The WWF - which says the proposals do not go far enough - last week accused the department of dereliction of duty and said it should be split to create a separate agency dedicated to conservation.

However, the AFCD responded that it had a duty to strike a balance between marine conservation and fishermen's livelihoods.

Dr Sadovy said subsidies such as the loans and training given by the AFCD to fishermen should be halted. 'Subsidies are recognised worldwide as one of the major factors leading to and exacerbating overfishing.

'It runs counter to Hong Kong's free market approach. Without subsidies, if there are not enough fish, the fishery collapses because it cannot support itself. Subsidies allow continuing declines, which is what has happened here. Without subsidies we would have a better fishery.'

She also argued that the introduction of artificial reefs to try to build up fish stocks may be speeding up the decline in numbers.

'It is true they attract and concentrate fish but this concentration makes fish easier to catch and further depletes the fishery. In the Philippines, artificial reefs are now banned because of such concerns.'

A spokesman for the AFCD said credit facilities and training were 'mainly provided to help fishermen turn to sustainable fisheries such as offshore fishing'.

Loans for fishermen to build new trawlers had been halted since 2002.

The AFCD had 'taken the initiative' in acting to prevent further falls in fish stocks 'as soon as the trend of shrinking catches became apparent in the mid 1990s'.

'We completed the Consultancy Study on Fisheries Resources in 1998, which as a baseline survey established clear evidence of over-fishing in Hong Kong waters,' he said. 'Since then we have been working on suitable measures to address the problem.

The study recommended six management measures which the AFCD had implemented, including artificial reefs and fish restocking through a fish fry releasing trial.