Environmental Audit CommitteeWritten evidence submitted by the Pew Environment Group

Executive Summary

There have been a number of significant initiatives concerning the conservation of biodiversity in the UK Overseas Territories (UKOTs) since the Committee last looked into this issue. These include the declaration in April 2010 of the largest fully protected marine reserve in the world in the British Indian Ocean Territory (BIOT), and programmes to remove rats from Henderson (in the Pitcairn Islands), and from South Georgia.

Finance for conservation in the UK Overseas Territories remains wholly inadequate, but given the savings found elsewhere in Government budgets, it is notable that the value of total support to biodiversity conservation in UKOTs has been at least maintained or possibly slightly increased.

Aside from BIOT, South Georgia and the South Sandwich Islands, and the Falklands, there is no marine monitoring or enforcement capacity in any of the other UKOTs. Despite this, fisheries licenses are granted in many of these areas. This complete lack of any monitoring or enforcement invites illegal and unregulated fishing and does not represent sound governance either in terms of biodiversity conservation or of economic development.

The UK has a number of Territories which have no (British Indian Ocean Territory, and South Georgia and the South Sandwich Islands) or very small resident human populations (Pitcairn, and Tristan da Cunha). Each of these territories also has an exceptionally large marine area, which is far less biologically degraded and over-exploited than most other areas of the world.

These territories give the UK an extraordinary opportunity to take a lead in international marine conservation by creating extensive fully protected marine reserves that will ensure that the remarkable marine biodiversity of these areas persists for the future. This would also make a significant contribution to meeting the globally agreed target of protecting 10% of the world’s coastal and marine habitats by 2020.

Introduction

1. The Pew Environment Group is the conservation arm of The Pew Charitable Trusts, a US based non-governmental organisation that works globally to establish pragmatic, science-based policies that protect our oceans, preserve our wildlands, and promote clean energy. We have offices in Australia, the UK , Belgium and the United States.

2. Global Ocean Legacy, a project of the Pew Environment Group and its partners, aims to establish very large, fully protected marine reserves where fishing and other extractive activities are prohibited. We work with local citizens, governments and scientists around the world to protect and conserve some of the Earth’s most important and unspoiled marine environments. Since the UK has the fifth largest marine area of any country on earth (a total of 6,793,928 km2), most of which is in the UK’s Overseas Territories , Global Ocean Legacy has a work programme, established in its London office, to promote better marine protection in the UKOTs.

3. Better marine protection is essential to the conservation of marine biodiversity and to help rebuild the productivity of the oceans. Despite commitments from the 193 countries that are Parties to the Convention on Biological Diversity (CBD) to protect 10% of coastal and marine areas by 2020, especially areas of particular importance for biodiversity and ecosystem services, there has only been limited progress. Indeed this target, when originally established, was intended to be achieved by 2012, but to date only 3.2% has been partially protected and of this, less than 1% is fully protected in no-take marine reserves. Unless determined action is taken by governments worldwide, this target is in danger of being missed yet again, with potentially dire consequences for ocean biodiversity.

4. The UK Overseas Territories are very different in comparison to one another. Some are relatively wealthy, have large populations and small marine areas, whilst others are notable because of the vast expanse of their marine areas, exceptionally rich marine biodiversity, limited commercial fishing and low (or no) local human populations. Where human populations do exist, the exploitation of fisheries is often largely confined to near-shore areas for local use. These circumstances give the UK a comparatively easy and cost effective opportunity to make a huge contribution to the achievement of global marine protection targets and the conservation of ocean biodiversity, and present a great opportunity for the UK government to become a leader in urgently needed global efforts for ocean and biodiversity conservation.

5. The Pew Environment Group is committed to working with the residents of the UK Overseas Territories, the UK Government, and other UK NGOs, to explore how the oceans around UK Overseas Territories could be better protected. Such protection would make a substantial contribution to global ocean biodiversity conservation and the achievement of global targets, and to raising the global recognition of these islands. In certain cases it also has great potential to contribute to their economic wellbeing through increased awareness of and interest in adventure tourism and ecotourism, and as important sites for future marine research.

