Yorkshire and Lincolnshire association of sea anglers update.

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THis is yalasa's response to the marine Bill. For more details on yalasa visit www.yalasa.co.uk

 

 

Yorkshire and Lincolnshire Association of Sea Anglers

Chairman

Nigel Proctor

49 Guildford Avenue

Hull

HU8 0LA

 

Marine Bill Consultation Team

DEFRA – Marine Legislation Division

Area 2E,

3-8 Whitehall Place,

London,

SW1A 2HH

 

 

21st June 2006

 

Dear Sir,

 

Re: Marine Bill Consultation

 

The Yorkshire and Lincolnshire Association of Sea Anglers was established 18 months ago to represent the views of anglers throughout Yorkshire and Lincolnshire and aid the development of sea angling within the region. Its remit is not just representative, the association also aspires to develop and enhance RSA within the area for both experienced and in-experienced anglers alike, with special regard for youth and offering the often disenfranchised an opportunity that under normal circumstances may not be afforded them, in the hope that such opportunity will provide environmental awareness and a more stabilised life style.

 

We appreciate the opportunity to provide a response to such a formidable piece of legislation, however, given the length of the consultation document, and the limited time available for the preparation of our response, we consider it appropriate to forward responses to relevant questions only. We have taken a particular position on specific subjects that may deleteriously affect our members and the sport in the wider context, and we refer to these issues in a singular response where appropriate. There is much within the consultation package we are unwilling and unable to offer opinion on, given that fisheries have previously been out to consultation, although we do feel it necessary to re-evaluate some of the angling effects, specifically issues of access, sea angling rod licences, proposals for bag limits etc. We trust, therefore, that prior to the implementation or provision of any specific angling regulation/restriction, the impacts/benefits will be widely discussed through consultation prior to the formulation of any pending legislation.

 

Regulation of RSA Activity

 

We note with significant concern that the proposed bill indicates that it may be prudent to initiate, via licensing and bag limits, powers to regulate RSA activity. We question the rationale behind such a move, and note the subtle change from the ‘Drew and Bradley reports’ where much of the discussion was of how to develop and enhance RSA activity, to the present climate of managing RSA activity. We cannot support any legislation that restricts our natural freedom and right to fish, on the basis that such regulation would be of benefit to the marine environment as a whole. The association considers that sea anglers are becoming increasingly more environmentally aware, have great consideration for the marine environment, and have a negligible impact on both habitat and resources. We see no justification for taxing those who have not contributed directly to the present poor state of many marine biological resources. Notwithstanding this, if finances were to be used solely to enhance RSA within the regions (not simply for enforcement of users) and that prior to implementation measures were put in place to enhance and develop sea angling and the resources it requires to be a successful activity, then we can envisage a time when such a scheme may be acceptable, however, until such time YALASA vehemently opposes the introduction of rod licences and or broadscale bag limits.

 

Marine Spatial Planning

 

Marine Spatial Planning (MSP) is recognised as a tool to inform relevant bodies as to the degree of activity of various descriptions within the marine environment to enable decisions to be made as to siting of developments (SEA’s) and conflict resolution. We recognise the need for such data to inform all aspects of marine activity, however, we are concerned that such spatial planning within the marine environment will lead to the establishment of specific user boundaries and subsequently lead to certain activities being restricted or confined to especial areas as a result of ‘activities considered to be of a higher importance’ and being in the best interests of the country (offshore development & nature conservation etc.). We consider that RSA is a high importance user on both social and economic grounds and as a consequence it is imperative that this activity is fully mapped and integrated with that of other marine users. Given the continued loss of access to many waterfront areas, especially in coastal towns and cities we believe that mapping of RSA activity will allow for an integrated approach to redevelopment of these areas by legitimising the activity, as opposed to the present situation whereby waterfront developers, docks boards & port authorities either restrict access or blatantly inhibit angling activity.

 

We therefore support the principal of Marine Spatial Planning provided it is a tool to inform and resolve conflicts, as opposed to a means to partition activity and ultimately exclude.

 

Inshore Fisheries Management

 

We have grave concern over the current system of Inshore Fisheries Management, which we consider is not suitable to account for the diverse range of users within inshore waters and the equitable utilisation of the resources contained within. The present structure under the remit of the SFC’s focuses predominantly on catering to the needs of a single sector, with resources managed to account for this sector, often at the expense of other users, who in some circumstances would derive significantly greater social and economic benefit from the utilisation of said resources, whilst having a significantly lower impact, in terms of habitat and resource exploitation. We are of the belief that inshore fisheries management should be to the benefit of all users and no one sector alone, however, the sustainable utilisation and management of the resource should be the principal priority.

