HLPE consultation on the V0 draft of the
Report:
The Role of Sustainable Fisheries and
Aquaculture for Food Security
and Nutrition
From 18 November to 20 December 2013
http://www.fao.org/fsnforum/cfs-hlpe/fisheries-and-aquaculture-V0
− Collection of contributions received −
These proceedings are compiled by the
Global Forum on Food Security and Nutrition (FSN Forum)
for the High Level Panel of Experts (HLPE)
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Proceedings / 2
Table of contents
Topic ................................................................................................................................................... 5
Contributions received ....................................................................................................................... 8
1. Erick Baqueiro Cardenas Private consultant, Mexico .......................................................................8
2. Selina Juul Stop Wasting Food movement Denmark (Stop Spild Af Mad), Denmark.......................8
3. Dinesh Kaippilly Kerala University of Fisheries and Ocean Studies (KUFOS), India ..........................8
4. Dr Krishna Kaphle Institute of Agriculture and Animal Science, Tribhuvan University, Nepal ........9
5. George Kent University of Hawaii (Emeritus), United States of America.........................................9
6. Olivier Mikolasek APDRA-pisciculture paysanne, France ...............................................................11
7. Olivier MIKOLASEK CIRAD & NGO APDRA, France .........................................................................12
8. Shekhar Ojha Central Institute of Fisheries Education, Mumbai, India .........................................15
9. Samueline RANAIVOSON Ministère de la Pêche, Madagascar.......................................................15
10. Eltighani Elamin, GIZ/WB AfghanStat, Afghanistan......................................................................16
11. Menakhem Ben-Yami, Israel.........................................................................................................16
12. Paulo Pereira, Colonia dos pescadores, Brazil ..............................................................................16
13. Emad Mahgoub, Agricultural Research Corporation, Sudan ........................................................17
14. Camille Piche, Canada...................................................................................................................18
15. Lizzy Igbinne, Nigerian women agro allied farmers association, Nigeria .....................................19
16. Lizzy Igbinne, Nigerian women agro allied farmers association, Nigeria .....................................19
17. Alu Ibrahim Elkhalil, Sudan ...........................................................................................................20
18. Gianluca Ragusa, International independent consultant, Italy ....................................................20
19. Jariah Masud Institute of Gerontology, Universiti Putra Malaysia, Malaysia ..............................21
20. Abdul Waheed, Society for Environmental Actions, Re-Construction & Humanitarian
Response, Pakistan .............................................................................................................................22
21. Vijaya Khader, India ......................................................................................................................23
22. Anura Widana New Zealand .........................................................................................................23
23. Stephen J. Hall WorldFish, Malaysia .............................................................................................24
24. Anne Mugaas, The Royal Norwegian Society for Development, Norway ....................................27
25. Mohammad Nuruzzaman, Bangladesh ........................................................................................28
26. Janine Pierce, Centre for Regional Engagement , Australia .........................................................29
27. Fabrizio De Pascale, UILAPESCA (fishworkers union), Italy ..........................................................31
28. Ministry of Food, Agriculture and Livestock, Turkey ....................................................................32
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29. Eranga Galappaththi, Natural Resources Institute, University of Manitoba, Canada ..................33
30. Ghazanfar Azadi Iran fisheries organization, Iran (Islamic Republic of) .......................................34
31 Peter Edwards Thailand .................................................................................................................35
32. Rizalito Lopez Southeast Asia Fish for Justice Network, Philippines ............................................36
33. Farisal U. Bagsit (Researcher) and Caridad N. Jimenez (Faculty),Institute of Fisheries Policy
and Development Studies, Philippines ...............................................................................................39
34. Jacqueline Demeranville, Decent Rural Employment Team, FAO ................................................40
35. Government of Switzerland..........................................................................................................40
36. Alvaro Luis Céspedes Ramirez, IMG Consulting, Bolivia (Plurinational State of) .........................41
37. Conchi Quintana, World Rural Forum. (IYFF-214), Spain .............................................................42
38. John Kurien, India .........................................................................................................................43
39. Sea Fish Industry Authority, United Kingdom ..............................................................................44
40. Ambekar Eknath, Network of Aquaculture Centers in Asia-Pacific (NACA), Thailand .................46
41. Clara Whyte, Economist and Policy Analyst, Canada ...................................................................47
42. Paul Denekamp, Stichting Vissenbescherming , Netherlands ......................................................47
43. Marc Oswald, ISTOM, France .......................................................................................................48
44. Natasha Stacey, Australia .............................................................................................................52
45. Richard Veeran, Suresh Chand, Ministry of Fisheries & Forests, Fiji ............................................54
46. UN Special Rapporteur on the right to food.................................................................................56
47. Government of New Zealand .......................................................................................................56
48. Shashi Kumar, Bangalore University , India ..................................................................................58
49. Jorge Lopez,Argentina ..................................................................................................................59
50. Ministry of Fisheries and Coastal Affairs , Norway .......................................................................60
51. Gabriel de Labra, Independent Consultant on Small Scale Fisheries and Aquaculture, Spain .....61
52. Pat Heslop-Harrison, United States of America ...........................................................................64
53. James Rohan, Australia.................................................................................................................65
54. Government of Australia ..............................................................................................................65
55. Niracha Wongchinda Thailand......................................................................................................68
56. Sue Longley IUF/UITA, Switzerland ..............................................................................................69
57. ICSF, Belgium ................................................................................................................................70
58.Brian O'Riordan, ICSF, Belgium ......................................................................................................81
59. IBON International, Philippines ....................................................................................................82
60. Françoise Medale, INRA, France...................................................................................................83
61. Anna Antwi, Development Consultant, Ghana.............................................................................84
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62. Alexandre Meybeck, FAO/UNEP Sustainable Food Systems Program, Italy ................................85
63. Samuel Ayuba Hamisu, Yobe State College of Agriculture Gujba, Nigeria ...................................86
64. Katosi Women Development Trust, Uganda ................................................................................88
65. FAO Department of Fisheries and Aquaculture, Italy...................................................................90
66. Government of France..................................................................................................................99
67. European Commission Services ..................................................................................................102
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Topic
In November 2012, the UN Committee on World Food Security (CFS) requested the High Level
Panel of Experts on Food Security and Nutrition (HLPE) to conduct a study on The Role of
Sustainable Fisheries and Aquaculture for food security and nutrition. Taking into account the
results of the scoping consultation, the HLPE intends to assess the importance and relevance of
Fisheries and Aquaculture for Food Security and nutrition as well as the current challenges faced
by Fisheries and Aquaculture in relation to Food Security, pointing out changes going on, including
overexploitation of fish stocks and the boom of aquaculture, in order to better understand these
changes and to maximize the positive effects of them.
Final findings of the study will feed into CFS 41 Plenary session on policy convergence
(October 2014).
As part of the process of elaboration of its reports, the HLPE now seeks inputs, suggestions,
comments on the present V0 draft.
This e-consultation will be used by the HLPE to further elaborate the report, which will then be
submitted to external expert review, before finalization and approval by the HLPE Steering
Committee.
HLPE V0 drafts are deliberately presented – with their range of imperfections – early enough in
the process, at a work-in-progress stage, when sufficient time remains to give proper
consideration feedback received so that it can be really useful and play a real role in the
elaboration of the report. It is a key part of the scientific dialogue between the HLPE Project team
and Steering Committee with the rest of the knowledge community.
In particular, the HLPE would welcome comments and evidence based suggestions, references,
examples, etc. on policy aspects, from an evidence-based perspective, on what can be done to
improve the contributions of fisheries and aquaculture to improve food security and nutrition,
now and in the future, in various contexts.
It is a fact: fish is nutritionally rich (in particular in bioavailable calcium, iron, zinc, and vitamin A);
and fish (either produced through fish-farming activity or caught from wild stocks through
fisheries) is used in many developing countries as a primary source of animal protein. The latest
estimate by the FAO suggests for instance that in 2009, fish accounted for 17% of the global
population’s intake of animal protein and 6.5% of all protein consumed. Globally, fish provides
about 3.0 billion people with almost 20 percent of their average per capita intake of animal
protein, and 4.3 billion people with about 15 percent of such protein (FAO 2012).
Yet, fisheries and aquaculture are absent from most global reports on food and food insecurity
(e.g., FAO SOFA and the FAO food insecurity reports) and, with some few exceptions, fish has so
far been ignored in the international debate on food security and nutrition. At the same time,
although the fisheries literature recognizes the importance of fish in relation to food security and
nutrition,
the analysis goes rarely beyond the simple adage stating that: “Fish is a rich food for the poor”.
There is an urgent need to go beyond this adage and establish more rigorously the link between
fish ad food security and nutrition. The key-question that this study will aim to address is:
“recognizing the well-established importance of fish to food security and nutrition, what should
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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 that they have to respond to?”
In order to address this overarching question, several more specific interrogations may be
considered:
Respective contribution of fisheries and aquaculture to food security and nutrition: How and to
what extent do fisheries and aquaculture contribute to food security - through which impact
pathways? What is the evidence available to present fisheries and aquaculture as key ways for
improving the food security of targeted populations?
Women and food security: What is the specific role of women in enhancing food security in
fisheries and aquaculture sectors? What are the threats and barriers to this specific role and why
and how should this role be strengthened?
Sectorial trade-offs and food security: Are there any trade-offs between the sectors’
contributions at different levels or between different groups? In other words, is it possible that
enhancing food security at one level (or for one specific target group, e.g. urban consumers)
reduces food security at another level (or for another specific group, e.g. fishers/producers)? As
part of this issue, what is the overall contribution of international fish trade on food security?
Environmental sustainability of fisheries and aquaculture: Beyond an obvious long-term
dependence, what is the relationship (trade-offs; synergies) between resource conservation and
food security? In particular what are the short- and medium-term impacts of the large number of
conservation interventions (e.g. marine protected areas) that have been recently established, on
the local populations dependent on small-scale fisheries?
Governance and food security: What are the effects of the various management and governance
reforms (e.g. co-management programmes) currently implemented at national level throughout
the world’s fisheries, on food security? At the international level what is the role and impact of
recent global programmes and campaigns such as the “International Plan of Action to Prevent,
Deter and Eliminate Illegal, Unreported and Unregulated Fishing (IPOA-IUU)”, or the
implementation of BMPs (Best Management Practices) in aquaculture on food security?
Fisheries and aquaculture interaction: Are there any trade-offs between aquaculture and
fisheries in relation food security? In particular is the use of fish meal (to feed farmed fish) a
threat to human food security?
The future of fisheries and aquaculture in the context of foods security: What future role
fisheries and aquaculture will be able to play in the context of the combined impact of
demographic transition (increased population and increased living standard) and climate change
(likely decrease in world agriculture production capacity)?
We thank in advance all the contributors for being kind enough to read and comment on this
early version of our report. We look forward for a rich and fruitful consultation.
The HLPE Project Team and Steering Committee
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Contributions received
1. Erick Baqueiro Cardenas Private consultant, Mexico
Making production catch up with human population, requires five E the solution is not on
straining the system more, rather reduce human population. We are a pest.
On the other hand, as fishery's biologist, it is evident that every fishery managed under the
minimum size philosophy has failed, as the policy reduces the reproductive potential of the
species, and promotes the development of dwarfs and slow growers.
A change to maximum catch limit should be overtaken to promote the recovery of the
reproductive potential and the predominance of gigantism and fast growers.
2. Selina Juul Stop Wasting Food movement Denmark (Stop Spild Af Mad), Denmark
Regadring the Bycatch discarded at sea:
Address the solutions:
Lobbying campaigns targeting the retailers to sell fish of every size and type.
Campaigns targeting and educating the consumers to buy fish of every size and type.
New green growth opportunities targeting the canteens, foodservice and hospitals and others b2b
to by fish of every size and type from the fishermen.
Since 2015 will most probably be the European Year Against Food Waste, it's is important that the
EU must look at it's own laws and legistrations that will allow to introduce a Fish Discard Ban.
Sincerely yours,
Selina Juul
Founder,
Stop Wasting Food movement Denmark (Stop Spild Af Mad)
Winner of Nordic Council Nature and Environment Prize 2013
Winner of Svend Auken Prize
Recipient of Cross of Merit Pro Utilitate Hominum of Sovereign Order of Saint John of Jerusalem,
Knights Hospitaller
Winner of Junior Chamber International Denmark's The Outstanding Young Person Award
3. Dinesh Kaippilly Kerala University of Fisheries and Ocean Studies (KUFOS), India
India is second in inland aquaculre production after China, the mainstay being the carp
production. But in resource utilization, the country lags behind. In the brackishwater side, the %
of potential land utilization still remains less than 15. Cage aquaculture sector still reamains in
infancy owing to lack of rules and regulations and inflow of funds. In the freshwater side, some of
the endemic species (eg. belonging to Western Ghats) are yet to be studied and used for
commercial aquaculture. The number of species commercially cultured in India remains less than
20 and this can be easily augmented to 100 for augmenting the aquaculture production of the
country. This will also lead to diversification-possibilites. Again, the aquaculture production of
Vietnam is almost equl to India's production. But the export value of the the former is 6.5 billion
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US$ while that of India is 3.5 billion US$. If the country can make a few strategic shifts in the
"aquacultural attitude" she can move forward must faster. Then, the aquaculture sector will be
able to contribute to the protein security and food basket of the country with much more impact
and significance.
(please double check the values as I am forwarding this in a hurry).
Dr. K. Dinesh
Assistant Professor & Head, Fisheries Station, Puduveypu, Cochin- 682508
Kerala University of Fisheries and Ocean Studies (KUFOS)
4. Dr Krishna Kaphle Institute of Agriculture and Animal Science, Tribhuvan University,
Nepal
The growing population of the planet that is bound to rise for another fifty years is a severe global
concern. Though, negative population growth in some countries may be positive news but now
with relaxed birth control policy in China, uncontrolled growth in many developing and
underdeveloped nations, rise in ethnic politics is bound to delay balance of global population. The
challenge to feed growing mouths by ensuring that the delicate eco-system is not exploited
beyond repair is no easy task.
Ending hunger and poverty requires major national policy initiatives in developing countries,
focused investment and change in feeding habbits. The UN has articulated a broad zero hunger
vision, endorsed and embraced as a priority by nations. Production of food by small cultivators in
developing countries has a critical role to play in ending world hunger and it applies to aqua
farmers.
Food habbit change, targeted culinary tourism in coastal/fish producing areas.
Sustainable harvesting from nature and production.
Managing production shun chemicals.
Price protection to producers and consumers.
R and D incorporation at all aspects from pond to fork.
5. George Kent University of Hawaii (Emeritus), United States of America
Greetings
I am commenting here on the zero draft consultation paper, The Role of Sustainable Fisheries and
Aquaculture for Food Security and Nutrition, dated 18 November 2013. My focus is on issues
relating to trade, particularly those discussed in section 3.6 of the draft, at pages 39-45.
At page 93, the draft’s bibliography refers to a publication of mine from 1997. There is no reason
to list it twice. There is also a reference to a manuscript of mine dated 2003. I recommend
replacing that with a reference to my paper, “Fish Trade, Food Security, and the Human Right to
Adequate
Food,”
available
on
the
FAO
website
at
http://www.fao.org/docrep/006/y4961e/y4961e06.htm
Section 3.6 refers to my assertion in the 1997 paper that “trade tends to move fish away from
poor people.” Is the purpose here to question the validity of that statement? If it is, I would like to
refer the writers to these other publications of mine:
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Proceedings / 10
"The Poor Feed the Rich," Development Forum, Vol. X, No. 4 (May 1982), p. 5; republished in
Development Education Forum, No. 5 (June 1982), pp. 3-7.
"Food Trade: The Poor Feed the Rich," Food and Nutrition Bulletin, (United Nations University),
Vol. 4, No. 4 (October 1982), pp. 25-33.
"The Pattern of Fish Trade," ICLARM Newsletter, Vol. 6, No. 2 (April 1983), pp. 12-13; republished
in Asian-Pacific Environment, Vol. 3, No. 2 (July 1985), p. 2.
"Fisheries and Undernutrition," Ecology of Food and Nutrition, Vol. 16, No. 3 (1985), pp. 281-294.
"Aid, Trade, and Hunger," Food and Nutrition Bulletin, Vol. 7, No. 4 (December 1985), pp. 73-79.
http://www.unu.edu/unupress/food/8f074e/8F074E0d.htm
"Fishing in the Solomon Islands: Review of A Japanese Fishing Joint Venture: Worker Experience
and National Development in the Solomon Islands," Fisheries Research, Vol. 3, No. 4 (December
1985), pp. 382-383.
"The Industrialization of Fisheries," Peasant Studies, Vol. 13, No. 2 (Winter 1986), pp. 133-143.
"Impacts of Fisheries Policy," Food and Nutrition, Vol. 12, No. 2 (1986), pp. 32-35.
"Fish and Nutrition in India," Food Policy, Vol. 12, No. 2 (May 1987), pp. 161-175.
"Fish and Nutrition in the Pacific Islands," Asia-Pacific Journal of Public Health, Vol. 1, No. 2 (1987),
pp. 64-73. http://www2.hawaii.edu/~kent/FishNutinPI.pdf
Fish, Food, and Hunger: The Potential of Fisheries for Alleviating Malnutrition, Boulder, Colorado:
Westview Press, 1987 (ISBN 0-8133-7409-X).
"Improved Use of Fisheries Resources: Alleviating Malnutrition in Southern Africa," Food Policy,
Vol. 13, No. 4 (November 1988), p. 341-358.
“’Fish for the Poor’: Competing with Chickens,” The Ecologist, Vol. 25, No. 2/3 (March/April,
May/June 1995), p. 48. http://exacteditions.theecologist.org/read/ecologist/vol-25-no-2-3-marchapril-may-june-1995-5491/11/2/
“Fisheries, Food Security, and the Poor,” Food Policy, Vol. 22, No. 5 (1997), pp. 393-404.
http://www2.hawaii.edu/~kent/fisheriesfoodsecurity.pdf
The zero draft speaks of two polarized narratives:
“On one side, following the general theory on trade, the first narrative claims that international
fish trade is good for poverty alleviation and food security. Fish export, it is argued, can act as an
engine of growth for developing countries endowed with large fish resources and provide them
with important sources of hard cash flow, which can then be used to service international debt,
fund the operations of national governments, and import large volumes of (low cost) food to
supply the domestic market, thus contributing to national food security.”
“In contrast, the ‘anti-fish trade’ narrative contends that international fish trade impacts
negatively food security and livelihood options for the poor by taking away fish from the local
economy and the local populations.”
With regard to the question of whether international trade reduces or accentuates food
insecurity, p. 39 of the draft says: “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.”
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Section 3.6 of the zero draft began by saying, “One of the key issues which needs to stay central in
this whole discussion is the question of ‘food security for whom?’” In this discussion, a distinction
must be made between the fishers and others in low income countries. Clearly, people involved in
fishing may have improved food security because of their involvement in the business. This
benefit is due to their cash income, not their intake of the fish. However, low-income people who
are not involved in the business would not have that benefit. If the fishers sell their products
mainly to high income people elsewhere, the food security of the local poor is likely to be worse
than it would have been if the producers distributed their products locally. The local poor might
get some benefit from factory wastes and by-products, but that is meager compensation for
seeing most of the local product being shipped away. The global pattern of fish trade clearly is
oriented to supplying fish to people with money more than to people with needs. The analysis on
pp. 40-41 of the zero draft supports this view.
The pattern of fish in trade flowing from the poor to the rich is strong and clear. Trade improves
the food supply of fish for the rich far more than it improves the supply for the poor. Any analysis
of fisheries and food security should be attentive to this pattern.
To review what I said in my 2003 paper, the abstract reads:
“In global fish trade, large volumes of fish are exported from poorer countries to richer countries.
This trade can affect food security in different ways for different parties, depending on the
particular local circumstances. In assessing the impacts of fisheries trade on food security, it is
important to distinguish among the impacts on fish workers and their communities, on the
general population, and on the poor, who are the most vulnerable to malnutrition. The benefits of
fisheries trade are likely to be enjoyed primarily by those whose are already well off. The poor
may benefit, but they may also be hurt. At times the harm may be quite direct, as when fish on
which they had depended for their diet is diverted to overseas markets. At times the impacts may
be indirect, as when export oriented fisheries deplete or otherwise harm fisheries that had
traditionally been used to provide for local consumption. Export-oriented fisheries may divert
resources such as labor and capital away from production for local consumption. Fish workers
may benefit from new export oriented fisheries if they participate in them, but in some cases
these workers are simply displaced from their traditional livelihoods. The human right to
adequate food is now well articulated in international human rights law. Under this law, national
governments and other agencies are required to respect, protect, facilitate, and fulfill the right to
adequate food. This means that public agencies that oversee the management of fisheries,
including fish trade, are obligated to assure that these activities contribute to the achievement of
food security, especially for those who are most vulnerable to malnutrition. To this end, it would
be useful for the international community to provide guidance on how this can be done. The Code
of Conduct for Responsible Fisheries could be elaborated to provide this guidance, giving
particular attention to the impacts of fish trade on food security.
The final document on The Role of Sustainable Fisheries and Aquaculture for Food Security and
Nutrition should take these considerations into account.
Aloha, George Kent
6. Olivier Mikolasek APDRA-pisciculture paysanne, France
This study examines intensification of low-input tilapia farming in large dam ponds and identifies
innovative practices that farmers can use for this purpose. More broadly, we consider
mechanisms for expanding development of smallholder fish farming and corresponding research
requirements to increase the efficiency and dissemination of fish farming. The analysis examines
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several levels at which innovations are produced: fish, pond population, fish rearing system,
watershed, farm and territory. We also examine the choice of the level and time horizon
analyzed. Based on existing smallholder practices, further research about effective practices that
farmers have and could adopt is proposed and discussed. The history of local smallholder fish
farming in Cameroon, the development approach carried out by non-governmental organizations
and the reference fish polyculture system based on all male tilapia are presented. Regarding the
current situation, innovative practices must be considered, particularly smallholder initiatives for
water management or floating rice production in fishponds. At each level, relevant practices are
emerging to increase fish yields or intensify lowland production while respecting the social and
economic dimensions of fish farming. It is important to recognize that the agroecological
principles and associated technical solutions are appropriate and that decreased conflict among
stakeholders can provide a consistent response. This positioning of research for rural
development favors the emergence of innovations and allows for intensification of smallholder
fish farming while taking its complexity into account. Low-input fish farming should not be
considered as only a subsistence activity of smallholders to alleviate smallholder poverty. On the
contrary, rural fish farming can generate sustainable development that is complementary with
commercial fish farming.
7. Olivier MIKOLASEK CIRAD & NGO APDRA, France
bonjour,
je prend le forum en route,excusez moi si mes propos sont décalés. Je fais donc quelques premièrs
commentaires (un peu précipité) sur le document,
best wishes
Olivier
Page 20: "Overall at these regional levels, fish consumption is lowest in Africa (9.1 million tonnes,
with 9.1 kg per capita in 2009), while Asia accounts for broadly two-thirds of total consumption,
with 85.4 million tonnes (20.7 kg per capita)."
de fait, les statistiques nationalespeuvetn masquer des consommations locales en milieu rural très
importantes. Sur 98 foyers issus de 6 villages en région Centre (Cameroon), enquêtés 1
semaine/mois en 2007-2008 (soit 8132 données quotidiennes): les dépenses moyennes pour
l’achat de poisson s ’élèvent à 130 000 F CFA /foyer/an ou 19 300 F /pers; la consommation
annuelle en équivalent poisson frais de l’ordre de 35 kg/pers./an.
Grosse O., 2009. Importance of the fish in the food consumption of villagers in the Central and
West-Region of Cameroon, APDRA-F, Massy, France, 25 pp., French, http://www.cabi.org/ac/
(consulted in July 2013)
Page 31 : Environmentally sustainable aquaculture production depends on the right combination
of farming systems (including health management), feeds (See section 3.7) and improved
germplasm (Browdy et al. 2012)../.. However, in the absence of effective genetic improvement
and breeding programs cultured stocks may even beinferior to wild populations due to inbreeding
(Acosta and Gupta, 2010)"
"l'amélioration génétique n'est pas toujours une panacée: "For Brummett and Ponzoni (2004),
there is a need for genetic improvement programs in face of the genetic degradation of reared
Nile tilapia (O. niloticus) in African fish farming systems. In a study carried out in Cameroon,
Brummett et al. (2004) compared growth of a wild strain with that of a domestic one in a rural
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environment and an experiment station (Table 3). They observed a significant decrease in growth
(up to 40%) of the reared strains. Therefore, they concluded that smallholders cannot ensure
correct genetic management of their fish and proposed entrusting it to large farms in a publicprivate partnership. Moreover, the improved and synthetic tilapia strain called GIFT would be a
neutral technology which can meet the expectations of small and large producers regardless of the
feed and manure levels used in the fish farming system (Acosta and Gupta, 2010).
However, without any genetic improvement, large fish of 400 g are obtained in 6 months from 30
g fingerlings (at a density of 0.11 fish/m2) with a daily weight gain of 2 g/day and a water
temperature around 26°C during the rearing cycle. An improved strain such as GIFT fed with
balanced feed reach this weight in 4 months at a daily weight gain of 3 g/day and a constant
temperature of 28°C, but at 22°C and the same duration the final weight would be 60 g (Santos et
al., 2013). It is unknown what additional production GIFT will bring to an unfed pond, the utility in
selecting a strain in this low-input environment (Charo-Charisa, 2006) and the reaction of this
selected strain when facing moderate intensification.
Probably, the value of the expected gain is not able to finance any selection service or even fry
distribution at these small scales. Though carp fingerlings are available at the national level,
producers give up their supplies, showing how unrealistic this option is. Farmers will see access to
selected fish as an additional financial cost, which does not meet their expectations. Moreover, in
the current situation, some traders or projects already promote exceptional quality seed that are
never verified, an inevitable scam which perhaps participates in the maturing of the fish farming
sector.
First, the tilapia population used by smallholders should be described genetically. It would help to
set up a management plan to preserve the potential and genetic variability taking while also
considering the specific context. It should be noted that the fish farmers described have already
implemented a rough genetic management plan; it is based on integral renewal of broodstock
combined with exchanges of a few breeders within and between groups of fish farmers and also a
small supply from the natural environment.
The position of international institutions (such as FAO, WorldFish) on genetics, since taken by the
technical services of Cameroon, has to be questioned by research. Does this apparent vocation of
universality of improved tilapia apply to fish farming systems that are primarily based on natural
productivity and geographically scattered (Khaw et al., 2013)? Does it not exclude all forms of
development based on self-sufficiency of farmers for fish stocking supply? And does it thus exclude
the ability of most people in rural and poor environments to sustainably adopt a system that is
self-sufficient in fish? Like the paradigm of balanced feed, access to genetically improved strains is
not the limiting factor in developing smallholders’ fish farming and increasing fish yields; the
supply of nutrients to stimulate the pond food chain appears more efficient (Karim et al., 2011)."
(Oswald, Efolé et Mikolasek, in press)
page 43 "In sub-Saharan Africa the very limited information available also underlines the
importance of local trade. In the Democratic Republic of the Congo for instance, data collected
from the region of Lubumbashi revealed that households consume fish on average 5.17 times per
week (31% consumed fish every day)"
voir au dessus
Page 43 : It could also in the specific case of Africa stimulate the production of aquaculture which
has had difficulties in taking off. The increased demand for fish by the growing urban (and rural)
population could boost investments of, e.g., peri-urban aquaculture (Brummett et al 2004)
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Proceedings / 14
"Commercial farming is successful; however, it requires the use of many imported resources
(inputs, expertise). Purely commercial farming supplies the large African city markets, which are
most likely to generate profits. Integrated and more extensive fish farming is often considered
inefficient because of the perceived waste of subsidies (i.e., spending without subsequent
development). For fish farming integrated into small household agriculture, many realities exist in
humid West Africa. Many such systems have proven both their efficiency and resilience over the
past 20 years (Oswald, 2013; Simon and Benhamou, 2009; El Sayed 2006; Oswald et al., 1997a)"
(Oswald, Efole et Mikolasek, in press)
Les modèles industriels ( et le plus souvent les PME ) - le nouveau paradigme de l'aliment extrudé
complet- produisent un poisson cher qui est réservé à la clientèle iasée des grandes villes
Page 54 : Although demand for fresh fish is increasing in Africa (in particular in urban areas),
smoked, dried and low quality processed fish still represents by far the largest majority of the fish
consumed by the rural populations but also by the low income classes in urban areas.
La faible efficience des filières de distribution du poisson congelé importé par exemple fait que le
poisson y est distribué en milieu rural à un prix plus élevé que celui en ville (observations faite au
Cameroun, en côte dIvoire ...)
Page 59 : ”The relative poor performance of African aquaculture has been caused by a number of
factors, among them the different market conditions in Africa, but also the externally driven
focus on smallholder aquaculture. Whilst this has proven successful in building resilience of poor
smallholder farmers to external shocks through improving household nutrition, building social
capital (through exchange of fish within communities) and reducing sensibility to periodic
drought, it had not led to significant growth in production at national or continental level.
voir plus haut, il peut exister des développement significatifs de modèles de pisciculture qui soient
en adéquation avec les ressources en intrants limités des paysans
Rather, current evidence indicate that significant increases in farmed fish production in Africa are
more likely to be achieved through careful investment in well targeted value chain approaches to
the development of the SME [small and medium enterprises] aquaculture sector in place where
this can respond to strong markets (…)” (2010, p. 355)
Les SME, est uen réalité généralisable ou un voeux (en Afrique)
Page 61 : For aquaculture, the conclusions are not so clear. The small-scale, subsistence
aquaculture model has failed to deliver its promises in terms of poverty alleviation and food
security, and the paradigm has now shifted toward slightly larger (i.e. medium- scale), more
commercial-oriented enterprises, with the hope that this new emphasis on medium scale will be
more successful at delivering benefits. Time will tell whether this was the right strategy.
j'adère cette idée que le rôle respectif des différenes catégories de pisciculture reste à clarifier. Et
les insuccès en Afrique de la pisiculture paysanne ne restent -elles pas liées à l'insuffisance de la
prise en compte de la dimension socioéconomique de l'activité en lien avec la valorisation du statu
de paysan ou d'agriculteurs familiaux ?
cela pose toutes sortes d'autres quesions sur les modèles qui sont proposés (reconstruits) aux
paysans. Et ceci est crai pour l'Afrique mais aussi sur d'autres continent à l'exemple des modèles
sociotechniques développés dans certains Etat du Sud Brésilien etc."
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8. Shekhar Ojha Central Institute of Fisheries Education, Mumbai, India
Sir/ Madam,
Human hunger is greatest humiliation to humanity. Food security bill of India ensures food to the
mass. This is a welcome gesture. To march beyond food security to nutritional security is not
marely an emotional commitment; it requires technology and strategies. Wasteges in nutritional
but perishable food is expected to be more than general food items. Such wasteges can be
miniised by integrating production and consumption of perishable fish by the poor, for the poor
and of the poor.
1. Every school in the villages may be provided with ponds culture fish and share its benifits.
2. New "Livelihood Habitates Centers(LHC)" for the poor" may be developed around a pond
so that the poor can consume fish while learning about new livelihood skills.
3. Similarly mariculture and cage cultures may be encouraged through village schools and
new LHCs developed.
Having done so we can ensure nutritioal security through fish to some extent.
REGARDS,
Dr. S.N.Ojha
Principal Scientist
Central Institute of Fisheries Education, Mumbai, INDIA
9. Samueline RANAIVOSON Ministère de la Pêche, Madagascar
Bien que pauvre, les populations en zone côtières ont la majorité une dentition saine par une
consommation régulière de produits halieutiques,
les femmes des pêcheurs constituent la majorité des mareyeurs qui vendent porte à porte ou
directement au marché les produits pêchés et en aquaculture, ce sont toujours elles qui
s'occupent de l'aquaculture familiale, une sensibilisation plus poussée et un renforcement de
capacité de ces f
les produits halieutiques sont considérés comme produits nobles pour beaucoup pays en voie de
développement suite au faible pouvoir d'achat que ce soit des consommateurs urbains que des
producteurs mais la pêche industrielle doit contribuer à l'amélioration de la sécurité alimentaire
par le débarquement des bycath pour le bien de la population locale
les aires marines protégées ou réserves de pêche gérés conjointement avec la communauté de
pêcheurs , contribuent à la sécurité alimentaire, les expériences vécues par la gestion unilatérale
de ces réserves par l'administration a été toujours un échec
L'aménagement concerté avec toutes les parties prenantes au niveau national est la formule la
plus appropriée de gouvernance
la farine de poisson utilisée pour l'alimentation de poisson qui ne constitue que 10% de cette
alimentation ne nuit pas à la sécurité alimentaire mais une production de farine de poisson
consommable pour l'alimentation humaine à partir des bycath serait un plus
les impacts du changement climatique jouent un rôle prépondérant en pisciculture en étag et en
rizière, alors le développement de l'aquaculture marine et cage serait un atout, il ne faut surtout
pas minimiser la culture d'algues marines. l' ICAM constitue aussi un phénomène à ne pas
négliger
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10. Eltighani Elamin, GIZ/WB AfghanStat, Afghanistan
Dear Madam/Sir
First I would to see the subject title qualified as "Role of sustainable fisheries and aquaculture in
food and nutritional security" rather than food security and nutrition, because once people are
nutritionally secured then by virtue they also food secured, but, the reverse relation is not
necessary maintained. In Sudan, we experienced with WFP programme that the more food we
distribute to the needy people the more higher rates of malnutrition prevailed, simply, because
the WFP ration is mainly energy based cereals. Therefore, with lack of protein and other micro
nutrients hidden hunger and malnourishment are perpetuated cross the country.
Actually, I run fast through subject report and I see the above argument is missing. Fish and sea
food are plentiful and fisheries can balance the food ration/basket of WFP and other
humanitarian programmes worldwide. All we need is to leveraging the fisheries industry to bridge
this unbalance food distribution and even more engagement of the private sector in fisheries to
play its right roles in boosting global nutritional security. Issues like developing the taste for sea
food in particular in Africa and Middle East and encouraging fishery industry in inland river waters
for landlocked countries deserve more attention by the FAO and its subsidiaries.
Elamin
Key Expert
GIZ/WB AfghanStat
Kabul
-----Professor Eltighani Elamin (PhD)
Freelance consultant
Senior food/agriculture policy & capacity development specialist
Khartoum, Sudan
11. Menakhem Ben-Yami, Israel
I'm sending you separately a chapter I wrote for the OCEAN YEARBOOK 25, 2011, Publ. by
Martinus Nijhoff Publishers, Leiden-Boston, entitled: Marine Farming: Perspectives on its
Inevitability and Sustainability. Pp. 1-25
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/Final%20version_0.pdf
12. Paulo Pereira, Colonia dos pescadores, Brazil
Eu sou coordenador da colonia dos pescadores z- 26 de Italva - RJ.Trabalhamos com eles na
orientação de presevar a natureza. Qual tipo de apatrexo q eles estão usando, para não capitura
os peixe pequenos
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13. Emad Mahgoub, Agricultural Research Corporation, Sudan
Current State of Global Aquaculture
Believed to have originated in China over 2000 years ago as a recreational pursuit, aquaculture is
expected to have overtaken capture fisheries as the key food-fish producer by 2014. According to
the United Nation’s Food and Agriculture Organization (FAO) total aquaculture production in 2011
was over 63 million tonnes. A significant trend in much of developing Asia is the growth in
commercial and small farm aquaculture, spurred by increasing demand. The Asian region
contributes over 90 per cent of global production, while China remains the world’s largest
producer in the sector with 47.5 million tonnes produced in 2004.
Role of Aquaculture for Food Security and Nutrition
Nutritional Benefits
According to the FAO, over one billion people worldwide rely on fish as their primary source of
animal protein. Around the world, average annual fish consumption is 16.1 kg per capita. In
South-East Asia most major species of fish produced are primarily for local consumption, with
Thailand and Vietnam deriving over a third of their fish production from aquaculture. In the last
30 years, animal protein consumption per capita in developing countries has more than doubled,
as a direct result of technology advancement in aquaculture.
Those living in poverty and in lower socio-economic households are unable to access sufficient
nutritional food to ensure their health and wellbeing. Often the food produced or purchased
consists of cereals or low-cost staple ingredients; budgets are unable to stretch to include meat or
fruit and vegetables. Fish, particularly produced through aquaculture, is commonly cheaper than
other animal meat. It also contains much higher protein levels, as well as other important
minerals and vitamins. As a means of providing greater nutrition for many poorer households,
increased availability of fish can mean better health and a more diverse diet.
Indirectly, commercial aquaculture leads to increased food security by providing opportunities for
employment and income generation for local communities. More than 500 million people in
developing states reportedly depend on fisheries and aquaculture for their livelihood. As a
majority of aquaculture production occurs in developing states, a rise in income leads to an
increase in food purchasing power and, more importantly, diversification. The consumption of
non-staple foods, including fish and vegetables, has a positive correlation with income growth,
supporting food security and greater nutritional content in diets.
As poverty is often worst among rural communities, aquaculture presents an opportunity to
diversify income and protect against market fluctuations in the prices of agricultural products.
This integrated system of using agricultural land to raise fish, increases potential yield rates per
annum. Diversification also increases overall land productivity, by utilising farm by-products as
aquaculture feed and the water from aquaculture sites as a means of irrigating crops.
There are considerable constraints on aquaculture, particularly when intensive production is the
key income generator for a farmer. Poorly developed infrastructure and limited access to
transportation or urban centers,
Future Opportunities
Governance and access to market
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The culture of exporting high-value fish persists, aided by government incentives; credit, low
tariffs on imported supplies and infrastructure, and cheap land leases are prevalent. These
benefits tend to favour wealthier producers, with low-income subsistence farmers often left with
little support to sustain their aquaculture farms. Future policies and governance should focus on
small-scale aquaculture as a means of poverty alleviation and improving food security. This
assessment is supported by the positive effects on the production levels of poorer farmers, when
they have been given access to technology and market opportunities.
Growth in the sector over the last two decades has been achieved through the adoption of new
technologies and the diversification of farming practices. In Vietnam, the adoption of artificial
propagation techniques for striped catfish, made it possible to produce fish seeds on a mass scale.
In 2007, catfish production accounted for more than 50 per cent of Vietnam’s aquaculture
production and has created livelihood opportunities for hundreds of people living in the Mekong
Delta.
Past failures in aquaculture development have been linked to mismanagement, unclear land and
water rights, and the use of inefficient government hatcheries. The capacity to develop
aquaculture continues to suffer limitations due to weak institutions. A critical issue for fish
farming, both subsistence and commercial, is the stringent health and safety requirements for
exporting to the global market. With the costs and infrastructure required to meet standards,
government support will be necessary if farmers, particularly small-hold farmers, are to
successfully produce for overseas markets.
Instead of policies focusing on commercial farming and exports, policies and supporting systems
need to address the needs of small-hold farmers, to ensure stability and food security for
subsistence level households. Improved productivity, the expansion of aquaculture and the
introduction of strategies to engage the poor, will enable aquaculture to have a far greater impact
on food security. A key challenge regionally will be in developing standardised regulations and
practices in line with international regulations.
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/Current%20State%20of%20Global%20Aquaculture.docx
14. Camille Piche, Canada
Dear HLPE Secretariat,
e-HLPE Consultation,
I believe that the information I am sending you fits within your mandate to: "consider the
environmental, social and economic aspects of fisheries including artisanal fisheries, as well as a
review of aquaculture development".
I am sending you a film which was made in British Columbia, Canada on BC Salmon. I believe this
film really puts in focus the whole question of Sustainable fisheries and aquaculture. I see it as a
very credible and very enlightening film and I am sure that those who participated in the research
and made the film would be most happy to contribute any additional information.
This video is worth the viewing...especially if you live in BC or on the West Coast or if you love
salmon,
The way Industrial fish farms get support from the municipal, provincial and national
Governments, discount findings by world experts or prevent the truth from being made public is
an outrage.
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Seeing how that is depleting wild salmon runs, causing deformities and sickness in the fish that
are then allowed to be placed on supermarket shelves or shipped to the US and China is criminal.
It shows what one is up against when dealing with Government or multinational Corporations.
Part of my work is alerting people!
If you know of a different interpretation of fish farms, let me know.
http://www.salmonconfidential.ca
I am not a 'fish' expert - but hope you can look at this, investigate and find some response.
Kindest regards,
Camille
15. Lizzy Igbinne, Nigerian women agro allied farmers association, Nigeria
In issues of Water and food security, Women farmers contributions have enhanced growth of
Agriculture. Women farmers therefore have great experience and potentials in fighting hunger
and enhancing a food secured world.
This makes case for women farmers to be involved in land policy decisions and and Agriculture
and Water developements in their countries.
Lizzy Igbinne, Nigerian women agro allied farmers association, Nigeria
16. Lizzy Igbinne, Nigerian women agro allied farmers association, Nigeria
Dear Partners,
We have to use evidence in treating food security issues.
We the Nigerian women aa farmers association have contributed immensely in Nigerian
Agriculture growth including water and food security.
W have clusters and thematic groups and we have practically trained and empowered and
returned to farms women in rural communities in Nigeria.
These women are in fisheries, aguaculture and other areas. I am using pictures to show some of
our work and evidences of women we have touched and our contributions to food security.
Please expect our pictures as Pdf on my next submission and look at this examples.
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Proceedings / 20
17. Alu Ibrahim Elkhalil, Sudan
Some policy aspects & recommendations on the zero draft paper titled: “The Role of Sustainable
Fisheries & Aquaculture for Food Security & Nutrition”, by Ali Ibrahim Elkhalil from
SUDAN
The zero draft report contains lot of information enough to produce an excellent report but of
course it needs some fine tuning & editing which I do strongly believe that the paper committee is
quite capable of doing it.
Some Policy Aspects:
Lack of clear & practical government policies towards developing fisheries resources as in the case
of Sudan though it is well endowed with a variety of fresh & marine water fish from the red sea ,
river nile & tributaries , flood plains & swamps.
Weak marketing structures accompanied with the remoteness of catching centers
Focusing on fish & ignoring aquaculture
Lack of awareness with regard to the importance of fish & aquaculture in food security & nutrition
Fish farming is still limited in some countries though conditions are conducive and encouraging
Recommendations: FAO should help & encourage member states to plan for & develop this
sector for the sake of poor & their health& nutrition in particular countries with good resources:
- strengthening marketing & transport structures
- cancelling all types of taxes & fees imposed on this sector
18. Gianluca Ragusa, International independent consultant, Italy
Dear Madam/Sir,
thank you for your kind focus of the role of fisheries and aquaculture in contributing in food
security. Fishery (namely traditional and small scale fishery including collection) and aquaculture
contribution to food security is in my knowledge underextimated (contributing as in the case of
the Mali to the livelihood and benefits sharing of rural populations and before the recent
problems to the third voice of the internal production, with no enogh resources (human, capacity
and financial) to contribute to the sustainable and equitably managent the sector or eg in The
Gambia were the actual level of governance (DoF and civil sosciety) risks to not have the needed
capacity to accomplish the on-going and planned fishery development strategies.
Let me stress some key factors
Governance : co-management and decentralisation or deconcentration are procedures that are
still unfortunately on the paper (lack of human resources, trained and fincial instruments). This
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procedure could be better overcome at country level compresied in a procedure of
regionalisation and transfer of knowledge/solidarity among the concerned countries.
Gender : the role of the women is still underestimated and the new valid associations (eg. Try
Oyster. women collectors in The Gambia) can risk to survive in the long term to the on-going
programmes/projects, if not further supported bytheend of the programmes/projects. Please,
kindly find attached a FAO report with some interesting figures on the role of the women in
fisheries.
Hope it will be useful.
Looking forward to hear from you, let me thank you, Madam/Sir, for the efforts that your
Organization do to enhance the International cooperation, sustainable development and to
eradicate poverty and hunger.
Sincerely.
Gianluca RAGUSA - International consultant (Fishery and aquaculture)
Via Tuscia, 7 - 00191 Rome (Italy)
Ph: (+39) 063291240
Mb: (+39) 3393096798
Dans l'attente, veuillez agréer, Madame/Monsieur, l’expression de mes remerciements les plus
vives pour les efforts de vôtre Organisation dans les domaines de la coopération International, du
développement durable, de l’éradication de la pauvreté et de la faim dans le monde.
Salutations sincères.
Gianluca RAGUSA – Consultant international (Pêche et aquaculture).
Via Tuscia, 7
00191 Rome (Italie)
Tel.: (+39) 063291240
Mobile: (+39) 3393096798
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/Gender%20and%20Fish%20Value%20Chains.pdf
19. Jariah Masud Institute of Gerontology, Universiti Putra Malaysia, Malaysia
Women comprised of almost half of the fishing communities and their roles have not been fully
developed. The traditional gender roles remain intact and those responsible for the development
of small scale fishing communities remain gender blind or consider themselves gender neutral.
Enhancing women's roles in fishing sector especially in the post harvest or processing will help
enhance food security and eventually help eradicate poverty which remain high among fishing
sector even in Malaysia.
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Focusing the development human resources in the fishing sector will eventually help eradicate
poverty and achieve food security. Efforts should be undertaken to integrate gender into the
development of small scale fishing sector. Those responsible in the policy and program
formulation must be gender sensitize as to enable them to address the gender issues in the
sector.
More research on the fishing communities are needed to provide better understanding of the
dynamic of the community as input into the evidence based planning.
20. Abdul Waheed, Society for Environmental Actions,
Humanitarian Response, Pakistan
Re-Construction &
I am sharing one of my field story: Fisherwomen Seeking Livelihoods
Ali Hilayo a 45 year old fisherman has been fishing since childhood and his parents were doing
same since their grandparents. But increasing pollution and reduction of fish stock at Keenjhar
Lake turns him to hunt migratory birds during winter season.
This very important eco-system supports a rich biological diversity. Keenjhar Lake is situated in
Thatta District, Sindh, Pakistan. It is 122 km away from Karachi. Being situated along the Indus
flyway, the lake has been an important breeding, staging and wintering ground for a wide array of
waterfowl. Common species of mammals found at the lake. Reptiles include Indian cobra, Sawscaled viper and Monitor lizards. During a recent survey 48 different fish species were recorded
from Keenjhar Lake.
Ali Hilayo realized “only hunting of birds would not resilient food and livelihoods of his family”. He
started to entertain visitors at Keenjhar Lake with speed boat and in a short time number of his
speed boats increased from one to four and set an example for other fishermen. A shift in
occupation enabled other community members to think of the alternative of livelihoods rather
than practicing illegal or unfriendly environmental activities such as hunting of migratory birds,
mammals, stone extraction, and using zero size nets for fishing.
Soon after, Livelihoods concern brought fisher folks men and women together under one roof for
discussing the alternative livelihoods in the leadership of Mr. Ali Hilayo. Almost all the
development plans were man focused, because; due to cultural barriers, women of the
community were not allowed to be engaged in outdoor activities for livelihoods; however, women
themselves brought an idea to setup an eco-fish outlet at Keenjhar Lake, since they are expert in
fish recipes and can prepare the order at household level collectively and send to outlet where
local fish dishes would be served to visitors.
It was first time, women and men collectively thought some different from traditional embroidery
or making some stitching work. The idea was appreciated very much because, it was empowering
women practicing culture and promoting importance of Keenjhar Lake.
With the support of WWF-Pakistan’s Indus for All Programme, the Eco-Fish outlet was
constructed and equipped with all facilities. Very soon, it becomes famous and attracts attention
of visitors at Lake. Mr. Ali told; “It earns about 1 million approximately in every season (May to
August) since last four years.”
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Other fishermen at Picnic Point of Keenjhar Lake expressed; “In beginning, we all were not
considering the eco-fish outlet as an option of alternative livelihood, but a group of 20 women in
the leadership of Mr. Ali proved they can earn 12000 rupees approximately per month by cooking
for few hours at their home. We appreciate the efforts and contribution of women for securing
food of their families since the lake is steadily becoming dumping site of liter, unsafe chemicals of
Kotri SITE area.”
A group of women collectively expressed “We are thankful to WWF for supporting us, today we
can earn to feed our families at our own. This also helped our families not to migrate from
Keenjhar to somewhere else”. They felt very sorry; due to limited skills of marketing and
entrepreneurships otherwise, local eco-fish outlets could be started at every town or big city such
as Karachi and Hyderabad.
Mr. Ali and group of 20 women are contributing greatly for conservation of the Keenjhar Lake and
securing food for their families. The Eco-Fish outlet has become sustainable and today they are
working at their own. Reflecting his emotions, Mr. Hilayo expressed and asked “If a very small
initiative of WWF can contribute to save the livelihoods of 20-30 families, why our Government
policies have failed to save this Lake?
Mr. Ali and a group of women were requesting to their elected representatives, Government
official and Water Board Karachi for extending their sincere efforts for the development and
conservation Keenjhar Lake. Because; this is not only the matter of water storage for Karachi but
50 villages having approximately 70’000 populations are living around this second largest fresh
water lake in Pakistan and it is important Ramser Site, Wetland and Wildlife Sanctuary.
21. Vijaya Khader, India
Sir / Madam,
Please find the enclosed broucher on Fisher Women Entrepreneurship & Success Stories. You may
find some information. http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/fisher%20women_brochure.pdf
VijayaThanks & regards,
Prof.(Mrs) Vijaya Khader, PhD
Former Dean, Acharya N G R A University, Hyderabad &
Principal Investigator, Food Technology, e-PG Pathshala
22. Anura Widana New Zealand
Wet-paddy fields are a tremendous source of protein-rich food, income and livelihoods to people
in the Delta regions. The countries in the region include Cambodia, Laos, Myanmar, Vietnam and
parts of Thailand. The first three countries are perhaps some of the few in the world where the
application of agro-chemcials is not heavy as elsewhere. However, there is an increasing trend of
application into wet-paddy lands. This has created a substantial loss of protein-rich food and
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livelhoods for the majority population who depend on the collection, sale and consumption of
fish, crabs, prawns, snails, insects and other creatures from paddy fields.
The attached pictures show the dependency of people in Delta region on the free-harvesting of
creatures frm paddy fields. Measures to reduce chemcial application is warranted to save
livelihoods of the majority living in Delta areas.
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/Food%20from%20chemicalfree%20paddy%20fields.pdf
23. Stephen J. Hall WorldFish, Malaysia
Please find below some comments on the report.
The team has done an excellent job on this first draft and I hope that you find these thoughts
useful in preparing the next version.
This is a compilation of comments from several staff at WorldFish.
Regards
Stephen J. Hall
Director General
WorldFish
General Comments
This report will provide a welcome contribution to the global food security debate and a broader
appreciation of the role of fish in FNS. There is general agreement that fish can play a greater role
in providing for a food secure future. In order for that to happen the dominant narrative around
fish needs to shift. This report is a welcome move in the right direction.
Below we provide some comments and references that may be of interest (see also appended
pdfs). The report is an early draft and needs a great deal of editing; as a result we have not
offered any copy editing comment. Particular care will need to be taken in future versions of this
document to make the referencing more comprehensive. Cite original data sources and or
citations for empirical papers, opinion pieces and synthetic reviews in the text and figures/tables
(e.g. Figures 3.3 and 3.4).
Specific Comments
Chapter 3

