Top current issues

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

 
 

European Fishery Fund / Bangor University Fish Stock

http://fisheries-conservation.bangor.ac.uk

"This new project aims to describe sustainability of fishing in Wales. 
It is supported by WFSA and this web link will provide all the details. 
We'll be asking members to get involved by supporting the surveys, expecting that the research will provide sound information for future management of fish stocks, including bass.
Please contact our Environment and Conservation Officer, Roger Cook, with any questions, comments and suggestions and he'll feed them into to the scientists doing the work."

Information from Bangor University about their bass survey, follow link

Bass information from the European Anglers Alliance

Latest Information regarding MCZ areas

Link to final Stakeholder Information

 

Want to have your say?

Our seas are become increasingly crowded. We want to manage them in a more joined up and planned way to ensure that Wales gets the most out of them.

What is marine planning?

Marine plans help manage marine activities in a sustainable way considering economic, social and environmental issues.
The plans will clarify marine objectives and priorities. We are responsible for creating marine plans in Wales.

Public events in March

The eight week consultation on the Statement of Public Participation (SPP) on the Welsh National Marine Plan is underway. The closing date is Friday 28 March.
Our public events are being held in March and you have the opportunity to come along between 2:00 and 8:00 pm at the following locations:

  • Tuesday 4 March - Wales Millennium Centre, Cardiff
  • Wednesday 5 March - Torch Theatre, Milford Haven
  • Wednesday 12 March - The Pavilion Theatre, Rhyl
  • Thursday 13 March - The Celtic Royal Hotel, Caernarfon.

Stakeholder event

A stakeholder event will be held between 10:00 am – 4:00pm on Tuesday 18 March Aberystwyth University.
You can register to attend (external link) online.

Keeping up to date

You can up to date by subscribing to our newsletter or following us on twitter following us on twitter (external link).
You can find information on Marine licencing (external link) on the Natural Resources Wales website.

Carmarthen Bay and Estuaries European Marine Site
WFSA recently submitted a response to the consultation on the proposed management scheme for this site.  The consultation was on line and I’m not sure you can yet see our response there,  But its an interesting though very long set of electronic documents and the detail in the management scheme has to be seen to be believed (http://english.cbeems.org/).  It gives an indication of how demanding such schemes can be to write let alone to implement.

 

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.
Nevertheless, these two examples do serve to emphasise the need for gathering data and monitoring activities, which we agree is appropriate.

Appendix 4
Liaison Forum / Interest Groups
Stakeholders with fishery interests could be included in these effectively by inviting representation from the WG Inshore Fishery Group - South and/or establishing an appropriate relationship with that group.  Alternatively, WFSA would consider nominating representative(s) at the appropriate level of stakeholder engagement.

These comments have been submitted after consultation with the WFSA National Executive Committee by Roger Cook, WFSA Environment and Conservation Officer.

13 October 2011

 

 

Proposals for reform of the Common Fisheries Policy from 2013

There are  two draft WFSA responses

Defra consultation
I’m going to a workshop about the proposals on 4 November and will finalise the response after then and before the deadline of 11 November.  The consultation document is http://www.defra.gov.uk/consult/2011/08/10/cmo-cfp/

 

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?
Yes, the aims of the CFP are now targeted to sustainability of fish stocks and to integrate the management of stocks with sustainability of coastal communities as apart of the ecosystem.

2. What are your views on the proposed content of multi-annual plans and the
process to deliver management measures under these plans?
We think that 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 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?
Phasing out discarding is welcomed: 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. 

 

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?
We welcome decentralization of fisheries management: it is essential that localized management engages all stakeholders, not only commercial catchers but including recreational anglers, hobby fishermen, and others with a stake in the marine environment, if genuine ecosystem based management approaches are to be developed.

 

5. What are your views on the proposal to introduce “transferable fishing
concessions” for vessels over 12m and those which used towed gear? Are the
provisions for Member States to decide on allocations and set safeguards on
trading appropriate/sufficient?
We are not comfortable with the potential trading of these among the industry as emphasized by the example that they may serve to provide retiring fishermen with a pension pot.

I don’t fully understand this proposal and will comment further when I’ve been to the DEfra workshop (4 November 2011).
It looks like there’ll be opportunity for Welsh Government to tailor the rights as it sees fit within the Welsh fleet.

 

 

6. Are the proposals to help develop the aquaculture industry necessary, and the steps suggested helpful?
Yes but we believe that aquaculture has to look beyond marine species if it is to be environmentally sustainable.  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.

