A
Information adequacy for assessment of impact on minor primary species
Some quantitative
Guidepost estimate the impact of the
UoA on minor primary species
with respect to status.
Met? Not Relevant
Rationale N/A
Information adequacy for management strategy
Information is adequate to Information is adequate to

Information is adequate to
support a partial strategy to support a strategy to manage
Guidepost support measures to manage
manage main primary all primary species and
main primary species.
species. evaluate with a high degree of
page 48 of 120
certainty whether the strategy
is achieving its objective.
Rationale N/A
Draft Scoring ≥80

Range

Gap Indicator
PI 2.2.1 - Secondary Species Outcome
The UoA aims to maintain secondary species above a biologically based limit and does not
PI 2.2.1
hinder recovery of secondary species if they are below a biological based limit
Direct effects
Main secondary species are

highly likely to be above
biologically based limits.
OR
If below biologically based

limits, there is either evidence
Main secondary species are
of recovery or a demonstrably
likely to be above biologically
effective partial strategy in
based limits.
place such that the UoA does
not hinder recovery and There is a high degree of
OR
rebuilding. certainty that main secondary
Guidepost
AND species are above biologically
Where catches of a main based limits.
limits, there are measures in
secondary species outside of
place expected to ensure that
biological limits are
the UoA does not hinder
considerable, there is either
evidence of recovery or a
demonstrably effective
strategy in place between
those MSC UoAs that have
considerable catches of the
species, to ensure that they
collectively do not hinder
Met? Yes No No
page 49 of 120
KAW stock in South China Sea waters indicated highly likely in the safe stock
(2013 and 2018 data), current catch is higher than the MSY level in 2018.
Rationale
The exploitation rate (E=F/Z) of Decapterus macrosoma, and Decapterus
maruadsi in Malaysia (landed in Tok Bali) in the range of 0.59 - 0.75 (2003 and
2005 data). Data limited, and no specific management is in place.
Minor secondary species stock status
Minor secondary species are

highly likely to be above
biologically based limits.
OR
Guidepost
limits’, there is evidence that
the UoA does not hinder the
recovery and rebuilding of
secondary species
Met? No
The exploitation rate (E=F/Z) Rastrelliger kanagurta 2003-2005 and 2016-2020

in a row: 0.65 and o.64.
Rationale
There is no exploitation rate information about the rest of minor secondary
species found. Data limited, and no specific management is in place.
Draft Scoring <60

Range
The LOT purse seine fishing in the ECPM waters firmly indicated multispecies
catches, dominated by scad, LOT, KAW, FRI, low value and unwanted catch
Information (small pelagic fishes), even the C2 - LOT purse seiners tend to be dominated by
Gap Indicator the neritic tuna species. Unfortunately, not all species are clearly defined at the
UoA. Due to lack of adequate data, PSA applied in this circumstance (fail, <60)
(page 95 -107). SG 60-79 is not met.
Yes, refer to page 95-107 to Table 14 for secondary species assessment via
Data-Deficient?
PSA.
PI 2.2.2 - Secondary Species Management Strategy
There is a strategy in place for managing secondary species that is designed to maintain or to
PI 2.2.2 not hinder rebuilding of secondary species and the UoA regularly reviews and implements
measures, as appropriate, to minimise the mortality of unwanted catch.
page 50 of 120
There are measures in place, There is a partial strategy in

if necessary, which are place, if necessary, for the
expected to maintain or not UoA that is expected to
hinder rebuilding of main maintain or not hinder
There is a strategy in place for
secondary species at/to rebuilding of main secondary
Guidepost the UoA for managing main
levels which are highly likely species at/to levels which are
and minor secondary species.
to be above biologically based highly likely to be above
limits or to ensure that the biologically based limits or to
UoA does not hinder their ensure that the UoA does not
recovery. hinder their recovery.
Met? No No No
Rationale Partial strategy and measure is not in place.

measures/partial strategy will
plausible arguments (e.g. strategy/strategy will work,
Guidepost work, based on some
comparison with similar about the fishery and/or
fishery and/or species
fisheries/species). species involved.
involved.
Met? No No No
Rationale No management strategy evaluation applied.

being implemented
its objective as set out in
successfully.
scoring issue Management
Strategy in Place.
Met? No No
Rationale No management strategy implementation applied.
Shark finning

It is likely that shark finning is It is highly likely that shark
Guidepost certainty that shark finning is
not taking place. finning is not taking place.
not taking place.
Rationale N/A
Review of alternative measures to minimise mortality of unwanted catch
page 51 of 120
There is a review of the the potential effectiveness the potential effectiveness
potential effectiveness and and practicality of alternative and practicality of alternative
practicality of alternative measures to minimise measures to minimise
Guidepost measures to minimise UoA-related mortality of UoA-related mortality of
UoA-related mortality of unwanted catch of main unwanted catch of all
unwanted catch of main secondary species and they secondary species, and they
secondary species. are implemented as are implemented, as
appropriate. appropriate.
Rationale N/A
Draft Scoring <60

Range
Information The secondary species management and strategy is not in place. SG 60-79 is
Gap Indicator not met.
PI 2.2.3 - Secondary Species Information
Information on the nature and amount of secondary species taken is adequate to determine the
PI 2.1.3
risk posed by the UoA and the effectiveness of the strategy to manage secondary species
Information adequacy for assessment of impact on main primary species
Some quantitative
adequate to assess the
main secondary species with
main secondary species with
respect to status. Quantitative information is
respect to status.
available and is adequate to
OR assess with a high degree of
OR
Guidepost certainty the impact of the
If RBF is used to score PI UoA on main secondary
2.2.1 for the UoA: species with respect to
2.2.1 for the UoA:
Qualitative information is status.
Some quantitative
attributes for main secondary
species.
main secondary species.
Met? Yes Yes No
Rationale Some information and data (both qualitative & quantitative) of the main
page 52 of 120
secondary species is available to assess productivity and susceptibility
attributes, by giving the status of the fisheries, e.g. biological parameters,
distribution, etc. However some species are not defined well. There is
uncertainty with the data to be considered for the partial strategy actions
within UoA.
Information adequacy for assessment of impact on minor primary species
Some quantitative
estimate the impact of the
Guidepost
UoA on minor secondary
species with respect to
status.
Met? No
Some quantitative information and data about minor secondary species

(Rastrelliger kanagurta) is available to give an understanding and estimation of
Rationale
the impact of LOT fishery within UoA, but the other minor secondary species is
unwell known.
Information is adequate to support a strategy to manage
support a partial strategy to all secondary species and
Guidepost support measures to manage
manage main secondary evaluate with a high degree of
main secondary species.
species. certainty whether the strategy
is achieving its objective.
Met? Yes No No
The existing data and information about the secondary species impacted are
less to support the partial strategy to maintain the main secondary species
Rationale
within the LOT fishery, including consideration for strategy review and
evaluation.
Draft Scoring 60-79

Range
Some and/or partial data and information about the secondary species is
Information available but likely not adequate to estimate the impact of the LOT purse seine
Gap Indicator fishery for the bycatch, both retained or unwanted fishes, as well as its
changes in every season and periode. SG 100 is not met.
PI 2.3.1 - ETP Species Outcome
● The UoA meets national and international requirements for the protection of ETP
PI 2.3.1
species
page 53 of 120
● The UoA does not hinder recovery of ETP species
Effects of the UoA on population/stock within national or international limits, where applicable
Where national and/or Where national and/or Where national and/or

international requirements set international requirements set international requirements set
limits for ETP species, the limits for ETP species, the limits for ETP species, there is
Guidepost effects of the UoA on the combined effects of the MSC a high degree of certainty that
population/ stock are known UoAs on the population the combined effects of the
and likely to be within these /stock are known and highly MSC UoAs are within these
limits. likely to be within these limits. limits.
Met? Yes No No
The status of ETP species identified in the UoA: Dermochelys coriacea,

Lepidochelys olivacea, Chelonia mydas, Eretmochelys imbricata and Tursiops
truncatus clearly defined trough IUCN red list species. All of them are involved
as prohibited species in Malaysia, even the data and information about their
Rationale stock are rarely found, moreover for Dermochelys coriacea and Tursiops
truncatus. Based on the anecdotal information shows that their stock to be
within the limits. The existing MSC does not really show that these ETP
species are well-monitored and maintained. Therefore, PSA (page 110-114)
used to assess this indicator.
Direct effects

Known direct effects of the Direct effects of the UoA are confidence that there are no
Guidepost UoA are likely to not hinder highly likely to not hinder significant detrimental direct
recovery of ETP species. recovery of ETP species. effects of the UoA on ETP
species.
Met? Yes No No
The existing information is likely that the LOT fishery impacts in the UoA do
Rationale not hinder ETP species recovery. Adequate information to cover these
indicators is needed.
Indirect effects
Indirect effects have been There is a high degree of

considered for the UoA and confidence that there are no
Guidepost are thought to be highly likely significant detrimental
to not create unacceptable indirect effects of the UoA on
impacts. ETP species.
Met? No No
Indirect effects within UoA to create unacceptable impacts are unidentified, in

Rationale accordance with the lack of data to represent the impact of the LOT fishing in
the UoA for the ETP species.
page 54 of 120
Draft Scoring <60
Range
Anecdotal information indicates that interactions of the fishing gear with ETP
biota rarely happens, but this findings has not been supported with sufficient
Information
data to ascertain the fishery does not hinder recovery of ETP species.
Gap Indicator
Therefore, PSA used to address this performance indicator (fail, <60) (page
110 - 114). SG 60-79 is not met.
Data-Deficient? Yes, refer to Table 15 for ETP assessment via PSA (page 110-114)
PI 2.3.2 - ETP Species Management Strategy
The UoA has in place precautionary management strategies designed to:

● Meet national and international requirements.
● Ensure the UoA does not hinder recovery of ETP species.
PI 2.3.2
Also, the UoA regularly reviews and implements measures, as appropriate, to minimise the
mortality of ETP species
Management strategy in place (national and international requirements)
There is a strategy in place for There is a comprehensive

There are measures in place managing the UoA’s impact strategy in place for
that minimise the UoA-related on ETP species, including managing the UoA’s impact
mortality of ETP species, and measures to minimise on ETP species, including
Guidepost are expected to be highly mortality, which is designed measures to minimise
likely to achieve national and to be highly likely to achieve mortality, which is designed
international requirements for national and international to achieve above national and
the protection of ETP species. requirements for the international requirements for
protection of ETP species. the protection of ETP species.
Met? No No No
Sea Turtle species found in the fishing area are protected under the Fisheries
Act 1985. Sea Turtles are also protected under various Conventions, national
and international laws, treaties, agreements, and memoranda of
understanding. However Tursiops aduncus, the specific conservation actions
Rationale
for this species are lacking from most of the range of the species although
they are generally legally protected in most range states. Unfortunately, there
was no management strategy to ensure the reduction of these species from
being caught.
Management strategy in place (alternative)
There are measures in place There is a strategy in place There is a comprehensive

that are expected to ensure that is expected to ensure the strategy in place for
Guidepost
the UoA does not hinder the UoA does not hinder the managing ETP species, to
recovery of ETP species. recovery of ETP species. ensure the UoA does not
page 55 of 120
hinder the recovery of ETP
species.
Met? No No No
No alternative measure and partial strategy was identified to avoid ETP

species to be caught, for example, turtle excluder device installation, sonar
Rationale
application during fishing, which prioritises targets to identify areas that are
abundant with LOT, etc.

