Pramod et al. methods to estimate IUU are not credible

Abstract

We have examined the estimates in Pramod et al. of IUU Alaskan Pollock imported into Japan. Based on extensive knowledge of this fishery we find that their estimates are not substantiated by any known facts from the fishery. Whereas in a retracted version of the paper the authors estimated that 15–22% of Alaskan Pollock imported into Japan were IUU and listed the sources as discards & high-grading; unreported by-catch in trawl fisheries and unreported catches in artisanal fisheries, the authors have now added blending of IUU Pollock overseas with Alaskan Pollock as the dominant source of IUU Alaskan Pollock entering Japan. Remarkably, the authors estimate the same 15–22%, and continue to assert that discarded and high-graded fish in Alaska somehow make their way to Japan. None of the citations provided in the Pramod et al. paper provide any estimates of IUU, so their numerical estimates must therefore come from two confidential informants. No documentation of how the estimates are made is provided and the paper completely fails to meet normal standards of scientific replicability. The deficiencies in the estimate of IUU in Alaskan Pollock must cast serious doubt on their approach for all fisheries.