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 8 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[1]. 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[2].


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[3]); 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[4]; 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[5]), 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[6], and around the British Isles only 8 out of 47 stocks are known to be in a healthy state[7]. 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[8]. 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[9].


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[10] 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[11]. 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 8 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

[1] The state of the Worlds Fisheries and aquaculture 2004. Food and Agriculture Organization 2004. ISBN 92-5-105177-1

[2] The role of aquaculture in sustainable development Thirty-fourth session, Rome, 17-24 November 2007. Food and Agriculture Organization. C/2007/INF/16

[3] Food Standards Agency public written consultation. 6th January 2009. NUA 16/234

[4] Twenty-fifth report of the Royal Commission on the Environmental Pollution "turning the Tide" 2004

[5] Seafish Indsutry Authority:

[6] European Commission: policy statement proposes major changes in fisheries management regimes for 2009

[7] Defra (2008) UK Biodiversity Indicators: sustainable fisheries

[8] ICES (2007) species advice for cod in Subarea IV (North Sea), Division VIId (Eastern Channel) and Division IIIa (Skagerrak)

[9] Covery. R & Laffoley D.d'A (2002) Maritime State of Nature Report for England: getting on to an even keel. Peterborough, English Nature

[10] Twenty-fifth report of the Royal Commission on the Environmental Pollution "turning the Tide" 2004


[11] 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.