Environmental Audit CommitteeWritten evidence submitted by the Marine Reserves Coalition

This submission is supported by the following Marine Reserves Coalition members:

BLUE Marine Foundation.

ClientEarth.

Greenpeace UK.

Marine Conservation Society.

Zoological Society of London.

Executive Summary

The most significant recent initiative concerning the conservation of biodiversity in the UK Overseas Territories was the designation of the Chagos Marine Reserve in April 2010.

Marine reserves are the most strictly protected type of marine protected area (MPA), in which all extractive and potentially damaging activities are prohibited. Marine reserves are now widely recognised as an effective and important tool in global marine conservation efforts.

Well managed marine reserves should be integrated into marine planning in all of the UKOTs, to ensure the protection of biodiversity and sustainable management of marine resources throughout the entirety of seas under UK jurisdiction.

It is widely accepted that healthy ecosystems are better placed to cope with the impacts of climate change, and effectively managed marine reserves are a mechanism by which we can achieve healthy and functional ecosystems.

The best-practice approach to conserving the marine environment (including representative areas of habitat and areas of ecological/biological significance) is to protect areas before threats or damage occur (in a proactive rather than a reactive manner), in accordance with the precautionary principle and ecosystem-based management.

There continues to be a lack of clarity within the Department for Environment, Food and Rural Affairs and the Foreign and Commonwealth Office, as to who holds responsibility for marine biodiversity in the UK Overseas Territories.

Introduction

1. The Marine Reserves Coalition (MRC) is a group of six UK-based organisations1 dedicated to the task of protecting marine resources by the creation of highly protected marine reserves, in concert with other management strategies where appropriate. Focusing on seas under UK jurisdiction, we encourage the UK government to commit to establishing ecologically representative networks of marine reserves throughout all UK waters by 2020. We are extremely pleased that the Environmental Audit Committee (henceforth the Committee) has decided to conduct an inquiry into sustainability in the UK Overseas Territories (UKOTs). Given that over 90% of the UK’s total biodiversity is found in the UKOTs, we consider this issue to be of the utmost importance and we look forward to the Committee making robust recommendations to ensure that the UK and Territory governments are delivering accordingly.

2. As the MRC is primarily concerned with protection of the marine environment, our comments will focus on marine conservation and marine biodiversity in the UKOTs.

3. The biodiversity and productivity of the world’s ocean is diminishing at an alarming rate. Globally 90% of large fish species, such as sharks, tuna and swordfish, have disappeared in the last few decades2 and many marine habitats have been fundamentally altered by destructive fishing practices and other human activities.3 Marine Protected Areas (MPAs) are an effective and key tool in the conservation of marine biodiversity.

4. Despite commitments from the 193 countries that are Parties to the Convention on Biological Diversity, to protect 10% of coastal and marine areas by 2020, there has been limited implementation and ambition from the world’s governments. Currently, MPAs cover just 2.3%4 of the ocean and only a tiny fraction of these are highly protected marine reserves (or no-take areas).

How the UK government is fulfilling its responsibilities to protect biodiversity in the UKOTs

5. The UK has the fifth largest marine area in the world under its jurisdiction, and as such has a responsibility and an opportunity to become a global leader in the stewardship of marine biodiversity.

6. The UK government’s lack of support for the conservation of biodiversity in the UKOTs was criticized in the Committee’s UN Millennium Ecosystem Assessment report,5 published in January 2007 (paragraph 126–141 and conclusions 31–33), and again in the Committee’s Halting biodiversity loss- report,6 published in October 2008 (paragraphs 39–47 and conclusions 11 and 12).

7. The criticisms contained in the 2007 report were endorsed in the Foreign Affairs Committee’s report on the Overseas Territories published in June 2008,7 which also stated, “We conclude that given the vulnerability of Overseas Territories’ species and ecosystems, this lack of action by the government is highly negligent. The environmental funding currently being provided by the UK to the Overseas Territories appears grossly inadequate and we recommend that it should be increased.”

8. Both the importance of the biodiversity in the UKOTs and the lack of UK government support at that time for its conservation have thus been well established and are taken in this submission as read.

9. The most significant recent initiative concerning marine biodiversity in the UKOTs was the designation of the Chagos Marine Reserve, announced by the then Foreign Secretary, David Miliband in April 2010. At 640,000 km², Chagos is the largest fully protected marine area in the world (detailed further in paragraph 19). The Foreign and Commonwealth Office (FCO) received private funding from the Bertarelli Foundation to assist enforcement of the Chagos Marine Reserve in the first years of establishment.

10. Although the level of financial support provided by the UK government remains inadequate against the needs of the unique and often vulnerable biodiversity found in the UKOTs, we do note that this level has been maintained in the face of significant budget cuts. We refer you to the response of the Pew Environment Group to this inquiry (paragraphs 7–14) for further detail on this point.

