The state of biodiversity:

The extent and effectiveness of monitoring the impact of UK domestic and international fisheries on biodiversity is mixed. The full ecosystem wide impact of fishing is not effectively monitored, either at home or abroad, and fisheries policy remains siloed from biodiversity considerations. Policy is directed towards maximising yield in the short term and not sufficiently focused on measuring and mitigating impacts or restoring biodiversity. Priority is often given to maximising yield even when this comes at the expense of ecosystem integrity

The UK, like most other countries and relevant international agreements, including the UN Convention on the Law of the Sea (UNCLOS), the UN Shared Stocks Agreement, UN Sustainable Development Goal (SDG) 14 and the Convention on Biodiversity (CBD), uses the maximum sustainable yield (MSY) as the benchmark to define sustainable harvesting of marine biological resources. The maximum sustainable yield is a measurement of the highest yield that can be taken from any individual stock without damaging the long-term reproductive viability of the stock. A stock is harvested sustainably and in a healthy condition if the fishing mortality does not exceed the scientifically advised level and the biomass is above the level capable of supporting the maximum sustainable yield. Ensuring stocks are not over exploited is a low baseline and should be considered the minimum point for management rather than the desired aim. For biodiversity to be considered central to policy making the Government should move beyond setting fishing limits based on the highest level that an individual stock can withstand. Instead the government should consider, and monitor, the wider ecosystem role of fish (including their role as a food source for marine mammals, birds and other fish), the impact of fisheries on marine habitats and ensure a suitably precautionary approach is taken.

In relation to monitoring the impact of human activity on marine biodiversity an important first step would be full monitoring of all exploited stocks. Several stocks that inhabit UK waters receive full MSY based assessments that provide reference points based on the maximum sustainable yield. However, a significant number of assessed stocks receive a less comprehensive assessment and some stocks are not assessed or monitored at all. The lack of sufficient monitoring of these stocks makes them vulnerable to overexploitation. Where these MSY based reference points are not known the government is required to adopt the precautionary approach to fisheries management (as defined in Article 6 of the UN Shared Stocks Agreement), which it has not done for all stocks.

We ask that the UK continues to champion action, evaluation and international cooperation to properly manage migratory marine species, through the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and other fora. Every year, millions of sharks are caught and killed in commercial fisheries. The demand for shark fins, meat, liver oil, and other products continues to drive population declines worldwide, and more than half of all shark and ray species are estimated to be threatened or near threatened with extinction due to overfishing. At best, only around 17% of the international shark fin trade is regulated, with many of the worlds most threatened shark and ray species, including several of the highest value in trade unlisted and unprotected. Measures such as CITES listings can help gather additional data on current catch levels to better inform RFMO management and deliver sustainable catch limits, while ensuring that high demand for shark products internationally is not driving unsustainable fisheries both domestically and in international waters.

Ongoing funding for the UK’s Blue Belt programme is further necessary to support the UKOTs work in implementing and evaluating their marine protected areas (MPAs).

Effective monitoring of the impact of human activity on the marine environment is a vital component of good management. Equally important, however, is ensuring that the scientific evidence obtained through monitoring is used to inform the development, delivery and monitoring of policies that restore and protect biodiversity.


Aichi Biodiversity target 6[1] is concerned with the direct and indirect ecosystem impacts caused by overfishing of fish and invertebrate (shellfish) stocks. It requires that by 2020 all harvested stocks are fully assessed, all stocks are harvested sustainably, an ecosystem-based approach has been adopted for fisheries management, that recovery plans are implemented for depleted stocks, that fisheries have no significant adverse impacts on threatened species and vulnerable ecosystems and that the impacts of fisheries on stocks, species and ecosystems are within safe ecological limits. Unfortunately, the Government has not yet fully met any of the requirements under target 6.

