Memorandum submitted by the Sea Anglers'
Conservation Network (W02)
1. THE NEED
FOR CHANGE
1.1 For a considerable period of time technological
advances have considerably increased mankind's ability to extract
the creatures of the sea leaving no hiding place, whilst causing
irreparable damage to the marine environment that supports the
ecological web that generates and regenerates future stocks.
1.2 If the marine environment were to be
fully restored and sympathetically harvested, in many cases the
annual sustainable harvest would greatly exceed the remnant stocks
that are now available.
1.3 We have now reached the stage where
decline in fish catching is inevitably leading to a slow collapse
in the fishing industry, with an attendant loss of value and employment,
not just for this generation, but for numerically increasing populations
yet to come.
1.4 Rather than focusing efforts in cushioning
the effects of collapse upon the fish catching industry, there
is a need to refocus efforts into halting and reversing the decline
in the marine ecosystems, so that maximum value can be made available
for sustainable benefit into the distant future.
1.5 To achieve this will require a new mindset
and culture to be adopted by fishery managers and responsible
politicians, with previous unhelpful "baggage" abandoned.
1.6 To bring about necessary change, things
in the future must be done differently to how things have been
managed in the past. There is a need to confront the unthinkable
and boldly face reality.
1.7 The report by the strategy unit is to
be congratulated in its appreciation that the problems to be addressed
go much wider than simply addressing the needs of the netting
and shellfish sectors, but there is little evidence that those
who are charged with implementing the report's recommendations
have realised that there needs to be a fundamental reappraisal
of the use that we make of our marine resources, if the netting
and shellfish sectors, along with all other stakeholders, are
to have a secure and sustainable future.
2. DELIVERING
"BEST VALUE"
2.1 The marine resources are the heritage
of all mankind, for all generations, and should not be regarded
as the sole property of any one stakeholder for a single purpose.
2.2 Management of the common resource must
be directed at obtaining the best socio-economic value available
by considering all potential uses of the stock, whether by species
or by location, for the greater benefit of the population of the
UK as a whole, and particularly of those rural coastal communities
who are most dependent upon the appropriate management of "local"
stocks and marine areas.
2.3 Evidence contained both within the Strategy
Unit's report, and the report recently produced by Drew Associates
for Defra confirm similar information that has emerged from overseas
that in some cases the value to be obtained by managing stocks
and areas for the development of the recreational sea angling
sector, and its attendant leisure and tourism potential, will
greatly exceed that obtainable from simply allowing the netting
sector to remove fish.
2.4 The Drew study reports that 1.1 million
households in England and Wales have at least one member who has
been sea angling in the past 12 months (so the number of anglers
will be much greater), directly spending £538 million (mostly
subject to VAT), and with an overall value between £600 million
and £1,300 million. There is considerable scope to develop
the sector significantly; several fold according to evidence from
overseas.
2.5 Defra statistics value the UK catch
by commercial fishermen (including shellfish, crustaceans etc)
at £521 million, continuing a decline in line with declining
fish stocks.
2.6 Although there is a tendency to view
such information as a source of contention between the inshore
netting and shellfish sectors with the recreational sea angling
sector, the needs of the differing sectors are often both non-competitive
(much of the value of the other sectors is made up of species
of no great interest to the recreational angling sector and vice
versa) and complementary (for instance, men who know the area
and its resources well can supplement a living made from shellfish
during the week, by taking out angling charter boats, and providing
angling guiding services etc, at the weekend).
2.7 Where there is little possibility of
developing an economy based on visitors, then it is sensible to
concentrate on developing netting etc. Where an area is dependent
upon visitors, it is criminal to allow the destruction of a great
natural resource for the sake of benefit to just a few individual
netsmen who could be better employed in the development of the
recreational angling sector, increasing job opportunities for
many local people, not just a few.
2.8 It should be borne in mind that many
species were almost exclusively regarded as recreational species
until recently. Bass, mullet, conger, wrasse, flounder, tope are
all valuable recreational species which have received considerable
commercial pressure, either directly or through bycatch, as netsmen
scrape around following scarcity of other species and faced with
temporary closure of traditional commercial fisheries. Recreational
angling is not taking away the livelihoods of netsmen, rather
the reverse applies as angling declines because of pressure from
netsmen and many livelihoods (charter skippers, bait suppliers,
tackle shops, boat and tackle manufacturers etc) are lost from
the recreational sector.
3. STAKEHOLDER
REPRESENTATION
3.1 A failure of the current system is the
practical exclusiveness of representation for those who represent
the netting and shellfish sectors.
3.2 Where representation is accorded to
other stakeholder interests this is always engineered so that
other stakeholders are very much in the minority, and therefore
powerless to influence policy and management.
3.3 Many a fine word has been spoken and
written about according recognition of other stakeholder interests,
but until such time as other stakeholders are given a real opportunity
to press their case, then it will always be difficult to identify
other stakeholder representatives willing to take on the considerable
amount of work involved in representing their sector.
3.4 This need of "effective" rather
than symbolic representation needs to be addressed within the
review, particularly if the right people with the right skills
are to be motivated to make an effective contribution.
4. THE "USER
PAYS" PRINCIPLE
4.1 The suggestion that Recreational Sea
Anglers should be licensed is noted.