 

7. Do these proposals go far enough to ensure the sustainability of EU fishing
activity in external, non-EU waters? If not, what other measures are necessary?

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
labelling requirements? (If not, how should they be made consistent or will they place additional burdens on the industry).

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)
Better prices are essential for the economic and sustainable success of the commercial sector.  Marketing to achieve this requires better informed consumers with information available relevant to sustainability at all outlets for fish consumption.   Of course, recreational anglers do not sell fish but some do eat some of the fish they catch.  Improvements in marketing commercial catches should go hand in hand with limiting sales of black fish and decentralised management of fisheries, including all sales, may be the best way forward.

 

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National Assembly of Wales Environment and Sustainability Committee
This committee is holding an enquiry into impacts of CFP reform in Wales and asked for evidence by 21 October 2011.  WFSA have prepared the attached for submission and hope we may get the chance to give oral evidence later on.

 

Welsh Federation of Sea Anglers

Proposed Reforms to the Common Fisheries Policy

Draft Evidence to National Assembly of Wales’ Environment and Sustainability Committee
 
WFSA
The Welsh Federation of Sea Anglers (WFSA) is the national governing body of the sport of sea angling in Wales. Many sea angling clubs and associations in Wales, and some from England, representing thousands of anglers, are affiliated to WFSA, which also has several hundred individual members.

WFSA has a governing structure consisting of regional sections, and a National Executive Committee meeting quarterly: all officers and members are volunteers.
WFSA organizes national teams of anglers for international competitions from shore and in boats and team managers are members of the NEC. 

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 Wales and the management of Welsh Fisheries Zone and in particular whether the Commission’s proposals to decentralise the management of fisheries will be of benefit to Wales?

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
WFSA is principally concerned with fin fish and the impacts of the CFP on these, whereas much of the Welsh commercial catching sector is dependent upon crustacea. 

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
The proposed reform of the CFP strikes a balance between environmental, social and economic objectives and appears to target sustainability of fish stocks and to integrate the management of stocks with sustainability of coastal communities as apart of the ecosystem.

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
We welcome decentralisation of fisheries management: it is essential that localised management engages all stakeholders, not only commercial catchers but including recreational anglers, hobby fishermen, and others with a stake in the marine environment, if genuine ecosystem based management approaches are to be developed. We consider that, in Wales, we are well placed and structured to develop sustainable fishing with particular benefit to recreational sea angling, including the development of angling-linked tourism. 

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.

Generally, WFSA is not comfortable with the potential trading of these tfc among the industry as exemplified by the proposal that tfc may serve to provide retiring fishermen with a pension pot.  We do not fully understand the likely consequences for stock management nor the likely impacts on the Welsh commercial fleet and individual fishers, but would press for Welsh Government to have the power to tailor the rights to fit sustainability of Welsh stocks and of the Welsh commercial fleet.

 

Aquaculture
There are proposals to help develop the aquaculture industry: we think these could be valuable contributors to coastal communities but that Wales should take the opportunity to look beyond aquaculture only of marine species if it is to be environmentally sustainable. 

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
There are a number of proposed reforms to fish marketing.  WFSA considers that
better prices for catches are essential for the economic and sustainable success of the commercial sector.  Marketing to achieve this requires better informed consumers with information available relevant to sustainability at all outlets for fish consumption.   Of course, recreational anglers do not sell fish but some do eat some of the fish they catch.  Other unlicensed fishers catch and sell fish through local contacts (so-called ‘black fish’).  Improvements in marketing commercial catches should go hand in hand with stopping the sale of “black” fish.  Decentralised management of fisheries, including all sales, may be the best way forward.

 

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.

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Marine Conservation Zones including Highly Protected MCZs in Wales
In Wales, a very high proportion of our seas and coasts have some degree of protection already.  It is planned that 3 (or 4) small highly protected marine conservation zones will be used to augment these. These HPMCZs will have nothing taken out and nothing put in: so no angling and will be used for observation of ecological responses.
There will be consultation in early 2012 on a suite of possible sites (perhaps about 12) from which the final 3 or 4 will be chosen. The consultation will take into account “socio-economic factors” – in our case angling so as to minimise impacts.  So we’ll be responding to those in due course. 
I do sit on a group organised by the WCMP to provide stakeholder input into the Welsh project so am up to date with what’s happening here. http://wales.gov.uk/topics/environmentcountryside/consmanagement/marinefisheries/conservation/protected/conservationzones/project/engagement/;jsessionid=HV3RTp2CjwyF5f1p2H3TqNLmrW4D8ywhj6dynqbVyXfKN3yvGjnj!1905156274?lang=en

 

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

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FishMap Môn
This European Fishery Funded project is run by a partnership led by Countryside Council for Wales (CCW) and including WFSA. CCW have a good record in initiating surveys on recreational sea angling.  This project is limited to Anglesey and is important because it may prove to be a model for fishing and environment mapping in all Wales.