The measures are considered There is an objective basis for
the strategy / comprehensive
likely to work, based on confidence that the measures
strategy is being implemented
plausible arguments (e.g. / strategy will work, based on
general experience, theory or information directly about the
comparison with similar fishery and/or the species
fisheries/species). involved.
Strategy in Place.
Met? No No No
There is no management evaluation to measure compliance with ETP catch

Rationale
mitigation within UoA.

the strategy / comprehensive
strategy is being implemented
the measures/strategy is
being implemented
successfully.
Strategy in Place.
Met? No No
Evidence to measure the strategy implementation of ETP species within the

Rationale
LOT fishery is not in place.
Review of alternative measures to minimise mortality of ETP species

There is a review of the
potential effectiveness and
practicality of alternative
Guidepost measures to minimise measures to minimise
measures to minimise
UoA-related mortality of ETP UoA-related mortality ETP
UoA-related mortality of ETP
species and they are species, and they are
species.
Met? No No No
The review of potential effectiveness and/or alternative measures

Rationale implementation to maintain the mortality of ETP species within the LOT fishery
is not in place.
page 56 of 120
Draft Scoring <60
Range
ETP species found in the fishing ground of the UoA are protected by the
Fisheries Act 1985, except for Tursiops aduncus. There is a Regional and
Information
National Plan of Action for ETP marine species conservation in the region.
Gap Indicator
Unfortunately, the adequate information or report as evidence that ETP species
management in place is unavailable. SG 60-79 is not met.
PI 2.3.3 ETP Species Information
Relevant information is collected to support the management of UoA impacts on ETP species,
including:
PI 2.3.3 ● Information for the development of the management strategy;
● Information to assess the effectiveness of the management strategy; and
● Information to determine the outcome status of ETP species
Information adequacy for assessment of impacts
Some quantitative
assess the UoA related
mortality and impact and to
adequate to estimate the UoA
determine whether the UoA
related mortality on ETP
may be a threat to protection Quantitative information is
species.
and recovery of the ETP available to assess with a
species. high degree of certainty the
OR
magnitude of UoA-related
Guidepost
OR impacts, mortalities and
injuries and the
2.3.1 for the UoA:
If RBF is used to score PI consequences for the status
2.3.1 for the UoA: of ETP species.
Some quantitative
attributes for ETP species.
ETP species.
Met? Yes Yes No
The reference used to cover the productivity and susceptibility attribute for
ETP species collected from previous research and biological information both
Rationale qualitative and quantitative data. However not all attributes are well known, i.e.
availability and accountability of ETP species to the LOT fishing activities
within UoA.
Information is adequate to Information is adequate to Information is adequate to

Guidepost support measures to manage measure trends and support a support a comprehensive
the impacts on ETP species. strategy to manage impacts strategy to manage impacts,
page 57 of 120
on ETP species. minimise mortality and injury
of ETP species, and evaluate
with a high degree of certainty
whether a strategy is
achieving its objectives.
Met? No No No
Lack of data to describe the impact of the LOT fishing for the ETP species.
Several information available but not comprehensively define their habit,
Rationale
migration pathways, and the probability caught by the purse seine, including
the evidence of ETP handling/treatment on board.
Draft Scoring <60

Range
There is no clear information to assess the ETP caught and their mortality
Information
whether the fishery is potentially a threat to recovery of the ETP species in the
Gap Indicator
region. SG 60-79 is not met.
PI 2.4.1 - Habitats Outcome
The UoA does not cause serious or irreversible harm to habitat structure and function,
PI 2.4.1 considered on the basis of the area covered by the governance body(s) responsible for fisheries
management in the area(s) where the UoA operates
Commonly encountered habitat status

The UoA is unlikely to reduce The UoA is highly unlikely to
UoA is highly unlikely to
structure and function of the reduce structure and function
reduce structure and function
commonly encountered of the commonly encountered
Guidepost of the commonly encountered
habitats to a point where habitats to a point where
habitats to a point where
there would be serious or there would be serious or
there would be serious or
irreversible harm. irreversible harm.
irreversible harm.
Met? Yes Yes Yes
The purse seine fishing in Tok Bali and surrounding water operates in an
inner-shelf zone without interaction with the sea bed. No irreversible harm
Rationale which was caused by the fishery, nor required specific management strategy
and information or monitoring. The fishery is default ≥80 passes (CSA score:
93, low risk/ pass)(page 115).
Vulnerable Marine Ecosystem (VME) habitat status
page 58 of 120
The UoA is unlikely to reduce The UoA is highly unlikely to
structure and function of the reduce structure and function
Guidepost VME habitats to a point where of the VME habitats to a point
of the VME habitats to a point
there would be serious or where there would be serious
where there would be serious
irreversible harm. or irreversible harm.
or irreversible harm.
Met? Yes Yes Yes
Rationale The fishery is default ≥80 passes.
Minor habitat status

Guidepost
of the minor habitats to a
point where there would be
serious or irreversible harm.
Met? Yes
Rationale The fishery is default ≥80 passes.
Draft Scoring ≥80

Range

Gap Indicator
Data-Deficient? Yes (CSA score: 93, low risk/ pass) (page 115)
PI 2.4.2 Habitats Management Strategy
There is a strategy in place that is designed to ensure the UoA does not pose a risk of serious or
PI 2.4.2
irreversible harm to the habitats
There are measures in place, There is a partial strategy in

There is a strategy in place for
if necessary, that are place, if necessary, that is
managing the impact of all
Guidepost expected to achieve the expected to achieve the
MSC UoAs/non-MSC fisheries
Habitat Outcome 80 level of Habitat Outcome 80 level of
on habitats.
performance. performance or above.
Met? Yes Yes Yes
There is no interaction between the fishing gear (purse seine) with the sea bed.
Rationale The CSA (page 115) used in this circumstance showed that its operation has a
low-risk impact on the habitat.
page 59 of 120
The measures are considered There is some objective basis Testing supports high
likely to work, based on for confidence that the confidence that the partial
plausible arguments (e.g. measures/partial strategy will strategy/strategy will work,
Guidepost
general experience, theory or work, based on information based on information directly
comparison with similar directly about the UoA and/or about the UoA and/or habitats
UoAs/habitats). habitats involved. involved.
Met? Yes Yes Yes
There is clear quantitative

evidence that the partial
There is some quantitative
strategy/strategy is being
evidence that the
implemented successfully
Guidepost measures/partial strategy is
and is achieving its objective,
being implemented
as outlined in scoring issue
successfully.
Management Strategy in
Place.
Met? Not Relevant Not Relevant
Compliance with management requirements and other MSC UoAs’/non-MSC fisheries’

measures to protect VMEs
There is some quantitative There is clear quantitative

evidence that the UoA evidence that the UoA
There is qualitative evidence complies with both its complies with both its
that the UoA complies with its management requirements management requirements
Guidepost
management requirements to and with protection measures and with protection measures
protect VMEs. afforded to VMEs by other afforded to VMEs by other
MSC UoAs/non-MSC MSC UoAs/non-MSC
fisheries, where relevant. fisheries, where relevant.
Met? NA NA NA
Rationale There is no VME identified within UoA
Draft Scoring ≥80

Range

Gap Indicator
page 60 of 120
PI 2.4.3 - Habitats Information
Information is adequate to determine the risk posed to the habitat by the UoA and the
PI 2.4.3
effectiveness of the strategy to manage impacts on the habitat
Information quality
The nature, distribution and

vulnerability of the main
The types and distribution of habitats in the UoA area are
the main habitats are broadly known at a level of detail
understood. relevant to the scale and
intensity of the UoA.
The distribution of all habitats
OR
is known over their range, with
OR
Guidepost particular attention to the
If CSA is used to score PI
occurrence of vulnerable
2.4.1 for the UoA: If CSA is used to score PI
habitats.
Qualitative information is 2.4.1 for the UoA:
adequate to estimate the Some quantitative
types and distribution of the information is available and is
main habitats. adequate to estimate the
types and distribution of the
main habitats.
Met? Yes Yes Yes
Information adequacy for assessment of impacts
allow for identification of the
main impacts of the UoA on
broadly understand the nature
the main habitats, and there is
of the main impacts of gear
reliable information on the
use on the main habitats,
spatial extent of interaction
including spatial overlap of
and on the timing and
habitat with fishing gear.
location of use of the fishing
gear.
OR The physical impacts of the
Guidepost gear on all habitats have been
OR
If CSA is used to score PI quantified fully.
2.4.1 for the UoA:
If CSA is used to score PI
2.4.1 for the UoA:
Some quantitative
consequence and spatial
attributes of the main
habitats.
consequence and spatial
attributes of the main
habitats.
page 61 of 120
Met? Yes Yes Yes
Monitoring
Adequate information
Changes in all habitat
continues to be collected to
Guidepost distributions over time are
detect any increase in risk to
measured.
the main habitats.
Met? Yes Yes
Draft Scoring ≥80

Range

Gap Indicator
PI 2.5.1 - Ecosystem Outcome
The UoA does not cause serious or irreversible harm to the key elements underlying ecosystem
PI 2.5.1
structure and function
Ecosystem status

The UoA is unlikely to disrupt The UoA is highly unlikely to
the key elements underlying disrupt the key elements
disrupt the key elements
ecosystem structure and underlying ecosystem
Guidepost underlying ecosystem
function to a point where structure and function to a
structure and function to a
there would be serious or point where there would be
point where there would be
irreversible harm. serious or irreversible harm.
serious or irreversible harm.
Met? No No No
Rationale SICA (page 116) applied to this indicator.
Draft Scoring <60

Range
page 62 of 120
The lack of information on the LOT to represent their position within the food
web in the pelagic ecosystem raises doubts that key ecosystem elements are
Information
unaffected by existing fishing activities. SICA used in this circumstance (fail,
Gap Indicator
<60), due to potential high-risk for functional group composition (page 116).
SG 60-79 is not met.
Yes
Data-Deficient?
PI 2.5.2 - Ecosystem Management Strategy
There are measures in place to ensure the UoA does not pose a risk of serious or irreversible
PI 2.5.2
harm to ecosystem structure and function
There is a partial strategy in

place, if necessary, which There is a strategy that
There are measures in place, takes into account available consists of a plan, in place
if necessary, which take into information and is expected which contains measures to
Guidepost account the potential impacts to restrain impacts of the UoA address all main impacts of
of the UoA on key elements of on the ecosystem so as to the UoA on the ecosystem,
the ecosystem. achieve the Ecosystem and at least some of these
Outcome 80 level of measures are in place.
performance.
Met? No No No
Rationale Management strategy is not in place.

measures/ partial strategy
plausible arguments (e.g. strategy/ strategy will work,
Guidepost will work, based on some
comparison with similar about the UoA and/or
UoA and/or the ecosystem
UoAs/ ecosystems). ecosystem involved.
involved.
Met? No No No
Rationale Management strategy evaluation is not in place.

Guidepost being implemented
successfully and is achieving
successfully.
page 63 of 120
scoring issue (a).
Met? No No
Rationale Management strategy implementation is not in place.
Draft Scoring <60

Range
The management measures (design, implementation, and evaluation) to

Information
prevent ecosystem structure and function from irreversible harm by
Gap Indicator
purse-seine fishing in ECPM waters is not in place. SG 60-79 is not met.
PI 2.5.3 - Ecosystem Information
PI 2.5.3 There is adequate knowledge of the impacts of the UoA on the ecosystem
Information quality
Information is adequate to Information is adequate to

Guidepost identify the key elements of broadly understand the key
the ecosystem. elements of the ecosystem.
Met? No No
Lack of information and evidence on the relation of LOT with other associate
fishes in the ecosystem. This also includes how to make sure the anchovy as
Rationale
the main diet for the neritic-pelagic food web can be maintained, in
accordance with the highly likely their fishing ground are overlapped.
Investigation of UoA impacts
Main impacts of the UoA on Main impacts of the UoA on

Main interactions between the
these key ecosystem these key ecosystem
UoA and these ecosystem
elements can be inferred from elements can be inferred from
Guidepost elements can be inferred from
existing information, but have existing information, and
existing information, and have
not been investigated in some have been investigated
been investigated in detail.
detail. in detail.
Met? No No No
Lack of information to convince the impact of the UoA on the key elements of
Rationale
the ecosystem that clearly investigated.
Understanding of component functions
The main functions of the The impacts of the UoA on P1

Guidepost components (i.e. P1 target target species, primary,
species, primary, secondary secondary and ETP species
page 64 of 120
and ETP species and and Habitats are identified
Habitats) in the ecosystem and the main functions of
are known. these components in the
ecosystem are understood.
Met? No No
The existing conditions showed information deficiencies in the main function

Rationale
of the component species in the neritic-pelagic waters/ecosystem are known.
Information relevance
Adequate information is Adequate information is

available on the impacts of available on the impacts of
the UoA on these the UoA on the components
Guidepost
components to allow some of and elements to allow the
the main consequences for main consequences for the
the ecosystem to be inferred. ecosystem to be inferred.
Met? No No
The existing information showed indication of the fishing impact to the

ecosystem due to this fishery as multispecies fisheries. None of adequate
Rationale
information generated to make sure of the main consequence for the
ecosystem to be inferred.
Monitoring
Adequate data continue to be
support the development of
Guidepost collected to detect any
strategies to manage
increase in risk level.
ecosystem impacts.
Met? No No
Adequate data collected is unavailable to determine the function of each