The paper deals extensively with the many pathways for improved nutrition. It also takes
into consideration the current literature and debate on the linkages between agriculture
and nutrition, and in particular the role of fish as an animal-source food of multiple
macro-and micronutrients for nutrient contribution to vulnerable population groups, in
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particular women and young children. The text may benefit from an expanded
introduction to ‘why people eat fish’.
The contribution to nutrient requirements and health benefits are presented in a very
convincing manner, but it could be argued that it is more bullish than the scientific
evidence can really bear.
The report should make more of the role of fish as a source of micronutrients in the
complementary food of children from the age of 24 months.
Special mention should be made of the special role of dried fish in the diets of the poor
and “hard to reach” population groups, as well as food safety issues regarding processing
(e.g. use of contaminants and excess salt).
Pg 17: The issue of heavy metal content in large fishes is given only cursory mention. The
impact of mercury in tuna is an issue that continues to claim consumer attention in
developed country markets and should be discussed in more detail.
Figure 3.1 is difficult to follow and appears to be of limited value as a heuristic tool for
conceptualizing pathways in the use of fish
Pg 24 and onward: The ‘fish for cash’ section is poorly developed and omits reference to
a large literature on the local trade of fish
Pg 29: The ‘Fisheries Crisis’ section is poorly developed and does not adequately
represent a complex and heterogeneous literature
More needs to be made of the geographic differences in the supply and utilization of fish.
For example, (i) in 2008, Dey et al. reported that about 61% of the world supply of fish
comes from Asia where a large proportion is consumed domestically. The paper also
noted that as per capita income and population grow in most Asian countries, there will
be tremendous increases in fish demand that are expected to come mostly from the
poorer sector of the economy.; (ii) FAO has previously reported that China is increasing
its demand for fish and may have implications in global fish supply and consumption – this
needs to be teased out, (iii) obesity and diabetes are rapidly becoming a major heath
issue in some Pacific countries – the role of fish and the changes in diet adoption of
western diets needs to be highlighted. As these simple examples highlight, there are
many geographic differences in the supply and use of fish – there can therefore be no
global prescriptions for the better use of fish in improving nutrition and food security.
Rather surprisingly, climate change rates barely a mention. Climate change will change
the availability of fish, and change the distribution of supply and consumption. Analyses
of the implications of CC on the role of fish in FNS would be welcome. This should be
developed. Some references are noted below or appended as pdfs.
Chapter 4

