At long last, the Dept. of Agriculture and Rural Development in Northern Ireland (DARDNI) have published their Department’s Review of the 2010 Consultation on proposals to replicate bass management legislation as exists in the Republic of Ireland across Northern Ireland thus harmonising bass management across the island of Ireland. Details can be found at:  http://www.dardni.gov.uk 

Their conclusions are ambiguous. In some regards we think they have it right and the results are better than might have been the case but total harmonisation it isn’t and both the decision to exempt trawled bass from the legislation and in particular their rationale for so doing, raises serious questions about an apparent change to the whole purpose of their original proposals.

BASS have submitted a written response – see below — and hope that as many as possible from the Recreational Sea Angling community will also make representation.

Although this issue may at first seem to only be about bass in Northern Ireland, it is in fact an opportunity to begin altering the culture within the entire UK Management of marine fishery resources. If bass effectively become a RSA species in Northern Ireland, it will be the first instance in the United Kingdom for such designation. Such designation will contribute to altering the mindset of decision makers and politicians from one where commercial fishing is perceived as the ‘all important’ sector whilst RSA is all too often perceived as a fool with a rod trying to drown worms. Establishing the validity of RSA as a socially and economically valuable use of marine fishery resources, is a prerequisite to achieving a better deal for RSA in terms of both fisheries management and maintaining access to our coastline.

You may think BASS is exaggerating the potential that the DARDNI deliberations may have for improving the lot of RSA in general. However, please consider this:

Total commercial fish/shell fish landings in Northern Ireland in 2010 were £35.25 million. Bass accounted for just £1591 which is just 0.004% of total first sale value. On the evidence you wouldn’t think commercial interests would be bothered if bass in NI became a total RSA species but commercial fishing leaders understand the long term repercussions should bass be designated 100% recreational. This is why it is clear from the DARDNI Review, that despite commercial bass landings being so insignificant, the commercial voices are strenuously endeavouring to maintain their own access to the species. They understand the potential strategic significance of this issue and are almost certainly responsible for having persuaded Review staff to move the goalposts (see ‘Overarching Objective’ below).

The key issues to raise with DARDNI are:

Discards.

No one wants to see any fish discarded but in the case of accidental trawl bass catches, the quantities are so small that in context with the whole discard issue, the discard of bass is insignificant. If accidental catches of bass are allowed to be landed and therefore enter the supply chain, it will make enforcement of the proposed legislation very difficult if not impossible. Any wild bass found in the supply chain will simply be passed off as having originated from a trawler. Whereas, if NO bass are allowed to be sold the loop hole doesn’t exist. The proposed exemption for trawlers creates a loop hole that will almost certainly result in increased bass mortality as illegally caught bass (from whatever source) will be easier to sell and in terms of protecting the bass resource, mortality levels are more important than discards.

Stock assessment.

The Review confirms that trawl catches of bass are “small and infrequent” and are taken from “offshore waters whereas bass tend to be located in the inshore zone”. The notion of using such haphazard catches for stock assessment purposes borders on the bizarre.

Overarching objective of proposals.

The Consultation Paper was headed: Proposals for the introduction of Regulations for Protection & Conservation of Sea bass. Consultation documents stated:  “Sea Bass is important to our angling community and is considered a prize fishery by this group and sea angling for Sea Bass could provide an additional opportunity for the development of angling within some parts of our waters and could enhance income to our coastal communities through chartered fishing trips for both local and European fishers and an increase in angling tourism.” and: “It has been proposed that the species should be reserved for recreational angling by adopting measures similar to those already existing in the Republic of Ireland”.

The Regulatory Impact Assessment included that Recreational Sea Angling in NI is already valued at £7.4 million. The original intention of the proposals was to harmonise bass legislation with that in Southern Ireland where the species is managed as a tourism driver.

