Royal Commission on Environmental Pollution

INVITATION TO SUBMIT EVIDENCE

Invitation to submit evidence  Letter inviting submissions of evidence

Annex A   Issues on which the Commission would welcome evidence

Geographical scope
The current situation and possible futures
Marine science in relation to the issues covered by the study
Regulatory or management practices and regimes
The institutional/legal framework
General

Annex B  A Royal Commission on Environmental Pollution Seminar, Playfair Library, Old College, University of Edinburgh, 4 November 2002

Annex C  List of recipients of this invitation

Return to Marine Fisheries Study home page

INVITATION TO SUBMIT EVIDENCE

The Commission announced its intention to study the environmental effects of marine fisheries in June 2002. In the announcement the Commission noted that there has been much concern on the ocean's continuing ability to provide the resources on which we have come to rely. Action to protect and conserve them - and remedy damage - is not keeping pace with ubiquitous threats. There have been some notable successes in the past decade but their degradation has continued and, in many places, intensified. The picture that is emerging from shared observations throughout the world includes pollution, exhausted fishing stocks, disappearing coastlines and other widespread environmental damage. The Commission believe that this is an opportune time to consider one part of this picture: the wide environmental consequences of fisheries.

Since the announcement, it has been determining the scope of the study. As background and to illustrate the Commission's thinking so far, Annex B contains a copy of the report of a seminar held in Edinburgh to discuss issues raised by the study.

The Commission is now ready to begin the study and would be particularly interested in receiving evidence on the issues listed in Annex A. Responses on these issues are requested by Friday 30 May 2003. It would be helpful if, where possible, submissions could be sent by e-mail to howard.morrison@rcep.org.uk. Printed reports and references can be sent separately by post.

The central aim of the Study is to seek a coherent framework within which fisheries practice can be consistent with rich and diverse marine ecosystems and with protection and appropriate enhancement of other aspects of the marine environment. All forms of fisheries - including industrial, other capture, aquaculture and fish ranching - will be covered. The study will take into account the wider economic and social consequences of fisheries practice. In particular, the Commission will be looking at:

• Marine science and data, in relation to the issues covered by the study
• Regulatory or management practices and regimes
• The institutional/ legal framework

This invitation lists a series of issues that the Commission intends to address. These statements and questions are not intended to limit the Commission's range of study, but rather focus attention on the areas where Members believe they are most in need of input at this stage. Where information is sought, references to (preferably electronic) sources of relevant information accompanied by a brief summary of what these sources contain is, in general, more helpful to the Commission than reproducing the basic information in your response. Opinions offered should be supported with arguments or evidence. You do not need to address all the issues listed; indeed, you may feel that you can provide useful evidence on only a few.

Unless indicated otherwise when evidence is submitted, it will be assumed that the organisation or individual submitting it has no objection to its disclosure to other parties should the Commission so decide. The most likely method of such dissemination is through publication on the Commission's website.

This letter has been sent to a wide range of interested parties (listed in Annex C), and has been posted on the Commission's website. If you think that we have missed any individual or organisation that might like to contribute, feel free either to contact me or to pass a copy on to them directly.

I look forward to hearing from you.

Howard Morrison
Assistant Secretary
Royal Commission on Environmental Pollution
5-8 The Sanctuary
London SW1P 3JS
Telephone: 020 7799 8980
howard.morrison@rcep.org.uk

Annex A

Issues on which the Commission would welcome evidence

Geographical scope

1. The Commission intends to set its study in a global context but with a principal focus on the OSPAR area, other areas fished by the fleet from this area, and areas fished to supply European aquaculture. Is this choice appropriate in policy and scientific terms?

The current situation and possible futures

2. What are the key current strengths of the fishing industry (including industrial and other capture fisheries, aquaculture and producers of fish meal for aquaculture). What are its main weaknesses or challenges faced? How might these affect its future environmental impacts?
3. Is there firm evidence of substantial damage to the marine environment attributable to capture fisheries or aquaculture? If so, is the damage widespread or limited to particularly vulnerable areas? To what extent is it short-term or reversible? How do the environmental effects of fisheries compare, in magnitude and nature, with the impacts on the marine environment of the oil industry, dredging and other marine activities? How do they compare with the effects of natural variation?
4. The Commission intends look at plausible scenarios for capture fisheries and aquaculture over the next 20-30 years. Which environmental, social and economic scenarios should be examined? Are considerations of energy balances and available resources key factors in determining which scenarios are feasible? What are the likely effects of climate change on the European marine environment? How important will these effects be compared with natural variability?
5. What are the main environmental factors which could or should provide limits to the growth of aquaculture? Does current aquaculture of carnivorous fish use more than the sustainable yield of other fish for fish meal and, if not, what limits if any should the supply of fish meal place on aquaculture growth?
6. What key social and economic factors need to be considered alongside the environmental impacts of fisheries? For example, what are the extent and nature of fisheries subsidies, and how do they compare with those in other countries? What should be the role of subsidies for the fishing industry? If they were to be reduced, what transitional measures would be needed? Are there lessons to be learnt from the use of subsidies in European agriculture?
7. It is frequently claimed that there are health benefits in having a substantial amount of fish in people's diets. What is the evidence for these claimed benefits? What are the other major factors which influence the demand for fish products ?
8. Are fisheries agreements with developing nations likely to change their scope or nature? In what ways are current fisheries agreements advantageous and disadvantageous to developing countries' interests? Should there be a specific requirement for assessment of their likely social, economic and environmental effects before they are established?