The inclusion of a gender focus is welcome and the text comprehensive. Please find
attached documentation of a recent consultation on social relations and food and
nutrition security organized by FAO
(http://www.fao.org/fsnforum/forum/discussions/networks-for-FS) . Even though it is not
specifically focused on fisheries and aquaculture, it gives some good insights into the
gender relations-nutrition nexus.
Chapter 5

Page 74, lines 14 – 20. The argument against the prevailing IUU narrative as one that
characterizes small-scale fishers as “roving bandits” seems rather gratuitous. IUU debates
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 26
certainly focus on high seas fisheries, but to argue by extension that the IUU label is also
demonizing small-scale fisheries seems a stretch.
Chapter 8

Mention might be made here of the value of rapid restoration and re-stocking of smallscale aquaculture ponds following natural disasters. Following the tsunami in Aceh, this
was a rapid way to establish a cash and food generating activity in the months following
the immediate humanitarian relief efforts. Re-establishing gardens and crop production
took much longer.
Some references that may be of use (see also some attached pdfs)
Allison, E. H., A. L. Perry, M. C. Badjeck, W. N. Adger, K. Brown, D. Conway, A. S. Halls, G. M.
Pilling, J. D. Reynolds, N. L. Andrew, and N. K. Dulvy. 2009. Vulnerability of national economies to
the impacts of climate change on fisheries. Fish and Fisheries 10:173-196.
Badjeck, M.-C., E. H. Allison, A. S. Halls, and N. K. Dulvy. 2010. Impacts of climate variability and
change on fishery-based livelihoods. Marine Policy 34:375-383.
Bell, J. D., C. Reid, M. J. Batty, P. Lehodey, L. Rodwell, A. J. Hobday, J. E. Johnson, and A. Demmke.
2013. Effects of climate change on oceanic fisheries in the tropical Pacific: implications for
economic development and food security. Climatic Change 119:199-212.
Beveridge MCM, Thilsted SH, Phillips MJ, Metian M, Troell M, Hall SJ (2013). Meeting the food and
nutrition needs of the poor: the role of fish and the opportunities and constraints emerging from
the rise of aquaculture. Journal of Fisheries Biology, 83, 1067-1084.
Branch, T. A., B. M. De Joseph, L. J. Ray, and C. A. Wagner. 2013. Impacts of ocean acidification on
marine seafood production. Trends in Ecology & Evolution 28:168-186.
Delgado, C L 2003 Rising consumption of meat and milk in developing countries has created a new
food revolution. Journal of Nutrition,133, 3907S-3910S.
Gallet, G. A. (2009). The demand for fish: a meta-analysis of the own-price elasticity. Aquaculture
Economics and Management 13, 235–245. doi: 10.1080/13657300903123985.
Kabahenda, M. K., Amega, R., Okalany, E., Husken, S. M. C. & Heck, S. (2012). Protein and
micronutrient composition of low-value fish products commonly marketed in the Lake Victoria
region. World Journal of Agricultural Sciences 7, 521–526.
Leung, T. L. F., and A. E. Bates. 2013. More rapid and severe disease outbreaks for aquaculture at
the tropics: implications for food security. Journal of Applied Ecology 50:215-222.
Murshed-e-Jahan, K., Ahmed, M. & Belton, B. 2010. The impact of aquaculture development on
food security: lessons from Bangladesh. Aquaculture Research 41(4): 481-495.
Rae, A. N. 1998. The effects of expenditure growth and urbanization on food consumption in East
Asia: a note on animal products. Agriculture Economics, 18, 291–299.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 27
Speedy, A. W. (2003). Global production and consumption of animal source foods. Journal of
Nutrition 133, 4048S–4053S.
Sumaila, U. R., W. W. L. Cheung, V. W. Y. Lam, D. Pauly, and S. Herrick. 2011. Climate change
impacts on the biophysics and economics of world fisheries. Nature Climate Change 1:449-456.
Thilsted SH (2013). Fish diversity and fish consumption in Bangladesh. In: J Fanzo, D Hunter, T
Borelli, F Mattei, eds. Diversifying Food and Diets: Using Agricultural Biodiversity to Improve
Nutrition and Health. Earthscan, London. pp 270-282.
24. Anne Mugaas, The Royal Norwegian Society for Development, Norway
Comments from Norges Vel to HLPE Aquaculture and Fisheries 0 Draft Report
The report gives valuable input to the various issues analysed. The Royal Norwegian Society for
Development (Norges Vel) agrees to the overall recommendations given.
1. We agree completely with the focus on SMEs for developing aquaculture. One has to
focus on the whole value chain where SMEs are one of various actors to achieve lasting
and significant developments. SMEs can be organized in business units such as a
cooperative or AS/AS Ltd. They can include both medium scale and smaller farmers.
1. Through SMES, small and medium scale farmers can organize together to respond to local
and regional market demands. They can access common input (fingerlings, fertilization/
feed, investments), technical knowledge and apply common quality standards and
together ensure quality products and regular production. We believe SMEs can create
work places, income increase and improved nutrition. They can create sustainable
development of the sector.
2. Can contributions be given to food security through production of fish for food and fish
for sale? We agree that a careful balance needs to be struck between aquaculture of fish
for sale and for own consumption. Production for sale will limit possibilities for own
consumption, but might be achieved with consumption eg. of only smallest 10% of the
fish reared in aquaculture. The remaining part of produce is sold and generates profits in
the SMEs. This is our experience from Madagascar.
2. In eg. MPAs, our experience from Madagascar shows that fishing can be reduced when
aquaculture is promoted (time used for aquaculture limits time available for fishing, and
aquaculture generates sufficient income to maintain fishing only at low level). With
profitable aquaculture being carried out (in this case seaweed and sea cucumber farming
for export) parallel to continuation of some local fishing – both income, food, export
earnings and stock maintenance/ improvement is ensured.
3. Food waste should be included in the report. We know that marine value chains are very
vulnerable to production of food waste. Less food wasted equals more food available for
food and poverty reduction from fish farming/ aquaculture. Since a report recently has
been written on this theme, the main conclusions from the FAO report on food waste
should be integrated into the present report. This will add a further dimension to the
report.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 28
4. We strongly support FAOs recommendation to look at the whole value chain to see
women's position in fisheries and aquaculture. We believe in combining technical,
entrepreneurial, financial and organizational training for both women and men through
systems of Training of Trainers in order to reach out to more farmers and to strengthen
their capacities in existing and new parts of the value chains as relevant. We also fully
agree to involving men and women in sensitization about cultural values and limitations
for improving gender relations and women's participation, in order that specific plans/
strategies at local level can be elaborated by people themselves, and implemented based
on local empowerment processes which need to continue through local organizations
developed.
5. To succeed with the above, it is important that the governments provide an enabling
environment: access to improved genetics as highlighted in the report, together with
access to improved management and access to input for fertilisation/ feed is important,
but also important is that the state gives the frameworks through relevant policies and
laws for developing the fisheries and aquaculture sectors in close collaboration with local
communities/ associations and SMEs in addition to larger companies in relevant value
chains.
6. Savings and credit: After models for aquaculture are seen to be profitable – and only
after this in practice – access to savings and credit must be ensured for relevant SMEs.
This can promote further business development of the aquaculture sector.
7. Using seaweed and other marine ingredients for fish feed should be promoted – it is
already used to a certain degree (eg. in Norway), but should be further investigated as
much as possible. Large fish feed companies (eg. EWOS) already participate in pilots for
testing IMTA in Norway, but there is a need of course to upscale to reach substantial
amounts – it is also worked on in other regions – and could (should?) be an area to be
assessed / worked more on also for developing countries. Norges Vel has successful
experience from working in this area both in Norway (pilots) and internationally (seaweed
cultivation for poverty reduction/ Madagascar – as done in Asia by a large amount of
coastal people).
Norges Vel can contribute with more specific examples related to the comments here given if this
is wished for.
Sincerely,
Anne Mugaas
Senior Advisor
The Royal Norwegian Society for Development
25. Mohammad Nuruzzaman, Bangladesh
Dear HLPE,
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 29
Please see below some of my comments based on Bangladesh situation. I would be glad to add
more if it is worth.
(i) Women and food security: Over 11 % of total population engaged in fisheries and aquaculture
and out of them about 10% are women in Bangladesh (DOF, 2013). Involvement of women is not
always recognized and recorded well in Bangladesh.
(ii) In sectorial tradeoffs and food security: In Bangladesh, there are antagonistic relations
between fisheries and non-fisheries sectors. For example, there was a court case lodged by an
environmental NGO named BELA (Bangladesh Environmental Lawyers Association) against
fisheries (DG, Secretary, Minister) for destroying forest, environment and livelihoods across
coastal region by shrimp farming (Rfe:?) . In that case fisheries people fought in favor of
thousands of coastal inhabitants farming fish and shrimp. In saline coastal region, none can do
other farming except shrimp and fish due to salinity. Instead of real trade-off for food security,
the Dept of Agriculture, Department of Forest, Department of Environment and Wader
Development Board stood against fisheries farmers. The impact was farms were remain barren
following lack of saline water access by Water Board, planted rice did not grow well because both
land and water are saline, and thousands of shrimp farmers were accused and sued (Ref:?) for
setting sluice gates in their shrimp farms.
(iii) Environmental sustainability of fisheries and aquaculture: In many areas , fisheries and
aquaculture are not getting due attention for development in the fear of Environmental
sustainability. Farmers are being dictated to do something or stop something – which is not good
for food security. Propaganda by some quarters having vested interest, food security has been
threatened.
(iv) Fisheries and aquaculture interaction: Apart from use of fish meal, shrimp PL collection from
wild sources, harvesting fry and juvenile (Hilsha) has important interactions affecting food
security. Other interactions deserve attention are use of destructive gear (set-bag nets, fine
meshed nets, poison fishing) and crafts including over fishing and/or over using fish and shrimp
trawlers for marine capture. Such interactions have both short and long term food security
implications for the resource users.
With best regards,
Md. Nuruzzaman
26. Janine Pierce, Centre for Regional Engagement , Australia
Section 3.3.
(p.18) Pierce and O’Connor (2014 forthcoming) assessed impact on poor communes in North
Vietnam of oyster farming implementation under an ACIAR project. Findings showed the dual
nature of ‘fish for food and fish for cash’
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 30
(p.24) North Vietnamese oyster farmers also often have diversified land-based and water based
farming cash crops which spreads the risk and seasonal factors (Pierce and O’Connor (2014
forthcoming).
p.25) In North Vietnam oyster farming has had the wider impact on the community of improved
sanitation and better life quality options across the range of community capitals (natural, human,
social, human, social and produced (Pierce and O’Connor 2014 forthcoming). This positive impact
from oyster farming was also reflected in South Australian oyster farming communities,
particularly with focus on maintaining water quality (Pierce and Robinson 2012).
Section 3.5.
(p. 34) Re:Women in food insecure households fishing for household consumption: this could be
broadened as in Vietnam oyster farming (Pierce and O’Connor 2014 forthcoming) to show there
are women who both fish for household consumption as well as to provide a cash crop (e.g.
women only oyster farms some of whom are sole income families). Women in North Vietnam also
having women only oyster farms.
p. 36: Re fishing as a secondary source of income in Australia (Pierce and Robinson 2013)
highlighted in the Australian context extra work in oyster farming supplemented other seasonal
farming work or added to the income base. In the Vietnam study (Pierce and O’Connor, 2014
forthcoming) noted a similar trend with diversified water farming and land based farming income
crops. This has value both for the oyster farm owners and their workers to ensure continuous
income and food supply.
Section 3.6.
(p.39) The tendency of supply and demand and who benefits. Price determination moving more
into the control of the buyers rather than the fish farmers as more aquaculture farmers move
into the market was shown to be reflected both in the developed world context in Australia
(Pierce and Robinson 2013) and in the developing country context (Vietnam) Pierce and O’Connor
(2014 forthcoming). Food security therefore also needs to be considered in relation to security for
fish suppliers to ensure a fair income.
Section 4.2.
(p.63) Gendered fish sector work was found to occur (Pierce 2012) in oyster farming in Australia
with women more as partners and co-managers. However as women moved more from the more
remote land farms to operate in town based oyster farms, their visibility and therefore
opportunities to become more involved in community leadership roles increased. However their
aquaculture roles were more focussed on being the visible face for sales and marketing, lighter
work, and oyster processing, but all roles can be engaged in. Oyster farm management was
predominantly male driven in Vietnam with women in mainly oyster farming and processing work,
and sales. However some women in Vietnam are moving into owning and managing their own
oyster farms (Pierce and O’Connor 2014 forthcoming). Oyster associations in the Australian
context are predominantly male in membership and appear to be similar in composition in the
Vietnamese context also (no figures provided).
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 31
(p.68) Unlike findings of Allison et al 2011), in South Australia on the Eyre Peninsula there is a best
practice school aquaculture program open to both male and female students who receive school
education whilst receiving training on a real oyster lease to set them up for sustainable skills to
operate an oyster business in their community (Pierce and Robinson 2013; Pierce and McKay
2008).
Recommendation from Pierce: Sustainable fisheries and aquaculture need to look at impact
across more than just the income and environment. Findings (Pierce and Robinson 2013) and
Pierce and O’Connor (2014 forthcoming) in the Australian and Vietnamese context of a
developed and developing country highlight the interdependence of the environment, economic,
institutional, social and produced capital factors to achieve sustainable aquaculture for the people
and their communities.
A study done by Pierce in conjunction with ACIAR on their project in North Vietnam captured this
holistic approach to food security in the oyster farming context:food security is the key to life and
community security
http://aciar.gov.au/files/node/14983/incoming_earnings_pdf_64140.pdf
REFERENCES
Pierce, J and O’Connor, W. 2014 (forthcoming) ‘Impact of Oyster Farming on Rural Community
Sustainability in North Vietnam’, in S.Sandhu, S. McKenzie and H. Harris (eds), Linking Local and
Global Sustainability, Dordrecht NL: Springer.
Pierce, J and Robinson,G. 2012, "Oysters Thrive in the Right Environment: The Social Sustainability
of Oyster Farming in the Eyre Peninsula, South Australia", Marine Policy Journal.
Pierce J and J McKay 2008, “ Our community capitals as we see them through photovoice: Cowell
oyster industry in South Australia”, Australian Journal of Environmental Management, vol 15, p
159-168
27. Fabrizio De Pascale, UILAPESCA (fishworkers union), Italy
According to FAO statistics the number of fishworkers worldwide was 27,1 million in 1990 and
had increased to 38,3 million in 2010. There are no official statistics available to indicate how
many of these are owners or co-owners, independent fishermen working for themselves or
salaried fishworkers. There are also very few studies regarding the fishworkers’ legal status under
international law or under national laws and regulations (1).
While there have been numerous studies on fishery resources, as well as studies concerning
national and international legal frameworks for the management of the resources, there has been
an almost complete lack of effort to understand the third dimension of the management of
fishery resources: that is to say, the social dimension of fisheries has never been adequately
considered by the international organizations dealing with fisheries. Thus the international
measures adopted to protect and manage fishery resources have not been properly understood
or agreed on by the fishermen themselves.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 32
The conservation and proper management of resources is extremely important if the already
damaged and depleted fish stocks in many areas of the world are to be restored for the benefit of
future generations. To achieve this objective it is unthinkable not to involve fishermen and
fishworkers representative organisations in this process. Such an involvement is particularly
important in relation to IUU fishing which presents the most serious threat to the development of
sustainable fisheries.
It is in this context that the social dimension of the management of fishery resources becomes the
most important component of any management policies and decisions. The right to decent work,
as defined in ILO’s Convention, 2007 (C188) as well as by COFI and the UN, presents an important
and long overdue step in improving the social condition of fishworkers. The entry into force of
the ILO Convention (C188) will also contribute, to some extent, to the eradication of IUU fishing
since the majority of fishworkers will not endanger the benefits of decent work by engaging in
IUU fishing, which is a criminal act (2).
(1) PescaMed, 2011: PescaMed project Development of cooperation in the Mediterranean
Fishery sector: World of labour, Producers’ organizations, consumers’ associations and training –
Country
reports.
Imago
Pubblicitasrl
–
Tricase,
Lecce,
Italy;
443
pp.
http://www.uilapesca.eu/public/eventi/20121201/imm/pdf/55%20UILAPESCAMED%202011%20Rapporto.pdf
(2) Uilapesca for Mipaaf, 2012: IUU Fishing and its Relation to the Rights of Fishworkers in
International
Law,
by
Seyed
Hossein
MARASHI
&
Fabrizio
DE
PASCALE
http://www.uilapesca.eu/public/eventi/20121201/imm/home.aspx
28. Ministry of Food, Agriculture and Livestock, Turkey
Dear Madame/Sir,
We would like to thank HLPE for this study that comprehensively focus on different aspects of
fisheries and aquaculture. By this means, outcomes of the report will bring forward the link
between the role of fisheries, aquacualture and food security.
Please find below the opinions of the Ministry of Food, Agriculture and Livestock of Republic of
Turkey on HLPE V0 Draft.
Sincerely Yours
COMMENTS ON THE V0 DRAFT OF THE HLPE REPORT ON THE "ROLE OF SUSTAINABLE FISHERIES
AND AQUACULTURE FOR FOOD SECURITY AND NUTRITION":
1. Although it is recognized that fisheries and aquaculture share common issues, owing to
structure of activities , resources used and in many other aspects, fisheries and aquaculture
should be analyzed separetely.
2. It may be useful to put a new subtitle ‘’Fish Consumption and Food Security’’.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 33


