ROYAL COMMISSION ON ENVIRONMENTAL POLLUTION Comments from the Environment Agency on the scoping of the Environmental Effects of Marine Fisheries Study From: Dr. D Clarke, Head of Fisheries, Environment Agency, Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol BS32 4UD September 2002 SUMMARY The Agency welcomes this consultation and wishes to support the Commission in the search for more sustainable marine and coastal fisheries management policies. The Agency has recently similarly welcomed the DEFRA consultation on the Review of the Common Fisheries Policy, with its emphasis on sustainability and on the ecosystem approach to fisheries management. The Agency looks forward to further input to this consultation process. The key points raised in this response are that the Agency: Has an active and growing role in environmental monitoring in estuaries and coastal waters and can play a full part in the future development of more sustainable fisheries management policies. Has not conducted formal studies into the environmental effects of marine fisheries but has cited a number of studies of which it is aware. Considers that shellfish culture is a developing issue in England & Wales. There are risks of the attendant problems of pollution, disease and the introduction of alien species documented in relation to fin fish farming. Adequate control measures are required. Notes that many marine habitats are already recognised under conservation legislation. Damage to such habitats can be associated with marine fisheries. Recovery periods can be prolonged. Considers that commercial fishing gear can have a range of damaging impacts on target and non-target species and can cause habitat disturbance. Recreational fishing impacts should not be overlooked in this context. Considers that protected areas/closures are an important element in the development of more sustainable integrated regional fisheries management policies. 1. 0 INTRODUCTION 1.1 Under the Environment Act, 1995 the Environment Agency (hereafter referred to as the Agency ) has a general duty to maintain, improve and develop salmon, trout, freshwater fish and eel fisheries under its jurisdiction (out to 6nm from baselines). In certain areas, the Agency acts as a Sea Fisheries Committee under the terms of the Sea Fisheries Regulation Act 1966. In such areas it has powers to regulate sea fisheries under the 1966 Act and the Sea Fisheries (Conservation) Act 1967. Page 1 of 5
1.2 The Agency also has a range of marine monitoring responsibilities brought together under the National Marine Monitoring Programme and conducted with a range of partners. 2.0 KEY ISSUES 2.1 Future marine monitoring The Agency will be the competent body in England & Wales for the delivery of the monitoring requirements associated with the Water Framework Directive. For the first time, this will require the development of a robust fish sampling strategy in all estuaries and coastal lagoons (termed transitional waters). The Agency is leading an international project to develop this sampling strategy. Existing elements of the monitoring programme under development by the Agency have been recognised by the EC Agriculture and Fisheries Research programme (FAIR) as representing European Best Practice in the field of fish monitoring for commercial fish species in inner estuaries. The final sampling programme is very likely to be a partnership delivered between a number of interests. One important by-product of the sampling programme will be the provision, for the first time, of robust fish community data on which more sustainable fisheries management strategies can be based. The Agency will actively seek to support the development of such strategies through the use of this data. The Agency has contributed to a collaborative Expression of Interest under Framework VI to study the biology of fish in transitional waters in support of this intention. 2.2 Formal studies The Agency has not conducted formal studies into the theme of this consultation, but through its work it is aware of reports by other parties. Blaber et al. (1999), conducted a review of the effects of commercial fisheries on estuarine ecosystems. A more detailed assessment is provided by Jennings and Kaiser (1998). Hall (1999), conducted a similar study in marine areas, predominantly in the North Sea. Further information is available in the grey literature, particularly in the information developed for and by the International Council for the Exploitation of the Seas (ICES) and the local sea fisheries committees. Studies looking at the reform of the Common Fisheries Policy have also touched on the environmental impacts of marine fisheries. See Symes 2002, English Nature; Coffee and Dwyer, 2000 RSPB ; Edwards and White, 2001 The Wildlife Trusts; McGarvin and Jones, 2000 World Wildlife Fund UK. The next five issues for the Agency relate to the five of the seven priorities for action identified in OSPAR s Quality Status Report for the North Atlantic which are concerned with the environmental effects of fisheries and appear in the consultation. 2.3 Aquaculture Many studies have been conducted in recent years looking at the pollution, disease and alien species introduction issues which can be associated with aquaculture. While the Agency experience of this situation is largely limited to land based fin fish farming, it is aware that there are a growing number of applications for shellfish Page 2 of 5