One of the requirements of target 6 is that all harvested stocks are fully assessed. The Government has not yet fully met this requirement. Some fish stocks have full MSY based assessments, others have less comprehensive assessments and a significant number of stocks harvested in UK waters have no assessments and limited if any management in place. There has been limited progress in improving the number of fish populations subject to monitoring and some stocks have seen the quality of their assessments downgraded or have had catch limits removed, risking them becoming overfished. Requiring evaluations for all harvested stocks and implementing plans to deliver full assessments based on MSY would represent an effective first step in improving the monitoring and management of fisheries and the impact of fishing activity on marine biodiversity.

In relation to the target 6 requirement that all harvested stocks are harvested sustainably the government’s performance is mixed. Some welcome progress has been made in setting fishing limits in line with scientific advice, but progress has been too slow, and the 2020 deadline required by the CBD and other international agreements has been missed. Last year 44% of catch limits for stocks of interest to the UK were set above scientific advice. This figure does not include fisheries for stocks and species not managed by a quota system. It is difficult to evaluate if a stock is being sustainably harvested if it has no assessment but without any limits on catches a stock is very vulnerable to over exploitation. Progress has been better for stocks with a full MSY based assessment – catch limits for 67% of these stocks followed advice, but still falls far short of the requirements laid out in target 6.

To date, the Government’s performance has been insufficient to deliver the ecosystem-based approach required by target 6The Government has not produced a definition of what it would consider an ecosystem-based approach to be and has been willing to set catch limits significantly above sustainable levels for some stocks. This approach has led to a number of stocks being below safe biological levels as maximisation of fishing opportunities has been prioritised over stock recovery and wider ecosystem considerations. The Fisheries Bill includes an ecosystem objective and the Government should publish details of how its approach to fisheries management will deliver on this objective. This should include clear, measurable and time bound targets and the metrics the government will use to deliver on its ecosystem objective., including how it intends to protect non-target species.

To date the government has not implemented recovery plans for depleted fish stocks. Some stocks have continued to decline despite being below safe biological levels and recovery of these depleted stocks is unlikely whilst the fishing mortality remains too high. The UK should develop, publish and implement recovery plans that contain effective harvest control rules and have clear, ambitious and binding timetables for recovery for all fish stocks that are below scientifically advised stock recovery benchmarks. Furthermore, stock recovery plans should consider the wider ecosystem inhabited by these stocks and measures should be taken to restore habitats and ensure their protection in the future.

Target 6 includes a requirement that fisheries have no significant adverse impacts on threatened species and vulnerable ecosystems and that the impacts of fisheries on stocks, species and ecosystems are within safe ecological limits. There has been some progress in protecting some vulnerable marine ecosystems (VMEs) including certain deep-sea habitats but these provisions have not covered all habitats or all occurrences of these VMEs. As an independent coastal state, the UK can set stronger protections for vulnerable ecosystems than currently exists. The government should identify all existing vulnerable habitats and regulate fisheries in such a way that no further damage is done these ecosystems. Furthermore, the government should, through the fisheries management plans laid out in the Fisheries Bill or some other mechanism, implement policies that will restore depleted populations, threatened species and vulnerable or degraded ecosystems.

Significant progress is needed if the UK is to achieve the requirements set out under Aichi Biodiversity target 6. To achieve this the government must take several steps. The Government must set out its plans to provide full MSY based stock assessments for all harvested marine stocks within a set timetable; set all fishing limits below the scientifically advised levels and ensure that the precautionary approach is taken; take the ecosystem importance of fish species into account when setting catch limits, for example setting lower catch limits for important forage fish species such as sand eels, shad and blue whiting; deliver plans to ensure that fisheries do not have adverse effects on ecosystems that put them below safe ecological limits; and implement stock recovery plans for depleted stocks.

There are several indicators that would demonstrate clear progress. Under the Marine Strategy Framework Directive (MSFD) the UK government reports progress on 15 indicators of environmental status in the marine environment. Last year’s report, Marine Strategy Part One: UK updated assessment and Good Environmental Status, shows that the UK is failing to reach Good Environmental Status in 11 out of the 15 indicators. This includes indicators that relate to the health of fish stocks and the wider ecosystem impacts of fishing. Meeting the requirements of the MSFD would represent a clear indication of progress.


