Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

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…).

Position Française

Le rôle de la pêche durable et de l'aquaculture dans la sécurité alimentaire et la nutrition

      Contributions : AFD, IDDRI

      Ces commentaires ne préjugent pas de la position française sur le document final

Le GISA salue les travaux menés par le panel d’expert de haut niveau (HLPE) du Comité de la sécurité alimentaire mondiale (CSA) dans le cadre du rapport « Le rôle de la pêche durable et de l'aquaculture dans la sécurité alimentaire et la nutrition».

Cette première version du rapport aborde les problématiques du secteur halieutique vus sous le prisme de la sécurité alimentaire et apporte des éclairages précis sur les points suivants :

• les valeurs nutritionnelles du poisson, les relations entre poisson et santé et entre poisson et sécurité alimentaire et nutrition sont bien analysées et précises.
• les approches de gestion écosystémiques par stock de poissons permettent d'aborder correctement les fondements de la crise des pêches.
• le rôle de la petite aquaculture artisanale dans la sécurité alimentaire est justement mis en avant.
• le rapport détaille dans un chapitre entier la question genre qui a une importance significative dans le secteur pêche et aquaculture.
• le marché international des produits de la mer est présenté sous ses deux aspects, positif et négatif, pour la sécurité alimentaire, ce qui est objectif.
• La pêche illégale, qui porte préjudice à la santé des stocks halieutiques et donc à la sécurité alimentaire, est bien mentionnée, quoique le sujet soit traité de façon très synthétique.

Le GISA souhaiterait néanmoins profiter de la consultation électronique pour souligner quelques points :

      Le rapport gagnerait à analyser davantage la contribution de la pêche industrielle et celle de la pêche artisanale à la sécurité alimentaire sans les opposer. Même s'il est vrai que la pêche artisanale dégage une meilleure valeur ajoutée à la tonne capturée, la capacité des deux modes de pêche à contribuer à la sécurité alimentaire dépend fortement de la zone de pêche, des ressources ciblées, des engins de pêche utilisés, de la destination des produits etc … Le rapport pourrait aborder de manière plus objective cette question centrale au risque d'être perçu comme trop idéologique et approximatif ce qui desservirait l'analyse globale du rapport. Faire du soutien exclusif de la pêche artisanale par les États une recommandation finale du rapport pour la sécurité alimentaire semble maladroit ; le rôle majeur que joue la pêche artisanale pour la sécurité alimentaire, ne doit pas masquer la contribution des autres modes de pêches, tout en proposant des recommandations adéquates, y compris si nécessaire de garde fous,  afin de veiller à leur contribution effective à la sécurité alimentaire. La pêche artisanale n'étant par ailleurs pas garante d'une absence de surexploitation des ressources[1]. Le rapport devrait préciser qu'il n'existe pas de définition reconnue internationalement de la pêche artisanale (« small-scale fisheries »). Ce sont les Etats, au cas par cas, qui adoptent des législations indiquant quels navires/arts de pêche peuvent être considérés comme relevant de la pêche artisanale. Or, il est difficile, dans ce contexte, de faire des amalgames entre par exemple des navires de pêche artisanale norvégiens, motorisés, suréquipés et pêchant de grandes quantités de poisson, et de simples pirogues comme ce que l’on peut trouver en Afrique de l’Ouest. Il y a ici une généralisation, qui mériterait une analyse plus fine .

           Pour les grands chalutiers pélagiques traquant essentiellement le chinchard noir, petit pélagique hauturier dont la vitesse d’évitement des engins de pêche empêche sa capture par des embarcations artisanales, l'approche entre la pêche artisanale et la pêche industrielle mériterait d'être plus balancée dans le rapport. En termes de sécurité alimentaire, ces navires approvisionnent en poisson congelé à bas prix la population des pays du Golfe de Guinée (Côte d’Ivoire, Bénin, Nigeria, Cameroun, … ).  Cette pêche doit être encadrée (régime des droits d’accès à la ressource, partage de la valeur ajoutée avec l’Etat hôte) mais elle a le mérite de mettre en valeur une ressource qui serait inatteignable par la pêche artisanale, tout comme l’exploitation des thonidés du large (mais qui elle ne participe pas à la sécurité alimentaire, pêche exportatrice sur les places thonières mondiales). Malheureusement certains chalutiers ne respectent pas la réglementation nationale ou l’allocation qui leur a été faite, d’où le mécontentement des acteurs de la pêche artisanale.

      Le rapport ne traite pas des difficultés statistiques du secteur des pêches et donc de l’imprécision des chiffres relatifs à la part du poisson dans la sécurité alimentaire (le montant global des captures, la part destinée à l’autoconsommation, les sous déclarations de certains pays à la FAO, les captures de la pêche continentale et le volume de production des élevages piscicoles villageois …). Le nombre d’emplois directs et indirects dans le secteur halieutique résultent plus souvent d’extrapolations/évaluations que d’enregistrements statistiques. A ce titre on peut citer le tableau 4.2 qui donne 129 000 emplois dans le secteur pêche au Sénégal alors qu’il s’agit du nombre de pêcheurs : les statistiques nationales relèvent 600 000 emplois directs et indirects. Une  mention  de  ce sujet serait nécessaire pour nuancer les approches quantitatives et donner des fourchettes d’erreurs.

      Plusieurs chiffres sont donnés sur les emplois directs et indirects et sur la population mondiale dépendante de la pêche. Le rapport se base sur les dernières actualisations faites par Thomson et les statistiques FAO, soit 32 millions de pêcheurs dans le monde. Il est communément admis que ces statistiques sont sous-estimées, parce qu’elles ne tiennent compte que des emplois enregistrés, et donc sans estimation des emplois non enregistrés et  sans conversion en Equivalent Temps Plein des pêcheurs pratiquant ponctuellement cette activité. Les chiffres que l’on trouve dans la littérature mondiale citent plus volontiers le double, 60 millions pêcheurs, avec 120 millions d’emplois induits dans le secteur, soit une population dépendante de la pêche d’environ  600 millions de personnes.

