18/03/04
 SAA LETTER
TO EA
To
the Regional Director
The Environment Agency
PO Box 12
Richard Fairclough
House
Knutsford Road
Warrington
Cheshire WA4 1HG
3rd March 2004
Re: Assessment of effectiveness of livebait/coarse
deadbait ban Some
time has passed since restrictions were placed on recreational anglers targeting
species of predator fish, using live and dead coarse fish, for the purpose of
preserving the biological integrity of the waters involved, within the North West
region. We
now understand that similar bans are being considered for other areas within the
UK, for similar purposes. Whereas
the ban in the North West area was imposed with little opportunity for assessment
of its likely efficacy in achieving its objectives, any further such proposals
will have the advantage of incorporating knowledge gained from assessment of the
introductory ban in the North West area. Therefore
we would be grateful if you could supply the following information:
-
Can you tell us what ongoing assessment
of the effect of the ban in achieving its biological objective is taking place?
What methodology is being used? What results have been obtained so far?
-
We have anecdotal evidence that the ban
has proved damaging to angling based leisure and tourism in the area. Do you know
of any studies that quantify the economic disadvantage occurring because of the
ban? If not, is there any intention to carry out such a study by yourselves or
any other agency?
-
How
effective has been the enforcement of the ban? How many infringements have been
detected? What percentage of infringements are being detected?
-
(We are contemplating a study to test the
effectiveness of enforcement by asking predator anglers, targeting various species
of predator fish, to act as though they were surreptitiously fishing with the
banned baits, using plastic dummy ‘baits’ and employing tactics that those fishing
illegally are likely to employ (i.e. ‘live-baits’ stored in flasks etc. Knowing
the number of such ‘sessions’ that take place, and the number that are detected
by the enforcement agencies, it will be possible to extrapolate from the number
of detections the degree of effectiveness of enforcement, if any. There is little
point in imposing a ban, without effective enforcement in place).
-
As well as introductions of ‘alien’ species
through the activities of recreational anglers, there are a number of other routes
of inevitable introduction, mostly natural. What other routes of introduction
have the agency identified, and what action is being taken to close these routes
also? (There is little point installing a gate with a lock, if it stands isolated
without a fence, and access can be gained simply by walking past the gate!). There
is a wealth of scientific evidence that suggests routes of colonisation (and genetic
reinforcement) of isolated bodies of water, the limiting factor being whether
the receiving body of water provides a hospitable environment for the potential
colonisers. When conditions change, so does the biological mix of the water, even
though ‘isolated’.
-
There
was a recent report in The Times concerning the gwyniad, which stated that this
species is on the brink of extinction in Llyn Tegid because its eggs are being
eaten by ruffe that were introduced 30 years ago. This parallels your experience
in NW of course. It has proved impossible to eradicate the ruffe in Llyn Tegid
so the EA are planning to transplant the gwyniad to a new venue. Have your own
efforts to eradicate the ruffe in NW Region been any more successful? (Because
if not then the present NW ban on freshwater live and dead-baits will not seem
to serve any useful purpose). In
pioneering the introduction of these bans, we believe that the North West region
has taken on the responsibility of supplying data to the community that enables
the degree of achievement of the objectives of the ban to be weighed against the
socio-economic costs of imposing such bans, and that this information will be
extremely valuable when contemplating such bans in other parts of the country. Should
there be rigorous evidence that such bans, and supporting measures (including
blocking of other routes of introduction and effective enforcement) be shown to
achieve their objective, then such bans become much more acceptable to the affected
community (not just anglers, but those who depend on the substantial leisure and
tourism multipliers of regional angling opportunities). If
however, there is no such evidence, then the reasons for imposing such bans will
be called into question with increasing vigour. We
are hopeful that, having imposed such a ban, such information from ongoing assessment
of its effectiveness will be readily and publicly available, to enable sensible
future decisions to be taken in the light of knowledge gained, rather than unsupported
opinion. Yours
sincerely, Chris
Burt,
Vice President
Specialist Anglers Alliance
http://www.anglers-net.co.uk/saa
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