It’s not really about money is it?

By historicair 22:10, 30 May 2007 (UTC) (Own work (Lyubomir Ivanov)) [GFDL ( or CC-BY-SA-3.0 (], via Wikimedia Commons
By historicair 22:10, 30 May 2007 (UTC) (Own work (Lyubomir Ivanov)) [GFDL ( or CC-BY-SA-3.0 (], via Wikimedia Commons
The deadline for responses to the consultation about the South Georgia and South Sandwich Islands is 31 July – Friday.

Please respond as every response will count – as there won’t be very many.

Something along these lines would be useful, I believe:





Thank you for the opportunity to comment on the South Georgia and South Sandwich Islands Strategy for 2016-2020.  I am a UK taxpayer and I would like my money to be spent on conserving the important biodiversity in this far-flung UK Overseas Territory.

Your draft clearly acknowledges the global importance of these islands and of the seas around them for biodiversity. I welcome that and would congratulate you on your investment in the eradication of rats and reindeer on South Georgia, on the marine protection that already occurs in this Territory’s waters, and for your recent declaration of the extension of the Convention on Biological Diversity to SGSSI.

The introduction to the strategy could be strengthened by acknowledging that the Territory contains two of the 11 priority areas identified by CCAMLR as regions in which further work to identify marine areas for protection should be focussed.

Environmental management.
The Government has an opportunity in the South Sandwich sector further to improve the protection of biodiversity in this Territory at minimal cost, to contribute very constructively to CCAMLR’s protected area programme, and to attract considerable positive international recognition of the UK’s custodianship of this region. Specifically by giving full protection to the entire marine area out to the edge of the EEZ, in the South Sandwich sector of the EEZ, the UK could create a fully-protected marine reserve of c530,000km2. This would complement the marine reserve already established to the south of the South Orkney Islands. The scientific justification for this is similar to the justification put forward by the UK to secure the South Orkney marine reserve (see below) and the two reserves together could form part of a future chain of undisturbed reference sites stretching down to the Antarctic peninsula.

Given the interest of stakeholders, as well as the interest of the political parties in this suggestion (see 2015 manifestos and election statements), and the importance of establishing a more extensive marine protected area network in the CCAMLR region, I would ask that there should be a commitment in the strategy that the review of the MPA envisaged for 2018, will look specifically at the feasibility of establishing a fully-protected marine reserve in the South Sandwich sector of the EEZ to complement the South Orkney marine reserve, and that this commitment should be written in as a key objective.

The key objective which says “Sustainable use and management of the marine environment is continued and constantly reviewed in the light of new data”, should be removed from this section and placed, if needed at all, under the sustainable use section (the third Strategic objective). The reason for this is that use, sustainable or otherwise, is not necessary to achieve the second strategic objective (to “conserve the near-pristine nature of the Territory’s environment, preserving and, where practical, restoring the native biodiversity and habitats.”). Indeed inevitably it is likely to damage this objective, a fact that you acknowledge in your third strategic objective when it talks about “minimising the impact” (of fisheries).

Fisheries management
I welcome the investment GSGSSI already makes in enforcement using the Pharos and that also that you intend to investigate remote sensing as an additional enforcement tool. I’m sure that GSGSSI is aware of the efforts of FCO which is already engaged in finding solutions which are applicable to all territories, and we assume that GSGSSI intends to join in with these efforts, since that certainly seems the most cost-effective way to make progress on this important issue.

The Royal Navy and RAF when they overfly or send ships, such as HMS Protector, into the Territory, should explicitly be tasked to contribute to enforcement. Protecting resources (of the UKOTs) from illegal exploitation of our marine area (including fisheries) is one of the UK’s marine security objectives (The UK National Strategy for Maritime Security – May 2014). Including this commitment in the strategy would demonstrate joined up and cost-effective government.

Patagonian and Antarctic toothfish fisheries in the South Sandwich Islands
It is interesting to note that the total catch from the South Sandwich islands is only 35 tonnes. This represents only 1.6% of the South Georgia catch of 2200 tonnes. Figures show that the toothfish fishery contributes around 75% of the total fishery income. From this it is clear that fishing for toothfish in the South Sandwich sector of the EEZ contributes only a tiny amount to overall fisheries’ revenue and that, taking account of the extra fuel needed to travel to those islands, must be financially marginal at best.
An additional reason often used to justify this fishing is that it is alleged that having two boats in the area acts as an aid to enforcement. Given the limited time the boats are present and their limited horizon, beyond which other boats would be invisible to them, again this is a very small contribution to enforcement, which would be far surpassed by remote surveillance.