           Le rôle de l’aquaculture à petite échelle dans la  sécurité alimentaire mériterait d’être illustré par un encart sur la réussite du tilapia en Egypte (poissons très bon marché pour les couches socio-économique les plus défavorisées) et en Thaïlande. Le rapport recommande d’ailleurs de se focaliser sur les espèces omnivores, nécessitant peu de farine de poisson et peu d’huile de poisson dans leur alimentation.

           Le document critique à juste titre la capture du frai et des juvéniles de poissons dans le milieu naturel de certaines filières aquacoles, en tant que perturbation anthropique des stocks sauvages. Une exception devrait être soulignée dans le rapport sur la conchyliculture où le captage du naissain en milieu naturel est à l’échelle mondiale la méthode usuelle, bon marché et sans danger pour les stocks de mollusques concernés.

      Le rôle actuel et futur des Aires Marines Protégées, notamment en tant qu’outils contributifs aux plans d’aménagement des pêcheries et pas seulement en tant qu’outils de conservation n'est pas mentionné dans le rapport. Alors que l'existence des AMP permet de préserver ou de réguler certains stocks halieutiques et  jouent donc un rôle dans la sécurité alimentaire.

      Quelques remarques sur la partie consacrée à la pêche illégale dans la partie 5.2 relative à la gouvernance de la pêche :

• Aux lignes 11 et 12, les auteurs parlent de la Global Ocean Commission comme d’une autorité compétente en la matière, au même titre qu’Interpol. Or, cette commission est un club de réflexion visant à promouvoir certaines idées relatives à la gouvernance des océans sans aucun pouvoir en la matière.
• Les auteurs mentionnent également ligne 12 que l’attention est maintenant tournée vers les « flag, coastal and port States » et regrettent qu’un lien ne soit pas fait avec la pêche artisanale. Tout d'abord, il serait souhaitable d'inclure dans cette liste les « market States », les Etats qui importent beaucoup de produits de la pêche, et qui sont eux aussi l’objet d’une attention croissante[2]. Ensuite, les instruments discutés dans cette partie (le plan d’action de la FAO et l’accord sur les mesures de l’Etat du port) sont des instruments internationaux qui entendent avant tout réglementer les obligations et responsabilités des Etats en la matière, donc il est tout à fait légitime que les Etats soient les premiers destinataires et visés dans ce type d’instruments. Le plan d’action de la FAO a vocation à être ensuite adopté au niveau national, pour que soit mis en place des standards minimum de mesures et de moyens de contrôle du port afin d'assurer une lutter efficace contre la pêche INN (illicite), et c’est dans ce cadre que les Etats pourront faire la distinction, s’ils le souhaitent, entre pêcheries industrielles et pêcheries artisanales. Par exemple, l’UE, dans le cadre de son règlement 1005/2008 sur la lutte contre la pêche INN a simplifié considérablement le système des certificats de capture pour les captures de poissons en provenance de navires de pêche artisanale. 
• Il est indiqué qu’il n’y a pas de distinction faite entre ce qui est illégal, non déclaré et non réglementé. Or, le plan d’action de la FAO définit clairement ces trois types de pêche. Le manque de distinction peut en effet exister au niveau des conséquences qui existent à s’engager dans ce type d’activités[3]. Il s’agit ici de peser sur les Etats pour qu’ils s’engagent dans le développement de réglementations pour la bonne gestion et le suivi des stocks exploités par leurs pêcheurs, ce qui bénéficiera aux pêcheurs eux-mêmes, qui ont tout intérêt à avoir des stocks en bon état pour continuer à en vivre. Les réglementations, comme dans le cas du règlement européen sur la pêche INN, peuvent être adaptées au cas de la pêche artisanale, pour prendre en compte ses spécificités.

Comments on the CFS HLPE V0 Draft on the Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition (22 Dec 2014)

1. General Comments

The FAO Department of Fisheries and Aquaculture FI welcomes the opportunity to comment on the CFS HLPE V0 Draft on the Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition.

In general, this V0 DRAFT can serve as a frame for the major issues and important constraints that have affected and hampered sustainable development of the sector, especially in relation to its present and future contribution to food security and nutrition FSN. As such it is a starting point for preparing a thorough study on the subject for presentation at the CFS plenary in 2014. However, and as this draft states, it is “deliberately presented – with [its] range of imperfections – early enough in the process ... when sufficient time remains to give proper consideration for feedback received so that it can be really useful and play a real role in the elaboration of the report”.

Indeed, there are significant and worrying deficiencies in the draft report, possibly due to the fact that the main authors confined themselves often to their areas or work and did not reach out to other sources, views and works. This is why it is very important that the HLPE, strong on sociology, scrutinizes critically the various contributions provided during the first e-consultation and during this one. FI feels that the value of its first contribution, and many other important ones by leading authors and institutions, were only marginally debated or considered.  As an example, to assess how can the implementation of the FAO Code of Conduct for Responsible Fisheries CCRF and Aquaculture be further improved globally for sustainable aquatic resource management, FI suggested that the HLPE study should consider the overall work by the owners of the CCRF: FAO Members, the FAO Committee on Fisheries COFI and the secretariat FI. Not only the CCRF, but also other Code-relevant instruments and support for their implementation at national, regional and global levels should be looked into. This V0 Draft failed to do that. The role of the Regional Fisheries Bodies RFBs, including the Regional Fisheries Management Organizations RFMOs, and the importance of market instruments, such as eco-labelling and certification, are hardly considered.

While FAO recognizes in its work the special importance and challenges of small scale fisheries and aquaculture SSFA, it is important to highlight that this study is about the role of fisheries and aquaculture (small and large scale, artisanal and industrial, small and large fish, demersal and pelagics, including crustaceans and cephalopods) to FSN. V0 draft gives the impression that the HLPE has been tasked to look mainly at SSFA and the impact of large scale or commercial operations is considered more often under the prism of how negatively it can impact SSFA, but rarely on how these operations contribute fish to markets and food security, in developed and developing countries (e.g. the importance of supply of fresh, frozen, cured or canned pelagic fish such as sardines, mackerel or herrings to Sub-Saharan Africa or Egypt).  

