The need to progress towards EAF has been widely recognized and was embedded to a large extent in the Code of Conduct for Responsible Fisheries. However, there are substantial obstacles to the effective implementation of EAF, as evidenced by the difficulties of countries in implementing the requirements of the Code. Key impediments to EAF include the following:
1. The mismatch between expectations and resources (both human and financial) will need to be carefully managed. EAF has much to offer, but lack of investment in the process will certainly slow progress and might mean failure in the end. The differing timetables of the political and the management process may also mean that insufficient commitment and resources are made available. EAF is a long-term commitment with long-term benefits, which may be difficult to present convincingly to governments, which normally work in shorter cycles, and especially when EAF competes with short-term socio-economic objectives.
2. Difficulty may be foreseen in reconciling competing objectives of the multiple stakeholders. In some, perhaps many, cases the participatory process may be insufficient for finding compromises that satisfy all stakeholders. Conflicts may then require higher-level intervention to determine the relative priorities and possibly, compensation. This is already a serious problem in many TROM fisheries, and will be exacerbated by EAF.
3. Insufficient or ineffective participation of stakeholders in the development and implementation of EAF may occur, even when competing objectives can be reconciled. This deficiency could be caused by a number of factors including:
- an unwillingness of stakeholders to participate openly and transparently in the process or to make concessions, believing that they will fare better by non-cooperation than by cooperation;
- inadequate and fuzzy user rights that fail to recognize long-term interests and responsibilities leading to poor stewardship;
- a lack of access to necessary information;
- inadequate consultation process or arrangements;
- insufficient resources being invested to improve fisheries and their management;
- a lack of capacity to participate effectively (e.g. knowledge, financial or other resources, geographical dispersion); and
- hidden agendas (e.g. expectations that are not transparent to all participants, leading to distorting behaviour and mistrust).
4. The time and cost required for effective consultation with a wide range of stakeholders could be substantial but, in many cases, a good start can be made with the resources already being used for TROM.
5. Insufficient knowledge will continue to be a constraint. Biological uncertainty is recognized as a substantial problem in management of fisheries under TROM, and the combined biological and ecological uncertainty under EAF will be even greater. One manifestation of this will be an inability in some instances to identify meaningful, cost-effective indicators for important objectives. The sum of these uncertainties will require robust and precautionary approaches that could cause substantial difficulties in some cases for certain stakeholders, both social and economic. A further source of uncertainty is a widespread lack of adequate knowledge of fleet and fisher behaviour and dynamics.
6. A lack of adequate capacity for informative compilation and analysis of the available information will often add to the uncertainty. In cases where there are or have been inadequate monitoring and data storage systems in place, the problems will be particularly acute.
7. Insufficient education and awareness will also be a problem. This will apply to all stakeholders in exercising their responsibilities, including the fishery management agencies and the public, who will need to be better educated on their roles in the process.
8. Equity issues will always be difficult to resolve in relation to responsibility for ecosystem degradation, between fisheries and other economic activities such as agriculture (including forestry), chemical industries, urban and coastal development, energy and tourism.
9. Aligning the boundaries of the ecosystems and of the jurisdictions of the management authorities (whether at regional, national or sub-national levels), as well as between jurisdictions of the different authorities responsible for competing sectors, will continue to be a challenge. Trans-boundary issues will require particular attention. As foreseen in the United Nations Fish Stock Agreement (FSA), EAF measures adopted by different countries sharing an ecosystem will need to be compatible across the whole geographical range of the ecosystem.
10. Another impediment common to both TROM and EAF, which will continue to be a threat, is illegal stakeholder behaviour: illegal fishing, lack of implementation of flag state and port state responsibilities, and misreporting. While these types of practices continue, it is difficult to see how the principles and processes outlined in these guidelines can be implemented successfully, especially on the high seas. The Compliance Agreement and the International Plan of Action on Illegal, Unreported and Unregulated fishing should play a useful role in changing this situation for the future.
11. Poverty is a major threat to EAF. While poor coastal dwellers have few other options to derive livelihoods, fishing will continue to be the occupation of last resort for growing and displaced populations, resulting in excessive fishing effort, depletion of resources and ecosystem degradation. This will often occur in desperate circumstances where the incentive to care for the ecosystem is overshadowed by daily necessities.