WELSH FEDERATION OF SEA ANGLERS Est 1955 Environment & Conservation. |
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Top current issues are (autumn 2011) : Proposals for reform of the Common Fisheries Policy from 2013 Marine Conservation Zones including Highly Protected MCZs in Wales FishMap Môn Wales Marine Fishery Management and Enforcement Under-utilised fish species Carmarthen Bay and Estuaries European Marine Site
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Proposals for reform of the Common Fisheries Policy from 2013 There are two draft WFSA responses Defra consultation
Welsh Federation of Sea Anglers Draft Response to the Defra Consultation on
Proposals relating to the Common Fisheries Policy and the Common Organisation of the Markets in Fishery and Aquaculture Products CFP Reform 1. Are the aims of the CFP set out clearly and appropriately in these proposals, with the right balance between environmental, social and economic objectives? 2. What are your views on the proposed content of multi-annual plans and the Improved investment in the science is essential for this approach to work. For it to be adopted successfully, it seems to us that scientists and fishers should work together: this has the potential advantages of increasing data quality and relevance but more importantly also of enhancing the industry’s willingness to recognize and abide by the scientific evidence. It is particularly important to apply the precautionary principle in respect of fish species not subject to stock management plans: in the search for economic sustainability of the commercial catchers and following campaigns to diversify the species we eat, it is essential to safeguard species for which population data etc is weak or absent. These may be species currently of significance to recreational angling where commercial targeting can have dramatic impacts on stocks. The devolution of management of inshore stocks and the engagement of all stakeholders is key to ensuring that minor commercial species are managed sustainably.
3. Have the proposals got it right on ending fish discards? If not, what changes would you suggest? It is necessary that ending discards is accompanied by measures on minimum selling sizes as these will contribute to sustainability of stocks. For some scarcer species it is clearly necessary to set minimum sizes that allow fish to breed, for others, it may be possible to harvest immature fish. Marketing proposals that allow too small fish to be sold for human consumption will work against sustainability.
4. Do the proposals give sufficient flexibility to manage fisheries on a regional basis, with an appropriate voice for stakeholders? If not, what changes might be necessary?
5. What are your views on the proposal to introduce “transferable fishing I don’t fully understand this proposal and will comment further when I’ve been to the DEfra workshop (4 November 2011).
6. Are the proposals to help develop the aquaculture industry necessary, and the steps suggested helpful?
7. Do these proposals go far enough to ensure the sustainability of EU fishing CMO Reform 8. Do you think that quota management and marketing responsibilities for producer organisations should be brought out and strengthened in the legislation?
9. Are the proposals consistent with current, wider consumer information and 10. Should additional voluntary information’ be included in the proposals? 11. Do you think that intervention mechanisms should continue to be part of the new marketing regulation? (If so what form should this be in e.g. temporary or permanent)
+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ National Assembly of Wales Environment and Sustainability Committee
Welsh Federation of Sea Anglers Proposed Reforms to the Common Fisheries Policy Draft Evidence to National Assembly of Wales’ Environment and Sustainability Committee WFSA has a governing structure consisting of regional sections, and a National Executive Committee meeting quarterly: all officers and members are volunteers. As a Federation, we represent the interests of recreational sea anglers on the Federation of Welsh Anglers and on international angling associations, with observer status at the European Anglers’ Alliance. We have NEC members on the stakeholder committees of the new Welsh Fisheries Management and Enforcement regimes. WFSA members played an active part in developing the Welsh Fishery Strategy. We have representation at the Wales Coastal and Maritime Partnership, and on their Stakeholder and Citizen Engagement Group for the Welsh Government Highly Protected Marine Conservation Zones project. WFSA promotes a conservation approach to angling and has rules and a code of conduct to support this approach in all forms of sea angling. Further details are available via our website at http://www.wfsa.org.uk/. Common Fisheries Policy Reform WFSA is preparing a response to the Department for Environment, Food and Rural Affairs consultation on proposals relating to the Common Fisheries Policy and the Common Organisation of the Markets in Fishery and Aquaculture Products. This response will be completed for Defra by 10
November 2011.
The draft version of that response has been amended by members of the NEC, and forms the basis for this evidence to the ES committee task group. The CFP does not apply to recreational sea angling from the shore but does affect stocks targeted from there. Moreover it does apply to angling from boats. We welcome the opportunity to present written evidence to NAW and will be happy to amplify or explain further if requested. If invited, we would make every effort to provide oral evidence but cannot guarantee the availability of representatives during the working day. The five questions to be considered by the ES task group What the European Commission’s proposals could mean for social and economic viability of coastal communities in Wales? What impacts changes made in the wider fisheries sector in Europe could have on Wales? What should the Welsh Government prioritise in its negotiations on CFP Reform to ensure a beneficial outcome for Wales? How can Wales ensure that its views inform the negotiation process?
Fin fish : under-utilised species Diversification of commercial targets to include presently under-utilised species threatens more of the species we catch: we have seen this recently with flounder, dab and smoothhound whose market prices have all risen but for which species there is little reliable population information and no stock management plans. Nonetheless, we believe there are commercial opportunities for increased income for Welsh commercials from fin fish. WFSA is keen that for such opportunities to be developed there must be regard both to stock sustainability and to the access of anglers to more and bigger fish of the wide range of species we target. But to achieve any potential benefits, it is essential that there is emphasis on stock management and on enforcement in Wales. The reform proposals are likely to encourage self enforcement but it would be naïve to expect all fishers to comply with long term sustainability obligations at the expense of short term personal gain. Therefore, WFSA emphasise that increased levels of enforcement in Wales coastal and inshore fisheries will be essential. It is evident that current activities are constrained by lack of funding. We believe that the proposed reforms to CFP together with the new Welsh Marine Fisheries and Enforcement regime and its associated stakeholder groups could make it possible for such commercial developments to be introduced and managed sustainably but that needs proper consultation and acceptance of the precautionary principle in the absence of sound data. Stock management Much of the CFP reform deals with the few major species subject to quota and uses multi-annual plans and processes to deliver management measures under these plans. We think that the proposed stock management based on planning over several years, within the context of the ecosystem approach and with regard to the precautionary principle, is likely to be better for fish stocks. Therefore, we welcome this approach as one likely to leave more and bigger fish in the inshore and, particularly coastal zones available for recreational rod and line angling. Improved investment in the science is essential for this approach to work. For it to be adopted successfully, it seems to us that scientists and fishers should work together: this has the potential advantages of increasing data quality and relevance but more importantly also of enhancing the industry’s willingness to recognise and abide by the scientific evidence. It is particularly important to apply the precautionary principle in respect of fish species not subject to stock management plans: in the search for economic sustainability of the commercial catchers and, following campaigns to diversify the species we eat, it is essential to safeguard species for which population data etc is weak or absent. These may be species currently of significance to recreational angling where commercial targeting can have dramatic impacts on stocks. The devolution of management of inshore stocks and the engagement of all stakeholders is key to ensuring that minor commercial species are managed sustainably.
Discards WFSA have been concerned for years about the impact on commercial and other fish stocks of commercial boats discarding unwanted fish. We therefore
welcome the proposed phasing out of discarding: but we do not think it goes far enough. The proposal is to oblige fishermen (sic) to land all the commercial species they catch. We consider it is essential that all species caught are landed, if they will not survive being discarded. That is the only way we shall know what is taken and the only way to develop technical solutions to allow sustainable, ecosystem aware catching. It is necessary that ending discards is accompanied by measures on minimum selling sizes as these will contribute to sustainability of stocks. For some scarcer species it is clearly necessary to set minimum sizes that allow fish to breed, for others, it may be possible to harvest immature fish. Marketing proposals that allow too small fish to be sold for human consumption will work against sustainability.
Decentralisation The structures of the new management and enforcement regimes, with their stakeholder engagement, and with the strategic framework of the Welsh Fishery Strategy, are in place to ensure that effective stock management plans can be introduced. This does require continuing political commitment to ensure that adequate financial support is available for professionals. WFSA would also point out that the expertise and experience contributed to stakeholder involvement is contributed free of charge and at the expense of the members themselves. It is important that structures that depend partially on this volunteer input recognize the importance of providing support for the volunteer input through attention to services such as up-to-date information provision and administrative support of stakeholder groups. In this context, we are disappointed that the Welsh Government web pages are slow to update and, still at the time of writing, have no reference to the Welsh Marine Fisheries Management Advisory Group or to its constituent three regional Inshore Fishery Groups. That simply makes it harder for volunteers to become engaged and retain commitment to these structures and undermines the potential of these novel structures.
Transferable fishing concessions The reform proposes to introduce “transferable fishing concessions” (tfc) for vessels over 12m and those which used towed gear and for Member States to decide on allocations and set safeguards on trading. We consider that Wales’ interests will require a different approach from that which will suit the
commercial catching industries of Scotland and England. This is because of the substantial differences in the structure of the Welsh fleet, accurately presented by WAG in its 2010 response to the CFP Green paper in December 2010.
Aquaculture Marine fin fish all require high protein diets with the associated pollutant risks and the need for animal protein inputs. It may be better to focus on species which can be fed with plant products in contained systems rather than sea pens. This has the potential advantage of developing a land-based fish food production industry which could have economic benefits wider than those accruing to current aquaculture systems. Another potential beneficiary of land-based fish food production could be to provide a source of bait for commercial pot fishing for crustaceans. This has often depended upon “under-utilised” fin fish species, notably flounder which has impacted upon stocks and anglers catches. Reliable alternative baits would make a real contribution to enhancing the true sustainability of potting.
Marketing
Government support The best use of these proposals requires Welsh Government to be active in supporting commercial fishery associations so that their members can benefit from collaboration rather than competition in the marketing of their catches. It also requires innovation to capture the higher value of that the Welsh catch should have through sustainable management, local provenance, etc. This needs to be connected with the prohibition of illegal sales through revision of the provisions of the buyers and sellers legislation to reduce exemptions and increase traceability of fish. +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Marine Conservation Zones including Highly Protected MCZs in Wales
Anglers in Wales will also want to know about the MCZs proposed by the Finding Sanctuary and Irish Sea Conservation Zone projects in the south west, including the Bristol Channel and in the Irish Sea in the Welsh offshore zone (beyond 12 nm). These are extensive areas that don’t have such restrictive management schemes as HPMCZs. There will be equivalent no take zones called “reference areas” within these MCZs. There has not been good communication with these projects and representatives from Wales. Details are at : http://jncc.defra.gov.uk/page-2409 ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ FishMap Môn WFSA has been involved in developing fishery policy in Wales for several years and we’ve come to recognise the need for sound information when we argue for sea angler interests. I know we don’t have widespread adverse environmental impacts but that we are hampered by hard evidence of where and when we do what we do. So backing scientists at CCW and at the same time getting European Fishery Fund money into angling-related projects seemed like a win win situation. And WFSA will be part of the group that looks at the data and will have a say in the output – a report and publication. So I’d say we need anglers to help get that information. We also need well informed anglers to get engaged through their clubs and associations in sea fishery management. We really do have the structures that could allow us to make progress – and its needed now as much as ever as commercial interests target “under-utilised species”. More details at: http://www.ccw.gov.uk/landscape--wildlife/managing-land-and-sea/fishmap-mon.aspx ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Wales Marine Fishery Management and Enforcement Anglers who sit on the Inshore Fishery Groups are: South: Mid: Welsh Marine Fisheries Advisory Group
There is a list of contacts for Welsh Government Fisheries at http://wales.gov.uk/topics/environmentcountryside/foodandfisheries/fisheries/contactandlinks/fisheriescontacts/?lang=en. We’ll try to get links through to the minutes and agendas of these groups, but they’re still new and taking a little while to sort out procedures. But these should be a really good way to begin to deal with such problems as how to ensure our fish stocks are improved and that commercial interest in previously under-utilised species does not damage these stocks. +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
Under-utilised fish species I’ve prepared a table with a list of those species that CEFAS scientists think are most likely to be sustainable for commercial fishing. What do you think? We can start to form a policy about these to take to the Management regimes to try and get some sort of management regimes in place that will allow fish to survive.
+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Carmarthen Bay and Estuaries European Marine Site
Text submitted online to the Carmarthen Bay & Estuaries European Marine Site Management Scheme Consultation The Welsh Federation of Sea Anglers (WFSA) welcomes the detailed and balanced approach proposed in this management plan. We congratulate the author and RGA both on the content of the consultation documents and on their form and accessibilty (thoough this comments box would be better if larger!) With regard to Technical Annexe 1 4.2.8 and Tables 4.1 and 4.2, WFSA is comfortable with the level of assessment and with the proposed management actions both for angling and for bait collection activities. WFSA wil be happy to work with the management in developing aspects of the management where this will be appropriate e.g. through educational and information activities. Nonetheless, with regard to Technical Annex 2 5.1.4 Recreational sea angling, we find some of the threat assessment too anecdotal. Flounder stocks are particularly vulnerable to short periods of intensive netting and we consider this to be more likely to account for depletion than angling. Similarly, the impact of angling on sandeel populations is likely to be insignificant compared to the industrial scale commercial catches. Appendix 4 These comments have been submitted after consultation with the WFSA National Executive Committee by Roger Cook, WFSA Environment and Conservation Officer. 13 October 2011
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