However, the Review at paragraph 30, now introduces the entirely new idea that the proposals are about conserving bass stocks until such times as they improve, when restrictions on commercial exploitation could be reviewed. So, should these proposals eventually contribute to bass becoming more abundant, the notion of developing a sustainable valuable recreational sea angling sector as a tourism driver is now replaced with the idea of developing a commercial bass fishery.

The goal posts have been moved during the Consultation process.

BASS hopes that the RSA community, whether BASS members or not, will make written representation. BASS believes individual letters, no matter how short, are  far more influential than petitions. Letters can focus on as many or as few issues as you wish, but the three most crucial messages are:

1. That no exemptions for trawled bass should be made because such exemptions will undermine the purpose of the proposals

2. That the original objective – development of a sustainable recreational bass fishery as a tourism driver – should be adhered to since this provides the best societal value from the public sea bass resource

3. That harmonisation of sea bass legislation across the island of Ireland  is highly desirable.

The following is a template for your letter, and can be amended to include your own words, which will, as said before, achieve greater impact.

Dear Minister or Committee Clerk

I write regarding the DARDNI 2010 Consultation on the proposals to replicate bass management legislation, as exists in the Republic of Ireland, across Northern Ireland. I am encouraged by the conclusions but feel there has been an apparent change to the whole purpose of the original proposal.

It was my understanding that the original intention of the proposal was to harmonise bass legislation with that in Southern Ireland thereby having the ability to further develop a sustainable, valuable recreational sea angling sector as a tourism driver.

This proposal will be undermined if any exemptions are made regarding commercial fishing and the idea of developing a commercial bass fishery, as and when stocks improve.

Why have you included this in your proposal? No mention was made of this in the original consultation process. I feel that as a recreation sea angler I deserve an answer to this question. Your own document included the wording ‘Prohibition of fishing for bass by any means other than rod and line’ and ‘Prohibition on the retention on board of bass by any UK sea fishing vessel within the Northern Ireland zone.’

The inclusion of the words ‘could be reviewed’ in paragraph 30 of the Review completely undermines the spirit of the original proposal. Justify this to me.

Yours Sincerely 

Letters should be sent to both the Minister and the Committee.

Contact details are:
Minister Michelle O’Neil.
Dept. of Agriculture and Rural Development,
Dundonald House,
Upper Newtownards Rd.,
Ballymiscaw,
Belfast,
BT4 3SB.
Email: private.office@dardni.gov.uk

Committee Clerk,
Committee for Agriculture and Rural Development,
Room 412,
Parliament Building,
Ballymiscaw,
Stormont,
Belfast
BT4 3XX
Email: committee.agriculture@niassembly.gov.uk

If possible copies should also be sent to:

Northern Ireland Tourist Board,
59 North Street,
Belfast.
BT1 1NB

Loughs Agency,
22 Victoria Road,
Londonderry,
BT47 2AB

BASS response.

Dear Minister,

Re: The Consultation on proposals to implement legislation for capture/retention of bass in NI so as to harmonise with existing legislation in Southern Ireland.

It has been bought to my attention that the long awaited decision (Consultation period ended August last year) is available at:

http://www.dardni.gov.uk/sea_bass_consultation_review_of_proposals_following_consultation_responses.pdf

and it is the outcome of these deliberations that I write about.

We are of course very pleased that the Dept. has concluded that the 2 bass bag limit per day should go ahead and that the closed season 15th May to 15th June be adopted.

We are also pleased that the Dept. supports the proposal for a general prohibition on sale of bass, a prohibition of fishing for bass with any other metier than rod & line (incl. handline) and a prohibition on retention on board of bass by any licensed vessel.

As one of the lead organisations for recreational sea anglers who are interested in bass, we will be pleased to broadcast these results across Europe and have no doubt that Northern Ireland will be added to those destinations that are already regarded as worthwhile to visit for bass angling. There are hundreds of thousands of sea anglers in Europe who regard bass as their favourite species to target.