Evaluating measures to conserve and enhance biodiversity:

It is likely that climate change will cause adjustments in the ranges, populations and structure of some fish populations. To better integrate fisheries management to address biodiversity loss, climate change and sustainable development, fisheries policies should be adopted that increase the resilience of individual stocks and the wider ecosystem. The Fisheries Bill does include a climate change objective requiring fisheries managers to consider the impact of climate change, but no detail has been provided as to what, if any, tangible impact this will have on the setting of catch limits or other fisheries management policies. Fisheries managers cannot control the impacts of climate change, but they have significant control on the impact commercial fishing has on the marine environment. Taking a more precautionary and ecosystem-based approach to the setting of catch limits would make the marine environment and fishing industry more resilient to the impacts of climate change.

In parallel with this it is important that the UK implements measure to detect and deter any incidence of Illegal, Unreported or Unregulated (IUU) fishing in its waters or by its fleets. IUU fishing skews stock assessments and adversely impacts scientific advice. Adoption and continued implementation of the implementation of international instruments such as the FAO Port State Measures Agreement of 2009 will be key.

The UK is now well positioned to provide leadership on international governance of fisheries. Ensuring fisheries policy does not work against the achievement of biodiversity aims is an important step in recovering the marine environment. By better integrating fisheries into wider biodiversity policy the UK can support a more coherent and holistic approach to marine management. The UK should fully incorporate biodiversity into its interactions in bilateral and multilateral fora, including at Regional Fisheries Management Organisations (RFMOs). Doing so would enable the UK can deliver on its commitments under the CBD. By adopting and advocating for positions in RFMOs that deliver on its Aichi targets and putting biodiversity at the heart of new fisheries agreements in the North East Atlantic the UK can demonstrate leadership in delivering an ecosystem-based approach to the marine environment.

New industries, such as deep-sea mining should not be commenced, without better understanding of the role the environments to be affected play in climate mitigation and adaptation. Aspects requiring further research include: the role that relevant ecosystems play in the carbon cycle, how deep-sea ecosystems and biodiversity are affected by climate change, and how new large-scale disturbance by extractive activities could exacerbate such effects.

Co-ordination of UK environmental policy:

Unsustainable fishing remains the biggest threat to marine biodiversity and threatens the   resilience of species and the integrity of ecosystems-particularly in the context of a changing climate. Below are several recommended indicators the UK should be pushing in the forthcoming UN negotiations on the post-2020 global biodiversity framework;

The UK should continue to build support for a global target through CBD to protect or conserve at least 30% of the ocean by 2030 and sustainably manage the remainder. To maintain a healthy, productive, and resilient ocean, the world needs to protect and conserve at least 30% of coastal and marine areas by 2030, through effectively and equitably managed, ecologically representative and well-connected systems of fully or highly protected MPAs and other effective area-based conservation measures (OECMs) of equivalent conservation value.

These types of MPAs (i.e., no-take reserves) are more effective at restoring and protecting biodiversity than partially protected MPAs. A global target can be achieved through protections in countries’ national waters and in international waters (e.g., the high seas and Southern Ocean). 100% of the ocean should be sustainably managed to prevent significant adverse impacts on the coastal and marine ecosystems.

MPAs and OECMs need to be well-designed and well-managed to offer positive and sustained long-term outcomes for the in-situ conservation of biodiversity.  However, better management of existing MPAs will not be sufficient to meet conservation goals. 


Pairing nature-based solutions to climate change with biodiversity:

Harnessing nature-based solutions must be coupled with rapid decarbonization - Nature-based solutions (NBS) have huge potential. However, NBS alone will not address the impacts of climate and must be combined with rapid, deep decarbonization from global economies to preserve the health of the ocean. To this end, a countries greatest contribution to improving the health of the ocean and its value as a buffer and NBS is to commit to the ambitious emissions reductions necessary to reach the Paris Agreement goals.



September 2020