The V0 fails to consider appropriately important works such as the Rio+20 Outcome document “The Future We Want”, which in para 113 states: We also stress the crucial role of healthy marine ecosystems, sustainable fisheries, and sustainable aquaculture for food security and nutrition, and in providing for the livelihoods of millions of people, the FAO/World Fish Center Fishing for the Future process, the Global Partnership on Oceans GPO, the Post 2015 SDG agenda. These works also stress the importance of ensuring access to natural resources and to markets, including for small-scale producers. This is closely related to the realization of human rights, including direct and indirect food security.

Likewise, several countries and Organizations are looking at the contribution of fisheries and aquaculture to Food Security and Blue Growth. These are debated at international fora, including the Asia Conference on Oceans, Food Security and Blue Growth (June 2013, Bali, Indonesia), The Global Oceans Action Summit for Food Security and Blue Growth (February 2014, The Hague, Netherlands), the Blue Economy Summit (Abu Dhabi, 20 January 2014) and the Post-2015 Sustainable Development Goals (SDG) process. It has also become key in the development strategies of international organizations such as OECD, UNEP, the World Bank, UNIDO, FAO, the Global Green Growth Institute GGGI, the European Union and many nations, developed and developing, including SIDS. Consequently, the HLPE should analyse the linkages between sustainable management and conservation of aquatic resources, food security and Blue Growth.

There is a need to provide more discipline and coherence across the various sections of the report so that it is more apparent that it is clearly answering the key question of the study‑ namely,  “...what should be done to maintain or even enhance this contribution now and in the long term, given the challenges that both fisheries and aquaculture sectors are facing in terms of their own environmental sustainability and governance, and the external economic and demographic transitions...” to which they have to respond.

In particular, it would be useful if the specific interrogations ( page 3) were aligned along the lines of the four dimensions of food security and nutrition of availability, accessibility, Stability, and utilization. The reader would then be able to see the clear linkages and understand the message that the paper is trying to make.

1. Specific comments

2.1 Fish, food and nutritional value

Firstly, most issues are covered but the structure and language could be improved to make it more clear more readable and understandable. It reflects very much the excellent work done by World Fish!

the main challenges related to malnutrition should be offered some space; e.g. deficiencies of vitamin A, iron, iodine, zinc, etc. This could then be linked to how fish products could play a particular role.

The focus on small fish species as a very good source of micronutrients is great. However, the unique role they can play is not necessarily because they are small, but due to the fact that in this case the most nutritious part of the fish are eaten (head, bones, liver, etc.) and no thrown away. These nutrient dense part from bigger fish species can also be consumed if processed properly. Improved use of fish by-products has a great potential in this aspect, by-products represent in many cases more than 50% of fish being processed.

The HLPE should consider the draft paper on fish in nutrition prepared for the ICN2 and accessible online. It includes useful information and would enable the HLPE to align if deemed necessary with the views expressed at ICN2.The paper prepared for COFI:AQ on the role of aquaculture in nutrition could also give some useful inputs.

The part on by-catch is too narrow! The reference Watling and Norse, 1998 is an extreme environmental view written for media not for the scientific world.

Page 15.L16: Although fish oil contain some omega-6 oils, these oils are abundant in vegetable oils, not deficient in most diets; the problem is rather too much omega-6 in diets. Species like farmed pangasius are often claimed to be unhealthy because of the high level of omega-6 oils. The same arguments are used against farmed salmon.

L19: Levels of PUFAs in carps are much lower than in e.g. sardines and anchovies, but one meal of most carps will in most cases cover enough EPA+DHA for several days! The total contribution of omega-3s from carps are more than the total contribution of omega-3s from salmon due to the high volumes of carps produced (about 28 million tonnes per year).

Page 16.L24-27: Fish is in particular important as a source of essential micronutrients and fats (long chain omega-3s).

Page 17.L17: What is "high value chain processing"?

L26-28: Unclear.

Page 18. L17: Should be: ......in the human brain and neural system.

                2.2. Fisheries sustainability

Resource and environmental sustainability (Section 3.4). The document seems shying away from the fact that resource and environmental sustainability is the prerequisite for food security and that rebuilding the current overfished stocks can increase production by 16.5 million t, or 21% of the current marine fish landings[1]. This is a great boost to food security and nutrition and should be emphasized.

P27, L4-7. The text says, “Production losses from unsustainable over-exploitation were one cause of the estimated loss of $50 billion from capture. On the surface, the environmental sustainability of both fisheries and aquaculture is recognized to be a sine qua none condition for FSN”. In fact, the economic loss is also caused by reasons other than the decreasing production and has a week indication on the loss of food supply and then on FSN. The link between resource sustainability and FSN is not “on the surface”, but fundamental and obvious.

P28. R6-13: the important role of fish and fishery products to FSN in a large number of countries and/or in specific locations with limited access to other sources of (animal) protein should be mentioned here (data can be obtained from FAO Food Balance Sheets for fisheries). R14: it is not clear from the following text what the ‘changing modes’ in the title refer to. Capture fisheries and aquaculture production technology? If so, this would need to be better reflected. R19: There should be a reference to the linkages between fisheries and aquaculture. As it reads now, aquaculture seems to be the compensation for stable/declining capture fisheries - but it needs to be spelled out that there is an impact of aquaculture on capture fisheries and its contribution to FSN through the production of fish oil/meal as aquaculture feed, the collection of wild seeds etc.

R34 and following: another factor that may affect the geography of capture fisheries, in particular in the long run, is climate change. This should be mentioned here.

Fisheries crisis (P29). “ They are biological debates, relying on biological fish assessment methods and framed primarily around assumptions of maximizing the economic value of the fisheries stocks, such as by favoring fish of larger sizes and of higher value species. As a generalization, fish for FSN tend to be smaller and of lower value”. This description is not quite right, and a bit misleading. The so-called crisis often refers to overexploitation of fish stock. Overexploitation reduces the productivity of fish resources and has a negative impact on FSN. As FSN is concerned, it is about the total production of the stock, rather than small or big fish. It seems incorrect to say “fish for FSN tend to be smaller and of lower value” as what maters here is volume of food supply.

It is also worth noting that almost all the studies referenced in Table 3.4 are biological, not using assumptions of maximizing economic value as the document claimed.

