Mr J Cracken
Regional Director
Environment Agency
Richard Fairclough House
Knutsford Road
Warrington
WA4 1HG

Dear Sir,

North West Regional Fisheries Byelaws

I wish to object to the proposed amendments to the above, specifically to Section 1 of Byelaw 18 which seeks to prohibit the use of any dead or alive freshwater fish, salmonids or eels as bait, or to possess any of these with the intention of using them for bait. This would place severe and quite unreasonable restrictions on the lawful activities of predator anglers, activities which represent no environmental threat whatsoever.

The use of both live and dead fish for bait are established, legal angling methods.

• If it is acceptable to use minnows for bait in rivers and streams (Byelaw 18, Section 3(a), assuming that they are caught from the venue being fished, then there is no reason why it should not be acceptable to use those resident species which are readily available on the 14 waters listed in Section 1 (a) for bait (either live or dead).
• There appear to be no documented instances of British freshwater fisheries where the capture and removal of fish for bait has caused significant depletion of the fish populations.
• There has never been a single documented case where the use of live fish baits has resulted in the spread of diseases or parasites.
• There is no evidence to suggest that the introduction of dead fish baits poses any realistic threat in relation to the spread of diseases or parasites.
• The Environment Agency is at liberty to exercise its existing powers in declining to issue Sec. 30 Consent for the introduction of live fish for bait in the 14 lakes listed.
• The Environment Agency should consider the prohibition of the use, or possession of rare species (vendace, arctic char and schelly) for bait.

Yours faithfully
(signed)

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