Though the ecological footprint of this fishery might be small, it is still a footprint and, given the very small contribution to revenue and enforcement, it is an entirely unnecessary footprint. Given this, the first objective (“to continue managing the fishery in a precautionary manner to ensure long-term sustainability”) should be deleted and replaced by a commitment in the 2018 review to investigate the feasibility of establishing a large scale fully protected marine reserve in the South Sandwich sector of the EEZ to complement the South Orkney marine reserve.

Antarctic krill fishery in the South Georgia and South Sandwich Islands Maritime Zone
The paper notes that there has been very little krill fishing effort in the South Sandwich Islands area in recent years and this means that all krill in that area will have been available to seabirds, whales etc. It also means that revenue to GSGSSI from krill fishing for this area must also have been insignificant.

Outreach and publications
The opportunity to develop a large scale fully protected area in the South Sandwich sector of the EEZ, which is likely to be either the largest (today) or one of the largest fully protected marine areas in the CCAMLR area (depending on future decisions) would bring world attention to the UK’s good custody of this Territory. For the cost of less than 1% of its revenue, the GSGSSI/UK could derive considerable international approval and positive publicity by contributing such a large valuable marine area to CCAMLR’s marine protected area programme. This international approval would be infinitely more valuable than the insignificant revenue forgone.
Virtually all GSGSSI’s revenue comes from the South Georgia part of the EEZ and that the contribution from the South Sandwich marine area is less than 1% of GSGSSI’s income. The contribution two fishing boats (whose movements may well be known to illegal poachers), whose time in the area is brief, and whose field of view is limited, also makes their contribution to enforcement insignificant.
Alternatively there is the prospect of declaring a large scale fully protected marine reserve in the South Sandwich sector of the EEZ.

In proposing the South Orkney Marine Reserve the UK Government said (extracts from SC-CCAMLR-XXVIII/14) ”Any measures which reduce or minimise the direct impacts of human activities on species or habitats will contribute towards the objective of increasing the resilience of those features to the effects of climate change. Although it is unlikely that the effects of climate change can be mitigated altogether, the removal of other pressures will provide the best chance of recovery from climate-related impacts. For example, predators may have a better chance of withstanding a year of low food availability if they are able to forage in an area where prey is not being additionally depleted by a commercial fishery.”

“Implementation of the type of marine spatial protection and management proposed in this paper would be a significant achievement for CCAMLR in contributing to its objective of conservation and rational use of marine biodiversity. By establishing areas where pelagic, benthic and deep water species are given additional protection, CCAMLR has the opportunity to strengthen its precautionary approach in developing a representative network of areas for scientific reference, increased resilience of species to climate change, maintenance of critical ecosystem processes, and conservation of marine biodiversity. The area currently proposed in this paper (South Orkney) would have minimal impact on existing fisheries.”

These arguments are equally applicable to the South Sandwich sector of the EEZ and make a powerful statement in the UK Government’s own words as to why a fully protected marine reserve covering the South Sandwich Islands’ sector of the SGSSI EEZ should be considered as an option for this area.
For all the reasons above a commitment to look specifically at the feasibility of establishing a fully protected marine reserve in the South Sandwich sector of the EEZ to complement the South Orkney marine reserve should be written in to the strategy as part of the review of the MPA envisaged for 2018.


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6 Replies to “It’s not really about money is it?”

  1. Just do it and why not in English waters too? In July 2012, Richard Benyon announced a review of reference areas, or Highly Protected Marine Areas, following receipt of JNCC/NE advice on 127 proposed Marine Conservation Zones. Three years later, we have 37 designated and partially protected MCZs, consultation on a further 23 proposed MCZs, but no published review by Defra or its agencies of the evidence for HPMAs despite what already exists in peer reviewed scientific literature.

  2. Many thanks for this detailed suggestion, Mark.
    It’s very helpful for those of us who want to see the environment and its inhabitants protected but, like me, don’t have the relevant knowledge to make a submission useful.

  3. Done, Facebooked and Tweeted (or whatever the relevant terms for social media sharing are).

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