9 November 2009
Mr. Chairman, Distinguished Delegates and Observers,
Thank you for once again providing Seas At Risk with the opportunity to observe and address this meeting. I also deliver this statement on behalf of WWF and the Deep Sea Conservation Coalition.
We would like to congratulate NEAFC Contracting Parties on the significant achievements for the conservation of vulnerable marine ecosystems that have been made in this organisation. Some seven percent of NEAFC's Regulatory Area is now closed to bottom fishing to protect fragile cold-water coral reefs and seamount communities from the imminent threat of destruction. However, although these measures protect a notable amount of highly valuable habitat in the region, extensive areas where such habitats occur or are likely to occur are currently still left open for destructive bottom fishing and those habitats may be lost for centuries if bottom fishing in these areas continues without protection measures. The same fate awaits a number of populations of deep-sea fish which ICES constantly advises to protect from over fishing and excessive by-catch. We are deliberately losing the very basis on which generations of future fishermen could live.
This 28th Annual Meeting of the NEAFC Commission is the first annual meeting after the 31st of December 2008 deadline set by the United Nations General Assembly Resolution 61/105 - the review of this resolution will conclude next week in New York. While NEAFC has taken significant steps to implement the obligations arising from the Resolution, we are deeply concerned about the organisation's understanding that "current bottom fisheries practices in the NEAFC Regulatory Area do not have significant adverse impacts on VMEs" as stated in the response to the Secretary General of the UN. We would respectfully disagree as there is no scientific basis for making this assertion.
Paragraph 83 a of the Resolution commits NEAFC Contracting Parties to not authorize bottom fishing activities unless Environmental Impact Assessments show that these will not have significant adverse impact on vulnerable marine ecosystems or VMEs. We consider this provision to be the lynchpin of the Resolution, and we welcome the framework for EIAs NEAFC has agreed on. This requirement however, is currently only limited to areas with identified VMEs and areas outside the existing bottom fishing footprint. The underlying assumption is that within the existing footprint there would be no vulnerable marine ecosystems other than those identified, and therefore no EIA would be necessary. The UNGA Resolution does not make this distinction, and there is no scientific ground to restrict the requirement of impact assessments, as no systematic analysis of the likely occurrence of VMEs throughout the NEAFC Regulatory Areas has been conducted. In fact, it is quite likely that VMEs occur within the existing bottom fishing footprint in areas not closed to bottom fishing. Therefore, we call on this meeting to extend the requirement of prior EIAs to all proposed bottom fishing activities in the NEAFC Regulatory Area. Proving that those are sustainable in a manner consistent with internationally agreed criteria would greatly improve the implementation of the UN Resolution and the public perception of the regulation of high seas fisheries.
Currently, apart from the closed areas, the only protection granted to vulnerable marine ecosystems inside the historic footprint is the encounter or move-on rule. The cornerstone of the rule, the encounter threshold levels, are set at levels which have no scientific scientific basis and which effectively render the rule meaningless in all but exceptional circumstances. Adopting threshold levels of more than 60 kg of live coral and/or 800 kg of live sponge as recommended to this meeting (by AM 2009/12) would mean that, at a hypothetical retention efficiency of one to ten percent, the destruction of 8,000 to 80,000kg of sponges would not trigger any protective measures. This would not only result in significant further losses of habitat, but also be serious impediment to the recovery of these ecosystems. As ICES has been unable to provide advice on science-based threshold levels, and the rate of retention of certain cold water corals may well be in the range of zero to one percent, we recommend that any encounter of VME indicator species should trigger an interim closure of the area for bottom fishing.
The current approach also reveals a significant inconsistency in NEAFC's framework for protecting vulnerable ecosystems: if we expect such extensive impacts on habitats inside the current footprint, why are no Impact Assessment required prior to allowing these activities?
The management of deep-sea fisheries for sustainability requires substantial improvement. For most deep-sea species and stocks taken as catch or bycatch in deep-sea fisheries in the NEAFC Regulatory Area, insufficient information is available to even determine the impact of fishing, much less what level of catch could be considered sustainable. Several species of deep-sea sharks taken in the mixed fisheries for deep-sea species are classified as endangered or critically endangered by IUCN. We would also note that in spite of the measures agreed by NEAFC beginning in 2004 to cap and then reduce fishing effort, the reported catch of deep-sea species has risen by approximately 350% between 2004 and 2007 and that EC fleets are responsible for 95% of the catch. ICES has called for a complete overhaul in the management of deep-sea fisheries and the NEAFC performance review identified this as one area where substantial improvement by NEAFC is required. We reiterate our recommendation that fisheries for deep-sea stocks in the NEAFC Regulatory Area should be prohibited until an assessment of the impact of fishing on the fish stocks, including stocks of by-catch species, be conducted and a determination made as to what level of fishing, if any, on these stocks is sustainable in the long-term and appropriate and enforceable catch limits are established accordingly.
Ladies and Gentlemen, despite our identification of need for significant improvements to NEAFC's recommendation on bottom fishing activities, we not only acknowledge the difficulties in changing deep-sea fisheries to become sustainable and acknowledge the achievements made towards this end, but also welcome the further steps that have already been proposed, such as the recommendation from PECMAS to follow ICES' advice and protect further areas on Hatton Bank from destruction. We wish to draw the meeting's attention on a similar recommendation for areas on Rockall Bank.
We also welcome PECMAS' proposal that OSPAR is offered observer status to PECMAS and are pleased to see the development of the cooperation between OSPAR and NEAFC.
We would further like to draw your attention to our detailed position statement.
Seas At Risk, WWF and the Deep Sea Conservation Coalition would like to wish you, Mr. Chairman, Distinguished Delegates and Observers, a very successful meeting.