Contents lists available at ScienceDirect Marine Policy journal homepage: www.elsevier.com/locate/marpol Pramod et al. methods to estimate IUU are not credible Ray Hilborn a,* , Christopher M. Anderson a , Gordon H. Kruse b , Andre E. Punt a , Michael Sissenwine c , Chris Oliver d , James N. Ianelli e , Robert J. Trumble f , David J. Agnew g , Nicole Baker a a School of Aquatic and Fishery Sciences, University of Washington, Seattle WA 98195, USA b College of Fisheries and Ocean Sciences, University of Alaska Fairbanks, Juneau Center, Juneau, AK, USA c Marine Policy Center, Woods Hole Oceanographic Institution, Woods Hole, MA 02536, USA d NOAA Assistant Administrator for Fisheries, 1315 East West Highway, Silver Spring MD 20910, USA e Alaska Fisheries Science Center, National Marine Fisheries Service, NOAA, 7600 Sand Point Way NE, Seattle, WA 98115, USA f MRAG Americas, Inc., St. Petersburg, Florida, USA g Institute for Marine and Antarctic Studies, University of Tasmania, Hobart 7001, Australia ARTICLE INFO Keywords: IUU Alaskan pollock Discarding Blending Replicability ABSTRACT We have examined the estimates in Pramod et al. of IUU Alaskan Pollock imported into Japan. Based on ex- tensive knowledge of this fishery we find that their estimates are not substantiated by any known facts from the fishery. Whereas in a retracted version of the paper the authors estimated that 15–22% of Alaskan Pollock imported into Japan were IUU and listed the sources as discards & high-grading; unreported by-catch in trawl fisheries and unreported catches in artisanal fisheries, the authors have now added blending of IUU Pollock overseas with Alaskan Pollock as the dominant source of IUU Alaskan Pollock entering Japan. Remarkably, the authors estimate the same 15–22%, and continue to assert that discarded and high-graded fish in Alaska somehow make their way to Japan. None of the citations provided in the Pramod et al. paper provide any estimates of IUU, so their numerical estimates must therefore come from two confidential informants. No documentation of how the estimates are made is provided and the paper completely fails to meet normal standards of scientific replicability. The deficiencies in the estimate of IUU in Alaskan Pollock must cast serious doubt on their approach for all fisheries. Illegal fishing is of considerable concern around the world and it is important that public policy be guided by scientific data on the extent of IUU fishing. Pramod et al. [1] estimate the volume of illegal and unreported fish in imports into Japan. They report having done 121 interviews with confidential informants for 27 product categories and cite 191 documents. Each confidential informant was asked a likely average, minimum and maximum IUU contribution. The authors then use an “anchor point and influence table” [2] to estimate the total volume of IUU fish entering Japan. It is almost impossible for any individual to evaluate the reliability of this work overall as it would require knowledge of each of the fisheries and the product chain as it moves from harvest to arrival in Japan. Even among those in industry, the reality at each level of the supply chain is considered proprietary, and kept from those at other levels. This imposes considerable burden on the referee(s) who received the manuscript, to assess whether the method presented led to credible conclusions. However, proper scientific skepticism requires readers to ask about the degree to which the conclusions are corroborated by what is known, and well documented with strong primary data. This would require the authors to present what the confidential informants re- ported and to provide evidence that their confidential informants have knowledge of the product chain. Alaska Pollock is the largest human food fishery in the world, with an average harvest of over 1.3 million tons, and is by far the largest volume item considered in Pramod et al. (122,280 tons reported im- ported into Japan). The authors estimate that 15–22% of this is of IUU origin. As we have deep knowledge of this fishery, we will concentrate on how that estimate of 15–22% is derived. As reported, Pramod et al. appear to use standard methods in con- fidential business research, but implement them poorly by failing to https://doi.org/10.1016/j.marpol.2019.103632 Received 23 May 2019; Received in revised form 25 July 2019; Accepted 26 July 2019 * Corresponding author. E-mail addresses: rayh@uw.edu (R. Hilborn), cmand@uw.edu (C.M. Anderson), Gordon.kruse@alaska.edu (G.H. Kruse), aepunt@uw.edu (A.E. Punt), m.sissenwine@gmail.com (M. Sissenwine), chris.w.oliver@noaa.gov (C. Oliver), jim.ianelli@noaa.gov (J.N. Ianelli), Bobtrumble7@gmail.com (R.J. Trumble), davidagnew99@gmail.com (D.J. Agnew), Nbaker493@gmail.com (N. Baker). Marine Policy xxx (xxxx) xxxx 0308-597X/ © 2019 Elsevier Ltd. All rights reserved. Please cite this article as: Ray Hilborn, et al., Marine Policy, https://doi.org/10.1016/j.marpol.2019.103632