A couple of things mentioned in Table3.4 also require clarification: i) “ 90% of large, predatory fish have gone” should be “90% reduction in the biomass of large predatory fish” to avoid the impression that 90% of species are gone.ii) “Appropriate analyses of data-poor fisheries shows that the patterns of resource status are similar to those for more data-rich fisheries”. The method used for this analysis has its own limits, for example using the assessed stocks to tune the model. So, it is biased to say “ appropriate analyses”. Costello et al’s (2012) conclusion is in contrast with Thornsom et al’s (2011) that data poor fisheries are in better situation than data-rich stocks.

Box 3.2. The purpose of stock assessment is to assess the potential biological productivity and the responses of a fish stock to fishing so that fisheries managers can use the information to design regulatory measures to meet the objectives of the fishery. Things mentioned in Box 3.2 such as economic revenues, livelihood, FSN, equitable distribution of resources, value added processing can also be addressed in secondary analyses based on stock assessment outputs, although it is true in many fisheries such analyses have not been carried out as they should.

Other specific comments

P12, L17-20. “90% of 120 m ... fishermen … drive livelihood from the small-scale sector…contribute 70% of the total world catch” is inconsistent with “half of fish catches at global level originate from small-scale fisheries” (P33, L17).

P3, L9-10. “ The number of people employed in global aquaculture would be close to 11.89 million …in these selected case studies only”.  FAO should have official statistics available on this.

P23, L3-10. The authors should use FAO official figures on fish used for direct human consumption or non-direct food use.

P31, L4-6. “Much remains to be done … in terms of FSN rather than standard management objective such as maximum sustainable and maximum economic yield.” In general, FSN is consistent with maximum sustainable yield as a higher fish production can increase market supply and then improve FSN. But, maximum economic yield is different.

P39, L15-17. It reads that can we secure or improve the food security and nutrition of one group without compromising the food security of the other? The food security issue should be looked and addressed at the society level, rather than at the group level.

P39, L22-23. The remark, “trade tends to move fish away from poor people”, is incomplete and should be completed by adding to it “in turn for cash”. The cash earned shall empower fishermen to buy their needs and improve their livelihoods and FSN.

P42, L2-6. The structural failure of the fish export sector and national institutions to ensure an effective distribution of the fish trade revenues is not a fishery issue, but one of the wider society. From this failure, if you conclude that fish trade has negative impacts, you miss the point.

P44, Box 3.5. The box emphasizes the importance of an Africa-to-Africa trade. Fine, but how can an Africa-to-Africa trade increase supply to the whole Africa and meet its need of 27% increase in fish in 2020?

P45, L11-15. It reads that the bulk of these small-scale, unorganised, and unskilled African producers and traders are excluded from the high value fish trade activities promoted by the current trade model, as they are unable to comply with the food quality- standards requirements imposed by international trade institutions (e.g. WTO) and the importing countries. Because of this to ask small-scale fisheries to give up trading opportunities does not seem the right strategy. Instead, focus should be on how to organize SSF fishermen to increase their negotiation power.

P49, L28. The term of forage fish should be avoided, as technically any species is forage for other species at a certain stage.

P52, L19. It says “FAO has also for many years contributed to this biased agenda”. The right expression should be “FAO has not acted actively to correct this biased agenda”, as contributing to something means your action leads to the happening of something, but without acting to stop something from happening does not mean contributing.

P53, L11. “suggest than” should be “suggest that”.

P56, L21-24. Banning trawlers in inshore waters certainly has consideration of protecting small-scale fisheries, but another reason is for ecological concerns as the inshore waters are often the nursery ground for many fish species.

P56, Box 3.9. The contents in this box are not well balanced. First, SSF and large scale fisheries have developed with its own reasons. They target different stocks or fish in different areas. SSF cannot really fully replace LSF in terms of both resource use and fishing operation. Second, SSF also needs regulation and can definitely cause overfishing as well.

P57, L8-39. It is not true “today’s discards are really fish of the future. This is loss of future food security for all.” Some species cannot be used for food either today or in the future.

P69. R16: Add reference to the forthcoming Voluntary Guidelines for Securing Sustainable Small-scale Fisheries in the Context of Food Security and Poverty Eradication. R17: It would be important here to stress the principles of the human rights based approach a bit more. This could be nicely illustrated by the case of South Africa, were small-scale fishers secured access rights based on a claim for their right to food. See P. 27; www.fao.org/docrep/016/ap553e/ap553e.pdf

P73, L9-23. Economic efficiency as a fishery management objective is not a majority today. Cutting the number of fishermen is against the poverty alleviation and FSN for the poor you talked a lot in previous sectors.

P74, L22-26. “70% of what SSF catch in developing countries in actually unreported and unregulated” is not true. What did you get the figure? Basically, you are saying SSF is essentially IUU fishing. I think you get it wrong.

P.75. R7: In 2011COFI approved the development of a new international instrument in the form of Guidelines on small-scale fisheries that would draw on relevant existing instruments, complementing the Code. FAO has facilitated the development of these Voluntary Guidelines for Securing Sustainable Small-scale Fisheries in the Context of Food Security and Poverty Eradication (SSF Guidelines), taking a highly....The SSF Guidelines are expected to be endorsed by COFI in June 2014.

P.77. R18: This recommendation should not be limited to the development of these instruments but rather look at the implementation of existing ones, including related instruments like the VG Tenure and the Right to Food GuidelinesP78, L16-19. I do not agree with you that conventionally, assessments stress improving the yields of high value species, and generally large fish, often treating fish species… high value fish”. Conventional stock assessment often focuses on single species and is not able to compare large fish with small ones.