Rationale
species component in the ecosystem and the potential risk generated.
Draft Scoring <60

Range
Sufficient data is unavailable for the ecosystem as impact of the fishing,

Information
including the information on key elements, impact on UoA, and component
Gap Indicator
functions, to detect any risk to be inferred. SG 60-79 is not met.
page 65 of 120
PRINCIPLE 3
page 66 of 120
Background
Legal and/or Customary Framework
The distribution of LOT is concentrated in the tropical neritic zone, the shallow part of the
sea along the coast, above the continental shelf which is abundantly found in Indo - West Pacific
Waters including the economic zones and sub-regional marine waters of Southeast Asia
(fishofaustralia.net.au, 2023; and Siriraksophon, 2017). The status of this fishery is important to
discover as the utilisation rate of this species is inclining over the years, exploited by small-scale
commercial and artisanal fishing and generating revenues for the Southeast Asia countries and
providing important protein sources for domestic consumption (Siriraksophon, 2017; Griffiths et
al., 2020). The neritic tuna contributed of 4.5% Malaysia’s total marine fish landings in 2018. They
are mostly targeted by purse-seiner in zone C-C2 and constitute a significant portion of
multispecies fisheries for small neritic tuna, i.e. mackerel tuna/ KAW (Euthynus affinis); frigate
tuna/ FRI (Auzis thazarad), etc (Griffith et al., 2010). This fishing activity led to the resilience of
fishing pressure for this species to the level of medium (minimum population doubling time 1.4 -
4.4 years) and the vulnerability to extinction is moderate to high vulnerability (Fishebase, 2023).
Unfortunately, the existing catch-data for this species is not convincing to establish the
adequate stock status, moreover, the understanding of this fishery is underestimated, full of
uncertainty, even predicted to overfishing and overfished (Griffiths et al., 2020; asiapachfish.org,
2023) (as stated in the first chapter/stock status). Since LOT is regarded as a single unit stock for
Indo Pacific Ocean region (Willey et al., 2016; Griffiths et al., 2020; Ghani & Asmat, 2022) and
highly-likely transboundary occurs within the fishery (Siriraksophon, 2017), its management
needs to be considered at the regional level or UoA. Figure 17 strengthened the indication, by
showing the trajectory of the purse-seiner vessels that landed in Tok Bali (2013) which
concentrated in four fishing grounds spotted in grey circle (A), and the distribution of the vessels in
the ECPM which operated around C-C2 zone in 2018 (B). It assumed some of the vessels were
moving close and/or over the borderline of EEZ of Malaysia into Thailand waters.
The targeted fishing ground (zone C-C2), ECPM waters is part of South China Sea, Western
and Central Pacific Fisheries Commission (WCPFC), but at the moment, WCPFC has not covered
LOT as focus of work in this region. It is implied that the stock status and management of LOT in
the WCPFC region is absent (Kasim et al., 2020; WCPFC, 2023). The reason is WCPFC does not
consider LOT as a highly migratory species (referred to Annex I lists, UNCLOS 1982). In contrast
with WCPFC, the action for LOT management in the Indian Ocean is seen by pointing out the status
stock of LOT in the Indian Ocean in 2020, moreover, advice for the management is available (IOTC,
2022).
page 67 of 120
A
page 68 of 120
C
Figure 17. A) The purse-seiner of Tok Bali trajectory in 2013; B) The distribution of purse-seiner
fishing vessels in zone C & C2, ECPM in 2018 (Harlyan et al., 2021), and; C) Malaysia fishing zone
(Piah et al., 2018).
Table 9 shows the categorization of every fishing zone in Malaysia.
Table 9. The classification of the fishing zone and utilisation in Malaysia waters.
Zone A
Category Zone B Zone C Zone C2 Zone C3
(No-take-zone)
Commercial
Marine Park Commercial Commercial Commercial
fisheries (Tuna
(Only artisanal fisheries fisheries fisheries
Purpose longliners and
fisheries (Trawlers and (Trawlers and (Trawlers and
tuna purse
allowed) Purse seiners) Purse seiners) Purse seiners)
seiners)
Must be on
Does not have to Does not have to Does not have to Does not have to
Ownership board (one
be in the vessel be in the vessel be in the vessel be in the vessel
person owns one
Vessel Size <40 GRT <40 GRT 40 - <70 GRT ≥70 GRT ≥70 GRT
Fishing Area
30 nm - EEZ
(Distance from 0-5 nm 5-12 nm 12 - 30 nm High Seas
Boundary
shore)
page 69 of 120
The SEAFDEC as an autonomous inter-governmental body (based on the Agreement on
Establishing the Southeast Asian Development Center, 1987) established the Scientific Working
Group on Neritic Tuna Stock Assessment in the Southeast Asian Waters in 2014 and subsequently
initiated the Regional Plan of Action (RPOA) in 2015 as sustainable management framework of
neritic tuna in the region covering Sulu Sulawesi Sea, Andaman Sea, South China Sea and Gulf of
Thailand (Siriraksophon, 2017; asiapachfish.org, 2023; Griffiths et al., 2020). The objectives of
RPOA-Neritic Tunas were focused on the improvement of data and information; sustainable
fisheries management; interaction with marine ecosystems; compliance; social issues; and
regional cooperation (SEAFDEC, 2015). Explicitly, the section of co-management works is still in
the stage of appeal and/or promotion to enhance regional awareness through the ASEAN
Members States (AMSs) - SEAFDEC council mechanism. At the moment, the development of the
RPOA-Neritic Tunas in 2022 is still focusing on the stock status assessment and complementing
the proxies.
In order for the legal framework in the UoA, Malaysia has a clear legal framework for
fishery management authority under DOF as stated within Fisheries Act 1985 (317). Malaysia
initiated to comply and adopt international fisheries management instruments i.e. 1982 United
Nations Convention on the Law of the Sea (UNCLOS); FAO Code of Conduct Responsible Fisheries
(CCRF), Agreement on Port State Measures to Prevent, Deter and Eliminate Illegal, Unreported, and
Unregulated Fishing (IUU Fishing), which have been embedded in the National Agro-Food Policy
(2011-2020) and the Strategic Plan of the DOF Malaysia (2011-2020). However, due to the LOT
being considered one single stock within the South China Sea, the existence of a national legal
framework and system must have effective cooperation or binding procedure with other parties in
the region, where necessary, to deliver management outcomes consistent with the MSC principle 1
and 2. The absence of LOT as focussed-commodity under WCPFC arising challenges on how to
address and manage the LOT in the UoA. The national legal system in Malaysia and existing
framework initiated by SEAFDEC in ASEAN likely have not been applied effectively to address the
LOT management in the region.
Actually, the legal framework and legal system play key roles as appropriate mechanisms
to the size and scale of the UoA that comply with local, national and international laws toward
responsible and sustainable use of resources. High performing fisheries need to have transparent
dispute resolution mechanisms in the UoA (covering all relevant-jurisdictions) and proven this
mechanism is suitable and effective. None of the information and measures has been
implemented clearly demonstrated that the fishery has an effective multi-lateral management
framework. It’s also shown that the clear Regional Fishery Body (RFB) for neritic tuna
management within the Southeast Asia Waters region doesn't exist. This condition is also
affecting the absence of a legal dispute framework as a mechanism for the resolution in the
region.
Consultation, Roles and Responsibilities
Effective fishery management provides a platform for all the relevant-stakeholders within
the fishery to convey their concerns and sights to the management, and the decision clearly
informs the public, including the reason why it’s agreed and tackled. The stakeholders may include
people and organisations not directly related to fishery activities, but that interact with or have
interest in a fishery.
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Malaysia comprises 13 states and 3 federal territories. Each state has its own written
constitution, legislative assembly, and executive council, which is responsible to the legislative
assembly and headed by a chief minister. In Malaysia, the authority for fisheries management
within the country is under the responsibility of The Ministry of Agriculture and Food Security
(MAFS), through the Director General - Department of Fisheries, Malaysia. They used to collaborate
with several entities under the ministry to develop the fisheries industry in Malaysia, namely
Lembaga Kemajuan Ikan Malaysia (LKIM). To support the implementation of fishery management
within the country, established the representative DOF in every state. The Table 10 below is the list
of related entities to support the LOT fishery management with their clear roles & responsibilities
for fisheries affairs and also other key external stakeholders that have relevant mandate and
functions.
Table 10. The list of relevant stakeholders for LOT fishery management in Malaysia.
No Entity Roles & Responsibilities
1 Ministry of Agriculture and Food To provide any regulations and policies for fisheries
Security (MAFS) governance and management in Malaysia
2 Department of Fisheries (DOF) To be involved in fisheries management,

Malaysia & Tok Bali enforcement and socio-economic development.
Regulating the fishing, licence and vessel licences
(for all fishing zones), as well as protecting the
endangered marine species
3 Lembaga Kemajuan Ikan Malaysia To develop a progressive fishers community to

(LKIM) ensure seafood sustainability via a modern
approach and market exploration
4 Malaysian Maritime To ensure the reduction of illegal, unregulated, and

Enforcement Agency (MMEA) unmonitored (IUU) fishing activities
5 Malaysian Quarantine and Holds export data, which is helpful for the project to
Inspection Services (MAQIS) understand the supply chain details
6 Malaysia Fisheries Research Associated with DOF, to support any research

Institute (FRI) related to the fishery as reference for fisheries
management within the country.
7 East Coast Economic Region Coordinated with the government agencies to

Development Council (ECERDC) implement socio-economic projects in the east
coast region by attracting private investment,
increasing household income, developing
entrepreneurs, and creating job opportunities
8 Southeast Asia Fisheries Independent entity in the regional level concerned to

Development Center (SEAFDEC) promote and facilitate the actions by ensuring the
sustainability of fisheries and aquaculture in
Southeast Asia. The main action is by conducting
fishery research for stock assessment and provide
page 71 of 120
the recommendation for management action
9 Global Ikhwan Sdn Bhd A business company, in Tok Bali, launched a fishery
(GISB) Holdings sector with a key purpose to suffice the local
seafood
supplies
10 Fishers Association Associated with LKIM, a medium for fishers to

(Persatuan Nelayan address their fishery challenges
Kawasan)
11 Thai Exporters Potential parties to engage for lessons learned, or

for business opportunities in order to ensure the
modernisation of the seafood industry aligned with
fishery sustainability for Tok Bali, or for the local
communities’ food security
The clarity of the roles and responsibilities is reflected and specifically defined through the
existence of laws, e.g. LKIM Act 1971; Fisherman’s Act 1974; ZEE Act 1984; Malaysian Maritime
Enforcement Agency Act 2004; Malaysian Quarantine and Inspection Services Act 2011; etc. It is
demonstrated that the roles and responsibilities are explicitly defined, well understood, and in
place for all areas of responsibility and interaction. Toward good governance within the fishery
management, Malaysia has been trying to maximise the function and roles for every division, and
committed to improve their capacity in response to IUU fishing by collaborating with regional
entities, i.e. SEAFDEC, Regional Plan of Action (RPOA) IUU Fishing (South China Sea, Sulu-Sulawesi
Seas and Arafura-Timor Seas) and the Coral Triangle Initiative (CTI) by participating in seminars,
workshops and training to address IUU fishing. Figure 18 below represents the distribution of roles
and functions of Malaysian entities in order to prevent IUU fishing within Malaysia waters.
Notification Received
Department of Fisheries (DOF)
IUU
Vessels
Decision
List from
RPOA,
DOF
State RFMO
DOF websites
Dissemination of Notification /
Information to State DOF / Departments /
Agencies / Port Authorities / Port Operators
DOF
page 72 of 120
Monitoring and Intelligence
Malaysian Maritime Enforcement Agency

(MMEA) / DOF / Royal Malaysia Police (RMP)
/ Marine Department (MD) / Port Authority /
Malaysian Fisheries Development Authority
(LKIM) / Royal Malaysian Custom Department
(RMCD) / Malaysian Quarantine and
Inspection Services Department (MAQIS)
Vessels in Malaysian fisheries

waters/ vessels docked at the ports/ Vessels not docked at the ports/
jetty jetty

Port Operator/ Malaysian Fisheries
Development Authority (LKIM) / Royal
Malaysian Custom Department (RMCD) /
Malaysian Quarantine and Inspection Services
Department (MAQIS)
Law Enforcement