6. Since the Pew Environment Group’s work in the UKOTs is primarily concerned with conserving the marine environment, this submission will particularly focus on marine conservation in the UKOTs.

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

7. The UK Government’s lack of support for the conservation of biodiversity in the UK Overseas Territories was criticized in the Committee’s Report on the UN Millennium Ecosystem Assessment, published in January 2007 (paragraph 126–141 and conclusions 31–33), and again in the Committee’s thirteenth report in 2008 on Halting Biodiversity Loss (paragraphs 39–47 and conclusions 11 and 12). The criticisms contained in the 2007 report were endorsed (paragraph 27) in the Foreign Affairs Committee’s report on the Overseas Territories published in June 2008. Both the importance of the biodiversity in the Territories and the lack of UK Government support for conservation of this biodiversity have thus been well established and are taken as given in this submission.

8. Since 2008, there have been a number of significant initiatives concerning the conservation of biodiversity in the Territories. The most significant of these was the announcement in April 2010 by the then Foreign Secretary, David Miliband, of the creation of the world’s largest fully protected marine reserve (640,000 km²) in the British Indian Ocean Territory.

9. In addition, the RSPB has led a major initiative to remove rats from Henderson Island (in the Pitcairn Islands); the South Georgia Heritage Trust is undertaking a staged rat eradication in South Georgia; and the Government of South Georgia and the South Sandwich Islands is about to remove all reindeer from South Georgia. The removal of these introduced species is a complex and expensive undertaking to which the UK Government has contributed significant funding.

10. In 2011–12, Defra spent an estimated £2,969,140 on biodiversity conservation in the British Overseas Territories. This included commitments under the Darwin Initiative and support for projects to address invasive non-native species. It also included spend by the Joint Nature Conservation Committee and the Centre for Environment, Fisheries and Aquaculture Science (Hansard, 3 Sept 2012, Column 118W).

11. Up to 2011, when it was suspended, the FCO and the Department for International Development (DfID) provided £1 million a year through the Overseas Territories Environment Programme (OTEP). Whilst this had a wider remit than biodiversity conservation, in practice a significant proportion of that fund was applied to biodiversity conservation projects.

12. In October 2012 it was announced that OTEP and Darwin Initiative would be combined into one fund, The Overseas Territories Environment and Climate Fund (to be known as “Darwin Plus”) which will total around £2 million in the current year’s round. Since Darwin makes up the larger part of Defra’s expenditure on overseas territories, it seems unlikely that the £2,969,140 reported by Defra as having been spent by them on biodiversity conservation in the British Overseas Territories in 2011–12 will be increased, indeed it may possibly even decrease slightly.

13. It is believed that the Department for Culture, Media and Sport (DCMS) has not financially supported any biodiversity conservation in the UKOTs and that all DfID funding for biodiversity conservation in the UKOTs is given through Darwin and is therefore accounted for in the above Defra figures. The FCO through its support for the governments of South Georgia and the South Sandwich Islands, and of the British Indian Ocean Territory (BIOT), contributes financially to biodiversity conservation in these Territories. In the case of the BIOT, the FCO has received funding from the Bertarelli Foundation to assist enforcement in the first five years following creation of the marine reserve. The costs of running the British Indian Ocean Territory are obviously in excess of this, but those would have to be met by the FCO regardless of how the area was managed. The Government of South Georgia and the South Sandwich Islands is generally financially self-supporting, but in recent years has received support from the FCO to support its finances.

14. In conclusion, it appears that since 2008 the value of total support to biodiversity conservation has been at least maintained or possibly slightly increased. Whilst the total level of support remains wholly inadequate against the estimated needs (estimated by RSPB in 2007 to be about £16 million a year), it is nonetheless noteworthy that maintaining this level of financial support has been achieved in the face of a significant tightening of government expenditure more generally.

Whether the recommendations in our 2008 Report, Halting Biodiversity Loss, on safeguarding biodiversity and practising joined-up government to further conservation have been implemented;

15. 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 of 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)

16. In the preparation of the Government’s paper “The Overseas Territories—Security, Success and Sustainability” which was published in June 2012, the National Security Council in July 2011 requested each Government Department to submit information on how they could engage with the Territories in each of their areas of competence and expertise. This certainly demonstrated an interest by the Government in promoting a more joined-up approach to policy towards the UKOTs, including on the conservation of biodiversity. However, the responses from individual departments to this request generally failed to show much evidence of enthusiasm to change or improve their engagement with the Territories. (See paragraph 18 below for an example).