P. 81. R40: Appropriate measures to prevent any damage from escapes etc. on natural stocks need to accompany this.

2.3 Aquaculture

page 31- line 8: alternative proposed para: Environmentally sustainable aquaculture production depends on the right combination  of farming systems (including health management),  resource use (e.g. land water, energy) appropriate inputs (feeds, seeds, labour, infrastructure) and  management of outputs (escapes, diseases etc.)  (see  the ecosystem approach to aquaculture guidelines, FAO (2009) ().

p. 31 – line 13: eliminate "body", since it could running water, ground water etc.

p. 31 – line 35: you mean in terms of trade-off? compared with other food sectors?

p. 32 – line 33: this comment is really out of place, unless the role of other organisms is mentioned e.g.  FAO has made a very explicit commitment as well

p. 46 – lines 23-37: It is worth mentioning that  this practice  is despairing with the raise of larvae produced in hatcheries. Now a days in Nicaragua even small farmers are buying  the larvae

p. 51 – line 7: even large scale aquaculture can provide food security if provides jobs!! this is particularly the case through the provision of employment for women in the processing part. Many women in Chile and in Nicaragua are employed by the salmon and shrimp industry and they have increased access to food security for their families, an opportunity they did not have previously

P. 51 – line 32: Delgado P 75 - line 35: should also notice the need for more integrated strategies for implementation  of sustainable aquaculture giving due consideration to equity aspects. See the FAO EAA guidelines.

http://www.fao.org/docrep/013/i1750e/i1750e00.htm

p. 81 – line 17: here we are missing the need to strengthen equity aspects in aquaculture as business, greater share of benefit with workers and processors. This will ensure greater food security through employment and access to food

              2.4. Trade

Overall, the international trade aspects of this report are weak, with ad hoc evidence, usually one-sided. This report ignores the fact that fish trade does not take place within a vacuum, that other issues affect the poverty and nutrition of fishers and small scale aquaculture producers and their potential returns from international trade. Namely, there are a myriad of obstacles unrelated to fish trade that perhaps influence the trade patterns from local markets to international markets, such as weak transportation infrastructure to reach domestic and regional markets, political conflicts that prevent intra-regional trade, high customs duties and tariffs between developing countries which discourage intra-regional trade flows, border corruption, cross-border illegal trade that is already occurring but does not show in statistics (such as in Africa) or unreported trade (quite common in Asia), general lack of price and market data at local level in developing countries, ineffective government policies and fisheries management, lack of enforcement, etc. Most importantly, lack of policies that ensure equitable distribution of the benefits of trade along the value chain in some developing countries often leads to fishers and fishing communities getting the least benefits and unable to lift themselves out poverty.

The HLPE should review so many blanket statements and generalizations about international fish trade which are counter-intuitive and are not supported by data.  

Page 25, lines1-3 and 5-6. The question is: would fisher households be “poorer” if they didn’t sell part of their catch?  Economists look at evidence from the marketplace, i.e. small scale fishers worldwide sell all or part of their catch in local, regional and global markets. This is a visible fact. If selling fish was a less welfare-enhancing decision than eating the fish, then one wouldn’t observe this common market behaviour. The evidence may point to the problem of a general lack of education about nutritionally balanced diets and the nutritional requirements of growing children. Lack of education in poor communities contributes to malnutrition and poverty, not necessarily the selling of fish.

Page 25, lines 17 & 18. The fact that small scale fishers worldwide sell part or all of their catch, as opposed to consuming it, is clear market evidence (and common sense) that the former is a superior economic choice than the latter, and thus improves household welfare. If trading fish makes a family poorer and hungrier, they simply would not trade.

Page 26, 13-16. Income to each small scale fisher and aquaculture producer added together contributes to “national income”, by definition. National income does not belong to the government. Where is the evidence that income to individuals does not contribute to their food security and nutrition?

Page 39, lines 12-17. This is truly a complicated issue for policymakers and is well-known in the agricultural development literature. The flipside of the authors’ argument is whether food subsidies and food aid hurt producers. Namely, that if food producers do not receive sufficient prices to cover costs, they are forced out of production and into less productive work and deeper poverty. This is true for both farmers and fishers in developing countries which receive international food aid and/or government subsidies to support urban consumers. This is the vicious cycle, as food aid and subsidized food prices benefit urban consumers but reduce long term productivity of domestic farmers and fishers, further reducing domestic food supplies and putting upward pressure on food prices in the future.

International fish trade and food security (P39). On the one side, it claims that international trading is good for poverty alleviation and food security, but on the other, it contends that there are many negative impacts on food security and livelihood options for the poor by taking away fish from the local populations. The report seems mixing major consequences with side effects caused by governance failure. The typical example is the Nile perch Lake Victoria fishery. From a revenue perspective, it is a success, but from the perspective of food security of local population is a failure. In this case, the increased revenue has not turned into poverty alleviation and increased food security. This is caused by the failure of government, not a failure of trade. Without a proper functioning of other relevant sectors of the society, any other effort may also fail. It is worth mentioning that the study is not scientifically convincing and sound.  The fact that Ugandan and Tanzanian districts located on the shores of the lake were systematically displaying higher rates of stunted and wasted children may be caused by other reasons that were not examined in the study. Caution needs to be exercise when drawing such superficial link based on phenomena without examining its root cause. The fishing agreements signed between developed and developing countries are quite different from fish trade. It may not be appropriate to discuss it here.

Pages 39-45 International fish trade and food security. The authors refer to the NORAD study entitled “Fish trade for the people” (2004). A more recent NORAD-funded project “A value-chain analysis of international fish trade and food security with an impact assessment of the small scale sector” (August 2012) reports on  the impact of international fish trade and value chains on small scale fishers in 15 country case studies. The results of this more recent NORAD project should be incorporated into the HLPE report.

Page 40, Lines 37-39. Authors should include the results of the more recent NORAD fisheries value-chain analysis (2012).  It could also be useful to compare the food security situation of small scale fishers and aquaculture producers providing a cash crop to the international market with the food security and poverty situation of other cash crop farmers in developing countries, such as cocoa and coffee producers.

Page 42, Lines 8-17. It would be less-biased to also mention the role of resource governance and lack of sustainable policies in many developing country fisheries, compared to management of fisheries resources in developed countries. Examining fish trade in isolation is not showing the complete picture, as international trade cannot be the sole cause of poverty, food insecurity and unsustainable resource use in developing countries.

Page 42, lines 20-21. The statement “fish processing factories (often owned by companies in importing countries or multinational corporations)” needs to be justified with verifiable statistics, such as which regions, per cent of processing sectors are foreign owned, etc. In addition, it is important to look at the positive aspects foreign investment has had in several countries that are now emerging economies with healthy economic growth and poverty reduction records.

