Response to FISHERIES/2020/JUL/SWG-PEL/105

Comments are offered on many of the assertions made in PEL/105. A key overall concern is the absence of clear explanations/evidence for the reasons for the decline in the penguin population. Even if (presently contested) estimates of a beneficial impact for penguins of closure around the vicinity of penguin colonies were to be accepted, such closures are nevertheless projected to have relatively little impact on arresting this decline. Assertions of poor ecosystem health and implications of an excessive negative impact of pelagic fishing on the ecosystem are questioned. Ultimately decisions about island closures require decision makers to be presented with summarised costs for and benefits to penguins and the industries involved; existing industry cost analyses offer rather different perspectives on this, and most require critical review before they might be used to contribute to such summaries.