The reasons of low and high fish consumptions,
A detail and disaggregated analysis by different factors such as consumption culture, level
of income, types of fish, types of fishery products and etc.
3. It may be useful to put a new subtitle ‘‘ Issues threatening the contrubution of fisheries and
aquaculture to food security’’





Overexploitation (using of fish meal to feed farmed fish is actually contributing to the
overfishing crisis)
Conflicts of interest (tourism and aquaculture, etc)
Invasive species
Pollution
Etc.
S. Burak GÜRESİNLİ
Assistant EU Expert
Ministry of Food Agriculture and Livestock
Directorate General of EU and Foreign Relations
Department of International Organizations
Eskişehir Yolu 9.Km Lodumlu/Ankara/TÜRKİYE
29. Eranga Galappaththi, Natural Resources Institute, University of Manitoba, Canada
[We could comment on aquaculture under the section of “Governance and food security”]
Shrimp aquaculture is often omitted in literature when it comes to food and food security. This is
because; shrimp aquaculture in particular is oriented for export and not for local consumption.
Benefits go to large companies and not to local communities.
However, we have found small-scale shrimp aquaculture in northwestern Sri Lanka operated in a
different
way
(Thesis:
Galappaththi
2013)
http://mspace.lib.umanitoba.ca/handle/1993/22107?mode=full.
The case provides a unique governance model with implications for aquaculture and food security
in general. The shrimp farmers co-operate with each other by working collaboratively and
collectively to overcome common challenges (mainly shrimp diseases). The governance system
may be characterized as a mixed commons regime. It is a multi-layered community-based
institutional structure, which has been developed by shrimp farmers themselves in cooperation
with the government. The top institutional layer is represented by a joint body of government and
the sector association. Farming operations are owner-managed under community-level
institutions (Samithi=co-op), with government oversight and coordination. Each and every shrimp
farmer in the community has to be a member of this particular community association to operate
their shrimp farms. Community-level shrimp farming associations formulate and implement their
own rules to manage community-level resources.
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Proceedings / 34
This private-communal-state mixed commons management regime has evolved as a response to
shrimp diseases and their devastating impacts. White Spot Syndrome (WSS) is one of the most
critical shrimp diseases. In 1996, the WSS disease outbreak accounted for a huge loss of shrimp
harvest and had lasting negative impacts. As a result, many medium and small scale farmers quit
the industry and their livelihoods were badly affected. Later, shrimp farmers, industry, and the
government collectively managed to develop a mechanism that is capable of battling the spread
of shrimp diseases by way of controlling the medium through which the diseases spread -- water.
This mechanism is a remarkable achievement of the current governance regime and contributes
to securing the livelihood well-being of the community.
Most of the shrimp production is for the export market, but profits and benefits stay in the local
community and contribute towards local development and local needs. In 2012, a significant
portion (more than 35%) of annual shrimp harvest was sold at the local market. Prevailing market
prices offered by shrimp processing companies and local buyers (or middlemen), and size and
quality of shrimp determine how much of the shrimp is sold in local markets. Local households
and the restaurants tend to buy small shrimp to make curried shrimp to go with rice (staple food
of Sri Lanka). We have found that some shrimp farmers cater only to local markets because
quality standards for international markets are difficult to meet.
The study area, aquaculture shrimp contribute to food security because aquaculture owners are
mostly families and community households. Shrimp harvesting is done in a collective manner with
the participation of family members, relatives, and neighbours. Contribution of women is
apparent during shrimp harvesting operations, especially, towards the later stage of harvesting,
where women hand pick shrimp from muddy pond bottoms. As a means of gratitude, farmers
share small portions of harvest with neighbours and relatives. Another small portion is kept for
household consumption..
The Sri Lankan shrimp aquaculture governance model is based on strong traditions of collective
action and cooperatives, and may not be appropriate for other countries or regions. However, as
practiced in our study area, it appears to be a viable model for food security and sustainability.
Eranga Galappaththi* and Fikret Berkes**
Natural Resources Institute
University of Manitoba
Winnipeg, Manitoba
Canada R3T 2N2
30. Ghazanfar Azadi Iran fisheries organization, Iran (Islamic Republic of)
Dear HLPE Secretariat,
e-HLPE Consultation,
Role of Aquaculture for Food Security and Nutrition About
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 35
Due to reducing marine resources and decline some of the marine species in the world, the
aquaculture will be more important than fishery and would make the main role in food security.
In capture fishery should place emphasis on enhancing quality instead of increasing fishing effort.
Because some of the aquatics catches in developing countries by traditional methods are not of
good quality and endanger the health of consumers. Then the quality in marine fishery is more
important the quantity. In order to gain this matter we need more training and quality control.
Another important consideration in marine fisheries is of marine pollution which has bad effected
on catch quality and endangers public health. Nowadays the governments for various reasons,
including political and social reasons, have not this issue under consideration. In this way
sometimes the fish with low quality and unhealthy distributed in the markets and cause a variety
of diseases in the community. For this reason it is necessary to emphasize the issue of preventing
marine pollution, particularly oil pollution and some Issues such as the protection of marine
resources, the creation of artificial reefs, protecting nursery grounds, and prevent IUU fishing
should be emphasized in order to increasing marine supply and improving the quality of fish
caught.
With best regards,
Ghazanfar Azadi
31 Peter Edwards Thailand
An excellent first draft. Specific comments:
1. Within the key aspect of environmental sustainabilty there is no mention of the area that
aquaculture will operate in in future although this is mentioned for capture fisheries: in land or
inland and marine waters, in natural ecosystems or human-made agro-ecosystems. I addressed
this issue in a keynote recently presented at the Elsevier conference in Las Palmas, Gran Canaria
in November, which will be published early next year (abstract attached). Inland aquaculture is
likely to continue to be the major source of fish rather than mariculture through both
intensification and expansion of farmed area. Although there are limits to land and water, a
recent paper by Boyd and Brummett (2012) has indicated that 'renewable freshwater appears
adequate for considerable expansion of aquaculture, especially outside Asia'. A significant amount
of inland aquaculture production takes place in ponds converted from rice fields and this trend is
likely to continue as aquaculture is a more efficent use of land and water, especially than lowyielding rice fields. Isupport the call in the Recommendations for studies on the most efficient use
of land and water resources. Research is certainly required on the merits of conversion of the
realatively small area of rice fields, especially low-yielding ones, that would be needed to meet
the predicted 2050 demand for fish.
2. You cite me several times in Section 3.7 times, although the references are not listed, as well as
Little and Edwards (2003) that livestock manure 'supports the production of most cultured fish in
Asia'. This is not true anymore as there has been a major delinking of integrated livestock and
fish. The recent rapid increase in aquaculture production has been through intensification using
agro-industrial pelleted feed. Total production of pelleted feed increased more than 3 times from
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Proceedings / 36
7.6 million tonnes in 1995 to 27.1 million tonnes in 2007 and is expecyed to reach 70.9 million
metric tonnes by 2020 (Tacon et al.2012).
3. In Section 3, the poor eat tilapia as well as carps and catfish.
A plant-based diet may not lead to amino acid deficiency e.g. amino acid complementarity in Latin
America where the basic diet is not mainly grain but maize and beans.
32. Rizalito Lopez Southeast Asia Fish for Justice Network, Philippines
COMMENTS ON ZERO DRAFT ON THE ROLE OF SUSTAINABLE FISHERIES AND AQUACULTURE
IN FOOD SECURITY AND NUTRITION (RSFA-FSN)
RSFA-FSN can be contextualized in the poverty and vulnerability situation of fishing
communities in the coastal and marine fisheries, including inland fisheries. Issues of
governance in the access to and control of the distribution and valuation of fish products
must also be articulated as those are the case why fishing communities remain marginalized
in many developing countries.
Related issues confronting fishworkers and aquaculture farm workers such as lack of social
protection, unfair labor conditions, and contractualization must also be added in the context.
In Indonesia 32% of the 16.42 million Indonesians living in coastal areas fall below the poverty
line. In the Philippines, 41% of 27 percent poor of the national population comes from fishing
households. It would not be hard to believe that similar statistics exist in fishing communities
of less developed countries in Southeast Asia.
In this view, the pursuit for sustainable fisheries and aquaculture contribution to FSN will be
directly focused to the higher pursuit of poverty alleviation and empowerment of poor and
marginalized fishing communities. In this way, we would answer the question : Food security
for whom?
Page 19-25
Fish products generated from capture fishing and aquaculture are primarily intended for food
consumption or for cash. Lower value fish by-catch and losses from postharvest activities are
the ones used for feeds for aquaculture or other animal feeds. This only means that there is
a secondary process involved in the production of feeds. In the diagram on page 19, it
appears (because of parallel positioning) that feed production is also a primary purpose of
capture fishing and aquaculture and not as a result of by-catch from non-selective fishing and
post-harvest losses.
But, if the diagram is correct, maybe the paper can cite the countries where capture fishing
and aquaculture primarily produce for the fishmeal or feed market.
Pages 39-40
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Proceedings / 37
…In the light of these analyses one could hypothesize that the lack of apparent 2 relationship
between the huge revenues that are generated by international trade and 3 the food security of
the local population reflects the structural failure of the fish export 4 sector and national
institutions to ensure an effective (re)distribution of the fish trade 5 revenues and a non-harmful
mode of operating…- V.0 RSFA-FSN
Just to cite a similar case, the tuna industry in General Santos City, the Philippines has a
huge revenue in terms of export earnings. Revenues from the industry comprise 60% of the
economic production of the city. Revenues are reinvested to other economic activities that
create jobs and employment. Despite these achievement, huge revenues has not addressed
the following issues that make dependent sectors food insecure:

unfair sharing systems in small scale hand-line fishing boats

Lacking social protection for fishworkers in all economic scales of tuna fishing most
especially the women workers

Labor code not applicable in the Philippines since the fishworkers are not covered in
the law
Contractualisation of jobs in tuna canning factories, which unfairly treat women fish
processors
Poverty incidence in the coastal areas in General Santos City and adjacent Sarangani
Province remained high


Catch composition of tuna, as a highly traded fish product, are already mostly juveniles (more
than 60%) and showing decreasing trend of catch volumes.
Recommendations:







Social protection for both artisanal and fish workers including women workers have to be
proposed -- minimum wage, social security;
Full valuation of the effort to produce tuna
Fast track ratification of ILO and IMO convention
Stop unfair treatment of fish workers most especially the women workers
Conservation/Management concerns due to overfishing of tuna; proposed
comprehensive alternative livelihood to the small tuna players if fishing effort/capacity is
to be reduced
Compliance with sea worthiness, safety at sea and working condition
Regulated fish trade for fisheries with evident overfishing and depletion of fish
stocks.
Pages 52 -55
On small scale aquaculture
Aquaculture in Southeast Asia started with the more endemic species like gurami
and carp in small areas which is intended for the food consumption of households
and communities. Then aquaculture was modernized, got larger, and expanded with
the orientation of serving the demands of the international markets, with developing
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 38
countries supplying the more developed countries. Modernized aquaculture system
has largely benefited from this markets, while small scale aquaculture was delinked
from this development.

Aquaculture small holders, depending on the particular aquaculture commodities, have
proven to be beneficial and has not realized its full potential to contribute to FSN
and poverty alleviation in fishing communities. In the Philippines and Indonesia, small
scale seaweed culture has very important contribution in terms of increasing income
of hundreds of thousands of fishing households. In the Philippines alone there is
about 250,000 households from benefiting from seaweeds culture. In Vietnam and
Indonesia small scale shrimp aquaculture(less than 5 hectares) constitute a large
share of income sources of farming households (MCD 2012; KIARA 2012). The small
scale sector provides the bulk of the raw fish materials processed in seafood
factories in Vietnam. However, the sector is faced with high risk, low profit and
environmental pollution.
As a solution, governmentsshouldsupportcapacity ofaquaculture small holders
ofspecificcommoditiestobeabletocomplywithstandards of goodaquaculture
practicestoderivemore benefits.Existing internationalstandardscanbeuseda models and
references, but regulationmustbe developedat the local levelto givedue consideration oflocal
situation.
Page 77-81
On the recommendations related to Global Policy:




This paper on the RSFA-FSN should make a recommendation in relation to WTO’s
treatment on trade policy relating to fish products. Because WTO has continuously
regarded and categorized fish products along automobiles, mobile phones, cars, and
other industrial products, under the Non-Agriculture Market Agreement (NAMA),
without recognizing fisheries biological limits. Furthermore, the issue of fishery
subsidy is being discussed in WTO separately
With this kind of treatment on fish products and fisheries, WTO has, wittingly or
unwittingly, caused overcapacity and overfishing of many fisheries around the globe.
To serve FSN , there must be regulated fish trade regime specially to fishing areas
and fish species where there is already evidence of depletion and overfishing.
End WTO, it only resulted in further marginalization and exclusion of artisanal fishers in
economic development.
Recommendation in relation to Women in fisheries:


This paper should recognize the role and rights of women as shell gleaners in
mangrove areas, seagrass beds, tidal flats, and wetlands. Shell harvesting by women
and children serve also as important source of marine food for nutrition and
sometimes supplemental cash for fishing households. Management efforts must be
supported to ensure that the resources used by women are equally given attention with
women playing key role and participation.
Further study may be required to determine the extent and reach of its practice in
fishing countries and regions.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 39
Additional Comments


The paper can add a section on the relevance of certification. It can articulate if
certification of fish products, either caught in the wild or produced from
aquaculture, has improved working conditions of fishworkers and aquaculture farm
workers as a means to FSN. Perhaps, also include a section if the benefits from fish
product certification has trickle down to aquaculture small holders.
Product Certification and Government Regulation must be installed and encourage local
communities initiatives on regulation
33. Farisal U. Bagsit (Researcher) and Caridad N. Jimenez (Faculty),Institute of
Fisheries Policy and Development Studies, Philippines
Respective contribution of fisheries and aquaculture to food security and nutrition
For the Philippines, aquaculture production of fish, crustaceans, and mollusks in 2009 produced
0.737 million metric tons and ranked 11th in the world, contributing about 55.68 million metric
tons to the total global aquaculture production. In terms of value, aquaculture contributed PhP
82.86 billion or 37.5% to the country’s economy as compared to the PhP 60.46 billion (27.3%) of
commercial fisheries (BFAR* 2010 fisheries profile). The per capita food consumption of fish and
other fishery products is 11.7% of the total food intake of Filipinos, next to rice.
Women and food security
Filipino women are involved in pre and post fisheries production activities. For example, when a
husband fisherman goes out to sea, the wife wakes up early to prepare the food. Likewise, when
the husband returns from sea after fishing, part of the catch is locally sold by the woman in the
community. The woman also makes sure that the family will get its share from the catch, ensuring
the food security of the household.
In some coastal communities, women engage in fry collection, harvesting of sea urchins and sea
cucumbers, etc. but these are hardly recognized as fishing activities. They also help in net making
and mending activities.
However, many of the important contributions of women in food security and the fisheries sector,
in general, are hardly recognized because of the stereotyping of roles in a household wherein it is
the responsibility of the woman of the household to take care and nurture the family. Thus, it is
deemed as an inherent attribute of her being the mother.
Further, the lack of gender-differentiated data has contributed to the invisibility of women. Even
the Philippine Fisheries Profile does not reflect the number of women directly involved in
fisheries; data are clustered by sector. It is only very recently that the role and contribution of
women in fisheries and resource management has been given some attention.
Environmental sustainability of fisheries and aquaculture and governance
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 40
Parallel issues on conservation and poverty pose challenges in the prioritization of activities,
particularly at the coastal communities wherein more than 80% of the country’s population
reside, often at living standards below poverty line. Conflict in resource use and among resource
users are key concerns. In spite of this, many local government units (LGUs) advocate communitybased resource management to include participation of the different stakeholders within the
community.
Fisheries and aquaculture interaction
Some of the fishmeal, specifically prawn feeds) used in aquaculture are imported from other
countries thus it does not pose that much of a problem to human food security but rather
increases operational cost to aquaculture. In 2010, prawn feeds accounted for 4% of the total
import value in fisheries.
The future of fisheries and aquaculture in the context of foods security
With the dwindling catch from the wild (capture fisheries), it is believed that aquaculture will still
be the major source of protein for the country. That is why researches on major fishery
commodities like milkfish and shrimps are currently being undertaken by different research
institutions throughout the country for sustainable culture practices with the intent of increasing
production without adversely affecting the environment.
Contributions by
Farisal U. Bagsit (Researcher),
Caridad N. Jimenez (Faculty),
Institute of Fisheries Policy and Development Studies
College of Fisheries and Ocean Sciences
University of the Philippines Visayas
5023 Miagao, Iloilo, Philippines
34. Jacqueline Demeranville, Decent Rural Employment Team, FAO
We appreciate the acknowledgement of the important issues of child and forced labour in the
draft document. For further information and recommendations on this issue, we invite you to
refer to the FAO-ILO Guidance on addressing child labour in fisheries and aquaculture
http://www.fao.org/docrep/018/i3318e/i3318e.pdf
We would also suggest that working conditions and youth employment be given greater attention
in the report.
35. Government of Switzerland
Dear CFS – HLPE Secretariat,
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Proceedings / 41
Switzerland would like to thank the HLPE for the comprehensive but focused zero draft on “The
role of Sustainable Fisheries and Aquaculture for Food Security and Nutrition (FSN)”. We have
noted two areas that could be further addressed in the next phase of the research and therefore
we suggest to :


