IO, Jakarta – Maritime Affairs and Fisheries Minister Edhy Prabowo has issued Ministerial Regulation No. 12/2020 on the management of lobsters, mud crabs, and swimming crabs in Indonesian territory. Thus, Edhy effectively resumed lobster larvae exports, previously banned under his predecessor, Susi Pudjiastuti. “The export of lobster (Puerulus) larvae with Harmonized System Code 0306.31.10 from the territory of the Republic of Indonesia can only be done with this provision,” stated Article 5 Paragraph 1 of the regulation.
The export provisions include a quota and location of lobster larvae harvesting in accordance with the results of a study by the National Commission on the Study of Fish Resources, set forth by the Directorate General of Capture Fisheries. As a consequence, exporters must farm lobsters in the country by involving the community or local farmers, based on the recommendation of the Directorate General of Aquaculture.
Exporters have succeeded in lobster farming, as indicated by sustainable harvests, and have released two percent of lobsters from farming into the wild (size according to harvest). Lobster larvae exporters must be registered with the Directorate General of Capture Fisheries of the Maritime Affairs and Fisheries Ministries (KKP) and have a Certificate of Origin issued by the district/city local fisheries office.
The lobster larvae can only be obtained from small fishermen registered with the local fishermen group at the location of the capture. Capture is only allowed using passive capture gear. The Director General of Capture Fisheries will decide on who can harvest lobster larvae.
Further, the export of lobster larvae can only be done through certain airports that have been designated by the fish quarantine agency. “Exportation of lobster larvae must be done in line with the availability of stock in nature as per recommendation from the National Commission on Fish Stock Assessment (KAJISKAN) and as determined by the Directorate General of Capture Fisheries,” stated Point (f) Article 5 Paragraph 1.
The lowest benchmark price of fishermen-captured lobster larvae will be determined by the Directorate. This will serve as the basis for consideration and proposed export benchmark prices set forth by the Ministry of Trade. In the future, a decision on the quota and location of lobster larvae harvesting will be carried out every year.
The regulation also states that lobster larvae export is subject to Export Duty or Non-Tax State Revenues per larvae, the value of which will be determined by the Ministry of Finance.
The lobster larvae export resumption, according to the KKP Minister, will help fishermen whose lives depend on the farming of the commodity. In addition, this policy is aimed at reviving lobster farming in many regions. “By allowing the lobster larvae harvesting, we can support fishermen whose livelihood depends on capturing larvae,” said Edhy Prabowo.
Edhy elaborated that exporters must buy lobster larvae from local fishermen at a minimum price of Rp 5,000 per larva. This is higher than the going price before the export was banned. “The price at the farmers level is set at a minimum of Rp 5,000. Previously, they were illegally exported at only Rp 1,000 to Rp 2,000 per larva. Now I want it to be fair. The ministry is hard at work because we have to realise what Pak Jokowi has instructed,” said Edhy during a joint meeting with Committee IV of the House of Representatives in Jakarta, July 6, 2020.
If they are valued at Rp 5,000 per larva, when an exporter buys 100 million larvae, fishermen can earn Rp 500 billion. If they (exporters) violate this regulation, their export license will be revoked. “If a company is found putting a pressure on price, we will immediately revoke its license. The control is very easy because we can know where they are registered, where their office is, and the area where they conduct their business,” he said.
Furthermore, the country will receive income from taxes on lobster larvae exports. “If the price is below Rp 10,000 per larva, they (exporters) will only pay Rp 1,000 in tax. But if it is above Rp 25,000, they can pay up to Rp 5,000 to the state coffer. This is why I decided to allow the export, because if they purchase it, we won’t get any money. And they can’t buy from fishermen anymore, so who will be responsible for their loss of livelihood?” he reasoned.
Edhy emphasized that these regulations are not rigid. If the lobster larvae export regulation needs to be changed one day, he said he is ready to implement it. “This is not a regulation written in stone. If there is a mistake, we will right it. When it becomes a law, there will be checks and balances, controls and corrections. Don’t worry, unlike the previous one, I am not a stubborn minister who will refuse to change it when given advice,” he said.
With regard to the many concerns over lobster extinction should they be exported, Edhy pointed out that one lobster can produce up to 1 million eggs (roe) in the summer. “In a country where summer lasts for only four months, they can spawn up to four times. This is based on research conducted in Tasmania. In Indonesia, we have lots of sun all year around,” he said.
Edhy said that number was higher than his estimate. Rather than being left in nature, where their chances of survival are small. “I am convinced that if we leave the lobsters in nature, only 0.2% can grow into maturity. In other words, only 20% of the exported larvae will grow into adulthood. In contrast, if we farm them it can reach 30% and this can be done traditionally,” he explained.