Whether the recommendations in the Committee’s 2008 Report, Halting biodiversity loss, on safeguarding biodiversity and practising joined-up government to further conservation have been implemented

11. In the Committee’s report four recommendations were made concerning the UKOTs. These were that the government must:

“Adopt a truly joined-up approach to environmental protection the UKOTs and Crown Dependencies, by bringing together all relevant departments including the FCO, MoJ, DfID, Defra, DCMS and MoD with the governments of the UKOTs;

Make better use of the Inter-Departmental Group on biodiversity to provide more oversight and support for the development and implementation of effective environmental protection policy in the UKOTs, and expand the Group to include other relevant departments;

Have Defra assume joint responsibility for the UKOTs, and reflect this in future spending settlements; and

Address the dire lack of funds and information for environmental protection in the UKOTs. An ecosystem assessment should be conducted in partnership with each UKOT in order to provide the baseline environmental data required and to outline the effective response options needed to halt biodiversity loss. (Paragraph 46).”

12. Our comments here focus on the last two of these recommendations. In our view there is no evidence that Defra has assumed joint responsibility for the UKOTs and there continues to be a lack of clarity, even within Defra, on who holds responsibility for marine biodiversity in the UKOTs; is it the marine team or the biodiversity team? The government’s White Paper on the UKOTS, “Security, Success and Sustainability”,8 published in June 2012, clearly states that there should be a coordinated response to natural environment issues with “each Department leading in their respective areas of responsibility” (chapter 3, page 43). Departmental expertise in marine biodiversity clearly lies with Defra, not the FCO, yet it is not at all apparent that Defra is taking the lead in this area.

13. Whilst Defra, the FCO and the Department for International Development (DFID) have made limited, but certainly not sufficient, funds available for conservation in the UKOTS, the Department for Culture, Media and Sport (DCMS) has unfortunately not helped to make National Lottery money available to the UKOTs, despite frequent requests to do so and despite having lead responsibility in the UK for a number of World Heritage Convention sites in the UKOTs. Policy directions of the DCMS are established by The Secretary of State for Culture, Media and Sport, and therefore would appear to be entirely changeable, should they wish to assist the UKOTs.9 From their lack of action, it appears clear that they have decided not to do so. To all those who care about assisting the UKOTs with the conservation of their heritage, this lack of action by the DCMS symbolizes the continuing lack of interest in government departments in assisting the Territories.

How the introduction of “Marine Protected Areas” could safeguard the marine environment in the uninhabited territories

14. The term “MPA” covers a broad range of protection levels in the marine environment and is often used to describe areas that have been set up for purposes other than biodiversity conservation, such as fisheries management. This has led to over-estimates of global MPA coverage and an inflated sense of how much of the ocean is protected. Recent guidance published by the IUCN,10 aims to tackle this issue and defines a protected area as; “A clearly defined geographical space, recognised, dedicated and managed, through legal or other effective means, to achieve the long-term conservation of nature with associated ecosystem services and cultural values. This definition will make it much harder for actions that involve exploitation, such as fisheries, to be claimed as MPAs that protect the ocean. If marine areas involve extraction and have no defined long-term goals of conservation and ocean recovery, they are not MPAs.”

15. Marine reserves are the most strictly protected type of MPA, in which all extractive and potentially damaging activities are prohibited. Marine reserves are now widely recognised as an effective and important tool in global marine conservation efforts and have been shown to protect vulnerable species and habitats, as well as build the ocean’s resilience to significant emerging threats such as climate change.11 ^, 12 ^, 13 When established and managed properly, marine reserves can benefit people as well as the environment, by helping to rebuild depleted fish stocks that billions of people worldwide depend on for both income and protein.14

16. The MRC is calling for the designation of highly protected marine reserves throughout the UKOTs, as these areas are more effective than multi-use MPAs:

(a)They provide a greater benefit to ecosystem recovery than multi-use areas;15

(b)Allowing certain activities to continue within protected areas often leads to a marked increase in those activities, affecting the natural balance of the ecosystem;16

(c)Protecting the entire reserve makes it much easier to police and manage; if anyone is seen operating fishing gear, or carrying out any other extractive activity in a reserve, they can be prosecuted; and

(d)The cost of enforcement is lower for fully protected sites than for multi-use areas.17

17. We welcome this inquiry’s specific examination of how the introduction of MPAs could safeguard the marine environment. However, we are disappointed the inquiry only extends to the uninhabited UKOTs. Well managed MPAs and highly protected marine reserves should be integrated into marine planning in all of the UKOTs, to ensure the protection of biodiversity and sustainable management of marine resources throughout the entirety of seas under UK jurisdiction.

