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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 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.
Does Chapter 3 set out the key high-level considerations that need to be 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 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 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 For option 1 – What benefits do you/your organisation enjoy under the 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 – 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 Cae’r Odyn ****
Environment & Conservation Report to the EC 17 April 2010
WAG New Fisheries Management and Marine Enforcement Regime 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 Wales Coastal and Maritime Partnership, Cardiff, 18 March 2010
Marine Planning in Wales Irish Sea Marine Conservation Zones I wrote to the fisheries Minister and Ceredigion AMs – Dear Assembly Members
Roger Cook |
Environment & Conservation Report to the EC 23 January 2010
1. Wales Assembly Government Fisheries Meeting We discussed the following topics 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. Q1. What do you think about the proposed Wales Marine Fisheries Advisory Proposed Membership · Welsh Local Government Association 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? 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 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 Proposal is for open membership by correspondence with group of not more than 20 Proposed membership is local representatives of 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.
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. 4. Article 47 Control of Recreational Fisheries The contentious Article 47 now reads (my italics) 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. 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 |
Marine Conservation Zones The first closes on 16 December 2009 Consultation on a Strategy for Marine Protected Areas in Wales: Protecting Welsh Seas 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 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
Welsh Fisheries Strategy Implementation Plan
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.
Proposals for the scallop fishery in Wales 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
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