Address more directly existing and future FSN-related impact of climate change for
sustainable fisheries and aquaculture
Highlight the importance of strengthening and enhancing the effectiveness of
organizations (incl. cooperatives), that represent (and are accountable to) small-scale
fishers and fish processors, in policy processes as well as in delivering economic services
to their members.
Best regards,
Christina Blank
Deputy Permanent Representative
Deputy Head of the Permanent Representation of Switzerland to FAO, IFAD and WFP
Via Aventina 32
00153 Rome
Italy
36. Alvaro Luis Céspedes Ramirez, IMG Consulting, Bolivia (Plurinational State of)
[English translation]
HIGHLIGHTING THE IMPORTANCE OF CONSIDERING THE ACTIVE PARTICIPATION OF ALL
STAKEHOLDERS INVOLVED IN FISHERIES AND AQUACULTURE
In line with the previous contribution, the VO draft of the document does not include a section
mentioning the social role of fisheries and aquaculture, or a section giving visibility to the social
and organizational structure of both sectors, from the individual action of the fisherman or fish
farmer to the action (if applicable) of some type of organization and its degree of development,
trying to measure as well their interaction with different public stakeholders at diverse levels and
other related stakeholders (international cooperation, research centers, training centers,
associations and guilds, etc).
Consequently we should forget the purely vertical structure of the value chain and visualize as
well the horizontal interconnections. In certain contexts it will be possible to find very efficient
alternative actions for nutrition and food security, not only inside, but also outside the value
chain.
So, could it be valuable considering also the human being (fisherman and/or fish farmer) and
giving him a greater role in the search for solutions? In addition to considering the resource or
product (fish), is it possible to understand that it is not available for own consumption? And that
around fisheries and aquaculture there are other elements that must be considered?
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 42
In this regard, it could be interesting assessing if the approach of the Integrated Productive
Complexes (known as CPI in Spanish) would suit this purpose.
The attached chart represents the CPI integrative approach.
[Original contribution in Spanish]
INCIDIR SOBRE LA IMPORTANCIA DE TOMAR EN CUENTA LA PARTICIPACIÓN ACTIVA DE LOS
ACTORES INVOLUCRADOS TANTO EN PESCA COMO EN ACUICULTURA.
En línea con el anterior comentario, en la V0 del documento no existe un acápite que haga
mención al rol sociol de la pesca y acuicultura, un apartado que visibilize la estructura socialorganizacional de estos dos sectores desde el accionar individual del pescador o acuicultor hasta
el accionar o (no) de algún tipo de organización y su grado de desarrollo, procurando además
medir su interacción con los diferentes actores públicos de diferentes niveles estatales y otros
actores relacionados (cooperación internacional, centros de investigación, centros de
capacitación, gremios y empresas, etc, etc).
En consecuencia debemos olvidarnos de la estructura netamente vertical de la cadena de valor y
visualizar tambien los encadenamientos horizontales; sera posible (en algunos contextos)
encontrar alternativas de acción muy eficientes (para la nutrición y para la seguridad alimentaria)
no solo al interior de la cadena si no afuera de ella.
Entonces; podría ser valioso también mirar al ser humano (pescador y/o acuicultor) y darle mayor
protagonismo en la busqueda de soluciones?; es posible ademas de mirar el recurso o producto
(pescado), entender que este no esta disponible para el consumo por cuenta propia? y que
entorno a la pesca y acuicultura existen otros elementos que debemos mirarlos?.
En esa línea podría ser interesante analizar si el enfoque de Complejos Productivos Integrales
(C.P.I.) podria adecuarse para este efecto.
En el gráfico adjunto se muestra la integralidad que representa el enfoque de CPI.
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/CPI.docx
37. Conchi Quintana, World Rural Forum. (IYFF-214), Spain
CONTRIBUTION IN THE FRAMEWORK OF THE INTERNATIONAL YEAR OF FAMILY FARMING, IYFF2014
Small Scale Fishing contributes in a high proportion to food security and creates great
employment opportunities for rural dwellers, in particular women and youth. At the same time,
small scale fishing faces plethora of challenges.
Next year, 2014, it is a great opportunity to boost this traditional fishing model in order to
overcome its many challenges. And for this, it is crucial to capture the diversity that exists in SSF,
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Proceedings / 43
to understand its potential for food security and livelihoods for millions and to appreciate its
contribution in promoting biodiversity.
To show part of this reality the World Rural Forum has compiled the contributions of CAOPA
(African Confederation of Small scale Fisheries Professionnal Organisations), ESAFF (Easter and
Southern Africa Small Scale Farmers Forum) Uganda; NAFSO (National Fisheries Solidarity
Movement) Sri Lanka.
Finally we make two final recommendations at global level. (please find attached the document)
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/Small%20Scale%20Fishing_dec%202013.pdf
38. John Kurien, India
Comments on the HLPE Report on The Role of Sustainable Fisheries and Aquaculture for Food
Security and Nutrition
John Kurien
Viewed in its totality this is a good and informative report which examines the role of fisheries
and aquaculture and its contribution to food security and nutrition from several perspectives. In
particular the special emphasis on the issues of gender and governance add considerable value to
the report.
My own understanding is that there are four conditions which must be in place for sustainable
food security to materialise. They are (1) the physical availability of the food in question (2) the
physical and more importantly the economic accessibility to the food (3) the proper external
environmental circumstances for absorption of the food and (4) the right and proper awareness
about the qualities and merits of the food. To me, these are the 4 A’s to food security. I think they
go beyond the FAO criteria.
I think the issue of awareness about the role of fish in FS&N is not adequately emphasised in food
security and nutrition discussions. You can have a situation where all the other three A’s are
present. However, without awareness about the beneficial nature of fish as a source of good
protein and micro-nutrients it may not be consumed. In developing countries, an important
condition to ensure this awareness is female literacy.
In the HLPE report this issue of awareness is not mentioned. I think it should find a place in the
report and measures which need to be taken to enhance the awareness of the role of fish in FS&N
should be stated.
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39. Sea Fish Industry Authority, United Kingdom
We have limited our response to Section 3.4, Resource and environmental sustainability:
necessary but not-sufficient conditions for food security
These comments relate to page 28.
The statement in line 7 appears to downplay the importance of seafood in the global diet by
indicating that it is 1% of the total calorie intake of humans. Yet "Globally, fish provides about 3.0
billion people with almost 20 percent of their average per capita intake of animal protein, and 4.3
billion people with about 15 percent of such protein" (as stated on page 2 line 32). Animal protein
is important because it is the source of the essential amino acid lysine, which plant protein cannot
supply, and in addition seafood provides several micronutrients not available from other sources
(as stated in the report on pages 15–18). Therefore seafood must continue to be available to
satisfy these nutritional needs.
These comments relate to page 31.
The description of the impacts of aquaculture on the environment is not balanced. It infers that
aquaculture operations of themselves have converted large parts of the coastal zone from other
productive activity to a damaged state by destructive means. This may be indeed the case in some
locations and regions. However, the studies underpinning this statement are relatively old: two
from 1996 and 1999, which of necessity are retrospective, and the EJF study (2002), which draws
upon older and less reliable data and refers only to areas of Vietnam. The assertion that
environmental damage caused by aquaculture is mostly historical is borne out by the statement
further down the page (line 32) that "the era of severe environmental problems is behind and …
aquaculture is on the road to sustainability (Costa-Pierce et al. 2012)”. In common with several
human endeavours, aquaculture continues to have the potential of causing environmental
damage. However, with the benefit of experience and with more focus on sustainability, these
consequences can be reduced significantly. In several cases aquaculture can confer environmental
benefits e.g. shellfish farming can reduce the damaging effects of eutrophication (Rice, 1999).
The question is: can aquaculture proceed sustainably, so that any damage is reversible? Another
question may be: how does aquaculture fare in comparison to other forms of production of
animal protein?
When taking a global view of the need to alleviate hunger it may be worth looking at the potential
impact of restrictions and pressures being imposed on aquaculture growth in the developed part
of the globe and consider if such restrictions are displacing effort, production and consequential
‘damage’ to areas in less developed nations.
The seas around the UK and in the contiguous EU waters are under increasing pressure to provide
services to a wide range of other coastal users. See here for examples of cables and oil and gas
pipelines
in
waters
around
the
UK
http://www.seafish.org/media/1127829/cables_oilgas_owf_a0_bbord_ofc.pdf
and the Irish Sea http://www.seafish.org/media/1127826/activity_chart_i_sea_ofce_lr.pdf. The
FishSAFE (Oil & Gas pipelines in UK waters, www.fishsafe.eu ) and KIS-ORCA (Cables and
Renewables in UK and surrounding waters, www.kis-orca.eu ) mapping systems have accounted
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Proceedings / 45
for >16,000 miles of pipeline, >350 safety zones, >1,000 subsea structures, >1,200 wind turbines,
>600 miles of wind farm export cabling and >27,000 miles of subsea telecoms and power cables
(M. Frow, Seafish, personal communication).
In the UK the aquaculture sector experiences significant difficulties in gaining space and
permission to maintain operations, to expand or move offshore. Seafish and partners have
investigated the potential to coexist with other users, and found, for example, that shellfish
production can coexist with offshore wind farms ( Syvret et al., 2013). It may be advantageous for
this report to indicate the attributes and benefits of such agreements where they are suitable.
Also the species that are suitable for northern hemisphere culture operations are not necessarily
suitable for southern hemisphere production. Therefore if production of a traditional species is
stifled and unable to meet regional demand could it be said that the market for seafood is trying
to fulfil demand by encouraging consumption of a species easily cultivated in another part of the
world. If this appears to be the case, any study and report into the role of aquaculture in meeting
the needs of the global population may consider displacement of effort and the consequential
reduction of production regionally.
In line 34 it is stated, appropriately, that "as in fisheries, the debate on the sustainability of
aquaculture has only occasionally been framed in relation to food (or nutritional) security." More
work certainly needs to be carried out to evaluate the aquaculture "footprint" in relation to the
environmental cost of other methods of protein production. One rare study (Pelletier et al., 2011)
indicates that some forms of fishing and aquaculture are remarkably low in terms of "cradle-toproducer life cycle energy use" when compared to livestock production. Maintenance of
biodiversity in areas of fish production is much higher than in areas of livestock or agricultural
production (Hilborn, 2012).
Finally, on line 12, it is stated that "aquaculture is still a relatively new industry". Whereas the
intensification of aquaculture of some species is relatively new, aquaculture has been practised in
various parts of the world for millennia (Rabanal 1988; Stichtenoth, 2006)
http://www.monash.edu.au/pubs/monmag/issue17-2006/research/research-eels.html.,
References
Hilborn, R., 2012. Sustainability and environmental impacts of food from the sea. Presentation
given at the World Fisheries Congress, Edinburgh 7–11 May 2012. Available from
http://rayhblog.files.wordpress.com/2012/10/hilborn-world-fisheries-congress.pdf
Pelletier, N., Audsley, E., Brodt, S., Garnett, T., Henriksson, P., Kendall, A., Kramer, K. J., Murphy,
D., Nemecek, T., & Troell, M. (2011). Energy intensity of agriculture and food systems. Annual
Review of Environment and Resources, 36 (1), 223-246.
Rabanal, H.R., 1988. History of Aquaculture. ASEAN/SF/88/Tech. 7. ASEAN/UNDP/FAO Regional
Small-Scale Coastal Fisheries Development Project, Manila.
Rice, M.A., 1999. Control of eutrophication by bivalves: Filtration of particulates and removal of
nitrogen through harvest of rapidly growing stocks. Journal of Shellfish Research 18(1):275.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 46
Stichtenosh, K., 2006. Once were eel farmers. Monash Magazine, Autumn/Winter 2006. Available
from http://www.monash.edu.au/pubs/monmag/issue17-2006/research/research-eels.html
Syvret, M., FitzGerald, A., Wilson, J., Ashley, M., Ellis Jones, C., 2013. Aquaculture in Welsh
offshore wind farms: a feasibility study into potential cultivation in offshore wind farm sites.
Report for the Shellfish Association of Great Britain, 250p. Available from
http://www.shellfish.org.uk/readmore.php?newsid=51
40. Ambekar Eknath, Network of Aquaculture Centers in Asia-Pacific (NACA),
Thailand
NACA, an intergovernmental organization of 18 member states, devoted to sustainable
development of aquaculture in the Asia Pacific region, would like to place on record its
appreciation to the HLPE for developing an objective and focused document. The expert
committee has endeavoured to cover almost all critical areas of direct concern and relevance to
the NACA member states. NACA organization is therefore pleased to strongly endorse the report.
The well-articulated sections on Gender and Governance add considerable value to the report.
Some points the HLPE may wish to consider in finalizing the draft:







On Supply side HLPE should consider highlighting the importance of utilizing public water
bodies (village tanks and lakes), irrigation water holding systems, inland reservoirs, for
increasing fish production through Culture Based Fisheries (CBF) and community
management systems. The role of women self-help groups in enhancing the availability of
affordable fish at community level.
The HLPE should consider a special section on scenario mapping of “Demand for fish” and
most likely sources of supply of fish (and consequent deficits, if any) – globally and
regionally (under various realistic context and circumstances).
In the introduction section, it is better to remove the “critique” on bio-fortification. This
will probably dilute the main message of HLPE and will most certainly lead to unnecessary
and unproductive debate between bio-fortification vis-à-vis direct nutrition
supplementation (by fish and vegetables). Similarly, again for the same reasons, the HLPE
may consider down playing the thesis advocated by “doomsday prophets” in the section
on “Fisheries Crisis”. Instead, the HLPE may consider including early on the significant
positive messages which comes so late in the report in the “reflections section”.
The report recognizes the gradual shift in focus from small scale subsistence aquaculture
to SMEs and its role in food security and nutrition. Enabling mechanisms for this shift
may be highlighted, including mechanisms to responsibly address the challenges of trade
requirements (and other challenges already articulated in the report)
The HLPE should consider a section on “immediate productive interventions” needed to
mainstream fish in national and international FSN programs; most productive (high
impact) investment opportunities for donor agencies and national policy makers.
As already pointed out by others, there is a need to highlight strengthening and
enhancing the effectiveness of organizations (such as NACA) that are devoted to the
cause of small-scale fish farmers including women entrepreneurs.
The looming threat of climate change on fisheries and aquaculture including adaptation
and mitigation measures needs to be highlighted.
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Ambekar E. Eknath
Director General
Network of Aquaculture Centers in Asia-Pacific (NACA)
Suraswadi Building; Kasetsart University Campus,
Bangkok, Thailand
41. Clara Whyte, Economist and Policy Analyst, Canada
It seems to me that the report is good and very interesting. It is great that it includes a whole
section on the particular links between sustainable fisheries and aquaculture, food security and
gender issues.
In the same vein, I think it would be worth adding a section on the links between sustainable
fisheries and aquaculture, food security, traditional knowledge and Aboriginal people. In fact, fish
has been a traditional food of many Aboriginal people (Inuits in Northern Canada, coastal
Aboriginal people in Chile or Canada, Aboriginal people from the Amazon basin in Southern
America etc.). Today, many issues are threatening the traditional diet of those people and hence
their cultural heritage and food security. Many initiatives are also being undertaken in order to
revert those threats, some of them being attempts to promote sustainable fisheries and
aquaculture.
I would have liked to make a more in-depth contribution on that subject but I unfortunately found
out a bit late about the present consultation. Should it be of some interest, I suppose I could
submit a short concept paper on that matter.
I hope this idea will be useful and I will be looking forward to reading the next version of the
report. Thank you.
42. Paul Denekamp, Stichting Vissenbescherming , Netherlands
Dear members of the HLPE-project team,
as board member of the Stichting Vissenbescherming (the Dutch Foundation for the Protection of
Fish) I like to give some comments on the zero-draft consultation paper you wrote: The Role of
Sustainable Fisheries and Aquaculture for Food Security and Nutrition.
For sure food security and nutrition is world wide a very important issue. But if you want to
improve this with more animal products you also have to look at animal welfare. And if you want
to improve food security and nutrition with more products from the fisheries and aquaculture you
have to give attention to the affects of the fisheries and the aquaculture on the welfare of the fish
that is caught or kept. In the addendum you find the pamphlet They experience stress, fear and
pain I wrote about these welfare effects. The capture fisheries are with their present catch and
killing methods and the more than a trillion fish that are each year the victims, the most cruel
human activity to animals on this moment. In the aquaculture most kept fish also suffer a lot
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because of the used killing methods. Most fish farms must be considered as factory farming
because of the infringement of the welfare of the kept fish.
In the paper you wrote there is no attention for fish welfare and that must be changed. No
development can be named sustainable if it neglects animal welfare and that's not different for
the fisheries and aquaculture. As soon as possible new catch and killing methods that harm fish a
lot less must be developed for the capture fisheries. And in the aquaculture fish should also be
killed in a way that they don't suffer. And the way fish is kept must be improved enormously, so
these fish can develop their natural behaviours. I hope you agree with this and will mention in
your final consultation paper the necessity of attention for the welfare of fish and of these
changes in fishing methods and in the way fish is kept.
With the consultation paper as you have written it now, you contribute to the enormous suffering
of fish caused by the fisheries and the aquaculture. You cannot do that.
I hope I made our vision clear. But if you have questions about this, please let us know.
With best regards,
Paul Denekamp
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/they%20can%20experience%20stress%20%20EN%20new.doc
43. Marc Oswald, ISTOM, France
[English translation]
1. In General
1.1 Excellent summary:
The report is well documented and very interesting. It gives the fish its proper status, whether it is
fished or farmed. Well done!
It sets out to be a scientific summary of the sector, which is commendable, but actually focusses
the report on the principal known and on already described facts.
1.2 Fish distribution:
It is important to note that in certain enclosed rural areas where fish farming is little practiced
(frequently the case in areas with a plantation economy in Western and Central Africa), fish is
distributed at higher prices than the price obtained in town. For the rural population the stress
linked to the difficulty of getting fish (and also often its poor quality) is thus particularly acute and
the more so when these are areas where very many forms of malnutrition and deficiencies are
observed.
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2. Special comments regarding small-scale aquaculture (taken from African examples).
2.1 Use of water:
Small-scale aquaculture can, when it is well designed, be a tool for improving irrigation systems.
Competition is presented in terms of spatial competition, and above all competition between
fishing and aquaculture, never in terms of synergy.
Sometimes fish farming contributes (contrary situations have also been described) to
improvements of the distribution and storage of water for agricultural purposes. In terms of rural
development to improve food security, an assessment of global water usage with its fish farming
potential should be a more frequently promoted objective.
2.2 Genetic selection
Genetic selection when ill-conceived in terms of governance can be a means of restoring the
commercial bondage of the poor population which as a backlash will endure worse adversities
than if the states or the development institutions involved had not sought the improvement of
farmed stocks (Madagascar, Benz et Oswald, 2010). Therefore, there are costs and benefits to
genetic selection and not all the advantages are necessarily redistributed among the poor
populations. In certain cases, these attempts end up in failure. In particular if fish need to be
transported and if the purchases are made away from the rural community.
Thus, there is a cost to genetic selection which sometimes puts the small fish- farmers at a
disadvantage. Alternative solutions, like a networking organization of exchanging spawning adults
to maintain good genetic variability, which tend to give freedom to those involved, letting them
escape from the potential heavy handedness of certifying organisms and the associated controls,
are not sufficiently promoted even though they are locally more efficient than a genetic selection.
(Oswald et al 2013)
2.3 Realities of small-scale fishing development are present in Africa
The work of APDRA [Association Pisciculture et Development Rural en Afrique - African Fishing
and Rural Development Association] (www.apdra.org) supported particularly by AFD [Agence
Francaise de Développment - French Development Agency] and the EU [European Union] have
shown that the local experiences, in particular in Guinea and Ivory Coast have had successes with
lasting impacts on rural communities (Oswald 2013, Simon et Benhamou, 2009).
In Africa, it is not possible to simply contrast all forms of promoting small-scale aquaculture with
the promotion of small or medium scale fish-farming where the setbacks are also many and not
always well documented. One is obliged to record the lack of consensus on the fish farming
development strategies: for example some approaches advocate subsidies for building fishponds,
which as a result often increases the cost of overall investment, and which does not lead towards
systems where the small producers have the means of controlling the results and managing them
by themselves and in this way ends up eventually having the opposite effect. It is the same for
intensive systems, where many of the interventions propose a system of key in hand but where at
the end the financial risk carried by the farmer is much greater than the risk he runs for his other
agricultural activities. Finally, it is important to remember the lack of consensus on the species
introduced, with many actions launched on unknown species with no future. To make a catch-all
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of all the different supports to rural fish farming does not seem pertinent because it would put
together very different worlds. By contrast, it is necessary to note that if aquaculture was playing
a role like that played in the countryside of Asia, the problem of malnutrition would present itself
somewhat differently throughout Africa. In this comparison, it is necessary to bear in mind the
relatively weak understanding of water in agricultural use throughout this continent and a very
different history of fish farming.
The actions proposed for development of integrated fish farming have too often escaped,
because of their specific nature, from a rigorous and coherent analysis of fishing practices. This
situation is about to change but could be further encouraged by this report; fish rearing
workshops that the farmers find efficient should be proposed.
[Original contribution in French]
Quelques impressions sur le rapport : « The Role of Sutainable Fisheries and Aquaculture for
Food Security and Nutrition ».
1.Généralité :
1.1Excellent travail de synthèse :
Le rapport est très bien documenté et très intéressant. Il remet à sa juste place le poisson qu’il
soit pêché ou élevé. Féliciations.
Il se veut une synthèse scientifique du secteur, ce qui est louable mais ceci centre le rapport sur
les principaux faits connus et déjà décrits.
1.2Distribution du poisson :
Il faut noter que dans certaines campagnes enclavées où la pratique de la pisciculture existe peu
(cas fréquent des zones d’économie de plantation d’Afrique de l’Ouest et Centrale), le poisson est
distribué à des prix supérieurs au prix où il arrive en ville. Le stress pour les populations rurales lié
au difficile accès au poisson (et en plus souvent de médiocre qualité) est donc particulièrement
fort d’autant plus que ce sont des zones où de très nombreuses formes de malnutrition et de
carences sont observées.
2.Remarques particulières à propos de la petites aquaculture (tirés des exemples africains).
2.1Utilisation de l’eau :
La petite aquaculture peut être un outil lorsqu’elle est bien conçue d’amélioration des systèmes
irrigués. La compétition est présentée en terme de compétition spatiale, et surtout compétition
pêche aquaculture, jamais en terme de synergie.
La pisciculture participer parfois (des situations contraires sont aussi décrites) à l’amélioration de
la distribution, du stockage de l’eau à des fins agricoles. En terme de développement rural pour
améliorer la sécurité alimentaire, évaluer l’utilisation de l’eau globale avec sa valorisation
piscicole devrait être un objectif plus souvent promu.
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2.2Sélection génétique
La sélection génétique lorsqu’elle est mal conçue en terme de gouvernance peut être un moyen
de restaurer des oligopoles sur les populations pauvres qui en contrecoup vont subir un préjudice
plus fort que si les états ou les organismes de développement concernés n’avaient pas recherché
l’amélioration des souches élevées (en à Madagascar, Benz et Oswald, 2010). Il y a donc un coût
et des bénéfices à la sélection génétique et tous les gains ne sont pas forcément redistribués au
niveau des populations pauvres. Dans certaines situations, ces tentatives se soldent plutôt par des
échecs. Particulièrement, s’il faut davantage transporter les poissons et si les achats sortent de la
communauté rurale.
Il y a donc un coût à la sélection génétique qui peut parfois desservir les petits aquaculteurs. Les
solutions alternatives, comme une organisation de réseaux d’échange de géniteurs pour
maintenir une bonne variabilité génétique qui sont susceptibles de laisser la liberté aux acteurs,
les soustrayant à cette potentielle main mise des organismes certificateurs et des contrôles
associés, ne sont pas assez promues alors qu’elle restent localement plus efficiente qu’une
sélection génétique. (Oswald et al 2013)
2.3Des réalités de développement d’aquaculure de développement à petites échelles existent en
Afrique
Les travaux de l’APDRA (www.apdra.org) appuyés notamment par l’AFD et l’UE, ont montré que
des expériences locales particulièrement en Guinée et en Côte d’Ivoire étaient tout à fait des
réussites avec des impacts durables sur les communautés rurales en termes de manifestes
(Oswald 2013, Simon et Benhamou, 2009).
En Afrique, on ne peut pas opposer simplement toutes les formes de promotion de la petite
aquaculture aux actions de promotion de la pisciculture à petite ou moyenne échelle où les
échecs sont aussi très nombreux et pas toujours bien documentés. Force est de constater le nonconsensus sur les stratégies de développement de la pisciculture : par exemple certaines
approches font l’apologie de subventions pour la construction d’étangs, ce qui a souvent comme
conséquence d’augmenter le prix de l’investissement global, de ne pas tendre vers des systèmes
ou les petits producteurs ont les moyens de contrôler les réalisations et de les entretenir par euxmêmes et aboutit ainsi à terme à l’effet inverse. Il en est de même pour les systèmes intensifs, où
beaucoup d’interventions proposent des systèmes clés en main mais ou au final le risque financier
porté par le paysan est bien supérieur à ce qu’il court sur ses autres activités agricoles. Enfin, il
convient aussi de rappeler le non-consensus sur les espèces introduites, avec une quantité élevée
d’actions qui se lancent sur des espèces non connues et qui sont sans lendemain. Faire un fourretout de tous les appuis à la pisciculture rurale ne paraît pas pertinent car associe des univers très
hétéroclites. A l’opposé, il faut constater que si l’aquaculture jouait un rôle équivalent à celui
qu’elle joue dans les campagnes asiatiques, le problème de la malnutrition se poserait de façon
différente à l'échelle de l'AFrique. Dans cette comparaison, il faut cependant garder à l’esprit la
relative faible maîtrise de l’eau autour des activités agricoles à l’échelle de ce continent et une
histoire de la pisciculture très différente.
Les proposition d’actions de développement de la pisciculture intégrée ont trop souvent échappé
du fait de leur spécificité à une analyse rigoureuse et cohérente des pratiques piscicoles. Cette
situation est entrain de changer mais pourrait être encouragée par ce rapport, il faut proposer des
ateliers d’élevage piscicole que les paysans trouvent efficients.
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BENTZ B. et OSWALD M. 2010 “Respective roles of national institutions and farmers groups in the
implementation of an innovation enabling smallholders to reproduce carp inside their rice fields in
Betafo (Madagascar)”. Colloque IDSA, 28 juin- 1erjuillet 2010 ; Montpellier, France.
http://hal.archives-ouvertes.fr/hal-00522795/fr/
Oswald M., 2013. La pisciculture extensive, une diversification complémentaire des économies de
plantation, pp 165-183 In Ruf F. et Schroth G. (Eds), Cultures pérennes tropicales enjeux
économiques et écologiques de la diversification. Quae update sciences and technologies,
Montpellier France. 301 pp.
Oswald M., T Ewoukem T.E. et Mikolasek O., (2013) Approach and conceptual framework of
smallholder fish farming intensification: example of dam pond fish polyculture based on all- male
tilapia culture (Oreochromis niloticus) in Cameroon. Présenté à Ista 10, Jerusalement, 6-10
octobre 2013, accepté pour publication.
Simon D. et Benhamou J.F., 2009. Rice-fish farming in Guinée Forestière – outcome of a rural
development project. Field Actions Sci. Rep., 2, 49-56 - www.field-actionssci-rep.net/2/49/2009/
44. Natasha Stacey, Australia
Dear Team
Thanks for the opportunity to comment on this excellent report.
Some minor comments and suggestions included below for your consideration.
Regards
Dr Natasha Stacey
RESEARCH INSTITUTE FOR THE ENVIRONMENT AND LIVELIHOODS
CHARLES DARWIN UNIVERSITY
Darwin, Northern Territory 0909 AUSTRALIA
Section 4.2 under Gender and Work in the Fish Sector


P 63. While women cannot register as fishers, the work of women in small -scale fisheries
is often not counted in national government census collections under fisheries related
employment. For example in Indonesia, the Indonesian Bureau of Statistics collects and
produces fisheries related data for each province on the number of fishers employed in
the fishery sector either on a full time, part time ‘major’ or part time ‘minor’ basis but this
generally refers to male fishers only (see Fitriana and Stacey 2012:160).
There is also a paucity of literature of studies on Aboriginal and Torres Strait Islander
women and participation fisheries from Northern A National Indigenous fishing survey
conducted in 2000 (Henry and Lyle 2003) did not present any gender disaggregated data.
Australia. (Also Noting that Australia and Indigenous women was not mentioned at all in
Harper et al 2013 paper on women’s participation in fisheries globally).
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Indigenous, and Semi-Nomadic fishers and FSN

The specific food security needs and nutritional contribution of Indigenous maritime
mobile or semi-nomadic peoples of Southeast Asia perhaps warrants a specific mention or
paragraph. Here I am referring to the three major ethno-linguistic groups of the Moken,
Orang-Laut and the Sama-Bajau (and approximately the 9 sub groupings) found in
Indonesia, The Philippines, Thailand, Malaysia and Burmese waters (Stacey 2007). These
groups have a specific dependence on fish for food, nutrition and income however
virtually no research has been conducted into the links between their extremely high
dependence on marine resources, nutrition, and their health.

