The Pew Charitable Trusts ANT0011
Written evidence submitted by The Pew Charitable Trusts
The Pew Charitable Trusts (Pew) is a non-governmental organisation with an environmental programme that works globally to establish pragmatic, science-based policies to protect our oceans and preserve our wildland. Pew welcomes the Committee’s inquiry on the UK and the Antarctic Environment at this critical time and we hope that this submission is useful. We would be very happy to give oral evidence to expand on the points below, should the Committee wish to invite us.
Summary:
Scientists and governments now widely recognize the need for greater levels of protection for marine life, including coastal and deeper offshore waters – to meet the global goal of protecting and conserving at least 30% of the ocean by 2030.
The UK has an opportunity to contribute further to this through the extension of the Marine Protected Area (MPA) around South Georgia and the South Sandwich Islands (SGSSI) as part of the MPA review in late 2023. By fully protecting huge areas within the existing MPA, home to over one million chinstrap penguins - the largest colony in the world - more than 95% of the world’s population of Antarctic fur seals, and returning blue and humpback whales, the UK can ensure these waters are better protected. Such an action would align with the precautionary approach to marine conservation adopted in other Overseas Territories, such as the Pitcairn Islands and Tristan da Cunha.
As the Southern Ocean continues to recover from a legacy of over-exploitation and suffer the effects of climate change that will produce profound differences that aren’t yet fully understood[1], safeguarding species and habitats from adverse impacts of human activities will help these biodiverse ecosystems continue to function[2]. One of the most important returning species that will provide the foundation for these waters, will be the recovering populations of baleen whales[3]. However, their food-source, krill, is under threat from climate change and industrialised and ever more concentrated fishing efforts from fleets flagged to China, Norway, and others.
One solution for protecting the area against any future krill fishing and to give these globally significant waters the protection they deserve would be for the UK to work within the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) to close the waters around the islands and create a large no-take zone. However, given the realpolitik -currently preventing progress at CCAMLR, and its failure to designate any new MPAs since 2016, a more realistic option is for the UK to unilaterally designate the South Sandwich Islands as a national no-take marine reserve (building on previous actions in 2012, 2013 and 2018).
Opportunity to better protect biodiversity in UK Overseas Territory
As the Environmental Audit Committee (EAC) has previously pointed out, the UK Overseas Territories are home to 94 per cent of British endemic species and 90 per cent of the biodiversity for which the UK Government has responsibility.[4] In reports published in 2014 and 2021, the Environmental Audit Committee (EAC) [5] has repeatedly called for the Government to do more to better protect biodiversity in the UK’s Overseas Territories.
This year, 2023, provides a unique opportunity for the UK to unilaterally enhance full protection around one of its greatest biological assets. The UK can achieve this by.
Great Blue Ocean and its partners are calling for the United Kingdom to deliver the above marine conservation objectives to create a South Atlantic Marine Wildlife Sanctuary in SGSSI waters. Members include: The Blue Marine Foundation; Greenpeace UK; The Marine Conservation Society (MCS); The Pew Trusts; The Royal Society for the Protection of Birds (RSPB); The Zoological Society of London (ZSL)
Governance framework under CCAMLR
SGSSI waters sit fully within the area managed by CCAMLR, which has a mandate to conserve biodiversity and manage fisheries in accordance with strict ecological principles. However, at the sub-Antarctic islands, sovereign states maintain the option to apply unilateral management decisions to areas under their national jurisdiction. As such, GSGSSI has historically allowed CCAMLR to provide the broad framework for fisheries management - whilst upholding its right to designate and manage its waters through domestic legislation. Consequently, management of SGSSI waters remains complex, given the different contributions from CCAMLR, IWC and GSGSSI. Nevertheless, GSGSSI implements all internationally agreed management measures, with supplementary regulations implemented under domestic legal instruments and management processes that provide more robust management and protection. However, conflicts have recently arisen within CCAMLR that have the potential to delay, or even completely derail important work[6]. Such work includes ensuring management resilience to climate change[7], facilitating the designation of MPAs[8], and building a revised management framework for the krill fishery[9].
Conflicts have arisen, following increased polarization about how to interpret and implement the primary Objective of the ‘Convention’, that is, the conservation of Antarctic marine living resources, where conservation also includes rational use. Historically, rational use has meant fisheries management must follow a broad ecosystem approach[10]. This means that under CCAMLR, only fisheries where sufficient data exist are generally allowed to operate. However, in recent years the imperative to fish by some Members has become increasingly apparent, and is now risking much, not only in terms of biodiversity and ecosystem support, but also political stability. Currently, conflicts within CCAMLR mean that there is little chance of progressing modern management methods within a multilateral framework, leaving sovereign states with an imperative to protect the more northerly parts of the CCAMLR management area. With CCAMLR stalled, domestic legislation is now needed to ensure biodiverse areas are not subject to industrial fishing, and that they are protected to allow previously depleted baleen whale populations to recover, and to build resilience to the impacts of climate change[11].
Many threats are now well managed within the SGSSI MPA, including, inter alia, a prohibition on the carriage and use of heavy fuel oils, a prohibition on marine hydrocarbon and mineral resource extraction, a prohibition on destructive bottom trawling, and a closed season for the krill fishery to reduce competition with krill-dependent predators during critical breeding and feeding periods. The MPA also includes closed no-take zones where fishing is completely prohibited[12] [13].
