Global Forum on Food Security and Nutrition (FSN Forum)

Dear Sir/Madam,

In response to your call for input into your consultation on 'The role of sustainable fisheries and aquaculture for food security and nutrition' I would like to offer any support we are able to provide to your efforts. As a CGIAR center with a specific interest in ensuring that fisheries and aquaculture contribute as much as practicable to food and nutrition security we are delighted to see this issue given prominence. 

I have no doubt that the panel of experts who will prepare this document will draw upon the published work of WorldFish and it's partners, but allow me to point to two publications that I think may prove especially useful. The first is a paper that will appear shortly in PNAS entitled "Innovations in capture fisheries are an imperative for nutrition security in the developing world" the second is a WorldFish report by Dr Eddie Allison entitled: 'Aquaculture, fisheries, poverty and food security'.

I attached the submitted proof of the first of these (and will forward the final published version in due course). The second  can be obtained from http://www.worldfishcenter.org/resource_centre/WF_2971.pdf

Sincerely,

Stephen Hall

Point 3 mentions that "problems have been largely treated as a biological issue rather than economic and political matters". This is very true.

In this regard, in addition to the comments from the colleagues on covering gender and youth dimensions, the study should look into the business aspects of fisheries and aquaculture. In particular, the role of private sector in the value chain and policies that can support their engagement in a way that can benefit the small-holder fisherman and women along the chain.

Dear friends,

This is to inform that according to the OECD-FAO Agricultural Outlook 2012-2021,

http://www.fao.org/fileadmin/user_upload/newsroom/docs/OECD_FAO_A

g-outlook2012_ENG.pdf

http://www.agri-outlook.org/dataoecd/4/10/50679839.pdf?contentId=

50679840

• Protein meal production in India is expected to rise from an average 16419 thousand tonnes during 2009-11 to 20343 thousand tonnes in 2021.

• Protein meal consumption in India is estimated to rise from an average 11670 thousand tonnes during 2009-11 to 14149 thousand tonnes in 2021.

• Fish and seafood production in India is expected to rise from an average 8869 thousand tonnes during 2009-11 to 11007 thousand tonnes in 2021.

Therefore, it is important to discuss here the role of "catch shares" system, which has become dominant in the West. 

Please check the following links on sustainable fishing:

Who Owns the Fish? -Ariane Wu, Arthur Jones and Susanne Rust, 12 March, 2013,

http://cironline.org/reports/who-owns-fish-4251

System turns US fishing rights into commodity, squeezes small fishermen-Susanne Rust, 12 March, 2013,

http://cironline.org/reports/system-turns-us-fishing-rights-commodity-squeezes-small-fishermen-4250

For a good practice on fishing, please check:

Crab fattening sends her to S. Korea by B. Kolappan, The Hindu, 11 October, 2012,

http://www.thehindu.com/news/cities/chennai/crab-fattening-sends-her-to-s-korea/article3985429.ece?homepage=true    

Regards,

Shambhu Ghatak

Inclusive Media for Change

www.im4change.org

CSDS

29, Rajpur Road

Delhi 110054

INDIA

Blog:

www.talkative-shambhu.blogspot.com

Los sistemas inuslares (Islas) con las varibles climáticas que se están produciendo en los últimos años han mermado su producción alimenticia de origen marino, debido al calentamiento de las aguas marinas con los fenómenos naturales secuelas del cambio climático. Pero además de este proceso s eobserva una migración de especies desconocidas que están eliminando a especies endémicas de la zona de influencia de las islas. Se hace necesario el fomento de la acuacultura como una alternativa para enfrentar el deficit alimenticio como producto de la desarición de estas especies locales y citamos el caso del pez león en el caribe y casi todo el archipielago insular que ha mermado la capacidad de pezca de habitantes que antes vivíasn exclusivamente de este trabajo. Si a esto añadimos quie la subioda de las aguas costeras también ha influido en la pezca se ahrá necearia estudiar detenidamente el aproceso de cambios alimenticios y proveer una nueva nmanera de realziar la pezca y de incrementar el proceso dulceacuicola tan necesarios en los ríso sin contaminar que aun nos quedan.

