Memorandum submitted by the National Association
of Fisheries and Angling Consultatives
SUMMARY
S.1 The National Association of Fisheries
and Angling Consultatives is the national body for some 350,000
anglers and fishery owners represented by fisheries and angling
consultatives in England.
S.2 Our chief concerns in relation to the
Environment, Food and Rural Affairs Committee's Inquiry into the
Water Framework Directive are
(a) the need for a systematic, ecological
approach to the protection of the water environment as envisaged
in the Directive, and:
(b) environmental improvement being subject
to the concept of "disproportionate expense".
S.3 NAFAC believes that:
(a) with its broader, ecological approach
the Water Framework Directive is:
(i) the essential tool for dealing with
existing pressures on the aquatic environment and for managing
new pressures resulting from a growing economy and social aspirations;
(ii) central to sustainable development.
(b) timescales set out for implementation
of the Water Framework Directive should be regarded as the worst-case
scenario not minimum compliance requirements;
(c) substantial improvement in ecological
quality should occur well within the timescales laid down by the
Directive;
(d) in the implementation of the Water Framework
Directive there is a need for the development of—
(i) a clear, robust methodology for assessing
the value of natural environments and the costs associated with
environmental degradation;
(ii) a mechanism for assessing environmental
costs and values against the benefits of proposed schemes which
impact on the environment;
(iii) clear identification for the decision
making process for determining whether costs of protecting the
environment are disproportionate or not;
(iv) a requirement on the promoters of
any development to demonstrate that the benefits of the development
do, in fact, exceed the costs and benefits of keeping the affected
environments in being.
1. NEED FOR
THE WATER
FRAMEWORK DIRECTIVE
1.1 NAFAC strongly supports the central
purpose of the Water Framework Directive: viz. the promotion of
the sustainable use of the water environment through new, broader
ecological objectives, designed to protect and, where necessary,
restore the structure and function of aquatic ecosystems themselves.
This underlying concept of the Framework Directive appears to
have a great deal in common with approach advocated by NAFAC over
the last decade for the statutory protection of fisheries as required
today under Section 6(6) of the Environment Act 1995. This view
is based on the concept that:
(a) "fisheries" in freshwaters
should be considered to be "aquatic ecosystems in which fish
are, or, in natural circumstances, would be, the highest form
of life living wholly in the water"; and
(b) fisheries are protected through the management
of the factors which affect the aquatic ecosystem to ensure they
are sustainable.
1.2 River fisheries are possibly the most
extensive ecological resources in the country. Together with their
associated wetlands and floodplains they provide habitats for
a huge number of species of plants, animals, birds, insects and
fish, and they constitute long, continuous corridors for wildlife.
Although there are a large number of plans and strategies for
dealing with pressures which affect these aquatic ecosystems,
such as Biodiversity Action Plans, Salmon Action Plans, River
SSSIs, Structure Plans, Countryside Stewardship Schemes, Water
Level Management Plans, there is no clear framework for integrating
these initiatives or ensuring that all the pressures on the water
environment are tackled in a systematic and comprehensive manner.
1.3 NAFAC has supported the concept of Fisheries
Action Plans, first proposed in submissions to the recent Salmon
and Freshwater Fisheries Review, to provide the required framework.
The idea fits well with the shift to ecologically defined objectives
and river basin management planning introduced by the Water Framework
Directive. We consider that Fisheries Action Plans should constitute
crucial sub-sets of the River Basin Management Plans required
by the Directive, and be developed as such.
1.4 Although NAFAC's main interest is in
the freshwater environment, we recognise that estuaries and tidal
reaches of rivers can contain important populations of freshwater
fish, and estuaries and coastal waters are important feeding areas
for migratory salmonids. Some marine species such as shads migrate
into freshwaters and tidal reaches of rivers around the United
Kingdom comprise nursery grounds for marine species of international
importance. Estuaries and tidal reaches of rivers also contain
a wide range of plants and inter-tidal habitats, and support important
populations of birds and invertebrates. Despite their ecological
importance the statutory protection of these areas is relatively
weak. The inclusion of tidal waters within the remit of the Directive
is therefore very welcome.
1.5 NAFAC believes that:
(a) with its broader, ecological approach
the Water Framework Directive is:
(i) the essential tool for dealing with
existing pressures on the aquatic environment and for managing
new pressures resulting from a growing economy and social aspirations;
(ii) central to sustainable development.
