Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

Australian contribution to the High Level Panel of Experts for Food Security and Nutrition (HLPE) report on The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition

Australia considers that sustainable fisheries and aquaculture have the potential to improve livelihoods and promote food and nutritional security. Australia welcomes the zero draft HLPE report on The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition.

Australia’s fisheries are managed sustainably and for optimum yield. The Australian Government develops and implements policies that promote a profitable, competitive and sustainable fishing industry while protecting and conserving our marine ecosystems and biodiversity.

Overall comments

Australia encourages greater balance and nuance throughout the HLPE report on The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition.

Proper focus should be given to the benefits of open and transparent markets in the report.

The paper presents domestic and regional trade as an alternative to international trade, implying that there is competition between them. International trade is presented as a developed/developing country nexus when developing countries are the largest in terms of capture fish production and trade.

Aquaculture is a global, competitive industry and fish products are highly traded internationally. In many advanced economies, seafood imports will continue to be necessary to meet domestic demand in the foreseeable future. Meeting this demand through global trade is a significant opportunity.

Trade, including of fish and aquaculture products, can create commercial opportunities and investment, generating growth. It can also create employment, giving people higher and more stable incomes, and therefore greater access to food.

The content of the report is very focused on the role of sustainable fisheries and aquaculture for food security and nutrition in developing countries.  However, we do not feel the focus on developing countries is adequately expressed throughout the document. 

The paper should also provide balanced treatment of small-scale and large-scale operators and consider the consequences for food security of failing to develop appropriate sustainable domestic fisheries policies. 

Research related comments

Australia submits the following general research related matters for the HLPE’s consideration:

The question this paper seeks to address contains the premise that there is a link between the development of fisheries and aquaculture sectors and food security and nutrition. This premise should be critically examined. While there may be a link between poverty and food and nutrient deficiency, the paper does not present conclusive evidence that fish as a component of the diet is linked either to food and nutrient deficiency or to poverty. For example, page 28 states that fish provide 1% of the calorie intake of humans, and there are countries where fish does not constitute a significant part of peoples’ diet without leading to food or nutrient deficiency. Poverty has multiple causes and there may be commercial reasons why low-income food-deficient countries seek to develop their fisheries and aquaculture sectors. Applying a food security and nutrition lens to fisheries and aquaculture sector development can distort the complexity of these issues.

A better question could be ‘how can fish production in low-income food-deficient countries (LIFDCs) be maintained or increased now and in the long-term?’ An examination of this question could focus on issues such as market development, access agreements, trade barriers, equitable distribution of resources, infrastructure, value added processing, domestication and genetic improvement of fish stocks, efficiency of production, labour, and foreign exchange earnings. Most of these issues are touched on in the paper but do not get balanced treatment. The equitable distribution of resources is difficult to address but may be more relevant to poverty and food security.

The paper does not raise the role of subsidisation of fisheries effort which has been clearly identified internationally as major contributory factor in decreasing the sustainability of global fish stocks and in distorting production patterns in this sector.  The role of subsidies and potential approaches to reforming international policy in this area, and how this might have benefits in terms of sustainability of fisheries and increasing food security would be a worthwhile addition to the work carried out in connection with the production of this paper.

The paper could examine the negative food security impacts of poor fisheries management and fisheries policy. This could provide valuable background for international attempts to curb unstainable fishing.

From the perspective of Pacific fisheries, the body of the paper could be enhanced through greater consideration of small island developing states, most of which have significant marine resources; the significant threats to coastal fisheries from climate change and population growth; and the financial viability of small-scale fisheries.   

We also submit the following specific comments:

• Page 9, line 41. Suggest deleting ‘and the negative impact that large-scale operations can have on smaller operators’. There is also the possibility for small-scale operators to have negative impacts on large-scale operators. The report states artisanal fishers catch approximately the same volume of fish for human consumption as commercial fisheries (page 53). Therefore artisanal fishers should be under equal levels of scrutiny as their large-scale counterparts to ensure long-term sustainability of fish stocks. The key focus of international fisheries is proper management of key stocks and ensuring that the right of people to fish is maintained, for small-scale and large-scale operations. The report should treat operators of all sizes with balance. 
• Page 12, lines 16-30. Suggest rewording the final sentence (retaining appropriate references) to read: ‘In many countries, small-scale fisheries are an important, but underrated, source of employment, food security and income, particularly in the developing world and in rural areas.’
• Page 53, lines 4-12. The final sentence reads: ‘The estimate shown in Fig 3.9 suggests than in that regard small-scale fisheries are far more determinant than large-scale operations with respect to food security.’  We query whether this statement is accurate as it may not account for indirect employment. Indirect employment is likely to be higher for large-scale operations due to employment in related fields such as canning, processing, trade and oil production.
• Pages 52-55, ‘Economic efficiency’. Lines 11-15 on page 55 draw a conclusion about the relative amount of ‘attention, support and resources’ received by small-scale and large-scale fisheries. This conclusion does not appear to directly follow from the information presented. The narrative appears to relate to selected comparisons of costs but not whether these costs are supported by government intervention, investment or other sources. This section could be improved by broadening and deepening the analysis. It is important to consider whether the fisheries activity is economically viable and sustainable, particularly where fishers are in loss-making situations over sustained periods, yet continue to fish, supported by government intervention. Given the lack of clarity about the definition of ‘small-scale’ fishing, this section could also be improved by exploring possible impacts on various types of small-scale operations, including artisanal fishing/semi-subsistence fishing and the interaction with government domestic policies (which in turn have an impact on the international trade of fish). 

Specific comments on the recommendations of the paper

Recommendation 4

Lines 42-44 of recommendation 4 state that ‘where small-scale fisheries are in competition with larger-scale operations, governments should systematically establish national policies and regulations that discriminate positively these small-scale fisheries’.

This recommendation is not appropriate for all countries in all circumstances. Governments need to be able to implement policies and regulations that accommodate for a number of factors, not just providing benefit for small-scale fishing operations. Australia suggests rewording the recommendation to ‘Where small-scale fisheries are in competition with larger-scale operations, governments should give due consideration to all circumstances when implementing national policies and regulations as to not discriminate against either method.’

Recommendation 4 also calls for efforts to be made to ‘reform rapidly the way international fisheries and ocean governance is currently operating’. This statement is too broad, and not well substantiated by the evidence presented in the paper.

Recommendation 9

This recommendation is too simplistic about the positives and negatives of international fish trade. The suggestion that fish trade can cause malnutrition should be removed. Instead, the paper and its recommendations should recognise the negative outcomes that can occur where there are weaknesses or failures in the development of appropriate sustainable domestic fisheries policies and decisions by government which can then overflow and impact negatively onto world markets and international trade in fish.

Any additional guidelines, rules or procedures should not impose additional barriers to trade.

Regarding lines 32-35, the study should refer to the creation of parameters or rules for international trade and the role of governments in regulating to enforce them. This part of the recommendation should also reflect the role of the World Trade Organization.

Recommendation 10

This recommendation should be more balanced in regard to trade. It could call for improving fisheries governance everywhere to ensure increase sustainability.

Concluding comments

Australia thanks the HLPE for developing a zero draft of The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition and is happy to engage with the HLPE to provide comment on future drafts.