/ Marine Department (MD) / Port Authority / Report to DOF
No further action, Report to RPOA (DOF)

arrest,
investigation,
compound,
prosecution
Malaysian Maritime
Enforcement Agency
(MMEA) / DOF /
Royal Malaysia Police
page 73 of 120
(RMP) / Marine
Department (MD) /
Port Authority /
Malaysian Fisheries
Development
Authority (LKIM) /
Royal Malaysian
Custom Department
(RMCD) / Malaysian
Quarantine and
Inspection Services
Department (MAQIS)
Report to Flag
Report to RPOA State
(DOF) (DOF)/ Marine
Department
Figure 18. Standard Operational Procedure (SOP) for Malaysia’s entities in order to prevent IUU
Fishing within Malaysia waters.
The consultation process within the fishery management DOF provides consultation
sessions with the fisheries actors, including the fishers and vessel owners through Majlis
Perundingan Industri (MPI)/ Industrial consultative council meeting annually. In addition, the
presence of fishers's associations in Malaysia under LKIM coordination and assistance (especially
NEKMAT/Persatuan Nelayan Kebangsaan, and PNN Kelantan-Terengganu or fishers group above)
can ensure the social and economic financial schemes can be accessed by the fishers to improve
their capacity, and to mediate in disputes arising as well. The effectiveness of the consultation
process and the presence of the platform for the key stakeholders within fishery to meet and
consult plays an important role to support inclusivity of the fishery management.
The Malaysian government through LKIM and DOF at the state level frequently give
opportunities to the all/key stakeholders to share their concern and input for the fishery. One of the
important things, how local or customary knowledge can be recognized and considered as part of
fishery management actors. The consultation process provides an opportunity for the fishers or
the community to join the forum. Even some facts show the level of participation of the fishers or
the community (especially the vessel’s owner) within the forum is barely attended due to any
reasons. Even the management system regularly seeks and accepts relevant information from the
stakeholders, including local knowledge of fisheries management. But at the moment, no clear
evidence or measure is documented to prove the consideration of the information obtained and
explained to the public from the consultation process to be applied for the management, SG 100 is
not met.
page 74 of 120
Long Term Objectives
The sustainable fishery resources management long term vision in Malaysia is declared
through provisions of the Fisheries Act 1985 (317) as a legislative framework - amended in 2019
by governing fisheries plans development; licensing provisions; offences; inland waters;
aquaculture; marine parks and reserves; enforcement; and power of the Minister to make
regulations. Fisheries Act 1985/ 317, Part XI, 61 stated “The Minister may make regulations
specifically or generally for the proper conservation, development, and management of maritime and
estuaries fishing and fisheries in Malaysian fisheries waters …” this exhibit that the Minister of
Pertanian and Keterjaminan Makanan (Ministry of Agriculture and Food Security/MAFS) is
authorised to produce any regulation to support the sustainable fishery management within
Malaysia waters. These long term objectives reflected the vision of DOF Malaysia to be the leader
in the transformation of a sustainable and competitive fishery, by proposing strategies to achieve
the main goal for fisheries management within the country, as follows:
a. To develop a dynamic market-based fisheries industry through creative and innovative

approaches.
b. To manage the national fishery resources in an efficient, innovative and environmentally
friendly manner based on scientific information and good governance.
c. To enhance the delivery system through skillful, knowledgeable, and professional human
capital.
This management objective has been dealt with with the National Plan of Action (NPOA)
Fishing Capacity in Malaysia (Plan II). The NPOA Fishing Capacity is focused on the management
of fishing capacity in marine capture fisheries through the implementation of a range of policies
and technical measures aimed at ensuring the desired balance between fishing inputs and outputs
in terms of production (Shaupi et al., 2011). It is in accordance with the mandate of Fisheries Act
1985 (317) to develop the fisheries plan for specific management action. The fisheries plan
should be developed based on the scientific information available and designed to ensure
optimum utilisation of fishery resources, consistent with sound conservation and management
principles and with the avoidance of overfishing, and in accordance with the overall national
policies, development plans and programmes (Fisheries Act 1985/ 317, Part III, 6). By
understanding this, it’s demonstrated the management policy has clear long-term objectives that
guide decision-making, consistent with the MSC Fisheries Standard and the precautionary
approach are explicit within management policy.
Fishery-specific Objectives & Decision Making
Fishery-specific objectives provide directions and are designed around the overarching
national, international or regional goals and policies set by the government for the fishery within
UoA. The fishery-specific management for LOT in the unit stock of South China Sea needs to be
developed for both short term and long term operational targets and must also be explicitly stated.
This management is aiming the LOT stocks probably exploited in a high degree of certainty that
the stock is above the PRI (Point of Recruitment Impairment) by implementing responsive harvest
strategy. Unfortunately, as mentioned in the early section, none of the management action for LOT
is established in the region (UoA).
page 75 of 120
Meanwhile, several action plans to improve the management of LOT in Malaysian waters
were explicitly stated through the strategic action plan/ Fisheries Management Plan (FMP) for
tuna in the early 2010 by DOF Malaysia, this included the neritic tuna management in ECPM.
However this strategic plan is no longer available for access after it ends in 2020. Based on the
written statement by the DOF, at the moment they are also developing the specific neritic tuna
management for ECPM waters. But the detailed information about those previous achievements
and current progress is unavailable, involving: the information about the scope, objectives,
actions, and progress, also how it will be reviewed and monitored. As reference, the SEAFDEC
Country Report - Malaysia (2020), stated the main management goal for the Neritic Tuna FMP
need to be formulated in the region co-management level, due to several constraints identified, as
follows:
● The FMP needs to convince and consent from the fishers;

● SEAFDEC as potential partner is limited only for scientific research and fishery
management recommendation, the management action need to be addressed through
region level (ASEAN);
● Research collaboration to assess the stock under UoA with foreign research institutions
and regional ASEAN/RFMO in getting approval from the National Security Council.
Otherwise, In the region, the Regional Plan Of Action (RPOA) neritic-tuna already
proposed by SEAFDEC in 2015 seems not appropriate to cover LOT stock management within
UoA, due to never having been adopted or implemented and yet focusing on the stock status
assessment and complementing the proxies. Even though the objectives of the management are
defined in the document by focusing on:
● Determining available data and information, improving data collection and developing key
indicators;
● Improving sustainable fisheries management;
● Improving sustainable interaction between fisheries and marine ecosystem;
● Improving compliance to rules and regulations and access to markets;
● Addressing social issues;
In addition, the “Strategic Plan of Tuna Industry Development - South China Sea, Sulu Sea
and Sulawesi Sea 2021 - 2030” by DOF tend to focus on oceanic tuna development and
management, which highly-likely doesn't really address the LOT management that comply with
principle 1 and principle 2 of MSC standard in the Malaysian waters. The specific management
measures for LOT fishery management through adequate harvest strategy and ecosystem
management is clearly not endorsed under the tuna industry development plan.
High criteria for the fishery-specific objective both to be broadly consistent with MSC
principles 1 and 2, or even achieving well-defined and measurable short and long-term
objectives is not met. The absence of specific management action for the LOT fishery in the
region led to the failure of all indicators under fishery-specific objectives and decision-making.
page 76 of 120
Compliance and Enforcement
Monitoring, Control and Surveillance (MCS) is adequate to ensure the management and
conservation measures in a fishery are enforced and complied with, and with IUU fishing is avoided
or minimised. The design of the MCS system will depend upon the scale and nature of the fishery,
also should apply at all relevant jurisdictions of the fishery. In terms of MCS for LOT fishery in
targeted UoA, Malaysia’s Government has developed a plan of actions to combat IUU Fishing
through “Malaysia’s National Plan of Action to Prevent, to Deter an to Eliminate IUU” (Malaysia's
NPOA- IUU).
Figure 18 above has clear roles and functions as Malaysia entities react and prevent IUU
Fishing. This information shows the MCS mechanism exists with clear standard operation
procedures to handle both foreign and local fishing vessels. Nevertheless, by understanding the
vessels operations, the labour composition of the purse seiners in Tok Bali are dominated by
fishers employed from Thailand (90%) and locals for the rest, and VMS implementation seems
unconvincing due to some technical issues, and the problem still was not resolved accordingly
(Ghani & Asmat, 2022). VMS could only be effective for monitoring vessels that are equipped with
the system. Therefore, there is a need for a good surveillance protocol so that the fishing capacity
of vessels not equipped with VMS could also be monitored (Shaupi et al., 2011).
Information in Figure 17 indicates transboundary is exist and there were 3.642 licensed
purse seiners in 2016, with 41.3% operating in the ECPM; West Coast of Peninsular Malaysia
(WCPM) (30.3%); Sabah (24.6%); Sarawak (3.4%); others (0.4%). Dominated with >70 GRT (66.9%)
and 40 - 69.9 GRT (25.2%) (Harlyan et al., 2021). These conditions arising challenges how the
sanctions are consistently applied and how the evidence could provide that the compliance and
enforcement for the fishery-specific management carried out comprehensively in high degree of
confidence. However, the existence has not been effectively demonstrated, due to lack of
evidence.
Wanchana et al., (2016), transboundary fishery between Malaysia - Thailand waters (both
Gulf of Thailand and Andaman Sea) identified three major issues, e.g. dual flagging or registration
or deregistration; landing of catches in the neighbouring countries port; and encroachment foreign
(and national) fishing vessel in the coastal waters. Available MoU Malaysia - Thailand government
should be developed as a priority long-term activity. This would become the official mechanism for
strengthening future cooperation between both countries. At the regional level within South East
Asian region, established regional platform to combat IUU fishing via Regional Plan of Action
(RPOA) IUU in 2007 through joint ministerial agreement, involved: Australia; Brunei Darussalam;
Indonesia; Malaysia; Papua New Guinea; The Philippines; Singapore; Thailand; Timor-Leste; and
Vietnam. The Coordination Committee is a high level decision-making body providing strategic
advice and direction to RPOA member countries. The Committee’s function are:
● Foster an environment of cooperation and collaboration among RPOA member countries;
● Advise on national, sub-regional and regional priorities to guide implementation of the
RPOA;
● Plan RPOA activities, report on implementation of measures and maintain a forward work
agenda;
● Provide strategic oversight and advice on RPOA activities to further develop and implement
responsible fishing practices in the region;
● Monitor, review and advice on the effective implementation of the RPOA;
page 77 of 120
● Report to Fisheries Ministers on the progress of implementation and any additional
measures required for implementation; and
● Communicate with the FAO and other relevant international and regional bodies, as
appropriate;
● Collaborate with international/regional organisations, programs or projects concerned with
fisheries management and sustainable use of fisheries resources in implementing the
RPOA.
The Coordination Committee conducts an annual meeting and it is a high level decision
making body to provide strategic advice and direction to participating countries on coordination
and implementation covering matters such as marine environment conservation, sustainable
management of fisheries resources, managing fishing capacity, building competency in fisheries
management and combating IUU fishing. Minutes of the high panel meeting shared and uploaded
via RPOA website: rpoaiuu.org. In general, the MCS instrument and cooperation both within
Malaysia and in the regional waters are quite complete, however, the quality of the MCS
implementation is important to show how far the system is comprehensive and consistent,
supported by convincing evidence and reports, that the tuna longtail fishery complies with all
regulations. Without this circumstance, the fishery is going to fail.
Monitoring and Management Performance Evaluation
Transparent and accountable fisheries management and good decision-making processes

allow for on-going internal and external evaluation that ensure effective and improving
management performance. The design of the evaluations and reviews should be appropriate to the
cultural context, scale, and intensity of the fishery. In Malaysia, monitoring and management
performance evaluation is mentioned in the National Plan of Action for the Management of Fishing
Capacity in Malaysia (NPOA Fishing Capacity) which was published in 2008 and revised in 2015
(as Plan 2). This NPOA Fishing Capacity Plan 2 is a fulfilment of Malaysia’s commitment towards
Section II, FAO International Plan of Action for the Management of Fishing Capacity
(IPOA-Capacity). The long term objective of this NPOA Plan 2 is for the country to achieve an
efficient, equitable and transparent management of fishing capacity in marine capture fisheries by
2018. This plan reviewed and evaluated the achievements of the first plan. The issues and
challenges in managing fishing capacity, and the strategies to address them, which were listed in
the first plan, were also reviewed.
The NPOA Fishing Capacity Plan 2 emphasised on enhancing monitoring and evaluation on
the action undertaken to manage fishing capacity. Twelve issues and challenges were identified
and three strategies were developed. For each issue, relevant programs have been identified for
implementation, with key performance indicators for future evaluation. A detailed work plan with
timeline and implementing agencies has also been developed. This plan will be monitored and
evaluated by the National Steering Committee which will be established to oversee the
implementation of all national plans of action. This plan will be reviewed after five years. This Plan
2 will focus on twelve issues and challenges which have been identified (DOF, 2015). Based on
these issues, three strategies were developed namely:
● Strategy 1: Review and implement effective conservation measures