2. TIMETABLE
2.1 For over 100 years anglers have been
in the forefront of observing the effects of economic and social
pressures on the water environment. NAFAC and other fisheries
and angling organisations have been pressing for improvements
in the management of these pressures for many years.
2.2 Improvements in water quality over the
last few decades has been an environmental success, but the length
of time it has taken to achieve this has been greatly frustrating
to fisheries and angling interests. "The first (and only)
effective step taken by the Government" for example, "to
identify and control sources of river pollution was the statutory
authority given in 1923 for example. to "worm and bent-pin"
anglers to levy a rod tax on themselves." [1]It
has taken a long time for the benefit of that commitment to be
fully realised.
2.3 It is now generally recognised that
other factors, such as poor flow management, over-abstraction,
degraded river morphology, poor habitat diversity, and inappropriate
use of floodplain land are equally important influences on in-stream
environmental quality. Fisheries and angling interests have been
highlighting these problems for almost as long as they have been
trying to tackle pollution. The fact that the Water Framework
Directive lays down specific timescales for improvement is therefore
very welcome.
2.4 However, Governments should not be looking
for ways of prolonging or emasculating implementation, such as
occurred with 78/659/EEC On the quality of fresh waters needing
protection or improvement in order to support fish life. Regulatory
bodies, such as Ofwat, also need to be sensitive to environmental
needs if we are not to encounter the same long delay in achieving
satisfactory environmental quality.
2.5 NAFAC therefore believes that:
(a) timescales set out for implementation
of the Water Framework Directive should be regarded as the worst-case
scenario not minimum compliance requirements; and
(b) substantial improvement in ecological
quality should occur well within the timescales laid down by the
Directive.
3. COSTS
3.1 Implicit in the concept of sustainability
is the assumption that all the costs, including environmental
costs, of a good or service are fully reflected in the price of
the good or service. Failure to price any specific goods or services
distorts demand and sends misleading signals to the market. The
fact that environmental costs are not included in the price of
a good or service does not mean that they do not exist. What is
happening is simply that they are transferred elsewhere, effectively
providing a subsidy for the good or service.
3.2 NAFAC is concerned about the idea of
"disproportionate expense" which underlies some of the
requirements of the Water Framework Directive. "Disproportionate"
is very much a subjective concept, which has varied greatly over
time. In debates about the Salmon Fishery Act 1861, for example,
a Member of Parliament "protested against damaging the commercial
interests of the country for the sake of preserving a few fish".
Society may have moved on from such an attitude, but there is
still no mechanism for objectively deciding if something is too
expensive or not.
3.3 At present, the discipline of environmental
economics is not very well developed. No matter how sophisticated
they may be, methodologies such as contingency cost evaluation
amount to little more than asking the public what it thinks something
is worth. This contrasts strongly with the systematic, calculated
ways of evaluating the costs and benefits attached to any capital
project.
3.4 Such approaches do not take into account
the intrinsic value of a natural environment. It is arguable that
the benefits of natural environments can only be realised by keeping
them in being, and the cost of keeping them in being is a measure
of their value. However, the promotion of a development that would
result in deterioration in environmental quality or the continuation
of poor environmental quality implies an estimation of the value
of the environment. It would seem reasonable that the promoters
of the development should be required to demonstrate that the
benefits of the development do, in fact, exceed the costs and
benefits of keeping the environment in being.
3.5 From the information NAFAC has been
able to gain so far it is not clear as to how the concept of "disproportionate
expense" would work under the Framework Directive, and who
should be responsible ultimately for deciding if something is
too expensive or not. Ofwat, for example, has been criticised
for refusing on cost grounds to permit environmental improvements
to surface waters that fisheries interests, conservationists,
the Environment Agency and the water industry agreed were necessary
in the AMP3 process.
3.6 NAFAC therefore believes that:
(a) in the implementation of the Water Framework
Directive there is a need for the development of—
(i) a clear, robust methodology for assessing
the value of natural environments and the costs associated with
environmental degradation;
(ii) a mechanism for assessing environmental
costs and values against the benefits of proposed schemes which
impact on the environment;
(iii) clear identification for the decision
making process for determining whether costs of protecting the
environment are disproportionate or not; and
(iv) a requirement on the promoters of
any development to demonstrate that the benefits of the development
do, in fact, exceed the costs and benefits of keeping the affected
environments in being.
National Association of Fisheries and Angling Consultatives
20 September 2002
1 The Fisherman's Struggle Against Pollution, Trent
Fishery Board, 1947. Back
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