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Evidence to Marine Bill Select Committee

Jul 11,2008 SACN


As Well as the written evidence that SACN submitted to the Marine Bill Select Committee (see below), SACN along with the NFSA, were required to submit oral evidence to the committee, and a transcript of that hearing is available at:

http://www.publications.parliament.uk/pa/jt200708/jtselect/jtmarine/uc552-iii/uc55202.htm (following the evidence presented by the NFFO)

(Oral evidence from other parties can be accessed at: http://www.publications.parliament.uk/pa/jt/jtmarine.htm )

Marine Bill Evidence to Select Committee - SACN written submission

The Sea Anglers Conservation Network has over 600 members, many of these being sea angling clubs and federations etc whose own memberships total to tens of thousands.

Members of SACN recognise that their enjoyment of the sea is directly related to the overall health of the marine environment, and particularly inshore fin-fish species, the stocks of which have declined considerably both in number and the size of individual fish) in the last decades, and with few exceptions continues to do so.

We look to the Marine Bill with hope that fundamental changes to legislation, and the organisations with responsibility for restoring and maintaining our natural marine heritage, will result in seas that are restored towards their historical productivity, and which can be handed on to future generations with pride.

The proposals within the Marine Bill are far ranging but we will confine our discussion to those aspects that we believe will mostly impact upon Recreational Sea Angling (RSA) activity, and the inshore Recreational Sea Fisheries upon which participation in RSA activity depends.

It should be borne in mind that, according to Government information (contained in the ‘Drew’ Report), some 1.1 million households in England and Wales has at least one household member who engages in Recreational Sea Angling, spending some £538 million with an overall value to the economy of over £1 billion, directly supporting 19,000 livelihoods.

An activity available to everyone in the UK, regardless of earnings, age, gender, belief, race and disability, bringing many people into intimate contact with the marine environment and increasing their health and sense of wellbeing, evidence from overseas show that as the quality of the angling experience improves with the availability of more and bigger fish to catch, participation increases markedly, and spending increases exponentially, with minimal environmental impact.

Most RSA activity takes place in close to shore areas, with 50% or so directly from the shore (anglers refer to ‘The Golden Mile’).  It is this area which is coming under increasing pressure, both on the environment and the inshore fish stocks found within reach of most Recreational Sea Anglers.  

We are grateful for the opportunity to comment on the proposals in the Draft Marine Bill, but we have confined our comments only to those aspects of direct interest to our organisation and where we feel that further considerations should be taken into account.

Part 1

Marine Management Organisation

We feel strongly that rather than MMO, this organisation should be named the Marine Management and Conservation Organisation  thus giving a clear signal that conservation of the Marine Environment is high on the agenda in line with the ‘C’ in IFCAs. 

Parts 6 & 7

Sea Fisheries Committees / Inshore Fisheries and Conservation Authorities
      
The hoped for restoration and continued good management of the inshore marine environment, and the fin-fish species to be found inshore, demands more than anything an organisation with a culture and mindset that is focussed foremost upon that objective, above the (often short-term) interests of all stakeholders, especially stakeholders with an extractive interest in the produce of the marine environment.

In view of the almost impossibility of reforming an existing organisation, and in particular replacing an established culture and mindset with another, we had hoped that a new organisation would replace the existing Sea Fisheries Committees.

As described in the Josh Eagle report, many of those who sit upon those committees are of the view that their objective is to support the local fishing industry, regardless of the aspirations of other valid stakeholders within the marine environment, and the makeup of the Sea Fisheries Committees leads to a majority representation of people who have that view.

We still feel that a new organisation, given a clear purpose and objective, and strengthened powers would be a far surer way of achieving a renaissance of the UK’s inshore ecology, for the greater long term benefit of all stakeholders and future generations.

Although the proposals within the Draft Marine Bill to replace the SFCs with IFCAs do go some way to reform the purpose and powers of the old SFCs, we feel that an opportunity is being lost to bring about a truly radical reform and simply tinkers with the status quo with little hope of creating a new organisation culture and mindset that is fit for the task in hand.

We are particularly concerned that fishing industry interests will be over-represented upon the new bodies, both directly and indirectly (ie through appointed councillors with associations with the fishing industry) to the detriment of other stakeholders who should have at least an equal representation within the IFCAs.

However, we do welcome proposals for the new authorities to have clearer objectives and increased powers.


Control of Bait-Digging

Essential to angling for marine fish is a supply of fresh marine bait at an economic price (unlike freshwater angling there are few good alternatives to marine sourced bait).

