THE RISKS OF NOT DECIDING TO ALLOCATE THE PRECAUTIONARY KRILL CATCH LIMIT AMONG SSMUS AND ALLOWING UNCONTROLLED EXPANSION OF THE KRILL FISHERY UP TO THE TRIGGER LEVEL

After the Scientific Committee did not reach consensus and advise the Commission on the risks associated with three options for a Stage-1 allocation of the precautionary krill catch limit among SSMUs in Subareas 48.1-48.3, it was suggested that a comprehensive assessment of the risks that might be incurred by not deciding on such an allocation (i.e., a risk assessment of status quo management) be undertaken. We used the same methods applied by the WG-EMM in 2008, including averaging results provided from multiple parameterizations of the same model, and present such a risk assessment here. Our results demonstrate that i) status quo management may jeopardize the Commission's ability to achieve the objectives specified in Article II, and ii) the current trigger level is not as precautionary as previously presumed. Our work also reiterates the advice that the WG-EMM delivered to the Scientific Committee during 2008, and the caveats associated with that previous advice also apply here. Given the risks of status quo management, we identify three approaches by which the Commission can manage risks to krill-dependent predators in a precautionary manner: i) cap krill catches at recent levels until a feedback approach to management of the krill fishery can be implemented; ii) agree a new trigger level, that is less than the current trigger level, while continuing work to evaluate options for a Stage-1 allocation and feedback management strategies; or iii) eliminate the current trigger level, agree a Stage- 1 allocation, and focus research to design and evaluate a feedback management strategy. We feel that the collective body of scientific work to advise on issues related to the SSMU allocation has met the "burden of proof" that would be required for decision making.