Global Forum on Food Security and Nutrition (FSN Forum)

European Commission's services comments on the V0 draft of the HLPE report on "the role of sustainable fisheries and aquaculture for food security and nutrition"

The European Commission's services welcome the V0 draft of the HLPE report on "the role of sustainable fisheries and aquaculture for food security and nutrition".

The European Commission's services share the observation that fisheries and aquaculture are absent from most global reports and discussions on food security and consider that this report offer a good opportunity to highlight the possible role of sustainable fisheries and aquaculture for food security. We would like to thank the HLPE for this extensive draft report that provides a good understanding of the issues at stake and the complexity of fisheries management.

The European Commission's services agree that "food security and nutrition in relation to fish cannot be achieved without the combined sustainability of the two sectors (fisheries and aquaculture)". The crucial role of healthy marine ecosystems, sustainable fisheries and sustainable aquaculture in achieving food security was recognized at the third UN Conference on Sustainable Development, Rio+20[1]. In this context, States committed to meet the 2015 target as agreed in the Johannesburg Plan of Implementation to maintain or restore stocks to levels that can produce maximum sustainable yield on an urgent basis thought the development and implementation of science-based management plans including by adapting fishing catch and effort with the status of the stock and managing by-catch and discards. These objectives have guided the recent reform of the European Union Common Fisheries Policy. This being said, the European Commission's services recognize that further action would be needed to reinforce the contribution of sustainable fisheries and aquaculture to food security and welcome the initiative of the HLPE to propose some specific recommendations.

Through its development cooperation, the European Union (EU) has played a leading role in tackling hunger and malnutrition for many years and food security remains at the top of the EU development agenda. The EU is the world's largest donor in supporting global food security and sustainable agricultural development with an annual budget of some 1 billion euros.

The principles of the European Union (EU) development policy in the field of fisheries have been outlined in a Communication adopted in 2000[2]. For the period 2007-2013, the EU development policy funds have financed several projects in the field of fisheries and aquaculture for a total of around 150M euros. Regional programmes in Africa, in the Indian Ocean and in the Pacific Ocean have focused on strategic governance issues including control, surveillance and the fight against IUU fishing. As a complement, national programmes have supported the formulation and implementation of national sectoral policies developed by partner countries as well as initiatives led by local communities. Fisheries have also benefited from EU development programmes on health surveillance, sanitary issues and market-access.

The Commission's services note that HLPE recommendations in the VO draft report are not final recommendations and need to be further screened against evidence. At this stage of the process, we would like to make the following comments for HLPE's consideration:

Starting from a general point of view we think the draft report could more carefully delineate who are currently the food insecure (producers, consumers, owners, labourers, fishers, aquaculture, coastal, urban, subsistence, export, etc.) and whose food security could be improved by sustainable fisheries and aquaculture – and what impact policy choices (trade, fish consumption, fisheries partnership agreements, certification, labelling, aid, FDI, etc.) have on food security in third countries.

Furthermore the answer to the major question in the problem statement (p. 10: "recognizing the well-established importance of fish to food security and nutrition… frequently in a gendered way?") could be developed and made clearer in the final report.

Looking at specific sections of the draft paper the Commission's services have the following remarks:

• With regards to trade, the draft paper argues that export markets maybe benefitting groups of population in the exporting countries, but that the pressure of exports forces food out of the country and potentially damages small scale operations. Hence, on balance the benefits are not clear. Many trade related aspects of the draft report will be discussed at the FAO sub-committee on trade by the end of February 2014. It may be advisable to consider the results and conclusions from that meeting in the final report.
• Regarding fisheries management, looking at balanced harvesting as study object is commendable and the protection of undersized fish should be the main driver for sustainability and stock reproduction. In this context the report could perhaps explain in more (technical) detail how it defines "sustainable fisheries and aquaculture".
• There appears to be a strong bias in the draft paper in favour of small scale fisheries (SFF) and domestic markets and against industrial fisheries and international trade. The same goes for aquaculture. We believe this is a simplistic point of view. Looking at the small-scale fisheries sector as essentially a subsistence fisheries is an overstatement. The reality seems more complicated than this.  As regard recommendation 4, we consider that positive discrimination of SSF should not mean that SSF is excluded from the general principles of conservation and management policies.
• The chapter on governance in aquaculture could be better developed; it would be interesting to analyse how and what kind of governance (at national and international level) can contribute to food nutrition aspects.
• The draft report makes a link between small scale fisheries, the IUU fishing and the impact on food security (page 74 under section Fisheries governance at international level) which is important. However, the draft report ought to take a more holistic view on the full fish supply chain and cover also the processing industry. In that respect it is not only the small scale fisheries or the large scale industrial fleets that should be mentioned but also in land where raw materials are processed. The existence of effective port and market State measures and traceability of operations in transformation industry is of paramount importance to address in any strategy for sustainable fisheries and food security. This is particularly important in areas of the world like West Africa to avoid creation of 'ports of convenience' or 'back box processing factories' that would legalize IUU stemming products.

• Regarding the impact of measures against IUU fishing and their impact on SSF, we would like to stress that most of these measures focus on illegal activities on the high-seas or illegal activities by third country vessels in the EEZ of a coastal State which by nature in general concerns larger vessels. This in effect means that small-scale vessels rarely are directly targeted by international measures adopted by RFMO's, nor by the EU. All flag States should however elaborate national plan of actions against IUU and thereby target the illegalities in their own EEZ by all national fleet segments.
  
  The EU IUU regulation (1005/2008) which focuses on trade in fisheries products does take small scale vessels into account by allowing (in its implementing regulation) vessel owners of vessels smaller than a certain size to be represented by their exporters. The vessels must be registered though which in effect means that the EU IUU Regulation has led to registration of many small scale vessels - in particular in West Africa, which is an essential condition for proper fisheries management.
  
  We consider that the comment: "The IUU term does not make a clear distinction between what is illegal and what is unreported and unregulated" is not correct. There is a clear definition in the IUU regulation (1005/2008) of respectively illegal, unreported and unregulated fishing – just as in the FAO IPOA on IUU. We would recommend the HLPE to have a look at this definition – and to clarify their recommendations on this issue.
• It should be discussed whether it is fully justified to say in the "Summary of key governance points" (p.76, point 5.4) that there is no adequate international governance for adequate inclusion of both FSN and aquaculture. There are international instruments, binding and non-binding which regulate the relationship between fisheries and food security, particularly in relation to small-scale fisheries and aquaculture. It should be examined whether there is not a problem of implementation of these international instruments by coastal States and how this can be better remedied.   

On the more specific we would like to draw the intention of the HLPE to the EUs Sustainable Fisheries Partnership Agreements which could be a useful example for "Fisheries governance at international level" (page 77):

Bilateral fisheries agreements between the EU and third countries constitute a highly regulated and transparent framework for fishing activities of the EU fleet in third-country waters. Current Sustainable Fisheries Partnership Agreements (SFPAs) aim to create a partnership to promote sustainable fisheries, based on the best available scientific advice and information on the cumulative fishing effort in the waters concerned and have the objective to allow EU vessels to fish only surplus resources in the exclusive economic zones of a number of third countries, in line with the relevant provisions of UNCLOS. They constitute a transparent legal framework which aims to ensure that fishing activities of EU fleets are respectful of stock status, of the environment and ecosystems and do not compete with local fishermen communities. Through these FPAs, while obtaining access to the surplus resources of third countries, the EU provides financial and technical support for the sustainable development of the fisheries sector of partner countries. Thus, they can contribute to enhancing food security, both directly (by increasing the local supply of fish) and indirectly (through generated income due to employment creation, harbour activities, processing factories…).