I wish to emphasize the importance of focusing on points 5./6./4. when developing the scope and breadth of the upcoming report. Sufficient attention to socio-political issues in the sector seems to me as important as addressing technical matters  - in effort to attain sustainable food and nutrition security while promoting increased incomes, sustainable livelihoods through equitable stakeholder inclusion and engagement. Integration of gender issues (5.) in particular are vital to the issues paper, as women are key actors and also partners with men in the entire value chain, e.g. fishers, owners of boats and equipment,processors, sellers and traders of fish (small and larger scale markets). However, women often do not often realise equal access and benefits to men, and can experience less voice and access to investment opportunities. Examples include: weak negotiating and bargaining power, less control over assets and profits, weak access to capacity development, credit, equipment and materials, information, limited collective action and voice, as well as limitations due to time constraints and conflicting demands due to domestic roles. It is imperative that attention to and support to gender equity and institutions is therefore duly emphasized in the report.

The above is directly relevant to other points 4 and 6, which address rights, benefits and institutions. These are inter-related. Promoting good practice in policy dialogue and formulation relies on strong and capable stakeholder institutions and particularly, civil society/producer organisations. Providing support therefore to strengthen and support these organisations to form and/or develop and further grow towards adequately engaging in policy dialogue, in strategic decision-making processes of the concern, and becoming involved fully as key actors and networks in investment activities is vital. Capacity development for producer/stakeholders, notably smallholders engaged in the sector, is essential - in a broad range of technical skills and aspects of management, trade, and policy.

Dear Coordinators of CFS-HLPE,

The study on fisheries and aquaculture sectors in terms of sustainability to food security and nutrition completes the Global Strategy for Food Security and Nutrition. Most of the issues on the sector to be addressed have been taking into consideration.

But to sustainably address all the issues that the sector suffers from, it is important to include in the themes of reference a monitoring aspect on the sector. This implies identifying a minimum set of core data to be produced. This will assist policy decisions making towards sustainable development of the sector, including its sustainable contribution to food supply and provide basic data to assess the status of natural fishery resources and ecosystems, so as the impacts of fisheries and aquaculture activities.

Most of the time, censuses are carried on food production and livestock, and indicators are developed on the status of food security and nutrition while fisheries and aquaculture sectors, which also are sources of food, never know these and the few statistics on these sectors rest on the production. The rapid evolution of the sector needs more attention and it is very important to develop indicators for monitoring.

Best regards

Kodjo Dokodjo

Ministry of Agriculture, Livestock and Fishery

Agricultural Statistics Service

Lomé, Togo

Dear CFS-HLPE Coordinator,

I am pleased to see that the Committee on World Food Security and the High Level Panel of Experts are recognizing the significant role fisheries and aquaculture play in food security and nutrition. However, I would like to provide a few comments to the draft scope on “The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition”:

Role of fish in food security and nutrition

Fish and fisheries products are important sources of protein, but the role of fish in food security and nutrition is more than a provider of animal protein and livelihoods to vulnerable populations; this fact cannot be left out in a report covering the role of fisheries and aquaculture in food security and nutrition! Although fish is a unique source of high quality protein, fish is an even more important source of other nutrients such as essential long chained omega-3 fatty acids (EPA, DHA), minerals/trace elements and vitamins. For some nutrients, such as the long chained omega-3 fatty acids, iodine and vitamin D, fish is the main, and in most cases the only significant and natural food source available.

