LOUGH ERNE FISHERY MANAGEMENT PLAN CONSULTATION
RESPONSE DOCUMENT
RESPONDENT INFORMATION
Please Note this form must be returned with your response to ensure that we handle your
response appropriately.
1. Name / Organisation
Organisation Name (If applicable).
Ulster Angling Federation 6500 Anglers
Title Mr x
Ms
Mrs
Miss
Dr
Please tick as appropriate
Surname
Marshall
Forename
Robbie
2. Postal Address
14 Gleneden Park
Newtownabbey
Co Antrim
Postcode BT37
0QL
Phone 90864564
Email
rob_f_marshall@hotmail.com
1. Proposal for the removal of the imaginary line defining the
coarse and game areas of Lower Lough Erne and to allow the use
of maggots and ground bait in designated areas of the Lower
Lough shore. DCAL to review the legislation and simplify it where
possible.
Your comments: The removal of the imaginary line was
something DCAL agreed to do many years ago but failed to carry
this through, and we were of the understanding that the lake
would then be treated as a game fishery. We welcome the
removal of the line.
It was never agreed that ground baiting and maggots could be
used on the Lower Lough. This flies in the face of the
precautionary approach, where is the scientific evidence to show
this will not have a detrimental effect on fish and water quality?
We would not agree to this when there is no mention of which
areas would be designated. For example the Maho shore is a
productive trout drift for boats and any development there would
restrict trout angling.
2. DCAL to review of the cost and number of available commercial
and angling licences
Your comments: We welcome the fact that DCAL are to review
commercial licences and we would support the idea to allow
additional licence holders to commence commercial fishing. The
cost of an angling licence has nothing to do with a Fishery
Management Plan.
3. DCAL to review the policy on permits for commercial fishermen
on Lough Erne
Your comments:We welcome the fact that DCAL are to review the
policy for permits for commercial fisherman. This long
established commercial fishery must be allowed to continue and
younger people encouraged to go into commercial fishing.
4. DCAL propose to hold regular meetings with commercial
fishermen
Your comments: We welcome this proposal.
5. DCAL to consider mechanisms to improve the return rate of
annual angling catch returns
Your comments: This is essential to ensure the success of a
Fishery Management Plan.
We also believe that DCAL should request the catch records from
local clubs for their competitions and recognise these as an
indicator of fish stocks. The UAF would be happy to coordinate
this with their clubs.
6. DCAL to consider the introduction of a single licence to allow
both game and coarse angling
Your comments: No comment.
7. DCAL to allow up to 2 rods per angler with a maximum of 4 rods
allowed per boat for trolling on Lough Erne
Your comments: We welcome this proposal, however this needs
to be made clear that it applies to boat angling on Lough Erne
only. As it stands it could mean that an angler could take 2 rods
to a local river and fish both of them.
8. Proposal to develop angling infrastructure for coarse anglers in
deeper areas of Lough Erne
Your comments: We need more information on this proposal.
Does this apply to the Lower Lough or Upper Lough. We cannot
agree to this if it means additional infrastructure on the Lower
Lake or indeed where is it likely to occur. If it does apply to the
Lower Lough why is no development being proposed for the
Upper Lough?
9. Co-ordinate the promotion and development of angling on the
Lough Erne catchment with the relevant statutory and non-statutory
stakeholders
Your comments: Again there is insufficient information to make
an informed decision. Who are the relevant statutory and nonstatutory stakeholders?
10. DCAL to work with the stakeholders to maximise the economic
returns from both recreational angling and commercial fishing
Your comments: There is insufficient information to make a
decision on this proposal. What stakeholders? What does the
phrase “maximise the economic returns from both recreational
angling and commercial fishing” mean?
DCAL need to set out their proposals on how they intend to work
with local councils and how they intend to deliver these returns.
11. DCAL to consider the commercial exploitation of perch fish
stock on Lough Erne by carrying out some assessments using a
variety of non lethal methods to inform the policy:
Your comments: Once again DCAL need to advise which of the
lakes this proposal refers to? We reserve comment until we know
which.
12. DCAL to ensure an effective enforcement programme is in
place to protect fish stocks and their habitat, which will include
training and support for Private Water Bailiffs:
Your comments: DCAL need to advise how they intend to do this
when they only have 9 bailiffs on the ground for Northern Ireland.
There would be little support from Private Water Bailiffs if the
Lower Lough is not treated as a designated brown trout fishery.