Within this region, changes in the marine environment due to a range of drivers and
threats along with other socio-economic changes can impact on the traditional food
systems, nutrition and health of Indigenous people. This is particularly an issue for these
semi-nomadic populations, who rely heavily on marine foods for health and nutrition but
also for income.
Internationally the Policy around Maritime Indigenous Peoples and Food Security appears
weak but the work of Harriet Kuhnlein (eg Kuhnlein et al 2009) from McGill University
may deal with some of these issues in various publications in more detail.

The issue of marginalised (e.g semi-nomadic) groups, culture and MPAs and impacts on food
security was raised in Foale et al 2013. This paper also raised other issues around CTI Policy and
Plans and marine biodiversity, conservation and food security.



These issues could be raised at page 36 in the Report ( marginalised peoples and poor
health) - fish dependent communities may consume high amounts of fish but have poor
health due to some of the factors outlined at page 36-37 of the report as well as specific
issues around tenure and access to pursue mobile livelihoods (see Stacey and Allison
submitted, but also others have discussed this - Krueger 2009, Springer 2009)and related
issues from West African migratory fisheries (Cripps, Jorion and others)
In northern Australia, Aboriginal people in remote coastal communities rely on traditional
foods and marine resources to supplement their diets which are often based on refined
foods purchased from local community stores. Customary harvesting activities are
thought to critically contribute to local food security and provide important sources of
protein and micronutrients. The links between indigenous health and wellbeing and
access to ‘country' are increasingly recognised. Despite this, there have been few
detailed studies into the harvest practices and consumption of traditional foods of
Aboriginal peoples and the contribution to food security. Further, the contribution and
consumption of traditional foods is not generally included in health and nutritional
programs or studies of consumption patterns in remote Aboriginal communities
(Petheram et al 2013:8).
(There is also wide and varied body of research literature on the subsistence activities,
practices and economies among contemporary indigenous hunter-gatherer societies
across the world but in particular from North America, Asia and the Pacific. This includes
research on the contribution of subsistence harvests to health and nutrition (eg.Kuhnlein
1991, 2009, Berkes and Farkas 1979, Usher 1976) – but I have not included these
references here).
Some References cited
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Proceedings / 54
Fitriana, R and Stacey, N. 2012. The role of women in the fishery sector of Pantar Island,
Indonesia. Gender in Aquaculture and Fisheries: Moving the Agenda Forward Asian Fisheries
Science Special Issue Vol 25S (2012):159-175.
Foale, S., D. Adhuri, P. Aliño, E. Allison, N. Andrew, P. Cohen, L. Evans, Mi. Fabinyi, P Fidelman, C.
Gregory, N. Stacey, J. Tanzer, N. Weeratunge. 2013. Food security and the Coral Triangle
Initiative. Marine Policy 38: 174-183 http://dx.doi.org/10.1016/j.marpol.2012.05.033
Kuhnlein, HV, Erasmus, B & Spigelski, D 2009 Indigenous people’s food systems: themany
dimensions of culture, diversity and environment for nutrition and health. United Nations Food
and
Agriculture
Organization,
Rome.
Accessed
January
2013
http://www.fao.org/docrep/012/i0370e/i0370e00.htm
Krueger, L 2009, ‘Protected Areas and Human Displacement: Improving the Interface between
Policy and Practice’, Conservation Society [serial online], vol. 7, no. 21-5, viewed 2 May 2009,
<http://www.conservationandsociety.org/text.asp?2009/7/1/21/54793>.
Henry, GW & Lyle, JM 2003, National recreational and Indigenous fishing survey,
Australian Government Department of Agriculture, Fisheries and Forestry, Canberra
Petheram, L, Fleming, A, Stacey, N and Perry, A 2013 Indigenous women’s preferences for climate
change adaptation and aquaculture development to build capacity in the Northern Territory,
National Climate Change Adaptation Research Facility, Gold Coast, pp. 76.
http://www.nccarf.edu.au/sites/default/files/attached_files_publications/Fleming-2013Indigenous-women-aquaculture-WEB_0.pdf
Springer, J. 2009, ‘Addressing the social impacts of conservation: Lessons from experience and
future directions’, Opinion, Conservation and Society, vol. 7, no. 1, pp. 26-29.
Stacey, N. 2007. Boats to Burn: Bajo fishing activity in the Australian Fishing Zone. Asia-Pacific
Environment
Monograph
Series,
ANU
E
Press,
Canberra.
http://epress.anu.edu.au/boats_citation.html
Stacey, N and EH Allison (Submitted Oct 2013) Bajo Mobility, Livelihoods and Marine
Conservation in Indonesia. In King, T and G Robinson (eds) At Home on the Waves, Berghan Press
45. Richard Veeran, Suresh Chand, Ministry of Fisheries & Forests, Fiji
This is a well written and comprehensive report. The objectives appear to have been met with
thorough assessments of the gaps that exist today. However, allow us to make a few comments
and observations to help in the finalization process.
Though development of aquaculture in the region has been limited compared with other areas of
the world, it is of great importance to Pacific Islands Countries & Territories (PICTs) and has been
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identified and proven as a potential source of income to meet essential needs, and as a
supplement or alternative to revenues from coastal and freshwater fisheries. For Fiji in particular,
its impacts and contribution to Livelihood, Food Security and Economic Development has been
crucial although it has yet to achieve its full potential.
With Inshore fisheries and Offshore Fisheries, providing for a huge portion of exports and job
security in the Fisheries sector, pressure on stocks which have brought about significant catch
decline in the national waters as well as in the Pacific region can only be supported through
development of sustainable Aquaculture. Consequently, the Fiji government has invested close to
F$1.7million in a Multi-species hatchery for aquaculture in its western division. Initial stages will
focus on Freshwater species, culture of Brackishwater as well as Marine species.
In addition to stock pressure, Coastal Fisheries is projected to show progressive decline in
productivity due to both the direct effects (e.g. increased SST) and indirect effects (changes to fish
habitats) of climate change for Fiji. With almost 52% of the rural population's fisheries provided
by subsistence catch and 7% in urban areas (Bell et al. 2009) as their main protein source,
aquaculture will not only bridge the gap of protein requirement but also create sustainable
livelihoods and employment opportunities. Moreover, aquaculture is also one of the few fisheries
activities which have been confirmed by the International Food Policy Research Institute
[www.ifpri.org] to be undertaken for Climate Change Adaptation for food security and for the
improvements of livelihood for communities. It would be good to see these recommendations
emphatically reiterated for follow through.
As Bell states in his recent report (2011), despite the fact that there are negative impacts of
Aquaculture, responsible aquaculture holds promise to increase not only freshwater fish
production but with the potential to increase brackish and marine fish species. This would only
serve to bolster both food security and the livelihoods of peoples living in both rural and periurban areas.
In addition, given the far reaching global impacts of climate-change and the emergence of new
and or revised science around the issue, it may be prudent that the apparent and nuanced
impacts on our sector are comprehensively factored. Whilst the impacts of Climate Change is
mentioned, the authors of the Role of Sustainable Fisheries and Aquaculture for Food Security and
Nutrition report may need to take into consideration the findings in the IPCC AR5 to account as its
projections have direct as well as indirect impacts on the sector that we can ill afford to under
estimate nor down-play.
References:
· Bell JD, Johnson JE and Hobday AJ (eds) (2011). “Vulnerability of Tropical Pacific Fisheries and
Aquaculture to Climate Change.” Secretariat of the Pacific Community (SPC), Noumea, New
Caledonia.
· Cochrane, Kevern, Cassandra De Young, Doris Soto, and Tarûb Bahri. "Climate change
implications for fisheries and aquaculture." FAO Fisheries and aquaculture technical paper 530
(2009): 212.
Contributions by:
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Richard Veeran (Fisheries Assistant),
Suresh Chand (Director Fisheries),
Department of Fisheries
Ministry of Fisheries & Forests,
Level 3,Takayawa Bldgs,
Toorak, Suva,
Fiji Islands
46. UN Special Rapporteur on the right to food
On behalf of the UN Special Rapporteur on the right to food, Olivier De Schutter, I am enclosing
his report on 'Fisheries and the right to food', presented at the 67th Session of the United Nations
General Assembly [A/67/268].
In this report, the Rapporteur assesses the contribution of fisheries to the right to food, and
identifies the challenges facing global fisheries (unsustainability, rise of aquaculture, globalization
of the fishing industry). The report then examines how the individuals most vulnerable to negative
impacts (the residents of developing coastal and island countries, especially low-income fooddeficit countries) can be supported to ensure the progressive realization of the right to food,
noting that pursuing a human rights approach is critical to achieving sustainable development in
the fisheries sector.
The report ends with a series of recommendations which may be of interest for the HLPE report
on "The role of sustainable fisheries and aquaculture for food security and nutrition". Of particular
interest is a discussion on the role of trade agreements and an assessment of international efforts
to reduce overfishing.
We hope this will be of use to your important work.
Best regards,
Priscilla Claeys
47. Government of New Zealand
General comments:
• We appreciate the chance to input into the draft paper. It is an interesting paper on a topic
that has been attracting growing attention.
• While it is universally agreed that people need to have a secure and nutritious food supply,
views on the best way to ensure that are not always shared. For this reason, we anticipate
that there will be contradictory views on the recommendations in this paper. However we
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are confident that there is enough common ground for progressing towards better FSN
outcomes.
• New Zealand generally sees international trade as a means of providing for better FSN
outcomes (while also accepting that this isn’t true of every situation). New Zealand believes
improved and fairer distribution of fish trade benefits within a society, improved fisheries
management capability in countries facing FSN issues, and strengthening the value chain
particularly at the harvesting end will help to more consistently provide better FSN
outcomes from international trade.
• The risk of creating a separate set of rule for small scale fishers is that it will jeopardise
the long term sustainability of fisheries resources, and result in worse FSN outcomes.
• Note: FAO Fisheries Technical Paper number 456 titled ‘Responsible fish trade and food
security’ does not appear to have been referenced or referred to in this paper. Suggest that
the findings of this paper be considered.
Specific comments:
1. P27: Over-exploited resources. The paragraph which describes how many more people
could be fed were fisheries not over exploited is very important and needs to be reemphasised at critical points in the document. Suggest repeating the point that overexploited resources create an absolute loss of potential product for FSN purposes (lines
11-17 p27) in the discussion on balanced harvesting on p30.
2. P29-31: Fisheries crisis. Agree that there is uncertainty in state of oceans, but need to be
careful not to understate the current state of the world’s oceans too.
3. P30: Balanced harvesting. There may be ways to improve current fisheries management
principles/objectives to provide better use for low value fish for FSN. However, it is critical
that in developing FSN concepts there is no weakening of the existing sustainability
standards for fisheries. As per comment 1 above, it should be re-emphasised that
weakening current standards to provide for FSN would be a perverse outcome in terms of
food available for FSN purposes.
4. P39-44: Fish trade. Discussion concludes that evidence is contradictory and doesn’t favour
either narrative, but then examples are only included supporting the “anti fish trade”
narrative. Suggest including examples where there have been positive impacts on FSN from
international fish trade as a model for those endeavouring to use international trade as a
means of alleviating poverty. See FAO Fisheries Technical paper 456, referred to above.
5. P57-59 and Fig 3.9: Large scale vs small scale. The contribution that large scale fishing has
on food security needs to be included in the document too. The diagram depicting large
scale vs small scale shows a part of the picture, but not the whole picture. For example,
tax revenues for large scale fishing and the benefits to people flowing from those benefits
are not included.
6. P74: IUU definition. The appropriate solution to small scale fishers being included in the UU
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part of IUU is to develop the capability to regulate and establish reporting regimes, rather
than exclude small scale fishers from the definition.
7. P77: New CCRF instruments. A potentially useful way to promote these issues and their
discussion internationally.
8. P78: Fisheries resource assessments. There may be scope to expand on current fisheries
management objectives to help contribute to FSN outcomes – i.e. low value fish. However,
we need to be very cautious that this discussion is not misused to lower the current
standards for sustainability.
9. P78: Small scale fisheries. The benefits to FSN from large scale and small-scale fisheries need
to be assessed on a case by case basis. A universal rule suggesting small-scale fisheries
should always be preferred, would not always result in the best FSN outcomes.
10. P78: IUU definition. As per comment 6 above.
11. P80: International fish trade and FSN. Approach sounds sensible. As per comment 4
above, the paper should provide examples of where positive revenue and positive FSN
impacts have been possible, or suggest theoretical approaches that can help ensure
positive FSN outcomes.
12. P80: Regionalisation and domestication (vs internationalisation). Difficult to create a
general rule on this. Needs to be on a case by case basis. Example 1- trade between
coastal and land locked African states in smoked fish is critical to FSN. Example 2 Europe exports small pelagics important to FSN into Africa.
13. Typos: p 29 line1 “developing”; p 29 line 22 “academia”; p 49 line 18 missing bracket?; p
54 line 21 comma needs deleting; p 78 line 33 “FSN; p 79 line 19 remove s at end of
encourage.
48. Shashi Kumar, Bangalore University , India
Respected Sir,
As the title itself indicates there is a close interrelationship between the food security and the
sustainable aquaculture. The increasing population along with the increased income of the
people would definitely cause increased demand for food, particularly of the hygienic food in the
developed and developing countries. As such, the demand for overall agricultural produce is been
increasing.
Agriculture itself can’t provide the basic need to fulfill the consumerist attitude of ‘consumption
of food’. Because most of the developed countries are in shortage of food production as they
have much concentrated on the manufacturing sector. Nearly 60 percent of the developed
countries area much bothering about the payment for import of food, which has been earned
through the trading activity. The economic devastation in one way or the other is very much
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linked with the food crisis. Thus, both for developing and underdeveloped countries, the supply
chain of food would be of great importance and an opportunity to reap the fruits of food crisis.
The improvement of aquaculture not only promises to feed the hungry mouth, but also promotes
the nutrients for better health practices. Aqua-industry is an immense prospective for growth of
economy, if it been harvested, maintained and marketed properly. It would be of great potential
of generation of employment too. Concerned Governments should take initiative to explicit the
policies and programmes related to the aquaculture, thereby providing subsidies, training,
marketing, transport, warehousing etc., to improve the sustainability of fishing activity. As such,
the sustainable attitude with respect to the aquaculture results in emphasizing employment,
generation of income and overall development of socio-economic aspects of a nation.
Thanking you.
Sincerely yours,
Dr. R. SHASHI KUMAR M.A., M.Phil., Ph.D.
Associate Professor
Principal Researcher: India-EU Trade and Investment Relations(UGC, New Delhi)
Project Director: Inclusive Growth in India (ICSSR, New Delhi)
Department of Economics
Bangalore University
Bangalore-560 056
Karnataka State, India
49. Jorge Lopez,Argentina
[English translation]
I have read the zero draft of the report “The role of sustainable fisheries and aquaculture for
food security and nutrition” and would like to share the following comments:
1) I cannot see in the text any reference to the impact of climate change and variability on
fisheries and aquaculture and its consequences on food security and nutrition. In Central America,
we are working on this issue as it has greatsignificance, especially in coastal communities
depending on these activities.
2) The text correctly points out the conflicts between artisanal fisheries (small-scale) and
industrial fisheries (large-scale) as well as between aquaculture and fisheries. But this goes no
further and does not explore in detail any solutions or alternative options. In the region, we have
had successful experiences in which well managed consensus-building spaces have addressed
these disputes.
3) In 2008 a study was prepared in Central America entitled "Impact of Fishing and Aquaculture
on Food and Nutrition Security at Family Community Level in Central America" under the direction
and sponsorship of the CENTRAL AMERICAN ORGANIZATION OF THE FISHERIES AND
AQUACULTURE SECTOR (OSPESCA) and the REGIONAL PROGRAMME FOR FOOD AND NUTRITION
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SECURITY IN CENTRAL AMERICA (PRESANCA), both member agencies of the CENTRAL AMERICAN
INTEGRATION SYSTEM (SICA). I was personally involved in the design of this project.
If you are interested, I can send you the final report.
Jorge López
[Original contribution in Spanish]
Estimados señores, señoras:
He leido el Borrador cero del estudio "The role of sustainable fisheries and aquaculture for food
security and nutrition" y al respecto tengo los siguientes comentarios:
1) No veo en el texto el impacto de la variabilidad y cambio climático en la pesca y la acuicultura y
sus consecuencias en la Seguridad Alimentaria y Nutricional. En la región centroamericana,
estamos trabajando sobre el tema ya que tiene un gran significado sobre todo en las
comunidades costeras dedicadas a estas actividades.
2) El texto señala muy acertadamente los conflictos existentes entre la pesca artesanal (pequeña
escala) - pesca industrial (gran escala) asi como entre la acuicultura y la pesca. Pero ahí se queda
y no trasciende de manera clara en el planteamiento de soluciones o de vias alternativas. En la
región tenemos experiencias donde esos enfrentamientos fueron trabajados de manera exitosa
mediante espacios de concertación muy bien manejados.
3) En el año 2008 en Centroamérica se desarrolló un estudio bajo el título de "Impacto de la Pesca
y la Acuicultura en la Seguridad Alimentaria y Nutricional a Nivel Familiar y Comunitario en
Centroamérica" bajo la dirección y patrocinio de la ORGANIZACIÓN DEL SECTOR PESQUERO Y
ACUÍCOLA DEL ISTMO CENTROAMERICANO (OSPESCA) y EL PROGRAMA REGIONAL DE
SEGURIDAD ALIMENTARIA Y NUTRICIONAL PARA CENTROAMÉRICA (PRESANCA), ambos
organismos miembros del SISTEMA DE LA INTEGRACIÓN CENTROAMERICANA (SICA).
Personalmente trabaje en el diseño de este proyecto.
Puedo enviarles el informe final, si fuera de su interes.
Jorge López
50. Ministry of Fisheries and Coastal Affairs , Norway
Comments on the V0 draft of the Report: The Role of Sustainable Fisheries and Aquaculture for
Food Security and Nutrition
We would like to thank HLPE for this study regarding the role of fisheries and aquaculture for food
security and nutrition. We think the draft covers many themes of crucial importance for achieving
a sustainable development of food production from these sectors. It is an important topic that
often is forgotten in discussion on global food security.
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The focus of the report is mainly on the south-east part of the world where the problem of food
security is by far the greatest. The report is quite extensive regarding fisheries, but has some
shortcomings regarding aquaculture. We have full confidence that the HPLE will balance the two
topics, but want to stress one important issue that has escaped the draft.
When discussing the role of aquaculture on food security the focus in the report is the
comparison of farming herbivore/omnivore fish and carnivore fish. As this comparison is
important, one must not forget that an alternative to fish farming is the production of meat from
terrestrial animals. In this comparison lies the amount of resources needed to produce 1 kg food.
Looking at the feed conversion rate, fish farming undoubtedly is the most effective production
regardless of fish species. In this aspect aquaculture is a great contributor to global food security
and nutrition.
As the report points out, it is an important aspect that fish farming of carnivore fish uses fishmeal
and fish oil in the feed. However, the amount used has been drastically reduced during the last
decades. This has been the focus of two reports by Nofima (the Norwegian food research
institute):
http://www.nofima.no/filearchive/rapport-52-2011.pdf
and
http://www.nofima.no/filearchive/rapport-53-2011_5.pdf.
Regarding environmental sustainability, it is important that the report is balanced. It is our
experience that fish farming can be environmentally sustainable when the government has a longterm focus on the issue. Pollutants can challenge food safety, but Norwegian surveillance reveals
that the amount of environmental toxins has been reduced both in farmed fish and wild fish.
We would like to highlight the importance of food safety which is only scarcely dealt with in the
report. It is necessary to address food safety properly when addressing food security and
nutrition. Infections and malnutrition associated with these are responsible for a significant
proportion of deaths among infants and children worldwide each year. Food borne infections can
become a nutritional concern, e.g. infections causing diarrhea will interfere with the absorption of
nutrients from food. It is also important to assess and manage the risk and benefits of fish
consumption. Developing, maintaining and improving databases on nutrients and contaminants
such as methyl mercury and dioxins in fish consumed in the different regions are important. The
increase in international trade and cross-border transmission of infectious diseases makes food
borne disease surveillance programs important, nationally and internationally, in the control of
food borne diseases.
Finally, it would be useful if the report in one section could provide key statistics from the
fisheries and aquaculture sector. This could be information on the number of employees, the
amount of fish protein in diets, etc. It should cover both sectors at the global level and also split
into regional overviews.
51. Gabriel de Labra, Independent Consultant on Small Scale Fisheries and
Aquaculture, Spain
[English translation]
The document is certainly a valuable and necessary tool that will help to deservedly acknowledge
the men and women working in the artisanal fisheries and small-scale aquaculture sector as
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producers and suppliers of food of significant importance to human beings. As it has been
recognized and highlighted by the UN Rapporteur for the Right to Food in its August 2012 report,
“the contribution made by the global fisheries sector to the right to food and food security is
critical. Yet, it is often underestimated. Most strategies aimed at improving food security neglect
this sector or make only passing reference to it. Until recently, insufficient attention has been paid
to protecting the rights of fishermen and, more generally, people who depend on the fisheries
sector”.
In section 3.8 the document highlights the importance of the scale and the significant difference –
regarding NFS – between industrial fisheries and aquaculture and artisanal or small-scale fisheries
and aquaculture. Emphasizing this difference is crucial for any serious analysis and, in my opinion,
it is impossible to make an overall assessment or comparative analysis of fisheries or aquaculture
without specifying their scale. In other words, discussing about aquaculture or fisheries as a
whole, without specifying their scale, is useless, as this feature makes the activities completely
different and even opposing. And within the same scale, specifying if it is “responsible” or
“sustainable” is also deemed convenient.
Taking into account that the overall document is a complete and very good work, I would
modestly like to share two considerations.
On one hand, I believe it is necessary to emphasize that nutritional benefits of fish for health
(extensively discussed in Section 3.2) are often jeopardised by the frequent deficiencies and
shortcomings in preservation and processing means and procedures, common in most developing
countries. If the importance of fish for the food and nutritional security of the population is
acknowledged, the need of supporting and enhancing conservation and processing systems and
creating favorable conditions for improving infrastructure, training, access to credit, health
inspection, etc. should be acknowledged in public policies. Having access to the means and
knowledge required for an adequate professional performance is a right of the entire population,
and not only of the fish producers and processors.
On the other hand and, in my opinion, I would like to highlight the convenience of including and
making appropriate reference to the concept of Food Sovereignty amongst the aspects of
governance widely, rigorously and appropriately discussed in Chapter 5 (Governance, food
security and nutrition). With many examples around the world demonstrating that the laws of
free market (and even aid policies of multilateral agencies like the WFP ) have been the major
cause behind the abandonment and loss of food production capacity amongst smallholders in
several developing countries, Food Sovereignty prioritises local economies and local and national
markets over international law, acknowledging the role and rights of smallholders, and basing
food production, distribution and consumption on environmental, social and economic
sustainability. Food Sovereignty proposes new social relations without oppression or inequality
between men and women, people, ethnic groups, social classes and generations, and supports
that rights of access and management of land, water, seeds, fish and livestock resources and
biodiversity are held by those who produce food and adequately protected from those who put
the economic gain before the food and nutritional security of the people. In the present case, the
artisanal fishermen and rural fish farmers should, for the sake of Food Sovereignty, be
acknowledged, protected and defended by their governments in order to ensure food and
nutrition security in their respective territories and countries.
[Original comment in Spanish]
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El documento es sin duda un instrumento muy valioso y necesario que ayudará a dar al colectivo
de hombres y mujeres que trabajan en el sector de la pesca artesanal y de la acuicultura de
pequeña escala, el reconocimiento que la sociedad les debe como productores y proveedores de
un alimento de enorme importancia para el ser humano. Como ha sido reconocido y destacado
por el relator de NNUU para el derecho a la alimentación, en su informe de agosto de 2012, “ la
contribución aportada por el sector pesquero mundial al derecho a la alimentación y la seguridad
alimentaria es fundamental y sin embargo se la suele subestimar. La mayoría de las estrategias
destinadas a mejorar la seguridad alimentaria pasan por alto ese sector o solo se refieren a él de
pasada. Hasta hace poco, no se ha prestado suficiente atención a la protección de los derechos de
los pescadores y, más en general, las personas que dependen del sector pesquero”.
El documento resalta en su apartado 3.8 la importancia de la escala y la drástica diferencia que,
en relación a la SAN, existe entre la pesca o la acuicultura industrial y la pesca o la acuicultura
artesanal o de pequeña escala. Esta diferencia es fundamental remarcarla para cualquier análisis
serio y, en mi opinión, no es posible hacer una valoración global o análisis comparativo de la pesca
o la acuicultura sin añadir el epígrafe de su escala. Es decir, no se puede hablar de la acuicultura o
de la pesca como un todo sin hacer la precisión de su escala ya que en función de ésta se trata de
actividades totalmente distintas e incluso contrapuestas. Y dentro de la misma escala también
conviene precisar con otro calificativo, como es el de “responsable” o “sostenible”.
Considerando el documento en general como un trabajo completo y muy bien realizado, quiero
aportar modestamente un par de consideraciones.
Por una parte, creo que es necesario resaltar que el beneficio nutricional del pescado para la
salud (ampliamente tratado en el apartado 3.2) se ve en muchos casos comprometido por las
habituales deficiencias y carencias en medios y procedimientos de conservación y procesamiento,
que es una constante en la mayoría de los países en desarrollo. Si se reconoce la importancia del
pescado para la Seguridad Alimentaria y Nutricional de la población, debe reconocerse en las
políticas públicas la necesidad de apoyar y mejorar los sistemas de conservación y procesamiento
y crear las condiciones favorables para la mejora de estas condiciones: infraestructuras,
formación, acceso a créditos, inspección sanitaria, etc. Es un derecho de la población en general, y
no sólo de los productores y procesadores de pescado, tener acceso a los medios y los
conocimientos necesarios para un adecuado desempeño de su trabajo.
Por otra parte me gustaría destacar que, en mi opinión, dentro de los aspectos de Gobernanza
ampliamente tratados, con rigor y acierto, en el capítulo 5 (Governance, food security and
nutrition), sería deseable incluir y hacer la debida referencia al concepto de Soberanía
Alimentaria. Contando con múltiples ejemplos en todo el mundo que demuestran que las leyes
del libre mercado (e incluso las políticas de ayuda de organismos multilaterales como el PMA) han
sido la principal causa de abandono y pérdida de la capacidad de producción de alimentos entre
los pequeños productores de múltiples países en desarrollo, la Soberanía Alimentaria prioriza las
economías locales y los mercados locales y nacionales por encima de las leyes internacionales,
reconociendo el papel y los derechos de los pequeños productores, y colocando la producción
alimentaria, la distribución y el consumo sobre la base de la sustentabilidad ambiental, social y
económica. La Soberanía Alimentaria propone nuevas relaciones sociales libres de opresión y
desigualdades entre los hombres y mujeres, pueblos, grupos étnicos, clases sociales y
generaciones y aboga porque los derechos de acceso y la gestión de la tierra, las aguas, las
semillas, los recursos pesqueros y ganaderos y la biodiversidad, estén en manos de aquellos que
producen los alimentos y debidamente protegidos de los que anteponen el beneficio económico a
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la seguridad alimentaria y nutricional de los pueblos. En el caso que nos ocupa, los pescadores
artesanales y los acuicultores rurales deben, en aras de la Soberanía Alimentaria, ser reconocidos,
protegidos y defendidos por sus gobiernos para garantizar así la Seguridad Alimentaria y
Nutricional en sus respectivos territorios y países.
52. Pat Heslop-Harrison, United States of America
I am making some brief comments on the zero draft consultation "The Role of Sustainable
Fisheries and Aquaculture for Food Security and Nutrition, dated 18 November
2013.http://www.fao.org/fsnforum/cfs-hlpe/fisheries-and-aquaculture-V0
I am a geneticist with interests including improvement of agricultural species, food security and
environmental sustainability. There are many important issues addressed in this document; as is
stated, despite aquaculture having a 2,500 year history, modern research has been surprisingly
limited.
As an overall comment, I felt that many of key statements in the report were unreferenced or
referenced to weak and discursive reports rather than rigorous factual studies. This suggests a
need for study, and at a number of points in the report, there should be a recommendation of
research that is required.
I thought that the references and discussion of the importance of fish genetics was considerably
under-represented in the report. Genetics could well have its own complete section, not just a
subsection of 3.4. With respect to recommendation 12 of p. 81 line 39, can there be some precise
consideration of the genetic features being looked for in species used for aquaculture? Disease
again is mentioned, but the epidemiology of fish diseases, as well as their nature and control
options, should be looked at in more detail, particularly in relationship to prophylatic controls
(antibiotics etc) and having in place control measures and associated legistation.
There is an excellent consideration of the feeds used for fish from page 47. However, there is
surprisingly limited consideration of the future feeds, where it is essential to change to more
plant-based products. What is required? Why are current plant meals not universal? Will landbased crops or algal foods be more important? What should plant breeders be looking for in
producing fish feed?
I felt a few points were underdiscssed at other points: food safety issues may be greater with fish,
despite the number of preservation of approaches - drying, salting, cold-chain, processed ... Can
reduce post-consumer waste - bones and offal used more efficiently ('co-products) and not
discarded? Where is the profit and added value here? There is an excellent consideration of feed
conversion figures - but I expect the pork figure has improved considerably since 1999. The report
states "Fish oil, which cannot be readily replaced, is expected to continue to slowly increase": to
me, this sounds rather like comments on whale oil 30 years ago. Both plant breeding and plant-oil
processing can easily replace in a decadal timescale.
I think the report should include chapters on footprinting of various aquaculture systems: it is
important to have both a carbon footprint and a water footprint for aquaculture, carried out in a
rigorous and defendable way (unlike, say, the rediculous water 'use' figures for beef production
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which are widely cited). There could be a SWAT analysis of several areas: genetics, preservation,
genetic resources, nutrition inputs and outputs.
While the statements about little work on fish are in general true, it is by no means only the case:
there are huge parallels with plant domestication, and already there are large genomics projects
(stickleback; danio). The genomics revolution can quickly influence fish breeding, and the
Canadian Salmon genomic DNA sequence is soon to be published, while that of tilapia is also
nearly available. Genetics will be much quicker using these resources, and it should be noted
somewhere that already, transgenic fish are already available for purchase, the only animal and
vertebrate in this category (albeit for the tropical fish hobbyist).
The report is very valuable in emphasizing the importance and growth in aquaculture, and its
contribution to both food security and human nutrition, and I hope will lead to increased amounts
of appropriate research and the applications of that research.
53. James Rohan, Australia
As you might imagine, large topic and have put down some relevant ideas from existing research
and am reflecting on ways to model cultural approaches.
Am submitting progress if any at deadline but am now cognisant of strategic issues of fisheries
and food security. While offered personal growth, have included some ideas as to potential
reframing of research and development.
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/TheRoleofSustainableFisheriesandAquacultureforFoodSecurityandNutritionJamesRohanCPAMBAv2.pdf
Best Regards
James
54. Government of Australia
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
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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 fooddeficient 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
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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 largescale 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 largescale 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
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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.
55. Niracha Wongchinda Thailand
The project team has done a good work on the zero draft.
However there are some comments particularly on 7. Recommendations should cover these
topics:
National fisheries policies as stipulated in various national strategies for fisheries and aquaculture
development and management have emphasized on the following directions:
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• To have fishers and involving local organizations participate in fisheries administration,
management and development.
• To increase knowledge and skill of the fishers for their self-reliance and viable occupation as
well as to increase their capability in managing of their organizations.
• To maintain fisheries resources in harmony with sustainable utilization and without
compromising the impact to environment, under joint administration and management by
people, community, local organization, and government.
• To increase production from aquaculture sufficiently for domestic consumption.
• To accelerate research in supporting commercial aquaculture for increasing trade volume,
quality standard and reducing cost of production.
• To develop sustainable aquaculture system for domestic trade as well as for export based on
COC and GAP principle.
• To control and regulate fishing operation in compliance with agreements with other coastal
States or joint-venture partners.
Yours sincerely,
Niracha Wongchinda
Department of Fisheries, Bangkok, Thailand
56. Sue Longley IUF/UITA, Switzerland
This comment is submitted on behalf of the IUF*, the global trade union federation representing
workers throughout the food chain including in the fishing, aquaculture and fish processing
industries.
The IUF welcomes the decision of the CFS to ask the HLPE to conduct a study on The Role of
Sustainable Fisheries and Aquaculture for food security and nutrition.
The IUF believes that decent working conditions in the fishing and aquaculture sectors are
essential both to the sustainability of these industries and to ensuring the food security of people
working in fisheries and aquaculture.
We take this opportunity to remind the HLPE of the recognition in the CFS’s Global Strategic
Framework (paragraph 34), that “Many agricultural and food workers (note: which we understand
to include fish and aquaculture workers) and their families suffer from hunger and malnutrition
because basic labor laws, minimum wage policies and social security systems do not cover rural
workers. Formal employment and the assurance of a minimum living wage is key for workers’
food security and nutrition.”
The GSF calls for living wages and decent work as key tools to ensuring global food security and
nutrition for agricultural workers.
We would also like to draw to the attention of the HLPE to the “points of consensus” arising out of
the ILO’s global dialogue forum for the promotion of the Work in Fishing Convention, 2007 (no
188),
(http://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/--sector/documents/meetingdocument/wcms_214603.pdf),
in
particular
to
Point
4:
Recommendations for future actions by the International Labour Organization and its Members,
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point (vi) which calls on ILO and its member states to “continue to expand strategic partnerships
with other UN agencies and International organizations to foster policy and programme
coherence in the fishing sector to promote the ratification and effective implementation of
Convention No. 188.”
The IUF therefore calls on the HLPE to recognize the importance of ILO Convention 188, Work in
Fishing Convention and to call on CFS members states to ratify and implement the Convention as
a tool for ensuring both sustainable fishing/aquaculture and the right to food and nutrition for
workers in the fishing industry.
We support the comments already submitted by our affiliated organization, UILA PESCA.
************
*The International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied
Workers' Associations (IUF) is an international federation of trade unions representing workers
employed in agriculture and plantations; the preparation and manufacture of food and beverages;
hotels, restaurants and catering services; all stages of tobacco processing. The IUF is composed of
394 affiliated organizations in 126 countries representing a combined membership of around 2,6
million.
57. ICSF, Belgium
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
Contribution of ICSF to the HLPE V0 Draft report
The report flags some key issues. Comments on the report are provided keeping in mind the key
questions that the study is aiming to address:
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 71
“recognizing the well-established importance of fish to food security and nutrition, 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 that they have to respond to?”
I. ISSUES THAT NEED TO BE INCLUDED IN THE REPORT
Some key issues, with major implications for FSN are presently not addressed in the study. It will
be important to bring them in. These are as below:
1 Marine Protected Areas
Page 3 (Line 20) mentions the need to look at FSN implications of MPAs and similar conservation
tools. However, this is not discussed in the main body of the report. Since most MPAs are located
in coastal and marine areas of great biodiversity, their development has direct relevance and
concern to the livelihoods, culture and survival of small-scale and traditional fishing and coastal
communities who may be excluded from such areas, and their food security. Existing studies and
accounts received from fishing communities indicate that certain forms of top-down nonparticipatory conservation have had disastrous consequences for local fishing communities, who
lose both access to marine areas to fish and to access to coastal lands where they live. The costs
of such conservation measures are being borne by fishing communities, particularly by the
poorest among them, whose harvesting practices often have minimal impact on the resources
base. There are stories of exclusion from fishing grounds and decision-making processes, and
accounts of poverty and human-rights violations, associated with such forms of conservation.
Some references:

“Conservation, green/blue grabbing and accumulation by dispossession in Tanzania” by
Tor A. Benjaminsen and Ian Bryceson. Journal of Peasant Studies Vol. 39, No. 2, April
2012, 335–355. ?

Making
Local
Communities
Visible:
MPAs
in
http://www.icsf.net/en/samudra/detail/EN/937.html?detpag=mapart

Rajagopalan R, 2007. Restricting Lives and Livelihoods. Yemaya No. 26.
http://old.icsf.net/icsf2006/uploads/publications/yemaya/pdf/english/issue_26/art01.pdf

Marine protected areas: securing tenure rights of fishing communities. Chandrika Sharma,
Ramya
Rajagopalan.
Land
Tenure
Journal,
Issue
No.
1
(2013).
http://www.fao.org/nr/tenure/land-tenure-journal/index.php/LTJ/article/view/78

Mascia MB, Claus CA, Naidoo R. Impacts of marine protected areas on fishing
communities. Conserv Biol. 2010 Oct;24(5):1424-9.

ICSF case studies from Brazil, South Africa, Costa Rica, India, Tanzania, Thailand, Mexico
http://mpa.icsf.net/en/page/634-Publications/Case%20Studies.html
South
Africa
2. Competing uses of coastal spaces (impact of other sectors)
Coastal areas are today being targeted, backed by large investments, for various economic
activities that include aquaculture, tourism, real estate speculators, urban growth, energy (coal
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 72
powered plants, nuclear plants, wind energy…), ports, oil and gas exploration and extraction, etc.
There is unprecedented pressure, both on coastal lands and resources (being taken over/
captured by more powerful interests), and on coastal ecosystems (affected by pollution,
destruction of habitats etc.). For fishing communities this has meant, among other things, physical
displacement from their lands (used for housing and other domestic and productive purposes)
and their fishing grounds, in a process that has similarities to land-grabbing (this has received
widespread attention in recent years--see report of Special Rapporteur on Right to Food). It has
also meant declining fish catches due to destruction and degradation of spawning grounds/
coastal ecosystems. The implications for livelihoods and food security are obvious. The report
needs to discuss these trends (impacts of other sectors), their implications for FSN and propose
recommendations that allow fisheries and fishing communities to exist into the future in the face
of such pressures. Marine spatial planning is being put forward as a way to manage such
competing demands, and the implications, including FSN implications, of this for fishing
communities need to be analyzed.
There are similar pressures from other sectors (agriculture, irrigation, conservation….) on inland
fisheries.
Some references:

Fisheries and the Right to Food', Report presented at the 67th Session of the United
Nations General Assembly [A/67/268] http://www.srfood.org/en/access-to-land-and-theright-to-food

Securing Sustainable Livelihoods from Small-scale Fisheries. The Right to Food and
Nutrition
Watch
2013.
http://www.rtfn-watch.org/fileadmin/media/rtfnwatch.org/ENGLISH/pdf/Watch_2013/Watch_2013_PDFs/Separate_article_ENG/Watch2
013_EN_Chapter6_SecuringSustainableLivelihoods.pdf

The Fight for the Right to Food: Lessons Learned http://www.righttofood.org/work-ofjean-ziegler-at-the-un/what-is-the-right-to-food/

O’Riordan, B. 2006. Marine pollution: Fight over, but war goes on. SAMUDRA Report 45.

http://www.icsf.net/images/samudra/pdf/english/issue_45/2567_art03.pdf

Debnath, H. 2008. Save the coast, save the fishers. SAMUDRA Report 50.

http://www.icsf.net/images/samudra/pdf/english/issue_50/3191_art07.pdf

Viguera E, 2011. Defending the Sea. SAMUDRA Report No. 59

http://www.icsf.net/en/samudra/detail/EN/3619.html?detpag=mapart
This issue could also be discussed under the issue of sectoral trade-offs and food security, in this
case the trade-offs between energy, tourism, conservations etc. and fisheries (as a source of food
or source of feed)
3. Labour issues in fisheries
Fishermen working in fisheries, including small-scale and artisanal fisheries—who make up the
majority of the world ’s fishermen—face special problems that call for specific, targeted measures
to improve conditions of work and safety. As a result of the special nature of fishing, fishworkers
face several important labour issues. These labour issues range from workplace-related problems
and employment relationships to seasonality of employment and the effects of fisheries
management measures to reduce fishing effort. Paramount though they are to the lives of
fishworkers and fishing communities, they have remained unexamined and largely neglected,
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 73
even as the world’s fisheries have undergone significant and far-reaching changes over the last 40
years. During this period, laws and regulations covering other workers have been modified or
updated to recognize and accommodate changes. There is need to ratify and implement ILO Work
in Fishing Convention, 2007 (No.188) and to extend its provisions to small-scale fisheries and to
those who fish without vessels, many of who are women. At the very minimum implementation
of the convention will mean access to social security and medical services, for small-scale fishers.
For those on board larger vessels, it will mean safer and more dignified working conditions. The
links with food security are obvious.
Some references:





From Informal 'Co-adventurers' to Formal Workers? ILO's Work in Fishing Convention,
2007, Vol - XLV No. 05, January 30, 201o, Sebastian Mathew http://www.epw.in/specialarticles/informal-co-adventurers-formal-workers-ililos-work-fishing-convention-2007.html
The proposed ILO fishing standards and their relevance to small-scale fisheries by Sebastian
Mathew, Bay of Bengal News, June 2006, pp 26-29
http://bobpigo.org/html_site/bbn/june_06/pages26-28.pdf
Forced Labour: New Zealand's experience shows that labour conditions on board foreign
charter vessels are far from perfect, Comment, Samudra Report, No.65, July 2013
http://labour.icsf.net/en/samudra/article/EN/65-3891-Forced-Labour.html
Forced into Slavery, Working conditions for migrant crew on foreign chartered vessels
fishing in New Zealand's waters are nothing short of slavery, by Christina Stringer and Glenn
Simmons, Samudra Report, No.65, July 2013
Shore-Based Fishing Operations: Improving Working Conditions, Neena Koshy and
Chandrika Sharma. Labour File, Vol.5-No.3&4, May – August 2007. pp 33-37.
http://www.labourfile.org/ArticleMore.aspx?id=395
More information on labour.icsf.net.
4. Importance of organization (for resource management, socioeconomic issues, political issues)
Organization of those who actually fish, farm and engage in related activities is absolutely key to
maintaining and enhancing the contribution of fisheries to food security. It would be important to
discuss the ways fishworkers and fishing communities have organized to secure their interests or
to protect the resource base, and how this has contributed to FSN. The forms such organizations
have taken have perhaps varied, according to the reasons for organization and the kind of legal
and other realities prevailing in various countries. For resource management, forms of
organizations have included co-management and community-based management associations,
for socio-economic issues fishworkers are known to have organized as producer groups, cooperatives and other forms of economic associations, and for political demand they have
organized as unions etc. In some cases the same organization has taken on all the above tasks, in
others, there is a division. SAMUDRA Report and Yemaya has carried several articles about such
organizations, as well as interviews with their leaders.
 Studies on the role of fishermen's organizations in fisheries management.
http://www.fao.org/docrep/003/T0049E/T0049E00.HTM
 APFIC Regional workshop Mainstreaming fisheries co-management FAO 2005
http://coin.fao.org/coin-static/cms/media/9/13170364037740/2005_23.pdf
 Local Sea Fisheries Committees in France
http://www.icsf.net/en/samudra/article/EN/61-3707-Roundup.html
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 74
 Platform for Mediterranean Artisanal Fishermen
http://www.icsf.net/en/samudra/article/EN/59-3620-News,-events,-b.html
 The Locally-Managed Marine Area (LMMA) Network (for resources management)
www.lmmanetwork.org
http://www.icsf.net/en/samudra/article/EN/57-3532-News,-Events,-B.html
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 75
II. COMMENTS ON VARIOUS ISSUES COVERED IN THE REPORT
1. Characterization of small-scale fisheries (Page 12, line 11 to 14)
The description of small-scale fisheries provided lacks the socio-cultural dimension that is so
critical, including in the context of FSN. See, for example, the description of SSF in the Preface
(already adopted) of the SSF Guidelines that has done some justice to this aspect:
“Small-scale fisheries represent a diverse and dynamic subsector, often characterized by seasonal
migration. The precise characteristics of the subsector vary depending on the location; indeed
small-scale fisheries tend to be strongly anchored in local communities, reflecting often historic
links to adjacent fishery resources, traditions and values, and supporting social cohesion. For many
small-scale fishers and fish workers, fisheries represent a way of life and the subsector embodies a
diversity and cultural richness that is of global significance. Many small-scale fishers, fish workers
and their communities – including vulnerable and marginalized groups – are directly dependent on
access to fishery resources and land. Tenure rights to land in the coastal/waterfront area are
critical for ensuring and facilitating access to the fishery, for accessory activities (including
processing and marketing), and for housing and other livelihood support. The health of aquatic
ecosystems and associated biodiversity are a fundamental basis for their livelihoods and for the
subsector’s capacity to contribute to overall well-being.”
Mention should also be made about the artisanal nature of some kinds of small scale fisheries
that make them quite distinct in the logic to industrial fishing, and highly relevant in today’s postmodern fisheries, where the industrial model is looking increasingly untenable.
Whilst “small-scale” fishing readily lends itself to quantitative criteria, the use of the term
“artisanal” carries with it a number of implications (social, cultural and technical).
There is also range of terms associated with small-scale and artisanal fishing. These include such
terms as “subsistence”, “traditional”, “modern”, “peasant”, “commercial”, “inshore”,
“professional” and “non-professional”.
Ambiguities also arise because small-scale and artisanal fisheries “have evolved in time and space
from specific ecological, and changing socio-economic and cultural contexts which are marked by
diversity rather than homogeneity.”
Kurien, J. 1996. Towards a new Agenda for Sustainable Small-Scale Fisheries Development. South
Indian Federation of Fishermen Societies 1996. India
2. Governance, Food Security and Nutrition (Section 5)
Rights-based fisheries: There is discussion on fisheries governance at the international level (page
73) with some reference to the trend towards wealth-based fisheries management. However,
there is no specific discussion on the growing emphasis on/ espousal of rights-based
management, and the individual transferable quota (ITQ) and ITQ-like systems associated with
them. A discussion of these systems (that are mooted primarily for economic efficiency) and their
implications for FSN and the wellbeing of coastal fishing communities would be very important.
Rights regimes that promote individual rights to fish, rights that may also be transferable and
tradable, that essentially seek to privatize or otherwise restrict access to a privileged few, have
livelihood and food security implications that need to be analyzed. It can be argued that such
regimes benefit the financially stronger, and invariably lead to a displacement of small-scale
individual or family-owned fishing enterprises and their communities, and, sooner or later, to the
concentration of fishing rights in the hands of a few, either specialized fishing companies, or large
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 76
holding corporations for whom fishing is basically a business enterprise or a commodity for
speculative investment. This has also been borne out by experience.
Wrongly conceived rights based approaches based on individual rights that use market based
systems for distributing fishing rights create two classes of people: those who have access, rights,
or an exclusive privilege to the fishery and those that do not have such rights. Such a situation
gives rise to inequity, conflicts, and increased vulnerability and exploitation of the “have-nots.
The food security and human rights implications of such a shift are evident and of serious
concern.
Some references:
 Opinion of the Human-rights Committee (91th session, 2007) on behalf of Erlingur Sveinn
Haraldsson and Örn Snævar Sveinsson, under the Optional Protocol to the International
Covenant on Civil and Political Rights,
http://www.worldcourts.com/hrc/eng/decisions/2007.10.24_Haraldsson_v_Iceland.htm
 Kolding J and Zwieten P, 2011. The tragedy of our legacy: how do global management
discourses affect small-scale fisheries in the South? Forum for Development Studies. Volume
38, Issue No 3. http://www.tandfonline.com/doi/abs/10.1080/08039410.2011.577798
 Edward H Allison, Blake D Ratner , Bjorn Asgard, Rolf Willmann, Robert Pomeroy & John
Kurien, 2012. Rights Based Governance: from fishing rights to human rights. Fish and Fisheries,
13, 14–29 http://onlinelibrary.wiley.com/doi/10.1111/j.1467-2979.2011.00405.x/full
 The Other Story : New Zealand : ITQs
http://www.icsf.net/en/samudra/detail/EN/3654.html?detpag=mapart
 Sizing up - Property Rights and Fisheries Management: a collection of articles from SAMUDRA
Report, SAMUDRA Dossier
http://www.icsf.net/images/dossiers/pdf/english/issue_82/82_all.pdf
Co-management: The discussion on co-management needs to be more nuanced. It would be good
to discuss how co-management is understood and actually practiced. Is there a judiciable policy
framework in place, or is it just a project driven process that winds up when the project is over? Is
co-management reduced to token consultation, or does it actually mean shared decision making?
Without an understand of these aspects, analyzing FSN implications of co-management at the
macro level (meta analysis), and drawing out any conclusions about whether co-management is
effective or not, is meaningless and even misleading. It would be more meaningful to look at what
sort of co-management systems have been effective and why.
3. Regional Trade: From ‘pro-cash remunerative fish trade’ to ‘pro-food security fish trade’
(Page 42)
The arguments made in the report to support regional, national and local fish trade (and the need
for greater policy attention to support such forms of trade) are excellent. Some references (and
proposals made by women engaged in such forms of trade) that may be used to strengthen the
argument as below:


Workshop on Problems and Prospects for Developing Artisanal Fish Trade in West Africa:
Report http://www.icsf.net/images/proceedings/pdf/english/issue_102/102_all.pdf
Report of the Study on Problems and Prospects of Artisanal Fish Trade in West Africa,
International Collective in Support of Fishworkers (ICSF), March 2002
http://aquaticcommons.org/256/1/rep_WAfrica_artisanal_fishtrade.pdf
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 77

Open Borders, Closed Opportunities: Asia / Cambodia by Kyoko Kusakabe,
http://www.icsf.net/download.php?option=com_yemaya&sel_subsite=1&language=EN&fil
e=http://www.icsf.net/images/yemaya/pdf/english/issue_31/1552_art01.pdf
4. Gender, Food Security and Nutrition (Section 4, Page 61)
This section also draws out the “gendered impacts of the massive sectoral change such as
modernisation, mechanisation, market concentration and labour cost squeezes”. The issue raised
can be fleshed out in more detail.
Gender and Work in the Fish Sector (Page 63)
Some additional references that describe the poor conditions of work of women in the processing
sector, lack of recognition of women as fishers, etc.