Fish and fishery products have an important role as a source of nutrients particularly important for brain and neurodevelopment in children, underlining the importance of fish in the diets for women of childbearing age, infants and young children. The report of the “joint FAO/WHO expert consultation on the risks and benefits of fish” clearly underlined the importance of fish in our diets, particularly for the most vulnerable groups; young children and women of childbearing age: http://www.fao.org/docrep/014/ba0136e/ba0136e00.pdf

Small size fish of low economic value are often the ones with the highest nutritional value; eaten whole with heads and bones they are excellent sources of micronutrients in addition to providing valuable protein and essential fats.

Aquaculture, sustainability and food/nutrition security

Aquaculture is providing close to 50% of fish for human consumption and will be the main provider of fisheries products in the very near future. A sustainable management of fish farming is crucial, and feeding fish opt for human consumption to fish is a dilemma. However, significant resources are used on research looking for alternatives to fishmeal and fish oil. Despite the growing aquaculture production, total volumes of fish oil and fishmeal used for aquaculture have stabilized, or even started to go down. Raw material for fishmeal and fish oil is also more and more based on waste products from fish processing rather than fish.

The report mentions farmed species such as salmon, shrimp and oysters, species that provide livelihoods to many people. However, these species are mainly consumed by populations with a purchasing power far beyond the global average; they are hardly food insecure and are less affected by malnutrition. Farmed species such as carps (cyprinids) and tilapia have a much greater direct and indirect contribution to food security and nutrition. Total production of e.g. carps is more than ten times the production of salmonids, and utilizes only a fraction of fishmeal and fish oil (if anything at all) compared to carnivorous species. Carps provide more than ten times more protein than salmonids, and even though salmon is an extremely good source of long chained omega-3 fatty acids carps are much more important providers of these essential fatty acids due to their production volumes.

In 2010 around 20 million tonnes of seaweed was produced. This is a an important cash crop and a unique provider of essential nutrients to many diets, particularly as a source of essential minerals.

Best regards,

Jogeir Toppe

Fisheries Industry Officer

FAO-FIPM

 

Issue 1 highlighted for inclusion in the HLPE focuses on the implementation of the FAO “Code of conduct for Responsible Fisheries and Aquaculture”. The HLPE study would benefit by also considering guidelines for sustainable small-scale fisheries, since small scale fisheries and aquaculture make a major difference to food security and nutrition of food insecure people. In this regard, the ongoing process to negotiate the "International Guidelines for Securing Sustainable Small-scale Fisheries" should not be ignored. http://www.fao.org/fishery/ssf/guidelines/en

Regarding issue 3 on key socioeconomic issues affecting the sustainability and development of fisheries and aquaculture for food security, it is important to recognize the need for small-scale fishing communities to have secure incomes, decent working conditions and improved access to social services. Small-scale fishing communities are vulnerable not only to destruction of natural resources, but also to unpredictable income, injury and loss of life. Fishing is recognized as one of the most hazardous occupations and improvements are needed in terms of safety and health as well as access to social protection. Furthermore, fishing communities, especially those in remote locations, often do not have access to quality schools or health services. Child labour and a lack of decent employment opportunities for youth are also challenges facing many small-scale fishing communities that contribute to perpetuating cycles of poverty and food insecurity.

The Decent Work and Employment chapter of the published zero-draft of the International Guidelines for Securing Sustainable Small-scale Fisheries provides further guidance on these issues, ftp://ftp.fao.org/FI/DOCUMENT/ssf/SSF_guidelines/ZeroDraftSSFGuidelines_MAY2012.pdf as does the FAO-ILO guidance document on addressing child labour in fisheries and aquaculture http://typo3.fao.org/fileadmin/user_upload/fao_ilo/pdf/FAO-ILOGuidelines_child_labour_in_fisheries_and_aquaculture_Policy_practice_Preliminary_version.pdf

Additional materials can be found from the “Addressing labour conditions in fisheries and aquaculture: How to tackle child labour and improve working conditions?” FAO-ILO side-event to FAO’s Committee on Fisheries held in July 2012, including national experiences from Thailand, Cambodia and Malawi. http://www.fao-ilo.org/news-ilo/detail/en/c/151081/?no_cache=1