culture, particularly for mussels along the east coast of England from the North East down to Kent. These could become major industries over the next decade. The Agency will seek to ensure that sufficient controls are in place to obviate or minimise the problems attendant with cage fin fish farming. In one proposal for mussel farming in the North East, spat collection is proposed outside the estuary from an adjacent SPA. The impacts on the SPA are unknown. Escapement of alien species, presumably from culture stations, is now occurring. Pacific oysters are now established in the lower Thames estuary and in the Solent. A new dredge fishery for non-native clams has begun in the Isle of Wight. 2.4 Vulnerability of deep sea species No comment. 2.5 Risks posed by fisheries to particular ecosystems and habitats Many marine sites around the UK coastline are now recognised for their importance for nature conservation. For example, there are now 23 marine SAC s under the EU Habitats Directive, covering c. 950,000 ha in England and Wales. Many marine habitats are important to biodiversity and support a range of species which are protected or are UK BAP species ( eg. Twaite Shad, Common Skate, Native Oyster). The Marine Wildlife Bill was set to have important implications in this field. Many of the features for which sites are designated are vulnerable to disturbance by fisheries operations. The Agency has concern over the impact that dredge, trawl and rock-hopper fishing have on soft sea bed habitats (eg Sabellaria reefs) and the extremely productive sub littoral and littoral habitats. Concern has been expressed that the impacts on the softer habitats may be as devastating as those arising from aggregate extraction. Recovery periods may be prolonged. Many coastal and estuarine situations have poorly mapped archaeological resources which are similarly vulnerable to physical damage by fisheries operations. 2.6 Adverse environmental impacts of certain fishing gear There are a range of issues under this heading for which the Agency would cite the references given above, particularly Blaber, et al. 1999 and Hall, 1999. The Agency has direct concern over the following areas: Physical damage to habitat as described in 2.5 above. This may cause reductions in spawning success, recruitment or productivity. Smothering and toxin release associated with bed disturbance. Loss of biomass and biodiversity associated with shifts in community structure. Of particular concern are the losses to fragile and slower growing fish and invertebrate species. Non-target species. There are concerns about losses of cetaceans and birds, particularly in entanglement fisheries and the threat to salmon and sea trout stocks in drift net fisheries for bass and mullet. Target species. Undersized fish of target species are returned, but in practice many discards are damaged and will not survive. Many commercial fisheries operate in nursery and spawning areas with little effective regulation. Page 3 of 5
Recreational fishing. Rod and line fishing can have substantial direct and indirect impacts. Angling for sea fish may have damaging impacts on salmonids as unintended by catches. Some active bass fishing is no more than commercial fishing in disguise. The Nature Conservancy Council (Cadman, 1989) studied the impacts of bait digging for lugworm. Recreational collection of shellfish from the shore can have similar impacts. Some concern has been expressed about the growing collection of shellfish and spear fishing by recreational divers. A draft Code of Conservation has been produced by a consortium of interests to reduce the environmental impacts of recreational sea fishing. 2.7 Closures With the agreement and co-operation of the sea fisheries committees and other local interests, the Agency would support the introduction of closures to protect and promote local spawning and nursery sites as an essential part of the move towards more sustainable fisheries management. 2.8 Consensus management Coastal and estuary management planning processes have brought much new conflict resolution and consensus around the coasts of the UK in recent years. The role and effectiveness of sea fisheries committees and the growth of environmental demands placed upon them has been well summarised by Symes (2002). The Agency considers that more dialogue and effective partnership between the Agency and the committees is needed to bring about the resolution or minimisation of the problems described. The development of robust sustainable regional fisheries management policies integrating the interests of all parties concerned will be important. 3.0 CONCLUSIONS OR RECOMMENDATIONS The Agency is concerned about the environmental effects of marine fisheries. The Agency will work actively with other partners to develop more sustainable fisheries management policy and practice which minimise the negative environmental impacts of marine fisheries. 4.0 REFERENCES Blaber, S.J.M, Albaret, J-J., Chong Ving Ching, Cyrus, D.P., Day, J.W., Elliott, M., Fonseca, D., Hoss, J., Orensanz, J., Potter, I.C. & Silvert, W. 1999. Effects of fishing on the structure and functioning of estuarine and nearshore ecosystrems. ICES Journal of Marine Science 75pp. Cadman, P.S., 1989. Environmental impact of lugworm digging. Swansea. Nature Conservation Council. Coffey, C., & Dwyer, J., 2000. Managing Inshore Fisheries: Time for Change. Sandy: Royal Society for the Protection of Birds. Edwards, J., & White, R., 2001. The future of Inshore Fisheries : A Discussion Document. Newark: The Wildlife Trust. Page 4 of 5
Hall, S.J. 1999. The Effects of Fishing on Marine Ecosystems and Communities. (Fish Biology and Aquatic Resources Series 1.) Blackwell Science, Oxford. pp.274. Jennings, S. & Kaiser, M.J., 1998. The effects of fishing on Marine Ecosystems. Adv. Mar. Biol., 34, 201. McGarvin, M., & Jones, S., 2000. Choose or Lose: A Recovery Plan for Fish Stocks and the UK Fishing Industry. Godalming: WWF-UK. Symes, D. 2002. Inshore fisheries management in England and Wales: Facing up to the challenges of the 21 st Century. Peterborough: English Nature. FURTHER INFORMATION Further information or background to this response can be obtained from Dr. D Clarke, Head of Fisheries, Environment Agency, Rio House, Waterside Drive, Aztec West, Almondsbury. BS32 4UD. Email: dave.clarke@environment-agency.gov.uk. September 2002 Page 5 of 5