Memorandum submitted by the Marine Conservation
Society (SFS 11)
Fish are not only a vital part of the marine
ecosystem but also a healthy source of protein providing essential
fatty acids, vitamins and minerals for billions of people. Globally,
fisheries supply over 2.6 billion people with at least 20%
of their average protein intake. Currently the UK is not well
placed to respond to the anticipated challenges of increasing
global seafood production of 50% by 2030, or doubling it by 2050,
whilst ensuring production is sustainable. Around the British
Isles only eight out of 47 fish stocks are known to be in
a healthy state, and thus the UK faces a serious challenge to
secure food supplies sustainably from the marine environment.
Overfishing, discarding, single species management, lack of the
precautionary principle, underreported fishing, and the pressures
from aquaculture feed supply all threaten the future sustainability
of our fisheries. Defra has a fundamental role to play in addressing
the weaknesses that have resulted in the current poor health of
our marine food resources. It is vital that through increase research,
development, and monitoring of our fisheries as well as advocacy
and engagement with European and International bodies on fisheries
policy, Defra ensures that the exploitation of our marine fisheries
is sustainable.
The importance of seafood
1. Globally, fisheries supply over 2.6 billion
people with at least 20% of their average protein intake.[49]
In addition, seafood provides essential fatty acids, vitamins
and minerals, which are integral to a health diet.
2. In order to maintain current levels of
fish consumption for an expanding world population, the Food and
Agriculture Organisation (FAO) predict an additional 37 million
tonnes of fish per year will be needed by 2030.[50]
3. The Food Standards agency recommends
we consume at least two portions (140g) of fish a week, one of
which should be an oily fish. However at present, current consumption
is well below these guidelines (63g/person oily fish consumed
per week, 115g/person white fish consumed per week[51]);
consequently, UK consumption of fish would need to double to meet
the agency's advice. This equates to an extra 33 million
portions of oily fish a week alone based on the current population;[52]
with the expected population increase in the next 20-40 years,
we can anticipate an even greater demand for seafood in the future.
4. Although the UK is one of the main capture
fisheries producers in the EU, most of our seafood is imported
(560,700 tonnes in 2002[53]),
therefore it is vital that the UK engage with European and international
bodies, on fisheries and food policy to ensure food security for
2050.
Do we have enough fish?
5. Over 70% of the world's fish species
are either fully exploited or depleted; in the EU 88% of stocks
are overfished, compared with 25% on average globally,[54]
and around the British Isles only eight out of 47 stocks
are known to be in a healthy state.[55]
The current state of our fish stocks simply cannot meet an increasing
demand.
6. The UK's own independent government department
the Food Standards Agency is having to reviewing its advice on
fish consumption to take into account sustainability issues due
to the mismatch between how much fish we should be consuming and
how much fish is actually available due to declining fish stocks.
7. Overfishing is widely acknowledged as
the greatest single threat to marine wildlife and habitats, but
now it threatens our food security. The biomass of cod in the
North Sea has fallen from 250,000 tonnes in 1970 to
just 37,000 tons in 2007.[56]
Species such as common skate, angel sharks, Atlantic halibut,
which were once common in the North Sea, are now considered to
be critically endangered.
8. As well as the problem of overfishing,
the issue of by-catch and discards is significantly threatening
the health of our fish stocks and the marine environment. These
are fish and other organisms that are caught accidentally in fishing
gear and are thrown back in the sea. For example major demersal
trawl fisheries in the EU are estimated to discard 70-90% of catch
in number, which is an unacceptable waste of societal resources.
Discards also affect the long term future of a fishery- the mortality
of mature adults reduces the number of fish able to support future
productivity, and the discarding of juveniles reduces the future
catch opportunities as well as future yield. The estimate cost,
in terms of future catch, of discarding unwanted fish in the UK
is over 40% of the total annual value of the fishery.[57]
9. Poor management is in part to blame for
the decline in our fisheries and consequent reduction in future
food security: As part of the Common Fisheries Policy, "Total
Allowable Catch" (TAC) for each commercial species is set,
to protect our fisheries from this over-exploitation, however
these TAC's are often set 30% higher than levels recommended by
the scientists[58]
which compromises the long term security and sustainability of
supply.
