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This report analyzed the movements of carrier vessels operating in the Western and Central Pacific Fisheries Commission (WCPFC) Convention area in 2016. Through analysis of AIS data, the report identified carrier vessel voyage patterns and quantity, carrier vessels' flag state patterns, the spatial distribution of potential transshipment on the high seas, and the port visit locations by carrier and flag states. The report also found that many carrier vessels did not transponder on AIS, leading to significant gaps in data on unreported transshipment events. Ultimately, the WCPFC’s management of transshipment in its Convention area is compromised by a lack of reported information on transshipment, coupled with non-compliance with reporting requirements and non-standardized reporting responses by CCMs on carrier vessels and their activities.

The international community has sought to limit or ban-transshipment at sea due to the difficulty it poses in monitoring IUU fishing and controlling its effects. The WCPFC has banned purse seine vessels operating within the WCPFC Convention Area; however, for longliners and other vessels, the WCPFC merely encourages them to conduct transshipment at sea to the extent practicable. Despite proper infrastructure at port, a precedent of other vessels conducting transshipment at port, and insignificant costs, CCMs have used the "impracticability" test to continue transshipping at sea. This paper proposes replacing the "impracticability" test with bright-line rules to put an end to CCMs' patterns of transshipment at sea.

The Western and Central Pacific Fisheries Commission (WCPFC) manages fishing activity in the Western and Central Pacific Oceans, one of the largest areas in the world and one of the most valuable fisheries in the world. However, their ability to enforce transshipment rules to prevent IUU fishing is severely lacking due to insufficient funds and resources, specifically when it comes to onboard observers. The observers have failed at monitoring the activities of both the fishing vessel and carrier vessel during transshipment and reporting that information for independent verification. By adopting rules already in use by other t-RFMOs, the WCPF can significantly improve its current transshipment regime.