The HLPE study should also look into how youth can be best engaged to contribute to sustainable fisheries management, as well as the challenges faced by youth to engage in the sector beyond involvement in capture fisheries and how these constraints can be overcome. As an example of work in this area, the FAO Junior Farmer Field and Life Schools approach is being adapted for fisheries and aquaculture. Support for youth inclusion in workers’, producers’ and other socio-professional organizations is another important step in the promotion of decent youth employment in fisheries communities, particularly with regard to increasing youth’s access to natural resources, inputs, marketing, information and financial services.

Gender issues should also be systematically considered in the report as both women and men play important and complementary roles in the governance and development of the sector. Their differing roles and conditions of work, health and education as well as constraints in access to resources, information and markets need to be addressed in the adoption of a socially and environmentally inclusive approach to fisheries and aquaculture.

It is indeed very timely for a paper like this, and the hope is that the outcome will lead to a definitive guide on policies and practices that provide for a sustainable fisheries and aquaculture wherein a just equity is provided within the current generation as well as between generations and appropriate responsibilities are taken by those who take profit from the resource.

In suggestions on the scope, I would like to suggest to provide priority space for outlining and clarifying key responsibilities for both state and non-state actors (e.g. following the format of "Ruggie Principles").

Also the (likely) adverse effects, and on top of that likely widening further the in-equity gap between 'north and 'south', of climate change and how to deal with this responsibly deserve extra highlight. Insights provided by the Sea around us Project (Daniel Pauly), as to where fish will go if waters warm up, are quite staggering.

One area seldom discussed in-depth is the possible actual volume and value of inland fisheries and un- or underreported artisanal coastal catches. There may be more fish out-there then is realised. And with this, more value that needs properly taken care of, more to lose and more to win. In quite a few countries millions of the poorest of the poor rely on the 1-2 or 3 fishes they can catch every day. (Luckily for them) This is, as yet, rarely noticed by governments. However, as degradation continues these people will rely on a government that does take notice and develops appropriate policies that help secure this little but effective safety net the poor in many places (now) still enjoy.

In thematic information this paper can provide, I may not have specific new themes to suggest. I think I saw the most obvious themes mentioned. But here below I will want to make the case for specific perspectives to known themes.

A lot has been written about co-management approaches and CB-CRM in fisheries, and most of that is recommending the approach or presenting positive effects from applying the approach. However, little of this positive assessment yet comes through in actual policy decisions made both national and international levels. It will be worth it deciphering the drivers and incentives both for and against deciding for such an approach. The key question is perhaps not whether CB-CRM/co-management principles work. Rather, the key question is likely what is holding governments back to decide in favour of this approach? A discussion around drivers and incentives behind fisheries management decisions and practices may help us further. Costs, risks, profits and opportunities are not lined up appropriately in fisheries management practices, and it might be worthwhile to consider making a contribution to CB-CRM/co-management theory from the perspective of really linking up these drivers in a single framework.

Subsidies as stimulator of the wrong (unsustainable) behaviour are already mentioned. An additional lens to this could include the distortion that results from subsidies to the lives and livelihoods of those who need access to (a few) fish the most: the poor and vulnerable. Fisheries is an environmental concern, for sure. But it is also a social concern, and, with that, a concern of equity and injustice and a possible preventer or driver of great social unrest. The point that deserves to be made is that subsidies are not just an anomaly from an environmental sustainability perspective, but also provide receivers of the subsidy with an incentive to take livelihoods, food, and justice away from the very poor households and the children therein. Governments are, in fact, paying for the creation of poverty! Linked with subsidies (possibly a specific sub-set of subsidies) are the access agreements that have facilitated a 'northern' fishery on a 'southern' stock. The economic data around these clearly show the injustice and the, sometimes, laughable fees paid in relation to the value taken. Besides an attempt to try and curb this practice through voluntary policies and respectable recommendations , it could be worthwhile to look into the creation of an international law or body of laws that would, effectively, lead to criteria and a system of oversight to distinguish between a justifiable deal at an appropriate price and one that is clearly not so. In (only) slightly in-accurate but more philosophical terms....isn't 'stealing' quite the opposite of 'dumping' and aren't therefore both equally worth a system of judgements and sanctions under a just WTO?