10. Illegal, Unregulated Unreported (IUU)
fishing also threatens the sustainability of our fisheries. Poor
compliance to regulatory controls simply undermines the purpose
of these measures: to protect the future of our fisheries. For
example, misreporting catches may appear beneficial to the individual
in the short-term, via economic gains (by landing more of a species
than is permitted), however this threatens long term yields because
it reduces the accuracy of stock assessments which monitor the
health of our fisheries and are used in the management of this
resource.
The role of aquaculture
11. Aquaculture is and will be relied upon
to fill the seafood gap between supply and demand; currently aquaculture
supplies 43% of global seafood, a figure expected to rise to 50%
within the next 10 years.[59]
Aquaculture is the fastest growing food producing sector, growing
on average 8.8% per annum since 1970, compared to 1.2% for capture
fisheries and 2.8% for terrestrial farmed meat. Declines in wild
capture fisheries resources, economics and the increasing demand
for seafood has encouraged the aquaculture sector to expand, but
there are a number of issues, predominantly the increased demand
placed on wild capture fisheries as a protein source for aquaculture
feed, which threaten its future sustainability.
12. Two of the top five seafood species
we eat in the UK are farmed—salmon and warm water prawn,
both of these species are carnivorous and rely on wild capture
fisheries to provide their food. Current food conversion ratios
for both of these species illustrates that their production results
in a net loss of ocean biomass. It is therefore essential that
the species used to make fish feed are sustainability managed
and the precautionary principle be applied to these many non-assessed,
and poorly understood fisheries.
13. This supply of fishmeal and fish oil
needs to be substituted with alternative protein sources to allow
the aquaculture industry to expand to meet this growing demand.
Protein sources such as porcine blood meal, vegetable protein
and ragworm should be used, as should alternative oil sources
such as linseed and other vegetable oils. Support and encouragement
should be given to fish farmers that diversify into farming omnivorous
and herbivorous species such as tilapia and catfish that do not
rely on wild caught fisheries.
The solutions
14. Although the sustainability of our fisheries
is a global issue, the UK has an integral role to play in protecting
the future security and sustainability of this resource. Consequently
Defra has an imperative responsibility to address the weaknesses
that have been identified above.
15. The Marine Conservation Society firmly
believes in the need for effective implementation of ecosystem-based
fisheries management under developing UK marine legislation, the
reformed Common Fisheries Policy and all other relevant International
and regional fisheries management organisations. The ecosystem-based
approach considers the affect of fishing on biodiversity, habitat
structure, endangered species and water quality as well as fish
stocks. The overall aim is to maintain healthy ecosystems and
the fisheries they support. All management decisions should be
based upon the precautionary principle, whereby measures are designed
to take account of uncertainty in scientific advice and the likelihood
of whether or not an activity may cause significant harm to the
environment.
16. A greater shift away from current quota-based
methods of fisheries management and towards effort-based schemes
is needed (e.g. restrictions on licences, days at sea, fishing
gear types and size, engine power etc), particularly for mixed
species demersal fisheries. Quota based fisheries management has
clearly failed to adequately deal with the complexity of mixed
species fisheries in Europe, and inherent uncertainties in fisheries
science and stock assessment. Total allowable catches will still
need to be set, but only as a safeguard against unforeseen increases
in fishing efficiency. All management measures should be designed
to restore/maintain the spawning stock biomass of commercial fish
species above precautionary limits. Strong UK representation and
engagement at the European Fisheries Council, which puts scientific
advice before political pressure, will help to ensure that TAC's
are better aligned with scientific recommendations, and thus help
to recover and protect our commercial fish stocks.