Separately, Politician and former Deputy Speaker of the House Fahri Hamzah agreed with Edhy’s policy. According to him, fishermen welcomed this policy with great joy because it will revive their enterprise and a tradition of catching lobster larvae that has been going on for generations. “Since elementary school I have witnessed fishermen catching larvae in the sea like groupers and lobsters. I always looked forward to lobster-spawning season with excitement which extend to entire fishing communities. Therefore, this policy should be supported by the government, in this case Minister Edhy, must communicate well so that it is well received by the public,” Fahri explained.
“My argument is how can we allow extraction of minerals which is formed after millions of years from the crust of our green earth, while we ban the harvesting of lobster larvae that are spawned every day where one lobster can produce thousands of larvae? How can we allow mining which needs heavy equipment to be funded by conglomerates while we forbid lobster larvae harvesting that can be done with simple equipment made of cement paper by our fishermen? How can we ban something that provides a livelihood to hundreds of thousands of our fishermen on our coastline while allowing destructive mining industry which only enriches a small clique of people with massive capital? This is an important argument that we should forward to the Minister,” he continued.
This policy should form an ecosystem and it should be under discussion that there are no healthy fishermen if there are no risk-taking entrepreneurs. Let’s not forget that the fishermen live by cash and carry. But traders or collectors, both for farming and trading also take a big risk, because the transportation of lobster larvae from the sea to the farm let alone overseas carries a risk of becoming damaged, changing color to yellow or black which lowers the price or even the death of the larvae which renders them worthless. So the risk taken by entrepreneurs is a key element in the whole ecosystem of a healthy lobster farming supply chain.
So we must look at this policy, in the interests of fishermen and the ecosystem. “I would defend this export argument as benefitting the fishermen first. Then it would also generate non-tax state revenue (PNBP) which otherwise would not happen when there is a black market, because it will be a prevalence for bribery. This is more destructive. So, I think with the formal opening of the larvae export will hopefully discourage smuggling and enable the country to generate additional tax revenue. So I hope Minister Edhy can argue from a scientific standpoint, get the message across to the public, especially those who are not fishermen,” Fahri advised.
Fahri continued, lobster larvae export is a natural consequence of the lobster harvesting conducted by Indonesian fishermen for generations. These fishermen, estimated to be around 150,000, live on Indonesia’s massive coastlines and harvest lobster larvae using a simple piece of equipment called “pocong”. They scatter the net pouch covered by used cement wrapper which they cut up and shape like a fan them along the coastline before sunset. The pouches are then submerged so that lobster larvae will attach themselves to it. The following day after dawn prayer, the pocong are collected and they can sell the catch of the day to survive. That’s why they need buyers, i.e. the lobster farmers. After the farmers have enough of what they need, the remainder can be sold to other countries, because there is a huge demand. “So this is a policy that should be taken long ago because that is the life cycle of Indonesian lobster fishermen from a long time ago and we all must be thankful that finally what those fishermen dream of has been restored,” he said.
Extinction is fictitious
Based on a study, only 0.2% of lobster larvae are able to survive in the wild, because 99.8% would be killed by the sweeping currents or eaten by fishes that mistake them for plankton. If they are caught by fishermen it’s kind of being rescued, lifted, bred, kept and sold to be raised and a year later they become mature and consumable. This is valid research that must be defended by the government as the policymaker. On the positive note, fishermen can improve their welfare and lobster larvae can also make it to maturity.
“In response to the argument that if lobster larvae are exported, they will become extinct, on the contrary the research says that harvesting larvae from the wild will save them. Scientific arguments must take precedence. I’m afraid that the policy of the previous Maritime Affairs and Fisheries Minister was not made based on science but instead of particular interest. Scientifically, the extinction of lobster larvae is a fiction. We eat lobster very rarely, but we eat beef and mutton almost every day but there is no looming extinction of cows and goats. So, we must look at it from the scientific standpoint,” said Fahri.
Lobster researcher Bayu Priambodo explained that the future of provisions, including seafood, will come from aquaculture. The future of lobsters is in the farming of the crustacean. However, people need to know that it involves a complex process; thus, we need to build a supply chain from upstream to downstream. Lobster farming is unique, including in the “partial life-cycle farming”, meaning that the supply of larvae still relies on natural catches, which is then used for the breeding industry.
According to Bayu, many people still think that if you harvest lobster larvae from nature, it will lead to extinction. This way of thinking is inaccurate. On the contrary, it is precisely what causes extinction if egg-carrying female lobsters are caught. Captured larvae will not disrupt its life cycle. Lobsters spawn every year, in the range of tens of thousands to millions of eggs. One female lobster can spawn at least twice per year, and the number of eggs depends on the type and weight of lobster. For example, female pearl lobsters weighing 2 kg can produce up to 3 million larvae.
