Our Fish – Written Evidence (NFF0004)

  1. The UK government has said it wants to become a “world leader” in fisheries management following its departure from the EU. To do this, it must deliver on it’s legal obligations to manage fisheries in line with maximum sustainable yield, including, through the United Nations Convention on the Law of the Sea (UNCLOS), the United Nations Fish Stocks Agreement (UNFSA) and the FAO Code of Conduct, and the 2002 Johannesburg Earth Summit promise to “maintain or restore stocks to levels that can produce the maximum sustainable yield with the aim of achieving these goals for depleted stocks on an urgent basis and where possible not later than 2015;” (JPOI Article 31a).
  2. Commitments to sustainable fishing have also been made by all parties through the adoption of the Sustainable Development Goals (SDGs), in particular SDG 14 on ‘life below water’. Just a few weeks ago, the UK signed the Leaders Pledge for Nature at the United Nations Summit on Biodiversity. These pledges and promises will be deemed meaningless if the UK does not use its new negotiating position with Norway and the EU to ensure a combined end to overfishing of Northeast Atlantic fisheries, ensuring that Maximum Sustainable Yield (MSY) is considered the upper limit for exploitation rates.
  3. Talks on joint management should be comprehensive, including all relevant coastal states and stakeholders, avoiding unilateral processes where stocks are shared. In line with the United Nations Convention on the Law of the Sea (UNCLOS), collaboration on management must be multilateral when more than two coastal states have a stake in a given fish population, or fishery, in order to ensure transparency across all relevant states. The role of regional fisheries management organisations such as the NEAFC must be considered in this context.
  4. In the 2013 reform of the CFP, EU member states – including the UK at the time – committed to ending overfishing by 2015 where possible and 2020 at the latest. More recently, the EU has bolstered its wider environmental commitments with the publication of its Green Deal for Europe. Meanwhile, the UK government has said it wants to become a “world leader” in fisheries management following its departure from the EU.             
  5. Agreements on shared stocks must include provisions regarding abundance of fish populations, limit reference points for mortality, and precautionary and ecosystem considerations. In addition to objectives to maximise longterm sustainable yields, coastal states must act with urgency to conserve biodiversity, considering the impact of fishing activity on both fish populations and on the whole ecosystem, including food web, sensitive species, bycatch, seabed, and fish populations’ ability to mitigate and adapt to climate change.
  6. Agreements on shared stocks must implement a genuine precautionary approach as defined by the United Nations Fish Stock Agreement (UNFSA, 1995). When the available data and information are uncertain, unreliable or inadequate, decision makers should engage in more cautious management, and a lack of scientific certainty cannot preclude management action.
  7. Multiannual management should be the underlying approach by default. Although details will need to be revisited regularly, all stakeholders benefit from agreeing to and working toward longterm sustainable management objectives. That includes stable sharing arrangements, harvest strategies that include precautionary harvest control rules for setting catch limits, a robust monitoring and evaluation scheme, a periodic review process, and any necessary mechanisms to transition from previous arrangements to a new system.
  8. Coastal states should set explicit standards for the scientific advice on which decisions will be made, using the best available, peerreviewed scientific advice from independent institutions recognised at the international level. Published scientific advice from independent scientific institutions such as ICES should be used as the basis for management, rather than unpublished or lastminute submissions from individual states.
  9. Management proposals, negotiations and decisions should be made transparently, with access guaranteed for all stakeholders, including the fishing industry, civil society organisations and other interested parties.
  10. Citizens of the UK and of other coastal states involved in the shared fishery must be able to scrutinise management decisions. Management objectives and all other elements of negotiated harvest strategies and annual decisions must be clear and available to the public. The joint management measures, the scientific advice underpinning them and the positions of the different parties involved, must be made available and actively disseminated to those interested in reviewing them.

28 October 2020