17. A number of technical conservation measures
need to be applied at European level to conserve our threatened
fisheries, and through advocacy and engagement with our European
partners, the UK can ensure they are executed. However the UK
can lead the way through legislation and by encouraging voluntary
measures; increased development and more extensive and/or mandatory
use of selective and environmentally sensitive fishing gear and
practices would significantly aid the recovery of our most threatened
stocks. This includes legislating for net mesh sizes that adequately
reflect the size of maturity of all species being targeted (allowing
individuals to breed at least once), especially in mixed whitefish
fisheries. Increased and more widespread use of spatial/temporal
closures to protect biologically important areas such as spawning
and nursery grounds and essential fish habitat, and to help restore/maintain
stocks above precautionary limits. Greater use of total seasonal
closures for specific fisheries should also be encouraged to protect
species during key spawning periods. Spatial closures and gear
restrictions can also offer conservation benefits through helping
to reduce physical impacts on sensitive/vulnerable marine communities
and habitats
18. Progressive changes in fisheries legislation
that moves towards a ban on the discarding of commercial species
of fish and shellfish are required to ensure the future of our
fisheries resources. This should discourage selective grading
of catches towards high value species/individuals, incentivise
the development of more selective fishing methods and gear, and
reduce uncertainty in fisheries data and stock assessments.
19. Defra has a responsibility to effectively
monitor, maintain and recover depleted fish stocks surrounding
the UK, but with just eighth of the 47 known stocks around
the British Isles being in a healthy state, much more needs to
be done. Monitoring of commercially exploited species around the
UK is seriously lacking, with 47% of the stocks in an "unknown"
state. In addition, there are a number of fish and shellfish species,
which are not monitored because they are not "pressure-stocks",
yet they could be, at sustainable levels, able to contribute to
our future seafood demand.
20. Many of these under-utilised species,
the Marine Conservation Society recommends to consumers to help
alleviate the pressure of the well-known stocks, which are currently
in a poor state. Often these species are cheaper than the usual
fish consumed, and this is important, as affordability is just
as important an aspect of food access as food availability. Consequently
more resources need to be applied to effective assessment and
monitoring of the health of all fish stocks (pressure and non-pressure)
around the British Isles, to ensure the sustainability of our
fisheries, alternative seafood sources for the future and thus
the security of our seafood supplies by 2050.
21. With regards to aquaculture, it is essential
that the species used to make fish feed are fully assessed, sustainability
managed and the precautionary principle be applied to the poorly
understood, data deficient fisheries. Defra has a role to play
in encouraging the supply of fishmeal and fish oil be augmented
with sustainable alternative protein sources thus allowing the
aquaculture industry to expand to meet this growing demand.
January 2009
49 The state of the Worlds Fisheries and aquaculture
2004. Food and Agriculture Organization 2004. ISBN 92-5-105177-1. Back
50
The role of aquaculture in sustainable development Thirty-fourth
session, Rome, 17-24 November 2007. Food and Agriculture Organization.
C/2007/INF/16. Back
51
Food Standards Agency public written consultation. 6th January
2009. NUA 16/234 Back
52
Twenty-fifth report of the Royal Commission on the Environmental
Pollution "turning the Tide" 2004. Back
53
Seafish Indsutry Authority: http://www.seafish.org/land/chain.asp?p=fb204 Back
54
European Commission: policy statement proposes major changes in
fisheries management regimes for 2009. Back
55
Defra (2008) UK Biodiversity Indicators: sustainable fisheries. Back
56
ICES (2007) species advice for cod in Subarea IV (North Sea),
Division VIId (Eastern Channel) and Division IIIa (Skagerrak) Back
57
Covery. R & Laffoley D.d'A (2002) Maritime State of Nature
Report for England: getting on to an even keel. Peterborough,
English Nature. Back
58
Twenty-fifth report of the Royal Commission on the Environmental
Pollution "turning the Tide" 2004. Back
59
Status and important recent events concerning international trade
in fishery products. Committee on fisheries sub-committee on fish
trade, eleventh session, Bremen Germany, 2-6 June 2008. Back
| 