18. The two “uninhabited” UKOTs; the British Indian Ocean Territory (BIOT) and South Georgia and the South Sandwich Islands (SGSSI) both already have MPA designations in place; the highly protected Chagos Marine Reserve in the BIOT and the only partially protected “multi-use” SGSSI MPA. The government of SGSSI is currently considering proposals for further protection within the SGSSI MPA (see paragraphs 20–21). It is our view that there is considerable scope to significantly extend the SGSSI MPA measures, giving full protection to the entire South Sandwich Islands area of the Exclusive Economic Zone, and also to sizeable areas around South Georgia.

19. The designation of the Chagos Marine Reserve in 2010 (the campaign for which MRC member organisations played a key role in), was a milestone in marine protection, both in the UK and globally. The Chagos Marine Reserve remains today the largest highly-protected, no-take marine reserve in the world, covering 640,000km². The waters around Chagos have the largest and some of the most diverse undisturbed reefs in the Indian Ocean and are home to the world’s biggest living coral structure; the Great Chagos Bank, with over 220 coral species (almost half the recorded species of the entire Indian Ocean) and more than 1,000 species of reef fish. The designation of the Chagos Marine Reserve has resulted in increased international interest and innovative scientific research being undertaken in the area.

20. In February 2012 the government of SGSSI announced the designation of the SGSSI MPA; the largest multi-use MPA in the world covering 1.07 million km². Although this was a welcome announcement, the current MPA designation provides only limited protection and the area is managed primarily as a commercial fishery for toothfish, icefish and krill. The “multi-use MPA” designation meant that only 20,000km² (just 2% of the total MPA area) was fully protected within no-take zones, with the remaining 98% only partially protected. This is inadequate given that the marine environment of SGSSI is home to one of the most important and rich concentrations of marine wildlife on earth, with more than four million fur seals, as many as 100 million seabirds and a population of whales that is slowly recovering from the severe depletions caused by commercial whaling.

21. We welcome the recent proposals18 of the government of SGSSI for further protection within the MPA and believe that significantly greater and more meaningful protection can be achieved for relatively little “cost” to the UK.19 The Pew Environment Group estimates that fully protecting a large marine area in SGSSI would cost between £200,000 and £500,000 per year depending on the extent of the action taken. Furthermore, almost the entire current fishery income in SGSSI of £3–4 million a year could be earned from a sustainable fishery zone covering no more than 20% of the area, whilst fully protecting at least 80% of the area.

22. It is often argued that there is no (or very limited) advantage to setting up new MPAs in areas where little or no human activity currently takes place, as these areas are not deemed “at risk”. There are a number of reasons why we disagree with this line of thinking.

23. Firstly, this approach of “do nothing until after damage has occurred” is what, in general terms has led to the current situation of the continued loss of biodiversity on a global scale. The best-practice approach to conserving the marine environment (including representative areas of habitat and areas of ecological/biological significance) is to protect areas before threats or damage occur (in a proactive rather than a reactive manner), in accordance with the precautionary principle and ecosystem-based management.

24. Secondly, experience has shown that by the time future pressures arise, protection is considerably more difficult (or even impossible) to achieve. This is due to pressure from new interests.

25. And thirdly, there are wider implications to consider than simply the direct impacts on a specific area. As the global ocean comes under increasing threat from pollution, climate change, ocean acidification, coral bleaching, sea temperature rises and invasive species, having areas safeguarded against human activity will become ever more important. As well as protecting the biodiversity within their boundaries, marine reserves help to support the wider marine environment, and they provide us with important reference points against which to benchmark other areas of the ocean.

26. The government’s White Paper on the UKOTS (June 2012) recognises the vulnerability of the Territories to the impacts of climate change. It is widely accepted that healthy ecosystems are better placed to cope with these impacts, and effectively managed marine reserves and MPAs are a mechanism by which we can achieve healthy and functional ecosystems.

27. The UKOTs remain largely unknown to many UK residents. Creating MPAs and marine reserves will raise the profile of their rich and unique natural environments, leading to positive recognition by many who otherwise may not have heard of the Territories. Furthermore, it would demonstrate that the UK government takes its responsibility for the UKOTs (and their biodiversity) seriously and is committed to safeguarding these areas for future generations.

Recommendations

28. The UK government should enter a dialogue with the Overseas Territories with a view to establishing well-managed, enforced and monitored networks of highly protected marine reserves throughout all waters under UK jurisdiction.

29. The UK government should look to implementing previous recommendations to ensure there is a joined up approach to sustainability in the UKOTs throughout all government departments, with Defra and DCMS taking a more proactive lead in the conservation of marine biodiversity throughout the UKOTs.

30 November 2012