Salmon and Freshwater Fisheries Review

Introduction

The Chartered Institution of Water and Environmental Management (CIWEM) is an independent professional body representing over 12,000 environmental professionals. CIWEM's agreed purpose is to develop and promote better and integrated management of the environment; to foster a deeper understanding of water and environmental issues and to enhance the quality of people's lives. This is achieved through CIWEM's Royal Charter, education, training and professional development; dissemination of information; conferences and events; research and publications; contact with Government agencies and other bodies, partnerships with other organisations and the publication of Policy Position Statements (PPS).

Purpose

This PPS is based on CIWEM's contribution to the Government's Salmon and Freshwater Fisheries Review, which was submitted to the Ministry of Agriculture, Fisheries and Food in June 2000. The purpose of the PPS is to promote more widely the Institution's views.

General Comments

We feel that the way the report is organised makes it easy to read, but it is not targeted at prioritising action required. It would have been better for the report to make key priorities, whether or not these were easy to implement. It is possible that, in order for there to be an appearance of action, many of the "easy" actions will be undertaken at the cost of required key legislation.

It is pleasing that the review recognises the impact of non-fishery issues and activities on fisheries. The principles of integrated environmental management have a clear part to play in deciding priorities for actions arising from this review. It would be extremely effective if Government would consider a revision of current fisheries legislation into an integrated fisheries management Bill which, in one statute, addressed many of the interwoven issues presented in the report e.g. aquatic habitat protection, fishery water quality and fish protection. This would simplify legislation and highlight the requirement for law to be less "fragmented".

This Institution believes that the Environment Agency's response to the review is of key importance. The Agency's Fisheries Staff are the largest body of fisheries professionals of any independent organisation and their level of expertise is unrivalled. Any Government response to the review must be based upon the principles of sound science, integrated environmental management and the need to consider sustainable development in all decisions. In fact, sustainable development is generally ignored in the review report.

There needs to be a clear distinction between "fishing/angling" and "fisheries" and "a high quality fishery" and "good fishing". These central tenets are the cause of much criticism of the Environment Agency's Fisheries Staff, as their role is to "maintain, improve and develop fisheries" whereas many anglers merely require large numbers of large fish to catch. Noting the additional responsibility upon the Agency to be the lead organisation for key fish species in the EC Habitats Directive, it is clear that the Agency's priority should be to fishery science and species protection and hopefully improved fisheries will lead to better fishing.

This Institution believes that, in relation to the wide-ranging economic, social and environmental benefits of the fisheries work of the Environment Agency and other fisheries organisations, funding is wholly inadequate. CIWEM recommends that Government should urgently carry out an analysis of all costs and benefits of this work. Recommendation 190 is key to this. It is clear that this would highlight inadequate Government support; a legacy of the past which should be dealt with as soon as is practicable (noted in recommendation 4).

Organisation

CIWEM believes that the Environment Agency should be the responsible body for the management of salmon and freshwater fisheries in England and Wales. The response of the Institution's members in the field of fisheries is that the Agency performs well under great funding pressure. It has the complicated task of ensuring that fisheries are maintained, improved and developed and that fishing benefits as a result. Its Fisheries staff are internationally renowned and greatly admired. An example of this is the direction being taken in Australia with regard to the development of recreational fisheries, which mirrors much of the Agency's work.

Environment Agency's Duties

CIWEM agrees that there are wider benefits from the Agency than just ecological improvement, but in terms of their duties, the Agency's Fisheries staff are currently not the key providers or educators with regard to maximising financial benefit to less advantaged areas and sectors of the community and promoting the health and accessibility benefits of angling. If it is felt that the Agency has these roles in its main duties, it should be funded further through Government departments and agencies such as the Countryside Agency, DFEE and DSS. The fact that the Agency has staff in the field who have local links and knowledge would make them an ideal organisation to maximise social and economic benefits of fisheries. This task simply cannot be undertaken within the current funding levels.