Page 42, lines 36-37. The statement “This alternative is to re-orientate fish trade toward regional or domestic markets”, implies that global market integration excludes local and regional markets. This is not the case in developing countries. The availability of local and regional markets typically depends on the fish consumption habits of the population. For example, in some regions of Africa, Latin America and in Eastern Europe, per capita fish consumption is very low and there is not much demand for fish. Therefore, international markets offer an additional source of employment and income from underutilized inland fisheries. On the other hand, for coastal communities in Africa and in Asia, there is high per capita demand for fish. Thus local and regional trade are already actively pursued. 

The HLPE study needs to have more geographical sensitivity as fish consumption habits and trade are not homogenous around the world (i.e. Box 3.4 is a good example, however the statements and conclusions within the text of the document generalize too much).

Page 43, lines 20-21. The NORAD value chain study (2012) has good examples of local and regional trade within fisheries value chains and recommendations for increasing the role of regional markets.

Page 43, lines 34-41. Suggesting that developing country small scale fisheries move away from international trade to regional and domestic markets is a strong generalization and is not correct.  It is not a competition between local, regional and international markets. The fishers should have the opportunity to sell their fish in the market that brings them the most secure income source, and thus improved food security. The role of FAO is to assist developing country and small scale producers to overcome the obstacles mentioned by the authors (HACCP, eco-labels), rather than advise them to just stop trading with developed countries.

Page 44, lines 3-4, and 8-9. I do not see how “trade of high value fish exported to rich countries’ markets... indirectly” reduces “management support and donors’ money away from the small-scale fisheries and aquaculture producers and traders”  Evidence of this needs to be clearly demonstrated.

Page 44, Box 3.5. This box trivializes the very real issues of African infrastructure and lack of transport grid, which would directly affect the ability of African small-scale fishers to move fish (a perishable product) within Africa. The consumption patterns of fish within the African continent also vary considerably across countries and between coastal and inland regions. Box 3.5 contributes misleading one-sided information and should include, at least, other challenges facing the transport of perishable food products within Africa. Even international aid shipments needed during emergencies have faced critical transport problems, often sitting at harbours along the coast and never reaching the target populations due to poor transportation infrastructure or lack of security due to civil wars.

Box 3.5 ends by blaming the current trade model for excluding small scale African fishers from entering the international markets, namely due to the “food quality standards requirements imposed by international trade institutions (e.g. WTO) and the importing countries”. The statement by itself is wrong. The HLPE should consult the EU DG Sanco website to see how many small scale operators from developing countries currently meet EU safety and quality requirements. It is however true that small scale fishers have more difficulties facing these challenges, but these are not the only challenges. And there is no mention of the opportunities international markets offer, for example encouraging developing countries to improve their food safety systems to assist fishers to reach standards of international markets, while improving health and hygiene for their own people. 

              2.5 Gender

Overall, the section is well written, balanced and factual. However, it would be useful if the 5 priority facets linking gender and FSN could be arranged in terms of the four dimensions of food security and nutrition of availability, accessibility, Stability, and Utilization, particularly in section 4.3 Summing up. This has been done to some extent, but greater emphasis on these would help the reader’s focus and reinforce the message that fish are critical for FSN.

                2.6. Governance

Overall, the section is weak on providing facts about the fundamental links between governance and FSN.  Many of the opening points are not incorrect but would benefit from being presented in a neutral manner free from the overwhelming implicit bias that big is bad and small is great.

Section 5.1 doesn’t address why governance is key to food security.

Section 5.2 – The  sections do not flow. It would make sense to start with governance at the international level, including the Code of Conduct for Responsible Fisheries, and then later move to a short, concise section on governance options and issues, including co-management.

P 69 lines 6-18 is missing key instruments such as the Right to Food Guidelines, the Voluntary Guidelines on the Governance of Tenure..., and fails to mention the Voluntary Guidelines on Securing Small-scale Fisheries currently under development. Moreover, it is unclear as to why this is in the section on “Why is governance key to food Security?“ and not found in 5.3 subsection “Fisheries governance at the international level”.

The section is comprised of an extensive dialog regarding co-management instead of all forms of governance.

P74. Para 2 and 3. These two paragraphs seem to be letting small scale fisheries “off the hook” – although there is acknowledgement that operations / catches of small scale fisheries are largely unreported, the article suggests that small scale fisheries are not involved in illegal fishing, or, if so, it is justified! All three issues – illegal, unreported, unregulated fishing – are present in small scale fisheries around the globe and should be addressed appropriately. Nevertheless, the approach to combating IUU fishing in industrial and small scale fisheries should be different, with the latter benefitting more from capacity development programmes and stakeholder involvement in developing national / sub-regional sustainable fisheries management plans which lead to enhanced food security. In parallel, one must also highlight the fact that small scale fisheries are particularly vulnerable to the effects of IUU fishing by large scale / industrial vessels.

Contrary to what is suggested in the text, the IPOA-IUU clearly includes small scale fisheries (or at least, does not omit them) and explicitly distinguishes and defines the three IUU fishing components. The recently adopted international guidelines for flag State performance (which are not mentioned in the document), the objective of which is to prevent, deter and eliminate IUU fishing, also encompass small scale fisheries. The international guidelines on small scale fisheries, under formulation and discussion, will underpin certain aspects of such fisheries in accordance with the instruments mentioned above.

p. 75 The 34 lines in the section that are actually under the title “Governance issue[S] in aquaculture and links to food security” would benefit from the existence of a complementary section about governance, capture fisheries, and FSN.

P 75 It is unclear as to what is meant in lines 27-30.

Section 5.4 Summary of key governance points offers neither a summary of the discussion. And, although it mentions the issue of tenure in aquaculture, it did not discuss that in the section on aquaculture. It is entirely silent on the issue of the governance of tenure in capture fisheries, something that is essential if the small scale sector is going to be able to realize and defend its rights.

Again, as mentioned above, looking at the governance of capture fisheries and aquaculture through the lens of the four dimensions of food security and nutrition of availability, accessibility, Stability, and Utilization – may help to organize the points of this section and provide a more structured discussion.

