Download Does chapter 2 clearly state the vision and how it will

Angling Trust response to the UK Marine Policy
Statement: a draft for consultation
July 2010
Angling Trust
Eastwood House l 6 Rainbow Street l Leominster l Herefordshire l HR6 8DQ
Tel: 0844 770616 l Fax: 01159 819039 l Email: [email protected]
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Introduction
The Angling Trust is the national representative body for all angling in England. We campaign
for anglers’ rights and on environmental issues. We lobby Governments and agencies to
protect our marine environment and fish stocks and we support, develop and promote angling
as a sport and support angling interests.
The UK has over 1.9 million recreational sea anglers representing one of the largest
stakeholder groups in the marine environment and the largest number of direct user
stakeholders of our commonly-owned marine fish resources.
Marine policy decisions have a direct and indirect effect on fish stocks and access to these fish
stocks that impact on the recreational sea angling (RSA) sector. As such, we have responded
to this consultation in a constructive manner in order that the future marine policy statement
protects the environment and fish stocks on which RSA relies, as well as the access and rights
that angers have. We believe that recreational sea angling is an inherently sustainable activity
of significant economic value to coastal communities and our aim is to protect and promote it as
a sport within the context of the marine policy statement.
We have elected to respond only to those sections of the consultation that are of relevance to
recreational sea angling.
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CHAPTER 2
Does chapter 2 clearly state the vision and how it will be achieved? Are the high-level
principles and environmental, social and economic considerations to be taken into
account in marine planning clearly expressed?
2.2
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“The marine environment and its resources are used to maximise sustainable activity,
prosperity and opportunities for all, now and in the future.”
We support this statement providing it takes into account the economic benefit of
recreational sea angling and recognises that the greatest prosperity for some
communities can come from commonly-owned fish stocks being managed for
recreational purposes in an integrated management system. In addition it should be
recognised that angling is a sustainable activity and the prosperity of communities will
grow in the future as the value of the recreational fishing sector grows.
Securing The Benefits, the joint response to Net Benefits report, clearly lays out as an
overarching objective that fish should be harvested in a way that optimises “long term
economic returns”.
The evidence for utilising some fishery resources for recreational exploitation in order to
optimise economic impacts is overwhelming. Such an approach does not preclude
commercial exploitation of the same resources but requires an integrated management
plan designed to deliver ‘recreational management’ which may differ substantially from
conventional ‘commercial management’.
“The use of the marine environment is benefiting society as a whole, contributing to
resilient and cohesive communities that can adapt to coastal erosion and flood risk, as
well as contributing to physical and mental wellbeing.”
A vibrant and robust RSA industry contributes financially, environmentally and culturally
to local communities, distributing the wealth generated to the wider community. Angling
has been proven to contribute to wellbeing, mental health and social cohesion and
should therefore be encouraged.
“There is equitable access for those who want to use and enjoy the coast, seas and
their wide range of resources and assets and recognition that for some island and
peripheral communities the sea plays a significant role in their community.”
Equitable access to commonly-owned public resources such as marine fish stocks must
be achieved through integrated fisheries management systems for both recreational and
commercial interests. No sector shall be placed in the hands of commercial or private
interests where access can be restricted or denied.
“All those who have a stake in the marine environment have an input into associated
decision-making.”
We support this principle but would wish to see that RSA’s significant interests in fish
stock structure and abundance mean they should have proportionate representation on
all fisheries decision-making matters and their interests be taken into account and
integrated into fisheries management measures.
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2.5 Economic and Social Considerations
The integration of marine policies that take into account the socio-economic benefits of
recreational sea angling is essential. It is worth reiterating the value of the RSA sector in order
to appreciate how valuable the RSA contribution is and what an impact it has and can have
when the Government, through marine policies, maximises these contributions by providing
management measures for the specific benefit of RSA.
The following figures are taken from the Drew Associates report into recreational sea angling
(2004)
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Number of jobs provided by RSA – 19,000
Annual spend -- £645 million (adjusted for 2010)
Number of sea anglers – 1.9 million (adjusted for 2010)
Optimising the potential of environmental resources will therefore mean recognising the
cultural, social and economic value of managing some fisheries primarily for recreational use
and the financial, health and wellbeing benefits that this will bring to local and national
communities. For an example of how this has been achieved successfully please refer to the
East Coast of USA where scientifically calculated total allowable catches (TACs) are allocated
as follows:
Black Sea Bass
Bluefish
Red Drum
Spotted Sea Trout
Striped Bass
Commercial
49%
20%
15%
20%
20%
Recreational
51%
80%
85%
80%
80%
Reference: Atlantic States Marine Fisheries Commission, USA.
2.6 Marine Environment
Measures must be taken to ensure that environmental protection and actions taken to improve
marine and coastal waters are consistent with the requirements of the Water Framework
Directive and the Marine Strategic Framework Directive and that there is clear, comprehensive
and unambiguous understanding about the scope and nature and responsibilities of these
Directives.
2.7 Marine Ecology and Biodiversity
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“Populations of all commercially exploited fish and shellfish are within safe biological
limits, exhibiting a population age and size distribution that is indicative of a healthy
stock”
Angling Trust strongly believes that definition is needed of what constitutes
“commercially exploited” and “healthy stock”. As more species become pressure stocks,
markets open up for species to become commercially viable.