Despite these restrictions, some factors, such as plastic pollution originating from outside the SGSSI MPA, continue to impact wildlife (e.g.,[14]) and are beyond the control of local management. However, two factors will be the key to the future management of the SGSSI MPA, warranting consideration – which are not adequately managed under current MPA restrictions – climate change and industrial fishing.
Industrial fishing
Industrial fishing for Antarctic krill is found in the polar waters of the Southern Ocean. It is a key species in the Antarctic marine ecosystem, and one of the most abundant multicellular animal species on the planet with an estimated biomass of approximately 500 million tonnes[15]. Harvesting began in the 1960s, with the first catches in the Scotia Sea made in the 1970s by vessels from Japan and the former Soviet Union. Within CCAMLR, five Members currently fish for krill: Chile, China, Norway, South Korea, and Ukraine.
China is the world’s second largest producer of krill, and it is growing rapidly. A quarter of all the krill caught in 2020 headed for China – which has doubled its krill-fishing activity over the last few years increasing its catch of Antarctic krill from 50,423 tonnes in 2019 to 118,353 tonnes in 2020[16]. This is backed by the Chinese government; the Chinese fleet is now expanding, with State-backed loans, under a government strategic plan. China plans to launch three new super trawlers, including the world’s biggest krill trawler, specifically commissioned to increase fishing capacities to an estimated 240,000 tons per year[17].
Under CCAMLR, krill fishing is managed in a precautionary manner with catches allocated to different areas, including for waters around South Georgia and around the South Sandwich Islands. However, catches are increasing and becoming more concentrated in both space and time. As such, CCAMLR has been working to develop a new management framework to prevent ecosystem impacts from the fishery[18]. However, the revised management framework does not provide adequate safeguards to test for and prevent ecosystem impacts. The current work plan does not allow for adequate ecosystem monitoring, spatial protection through the designation of MPAs, or incorporation of climate resilience[19]. All these safeguards are critical to ecosystem protection. The revised framework, if agreed, would allow krill catches to increase more than four-fold at the Antarctic Peninsula, and if eventually implemented within SGSSI waters, by considerable amounts. Currently, adequate safeguards are not in place, and without such constraints, the krill fishery should not expand.
It will be challenging to develop the appropriate safeguards in some areas, due to their geographic isolation; indeed, in some areas it may never be possible to develop adequate monitoring. As such, krill fisheries should never expand into these regions. These areas should now be set aside as no-take closed areas, facilitating baleen whale recovery, and providing umbrella protection for all species. The South Sandwich Islands are a model example of where krill fisheries should never be allowed to operate. Similarly, baleen whales use offshore habitats to the north and east of South Georgia[20], which should also be closed to krill fishing.
Climate Change
Climate change impacts are projected to affect habitats and species, including species of commercial interest, across many parts of the Southern Ocean[21]. No issue, therefore, has greater importance for the future sustainable management of the Southern Ocean than does climate change[22]. Yet our ability to understand how species and ecosystems might change, is still rudimentary[23]. Most biological datasets are of short duration, with many shorter than 30 years. Last year, 2022, was globally the fifth warmest on record, indeed the last eight years have been the eight warmest on record; the annual average temperature was 0.3°C above the recent reference period of 1991- 2020, equating to approximately 1.2°C higher than the historical reference period of 1850-1900; atmospheric carbon dioxide concentrations increased by approximately 2.1 ppm, while atmospheric methane concentrations increased by approximately 12 ppb; in February, Antarctic sea ice reached its lowest ever minimum extent based on the 44-year satellite record, whilst five other calendar months saw the Antarctic sea ice extent reach record or near-record low values[24]. This year, 2023, Antarctic Sea ice saw even lower record values of extent[25]. Moreover, extreme events are occurring which potentially place unprecedented stress on ecosystems[26].
With climate change impacts increasingly apparent at South Georgia (e.g. there has been a mean temperature increase of ~0.9°C in January and ~2.3°C in August over the top 100 m of the water column over the past century, with warming diminished at deeper depths[27]; also, 97 percent of glaciers have retreated[28] [42]) and more widely across the Scotia Sea (e.g. krill abundance and distribution are changing[29]), comprehensive research and monitoring is needed to ensure that fisheries, particularly krill fisheries are sustainable. Many ecological interactions are not well understood, and many are not even studied. For example, recovery from historical over-exploitation and climate change can act in concert to alter ecosystem dynamics[30]. Disentangling these confounding drivers may be difficult and complex, and will require significant research and monitoring, which in remote regions is unlikely ever to be available. Areas with little or no ecological monitoring should therefore be set aside as no-take closed areas. Again, the South Sandwich Islands and offshore areas to the north and east of South Georgia are areas without comprehensive monitoring and which should therefore be closed from krill fishing.
September 2023
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[4] UK Parliament: Environmental Audit Committee, The UK’s footprint on global biodiversity, 2021
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[16] https://www.theguardian.com/environment/2021/sep/07/license-to-krill-the-destructive-demand-for-a-better-fish-oil
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[18] CCAMLR, “Report of the Thirty-eighth meeting of the Commission,” Commission for the Conservation of Antarctic Marine Living Resources, Hobart, 2019.
[19] P. Trathan, “What is needed to implement a sustainable expansion of the Antarctic krill?,” (n 7).
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