Rod Licences

This Institution feels that the current cost of the national rod licence is very reasonable, considering the fact that this pays for teams of fisheries staff to cover the whole of England and Wales to be ready at any time to rescue fish, carry out enforcement and manage fisheries with no extra charge for work carried out on individual fisheries. Clearly anglers should pay a "fair" licence fee and the Institution recommends that within the cost-benefit analysis of fishery work by responsible agencies, an analysis be made of how equitable the licence fee is. The general impression is that anglers within a club or organisational structure receive more attention and direct help from Environment Agency staff, and the cost of this effort in the private sector would often be higher than the collective licence fees of the organisations' members.

Promotion of Angling

This Institution believes that the promotion of angling and angling opportunity should be part of its recreation duty and funded accordingly. The difference between improving fishery quality and fishing quality would therefore be more clearly defined and there would be less potential for conflict.

CIWEM believes that angling should play a part in social education, especially in urban areas. There are major fisheries on canals, rivers and lakes in urban areas, which are generally an untapped and accessible resource. The funding, organisation and implementation of such activity would merit detailed investigation but the benefits of angling as social and environmental education would be maximised if there was a well organised scheme rather than a piecemeal approach.

Committee Structures

This Institution would not support a descent into "committeeism" by the Agency. Advisory Committees are of value and consultation with "customers" is essential, but the majority of Fisheries Committees are dominated by angling organisations. This does not fairly represent the customer base, as the majority of anglers do not belong to any organisation. It also leads to conflict between fishery scientists and fishermen who have different needs and wants. Environment Agency staff should not be encumbered by excessive committee administration.

Sea Fisheries Committees

Even among Environment Agency staff, CIWEM believes that there is a lack of understanding about Sea Fisheries Committees (SFC), what they do and why the Agency's staff are not responsible for sea fishery duties. This highlights the lack of co-operation between the two types of body and suggests that a consultation should be undertaken within the Agency, including all Fisheries staff, to openly discuss SFC issues.

Imposing a Close Season Where Fish Stocks Could be Damaged

This recommendation has merit, but would the Environment Agency have the power to implement this without the threat of legal action? Any descent into the Agency having to justify itself through the courts would be a retrograde step. Alternately, the Agency should have the confidence to make decisions based on scientific evidence and not be concerned about the pressures of commercial fishery owners.

Fisheries Monitoring

More cost and resource-effective fisheries monitoring methods are needed, although these methods should be carefully researched. The impression from our fisheries members in the Institution is that many fisheries field teams spend far too much time monitoring and not enough time improving fisheries. There is also rather an obsession with fish biomass class statistics instead of less intensive general assessments of species composition and distribution. More research is needed so that an improved classification can be considered, possibly using qualitative and species diversity measures.

Fisheries Research

There is an unfair emphasis on salmonid R and D in the Environment Agency's programme. This inequality seems particularly harsh as the income to the Agency from salmonid licences is well below that from coarse fish licences. Agency customers are right to feel aggrieved if their contribution goes mainly to salmonid work and R and D. Fundamental research into coarse fisheries is well overdue.

Legislation

This recommendation is rather contradictory. On reading the review report, there is a positive impression that fisheries issues are to be considered as part of an integrated environment, then in this recommendation there is a slew away from calling for an integrated approach to legislation. Also, the term "environmental legislation" is unclear. Is fisheries legislation not environmental? CIWEM believes that integrated environmental legislation is required.

Funding

There are clearly alternative funding sources which should be tapped, as well as levies on other functions. Alternative funding sources should be investigated. Some countries impose a tax on fishing equipment and pass this tax direct to fisheries work. The current "ring fencing" approach to Agency funding is too clumsy and the Fisheries function usually loses out from this process.

Power to Impose Close Seasons by Order or Byelaw

This Institution is concerned that the relaxation of close seasons on all waters will hinder attempts at minimising impacts on aquatic SSSI's. It is unclear who will enforce close seasons on SSSI's, but on some linear watercourses this will be a very complex matter. We hope that rural England and Wales does not become a mass-signage zone.