 

Unfortunately, with the SFC’s dominated by one sector, and supported by local councillors, who may have either financial and or family ties to the industry, a balanced view with regard to the management of inshore resources is currently not being achieved. We would refer you to Dr Josh Eagles report, Democracy and Natural Resources; British and American Approaches to Public Participation in Fishery management, British Council (2004). In this report Dr Eagles’ refers to the tendency of British councillors to vote in support of commercial fishermen because ‘they feel it is the right thing to do’. This makes a mockery of the inshore fisheries management system and shows that the model often referred to by the ASFC as being ’successful’ can only be considered as such if you are a commercial fisherman or employed within that sector. We have no confidence in the participation of councillors who have an extremely limited knowledge of the marine environment and the biological resources contained within. Recent examples of this ignorance include concerns on the number of shrimp taken in gillnets! and one councillor recently stated that a particular conservation measure would significantly affect the eight or nine large trawlers currently working from his home town, despite the fact that all vessels working from this town are beach launched from tractors and are solely employed in the shellfish sector (under 10m). More recently a councillor drove the SFC response to the bass mls on a Euro-sceptical stance, following representation from the commercial sector. The councillor stated that the needs of local fishermen must come first and that to increase the mls would only provide more fish for foreign vessels, further dialogue was ruled out when a motion to reject the proposal was forwarded and accepted. Subsequently, the responsible councillor admitted that he had not read the supporting document fully as he did not completely understand it. Such evidence of ignorance and a clear bias towards one specific sector gives us little confidence for the future management of inshore waters. We would recommend that SFC’s are included in the new MMO working in unison with the MFA. At the very least the composition of sea fisheries committees should reflect the economic and social value of user groups and the importance of decisions made to maximise the sustainable utilisation of inshore marine resources, thereby requiring educated personnel, not inexperienced and subjective representatives who bring nothing to the table..

 

Response to Individual Questions

 

Section 8 Planning in the Marine Area

 

Q1. Yes.

Q2. Implemented as a statutory system

Q3. The objectives are in line with YALASA objectives.

Q4. See above dedicated response

Q5. Option 4 – Binding plan.

Q8. 200 miles.

Q18. All seem to be relevant.

Q19. Not as yet?

Q22. Decisions on conflicts should be agreed upon by an independent planning authority, with socio-economic values given a high degree of reflection, along side environmental considerations.

Q23. Depends on the value of the activity and potential loss of other equally suitable areas, see specific response for general concerns.

Q24. Will be important provided the data is validated.

Q25. SEA’s are already in wide use and are important.

Q26. Externally validated.

Q27. See specific response, boundaries lead to exclusion of activities, although given legitimate and factual reasons there should be no significant issues.

Q28. Absolutely.

Q29 & 30. Depends on activity, but reviews should form the basis of monitoring, 5 years may be adequate for some activities but inappropriate for others.

 

 

Section 10. Improving Marine Nature Conservation

Q52 All management regimes and process should consider the marine ecosystem objectives.

Q53. Change to management regime.

Q54. Yes.

Q55. Replace.

Q57. A, b, c, d, g & h

Q58.Yes.

Q59. Yes

Q60, Yes, based on a site by site basis reflecting social and economic trends/impacts in conjunction with the degree of importance for key interest features.

Q61. Very much so, one shoe doesn’t necessarily fit all, what is best for one site may be different for another, similarly with impacts to the human user groups.

Q63. Appropriate assessments should be carried out if there is any doubt as to the nature of the activity and its potential impact on the site or any key interest feature or species.

Q64. Not particularly.

Q67. Offshore commercial fin fish species, not addressed by the CFP/ lack of political will to take harsh measures, ignorance of ICES advice.

Q68. Extend the species protection legislation, include species which are under threat or in decline and not just those which are of singular conservation value, in other words use marine resources in a sustainable and environmentally sensitive manner, that should include commercial finfish, which are generally ignored or bargained over.

Q69. Yes, indiscriminate fishing practices & aggregate extraction.

Q70. Should be national legislation not local byelaws.

Q71. Greater commitment to enforcement.

Q72 . Wider application.

Q73. Simplification and clarification of existing regulation in conjunction with strong enforcement and meaningful penalties.

Q74. Integrate EA with new MMO which incorporates SFC’s on a local scale.

Q76. Need to be responsive and proactive as opposed to reactive, too much time is often taken to initiate the remedial action required.

 

Section 11 The potential for a New Marine Management Organisation (MMO)

 

Q77. Almost.

Q78. Inshore Fisheries Management, replacement of SFC’s

Q79. In principal yes.

Q80. Yes.

Q81, See answer to Q78.

 

Once again many thanks for the opportunity to offer our considerations on these topics, should you wish clarification on any point, please do not hesitate to contact me at the above address or by e-mail.

 

Yours sincerely

 

 

 

 

 

 

Nigel Proctor

Chairman of the Yorkshire and Lincolnshire Association of Sea Anglers