Anglers advise that the patrol boat was rarely out during 2015
season at present this is a DCAL responsibility. What are DCAL
plans to ensure effective enforcement?
13. DCAL to promote the education of stakeholders to improve
compliance with the legislation:
Your comments:
This clause was not included in the original proposals.
We feel this approach will send out the wrong message and lead
to greater problems in the long run. While we appreciate that some
leeway would always be available to officers, we do not feel that
publishing this as a policy and then acting upon same will achieve
the desired result. There should be a concentration on making the
regulations well known and then applying them in the field.
14. Proposal that DCAL does not permit the use of commercial nets
in Upper Lough Erne:
Your comments: It is the understanding of the Federation that
there are 2 commercial licences on the Upper Lough, what is the
purpose of closing this fishery down? What evidence have DCAL
to suggest no commercial netting.
15. To increase the minimum takeable size for rod-caught trout to
35.5cm for Lough Erne and introduce a minimum takeable size for
trout of 25.4cm for all its tributaries and all waters in the DCAL
area. DCAL propose a daily bag limit of 3 trout per angler per day
to apply to Lough Erne and all other trout fisheries:
Your comments: Many of our member clubs have been operating
this size limit on a voluntary basis for many years. However when
this was discussed with Robert Rossell the trout clubs were
advised that such changes would have little to no effect on trout
stocks. Please provide the scientific evidence to back up this
proposal. The proposal to introduce a daily bag limit of 3 trout per
angler per day is welcomed, however we do not believe that all
other fisheries can be included in a Fishery Management Plan for
Lough Erne. The other fisheries should be the subject of a
separate review as they have nothing to do with Lough Erne.
16. DCAL to improve fisheries habitat, remove fish barriers or
improve fish passage at barriers in the tributaries of the Erne
Catchment:
Your comments: This is essential for the success of any Fishery
Management Plan.
17. DCAL to review stocking policy under-pinned by further
scientific analysis:
Your comments: Whilst DCAL are saying they have not closed the Marble
Arch hatchery, it is their lack of uncertainty around stocking which has
forced the Directors to look at closing the hatchery when there are sufficient
funds to do so. How then can DCAL propose to review stocking policy
under-pinned by further scientific analysis when no more indigenous trout
will be available. We recommend that future assistance is provided to EMEC
until such times as the scientific evidence is available so a proper informed
decision can be made.
DCAL also need to advise how they will stock tributaries in the Lough Erne
catchment with indigenous fish (as per the recent EU ruling) in the event of a
critical pollution incident or other such like incidents.
18. To continue to allow commercial fishing for pike on Lough Erne
using existing regulations, but to restrict it to a maximum catch of
10 tonnes per annum:
Your comments: The biggest part of the problem with trout
fishing on the Lower lake is that pike have displaced the trout
from the shallows. Research by Robert Rossell confirmed this.
With trout now in the deeper water they cannot be targeted by
fisherman and as such catches are now at an all time low. It is like
looking for a needle in a haystake to find trout in the deeps. If the
proposal to restrict the maxium catch of pike to 10 tonnes when
in the past 30 tonnes were removed the problem will get worse.
Again where is the scientific evidence to show that only up to 10
tonne is sufficient to allow trout fishing to be sustainable?
19. DCAL to commission regular scientific monitoring of fish
stocks on Lough Erne and its tributaries to provide long term
datasets to identify trends in fish populations:
Your comments: This proposal is welcomed.
20. DCAL to collect Catch per unit effort (CPUE) data on rod caught
fish:
Your comments: Could this not be incorporated into the proposal
to improve the return rate of annual angling catch returns?
21. To collect data on trout stocks in deeper areas of the Lough:
Your comments: DCAL need to explain the reason for collecting
data on trout stocks in deeper water. If trout remain in deeper
water then game angling will continue to suffer and anglers will
go elsewhere to fish.
22. To collect information on salmon movements and spawning
areas in the Erne catchment to help assess stocks levels:
Your comments: This proposal is welcomed.
23. DCAL to commission more genetic research on brown trout
stocks in the Erne catchment:
Your comments: What is the purpose of this proposal when the
hatchery which was producing Lough Erne indigenous trout will
be closed and stocks will not be available? We also think the
proposal should read “DCAL to commission more genetic
research on brown trout stocks in the rivers in the Erne
catchment”.
24. DCAL to commission more research on bream stocks in the
Erne catchment:
Your comments: No comment
As there is nowhere on the form for additional comments please
ensure you read our additional comments send as an appendix.