Not a rosy picture: Conditions of work of women workers in warrahs, sheds for processing
fish, leave much to be desired, highlighting problems in the implementation of existing
labour laws. Author(s) : Tayyaba Ahmed. Yemaya Issue No. 17 , December 2004
http://www.icsf.net/download.php?file=http://www.icsf.net/images/yemaya/pdf/english/i
ssue_17/572_art03.pdf
Women in seafood processing: A study carried out in Gujarat, India finds that changes in the
infrastructure of seafood processing plants post globalization has not really changed the
status of the women workers in the industry. Author(s) : Nikita Gopal, Geethalakshmi, V.,
Unnithan, G. R., Yemaya Issue No. 30 , March 2009
http://www.icsf.net/download.php?option=com_yemaya&sel_subsite=1&language=EN&fil
e=http://www.icsf.net/images/yemaya/pdf/english/issue_30/1518_art01.pdf
Equal Rights, Unequal Access: A new fisheries law in Brazil recognizes, for the first time,
fisherwomen as workers. But they need to come up to speed to take advantage of the
associated work-related benefits…Author(s) : Sueli Miranda and Maria Cristina Maneschy.
Yemaya Issue No. 34 , June 2010
http://www.icsf.net/download.php?option=com_yemaya&sel_subsite=1&language=EN&fil
e=http://www.icsf.net/images/yemaya/pdf/english/issue_34/1650_art02.pdf
Making their Voices Heard: Fisherwomen in Brazil have organized themselves to demand
recognition of their work and rights in the fisheries and, slowly, the government is being
forced to listen…Author(s) : Naina Pierri and Natália Tavares de Azevedo. Yemaya Issue No.
34 , June 2010
http://www.icsf.net/download.php?option=com_yemaya&sel_subsite=1&language=EN&fil
e=http://www.icsf.net/images/yemaya/pdf/english/issue_34/1651_art03.pdf
Questioning invisibility: Women workers in the fisheries sector in Chile are often not
formally recognized or covered by social security. Author(s) : Dodani Araneda, Jacqueline
Salas, Alejandra Pinto and Marisol Alvarez, Yemaya Issue No. 19 , August 2005
http://www.icsf.net/download.php?option=com_yemaya&sel_subsite=1&language=EN&fil
e=http://www.icsf.net/images/yemaya/pdf/english/issue_19/803_art03.pdf
Gender-blindness in Fish Sector Policy and Practice (Page 65)
The consequences of gender-blind policies and practice and how women have been affected and
marginalized women in concrete terms, merits a greater discussion.
www.fao.org/fsnforum/cfs-hlpe
Proceedings / 78
The thrust on mechanization and motorization, for example, has affected women in specific ways,
as landings have moved away from beaches (adjoining fishing villages) to centralized harbour and
landing centres, with repercussions for women’s access to fish (for domestic consumption and for
sale). Women are forced to travel long distance to harbours. Apart from having to tLacking credit
and infrastructure, they get access to only low value fish, with lower profit margins, or to low-paid
jobs sorting/ drying fish etc. These consequences have not been factored in by policy makers,
because of a lack of knowledge/data on women’s work. It would be useful to highlight, in this
context, the strong links between small-scale fisheries and women’s livelihoods and food and
nutritional security (briefly touched on in the box on trawling)
As women’s work is not accorded due attention, little policy attention is paid to improving the
conditions in which women’s work in the fisheries (related to, for example, marketing, processing
etc.) is undertaken. The conditions at fish markets and harbours/ landing centres leave much to
be desired in terms of hygiene and access to basic facilities (no toilets means that women often
suffer from urinary infections for example). As argued in the section on trade, little efforts is
devoted to improving women’s access to local, national, regional markets, removing basic
impediments and improving conditions of work. The implications for FSN, including for women’s
health, are obvious.
Some references:

Monograph Women Fish Vendors in Mumbai: Study Report by ICSF
http://www.icsf.net/images/monographs/pdf/english/issue_132/132_Monograph_WFV_M
umbai_26april2013_Final_w_Cover.pdf

Salagrama V, 2002. Fish Out of Water: The Story of Globalization, Modernization and
Artisanal Fisheries of India, in Proceedings of the Asian Fisherfolk Conference: Cut Away the
Net of Globalization, 2002, Follow-Through Committee, Thailand
Sharma C. 2003. The Impact of Fisheries Development and Globalization Processes on
Women of Fishing Communities in the Asian Region. APRN Journal, Volume 8 (2003).
http://aprnet.org/conferences-a-workshop/97-impact-of-globalization-on-womenlabor/162-the-impact-of-fisheries-development-and-globalization-processes-on-women-offishing-communities-in-the-asian-region

5. Aquaculture
In general the aquaculture section has brought in more information from Africa, with very little
discussion on the developments in Latin America in particular. A more regionally balanced
approach is called for.
Aquaculture (Page 31)
This section should also point to traditional forms of aquaculture (often combined with farming
and livestock rearing) that has played such an important role in FSN, and the need to popularize
such systems further for various reasons. See also discussion in SOFIA 2012 (Page 30, Box 2: Fish
culture in rice fields).

Integrated
livestock-fish
farming
ftp://ftp.fao.org/docrep/fao/006/y5098e/y5098e00.pdf
Aquaculture (Page 35, para starting on line 29)
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systems
Proceedings / 79
It would be useful to mention that in some cases, the emphasis on culturing fish as a cash crop
(such as carp species in India and Bangladesh) has wiped out local, indigenous species (seen as
‘weed’ fish that compete with cultured fish for feed, and that, therefore, need to be eliminated
through use of appropriate chemicals). This has major implications for FSN (both direct and
indirect). As local indigenous species, particularly small indigenous species (SIS) are often
consumed whole, they are more nutritious. Given that they are seen as low-value fish, they are
also more accessible to local populations (in contrast to other large cultured fish that are primarily
marketed in nearby towns and cities). Moreover, in certain situations, as in Madhya Pradesh,
India, these low value species are handled and marketing by women (providing a source of
income). Once these species decline women also lose a source of income. The attached report
provides information on these aspects (highlighted in yellow).

Small Indigenous Freshwater Fish Species: Their Role in Poverty Alleviation, Food Security
and Conservation of Biodiversity, Workshop 23-25 February 2010, Central Inland Fisheries
Research Institute, Barrackpore, Kolkata, West Bengal
http://www.icsf.net/download.php?option=com_proceedings&sel_subsite=1&language=E
N&file=http://www.icsf.net/images/proceedings/pdf/english/issue_106/106_all.pdf
Small but Nutritious: Report: SIFFS Workshop, Author(s):Sebastian Mathew and Neena
Koshy
http://indianfisheries.icsf.net/images/samudra/pdf/english/issue_55/3440_art_art10.pdf

Aquaculture feeds (Page 47, with specific reference to Box 3.6)
It will be good to mention that the market for low-value so-called trash fish for fishmeal, has given
a new lease of life to trawling. By-catch has now become even the main catch. (The main catch of
shrimp is declining due to excessive fishing pressure). Trawling, as the report discusses, has major
FSN implications. The diversion of by-catch for fishmeal also has food security implications, even
to the extent that the price offered for use as fishmeal may be higher than what poor consumers
can pay.
Some references:

Spatio-temporal analysis and impact assessment of trawl bycatch of Karnataka to suggest
operation
based
fishery
management
options
http://eprints.cmfri.org.in/8987/1/Dineshbabu_27-38.pdf

Assessment of low value bycatch and its application for management of trawl fisheries
http://eprints.cmfri.org.in/9678/1/Dineshbabu_Ecosystem_Approaches_to_the_Manage
ment_and_Conservation_of_Fisheries_and_Marine_Biodiversity_in_the_Asia_Region.pdf

Survey of Marine Trash Fish and Fish Meal as Aquaculture Feed Ingredients in Vietnam.
Author(s):
P.
Edwards,
Le
Anh
Tuan
&
G
L
Allen
http://aciar.gov.au/files/node/554/wp57.pdf
Aquaculture (Pg 52, Para starting line 23)
This assertion does not seem entirely correct. In several parts of developing world, funding by the
IFC and other development banks has been known to play a role in boosting production of
intensive forms of shrimp culture. See for example:
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Proceedings / 80

The World Bank. (2007). Changing the Face of the Waters: THE PROMISE AND CHALLENGE
OF SUSTAINABLE AQUACULTURE.http://wwwwds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2007/12/03/000020953
_20071203133332/Rendered/PDF/416940PAPER0Fa18082137015501PUBLIC1.pdf (Page 21
on the funding of shrimp culture by IFC in the period 1998 to 2006)
Also, national policies in many countries in Asia and Latin America have provided all kinds of
incentives
to
promote
intensive,
export-oriented
culture.
Aquaculture – scale issues (Page 60, para starting line 1)
The argument, based primarily on the African experience, is not clear. Is the report pointing to a
tension between local food security (small-scale aquaculture) and national and regional food
security (only attainable through medium or large-scale aquaculture)? Will medium or large-scale
aquaculture also contribute to local food security? Will not the “modern peasants” referred to
become ensnared in complex and ever longer value chains that create dependence on corporate
structures to provide the necessary inputs for their activities (seed, feed, treatments, etc.) and the
markets for their production?
Governance issue in aquaculture and links to food security (Section 5.3, Page 75, line 26)
There is no reference to culture-based capture fisheries, quite a unique category, but very
important in many countries, including from an FSN perspective. In this form the issue of who has
access becomes very important (as rights may be allocated through auctions, to the highest
bidder, not to those with customary rights, or to coops of adjacent communities).
Reference should also be made to the issue of aquaculture concessions, which like ITQs in capture
fisheries may be provided free of charge to companies, but which then become highly valuable
and may either be used to obtain bank loans, traded or included in the companies’ financial assets
to inflate their market value and hide their indebtedness. In countries like Brazil and Chile,
aquaculture concessions to waters that are the traditional fishing territories of local and
indigenous communities are being offered for tender by governments, with no PIC, compensation
or alternative livelihoods being offered to displaced communities.

Short-term model. ICSF Samudra 64. Tavares de Azevedo N. And Pierri, N. 2013
http://www.icsf.net/download.php?option=com_samudra&sel_subsite=1&language=EN
&file=http://www.icsf.net/images/samudra/pdf/english/issue_64/3853_art_Sam64_eart08.pdf
Key issues that need to be flagged
The section on aquaculture should also flag critical issues in relation to developments in
aquaculture that have a bearing on FSN. These include:
 Growth in contract farming and implications for FSN (often small farmers are provided credit
for the purchase, development and operation of ponds, while often dictating the sourcing of
inputs as well as the product prices)
 Trends towards increasing corporate control over seeds (market domination especially by
genetics companies), feeds including fishmeal, antibiotics and other inputs
 FSN implication of GM fish, and the patenting of genes, transgenic varieties, and genetic
manipulation (such as triploidy). GM is bolstering domination by corporate agribusiness in
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food production where the effects on FSN are already apparent, and this trend may well follow
in aquaculture.
 Despite claims to the contrary, present day aquaculture continues to be faced with problems,
such as escape of farmed (often exotic) species, disease etc. which have significant FSN and
biodiversity implications. Example of salmon aquaculture (though shrimp too continues to be
plagues by disease and other problems)
- Thorstad, E.B., Fleming, I.A., McGinnity, P., Soto, D., Wennevik, V. &
Whoriskey, F. 2008. Incidence and impacts of escaped farmed Atlantic salmon
Salmo salar in nature. INA Special Report 36. 110 pp.
- http://www.asf.ca/docs/uploads/impacts-escapes-2008.pdf (accessed
7/10/2009) http://www.salmontrout.org/pdf/STA_the_Impact_of_Salmon_Aquaculture_Briefting_Paper.pdf
6. Comments on Recommendations
 Several of the recommendations are very good. However, the issues raised above should also
be reflected in the recommendations
 Recommendations 7 and 12 need to be reviewed
58.Brian O'Riordan, ICSF, Belgium
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.
http://www.fao.org/fsnforum/cfs-hlpe/sites/cfshlpe/files/resources/SIFFS%20workshop%20report_0.pdf
Best wishes
Brian O'Riordan,
The Secretary, ICSF Belgium Office
Sentier des Rossignols 2
1330 Rixensart, Belgium
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59. IBON International, Philippines
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.
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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 smallscale fisheries play a central role in FNS. However, it must be noted that supporting smallscale 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 .
60. Françoise Medale, INRA, France
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
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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).
61. Anna Antwi, Development Consultant, Ghana
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
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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.
62. Alexandre Meybeck, FAO/UNEP Sustainable Food Systems Program, Italy
Dear HLPE Coordinator,
This draft and relative consultation are extremely welcome, especially as they give the
opportunity to non fish specialists to consider fisheries and aquaculture in their relation to
broader food security and sustainability.
In that respect this draft provides very usefull information and analysis. I also note that, given the
topic, it provides an opportunity for much more specific discussions on nutrition than in previous
reports.
It could still benefit from some aspects being more targetted to non fish specialists.
Two areas would, in that perspective, deserve more explanation:
- the Fisheries crisis p 29
- the Fisheries governance p 69. In particular some clear analysis for the layman on the way fish
rights are determined and attributed, including at international level, what about quotas and
transferable quotas.
The draft contains some preliminary thinking around the relations between sustainability and
food security. It would very much benefit from a more structured approach in the introduction to
the relations between the topic and the 4 dimensions of food security. A very good example of
such an analysis is the introduction of the HLPE report on biofuels and food security. This would
enable to better tacle the difficult question of the articulation of the 3 dimensions of sustainability
(to which could be added governance) with the 4 dimensions of FS. This seems all the more
important in relation with the notion of Sustainable Food Systems, considered in the other on
going HLPE report.
In fact it could broaden the perspective of the report towards the contribution of Fisheries and
Aquaculture to Sustainable Food Systems.
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A key here could be a more structured approach to the notion of resource efficiency (see for
instance section 2 of the paper on Ressources and Food Security prepared for the Food Security
Futures and accessible in a draft form at
http://www.pim.cgiar.org/files/2013/01/FoodSecurityandSustainableResourceUse2.pdf) .
Two points seem to me of particular relevance here:
- the comparisons made on contributions of various fisheries and aquaculture systems in terms of
jobs (direct and indirect), income, nutrition...
- the efficiency of aquaculture to provide animal protein as compared to other forms of animal
breeding (better efficiency to transform calories, less GHG emissions...). This is particularly
important given the projected increased demand for animal products and actual needs in some
regions. On top of course, as very well underlined in the draft are potential added benefits in
terms of micronutrients.
In the same perspective it would be of value to add more on the relations of fisheries and
aquaculture with other agricultural activities; particularly on integrated systems (such as rice/fish
for instance) and on competition between sectors for land and especially water -for instance
impact of irrigation on inland fisheries.
Finally, as the demand seems to be very much driven by rich consumers, this aspect would
deserve to be properly considered in chapter 6 on prospective. The notion of Sustainable diets
could be of interest here. Another point to be developed would certification and ecolabelling and
the way they could benefit to sustainability (including social dimensions and potential impacts on
small scale fisheries and aquaculture).
The recommendations could include the need to better integrate consideration of fisheries and
aquaculture in broader strategies and plans for food security and/or agriculture as well as in some
specific policy tools such as the NAPA s (National Adaptation Plans of Action) in the climate
change area.
Best regards
Alexandre Meybeck
FAO/UNEP Sustainable Food Systems Program.
63. Samuel Ayuba Hamisu, Yobe State College of Agriculture Gujba, Nigeria
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
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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:
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


Fish meal.
Fish Silage.
Fish muse - used to produce fish cake, scourge and fish finger.
64. Katosi Women Development Trust, Uganda
[Original contribution with pictures available here]
Katosi Women Development Trust (KWDT), (Reg. No. S.5914/6911) works with 425 women
organized in 16 groups in fishing communities along the shores of Lake Victoria in Mukono Uganda.
1.
Access to fish for fisher communities and women in fishing communities.
Access to fisheries resources for fishing communities and for women in fishing
communities is vital to enhance food security. The changes that have taken place in
fishing communities have reduced fish available for fisher communities especially to
women and children. The factors for the cause of these changes are diverse but to
mention a few that need to be addressed to enhance access to fish for local communities;
Trade in fish; export of fish has deprived fisher communities’ fish for local consumption
and trading. Harvesting and trade in juvenile fish is a thriving alternative in many rural
fisher communities which cannot be reached by enforcement officers. However this is
exacerbating the problem of sustaining fisheries resources in the lake.
Alternative livelihood strategies, awareness campaigns, community based management
are possible options to explore to deter juvenile fishing. External law enforcers when put
in place, has instead created a new niche for law enforcers to seek bribes from the
offenders as they discover a prime source of income. Community awareness and
community enforcement will halt juvenile fishing practices; contribute to sustenance of
fisheries resources and thus food and nutritional security.
The developments in the sector too tend to alienate the women more, increasing their
vulnerability in the sector. Therefore there is a need to explore solutions that will
minimize this vulnerability.
For example women had initiated the idea of processing by products from the factories;
the head, skin, etc. As the competition in access to these by products increased, factories
started to sell to individuals who were buying in bulk. Those buying in bulk and who had
the capital are men who have the money and then employ women in deplorable working
conditions. Women in fisheries need financing mechanism to enable them stay in the
sector.
To enhance access to fish for processing, women too in silver fish processing are
purchasing boats and giving boats to the men to ensure supply of silver fish. Such women
need to be further supported with access to capital to invest in fishing.
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Access to credit especially for women will reduce their vulnerability and alienation from
the sector.
As in other local communities, food security at the household level in fishing communities
is more of a woman’s concern and role. There is therefore need to put in place extra
measures to facilitate women stay in the fish processing industry and continue to access
fishery productions.
2.
Fish handling and hygiene of fish for local markets.
Many landing sites that handle fish for local consumption lack clean water and sanitation
facilities. In addition, many women working in the processing of fish in these communities
are working under very poor and unhygienic conditions.
Handling, storage, processing coupled with establishing sanitation facilities, water, child
centres will contribute to improved handling and working conditions for women in
processing.
3.
Women in governance of fisheries resources.
Engaging organized women groups and enhancing their capacity in the management of
fisheries resources is key to sustain food security.
For women to be able to fulfill this role, measures need to be put in place to reach out to
them, after which capacity building programs will enable them to effectively play an
active role in the governance of fisheries.
In 2010 KWDT initiated community dialogues that enable community members to meet
with their local leaders to voice out their concerns and together make an action plan.
These provide an opportunity for the community members to meet their local leaders and
challenge and demand accountability from their leaders. The World Fisheries day at
Nangooma landing site in Mukono on 21st November 2013 further provided this
opportunity
4
Aquaculture.
With a steady increase in the demand for fisheries resources, aquaculture has the
potential to provide alternative source of fish in many local communities. However lack of
ownership of land especially for women in rural communities hinders this potential.
KWDT has been supporting women into aquaculture but to make long term investment in
aquaculture, land ownership need to be addressed coupled with increasing access to
expertise support in fish farming especially for women.
In addition to all the above, fishing communities are still struggling with ill health especially
HIV/AIDS, poor infrastructure and inadequate services.
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65. FAO Department of Fisheries and Aquaculture, Italy
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
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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.
2- 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.
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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 landings1. 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.
1 Ye et al. (2013) Rebuilding global fisheries: the World Summit Goal, costs and benefits. Fish and
Fisheries, 14:164-185.
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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.
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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 smallscale 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 Smallscale 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.
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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 onesided. 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
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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.
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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 smallscale 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.
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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
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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.
66. Government of France
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
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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 ressources2. 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
2
Surexploitation des poissons démersaux côtiers au Sénégal, de la crevette dans les
mangrove à Madagascar, stocks côtiers en Inde ...
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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
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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
croissante3. 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’activités4. 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.
67. European Commission Services
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".
3
l’OIPC (interpol) offre des perspectives intéressantes en matière de coopération pour
lutter contre les marchés noirs de poisson et les trafics qui les alimentent.
4
Le règlement CE n°1005/2008 donne également trois définitions assez précises.
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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+205. 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 20006. 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,
5 Paragraph 113, "the Future we want", A/RES/66/288
6 Communication from the Commission to the Council and the European Parliament,
Fisheries and Poverty Reduction, COM(2000)724 final, of 8.11.2000
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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 smallscale 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.
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
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…).
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