Marine science in relation to the issues covered by the study

9. Is it possible to generate a set of indicators of marine environmental quality that would be useful for management purposes? What are the preconditions for achieving this and can ecosystem models assist? When indicators do change, how is it possible to distinguish between changes due to fishing pressure, natural variability, predation by larger sea creatures or birds and other factors? In what other ways can current ecosystem models assist management decisions? Could they be more effective for this purpose and, if so, how?
10. How reliable are models of fish populations and what practical steps could be taken to improve them? Do single species population models and 'safe allowable catches' provide an adequate basis for management decisions? How good is our understanding of the conditions for re-establishing fish populations once they are seriously depleted? How useful are the concepts of sustainability and sustainable yield?
11. To what extent does the available data match, both in type and range, that required to support management and research needs? Where relevant data exists, is it normally available to managers to assist their decisions? To the extent that there are data deficiencies, can new technology solve the problem of data acquisition or distribution? Who should be responsible for providing management data on the marine environment, and how can we ensure the data is robust?
12. Can the environmental impact of trawling be reliably assessed, including the effect on benthic biodiversity, population abundance, nutrient cycling and other key ecosystem processes? How reliably can marine science assess the full environmental effects of aquaculture? To what extent could it help to mitigate these, where mitigation is necessary, and on what timescale?
13. How advanced is the development of combined physical, chemical and biological models of the UK shelf seas and what might be their role in understanding and managing the impact of fisheries?
14. How can the scientific uncertainties and indeterminacies in the environmental effects of fisheries be substantially reduced and/ or overcome? Is there a knowledge base on fisheries in the fishing community which science ignores?

Regulatory or management practices and regimes

15. To what extent has the EU approach to regulation of fisheries and of the marine environment been effective and what is the likely effect of the proposed reforms to the CFP? How well integrated are the management of fisheries with the management of habitats and other aspects of the marine environment?
16. Are there particular management or regulatory approaches, for fisheries or other aspects of the marine environment, used by other countries that the Commission should examine, as examples of models that either could be, or should not be, adopted? Are different approaches needed to control the environmental effects of deep-water fisheries?
17. Can marine reserves be established without a net loss in commercial catches through providing breeding and spawning grounds? How effective are they in protecting the marine environment? Are there minimum sizes at which they are effective? Is it important to embed them within more general marine or coastal strategies for a wider area?
18. Can regulation on fishing gear be effective without the active cooperation of fishermen? How can this best be achieved? Is there a need for tighter regulations to reduce bycatch and discards? Are current monitoring methods, to ensure that regulations are observed, effective? If not, how can they be improved? Are the levels of fines and other punishments sufficient?
19. Should regulations be changed so that bycatch and potential discards are used for purposes such as fishmeal, with the aim of reducing the pressure from industrial fishing? What would be the overall environmental consequences of such changes?

The institutional/ legal framework

20. Do the current institutions provide a coherent and complete framework for managing the marine environment? How should the proposed new regional management councils be constituted and what powers should they be given?
21. How should responsibilities for the protection of the marine environment be divided between government, fishers, fish product manufacturers, importers, retailers, consumers, other ocean users and conservation bodies? What could be their roles in efficient and effective marine stewardship and control?
22. Is the current framework of international conventions on migratory species effective in managing the effects of human activities on these creatures?
23. How should society ensure fair and reasonable public participation in the management of the marine environment and how can this be facilitated?
24. Are existing rights and responsibilities conducive to sustainable use of the marine environment? If not, what changes are needed? To what extent are fisheries still treated as a common good which all may exploit? Are there potential benefits from a greater degree of ownership of fishing rights and the ability to trade these? What environmental effects might flow from any changes? Is there anything to be learnt from common property institutional arrangements (traditional or recent, formal or informal, community based or regional) for fisheries or natural resources.

General

25. There is a general commitment to using an 'ecosystems approach' to marine management. What do you understand by this term? How can it be realised in the multitude of individual management decisions concerning the marine environment?
26. The Commission would welcome views on the merits and likely consequences of adopting one or more of the following general approaches to management of the marine environment. Respondents may wish to suggest additional ones.
1. Basing management decisions on scientific knowledge concerning the integrity of highly dynamic ecosystems and monitoring the changes in appropriate indicators of, against benchmarks for, marine environmental quality;
2. Giving major weight to the impact of changes on the welfare of fishermen and fishing communities;
3. Reversing the burden of proof for capture fisheries and aquaculture: permitting them only where it is clear that serious environmental damage is unlikely;
4. Establishing protected areas covering all vulnerable habitats, within which fishing, dredging etc would not be allowed;
5. Requiring information to be available to buyers on the environmental performance of individual fisheries, so that they can make informed decisions on fisheries products;
6. Basing objectives on social expectations of a healthy or 'pristine' environment;
7. Removing market distortions caused by subsidies and other financial support to the fishing industry, with appropriate transitional measures.
27. Are there other aspects of the environmental effects of marine fisheries that should be addressed in the study? Do you have any other comments on the study?

Annex B

THE ENVIRONMENTAL EFFECTS OF MARINE FISHERIES

A Royal Commission on Environmental Pollution Seminar
Playfair Library, Old College, University of Edinburgh
4 November 2002

The report of the seminar is available in pdf format (16pp, 176Kb).

Annex C

List of recipients of this invitation

This letter has been sent to the following: