As Environment and Conservation Officer, I am representing WFSA in two current Wales Assembly Government initiatives:
The Wales Fisheries Strategy Steering Group and the Stakeholder Advisory Group on the development of a new regime for the management of fisheries in Wales.
There are two new consultations of interest to sea anglers.
Any comments / observation or information can be sent direct to me by e-mail at
caerodyn@hotmail.co.uk.

Irish Sea Marine Conservation Zones  www.mczmapping.org

Welsh Federation of Sea Anglers

Marine Policy Statement: Response to the Pre-consultation

Key questions

The Welsh Federation of Sea Anglers (WFSA) is the governing body of the sport of sea angling in Wales and comprises individual members and members of affiliated sea angling clubs throughout Wales and beyond who fish in Welsh waters.

In preparing our responses, officers have attended meetings on Marine Policy in Exeter and Reading and also taken account of the briefing materials presented at the Welsh Coastal and Maritime Partnership for their meeting in Cardiff.  These topic shave been presented and discussed by the WFSA National Executive Committee in April 2010.  We are grateful for those meetings and for this opportunity to comment at a formative stage.

 

Chapter 1

Aims: WFSA endorses the aims: concern that second aim to “promote sustainable economic development” indicates that economics may override environmental considerations.  Better to ensure that economic development is sustainable.

Marine Plans: noting that Welsh Ministers are the marine plan authorities for Welsh inshore and offshore regions, WFSA asks why there is no Welsh representation on the Irish Sea Marine Conservation Zone Project which covers the offshore zone?  This seems likely to work against any coherent approach to marine planning.  From our point of view – while acknowledging that most of our members fish the inshore waters- the ecology of fish stocks depends upon a commonality of approach to offshore and inshore.

WFSA have committed to the Welsh Fishery Strategy and within that and the hoped for reforms of Common Fisheries Policy expect regional fishery management plans to be very important to achieving our objective of better fish stocks: an area specific policy objective, if you like.  To achieve this it is essential to recognize that Wales Fishery management and enforcement covers more than inshore waters. There is an immediate concern that the apparent recognition of this in this Marine Policy Statement (MPS) is being overridden by arrangements for development of Marine Conservation Zones (MCZ) in both Irish Sea and Celtic Sea where there is no presence of Welsh Recreational Sea Angling nor, and perhaps more importantly, of Welsh Government. Angler stakeholder responses are likely to be very negative in the face of this situation: the overarching MPS being undermined by one of the principal mechanisms of delivering sustainable fish stocks. The sentiments of Paragraph 1.9 are totally negated by the Irish Sea MCZ Project structures.
 

Does the document contain a clear statement of policy objectives
applicable at the UK level for the marine environment? Are there any policy objectives that should be added, for clarity?

Generally, yes, but with significant reservations with regard top the treatment of fisheries as detailed below and some other specific points.

Figure 1 summary is strangely worded in places: e.g. “Biodiversity is protected, conserved and where appropriate recovered and loss has been halted.”  Not easy to understand with the use of  tense here.  What is the baseline for “loss has been recovered” – a super goal but what evidence that it can be achieved?  Shall we see skate as big as table tops in Welsh waters?  Even, or especially, a summary needs to be realistic.

“The coast, seas and oceans ..are safe to use” These will never be other than inherently dangerous: perhaps this should refer only to resources from the coasts, seas and oceans or perhaps you should refer to the user population being better able to use them more safely.

Marine Conservation: a number of commercial and recreational fish stocks are more than under pressure – they have virtually disappeared.  This statement has to be revised to reflect this historical fact or anglers will find it hard to believe that there is serious intent to conserve and improve fish stocks.

Marine Protected Areas: the differences between two Welsh Ministers / Departments in boundaries between inshore and offshore waters viz. with respect to fisheries and to other marine issues, needs to be resolved if MPAs are releated to the MPS aims and objectives.

Fisheries: after all the recent government led consultations in relation top fisheries, WFSA is appalled that in this high level document fish stocks are evaluated solely on the basis of the commercial role.  There ecological significance as species within the marine ecosystem be emphasized.  Additionally, attention should be paid to their societal value for recreational sea angling, which as the many government led studies have indicated has significant economic value, in the case of some species at least as great as the value to commercial catchers.
Moreover, it would be appropriate here to refer to the actual (not just potential) environmental impacts and indeed the need for fishing to be conducted so as minimize adverse impacts on sustainability.

 

Does Chapter 3 set out the key high-level considerations that need to be
taken into account when developing marine plans? Are the most
significant impacts and pressures identified?

Yes and yes, with the following qualifications and comments

WFSA have drawn attention to the disjunction in Wales boundaries between planning fisheries and environment: this needs urgent attention and if the MPS leads to this then WFSA will welcome that.Partly as a consequence of the ministerial disjunction, there has been a breakdown in stakeholder engagement in Wales: WFSA therefore welcomes the emphasis on a participative process.  This has to be inclusive and timely and the procedures adopted within Wales for developing the Fishery Strategy and the New Fisheries Management and Enforcement Regime Stakeholder Role are good examples of how to run these participative processes.

 

Para 3.7: allowing for uncertainty – perhaps here you should emphasise how the precautionary principle will be consistently applied rather than hint at leeway for commercial exploitation.

General Issues: heading order /typestyle need to indicate that the following paragraphs are sub-sections.

 

Does Chapter 4 set out the appropriate considerations for decision making
for the marine area? Does it provide guidance on the factors to consider
for specific activities in reaching decisions?

WFSA welcome the inclusion of fish and fisheries as factors to consider: we should prefer that somewhere there was a specific recognition that recreational sea angling is part of the general consideration of fish and fisheries.  The inclusive term of fishing industry was used in Wales and was carefully chosen after being defined to include recreational sea angling. This point should be made somewhere in this document and  marine planners should be required to give consideration to recreational sea angling.

Fisheries: It is essential that specific mention of recreational sea angling is included in this section.  We have outlined the reasons for this above and they are widely available and known to the UK administrations at least in Wales and England.  WFSA can see no reason why they have not been included but we fear that it indicates that Fishery Policy departments have reneged on agreements with anglers by failing to include our interests here.

Tourism and recreation: in Ch. 2, angling was included in this section.  We prefer it to be under fisheries, but there is some argument for putting it here.  If so, then it is important to recognize that angling –structured and run as a sport with well organised coaching regimes focusing particularly on young people and on women- has further positive socio-economic impacts than those “positive benefits” which merely accrue “to local communities through increased visitors and tourism.”  The individual and community benefits that taking part in angling can deliver have been presented to government in a number of consultations and forums and WFSA is disappointed that there is not recognition of these with thin the MPS guidelines.

“Positive benefit”:  this phrase used in para 4.72 is odd: what is a negative benefit?

 

Does the document provide an appropriate overarching framework for the
development of marine plans and decision-making in the UK marine area?

Is any additional information required at UK level?

Yes broadly and with the reservations and suggestions made in our response, WFSA endorses the draft statement.

Outline Impact Assessment
specifically:

For option 1 –
What costs do you/your organisation incur in complying with
existing systems?

What benefits do you/your organisation enjoy under the
current system?

None reckonable in financial terms although WFSA has been contributing members expertise to stakeholder consultation processes in respect of fisheries protection and management and marine conservation. WFSA has contributed to costs of those exercises and received benefits through knowledge shared in the process.

 

For option 2 –
what benefits do you foresee from having a coherent policy
framework provided by a MPS? Do you foresee any costs arising from having
a MPS in place?

WFSA members and recreational sea anglers in general, will (provided that the final version of the MPS recognizes our activities as worthy of significant mention as detailed in or previous comments) benefit from the MPS in the ways outlined in option 2.  In particular, WFSA will welcome realisation of the Benefit to the environment.

We foresee no additional costs from the objectives of the MPS.

 

Prepared for and submitted on behalf of the Welsh Federation of Sea Anglers by

 

Roger Cook
WFSA Environment and Conservation Officer

Cae’r Odyn
Rhoshendre
Waunfawr
Aberystwyth
SY23 3PX

****

 

Environment & Conservation Report to the EC 17 April 2010

 

WAG New Fisheries Management and Marine Enforcement Regime

The stakeholder advisory group met on 8 March.  We looked at the consultation responses, which were broadly supportive of the stakeholder arrangements developed by this group.  One developing problem is that the WFFA is unlikely to continue having lost funding from WAG /EFF and with its constituent associations looking unlikely to support it themselves.  This may present the commercials with a problem at the top table – and consequently cause instability for the whole regime.  They are trying to develop some interim arrangements.

It looks like the stakeholder advisory group will continue for a few months into the new regime and until the new structures are in place.  There is supposed to be another meeting in April but have had no date so far.

 

Welsh Skate, Ray and Inshore Shark Group, Cardiff, 25 February 2010
They have published some really good identification guides – will bring to the meeting. Some problems with the tagging programme – apparently on of the angling papers carried an editorial or article urging anglers not to return tags as “it was designed to help commercial anglers”.  I think that is rubbish and if anyone has a copy of the article, I’d like to see it so I can reply.  I’d explain that the tagging is about understanding populations of the fish, not to increase exploitation but to provide sound biology so as to be able to manage the stocks in a sustainable way – which will almost certainly mean more protection from commercials.
Otherwise there was poor attendance with no CCW there.  The MSC accreditation of the Bristol Channel is consulting on ways to proceed- really they seem to have no data and want to make guesses (what they call risk based assessments) as to impacts of trawling! I’ll try to get details so we can make our voices heard.

Wales Coastal and Maritime Partnership, Cardiff, 18 March 2010
This meeting was called “The Marine Act: the way forward in Wales” so I know all about that.  There is a newsletter which gives the background and focuses on the marine conservation zone project, Wales.  I’ve already circulated that the EC.  It appears that WCMP has agreed to be the SCEG - Stakeholder and Citizen Engagement Group- whose role is advise on stakeholder engagement in the site selection procedure.  It’s a small group and fishing (both commercial and recreational) is to be represented by Jerry Percy. I don’t think that’s a problem as he will cascade information out and will receive any inputs.  So we need to promote this widely and I have asked Mike to put the newsletter on the web site.  The key thing is that the criteria for site selection were established after consultation.  The next stage will be formal consultation on proposed sites in late 2011.  Before then we must feed in thorough the WCMP and directly via our meetings with WAG.
(Wales is different from England in already having a wide network of sites with some protection –the SACs- and it is likely that the MCZs that will be proposed will within the SACs.  We have to make sure that they protect fish but don’t ban angling.

 

Marine Planning in Wales
There is a workshop to discuss the pre consultation to the Marine Policy Statement (MPS) from the perspective of marine planning in Wales. 
Date: 22 April 2010
Time: 1.30pm until 5pm
Venue: Ty Cambria, Environment Agency Wales, 29 Newport Road, Cardiff CF24 0TP 
http://wales.gov.uk/consultations/environmentandcountryside/premarinepolicy/?lang=en
This pre-consultation paper invites views on proposals for the MPS and provides the framework for preparing marine plans and taking decisions that affect the marine environment in the UK. It will form the basis for informal discussions on developing the draft MPS and the consultation ends on 7 May 2010.  A formal consultation on the policy statement will be held in summer 2010.  
I have reserved a WFSA place but would be pleased if one of you nearer the venue was able to go instead of me……

Irish Sea Marine Conservation Zones
Outside 6nm, MCZs are being run by a group based in England Defra, and this has ignored Wales.  John and I have been insisting that anglers in Wales should be represented directly and not via Angling Trust and WAG have asked for our support in ensuring that Welsh Fisheries are represented too! (It seems like in Wales a different government department is responsible and fisheries have been excluded).

I wrote to the fisheries Minister and Ceredigion AMs –

Dear Assembly Members
 
I am sending you a copy of an e-mail I have just sent to the only recreational sea angler on the stakeholder group considering the designation of Marine Conservation Zones in the Irish Sea.  He is from the English Angling Trust.
 
You will know that the Irish Sea envelopes our coastline, within whose waters all Welsh anglers fish and yet we, the Welsh Federation of Sea Anglers, the National Governing Body for Sea Angling in Wales, of which I am the Environment and Conservation Officer are not represented on this group and have had no role in its formation. 
 
You will perhaps know that there is one seat on the Irish Sea project stakeholder group for a representative of the Wales Assembly Government but no appointment appears to have been made, and I understand there has been no consultation with WAG fisheries people on the project.
 
I know too that the Welsh Federation of Fishermens Associations has not been involved in the establishment of the project.
 
If we are really to manage fish stocks within these broader conservation zones in our new Welsh fisheries zone (generally, to the mid-line) then it is essential that we take a leading perhaps the prime role in MCZs in our offshore waters.
 
This seems to me and my Federation to be a matter of great significance and one that requires urgent action at government level if the Irish Sea project is to take account of stakeholder experience and interests.   WFSA and I am sure the commercial sector fishing from Wales will want to be positively involved.
 
For this to happen, it may be necessary to reconsitute the Irish Sea MCZ project so our involvement can be effective from the beginning of the process.
 
Yours sincerely
 
Elin Jones and Alun Davies are looking into it but I have no news of what they propose to do.

 

Roger Cook
Aberystwyth
16 April 2010

 

 

Environment & Conservation Report to the EC 23 January 2010

 

1. Wales Assembly Government Fisheries Meeting

John O’Connor, Helen Pearce, Mike Dixon and I met with Stuart Evans and his colleagues (and briefly too with the head of Fisheries Graham Rees) in Aberystwyth on 20 January.

We discussed the following topics
1. Introductions
 John O'Connor Chair; Mike Dixon Press Officer/ Personal Members Secretary; Helen Pearce National Angling Coaching Coordinator; Roger Cook Environment Officer

2. How we can get suspected overfishing issues dealt with, in general and based on some specific instances of on-going concern viz: flounder in Dee; crab Menai; thornback Cardigan Bay; bass at Cardiff Bay Barrage (and elsewhere); so-called recreational netting from beaches.
 
3. Sale of Fish
Overfishing issues often relate to sale of fish by non-registered commercials to restaurants and also we think via registered commercial.  Improved control of sale of fish an important way to prevent / reduce over-fishing. 
 
3. Wales Fisheries Strategy: progress and discussion on implementation plans
 WFS is a good framework for the above topics too but worth running through both RSA section and Commercial sections to update / kick start both sides on WAG and RSA led actions.

Arising from this, Stuart undertook to send us most appropriate fishery contacts and to keep this updated through the forthcoming changes.  We can also send him written details about the specific issues.  I have about the Cardigan Bay thornbacks and will about the others.

And regarding the Implementation Plan for the Welsh Fisheries Strategy, Helen is going to write a more readable version for us to work on and link it to WFSA strategic plans.  We agreed to meet again with WAG shortly after the WFSA AGM in March.
 

2. WAG New Fisheries Management and Marine Enforcement Regime

Consultation on this closes on 26 February 2010.  Details at http://wales.gov.uk/consultations/environmentandcountryside/091204seafisheriesframework/?lang=en&status=open
There are six specific questions

Q1. What do you think about the proposed Wales Marine Fisheries Advisory
Group and its role in fisheries management?
“The WMFAG will include senior representatives from national organizations with the organization having the seat rather than the individual member.”  “..interact on a National level with the Fisheries Unit, offering advice and recommendation to the Minister”

Proposed Membership
· Nominated representatives from the commercial fishing industry (for
example Welsh Federation of Fishermen’s Associations or Fishermen’s
Associations)
· Welsh Aquaculture Producers Association
· Welsh Federation of Sea Anglers
· Wales Coastal and Maritime Partnership
· Chairs of IFGs
· Sea Fish Industry Authority
· Wales Environment Link
· Countryside Council for Wales
· Environment Agency

· Welsh Local Government Association
· Other fisheries experts as required

I think this provides serious recognition for the WFSA at the top table, and has flexibility if we have to vary our representative.  If we endorse the proposal we should probably say how we will engage other organizations associations representing RSA in Wales: I’d envisage a formal approach to these to be determined at the AGM and then to offer them access via our WMFAG seat though appropriate mechanisms – to optimise exchange of information and experience in everyone’s interests.  

Q2. Do you think this division of boundaries for Inshore Fisheries Groups?
would be appropriate? If not, where do you think the boundaries should fall?

Below the WMFAG three Inshore Fisheries Groups are proposed: south (Bristol Channel), mid Wales (Cardigan Bay), North (north of Llyn)

Q3. What do you think about the roles of the proposed Inshore Fisheries
Groups? Do you think they would be well placed to develop, in consultation?
with WAG, local fisheries management plans including proposals for local
legislation?

These IFGs will represent local standpoints dealing with local issues, including initiating local management plans “The local IFG will be the voice of local fisheries interests to the WMFAG and Fisheries Unit”.

WFSA has four regions: south west and west probably overlapping the likely boundary between the south and mid IFGs

.Q4. What do you think about our proposal for open membership of IFGs via
correspondence with a focused group attending meetings? Do you think a
membership of 20 people would be appropriate?

Proposal is for open membership by correspondence with group of not more than 20
attending meetings.

Proposed membership is local representatives of
· Fishermen’s Associations
· Independent fishermen
· Recreational angling
· Shell fishing
· Aquaculture
· CCW
· Environmental interests
· Local Authorities
· Local land owners

Q5. Do you think quarterly meetings will be sufficient?

I’d think that, with correspondence between meetings, it may not be necessary for the IFGs to meet every quarter. Maybe, four meetings in the first year with the provision for fewer in subsequent years.
 
Q6. What do you think about the suggested membership of the WMFAG and
IFGs?

 

3. Standardising the Science – Fisheries Management in Wales: 26 January 2010

I’ve been invited to attend this WAG meeting with the following three items, about how to get better evidence about fisheries management - and hopefully about dealing with uncertainty

when data is missing or unreliable.  I think WAG also want to use this as a basis for priorities in their support to outside funding bodies like the EFF.
WAG – setting the scene (I guess about the need in the WFS for better information / science
Bangor University – Science to deliver sustainable fisheries in Wales ( BU get a lot of work from WAG on fisheries)
CCW – Fishing Intensity and Habitat Sensitivity  

4. Article 47 Control of Recreational Fisheries
The new control regulation will form the basis for EU Fisheries management, currently being examined in UK so that it can be put into effect.

The contentious Article 47 now reads (my italics)
1. Member States shall ensure that recreational fisheries on their territory, and in Community
waters are conducted in a manner compatible with the objectives and rules of the Common
Fisheries Policy.
2. The marketing of catches from recreational fisheries shall be prohibited.
3. Without prejudice to Council Regulation (EC) No 199/2008 of 25 February 2008 establishing
a Community framework for the collection, management and use of data in the fisheries
sector and support for scientific advice regarding the Common Fisheries Policy, Member
States shall monitor, on the basis of a sampling plan, the catches of stocks subject to recovery plans by recreational fisheries practiced from vessels flying their flag and from third country vessels, in waters subject to their sovereignty or jurisdiction. Fishing from shore shall not be included.
4. The Scientific, Technical and Economic Committee for Fisheries (STECF) shall evaluate the
biological impact of recreational fisheries as referred to in paragraph 3. Where a recreational
fishery is found to have a significant impact, the Council may submit it to specific management measures such as fishing authorisations and catch declarations.
5. Detailed rules for the application of this Article shall be adopted in accordance with the
procedure referred to in Article 111.

5. England: The Sustainable Access to Inshore Fisheries Advisory Group

Colin sent me this: it’s a consultation on “Steps towards sustainable inshore fisheries” and closes in two months.
It has a good summary of recent changes in fishing management.  It notes that catch from under 10m vessels was seriously underestimated prior to the Buyers and Sellers Regulations giving better recording and therefore emphasizes that this sector will likely be the focus of policy and management as part of sustainable fisheries.  (We have to make sure that it is managed sustainably since we know what a dramatic impact under 10m vessels have on inshore fisheries).

Lots of technical detail in the paper that is interesting and will be helpful in the IFGs.

But no mention of recreational sea angling – even when one proposal is ask “Is there scope for greater social benefits? How might local authorities and other organizations promote inshore fisheries to improve tourist revenues?”

I don’t think we need respond but it is interesting stuff: http://www.defra.gov.uk/foodfarm/fisheries/marine/fishman/saif.htm#pp.  
 

Roger Cook
Aberystwyth
22 January 2010


Marine Conservation Zones
Proposals for new highly protected marine conservation zones (MCZs) will be developed in Wales as part of a UK wide network of conservation areas as in the Marine and Coastal Access Bill.
There are two formal consultations to which anglers should respond.

The first closes on 16 December 2009

Consultation on a Strategy for Marine Protected Areas in Wales: Protecting Welsh Seas
www.wales.gov.uk/consultations / www.cymru.gov.uk/ymgynghoriadau (under environment and countryside).

The second closes on 26 February 2009 and is about specific proposals to protect red throated divers, common scoters and overwintering sea birds.

Liverpool Bay / Bae Lerpwl pSPA Draft Conservation Objectives and Advice on Operations

http://www.naturalengland.org.uk/Images/LivBay-consobj_tcm6-15189.pdf

 

In addition, the Marine Conservation Society has an open consultation on the areas that might be proposed as MCZs.  You can see and comment on these at www.yourseasyourvoice.com   and think about the issues of no take zones in relation to MCZs.

 

I think the concept of MCZs is clearly sensible and there are potential benefits for fish stocks as part of the overall conservation of biodiversity –there is good evidence too (from New Zealand, the Mediterranean and our own bass nursery areas) that no take zones can contribute very significantly to fish stocks. 

But in these new highly protected areas, the big unknown as far as we are concerned is what levels of restriction may be imposed on recreational angling.  The devil is in the detail but details are lacking. 

I don’t want to be alarmist since at all the meetings and discussions I’ve attended most of the proponents of MCZs accept that recreational angling is a legitimate activity and mostly not regarded as a damaging activity. 

 

But read the general statements in the consultation document such as:

“The intention is that (MCZs) will be protected from the extraction and deposition of living and non-living matters, and all other damaging or disturbing activities

and “One of the benefits of highly protected marine sites is by leaving areas of the seas to function in the absence of significant levels of human activity, ….”

Both these statements may worry us: they could so easily be applied to prevent angling. 

On the other hand, in relation to site selection, the consultation notes that sites should be chosen “to maximize ecological and socio-economic benefits while minimising any conflicts with different uses of the the sea as far as possible.”  This could suggest that areas important for recreational angling could be maintained for that as a socio-economic benefit. 

But look at the consultation on Liverpool Bay.  Here to protect red throated divers, common scoters and overwintering assemblages of sea birds, risks to and vunerabilities of the birds have been made. 

Two of the greatest vulnerabilities are listed as boating and “specific extraction of prey species by commercial and recreational fishing”.  It is unlikely that sea angling impacts directly on prey stocks for these birds but that’s not what the assessment says.  We need to make this point in response to the consultation.  (And anglers should note that the area covered in the proposed conservation area includes the whole of the north Wales coast.)

 

So have a look at the information on these three web links and let them know what you think: you could also send comments to me directly to include in the WFSA responses.

I really don’t think angling is an important damaging activity in relation to the conservation goals of these proposals but I am sure we have got to say so – and in some cases may have to recognize some management or restrictions but these must be specific to particular defined problems and not blanket prohibitions.

 

*** Marine Stewardship Council (MSC) Assessment
- Bristol Channel Bass Trawl Fishery ***

I have just received this note about the MSC assessment of the bass fishery in the Bristol Channel: if you follow the links you get information on how they propose to assess the fishery -with a view to deciding if it meets the MSC sustainability criteria.

If you want to comment please do so directly to Jim Andrews or if you have comments you'd like me to send on behalf of WFSA then send them to me, please.  I shall remind them of the arguments made about the need for a 45cm MLS if females are to breed and how important that is to sustainability of the fishery.

The call for comments on this announcement can be found
on the MSC website here.  Full information about this fishery assessment can be
found here.

 

Welsh Fisheries Strategy Implementation Plan
This newly published plan sets out the actions needed to address sustainable fish stock management in Wales.  It is available on the Wales Government website at http://wales.gov.uk/news/latest/090814fisheries/?lang=en


 The WFSA Executive Committee will be considering how we can help deliver on these plans for the benefit of sea anglers in Wales.
New Fisheries Management and Enforcement Regime in Wales
As sea angler stakeholder in the advisory group on the project to deliver a New Fisheries Management and Marine Enforcement Regime, Roger Cook would welcome comments and opinions as the plans develop.  He can then take these on board and try and use them to help in the overall aim of improving fish stocks available to anglers.  The original time-table was for the new regime to take over from sea fisheries committees in April 2010.
 
The New Regime is being developed by professionals in Welsh Assembly Government, Sea Fisheries Committees and so on.  But I am a member of the "Stakeholder Advisory Group" - the formal terms of reference (including members of that group) are and the initial work plan of that group is "Work Plan"
These were approved at the first meeting of the group and a note of that is viewable from this link.

Next meeting (4 September) will decide upon a form for future stakeholder involvement – and, of course, I’ll be seeking to ensure that sea angling continues to be recognised with seats at local and national levels.

 

Environment Agency Consultations

There are three consultation on new fishery byelaws to protect fish stocks relating to eels, trout and salmon and to removal of fish by rod and line; the last one proposes that all eel and shad caught by rod and line in any waters must be returned and that all coarse fish caught by rod and line from rivers, streams, drains and certain named large still waters must be returned with possible exceptions based on (unspecified) species/numbers/sixes and non-natives.


The details are available at
http://www.environment-agency.gov.uk/research/library/consultations
and responses have to be in by 22 September.
As these affect us directly (eels) and indirectly (no-take proposals) we should respond. I’d think that stock conservation as ever should be the yard stick for determining exceptions.  I’d be happy to take members comments in to account in the WFSA submission if you send them to me by the end of August.

Proposals for the scallop fishery in Wales
http://wales.gov.uk/consultations/environmentandcountryside/3256249/;jsessionid=69BCKJGJHK6xhp3y12Lwn2sGJ0HhWpPNc55Jbf4Dpk5mJ8vHhvvq!640458692?lang=en

The Minister has published a consultation document on this – some detailed restrictions and technical proposals that we should consider and submit a response by 25 September.  Again .  I’d be happy to take members comments in to account in the WFSA submission if you send them to me by the 15 September.

Economic value of sea angling
http://www.scotland.gov.uk/Publications/2009/07/27115735/0
In Scotland: New and factual evidence from their government confirming the general view we have in Wales.

 

 

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