Climate changes have impact on fishing in every part of the world. Most especially in some places that there are flooding a lot of destruction on fish farm occurred but nobody talk about the fishes. Fish farmers have major losses in the flood. Most of the fish ponds were wash away farmers suffer tremendous losses of their fishes.

This are the major reason HLPE is trying to make avenue for academician and group of expert to come together in e-consultation to figure a way out.

Developing of aquaculture and fisheries does not stand on artisans fishing alone, government and international community need to come together to build tower of expert because every government used to give attention on Crop farming  and neglect the fishery which is a big problem to fishing sector. Most especially Nigeria government spends billions annually importing fish into the country while there is a lot of water that its citizens can fish. Any country that needs to excel in fishery has to put these three aspects in cognizant.

Industrials trawlers which operate within the high sea which they do in industrial scale, artisanal fishing which harvest fish in the natural body of water which is normally done by the country. And aquaculture which is the actual fish farming, there is certain things that people does not realized  in fullest that is why a minimal allocation is being done in fishing sectors of some of the countries. Aquaculture which involves elites can contribute much to artisan fish farmers but to our dismay it found that in the coastal area, aquaculture had to be all over, but the practice was neglected in these regions.

Fish provides a very high percentage of nutrients to the health of human being such as protein, in Sub-sahara Africa many because of their health were instructed not to eat red meat accept fish to improve their health due to the nutritional content of the fish.

Some artisan fish farmers should be trained in such a manner that they could earn something for their survival, this will involve improve equipment such as out-board motors to give them access to deep water resources, appropriate nets, fishing gear and simple but better processing facilities this should involve drying smoking and so forth. Fish is an extremely perishable foodstuff. Spoilage start as soon as fish dies it will get spoiled within 12-20 hour depending on their species, methods of capture and the condition of the environment. So for preservation fish need to be dries or smoked to be able to store for long period to wait for the buyer. This innovation and recent one need to impart to artisan fish farmers to improve their earning and provide food security.

Fish handling to all tiers must cover various methods used by people involved in fisheries operation to ensure that the fish products are always in good condition to the end users.

This involved observing good quality measures, maintaining good hygiene and quality control. Such measures deter the prevention of the fish and made fish well acceptable to the consumers.

Once fish are harvested, they must be isolated from adverse sunlight/heat. If wanted alive they must be kept in good container with clean water within the shortage possible time. If wanted dead, the fish most starved or knocked at the head instantly without allowing it to struggle to dead.

The fish must be sorted out in species, age, sex, and size as desired

The fish must be gutted. This exercise should be carried out on boat (on the boat or canoe) by sliding the fish with a sharp knife from the neck to the vent and the gut viscera removed. Cutting helps to remove the bacteria and digestive juices which will accelerate autolysis and purification. The fish should be washed in clean water to remove the blood and debris. The offal’s can be properly saved for processing into feed meal and silage. Plastic boxes, aluminum balls or any other that will not retain stain and could be easily clean is better in fish storage in boat or canoes. Later the products (fish) should be chilled. The lower the temperature the better as long as the fish does not freeze. Fish can be process into many forms:

Fish meal.

Fish Silage.

• Fish muse - used to produce fish cake, scourge and fish finger.

The Role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition

In the countries along the west coast of Africa, fish plays a major role in food security and nutrition. In Ghana for example, the pathways for linking fish to food security is through job creation, employment and incomes generating in the sector. These sources of livelihood are also generated from its production catching and value chain: storage, processing and marketing. Production, consumption and utilisation of fish improves agro-biodiversity to ensure higher or sustainable incomes, dietary diversification for enhanced nutritional status, easy access to protein for the poor especially those along the coast and other water bodies like River Volta.

In Ghana, there are specific gender roles in fisheries and aquaculture development. Males are normally involved in fish production (in fresh water bodies) and catching, whiles women are involved in sorting, processing and preservation (salting, drying, frying, smoking etc). Both men and women are involved in the sale depending on the scale. Women buy from the fishers and do the retailing. Both boys and girls also support in selling fresh or processed fish but the females are mostly involved. The storage of fish on small scale is done mostly by women but most cold storage facilities are managed by men or companies. Both men and women can own aquaculture pond or cage but men are in majority, and they also own the fishing vessels or trolleys. The males do the mending of fishing gears.

I do not see any detrimental tradeoffs if the situation is properly managed, effectively monitored and regulations are adhered to. Tilapia production for example is for both local and international markets; however, as the international market fetches more money, there would be the likelihood that its production will be diverted towards the international market at the expense of home consumption especially for the poor. Again, the bigger commercial vessels with more storage and sophisticated equipment will catch more fish for the elite population or big markets that are not easily accessible to the poor. This means the local fishers employment and income from the sector is likely to be negatively impacted. Farmers along water bodies may not be able to use the water for irrigation purposes if that water body is badly polluted or contaminated due to numerous unregulated aquaculture development in particular water bodies. If the fish cages are not properly managed, those using it for transport may be affected too. Therefore the need for water users groups to be formed in various areas with the support of the government for effective regulation of the water bodies. In Ghana, aquaculture production in the Volta River upstream can even affect the performance of the hydroelectric dam.

Competition for feeding fishes in aquaculture development could affect food security of the human population especially in poor areas and hinterlands and the need for alternative feeding methods and practices for fish. Is it possible to use insects, poultry droppings among others as protein sources instead of fish meals?

Pollution, depleting and over exploitation of resources from the water bodies may be faster than regeneration leading to environmental un-sustainability of the fisheries sector. More aquaculture in big water bodies like the Volta River without any proper management and control is also likely to affect other sectors of the economy. Fisheries and aquaculture do contribute positively to improving food security and nutrition and must be monitored and supported to create jobs/ employment, incomes and enhance nutrition of not only the poor. Stakeholder consultation and supervision is therefore essential. All the different users and interest groups have a stake to contribute positively to the success of the fishery and aquaculture development in Ghana and other parts of the world.  

Anna Antwi (PhD)

Development Consultant.

First of all, congratulations for this excellent initiative.

This does not make sense to put fish apart from the other food sources in international reports related to human nutrition and food security.

As a fish nutritionnist working with aquaculture species, I am surprised to read that aquaculture "can " complement or supplement food provided by fisheries because half of fish is now supplied by aquaculture so this a fact.