We are however perplexed that in respect of the last three measures, it is proposed to exempt trawlers.

The rationale appears to be a concern about discards and the idea that commercial landings are the only available option for stock assessments.

The document draws attention to the very low numbers of bass being landed commercially in NI – 17 kilos in 2009.  The very low quantities of bass being caught commercially in NI are also detailed in the RIA that accompanied the original announcement of the Consultation in early 2010.

Given the thousands of tonnes of fish that are annually discarded in UK waters, the Department’s concerns about as little as 17 kilos of bass being discarded annually seems a little exaggerated. It is not at all certain that the current debate in respect of discards and the 2012 Common Fisheries Policy reform will result in a total ban on discards. One key issue is the possibility that a proportion of discards, under some circumstances, do survive. Bass are a hardy species, unlike some pelagic species, and a proportion of the very low numbers of bass that are captured by NI trawlers, may survive if returned.

The departments conclusions make the entirely valid points that commercial trawl bass catches are “small and infrequent”  and are taken ‘offshore waters whereas sea bass tend to be located in the inshore zone.”  Yet despite the foregoing, the department holds these catches out as the only means available for stock assessment purposes.

With respect, we suggest that such a profile of haphazard commercial landings is most definitely not suitable for stock assessment purposes. If the NI authorities wish to monitor bass stocks, a simple logbook system for recreational anglers who fish the inshore zone, is a far superior method. We would be pleased to provide you with information on how such a scheme might operate.

Reports of wild bass in the supply chain (fishmongers, restaurant etc)  that might initiate enquiries into the illegal capture and marketing of bass (where no import documentation is provided), facilitates enquiries in the Republic which is why, when commercial interests in the Republic recently tried to have their existing legislation  modified so as to allow trawl catches to be legally landed, Inland Fisheries Ireland     http://www.fisheriesireland.ie/   opposed any relaxation that would allow commercial landings of bass because of the difficulties such action would create for enforcement. In NI, any wild bass on sale will simply be passed off as originating from trawlers. This ‘loop hole’ will make enforcement all the more difficult.

The most worrying aspect of the latest deliberations by the department however is the idea outlined in para 25 that “If the stock were to grow significantly the measures restricting commercial fishing could be reviewed.”

The original purpose of these proposals included:

“Sea Bass is important to our angling community and is considered a prize fishery by this group and sea angling for Sea Bass could provide an additional opportunity for the development of angling within some parts of our waters and could enhance income to our coastal communities through chartered fishing trips for both local and European fishers and an increase in angling tourism.”

The RIA included information that Recreational Sea Angling in NI is already valued at £7.4 million and if sport fishing for bass (Europe’s most treasured sea angling species) in NI can be developed, and it most certainly would if stocks of bass improve, the best possible return from the public sea bass fishery resource is without question using it as a tourism driver. In other parts of the globe where stocks of marine species have flourished, levels of recreational sea angling for those species have increased directionally proportional to the improvement in stocks and in the case of striped bass on the east coast of the USA, their coastal economy had benefited from a seven fold increase in both stocks and economic impacts between 1985 and 1996. Even a very modest increase to the existing £7.4 million recreational sea angling spend  would absolutely dwarf any economic impacts from using any improvement to NI bass stocks for commercial fishing.

Before we broadcast the results of the DARDNI sea bass Consultation, could you please respond to the two key issues that we know will be of major concern to the recreational sea angling community – 1) how enforcement will be achieved with the presence of legal wild bass in the supply chain and 2) an explanation of why initially these measures appeared to be driven by a desire to achieve greater levels of sea angling tourism but now appear to be directed at improving bass stocks with a view to establishment of a commercial fishery.

Yours sincerely,
I Misselbrook
Chairman

cc. Northern Ireland Tourist Board, 59 North Street, Belfast. BT1 1NB
Loughs Agency, 22 Victoria Road, Londonderry, BT47 2AB