● Strategy 2: Strengthen capacity and capability for monitoring and surveillance programmes
page 78 of 120
● Strategy 3: Promote public awareness and education programme
Unfortunately the effectiveness and validity of these strategies have not been clearly
measured (Harlyan et al., 2017), and there is no mechanism for peer review in place, moreover,
evaluation for the fishery-specific management system to cover the update of stock of LOT in the
region, and set the harvest strategy through transparent and comprehensive decision-making is
absent. This goes along with the review and evaluation mechanism for management
performance which currently doesn’t exist.
PI 3.1.1 - Legal and Customary Framework
The management system exists within an appropriate and effective legal and/or customary
framework which ensures that it:
● Is capable of delivering sustainability in the UoA(s);
PI 3.1.1
● Observes the legal rights created explicitly or established by custom of people
dependent on fishing for food or livelihood; and
● Incorporates an appropriate dispute resolution framework
Compatibility of laws or standards with effective management
There is an effective national

There is an effective national There is an effective national
legal system and organised
legal system and a framework legal system and binding
and effective cooperation
for cooperation with other procedures governing
with other parties, where
Guidepost parties, where necessary, to cooperation with other parties
necessary, to deliver
deliver management that deliver management
management outcomes
outcomes consistent with outcomes consistent with
consistent with MSC
MSC Principles 1 and 2. MSC Principles 1 and 2.
Principles 1 and 2.
Met? Yes No No
The legal basis for fisheries management in Malaysia is stated through

Fisheries Act 1985 (317). Since LOT is regarded as a single unit stock for the
Indo Pacific Ocean region (South China Sea) and highly-likely transboundary
occurs within the fishery its management needs to be considered at the
regional level or UoA.
Rationale However, LOT is not under concern of WCPFC, and there is no effective
regional fishery body as a cooperation platform for LOT management in the
South China Sea.
This condition is also affecting the absence of a legal dispute framework as a

mechanism for the resolution in the region.
page 79 of 120
None of the information and measures has been implemented clearly
demonstrated that the fishery has an effective multi-lateral management
framework.
Resolution of disputes
The management system The management system

incorporates or is subject by incorporates or is subject by
The management system law to a transparent law to a transparent
incorporates or is subject by mechanism for the resolution mechanism for the resolution
Guidepost law to a mechanism for the of legal disputes which is of legal disputes, which is
resolution of legal disputes considered to be effective in appropriate to the context of
arising within the system. dealing with most issues and the fishery and has been
that is appropriate to the tested and proven to be
context of the UoA. effective.
Met? Yes No No
Malaysia has clearly legal mechanisms as subjected by law for the dispute
resolution within the fishery, unfortunately it does not support with proper
evidence to point out that this scheme is effective. Moreover the sufficient
Rationale
legal mechanism for the resolution of disputes within the fishery in the region
doesn't exist in accordance with the absence of a regional fishery body as a
platform for fishery management.
Respect for rights
The management system has The management system has

The management system has
a mechanism to generally a mechanism to formally
a mechanism to observe the
respect the legal rights commit to the legal rights
legal rights created explicitly
created explicitly or created explicitly or
or established by custom of
established by custom of established by custom of
Guidepost people dependent on fishing
people dependent on fishing people dependent on fishing
for food or livelihood in a
for food or livelihood in a for food and livelihood in a
manner consistent with the
manner consistent with the manner consistent with the
objectives of MSC Principles
objectives of MSC Principles objectives of MSC Principles
1 and 2.
1 and 2. 1 and 2.
Met? Yes Yes Yes
The Malaysian government has a mechanism to formally commit to the legal

Rationale
rights created explicitly.
Draft Scoring 60-79 (Pass with condition)

Range
Malaysia has a clear legal framework for fishery management authority under
DOF as stated within Fisheries Act 1985 (317). The absence of LOT as
Information
focussed-commodity under WCPFC arising challenges on how to address and
Gap Indicator
manage the LOT in the UoA. The national legal system in Malaysia and existing
framework initiated by SEAFDEC in ASEAN likely have not been applied
page 80 of 120
effectively to address the LOT management in the region. This condition is also
affecting the absence of a legal dispute framework as a mechanism for the
resolution in the region. None of the information and measures has been
implemented demonstrating that the fishery has an effective multi-lateral
management framework. SG 100 is not met.
PI 3.1.2 - Consultation, Roles, and Responsibilities
The management system has effective consultation processes that are open to interested and
PI 3.1.2 affected parties. The roles and responsibilities of organisations and individuals who are involved
in the management process are clear and understood by all relevant parties
Roles and responsibilities
Organisations and individuals Organisations and individuals

Organisations and individuals involved in the management involved in the management
involved in the management process have been identified. process have been identified.
process have been identified. Functions, roles, and Functions, roles, and
Guidepost
Functions, roles, and responsibilities are explicitly responsibilities are explicitly
responsibilities are generally defined and well understood defined and well understood
understood. for key areas of responsibility for all areas of responsibility
and interaction. and interaction.
Met? Yes Yes Yes
The roles and responsibilities for every position or entity within Malaysia
government for fisheries affairs demonstrated through any act or ordinance
used as basis or legality for them to execute their function, roles and
responsibilities, e.g. LKIM Act 1971; Fisherman’s Act 1974; ZEE Act 1984;
Malaysian Maritime Enforcement Agency Act 2004; Malaysian Quarantine and
Inspection Services Act 2011; etc
Rationale
It is demonstrated that the roles and responsibilities are explicitly defined and
well understood for all areas of responsibility and interaction. Toward good
governance within the fishery management, Malaysia has been trying to
maximise the function and roles for every division, and committed to improve
their capacity in response to IUU fishing by collaborating with regional entities.
Consultation processes
The management system The management system

The management system includes consultation includes consultation
includes consultation processes that regularly seek processes that regularly seek
processes that obtain relevant and accept relevant and accept relevant
Guidepost information from the main information, including local information, including local
affected parties, including knowledge. The management knowledge. The management
local knowledge, to inform the system demonstrates system demonstrates
management system. consideration of the consideration of the
information obtained. information and explains how
page 81 of 120
it is used or not used.
Met? Yes Yes No
Identified several processes of consultation that happen within the

stakeholder as a platform to gain inputs and concern for the fishery (MPI,
NEKMAT & PNN). The effectiveness of the local knowledge
Rationale
recognised/accepted to support the fisheries management with clear
consideration of the information obtained and explained is not demonstrated,
due to the lack of evidence and inclusivity within the process.
Participation
The consultation process

provides opportunity and
The consultation process
encouragement for all
provides opportunity for all
Guidepost interested and affected
interested and affected
parties to be involved, and
parties to be involved.
facilitates their effective
engagement.
Met? Yes No
The consultation is given opportunity for all of the stakeholders to join the
process, the evidence of how the consultation process is going effectively
Rationale addressing the issue within the fishery management is not clearly
demonstrated, barely an incomplete representative exists from the vessel's
owner, and fishers as consequence of lack of awareness.
Draft Scoring 60-79 (Pass with condition)

Range
The roles and responsibilities for fishery management in Malaysian waters are
explicitly defined, well understood, and in place for all areas of responsibility
and interaction. The consultation process provides an opportunity for the
Information fishers or the community to join the forum through Majlis Perundingan Industri
Gap Indicator (MPI) and fishers association. However, no clear evidence or measure is
documented to prove the consideration of the information obtained and
explained to the public from the consultation process to be applied for the
management. SG 100 is not met.
PI 3.1.3 - Long-Term Objectives
The management policy has clear long-term objectives to guide decision-making that are
PI 3.1.3
consistent with the MSC Fisheries Standard, and incorporates the precautionary approach
Objectives
page 82 of 120
Long-term objectives to guide Clear long-term objectives Clear long-term objectives
decision-making, consistent that guide decision-making, that guide decision-making,
with the MSC Fisheries consistent with the MSC consistent with the MSC
Guidepost Standard and the Fisheries Standard and the Fisheries Standard and the
precautionary approach, are precautionary approach, are precautionary approach, are
implicit within management explicit within management explicit within and required by
policy. policy. management policy.
Met? Yes Yes Yes
The fisheries management of Malaysia has clear long-term objectives

explicitly stated through several acts, mainly Fishery Act 1984 (317) appointed
that the fishery management should be developed and decided based on the
scientific information available consistent with sound conservation and
Rationale management principles and with the avoidance of overfishing, and in
accordance with the overall national policies, development plans and
programmes. This is also in line with the strategic plan of the Department of
Fisheries - Malaysia.
Draft Scoring ≥80

Range
Information No gap found

Gap Indicator
PI 3.2.1 - Fishery-Specific Objectives
The fishery-specific management system has clear, specific objectives designed to achieve the
PI 3.2.1
outcomes expressed by MSC Principles 1 and 2
Objectives
Well-defined and measurable

Short and long-term short- and long-term
Objectives, which are broadly
objectives, which are objectives, which are
consistent with achieving the
consistent with achieving the demonstrably consistent with
outcomes expressed by MSC
Guidepost outcomes expressed by MSC achieving the outcomes
Principles 1 and 2, are implicit
Principles 1 and 2, are explicit expressed by MSC Principles
within the fishery-specific
within the fishery-specific 1 and 2, are explicit within the
management system.
management system. fishery-specific management
system.
Met? No No No
The Fisheries Management Plan (FMP) for tuna (including neritic tuna)
Rationale developed by DOF in early 2010. However this FMP is no longer available for
access after it ends in 2020. Otherwise, currently the DOF is developing the
page 83 of 120
specific neritic tuna management for ECPM waters. The detailed information
about those previous achievements and current progress is unavailable,
involving: the information about the scope, objectives, actions, and progress,
also how it will be reviewed and monitored. In addition, the “Strategic Plan of
Tuna Industry Development - South China Sea, Sulu Sea and Sulawesi Sea
2021 - 2030” by DOF tend to focus on oceanic tuna management, which
highly-likely doesn't really address the LOT management that comply with
principle 1 and principle 2 of MSC standard in the Malaysian waters.
In the regional level, the Regional Plan Of Action (RPOA) neritic-tuna already
proposed by SEAFDEC in 2015 seems not appropriate to cover LOT stock
management within UoA.
Draft Scoring <60

Range
High criteria for the fishery-specific objective both to be broadly consistent

Information
with MSC principles 1 and 2 in the UoA, or even achieving well-defined and
Gap Indicator
measurable short and long-term objectives is not met. SG 100 is not met.
PI 3.2.2 - Decision-Making Processes
The fishery-specific management system includes effective decision-making processes that

PI 3.2.2 result in measures and strategies to achieve the objectives, and has an appropriate approach to
actual disputes in the fishery
Decision-making processes
There are some There are established

decision-making processes in decision-making processes
Guidepost place that result in measures that result in measures and
and strategies to achieve the strategies to achieve the
fishery-specific objectives. fishery-specific objectives.
Met? No No
The decision-making processes to measure and define a strategy to manage

Rationale the LOT in the targeted UoA is not in place, and any management measure
haven’t been established as well
Responsiveness of decision-making processes
Decision-making processes Decision-making processes Decision-making processes

respond to serious issues respond to serious and other respond to all issues
Guidepost identified in relevant research, important issues identified in identified in relevant research,
monitoring, evaluation, and relevant research, monitoring, monitoring, evaluation, and
consultation, in a transparent, evaluation, and consultation, consultation, in a transparent,
page 84 of 120
timely and adaptive manner, in a transparent, timely, and timely, and adaptive manner,
and take some account of the adaptive manner, and take and take account of the wider
wider implications of account of the wider implications of decisions.
decisions. implications of decisions.
Met? No No No
The absence of fishery-specific management by covering the harvest strategy

