Proposal to Revise CMM 2023-03 on Transshipment
At COM07, the Commission diligently revised the Conservation and Management Measure (CMM)
on transshipment through rigorous intersessional efforts aimed at enhancing its efficacy. In the initial
year of CMM implementation, Korea has discerned two aspects warranting careful review. This
revision seeks to alleviate administrative burdens while upholding the integrity and effectiveness of the
CMM:
1) Shorter Time Frame for Advance Notification for Other Transfer Activities (Para 14): Unlike
transshipment, other transfer activities exhibit a diverse nature, encompassing items ranging from food
to spare parts for basic repairs. This diversity requires a more flexible approach to advance notification
timelines, minimizing administrative burdens. Recognizing this distinction, certain Regional Fisheries
Management Organizations forego any advance notification requirements for other transfer activities.
As a middle-ground solution, Korea proposes a reduction in the time frame for advance notification for
other transfer activities to two hours. For instance, CCAMLR mandates a 2-hour advance notification
for such activities.
2) Deletion of the Advance Notification 24 Hours Prior or Within 20 Nautical Miles (Paras 15
and 16): The NPFC Area's harsh and unpredictable weather and sea conditions necessitate frequent
modifications to advance notifications. In some cases, a single notification has undergone up to six
revisions due to changing weather conditions. Each transshipment involves a declaration confirming
the date, time, and location of the event, and any significant discrepancies can be rectified using existing
Monitoring, Control, and Surveillance (MCS) tools, including Vessel Monitoring Systems (VMS).
Although Korea mandates its vessels to report any modifications to advance notification, the inclusion
of paragraphs 15 and 16 is deemed nonessential and imposes a significant burden on fishing vessels
and national Fishery Management Committees (FMCs). Therefore, the deletion of these paragraphs is
recommended to streamline procedures without compromising the overall integrity of the CMM.