Aquaculture currently has the reputation, among many in the fisheries sectors, that it provides jobs, development country incomes, and will fill the void that an (almost) imminent collapse of the world's fisheries will create in the (possibly very) near future. There is a lot that can be said to the contrary. When aquaculture and its future development is discussed, I recommend this is done with the full inclusion of its intended and un-intended effects on people and ecosystems; both nearby and far away from aquaculture production systems; and in the perspective of the duration of the assumed benefits to global food security. Solutions to overcome these problems do exist and seem not too costly. However, political incentives (short term maximisation of GDP statistics; tax benefits; job growth figures) and corporate incentives (opportunistic short term profit-taking) have sofar worked together to create an industry that has a negative biomass use/yield ratio, a negative environmetal cost/benefit ratio, and is likely also providing a negative livelihood gains/losses ratio. So both the negatives and the positives need to be looked at with equal attention and concern. We may wish to fill a future void, and we may, inadvertedly, end up enlarging that void. The risk is worth its scrutiny. At the same time, an analysis around aquaculture and (the drivers behind) its expansion may hold many useful lessons as to the need for links and connections between trade-related debates, MDGs and equity and poverty alleviation, and environmental economics. This sector potentially illustrates much of what, in somewhat less visible form, also ails sustainable and equitable development in other food sectors.

DAMS ARE DESTROYING FISHERIES & LIVELIHOODS IN INDIA

Submission from South Asia Network on Dams, Rivers and People to the FAO.

India stands second in terms of fisheries production in the world with a production recorded at 9.3 million tonnes (m T). 60% (5.8 m T) of the 9.3 m T is contributed by inland fisheries (FAO FISHSTAT 2010). Inland fisheries sector of India is not only a livelihoods provider (75% of 14.49 m fisherfolks are from the inland sector), but a crucial source of food/ nutritional security to millions of poor lining the banks of its 7 m ha of inland water area including 45,000 km of rivers, 1.2 m ha of floodplains, lakes and wetlands etc. Even waters categorized as derelict waters in statistics are not derelict to community residing by its bank as these could be a source of nutrition for the poorer communities.

The above figures could, more likely than not, be a gross underestimation given the widely dispersed nature of inland fisheries production (unlike its marine counterpart which is largely landing-center based) and also due to the fact that only the big marketable species are counted in. However, the small indigenous varieties which are most often considered as trash (in market parlance) play a huge role in ensuring nutritional security of the poorest of the poor. The Indian inland waters are also home to 877 indigenous species of freshwater fishes and 113 species of brackishwater species[1].

Impacts of Dams on Riverine Fisheries: Though our inland waters are biodiversity rich supporting millions in terms of fisheries-based livelihoods and / or food (cheap protein in the form of fish), this very environment is constantly under threat of depletion and degradation due to changed land and water use pattern, in the name of development. The major culprit as shown by increasing number of studies[2], reports, local experience are the 5,100+ large dams of India that hamper water cycle by drying up rivers, changing hydrology, increasing sedimentation, concentrating pollution/ pollutants, etc. This in turn blocks migration, destroy spawning grounds, spawning cues, etc affecting the fisheries and thereby fisheries-based livelihoods as well as the source of cheap nutrition for the poor. Similarly, water pollution, over fishing and introduction of exotic species are also factors adversely affecting freshwater fisheries. However, dams are the greatest threat to riverine fisheries.