I share a lot of ideas of this first draft report. However I think that more emphasis could be put on education as a way to alleviate poverty. For example, improvments in culture pratices, diseases prevention, fish nutrition, wastes reduction and management applied to high trophic level species could benefit to low trophic species if knowledge transfer is organized and encouraged;

Table 3.1 should be added with other fish species such as salmon, eel, Tuna and nile perch. In the document, more consideration should be given to the contribution of fish to the n-3 fatty acid supply in human consumption.

Alternative resources for fish feed such as microlagae or insects could be considered (chapter 3.7).

IBON International welcomes the High Level Panel of the Committee on Food Security’s (CFS HLPE) recognition that fisheries play a crucial role in food security and nutrition (FSN) — a recognition which has been lacking in many international FSN reports, as the CFS itself acknowledges — and offer some comments on this zero draft.

• Food sovereignty. This concept goes beyond food security, as it tackles not just the need to ensure that everyone has sufficient food, but also the right of peoples to determine their own food policies and systems of production. Food sovereignty, in general, is the right of peoples, communities, and countries to define their own agricultural, labor, fishing, food and land policies, which are ecologically, socially, economically and culturally appropriate to their unique circumstances. Any discussion of fisheries and aquaculture — a sector in which small-scale producers are held by consensus to play a central role — would greatly benefit from consideration of a food sovereignty framework.

For instance, food sovereignty includes the right to fight the power of corporations and other forces that destroy the people’s food production systems and deny them food and life. This is a key concept that could help to reframe the discussion of the relationship between small-scale fishers and large-scale, corporate fisheries. Under a food sovereignty framework, the discourse is not limited to a weighing of the pros and cons of both sides, but moves beyond, to recognizing the need to take a stand that would best serve the end of FSM for all.

• International fish trade. The CFS proposal to move from “pro-cash remunerative fish trade to pro-food security fish trade,” or towards a more regional or domestic-oriented fish trade, is a positive step in the right direction. But it is not enough. Especially troubling is the hesitancy evident in the draft when it comes to asserting the negative impacts of international fish trade on food security and livelihood options for the poor:

“So, does international trade reduce or accentuate food insecurity? Two recent comprehensive reviews conducted independently converged towards the same findings (Allison et al., 2013; Arthur et al., 2013). Their conclusion is: at best, the evidence is unclear and contradicting, and at worse no strong / rigorous evidence exists to substantiate either of the two narratives.”

The draft goes on to cite a study that “can help clarify the situation.”

“While there is little doubt... that international fish trade has positive effect on trade revenues and possibly on job creation, these revenues don’t seem to translate into positive outcome in terms of food security... In other words, depending on the criteria used to assess the ‘success’ of international fish trade, the conclusions may differ quite dramatically, even when one is looking at the same case.”

On the contrary, this vacillation in the draft is indicative, not of confusion between “pro-trade” and “anti-trade” narratives, but of a hesitancy to honestly criticize the international trade system.

The CFS should take a firmer stand in its document. After all, the CFS itself cites numerous studies explaining the ways in which the present structure of the international trade system, including the fisheries and aquaculture global value chain, has made fish products inaccessible or unaffordable to the most marginalized sectors of society, even small-scale fisherfolk.

IBON International notes that very manner in which the CFS zero draft frames the issue is flawed. The dichotomy should not be between pro and anti-trade stances; instead, it should be a discussion on how to reshape trade in a way that is more beneficial to more people around the globe.

Trade in fish products does not occur in a vacuum, but within the existing international trade system, with all its problems and weaknesses. Thus, to address the negative impacts of international fish trade requires a study of context and root causes. By recognizing that entirety of the present international trade system is structurally flawed, the dialogue can shift to the establishment of a just trade system, as a necessary requisite for making sure that fish trade, in particular, supports or complements the goal of food security for all.

• Climate change and climate crisis issues. No discussion of fisheries and aquaculture is complete without a serious discussion of the perils brought about by global warming, as well as its economic, political, and social aspects, which have a direct impact on all scales of fisheries and aquaculture. Indeed, any progress made in achieving sustainable catching and harvesting processes may well be undermined by climate change. The CFS should take the opportunity to underscore the urgency of the climate crisis, in order to push the fisheries sector, a primary stakeholder in the issue, to become more actively involved.

• Small versus large-scale fisheries. IBON International lauds the recognition that small-scale fisheries play a central role in FNS. However, it must be noted that supporting small-scale fisheries necessarily entails curtailing — perhaps significantly — some of the irresponsible actions of large-scale, corporatized fisheries and aquaculture industries. The practices of the latter have a direct and negative impact on small-scale fisherfolk, who are by far more numerous and more crucial to the achievement of the goal of FSN. The CFS should emphasize this reality in its document, not as a “necessary trade-off,” but as a problem that can and must be addressed.

In this light, we add that the abovementioned points should be raised in the ongoing drafting process of the Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries. Genuine moves to consider these issues would aid in formulating the VG as an active tool in stemming the ongoing destruction of small fishing communities which are being displaced or replaced by corporatized large-scale fisheries or aquaculture industries .

Dear HLPE Colleagues,

Please also find attached a report from a Workshop on “Small Indigenous Freshwater Fish Species: Their Role in Poverty Alleviation, Food Security and

Conservation of Biodiversity, organized by ICSF, which we feel is of relevance for the study on the Role of sustainable fisheries and aquaculture for food security and nutrition.

Best wishes

Brian O'Riordan,

The Secretary, ICSF Belgium Office

Sentier des Rossignols 2

1330 Rixensart, Belgium

URL: www.icsf.net; https://twitter.com/#!/ICSF_EU

Please find attached the contribution of ICSF to the High Level Panel of Experts for Food Security and Nutrition (HLPE), VO Draft report on the Role of sustainable fisheries and aquaculture for food security and nutrition.

On behalf of ICSF I would like to thank you for providing the opportunity to contribute to this initiative

Best wishes

Brian O'Riordan,

The Secretary, ICSF Belgium Office

Sentier des Rossignols 2

1330 Rixensart, Belgium

Tel: 00 32 26525201

Fax: 00 32 26540407