Rationale and harvest control rules for the LOT in the UoA made no reaction in how the
management authority responded to the changes within the stock.
Use of precautionary approach
Decision-making processes
use the precautionary
Guidepost
approach and are based on
best available information.
Met? No
The precautionary approach for fishery management in Malaysia is explicitly

Rationale stated under Fisheries Act 1985 (317), but the decision-making process of
fishery-specific management measures for LOT is not in place at the moment.
Accountability and transparency of management system and decision-making process
Formal reporting to all

Information on the fishery’s interested stakeholders
performance and provides comprehensive
management action is information on the fishery’s
Some information on the available on request, and performance and
fishery’s performance and explanations are provided for management actions and
Guidepost management action is any actions or lack of action describes how the
generally available on request associated with findings and management system
to stakeholders. relevant recommendations responded to findings and
emerging from research, relevant recommendations
monitoring, evaluation, and emerging from research,
review activity. monitoring, evaluation, and
review activity.
Met? No No No
Accountability and transparency of the management system and

Rationale decision-making process to agree and implement fishery-specific
management systems is not in place.
Approach to disputes
Although the management

authority or fishery may be
The management system or The management system or
subject to continuing court
UoA is attempting to comply UoA acts proactively to avoid
challenges, it is not indicating
Guidepost in a timely fashion with legal disputes or rapidly
a disrespect or defiance of
judicial decisions arising from implements judicial decisions
the law by repeatedly violating
any legal challenges. arising from legal challenges.
the same law or regulation
necessary for the
page 85 of 120
sustainability of the fishery.
Met? Yes No No
Malaysia's legal framework already covers for any laws relevant with dispute
within fishery affairs, involving how the legal instruments to take action
Rationale against any violation of the rules previously agreed upon by the
stakeholders/authority. However, how it demonstrated in the regional level
within UoA is indescribable.
Draft Scoring <60

Range
Fishery-specific management for LOT in the UoA is not in place, a

precautionary approach within the fishery management explicitly endorsed, but
the absence of the RFB in the region level affects the clarity of
Information
appropriate-authority as decision maker to achieving and to agreeing the
Gap Indicator
management objective transparently with the stakeholders. This is also
relevant with how the dispute appearing within the LOT fishery in the UoA is
precautionarily resolved. SG 60-79 is not met.
PI 3.2.3 - Compliance and Enforcement
Monitoring, control, and surveillance (MCS) mechanisms ensure the management measures in
PI 3.2.3
the UoA are enforced and complied with
MCS system
A comprehensive monitoring,
A monitoring, control and control and surveillance
Monitoring, control and
surveillance system has been system has been
surveillance mechanisms
implemented in the fishery implemented in the fishery
exist, and are implemented in
Guidepost and has demonstrated an and has demonstrated a
the fishery and there is a
ability to enforce relevant consistent ability to enforce
reasonable expectation that
management measures, relevant management
they are effective.
strategies and/or rules. measures, strategies and/or
rules.
Met? Yes No No
The MCS for LOT fishery in targeted UoA, Malaysia’s Government has been
developed plan of actions to combat IUU Fishing through “Malaysia’s National
Plan of Action to Prevent, to Deter an to Eliminate IUU” (Malaysia's NPOA- IUU
Rationale
2013) along with Economic Zone Act, 1984 (311); Malaysian Maritime
Enforcement Agency Act 2004; and Merchant Shipping Ordinance 1952. This
information shows the MCS mechanism exists with clear standard operation
page 86 of 120
procedures to handle both foreign and local fishing vessels. This NPOA-IUU
focused on:
● State control over nationals;
● Restriction on foreign fishing vessels and vessels without nationality;
● Sanctions;
● Non-cooperating states;
● Economic incentives;
● MCS (including registration, transhipment, Vessel Monitoring
System/VMS, inspection, enforcement, etc);
● and cooperation between states as well.
Sanctions
Sanctions to deal with Sanctions to deal with

Sanctions to deal with
non-compliance exist, are non-compliance exist, are
non-compliance exist and
Guidepost consistently applied and consistently applied and
there is some evidence that
thought to provide effective demonstrably provide
they are applied.
deterrence. effective deterrence.
Met? Yes No No
The sanctions/penalties clearly stated via Economic Zone Act, 1984 (311);
Malaysian Maritime Enforcement Agency Act 2004; and Merchant Shipping
Ordinance 1952.
Rationale The sanctions/penalties should be consistently applied and the evidence

could provide that the compliance and enforcement for the fishery-specific
management carried out comprehensively with a high degree of confidence.
However, the existence has not been effectively demonstrated, due to a lack of
evidence.
Compliance (information)
Fishers are generally thought Some evidence exists to There is a high degree of
to comply with the demonstrate fishers comply confidence that fishers
management system for the with the management system comply with the management
fishery under assessment, under assessment, including, system under assessment,
Guidepost
including, when required, when required, providing including, providing
providing information of information of importance to information of importance to
importance to the effective the effective management of the effective management of
management of the fishery. the fishery. the fishery.
Met? Yes No No
All regulations related to fisheries including permit regulations (fishing gear,

vessel, legality of the workers) and fishing areas have been determined and
published in several media, such as the DOF website, etc. Identified three
Rationale
major issues, e.g. dual flagging or registration or deregistration; landing of
catches in the neighbouring countries' ports; and encroachment foreign (and
national) fishing vessels in the coastal waters.
Compliance (outcome)
page 87 of 120
There is no evidence of
Guidepost
systematic non-compliance.
Met? Yes
At the regional level within the South East Asian region, established a regional
platform to combat IUU fishing via Regional Plan of Action (RPOA) IUU in 2007
through joint ministerial agreement. The Coordination Committee is a high
level decision-making body providing strategic advice and direction to RPOA
member countries.
Rationale
The Coordination Committee conducts an annual meeting and it is a high level
decision making body to provide strategic advice and direction to participating
countries on coordination and implementation covering matters such as
marine environment conservation, sustainable management of fisheries
resources, managing fishing capacity, building competency in fisheries
management and combating IUU fishing.
Draft Scoring <60

Range
In general, the MCS instrument and cooperation both within Malaysia and in
the regional waters are quite complete, however, the quality of the MCS
Information implementation is important to show whether the system is comprehensive
Gap Indicator and consistent, supported by convincing evidence and reports that the tuna
longtail fishery complies with all regulations. Without this circumstance, the
fishery is going to fail.
PI 3.2.4 - Monitoring and Management Performance Evaluation
There is a system for monitoring and evaluating the performance of the fishery-specific
PI 3.2.4 management system against its objectives. There is effective and timely review of the
fishery-specific management system
Evaluation coverage
There are mechanisms in There are mechanisms in There are mechanisms in

place to evaluate some parts place to evaluate key parts of place to evaluate all parts of
Guidepost
of the fishery-specific the fishery-specific the fishery-specific
management system. management system. management system.
Met? No No No
The monitoring and management performance evaluation is mentioned in the

National Plan of Action for the Management of Fishing Capacity in Malaysia
Rationale
(NPOA Fishing Capacity) which was published in 2008 and revised in 2015 (as
Plan 2). The long term objective of this NPOA Plan 2 is for the country to
page 88 of 120
achieve an efficient, equitable and transparent management of fishing capacity
in marine capture fisheries by 2018. This plan will be reviewed after five years.
Nevertheless, its planning seems general for all fisheries within Malaysian
waters, not specific for LOT fishery within UoA, certainly with the harvest
strategy and control rules that are not in place yet.
Internal and / or external review
The fishery-specific The fishery-specific The fishery-specific

management system is management system is management system is
Guidepost
subject to occasional internal subject to regular internal and subject to regular internal and
review. occasional external review. external review.
Met? No No No
The effectiveness and validity of the NPOA Fishing Capacity (Plan 2) have not
been clearly measured, and there is no mechanism for peer review in place,
moreover, evaluation for the fishery-specific management system to cover the
Rationale update of stock of LOT in the region, and set the harvest strategy through
transparent and comprehensive decision-making is absent. This goes along
with the review and evaluation mechanism for management performance
which currently doesn’t exist.
Draft Scoring <60

Range
The Monitoring and evaluation mechanism/system to assess the performance

Information
of the fishery-specific management system against its objectives is not in
Gap Indicator
place. SG 60-79 is not met.
page 89 of 120
APPENDICES
Evaluation Process and Techniques
Site Visits
The process of LOT fishery pre-assessment was conducted during March 31st 2023 - June
30th 2023, whereas the field visit was carried out between 14th-20th May, 2023 by visiting various
locations in Malaysia. The field visits are important steps to observe the information and to
confirm the result of the pre-assessment with related stakeholders i.e. representatives of the
government, fishers, vessel crews, researchers, etc. The result of the field visits reflected in the
report for any changes based on the fact found on the ground. The main objective of this
pre-assessment was to evaluate the performance of the LOT fishery (especially in ECPM waters)
that landed in Tok Bali against the MSC standard. The raising gaps would be a basis for the
stakeholders to design and implement the improvement toward sustainability of the resources. .
The field visit agenda commenced with a visit to the DOF office in Kelantan to do the
coordination and interviews regarding the management of the LOT fishery in ECPM waters.
Unfortunately, the team could not meet the concerned persons as they had urgent matters. Then,
the team visited the Siti Khadijah Traditional Market in Kelantan to observe the availability of the
LOT in the local market, and gained information from the seller about the LOT fishery in Kelantan
both past and present condition. Through this visit, the team was able to watch the significance of
LOT in the local community and given an initial vision about the potential secondary fisheries
impacted.
The visit continued to Tok Bali Fishing Port under authority of LKIM, to observe the purse
seine vessels specification (used to operate in zone C-C2) and their catch compositions. The
discussion with LKIM in Tok Bali was conducted to gather further information on their roles to
support and develop the LOT business in the region, and how they connected with the association
of fishers. The LOT supply chain, and fishery operation slightly discovered within the discussion.
The team then proceeded to Besut Port to observe and to compare the purse seine vessels and the
catch compositions against Tok Bali. This visit gave the team a more holistic understanding of the
purse seine fishery operated in different zones, different target species and catch composition,
whereas in Besut, tend to dominated by purse seine vessel that operates in zone C, with
small-pelagic fishes dominated the catches, even LOT abundantly landed during the peak season.
Not only purse seiners, in Besut also available various vessels and fishing gears that target
demersal fishes, squids, etc, in zone A and B. The team interviewed the fishers, and purse seine
vessel crew that landed there, and they gave many understanding about typical fishing activities
and operation in the region.
The planned visit to the Southeast Asian Fisheries Development Center (SEAFDEC) in
Terengganu was unsuccessful as SEAFDEC was on leave. This meeting actually has significant
impact to clarify any previous interpretations about the fishery, i.e. neritic tuna fishery in the region,
the dynamics of the LOT’s stock, movement and progress to mainstreaming neritic tuna
management in South China Sea, etc. To understand the potential bycatch and ETP encountered by
purse seine fishery in ECPM waters, the team visited the WWF site in Terengganu by discussing
with the local WWF staff about the potential of purse seine fishery encounter the turtle migration
page 90 of 120
in Malaysia waters. Before returning to Indonesia, the team visited Putra Jaya, to meet the
Department of Fisheries (DOF) headquarters to discuss with the representative of the capture
fishery resources division. However, the team could not meet with them due to an impromptu
meeting. In addition, the group met with a former WWF staff member who had experience in ETP
conservation, providing additional insights into the potential ETP bycatch in fishing activities in
Malaysia.
In addition, a written statement about LOT fishery in Malaysia (including ECPM waters)
from DOF Malaysia also available to complement the assessment. Based on these observations,
the team has obtained a clearer picture of the LOT purse seine fishery in Malaysia. This
pre-assessment has provided valuable initial insights as a starting point for further improvement
for LOT fishery in ECPM waters specifically, and in Malaysia generally, toward sustainable use of
resources in the future.
Table 11. Site Visit Agenda

No. Activity Achievement Reasons
May 14, 2023
1 Travel from Indonesia to Kota Bharu, Achieved -

Kelantan
May 15, 2023
2 Discussion with DOF Kelantan Not Achieved Unexpected

commitment
3 Survey of LOT at the local market Achieved -
May 16, 2023
4 Observation of Purse Seine and LOT catch at Achieved -