17. There is little evidence that the Inter-Departmental Group on Biodiversity has made any substantial contribution to forwarding biodiversity conservation in the UKOTs, nor is there any evidence that Defra has assumed joint responsibility for the UKOTs.

18. Whilst Defra, FCO and 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. In its paper responding to the National Security Council’s request for Departments to detail how they could play a role in assisting the UK’s relations with the UKOTs, the DCMS on the subject of the National Lottery, said (The Department for Culture, Media and Sport and the United Kingdom’s Overseas Territories, March 2012, page 12) “There is no bar on Heritage Lottery Fund (HLF) making such grants [ie, grants for work in the UKOTs] but HLF’s current policy is to treat any such applications as a low priority. When making decisions on funding, HLF take into account their policy directions which place an emphasis on funding the heritage of the UK for access by the people of the UK. HLF are currently considering their strategic priorities for 2013–19 but, again, that strategic approach is decided at arms’ length from Government.” This makes clear that HLF are guided by their “policy directions”, but it fails to make clear that these “policy directions” are in fact established by The Secretary of State for Culture, Media and Sport (see http://www.culture.gov.uk/images/publications/HLFPolicyDirections2007.pdf) and thus would appear to be entirely changeable by DCMS, should they wish to assist the UKOTs. In the absence of any change in policy directions, the HLF have now published their 2013–18 strategic framework (http://www.hlf.org.uk/aboutus/whatwedo/Documents/HLFStrategicFramework_2013to2018.pdf). No mention of UKOTs is made. To all those who care about supporting the UKOTs with conservation of their heritage, this lack of action by DCMS symbolizes the continuing lack of interest by Government departments in assisting the Territories.

How weaknesses in civil society and governance in the UKOTs impact on conservation

19. With regard to the marine environment, the major threat comes from overfishing, which may be either legal or illegal. With the exception of BIOT, South Georgia and the South Sandwich Islands, and the Falklands, there is no fisheries or other marine monitoring or enforcement capacity in any of the other UKOT’s marine zones. That means an area of 3,381,280 km², half of the UK’s total marine area, has no monitoring or enforcement whatsoever. Yet within these areas, fishing by foreign fleets is often licenced despite the lack of any means of monitoring or control. This lack of enforcement makes it extremely likely that illegal and/or legal but unregulated fishing is significantly damaging marine biodiversity in UK waters.

20. Those Territories with small human populations all have high biodiversity and also lack the local means of finance to fund the conservation measures necessary to conserve these species. Current UK Government practice is to fund conservation activities from periodic grants rather than though the provision of on-going funding. This means that local conservation capacity is difficult to sustain and grow since it cannot be maintained during periods when grant funding is not available. The building of conservation skills in these Territories would be assisted by the provision of on-going funding to support the activities of dedicated local conservation personnel.

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

21. It is worth noting at the outset of this section that the term “Marine Protected Area” (MPA) encompasses a wide range of possible policy options from fully protected no-take areas to areas that are protected from only a limited number of activities, whilst potentially permitting other destructive activities to continue. These “multi-use” MPAs are often in effect resource management zones, rather than protected areas with a primary goal of biodiversity conservation, and should be recognised as such.

22. The International Union for the Conservation of Nature’s (IUCN) guidance on MPAs issued in September 2012 says MPAs should be “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.” In announcing this guidance, IUCN said “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.”1

23. For many of the wealthier Territories with larger populations, the decision on whether to protect their marine waters is effectively almost entirely devolved by the UK to their own Government, with the UK only retaining oversight to ensure that all international obligations are honoured. However for those territories with much smaller (or no) populations, the UK Government retains a much greater hand in governance, though quite correctly reflecting where possible the wishes of local inhabitants.

24. The UK has two territories (South Georgia and the South Sandwich Islands, and BIOT), which have no resident human population and two others (Pitcairn Islands and Tristan da Cunha) which have small human populations. All of four these territories also have exceptionally large marine areas.