The commercial fishing industry’s definitions of ‘healthy’ and ‘sustainable’ are not
reflected by the RSA sector. There is a strongly held view that the commercial
definitions are derived from political decisions and faux science aimed at justifying
political purposes rather than environmental and ecological aims.
There is a pressing need for the development of a large stock strategy as defined in
Securing the Benefits, the follow up to the Prime Minister’s Strategy Unit report, Net
Benefits.
It must be recognised that regulations are imperfectly enforced and hence routinely
exceeded; therefore a safety margin must be built into all regulation of commercial
exploitation.
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2.10
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“Being in a position to take advantage of the opportunities that climate change may
bring to certain marine areas, e.g. increase in leisure activities and the aquaculture of
acceptable and commercially desirable species”
Marine planning authorities should therefore also be prepared to take advantage of
“recreational” species and the benefits that they might bring through the effects of
climate change. The changes in species composition should be regularly monitored to
adapt integrated management measures as species move away from and into areas of
the marine environment due to the effects of sea temperature change.
CHAPTER 3
Does chapter 3 provide a clear statement of policy objectives for the marine
environment? Are the key impacts, pressures and issues for consideration in marine
planning appropriately identified?
3.8 Fisheries
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“The marine fisheries sector comprises all socio-economic activities related to the
capture of wild marine organisms”
The Angling Trust requests confirmation that this includes the recreational sea angling
(RSA) sector and that the interests of RSA are taken into account within the fisheries
section of the marine policy statement.
“The view of the UK Administrations is that the overall aim of the reformed CFP should
be to “attain ecological sustainability by optimising the wealth generation of marine fish
resources”,
It should therefore include the integration of recreational sea angling interests into
fisheries management measures in order to take account of the £645 million that RSA
generates, the 19,000 jobs that it supports and the 1.9 million anglers who put money
into the UK economy in England and Wales (Drew Associates Report into Recreational
Sea Angling, 2004)
The stocks of fish species upon which the £645 million RSA sector (in Eng. & Wales)
are dependent, only contribute £42 million to commercial landings in Eng. & Wales.
Therefore in order to “optimise wealth generation” fisheries administrations should focus
upon providing specific management requirements for the RSA sector which differ
significantly from those of the commercial fishing sector.
Policy decision-makers should be aware that good environmental status under the
marine strategy framework directive can be achieved by the RSA requirement to have
large stock structures and population ages with integrated management measures that
support this.
The designation of ‘game fish’ status – similar to that of salmonids -- for certain species
would provide the structure for long term management plans to include recreational
exploitation and commercial exploitation within an overall plan for sustainability. Please
refer to ‘Invest In Fish South West’ for a regional vision of how this might work.
Potential Impacts
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Marine planning decisions have the potential to impact on recreational sea angling and
as the representative body for all sea angling in England the Angling Trust asks to be
consulted on any marine planning issues that have the potential to impact on fisheries
or access to angling.
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Commercial exploitation of fish stocks is by far the largest factor impacting on the
recreational sea angling sector and any decisions made on fisheries management
should include recreational sea angling as a direct user stakeholder of fishery resources
taking into account the social, cultural and financial contribution of RSA to the economy.
Issues for Consideration
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“Wherever possible, decision makers should seek to encourage opportunities for coexistence between fishing and other activities.”
Co-existence between commercial fishing and recreational sea angling can exist if
integrated management measures are adopted to give fair and proportionate
representation to the interests of both under an overarching goal of delivering the best
return to the UK.
3.11 Tourism and Recreation
Potential Impacts
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“Socio-economic benefits include the positive benefits to local communities through
increased visitors and tourism. Improving access may also attract more visitors.”
Recreational sea angling contributes heavily to coastal communities that rely on
tourism. With integrated management measures for fisheries including RSA this
contribution will increase and has the potential, in some areas, to be the single largest
contributor to tourism and local economies. However, this relies on healthy and
abundant fish stocks. It is therefore crucial that decision makers include fisheries
management in relation to tourism and “a well maintained and healthy marine
environment
Issues for Consideration
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“Decision makers should consider the potential for tourism and recreation in the
marine environment and consider the likely implications on other activities, both in
the marine environment and on shore.”
The effect of increased recreational angling tourism would reach deep into local
coastal communities with the increased business and trade of local goods and
services, an infrastructure to support this and the associated employment that this
would bring to many coastal communities with little or no industry. In addition, sea
angling takes place year round as anglers target different species and has the
potential to provide tourism benefits on a more even distribution than some of the
more traditional summer tourism and recreational activities.
The management of striped bass on the East coast of the United States has resulted in
tourism from overseas as anglers travel from around the World to fish for this species.
This has pumped millions of dollars into the local economy and is an excellent example
of where tourism and recreation have benefitted the marine environment – with
conservation measures and a large stock strategy for striped bass – and the onshore
tourism sector to support the increased number of anglers travelling to the East coast
for the fishing.
The potential for RSA and tourism to increase is huge if depleted fish stocks can be
rebuilt and the RSA “experience” is invested in.
Angling Trust 2010
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