We understand that collection of bait has the potential to deplete resources and to impact on the inshore marine environment, and that some control is necessary in some circumstances.

However such management should not be confined to issuing permissions and restricting activity.

As with shellfish, as part of their new duties, it should be clear to IFCAs that they also have a responsibility to ensuring continued productive capacity of bait beds (as much as (say) cockle-beds for commercial gathering) and for ensuring access to bait gathering for both individuals and the commercial enterprises that supply the Recreational Sea Angling community with marine bait.

Accessibility and productivity should be the main objective of the authority, with restrictions and enforcement used only to support those objectives.

These objectives need to be included within the legislation.

Bag Limits on Anglers’ Catches

When a fish species is under considerable pressure, we accept that any reduction in mortality is welcome.

(But cannot help to think it unfair when angling, which has a minimal impact, is expected to suffer restrictions when a stock has been allowed to be fished down by others, especially when anglers past concerns have been largely ignored).

So long as any restriction on angling activity is proportionate to the reduction in extractive activity by others, and lifted as soon as possible then there will be circumstances where the imposition of a bag limit on strictly conservation grounds will be acceptable to most anglers.

However we have great concerns with the proposal that bag limits should be place upon anglers ‘for enforcement purposes’ (rather than for a conservation need).

We believe this is intended to deal with circumstances where unlicensed fishermen using a rod and line illegally sell their catch.

(Recreational Sea Anglers fish for recreation, only keeping fish for private use.  When a fisherman uses a rod and line to catch fish with the intention of selling their catch, they are catching for commercial purposes and are not to be considered a Recreational Sea Angler).

We understand that it is sometimes difficult for fisheries officers, confronted by an unlicensed  rod and line fisherman, with a large catch, to obtain evidence that it is the intention of the fisherman to sell those fish.

However there needs to be some sense of proportion.

From a conservation point of view, it matters not whether market demand is satisfied by a licensed or unlicensed fisherman. 

The vast majority of anglers do not sell their catch.

The number of fish taken for sale by unlicensed fishermen is extremely small compared to the catch by powerful commercial boats, and there are already laws in place to deal with the illegal selling of fish.

There are more effective means of controlling the sale of fish by unlicensed fishermen, such as carcass-tagging.

Angling charter boats rely on the income from anglers who may individually only be able to afford a handful of trips a year, often costing around £50 per angler on top of all other expenses.

Limiting the catch of each angler to just a few fish per trip would make the whole sector unviable.

(Having paid a considerable amount and planned and looked forward to an angling trip for weeks, and set out for a days fishing and caught the bag limit within the first hour, what is an angler meant to do.  Keep catching fish hoping for a bigger one, whilst throwing previously caught smaller fish back dead?  For many anglers, who only fish for food, and believe it wrong to fish for the pleasure of catching alone, being forced into practising ‘catch and release’ once their bag limit is reached at the start of a day’s fishing, would present them with an unwanted and uncomfortable ethical dilemma)

And anglers who often travel a long way, just a few times a year wouldn’t find the effort worthwhile, with a consequence for the tackle trade and other businesses dependent upon visiting anglers.

A draconian sledgehammer to crack an exceedingly small nut.

We can see no justification for removing such a basic right of possession of fish caught by Recreational Anglers simply to protect the market of others whose activities are far more damaging to the sustainability of fish-stocks, especially when there are much better and more equitable ways of achieving the same objective.

Rather than ‘The powers in the draft Bill would only be used to extend controls to activities on conservation or enforcement grounds.’  (Section 3.108 page 45)

Legislation should only be introduced to allow the setting of bag-limits on conservation grounds, and only where this is necessary.


Parts 4 & 5

Marine Nature Conservation ��" Marine Conservation Zones

In the not-so-distant-past there were many areas where fish could seek refuge, where conditions made it dangerous for boats and fishing gear and uncertainty of forecasting would keep boats away.

Now technologies exist enabling boats to find and harvest fish almost anywhere, in conditions that would have been far too dangerous then.

With nowhere now to hide, protection by legislation is needed to replace those natural refuges that have been opened up by advancing technology.

Many marine species need structural habit that can be destroyed by inappropriate fishing gears in certain areas.

SACN supports the creation of Marine Protected Areas (MCZs) as a welcome and necessary conservation tool.

But we are concerned that there will be a temptation to use that tool indiscriminately and for dogmatic rather than for real conservation need.

We would like to see legislation enabling the creation of MCZs which contains safeguards requiring any such area to have a clear objective, and only restrictions on activities that clearly and significantly threaten the attainment of the specific objective for establishing that MCZ.