Crayfish

The Agency should be responsible for crayfish monitoring, protection and the control of the spread of non-native species as well as the destroying of unlicensed crayfish. This action is essential to ensure the survival of native crayfish in areas such as the River Wensum in Norfolk, where the distribution and source lake of non-native species is known. Cost recovery measures should be introduced and there should be additional funding for these activities.

Movement and Import of Fish

The Institution believes that firm control over the import, transport and introduction of fish (including crayfish) is essential to prevent the spread of disease and the introduction of alien or unsuitable species. For salmon stocks this is an essential precautionary approach.

Prior authorisation by the Agency of fish movement with an agreed date and time of movement is necessary to permit strict enforcement of movements. CIWEM also supports the reversal of burden of proof, as this is a significant weakness which is easily exploited by "rogue" fish suppliers.

Farm Waste Management Plans

CIWEM agrees that all farms should be required by law to prepare Farm Waste Management Plans.

Government Agencies Withholding Information

It is rather ludicrous that one Government agency can withhold from another information needed to protect the environment; this anomaly should be ended immediately.

Reform of the Common Agricultural Policy

Reform of the Common Agricultural Policy has great potential for the implementation of measures to improve fisheries. We applaud the positive recommendations but are concerned that most of the recommendations will be ignored and opposed by the agricultural lobby.

Fisheries Action Plans

The production of fisheries action plans for each catchment is essential, and it would be valuable if Government were able to include non-fisheries actions in these which were beneficial, such as the inclusion of buffer strips, livestock fencing and sensitive riparian management. It is important that the Fisheries Action Plans are not just a repackaging of information already in LEAPs.

Habitat Damage

There is significant evidence that Agency and Internal Drainage Board "flood defence" works, predominantly in the past, have caused significant damage to fisheries. There is a historic backlog of damaged habitats due to flood defence and other works, such as reservoir construction on watercourses inhabited by migratory species of fish.

Not only is a revision of work programmes required; amelioration of damaged areas should form the basis for an ongoing programme of work funded by those responsible.

Otters

While the re-introduction of Otters is a very positive step, assessment of the impact on receiving waters is necessary. This would ensure that Otters are stocked into the most appropriate areas and the impact on fisheries is minimised.

Access to Land

CIWEM believes that unrestricted access to land along watercourses would lead to significant environmental damage. It also is unlikely to be politically acceptable.

Key recommendations which the Institution supports are:

126 (legal requirement to install fish pass)

127 (legal requirement to install elver pass)

163 (establish environmentally acceptable flow regimes for all species)

165 (unlawful to affect a watercourse or stillwater without rescuing/protecting fish)

168 (review flood defence programmes)

170 (co-ordinated programme of river and river corridor habitat restoration)

171 (adopt Statutory Water Quality Objectives for all watercourses)

Fines

CIWEM believes that fines imposed by the courts for environmental offences should be paid to the agency responsible for bringing the prosecution to help with mitigation costs.

There should be a review of the derisory level of fines payable by offenders in fisheries cases, which at current levels are so low that organised criminals are becoming involved in the thieving of valuable fish. The balance of risk of being caught versus profit attainable is firmly in favour of the offender.

Conclusion

CIWEM urges Government and regulators to consider its response to the Fisheries Review when any future legislation is sought which impacts on fisheries issues.

January 2001

Note:- CIWEM Policy Position Statements (PPS) represents the Institution's views on issues at a particular point in time. It is accepted that situations change as research provides new evidence. It should be understood, therefore, that CIWEM PPS's are under constant review, that previously held views may alter and lead to revised PPS's

Published PPS's

PPS Title
Wastewater Biosolids Treatment and Use
Flood and Coastal Defence
Nature Conservation and Urban Greenspace
Professional Bodies, Pressure Groups and the Political Process
The Environment
The Use of Peat
Water Use Efficiency
Leakage
Parks for People
Endocrine Disruptors
Climate Change
Reservoirs - Global Issues
Fisheries Review