4.2 Where resources have been managed principally
or wholly for the benefit of recreational sea angling overseas,
these schemes have sometimes involved angler contribution to the
management of the resources by the way of licences.
4.3 These schemes have often been successful
and welcomed by anglers, the difficulties of enforcement and cost
of collection etc being much the same as would be encountered
in a UK context, yet not proving to be that difficult when applied
to a scheme that has invited acceptance because of the obvious
benefits delivered.
4.4 However, the experience of UK anglers
has been one of a diminishing resource caused by the (mis)management
of the netting sector, and there would be a great deal of opposition
to any licensing scheme that might be introduced on a "jam
tomorrow" basis, especially if that licence fee were to be
collected by the same authorities that many recreational anglers
believe to be responsible for the decline they have experienced.
4.5 It is evident that there is a failure
to properly manage the ecology of inshore waters, and to rigorously
enforce management measures.
4.6 This, we believe is largely because
of the domination of Sea Fishery Committees by commercial fishing
interests and an unwillingness to take action against "brother"
fishermen.
4.7 With the Environment Agency already
becoming responsible for management of estuaries and the first
mile from the shore, under the Water Framework Directive, and
having experience of operating as the Sea Fisheries Committee
in some areas, and with experience of gathering and using biological
and ecological data to manage fisheries, we feel that the EA is
the best placed organisation to take inshore management of inshore
resources for the benefit of all stakeholders into the 21st Century.
4.8 The EA are already responsible for licensing
angling for coarse fish, migratory salmon and trout and eels up
to six nautical miles, and have developed sophisticated systems
for angling licence collection and enforcement. It would be ridiculous
and costly not to directly use their expertise to deliver and
enforce a sea angling licensing system for marine species.
4.9 Before a licensing scheme would be accepted
by many recreational sea anglers, a development plan that was
aimed at improving the angling "product" (more and bigger
fish of certain species and access to good fishing) would need
to be formulated and delivered and, when there was an apparent
and measurable improvement in the "product", a licensing
scheme would become much more acceptable.
4.10 If licensing was to be introduced before
there was an improvement, on the basis of management plans that
had not yet been shown to be effective, then there would need
to be measurable and timely objectives set out, with those charged
with delivering the benefits being held to account should targets
not be achieved within the stated timescales.
5. ENFORCEMENT
5.1 "Black" fish landings are
a major problem. Whilst there is a market for "black"
fish, enforcement will remain difficult and costly.
5.2 Much more emphasis should be placed
on sharing/transferring the risk from illegal landings from fishermen
to buyers of "black" fish, with audit trails and traceability
systems (such as carcass tagging) being adopted on a "buyer
beware" principle.
5.3 Removing the market for "black"
fish would obviate the need for enforcement and enhance the effectiveness
of stock recovery measures and availability of scientific data.
6. TIMESCALES
6.1 Many suspect that when civil servants
are unsure of what their real objectives should be, or are not
fully motivated by what they are expected to deliver, some foot-dragging
takes place.
6.2 SACN representatives have largely been
impressed with the commitment of those with whom we have met,
charged with taking forward the recommendations of the Strategy
Unit.
6.3 However, we sense an uncomfortableness
with some of the proposals, and look toward the Committee to ensure
that there is an atmosphere where it is recognised that delivering
real change is fundamental to the success of the work in hand.
6.4 We have been a little disappointed with
the speed of progress so far. It is important that enthusiasm
for delivering change and a sense of direction is not lost.
6.5 It should also be borne in mind that
the world does not stand still, and no time can afford to be lost
when we are dealing with a situation where our marine resources
continue to decline, even as technology advances to enable ever
more efficient extraction of the remaining living resources from
the marine environment, regardless of attendant consequential
damage to that environment.
7. ORAL EVIDENCE
7.1 Undoubtedly there will be many questions
not dealt with here, or not dealt with fully, that the Committee
will require further details of from those with particular experience
of the Recreational Sea Angling sector.
7.2 SACN are eager to supply oral evidence
to the Committee and we respectfully advise the Committee to also
consider obtaining oral evidence from the National Federation
of Sea Anglers, and from the Bass Anglers Sportfishing Society,
along with any other angling organisations that the Committee
deem appropriate to take evidence from.
8. EXECUTIVE
SUMMARY
8.1 Focus should be on the recovery and
development of marine resources, rather than the cushioning of
the effects of decline on the netting and shellfish sectors.
8.2 The overarching aim should be to deliver
best value to the country from the management of marine resources
rather than concentrating on the needs of any particular stakeholders.
8.3 Stakeholder representation is currently
skewed to favour some stakeholders over others. To obtain best
value, representation of all stakeholders needs to be effective
representation if the right people are to become available to
represent their sectors.
8.4 There first needs to be discernable
benefits delivered to the recreational sea angling sector before
a sea angling licence is likely to be acceptable to the majority
of sea anglers.
8.5 SACN believes that the Environment Agency
would be the most appropriate agency to manage any scheme licensing
anglers and managing the ecology of inshore waters.
8.6 Onshore enforcement, with purchaser
liability, will help to remove the market for "black"
fish.
8.7 The Committee needs to play its part
in creating the right environment for delivery of the Strategy
Unit recommendations within envisaged timescales. The situation
can only get worse if timescales slip.
8.8 The Committee should seek further oral
evidence from angling organisations.
14 September 2004
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