TERRITORY	Area EEZ km2	Resident human population
BIOT	642,746	0
Tristan da Cunha	754,720	~260
Pitcairn	836,108	~50
South Georgia and South Sandwich Islands	1,066,000	0

Each of these territories is also of very high biodiversity importance, having exceptionally large populations of some animal species and/or numerous endemic species not found anywhere else. These territories, due to their remoteness and other factors, are also far less biologically degraded and over-exploited than some of the more populous territories.

25. Together the marine area of these four territories covers 3,299,574 km². This is almost half of the total marine area under the sovereignty of the UK (3,299,574 km² ÷ 6,793,928km² x 100 = 48.6%) and almost 1% of the total area of the world’s oceans (3,299,574 km² ÷ 361,000,000 km² x 100 = 0.91%).

26. This is not to imply that other opportunities and needs do not exist for extensive marine protection elsewhere in UKOTs; they do, but where local populations are larger and EEZ’s are smaller, the pressures increase proportionately. This makes the declaration of marine reserves much more difficult.

27. In respect of South Georgia and the South Sandwich Islands, Pitcairn and Tristan da Cunha, arguments have been advanced by UK officials that there is little advantage in protecting areas in the UKOTs where there are no current risks or threats to species or communities. Their view is that if threats to such areas were to arise in the future, then and only then is it appropriate to consider whether to implement protective measures. Such a policy wilfully leaves areas unprotected when protection is easily possible, and means that it is likely that much less will eventually be protected, since vested interests once they arrive on the scene, will actively oppose the establishment of a reserve. Worse still, in many cases by the time the threat has been identified and action to protect the area has been taken, considerable damage may already have been done. Our view is that the best time to take action is before the threat manifests itself and before damage occurs. That is both easier and is the only way to be sure that species and ecosystems are effectively conserved.

28. Located in the centre of the Indian Ocean, BIOT was declared a fully protected marine reserve in April 2010 and at 640,000 km², is the largest such area on the planet. It contains the world’s largest living coral atoll and has the greatest marine biodiversity by far in UK waters. It also has one of the healthiest reef systems with the cleanest waters in the world, supporting half the total area of healthy reefs in the Indian Ocean. As a result, the ecosystems of BIOT have so far proven resilient to climate change and environmental disruptions. The creation of a marine reserve has resulted in a significant increase in scientific interest and work in BIOT, and has also led to the commencement of an environmental capacity building outreach project with the Chagossian community.

29. Tristan da Cunha’s economy is based primarily on a lobster fishery that occurs around the coasts of its four islands but it also occasionally sells licences for offshore fishing for tuna and other species. Any support for enhanced marine protection should come first and foremost from the islanders. The seas around Tristan are an Important Bird Area and are therefore likely to be rich in biodiversity, but little is known about them and further information about the marine biodiversity of the area would be valuable. We believe that there would be value in the establishment of a marine reserve around these islands and have established contact with the islanders to hear their views, but until further work is undertaken and until the islanders have formed a view on what they want, it is premature to advocate any particular action.

30. The Pitcairn Islands in the South Pacific is home to around just 50 people, but has a marine EEZ of 836,108 km², more than three times the size of the UK. Because it is so remote and is situated in a part of the ocean which is low in nutrients, it does not have extensive fish stocks and so has to date been left almost untouched. As a result it has one of the best preserved marine ecosystems on Earth. However, as fisheries elsewhere become over-exploited, even areas such as Pitcairn are likely to come under increased threat from distant water fishing fleets. Whilst it is comparatively unspoiled, Pitcairn’s marine environment is also very fragile, and any industrial fishing, were it to occur, would rapidly deplete stocks. This would damage one of the few remaining parts of the ocean still in a natural state, and would not provide sustainable income for the Pitcairn islanders.

31. To keep Pitcairn’s marine environment in its present state, the Pitcairn islanders, working with the Pew Environment Group and National Geographic, have requested that the greater part of the area be declared a fully protected no-take marine reserve by the Governor (who would act on the instruction of the Foreign Secretary). A fully protected marine reserve would be a statement of intent by the UK to do everything in its power to preserve this area, which would become the largest such reserve in the world. It would also increase international interest in and profile for Pitcairn, which is important in itself and would attract scientists who would contribute to Pitcairn’s economy and be able to study and monitor the marine environment. Enforcement would remain a priority, as it would be even if the area were not protected, but a marine reserve could perhaps help to get assistance with this.