And that restrictions on any particular activity should be minimised (ie confined to relevant times of year or methods of extraction that are damaging, rather than the application of total bans where these are not necessary).

Social and economic factors should also be considered, alongside potential benefits when defining areas to be protected.

Before any such area is established, there should be a full consultation with all stakeholders likely to be affected, both with representative organisations and individuals who will be directly affected.

There should also be a review process whereby such areas are only maintained so long as it can be demonstrated that they are achieving the purpose for which they have been created.

The key to making such areas a success is buy-in from all affected stakeholders and the cost of attaining willing compliance must be weighed against the cost of enforcement of misunderstood and unwelcome area closures.

Perhaps our greatest concern is with displacement of fishing effort that is likely to occur as MCZs  become established.

Given that most productive areas are already pressured too much, if (say) 30% of the currently fished area is put out of bounds then, unless there is a proportional reduction in fishing capacity, effort which would previously have taken place in the closure areas will now be forced to compete in the remaining unclosed areas, or new fishing grounds opened causing damage to previously relatively pristine areas of seabed etc

Any plans for closure must also include an assessment of likely displacement on other areas and include mitigation measures (reduction in fleet capacity, compensatory enhancement of areas outside the closed area to cushion against the increase in pressure etc).

Legislation should include measures to ensure that closed or restricted areas are regularly reviewed to ensure that they are meeting their objectives, with mechanisms available to re-open or adapt closures and restrictions should they be found to be not achieving their objective, or they are increasing impacts on other areas, and any other factors not fully appreciated at the time that the closure or restricted area was initiated.

We would especially like to see within the legislation provision made for protection of the marine environment and inshore fish stocks, specifically for the purpose of reserving areas and fish for the development of Recreational Sea Angling, especially within the ‘Golden Mile’.

Whereas commercial exploitation of fish stocks is possible across the entire area of the sea, most Recreational Sea Angling occurs very close inshore, and it is from this small area that so much value is attained both in social activity and in the provision of many thousands of livelihoods and business opportunities servicing the Recreational Sea Angling sector, with minimal environmental impact.  
     

Land/Sea Interface and Transitional Habitat / Coastal Margin

Some of the most ecologically important areas of the marine environment occur at the land/sea boundary and in shallow inshore waters, particularly amongst estuaries and saltmarsh which act as breeding spawning and nursery areas for many creatures, not only the fry of important fish stocks, but the generation of components of the food-web that affects marine ecology far out to sea.

And yet these areas are coming under increasing pressure, not only from sea-level rises and hard coastal defences, but coastal development and terrestrial activities impacting upon inshore areas.

It is important that any system of marine or terrestrial coastal planning interfaces seamlessly with the objective of understanding and ameliorating impacts upon the fragile habitat of inshore transitional areas.  

Legislation must make it mandatory that any onshore developments which are likely to impact upon the marine environment include an assessment of that impact and be subject to approval by the Marine Planning Authority.


Parts 6 & 7

Flexible Charging of Commercial Fishing Vessels

It is well known that different types of gear, in a variety of situations, can be far more damaging, sometimes for only modest efficiency in catching.

A system which favours more environmentally acceptable ways of fishing over more damaging alternative methods is to be welcomed.

Part 9
 
Coastal Access

We very much welcome proposals for improving coastal access.

Although there is an ancient public right to fish between high and low water marks, access to productive fishing marks is often barred, and increasingly so.

Often meaning that local anglers have to travel further afield for equivalent fishing, which restricts participation for many and has environmental consequences.

And many places sport arbitary ‘No Fishing Allowed’ signs for no apparent good reason, which can be annoying when shown on council owned piers and marine basins etc, when millions have been spent on under-used sports fields and yet access to the facilities that young anglers most desire are arbitrarily blocked.

Legislation which is aimed at giving greater access to the coast for all, should include consideration for a default position of allowing access by anglers to water unless there are genuine overriding reasons why this should not be the case.

(Health and Safety and Public Liability considerations are routinely misused as an excuse for erecting ‘No Fishing’ signs. That is wrong and a denial of reasonable access).

‘Sea Fisheries Management’  

Although it is often stated by DEFRA and others that the terms ‘fishing’ and ‘fisheries’ includes both commercial and recreational fishing and fisheries, the traditional mindset of many people assume that these terms only refer to commercial fishing.

When talking about fishing and fisheries, the wording of the bill and legislation should leave in no doubt that Recreational Sea Fishing and Recreational Sea Fisheries are included in the terms where appropriate. 


Sea Anglers Conservation Network  

See also Draft Marine Bill Consultation Response



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