 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

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Wales Marine Fishery Management and Enforcement
We’re involved with Wales’ new fishery management and enforcement regimes as part of the stakeholder groups.
There are WFSA and SWWASAC anglers on the three Inshore Fishery Groups and the WFSA Chair is at the top table - the Welsh Marine Fisheries Advisory Group. 

Anglers who sit on the Inshore Fishery Groups are:

South: 
Paul Thomas (WFSA) tomowales@penarth14.freeserve.co.uk
Lyndon Lammas (SWASAC)
Alan Duthie (SWASAC)

Mid:
Karl Worral (WFSA) worrall116@btinternet.com
Roger Cook (WFSA) caerodyn@hotmail.co.uk

North:
Hefin Jones (WFSA) gruffydd.jones@mypostoffice.co.uk
Mike Flynn (WFSA) flynnmike2004@sky.com

Welsh Marine Fisheries Advisory Group
John O’Connor (WFSA) aardvet1@gmail.com

 

There is a list of contacts for Welsh Government Fisheries at http://wales.gov.uk/topics/environmentcountryside/foodandfisheries/fisheries/contactandlinks/fisheriescontacts/?lang=en.
But if you have any questions or information about illegal fishing or aspects of fishing in Wales that look wrong, please contact on eof the angler IFG reps, in the first place.

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.

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Under-utilised fish species
Lots of the chefs and journalists promoting new fish experiences seem not to realise how little sound science there is about them and how easily a couple of passes with nets could wipe out stocks of some of them in some places. 

I’ve prepared a table with a list of those species that CEFAS scientists think are most likely to be sustainable for commercial fishing.
Top targets are said to be : red gurnard, red mullet, pouting, flounder, John Dory, dab, and tub gurnard.

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.

 

 

 

 

 

 

 

Latest News

Seeing the concerns in these emails following the BFM report circulated by John O'Connor, I hope it will be useful to outline the situation in Wales  from today re the bodies developing proposals for Marine Conservation Zones that affect Welsh waters.  I'm sorry its a long mail but it is a complex situation.  I've tried to include the latest links for up to date information.  Maps of the England MCZ areas which allow you to see whats being planned for where are available at http://www.mczmapping.org/ 
 
Finding Sanctuary: (south west and south Wales offshore):  no Welsh government or angling representation. Plans well advanced see:  http://www.finding-sanctuary.org/page/home.html.  Welsh anglers may be surprised to see their Bristol Channel and west marks being considered by this project!
 
Irish Sea Conservation Zones: affecting Welsh offshore (outside 12 nm waters and neighbouring English and Irish off and inshore waters): no Welsh government representative.  The responsible Welsh Minister is Jane Davidson;  on 4 June 2010, after considerable probing by Nerys Evans AM, the Minister wrote to Nerys:
 
"Officials (of her department) have been approached about membership of the Regional Stakeholder Group.  (The ISCZ) offer of membership to my officials was that they nominate an official (or a non-Welsh Assembly Government individual/organisation) who is able to represent all interests in Wales. 
 
I am sure you wil understand that it is not possible or appropriate for one individual or one organisation to represent all interests from Wales....My officials have advised the ISCZ project of this and offered to assist in identifying appropriate representation from Wales. (to be discussed in future meetings between WAG, DEFRA and ISCZ: no more news of the outcome!)
 
Officials have already agreed with the ISCZ project that WAG will have prior notice of key draft documents in order to consider how they impact on Assembly Government policies."
 
So it does not look as if the WAG and ISCZ are getting on very well!
 
It is true that John Amery has contacted us but only after we started to make a fuss about lack of any Welsh representation and then only by sending project approved information - not sharing real concerns or briefing himself on our concerns in time to do anything about them. 
 