32. South Georgia and the South Sandwich Islands (SGSSI) has no resident human population and therefore there are no local residents whose livelihoods and food security depend on maintaining a fishery. Despite a history of over-exploitation which even today has left an impact on populations of whales and fish, it is the most species rich ecosystem in the entire Southern Ocean and has a higher marine biodiversity than the ocean around the Galapagos Islands (which is often cited for its high biodiversity values). It is home to one of the most important concentrations of marine wildlife on earth, with more than four million fur seals, as many as 100 million seabirds and a rich population of whales that is slowly recovering from the severe depletions caused by commercial whaling, particularly in the 20th century. But many species remain depleted as a result of previous mismanagement and it may take many years for them to recover. Whilst the Government claims to have protected the entire marine area through the establishment of a protected area, this only gives partial protection and the territory is managed primarily as a commercial fishery for toothfish, icefish and krill.

33. The Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR), the body that manages the marine living resources of the Southern Ocean, had set a target date of 2012 for the establishment of an initial network of Antarctic Marine Protected Areas. Despite the fragility of the Southern Ocean, the importance of its wildlife, and the challenges the ocean and its biodiversity face from multiple factors, including climate change, this target is clearly going to be missed. Of the 11 areas identified by CCAMLR as priority areas for protection based on a bioregional analysis, two—South Georgia, and The South Sandwich Isles—are under UK sovereignty. The establishment of a large fully protected marine reserve in SGSSI would clearly be consistent with CCAMLR’s recommendation and would make an important contribution to meeting its conservation goals. The UK is a member of CCAMLR.

34. Whilst the fishery in SGSSI is undoubtedly well managed relative to other fisheries, the removal of krill and other species from the ecosystem is very likely to be having a negative impact on the marine environment, which would be better conserved if it were to be given complete protection. There are very limited areas left in the world where biodiversity is so diverse and so relatively intact, but there are no people, making it possible to give full protection. But this is one of them. Given its teeming wildlife, which makes it a marine analogue to world-famous parks on land such as the Serengeti or Yellowstone, we believe the case for complete protection is beyond compelling. This would not only give important recognition to the extreme significance of this area for wildlife, but would also gain world-wide recognition for the UK’s beneficent sovereignty over these islands.

35. To fully protect a large marine area in SGSSI would “cost” the UK very little (maybe between £200,000 and £500,000 per year depending on the boundaries), since almost the entire fishery income of £3–4 million a year could be earned from a sustainable fishery zone covering no more than 10–20% of the area, whilst fully protecting around at least 80% of the area.

36. In conclusion, we believe that establishing large-scale fully protected marine reserves in South Georgia and the South Sandwich Islands, and the Pitcairn Islands, is compelling given the high biodiversity values of their waters and the contribution this would make to achieving the global target of 10% of the oceans being protected by 2020, a target which unless large areas such as these are protected, is unlikely to be achieved. Furthermore, we believe that establishing large-scale marine protection in these territories would imbue them with a positive image and visibility—a global brand—which would move them from being almost unheard of backwaters, into the limelight and in a way that had many positives for the inhabitants, the UK, and indeed, through the contribution it would make to global targets, to the world as a whole. It would be the largest, most visionary and most important marine conservation network managed by any country on earth. For Tristan, and other Territories too, we recommend that the Government should enter a dialogue with islanders to determine the extent to which marine protection could enhance the seas around their islands.

Recommendations

37. The Government should without delay establish large scale fully protected marine reserves in Pitcairn and in South Georgia and the South Sandwich Islands covering a very significant portion of their EEZs.

38. The Government should enter a dialogue with other Territories with a view to extending marine protections within their EEZs so that further large, fully protected areas are established.

39. The Government should establish a means of monitoring and enforcing all marine areas under UK jurisdiction, regardless of how they are managed, to ensure that UK seas are not subject to illegal, unreported, or unregulated fishing.

30 November 2012