Fisheries in mighty rivers like Ganga, Krishna, Cauvery, Narmada, Sutlej, Pennar, Mahi and Sabarmati have collapsed already.

In Ganga, average yield of carps has come down by a whopping 90% in past four decades, from 26.25 kg/ha/year to 2.55 kg/ha/year (see adjacent table). Sedimentation has increased 30 times at Allahabad and Varanasi since 1980s. This has coincided with worst fisheries period.

Hilsa Fish, Bengali delicacy has suffered hige losses after commissioning Farakka Barrage in 1975. Prior to Farakka the fish migrated from Bay of Bengal upto Allahabad.

Post Farraka, the yield of Hilsa dropped from 91 kg/km in 1960s to near zero in 2006 in Allahabad. The fish production is declining year by year and can now be afforded only by the very rich. How water flow volume affects fishery can be well illustrated by Hooghly estuary, where the quantum jump in water volume after commissioning Farrakka Barrage resulted in sharp increase in estuarine fishery from 9482 t (1966-75: pre Farrakka period) to 62000 t (1999-2000).[3]

However, Hilsa catch in almost all estuaries and rivers like Ganga, Krishna, Godavari, Mahanadi, Cauvery and Narmada have collapsed due to blockage caused by upstream dams.

Krishna Estuary has become hypersaline due to absence of water release. This has resulted in collapse of fisheries in the estuary.

Mahseer fisheries have collapsed in Madhya Pradesh which once had the best Mahseer in India, following blockage to migration and changes caused by Bargi and Tawa Dams. Mahseer, which was once an abundant fish throughout Indian has now become endangered species.

Dams have also affected our National Aquatic Animal Gangetic Dolphin by blocking its migration, isolating groups, limiting food availability in the Ganga. It now thrives only in a few sanctuaries between barrages.

Central Inland Fisheries Research Institute says: “Larger dams are major cause of degradation of aquatic environment and disruption of livelihoods of communities dependent upon the fishery along the rivers. In India, natural flow of all major rivers have been regulated for fulfilling water demand of agriculture and power sector, without giving any attention to fisheries sector. As a result, rivers have lost their character and fisheries have suffered huge losses.”

The Working Group (WG) 12th FYP states: “Water abstraction for irrigation and power generation is the biggest reason (for problems of inland fisheries), causing reduced or no flow in the main channel to support fisheries and other riverine fauna and flora.”

The WG of 10th FYP said, “Riverine fishery is already showing a declining trend. Millions of fisherfolks and their families depend on rivers for their livelihood. These factors prompt an accent on development of riverine fisheries, which has rarely got the deserved emphasis of the planners.  Therefore, it is the time, to take emergent steps to conserve our riverine fish biomass, to restore their habitat.”

Impacts on Communities Fisher folk communities adversely affected by dams, hydropower projects and diversions in the upstream and downstream receive no rehabilitation or compensation. These are some of the poorest sections of Indian society. Wainganga Dam, mired in corruption charges and controversies will destroy livelihoods of more than 15000 people in the upstream of the dam, while we do not even have estimates for downstream losses.

Though efforts at mitigation through establishing hatcheries are one of the mainstays of the Environment Management Plans of such projects, the effectiveness of these interventions are rarely assessed by MoEF or any credible agency. A credible baseline study on the biodiversity of the affected rivers is imperative step prior to the approval of any projects, but that is not happening either as part of the Environment Impact Assessment nor are there any credible cumulative impact assessment and carrying capacity studies before approving multiple projects on the same river.

Though India is a signatory to the Convention on Biological Diversity (CBD), huge loss of its aquatic biodiversity in general and fish biodiversity in particular is continuing unabated, CBD has been of no help, nor is the National Biodiversity Authority of any help.

Is the Ministry of Environment and Forests listening? Ministry of Environment and Forests, Govt of India and the Expert Appraisal Committee on River Valley and Hydropower projects have taken the role of mute by-standers.

