Memorandum submitted by the National Federation
of Sea Anglers (W25)[1]
1. EXECUTIVE
SUMMARY
Recent Government studies for the first time
highlighted the size and commercial importance of the RSA sector
in the England and Wales. Over one million people participate
in the activity each year and they spend over £500 million
doing do. In the past the diverse nature of the participants have
disguised these vitally important facts and as a result for many
years the sector has had no voice and a major opportunity for
the UK has been missed.
Most of species that RSA target and which drive
the majority of the £500 million related expenditure are
in the main of little financial significance to the commercial
sector and make up less than £10 million of reported fish
landings in England and Wales.
The total commercial landed value of all the
species RSA targets is circa £50 million. Managed correctly
the sectors will not compete.
The SU report recognises both the size and importance
of the RSA sector and the potential within for development if
managed correctly in the future.
The key recommendations within the report relevant
to RSA are:
— Maximise the return to the UK of
the sustainable use of fishery resources. (Page 11, Recommendation
2.)
— Fishery departments should give specific
focus to the management of RSA interests. (Page 13, Recommendation
15.)
— Stakeholder involvement in fishery
advisory groups. (Page 13, Recommendation 16.)
— Experimental Marine Protected areas.
(Page 15, Recommendation 31.)
— Consideration should be given to
designating some species (starting with bass) RSA access only.
(Page 131, Recommendation i.)
To date none of these recommendations has actually
been implemented, but two processes currently underway have the
opportunity to do so. Unfortunately, history has shown all fishery
decisions being taken for the good of the commercial sector, therefore
although RSA is actively involved its confidence levels in a positive
outcome for RSA is low.
The Defra process to manage implementation has
commenced, with the recent distribution of 13 issue papers for
discussion covering most of the SU recommendations and the first
meeting of the Stakeholders Advisory Group (SAG) which is intended
to form and oversee working groups progressing individual topics
to the point of proposals for ministerial approval next year.
There is one major element missing from this
process at this time. Due to the Review of Marine Fisheries and
Environmental Enforcement which is taking place at the same time
Defra have not, as yet, proposed a stakeholder project group to
look at inshore fisheries which is where RSA interests primarily
lie. This appears to be an England only issue but must be resolved
rapidly if effective decisions are to be made in a "joined
up thinking" manner.
The Enforcement Review document, also issued
by Defra, appears to incorporate elements of the SU recommendations
and in particular covers the contentious topic of licensing for
the RSA sector.
NFSA views on the two key topics in this review
are clear and simple:
— Give management control of inshore
fisheries to the Environmental Agency who have a good track record
of understanding Recreational Angling needs and enforcing fishery
regulations. Defra statistics on enforcement actions by the current
SFC structure show virtually no meaningful enforcement at this
time.
— Do not impose a license fee until
actions are in place to improve fish stocks around our shores.
(Our proposed list of actions is listed in Paragraph 3.)
The RSA sector catches fish in an environmentally
friendly way, returns alive the majority of its catch and has
excellent growth potential if managed properly. We request that
the Select Committee uses its powers to ensure that that the SU
recommendations relating to the RSA sector are implemented rapidly
and in full.
The NFSA would welcome the chance, along with
other RSA representative organisations such as SACN and Bass to
answer first hand any questions the Select Committee may have
about the proposals in this document and in particular our assertion
that inshore fisheries enforcement is virtually non-existent today.
2. KEY SU RECOMMENDATIONS
OF RELEVANCE
TO THE
RSA SECTOR AND
DETAILED PROGRESS
TO DATE
The following are the recommendations from
the SU report which the RSA sector identify as key to the future
development of the sector, with some comment as to why and an
update on implementation progress to date:
— The overarching aim of fisheries
management should be to "maximise the return to the UK of
the sustainable use of fishery resources and protection of the
marine environment".
For far too long fishery decisions affecting
the fish stocks around our shores have been taken solely for the
commercial sector. The RSA sector primarily targets a fairly small
group of mostly inshore fish, spending some £500 million
a year doing so. To give examples, the total reported value of
commercial landings for a number of these species in England and
Wales is as follows (Defra statistics).
| Bass | £3.2 million
|
| Conger Eels | £0.16 million
|
| Dabs | £0.085 million |
| Flounder | £0.04 million
|
| Rays | £3.2 million |
| Other | £2.5 million (includes mullet, sharks, tope and smoothound)
|
| Total | £9.185 million
|
| |
The commercial catch value of all the species that RSA targets
is only £50 million yet all the decisions are made today
with the commercial sector in mind because the fishery committees
are dominated by the commercial sector.
The commercial logic for balanced decision making taking
into account all sectors is overwhelming and long overdue.
Implementation of this topic should be via the Defra implementation
progress overseen by the SAG of which we are a member. Deadline
for completion currently 5 April 2004:
— Fishery Departments should reform inshore fisheries
management and give focus on developing the sector, including
explicit management of recreational sea angling interests.