Tok Bali fishing port
5 Discussion with LKIM Tok Bali Achieved -
6 Discussion with MMEA Kelantan Not Achieved Pending disposition

from supervisor
May 17, 2023
7 Survey at the Besut fishing port Achieved -
8 Travel to Terengganu Achieved -
9 Discussion with WWF Terengganu staff Achieved -
May 18, 2023
10 Discussion with SEAFDEC Not Achieved On leave
11 Travel to Kuala Lumpur Achieved -
May 19, 2023
page 91 of 120
12 Discussion with LKIM and DoF headquarters Not Achieved Unexpected meeting
May 20, 2023
13 Wrap-up of activities Achieved -
May 21, 2023
14 Conditional meeting with former WWF staff Achieved -

related to ETP conservation
15 Return travel to Indonesia Achieved -
page 92 of 120
Recommendations for Stakeholders Participation
The implementation of FIP is fundamental to be tackled harmoniously with the relevant

stakeholder by creating an effective co-management. The characteristics of the targeted fishery
(e.g. LOT) also impacts the scale and the scope of intervention to be addressed toward the
effective fishery management measure. The definitions and the objectives of the MSC standard
and the FIP itself are important for the stakeholders to set their interpretations within the same
understanding. The transparency of the data and information is a basis to develop an adequate
fishery management strategy that is right on the target.
These requirements raise a challenge to connect various stakeholders to move forward

precisely in further collaboration. The limited interviewed stakeholders during the assessment
process indicated an undelivered-message happened. A partial strategy should be proposed to
engage the stakeholders into the same vision and perspective. A conditioning period can be an
option to build trust and opportunity with them before bigger context about FIP and ecolabel
certification (MSC) is introduced and inferred.
Table 12. Interviewed stakeholders
No. Name Institution
1 Azuan Zahari LKIM - Tok Bali, Kelantan, Malaysia (Head)
2 Anizan Bin Ramli LKIM - Tok Bali, Kelantan, Malaysia (Staff)
3 Kamarudin Bin Halim Purse seine vessel (zone C), Besut (Mechanic)
4 Hasham Bin Mamat Purse seine vessel (zone C), Besut (Crew/ Thailand)
5 Izat Fishes shorter staff (Besut Port)
6 Noor Azzaria Mohtar WWF Terengganu Site Leader (Malaysia)
7 Mohd. Fadzlee Bin Asmat WWF Fisheries Officer (Malaysia)
8 Ledhyan Eka Harliyan LOT researcher
9 Tegoeh Noegroho Neritic tuna researcher
page 93 of 120
Risk-Based Framework Outputs
Productivity Susceptibility Analysis (PSA)
Table 13 shows elements that are assessed via PSA as per in Table 14.
Table 13. Productivity Susceptibility Analysis (PSA) elements of fish and invertebrates
Productivity Susceptibility
Decapterus spp. Decapterus akaadsi, D. koheru, D. page 95

kurroides, D. lajang, D. macarellus, D.
macrosoma, D. maruadsi, D. muroadsi,
D. punctatus, D. russelli, D. scombrinus
and D. tabl (Muchlisin et al., 2009).
Euthynnus affinis N/A page 97
Sardinella spp Sardinella fimbriata, Sardinella albella, page 99

Sardinella gibbosa (Rosidi et al., 2021;
www.mybis.gov.my, 2023)
Selar crumenophthalmus N/A page 101
Rastrelliger kanagurta N/A page 103
Amblygaster spp Amblygaster clupeoides, Amblygaster page 105

leiogaster, & Amblygaster sirm
Atule mate N/A page 107
Auxis thazard N/A Page 109
page 94 of 120
Table 14 (a). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Performance Indicator 2.2.1
Productivity
Scoring element Decapterus spp.
Attribute Justification Score
Average age at
1.2-1.9 years 1
maturity
Average maximum
12 years 2
age
Fecundity Up to > 84,000 1
Average maximum
45 cm 1
size
Average size at
16.1 cm; 14-24.5 cm in range 1
maturity
Reproductive
Broadcast spawner 1
strategy
Trophic level 3.7 ± 0.4 (based on diet studies) 3
Susceptibility
Fishery Decapterus akaadsi, D. koheru, D. kurroides, D. lajang, D. macarellus, D.

Only where the scoring
macrosoma, D. maruadsi, D. muroadsi, D. punctatus, D. russelli, D.
element is scored
cumulatively scombrinus and D. tabl (Muchlisin et al., 2009).
Decapterus spp. It has a wide distribution in tropical waters,

which is concentrated in Indo-West Pacific; East Africa to
Japan; and the Arafura Sea. This genus dominated the
Areal Overlap 3
purse-seiners catch in ECPM waters (34% of the catch),
resulting in high-risk for aerial overlap (>30% overlapped with
the fishing effort).
Decapterus spp. depth range is 0-275m, by comparison with

Encounterability the purse seine in ECPM, this species has a wide depth 2
stratification, making it possible to avoid fishing gear.
Indicated multispecies fisheries, trash fishes and

Selectivity of gear
mixed-fishes caught in huge numbers (20% and 4% in a row); 3
type
mesh size 1.5-2.5 inches.
page 95 of 120
Post capture
Highly likely the catch is majority dead when released. 3
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 96 of 120
Table 14 (b). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Euthynnus affinis
Average age at
37.7 - 50 cm 1
maturity
Average maximum
6 years 1
age
Fecundity 210,000-680,000 1
Average maximum
110 cm 2
size
Average size at
40-65 cm 2
maturity
Reproductive
Broadcast spawner 1
strategy
Trophic level 4.5 ± 0.0 (based on diet studies) 3
Susceptibility
Fishery
N/A
element is scored
cumulatively
Euthynnus affinis distribution around Indo-West Pacific

waters: in warm waters including oceanic islands and
archipelagos. A few stray specimens have been collected in
Areal Overlap the Eastern Central Pacific. The Euthynnus affinis occupied 3
10% of the purse seine total landings during 2017 - 2018 in
ECPM waters, and stock concentration indicated >30%
overlapped with the fishing effort.
Euthynnus affinis depth range from 0 - 200m by comparison

with the purse seine ability in ECPM, this species has a
Encounterability wide-depth stratification, making it possible to avoid fishing 2
gear. It indicated a medium risk of encounterability with the
fishing gear.
Selectivity of gear Indicated multispecies fisheries, trash fishes and 3
page 97 of 120
type mixed-fishes caught in huge numbers (20% and 4% in a row);
Post capture
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 98 of 120
Table 14 (c). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Sardinella spp
Average age at 4-6 months to 2 years (round bodies sardinella) (Hunnam,

1
maturity 2021)
Average maximum
3-4 years (round bodies sardinella) (Hunnam, 2021) 1
age
Fecundity 14,851 1
Average maximum
19 cm 1
size
Average size at
13.5 cm 1
maturity
Reproductive
Broadcast spawner 1
strategy
Trophic level 2.7 ±0.30 2
Susceptibility
Fishery
Only where the scoring Sardinella fimbriata, Sardinella albella, Sardinella gibbosa (Rosidi et al.,
element is scored 2021; www.mybis.gov.my, 2023)
cumulatively
Sardinella spp. has wide distribution in the region of

Indo-West Pacific: from Kuwait to southern India and Bay of
Bengal to the Philippines, also eastern tip of Papua New
Guinea. Their productivity and biomass in accordance with
Areal Overlap 3
the dynamic of the upwelling in their certain habitat.
Sardinella spp. included as main secondary species due to
covered 5% of the purse seine total landing during 2017-2018
in ECPM waters and indicated > 30% overlapped.
Sardinella spp. depth range is 0 - 50 m by comparison with

Encounterability the purse seine ability in ECPM, highly likely it has a high risk 3
for the stock.
Selectivity of gear Indicated multispecies fisheries, trash fishes and

3
page 99 of 120
Post capture
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 100 of 120

Table 14 (d). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Selar crumenophthalmus
Average age at
< 2 years (Noegroho et al., 2021) 1
maturity
Average maximum
3 years 1
age
Fecundity 48,000-262,000 1
Average maximum
70 cm 1
size
Average size at
17.7 cm 1
maturity
Reproductive
Broadcast spawner 1
strategy
Susceptibility
Fishery
N/A
element is scored
cumulatively
Selar crumenophthalmus is circumtropical, widely distributed

in several tropical waters, e.g. Indo-Pacific: East Africa to
Rapa, north to southern Japan and the Hawaiian Islands,
south to New Caledonia. The largest purse seine fishing in
Areal Overlap Malaysia is concentrated in ECPM waters, involving; Kelantan, 3
Trengganu, Pahang and Johor resulting in 5% of total
landings during 2017-2018. Indicated the stock concentration
of Selar crumenophthalmus is overlapped with fishing effort
>30%.
Selar crumenophthalmus depth range is 0 - 170m by

Encounterability comparison with the purse seine ability in ECPM, highly likely 2
it has a medium risk for the stock.
page 101 of 120

Selectivity of gear
type
Post capture
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 102 of 120

Table 14 (e). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Rastrelliger kanagurta
Average age at
1.1 year: 0.9-1.4 year (in a range) (fishider.org, 2023) 1
maturity
Average maximum
4 years 1
age
Fecundity 37,690-170,455 1
Average maximum
36 cm 1
size
Average size at
19.9 cm 2
maturity
Reproductive
Broadcast spawner 1
strategy
Susceptibility
Fishery
N/A
element is scored
cumulatively
Rastrelliger kanagurta distribution is concentrated in the

Indo-West Pacific: Red Sea and East Africa to Indonesia,
north to the Ryukyu Islands and China, south to Australia,
Melanesia and Samoa. The largest purse seine fishing in
Areal Overlap Malaysia is concentrated in ECPM waters, involving; Kelantan, 2
Trengganu, Pahang and Johor resulting in 3% of total
landings during 2017-2018 (minor - secondary species).
Indicated the stock concentration of Rastrelliger kanagurta is
mediumly overlapped with fishing effort 10-30%.
Rastrelliger kanagurta depth range is 20 - 90m by comparison

Encounterability with the purse seine ability in ECPM, highly likely it has a 2
medium risk for the stock.
Selectivity of gear Indicated multispecies fisheries, trash fishes and 3
page 103 of 120

Post capture
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 104 of 120

Table 14 (f). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Amblygaster spp
Average age at
1 years 1
maturity
Average maximum
8 years 1
age
Fecundity 121,000-132,900 1
Average maximum
27 cm- 1
size
Average size at
15 cm 1
maturity
Reproductive
Broadcast spawner 1
strategy
Susceptibility
Fishery
Only where the scoring Amblygaster clupeoides, Amblygaster leiogaster, & Amblygaster sirm
element is scored
cumulatively
The distribution of Amblygaster spp is around Indo-West

Pacific: Red Sea and Mozambique to the Philippines, north to
Areal Overlap Taiwan and Okinawa (Japan), south to New Guinea, the 2
Arafura Sea. Indicated that this fishery is mediumly
overlapped with fishing effort 10-30%.
Amblygaster spp depth range 10 - 75m by comparison with

Encounterability the purse seine ability in ECPM, highly likely it has a high risk 3
for the stock.

Selectivity of gear
type
Post capture Highly likely the catch is majority dead when released. 3
page 105 of 120

mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 106 of 120

Table 14 (g). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Atule mate
Average age at
1.5 year (fishider.org, 2023) 1
maturity
Average maximum
3.5 years (fishider.org, 2023) 1
age
Fecundity 63,000-161,000 1
Average maximum
30 cm 1
size
Average size at
17 cm 1
maturity
Reproductive
Broadcast spawner 1
strategy
Susceptibility
Fishery
N/A
element is scored
cumulatively
Atule mate distributed around the Indo-Pacific: Red Sea and

the east coast of Africa to the Hawaiian Islands and Samoa,
Areal Overlap north to south of Japan, and the Arafura Sea. Based on the 3
purse seine operation within the UoA indicated that this
fishery is mediumly overlapped with fishing effort 10-30%.
Atule mate depth range is 1 - 80m by comparison with the

Encounterability purse seine ability in ECPM, highly likely it has a high risk for 3
the stock.