Dams, even cascade of dams are increasingly being sanctioned in bio-diverse areas, without proper appraisal, properly researched mitigation measures including fish ladders, fish passes or proper environmental flow regimes, there is no monitoring of compliance of environmental laws, environment management plan or conditions of clearances, and decisions of the EAC are unscientific, inconsistent and ad hoc. For rare dams, they recommend fish ladders, but for most where it should be feasible they do not.

Fisheries Management Plans hinge on setting up hatcheries and fish farms, which are cost intensive, do not always help local species and communities and whose efficacy on river biodiversity is entirely unassessed. Fisheries Departments are getting crores of rupees per dam as compensation and additional amount for setting up hatcheries, so they are happily sanctioning more and more dams on hereto free flowing rivers like in Himachal, Uttarakhand, Jammu & Kashmir and North East.

EAC relies completely on almost entirely cooked up and false EIAs. The Comprehensive EIA for  200 MW Gundia HEP done for KPCL says that there are no endemic fish species in the region, where more than 6 new fish species have been discovered just in the past 6 months!

Currently, there is no body entrusted with the protection of freshwater biodiversity, no separate Ministry for fisheries, no law for protecting fish diversity (the Fisheries Act, 1897 deals only with edible species), no law for protecting river flows, no law for enabling fish migration, no law for compensating affected Fisherfolk, to list a few. These are very serious gaps, with impacts on ecology as well as sociology. We request the MoEF to look into these overarching issues.

Our Appeal:

1. We urge MoEF and specifically EAC to pay attention to in situ conservation of rivers and fish. At least one river should be declared per state as protected, no go zones for dams and hydropower projects to conserve fish biodiversity. More riverine areas should be protected under commitment to CBD and Wildlife Protection Act.
2. Support, encourage or undertake research about the nutritional contribution of freshwater fish to rural and urban poor communities.
3. Research on fish passes and ladders appropriate for Indian conditions and fish species must be undertaken urgently
4. Appropriately designed Fish ladders & passes must be fitted to all existing barrages and dams where possible.
5. E flows norms should be stringent, river and species specific. Eflows releases should happen preferably happen through fish passes and ladders, certainly not additional turbines.
6. Free flowing distance of river between two dams in a cascade should be minimum 5 kms, not the current 1 or less than 1 km.
7. Amend EIA notification 2006 to include dams for drinking water, industrial supply, embankments and hydro above 1 MW to require clearances. Strong punitive action against shoddy EIA consultants submitting false reports.
8. Undertake assessment of fish diversity in various rivers and on impacts of dams on fish and livelihoods and reliable inland fish production statistics.
9. Bring out a white paper on effectiveness of hatcheries, including their impacts on riverine fish diversity and livelihoods, how the money allocated for hatcheries is spent.
10. Inventory of freshwater fisherfolks in India and their problems
11. Ensure that fishermen affected by dams are included in social impact assessment and adequately compensated, including fishing rights in reservoirs.
12. Consider the rivers from an ecosystem perspective rather than just as a source of water or just considering a particular stretch of river.
13. A Comprehensive National Inland Fisheries Act for protection of fisherfolks and fisheries.

A detailed submission on the issue has been sent to the Union Ministry of Environment Forests and its Expert Appraisal Committee on River Valley and Hydropower projects, endorsed and supported by over twenty groups and eminent individuals including scientists and member of National Board of Wildlife and National Tiger Conservation Authority, to take urgent steps for protection of inland water fisheries and millions dependent on them. Full text of the submission is available at: http://sandrp.in/rivers/MoEF_EAC_Submission_Fisheries_Nov2012.pdf

We hope that that the High Level Panel of Experts at FAO considers our submission and strongly recommends protection of rivers, fish and communities from the onslaught of Dams, Hydropower projects and abstraction.

Parineeta Dandekar www.sandrp.in