The new ISCZ Liaison Officer for Merseyside, Cheshire, Wales and the Isle of Man is Chris Egan and he will be happy to answer any questions that you might have about the Project. His contact details are: c.egan@irishseaconservation.org.uk or 07891 842 282.  

The First Progress Report on potential MCZ in the Irish Sea project area is now available to download from http://www.irishseaconservation.org.uk/node/92

The project team have stressed that the potential Marine Conservation Zones by the Regional Stakeholder Group are tentative, based on limited information, liable to change and only considers offshore ‘broad-scale’ habitats on the seabed: mud, sand, gravel and rock. It does not yet consider inshore habitats.

The project team has requested comments using their comment form from the First Progress Report page of the website, www.irishseaconservation.org.uk , or request it by calling 01925 813 200 or emailing info@irishseaconservation.org.uk .

 
Welsh Inshore waters:
Wales Assembly Government appointed the Wales Coastal and Maritime Partnership to establish a Stakeholder and Citizen Engagement Group (SCEG) to be resposnible for Welsh public and sectoral involvement with MCZ site selection in Welsh inshore waters to 12 nm. This SCEG was established early this year and I have just been asked to join as representing Welsh Federation of Sea Anglers.  I have agreed to do this and my first meeting will be very soon.
 
As I understand it 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.
(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.
 
I shall also use this SCEG to draw attention to the problem with the ISCZ project (and I suppose that the Finding Sanctuary one also presents the exact same issues for Wales)
  
Details at: http://wales.gov.uk/topics/environmentcountryside/consmanagement/marinefisheries/conservation/protected/conservationzones/?lang=en

 
WAG New Fisheries Management and Marine Enforcement Regime

There are no longer any SEa Fisheries Committees in Wales! Inshore fisheries management and enforcement is now the responibility of WAG.

The Stakeholder Advisory Group (SAG - I represent WFSA) met again – at last - on 12 July.  WAG Fisheries have had a lot on their plate and staff illnesses and cut backs have not helped.  The new regime is reportedly up and running with 23 staff, 2 vessels plus ribs and land vehicles, offices storage and berthing all transferred from the Sea Fisheries Committees.  And £1.65m has been incorporated from SFC into WAG Fisheries budget. The staff are presently reviewing byelaws that are in areas of immediate risk.
WFSA should have a seat (the Chairman) at the top table: but the stakeholder arrangements are not yet in place: there will be another meeting of the SAG in September to try to get the top table Wales Marine Fisheries Advisory Group established after input from from the Minister (Elin Jones)  and to progress the appointment in accordance with the Nolan principles of a Chairperson or of an interim chair. The three regional Inshore Fisheries Groups will then be established and should be really useful for anglers to promote sustainable fish management programmes.

 
Finally,

It does seem to me that the conservation organisations really believe that angling-and indeed all hobby and commercial catching- has the same impact on the marine environment as dredging and trawling.  So they - see the Marine Conservation Society and Co-op promotion-seek to establish zones where no fish can be caught or taken: have a look at http://www.co-operative.coop/ethicsinaction/takeaction/Marine-Reserves/ and vote! Their suggestions include such important areas as the reefs in west Wales: my own patch and where I do not believe there is sound evidence that angling has significant detrimental impact.  Indeed much of the commercial catching (mainly potting) probably has little if any impact.  Certainbly none that can't be managed with less draconian approaches than establishing large no take zones covering what is virtulaly the only area of the inshore waters with any fish! 
 
In Wales, we should talk more with CCW who have a real interest in defining angling and environmental impacts and provide scientific advice to WAG. Colin Charman is their new Sea Fisheries Liaison Officer and can be contacted at: c.charman@ccw.gov.uk 

Anyway, and to come back to the BFM article that prompted your interest, if we are going to have anywhere left for recreational sea angling, it is not is going to be enough just to attend meetings: nor will it be enough to respond to consultations -though that is very important.  We must individually and together engage in the discussions, lobby the politicians question the scientists and input into policy as much as we can.  Otherwise the consulations will be meaningless exercises and we have seen in Wales, over the new fisheries management regime, how difficult it can be to change views taken by politicians before they consult!
 
In Wales, I believe we nearly have the framework for anglers to have proper input: lets hope we can sort out the Devon and Irish Sea areas soon and then we can focus fully on the new EU common fisheries policy!
  
Please get in touch and keep me informed.
 
 
 
Roger Cook
Environment and Conservation Officer
Welsh Federation of Sea

 

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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