Selectivity of gear
type
Post capture Highly likely the catch is majority dead when released. 3
page 107 of 120

mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 108 of 120

Table 14 (h). PSA productivity and susceptibility attributes and scores for fish and invertebrates.
Productivity
Scoring element Auxis thazard
Average age at
2 - 3 years 1
maturity
Average maximum
5 years 1
age
Fecundity 78,000 - 1,370,000 1
Average maximum
65 cm 1
size
Average size at
29.5 cm 1
maturity
Reproductive
Broadcast spawner (external) 1
strategy
Susceptibility
Fishery
N/A
element is scored
cumulatively
Auxis thazard distributed the Atlantic,Mediterranean, Indian

and Pacific (Western Central). Eastern Pacific population
recognized as subspecies Auxis thazard brachydorax. Many
Areal Overlap authors have used the name Auxis thazard as including Auxis 2
rochei in the belief that there was only a single worldwide
species of Auxis. Highly migratory species, Annex I of the
1982 Convention on the Law of the Sea.
Auxis thazard depth range is 0-200m by comparison with the

Encounterability purse seine ability in ECPM, highly likely it has a high risk for 3
the stock.

Selectivity of gear
type
page 109 of 120

Post capture
mortality
Catch (weight)
N/A -
element is scored
cumulatively
page 110 of 120

Table 15 shows elements that are assessed via PSA as per in Table 16.
Table 15. Productivity Susceptibility Analysis (PSA) elements of sea turtles and cetacean
Productivity Susceptibility
Dermochelys coriacea N/A page 112
Lepidochelys olivacea N/A page 113
Chelonia mydas N/A page 114
Eretmochelys imbricata N/A page 115
Tursiops aduncus N/A page 116
page 111 of 120

Table 16 (a). PSA productivity and susceptibility attributes and scores for sea turtles & cetaceans.
Productivity
Scoring element Dermochelys coriacea
Average age at
7-13 years: 14-17 years 2
maturity
Fecundity: eggs per

season per 50-100 eggs 3
remigration interval
Susceptibility
Fishery
N/A
element is scored
cumulatively
The fishing ground of Purse Seine is in the leatherback turtle

Areal Overlap migration area, so that it is very possible for potential 2
interactions with leatherback turtles
Leatherback turtles swim at great depths (500-1200 m), so

Encounterability 1
their potential to be encircled by purse seine nets is low
Selectivity of gear The purse seine is less selective, it is convincing in high

3
type possibility for sea turtles to get caught.
Post capture All of the ETP species listed in Table 8 prohibited by Malaysia
2
mortality government, mandatory release, but no evidence.
page 112 of 120

Table 16 (b). PSA productivity and susceptibility attributes and scores for sea turtles & cetacean.
Productivity
Scoring element Lepidochelys olivacea
Average age at
11-16 years 3
maturity
Fecundity: eggs per

season per 110 eggs 3
Susceptibility
Fishery
N/A
element is scored
cumulatively
Malaysian waters are not the main migration area for

Lepidochelys olivacea turtles. The main migration area for
Areal Overlap this turtle is in the waters of the Pacific Ocean, and especially 1
in the waters of Central and South America, including the
coasts of Mexico.
The swimming depth of Lepidochelys olivaceae is less than

Encounterability 50 m so the chance of being encircled by purse seine nets is 3
high

3
2
page 113 of 120

Table 16 (c). PSA productivity and susceptibility attributes and scores for sea turtles & cetaceans.
Productivity
Scoring element Chelonia mydas
Average age at
26-40 years 3
maturity
Fecundity: eggs per

season per 65-90 eggs 3
Susceptibility
Fishery
N/A
element is scored
cumulatively
Green turtles dominate the population of sea turtles within

Areal Overlap the South China Sea as shown in Table 11, their possibility of 3
being caught by the LOT purse seine is high.
Green turtles can depth up to > 200 m, but mostly they will
spend their life on the surface in order to access oxygen for
Encounterability 3
their breath. This makes them highly likely to be accidentally
caught by the LOT fishing in the UoA.

3
2
page 114 of 120

Table 16 (d). PSA productivity and susceptibility attributes and scores for sea turtles & cetaceans.
Productivity
Scoring element Eretmochelys imbricata
Average age at
20-25 years 3
maturity
Fecundity: eggs per

season per 130 eggs 3
Susceptibility
Fishery
N/A
element is scored
cumulatively
Eretmochelys imbricata migration route is mainly in the Indian

Areal Overlap Ocean or the west of the peninsula, but it does not rule out 2
the possibility of being found in the east of the peninsula
Hawksbill sea turtles can depth up to > 200 m, but mostly

they will spend around the surface (2-20m). This makes them
Encounterability 3
highly likely to be accidentally caught by the LOT fishing in the
UoA.

3
2
page 115 of 120

Table 16 (e). PSA productivity and susceptibility attributes and scores for sea turtles & cetaceans.
Productivity
Scoring element Tursiops aduncus
Average age at
5 - 10 years 3
maturity
Fecundity: eggs per

season per 1 calf 3
Susceptibility
Fishery
N/A
element is scored
cumulatively
Tursiops aduncus is found in Malaysian waters, especially

around Tioman Island, Redang Island, and Pulau Pinang State
Areal Overlap 3
Park. potential for interaction with purse seine fisheries is
high
Bottlenose dolphins are mostly distributed in the warm

temperate and tropical coastal waters, usually <100m depth.
Encounterability 3
Mostly dive 12-112 depth in a range. This makes them highly
likely to be accidentally caught by the LOT fishing in the UoA.

3
type possibility for dolphins to get caught.
2
page 116 of 120

Consequence Spatial Analysis (CSA)
Table 17. CSA justification table for PI 2.4.1 Habitats.

Consequence Justification Score
The fishing ground in the part of ECPM waters has a depth of

around 25 - 60 m (Ahmad et al., 2016; Marziah et al., 2015)
Regeneration of
which consists of mixed faunal communities, e.g. epifauna, 3
biota
small erect/encrusting, etc. Even though the operation of the
gear does not disturb the sea floor.
Natural disturbance (in terms of absence of information) in

the area of coastal margin and inner shelf is scored by
default.
Natural disturbance 1
ECPM is subject to severe weather during the north-east
monsoon (Nov-Mar), during which no fishing – (except prawn
trawling).
Removability of N/A (interaction between the fishing gear and the sea bed do
1
biota not occurs)
Removability of N/A (interaction between the fishing gear and the sea bed do
1
substratum not occurs)
Sediment (soft, light, consolidated, biogenic), e.g., muddy

Substratum
and/or sandy bottoms due to the presence of patchy coral 2
hardness
reef that occurs along the coast
Substratum Flat, simple surface structure (mounds, undulations, ripples),

3
ruggedness current rippled, wave rippled, or irregular
Seabed slope Low degree, plains in coastal margin, inner or outer shelf 1
Spatial Justification Score
Gear footprint Purse seine is leaving without footprint - scored by default 1
The LOT is widely distributed in the tropical waters, involving

in targeted UoA. The fishing activities exist not only in ECPM
Spatial overlap but also the surrounding waters. It indicated that the stock 1.5
can cover up to more than 45% of the total stock of LOT in the
region.
None of specific information; based on the fishing gear

structure vs the bathymetric profile of ECPM waters its
Encounterability 1
indicated that the encounterability of the gears with stock is
about 30%
page 117 of 120

Scale Intensity Consequence Analysis (SICA)
Table 18. SICA scoring template for PI 2.5.1 Ecosystem.

Spatial scale of Temporal scale Intensity of Relevant Consequence
fishing activity of fishing activity fishing activity subcomponents Score
Species
-
Performance composition
Indicator PI Functional
2.5.1 group 60
Ecosystem 5 4 4 composition
outcome
Distribution of
-
the community
Trophic
-
size/structure
The LOT fishing in Southeast Asia is utilised from the South China Sea
Justification including the Gulf of Thailand and ECPM waters of Malaysia. This also
for spatial expanded to the Sulu and Sulawesi Seas as part of Indo - Pacific waters where
scale of LOT is concentrated. The LOT is a high economic value commodity and
fishing activity important nutrition in the region. Firmly the overlap of the ecosystem with the
fishing activity of the UoA covered up to 60% as the operated vessels.
The intensity of LOT fishing in the ECPM waters was predicted to be 101-200
Justification
days per year. Whereas the fishing season effectively happens during April to
for temporal
September for ECPM waters. Highly likely indicated that the surrounding waters
scale of
also have similar fishing seasons, such as in Gulf of Thailand where LOT fishing
fishing activity
(purse seine) mainly happen in the southern part near the Malaysia waters.
LOT fishing identified local to regional and occupied widespread areas within
Justification the South China Sea, including commercial fishers from ECPM and the Gulf of
for intensity of Thailand that caught LOT in the same stock. Categorised as major due to
fishing activity evidence of fishing activity occurring reasonably often at a broad spatial scale
within the South China Sea.
Functional groups were chosen as the main indicators scored in this

circumstance regarding the dynamic of the pelagic-neritic ecosystem. The
ocean circulation dynamic contributes to nutrient richness and supports
primary productivity in the ecosystem. The MSC standard requires the fishery
Justification not to cause irreversible harm to the key elements of the ecosystem or the
for underlying ecosystem structure and function pointed to hinder the ecosystem's
consequence resilience or recovery ability from the impact. The role of LOT in the food web is
score shown by the trophic level in the range of 4.5 ± 0.6. It represents a high position
in the food web, although its actual function in ecosystem structure is unclear
due to a lack of evidence. Moreover, the dynamic for lower trophic level
organisms potentially affected the upper organism within the food web, mainly
for the diet source availability.
page 118 of 120

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Pre-Assessment of Longtail Tuna FIP Tok Bali - Report (Draft)

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Pre-Assessment of Longtail Tuna FIP Tok Bali - Report (Draft)

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This first draft report was

submitted on 15 May 2023

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Copyright © 2023 BlueSeed Indonesia

Design and layout by Fadzliee Asmat (WWF-Malaysia).

Aim and Constraint of the Pre-Assessment 1

UNIT OF ASSESSMENT (UoA) 3

TRACEABILITY WITHIN THE FISHERY 4

Pre-Assessment Result Overview 5

Summary of Potential conditions by Principle 9

Summary of Performance Indicators Level Scores 10

Total Allowable Catch (TAC) and Catch data 26

Performance Indicator Scores and Rationales 26

Performance Indicator Scores and Rationales 46

Performance Indicator Scores and Rationales 80

Evaluation Process and Techniques 91

Recommendations for Stakeholders Participation 93

Risk-Based Framework Outputs 94

Productivity Susceptibility Analysis (PSA) 94

Consequence Spatial Analysis (CSA) 115

Scale Intensity Consequence Analysis (SICA) 116

Blue Seed Indonesia is an independent entity expertised on environmental issues, both

CAB Conformity Assessment Bodies

FIP Fishery Improvement Project

MSC Marine Stewardship Council

TAC Total Allowable Catch

UoA Unit of Assessment

UoC Unit of Certification

ETP Endangered, Threatened, and Protected

ECPM East Coast of Peninsular Malaysia

IOTC Indian Ocean Tuna Commission

WCPFC Western Central Pacific Fisheries Commission

ASEAN Association of Southeast Asian Nations

FMP Fisheries Management Plan

RPOA Regional Plan of Actions

RFB Regional Fisheries Body

MCS Monitoring, Control and Surveillance

IUU Illegal, Unreported and Unregulated

EEZ Exclusive Economic Zone

LOT Longtail Tuna

FRI Frigate Tuna

IQS Individual Quota System

CNP Central North Pacific

RBF Risk-based Framework

PSA Productivity, Susceptibility Analysis

CSA Consequence Spatial Analysis

MSY Maximum Sustainable Yield

PRI Point of Recruitment Impairment

HCR Harvest Control Rules

Figure 1. Longtail tuna (LOT) 15

Figure 3. FAO Fishing Area 57 and 71 17

Figure 5. Risk assessment of LOT in the Pacific Ocean 2018 18

Figure 6. Fishing grounds of LOT fisheries in the ECPM 22

Figure 7. Percentage of tuna species and tuna-like species production of 24

Figure 8. CPUE (Mt/Unit) of LOT caught by purse seiners in the ECPM 25

Figure 9. LOT landings in Kelantan from 2010 to 2020 25

Figure 12 The distribution of the 26 species of LOT purse seine’s catch 38

Figure 15 Sighting and Stranding Location of Various Marine Mammals in 44

Figure 16. The food web in the pelagic ecosystem of CNP 46

Table 1. Unit of Assessment (UoA) 3

Table 2. Traceability within the fishery 4

Table 3. Recommendations for Performance Indicators 6

Table 4. Summary of Performance Indicator level scores <60 9