To manage this lobster resource, we must understand the biological and ecological aspects of the species itself. In the nature, once the eggs hatch into larvae, they are fully at the mercy of ocean current movement. The distribution of lobster seeds in nature is divided into two, namely non-sinking (source) and sinking population. The so-called non-sinking population is the spread of lobster seeds throughout Indonesian waters. But they are in low abundance. This population correlates very strongly with the adult population. That is, from every 1,000 lobsters larvae, only one will grow into an adult. With non-sink population, technically they cannot be caught because they are spread out and is in low abundance. In contrast, sinking population is lobster seeds that are in very high abundance and are concentrated in limited areas. This sinking population occurs due to natural phenomena, such as local current patterns and natural conditions in the region, making the lobster larvae gather at certain points in a very high density, but the adult population is very small. Like that in southern Java sea and Southwest Nusa Tenggara.
Lobster seeds that are unlikely to become extinct are the ones caught from the sinking population, because it does not supply a significant adult lobster population. Surely when we talk about species extinction, we must refer to the authority in this field namely the official international institution called The International Union for Conservation of Nature (IUCN). This body regularly issues a red list of endangered species. And lobsters are included in the low-risk category (Least Concern – LC). That is a category designated by IUCN for species which does not belong in any of the other categories.
In the animal trade regulation which refers to the CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) consensus which has the authority to regulate trade of endangered animals and plants, lobster is not included in the Appendix II, meaning that lobster can still be widely traded. So, we should not be surprised if all over the world lobsters are traded freely. The fact that there are regulations such as when to catch, minimum size and species that can be caught, these are all managed for the sake of sustainability. So the paradigm should be to regulate, not prohibit.
Bayu explained, as a rough estimation, that to farm lobsters in a square plot of net requires 200 seeds. The number of bamboo rafts (karamba) in Indonesia, the highest of which is in Lombok is 6,750 plots (as of March 2020). This means that the seeds needed for the aquaculture industry amount to at least 2 million per year. In comparison, the supply of lobster seeds in nature is not more than 1 million larvae per day. In other words, it would only take two days to meet the domestic lobster farming industry needs for larvae.
“For the past five years, lobster farming in Indonesia has been banned. Thus, the capacity of lobster farming in Indonesia certainly still needs to be increased. The farmers’ level of technical skills and mentality also needs to be upgraded. When compared with that of Vietnamese lobster farmers, who have been farming lobsters for 30-35 years, surely we must acknowledge the superiority of lobster farmers in our neighboring country,” Bayu said.
Currently, the supply of lobster seeds is 365-416 million per year but domestic demand is only 2 million per year. Meanwhile, there is a huge export market and many of our fishermen need to earn a livelihood. “I would say that the development of domestic farming is definitely priority number one because the future of food supply is in aquaculture. But of course we must also be realistic. To build an aquaculture industry, especially lobster, is not something that can be done overnight. It is impossible to have lobster farming without a feed industry and building the knowledge and skills of the farmers. Not to mention, not all places are suitable lobster farming,” Bayu argued.
Today, the feed for lobster farming still relies on natural feed. In the future, artificial feed manufacturers are certainly needed in developing the country’s lobster farming industry. A good lobster feed consists of three types – trash fish, crustaceans and molluscs. The composition will vary according to the size of the lobster being farmed. When the lobster seeds are still small, they must be fed a lot of crustaceans with a composition of 60% over trash fish. When they weigh around 50 grams and above, the percentage of trash fish will be increased. The time it takes to grow, from larvae to about 200 -300 grams (ready for consumption) is 12-14 months.
Another challenge is the FCR (Feeding Conversion Ratio). Lobster FCR is very high, ranging from 16 to 25. Or you can say the average is 20. That is, to produce 1 kg of lobster, you will need 20 kg of feed. Imagine, if you are going to produce 1,000 tons of lobster, you have to prepare 20,000 tons of feed during the growth cycle.
Regarding the implementation of ministerial regulation No.12/2020 on the development of farming and export of lobsters larvae, would-be exporters are required to farm in a sustainable fashion and restock 2% of the population (higher than previously minimum 1%). The ceiling and floor price of lobster seeds from fishermen has also been set.
With the resumption of the lobster seed export in the era of Minister Edhy, anyone could register for export, including cooperatives, but before that they have to farm the lobster first and meet other requirements. “I myself who grew up with lobster fishermen and lobster farmers only wish for one thing, that they should be the ones who greatly benefit from this natural resources, which can generate prosperity for our people, especially fishermen and the coastal communities. Let’s end this prolonged polemic, focus our energy on developing lobster cultivation in the country through concrete steps. We hope that in the near future we can gradually increase the demand for lobster seeds to supply the domestic lobster farming industry and the rest can be exported,” he said optimistically. (Dessy Aipipidely and Ekawati)