RSA representation on Sea Fishery Committees ranges from
minimal to zero, which misses a real opportunity to develop the
sector. Those committees where a token RSA member has been appointed
are still overwhelmingly controlled by current or ex commercial
fishermen. Well meaning as they may be today's environment calls
for a fresh approach that looks at the resource as a whole for
the benefit of all stakeholders and in particular UK plc. The
resulting decisions have over the years allowed inshore fish stocks
to decline drastically in size and numbers. RSA members want large
fish to incentivise them. Minimum size fish are of little interest.
Progress in this area is dependant upon the outcome of the
Enforcement Review currently in its consultation phase. Due to
this process (and perhaps internal Defra tensions) at first meeting
of the SAG the members were told that no project team would be
set up for Inshore Fisheries, despite there being an issue paper
on the topic. The NFSA formally requested that some form of similar
stakeholder project group be set up to contribute to the outcome.
This is extremely important for the RSA sector as all the most
beneficial SU recommendations for RSA are in this section:
— Fishery Departments should give industry and
other stakeholders clearly defined advisory roles inside the Regional
and Inshore management structures in the form of a formal Stakeholder
Advisory Group.
This has been started for offshore fisheries with the first
meeting recently held. However as outlined in the previous paragraph,
no group has been set up for English inshore fisheries as yet,
which concerns us greatly.
The UK Government and devolved administration should develop
an experimental programme of Marine Protected Areas focussing
initially on areas that will provide benefit to multiple users.
The NFSA welcome the concept of Marine Protected Areas for
multiple access and understand this may well involve some restrictions
such as bag limits for RSA. However, these areas must exclude
net based commercial fishing if the environment is to be protected
and improved. Shellfish fishing using a controlled amount of pots
is not an issue.
Progress on this topic will be via the stakeholder project
team shortly to be established for MARINE Environment Conservation.
— Fisheries Departments should review the evidence
supporting arguments for re-designating some species for wholly
recreational sea angling, beginning with Bass, by the end of 2004.
Current government produced information clearly shows that
a small subset of fish caught by the commercial sector generate
less than £10 million of landed value but make up the majority
of the fish targeted by the RSA sector who spend £500 million
in the process, despite falling size and numbers of fish stocks.
If a handful of species were designated RSA access only, allowing
stocks to recover, the potential for growth in the RSA sector
is significant. Currently UK people pay good money to travel overseas
to catch fish that used to be plentiful around our shore.
Progress on this topic is linked to the Enforcement Review
and issue papers just released, but is severely hampered by the
current lack of stakeholder involvement as mentioned previously.
2. KEY ACTION
POINTS FOR
THE NFSA AND
RSA SECTOR
The NFSA, through its Conservation Group, has developed a
short list of actions that would dramatically improve fish stocks
and encourage a steady increase in RSA activity, as it has elsewhere
in the world when similar actions have been implemented:
(a) Representation commensurate with our commercial importance
and participation level. This would include today much increased
representation on Sea Fishery Committees in the very near term,
such representation to include shore, private and charter boat
anglers and the tackle trade.
(b) Sensible controls on the use of gill nets in inshore
waters and a total ban on their use within one mile of shore.
(Ideally defined as the area covered by the Water Framework Directive)
and around some wrecks to enable predictable access by the RSA
sector.
(c) A "Right to fish charter" in the form of
a requirement on Local Authorities and management agencies to
actively support the RSA sector in any management plans they have
or will develop.
(d) Increased Minimum Landing Sizes (MLS). We recognise
this is largely (but not totally) a CFP issue. However the RSA
sector is much more influenced by the size of fish, where the
commercial sector is driven by total catch weights. The current
trends to fish just over MLS being the norm are hugely detrimental
to the RSA sector and a complete waste of the total commercial
opportunities that could be derived from fish stocks.
(e) Establishment of Recreational Sea Fisheries where
commercial fishing is excluded and recreational angling takes
place under agreed guidelines.
(f) Consideration to be given to the clear commercial
argument that some species be considered RSA only, bass. conger
eels, small sharks, rays and mullet being the prime examples.
These species are of little or no value to the overall UK commercial
sector, but have a huge influence over RSA spend levels.
(g) No inshore trawling within one mile of shore. (Ideally
defined as the area covered by the Water Framework Directive).
This is primarily a habitat protection proposal. The inshore corridor
is a significant migration zone for immature fish moving between
estuaries and deep sea, increasing in size as they do so. Inshore
trawling also has a high impact on shellfish stocks, including
immature lobsters which have not yet reached sufficient size to
move offshore.
(h) Ways should be actively sought to measure and reduce
levels of discards as a measure to improve fish stocks.
The majority of these actions could be implemented by the
current Sea Fishery Committees, which explains the NFSA's enthusiasm
for increased levels of representation and involvement. Give us
some influence and we will improve our inshore fisheries through
the application of knowledge, enthusiasm and a desire for a sustainable
fishery around England's shores.
8 December 2004
1
The NFSA through direct and affiliated membership represents
the views of over 40,000 Recreational Sea Anglers (RSA).
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