Federation of Irish Salmon
& Sea Trout Anglers
Conaidhm na Slat Iascairi Bradan
& Breac Geal
F.I.S.S.T.A.
www.fissta.com
Noel Carr, Runai, Teelin Rd, Carrick, Co Donegal 074 9730300 phone & fax email:dgl1@indigo.ie
FISSTA SUBMISSION DOCUMENT TO THE JOINT OIREACHTAS SUB
COMMITTEE ON MARINE – REVIEW OF SALMON ANGLING AND NETTING.
THE VIEWS OF THE ANGLING SECTOR
INTRODUCTION
This Federation firstly wishes to thank your Sub Committee for their initiative in reviewing
angling and commercial netting of the wild Atlantic salmon. Our Federation or FISSTA have
lead the angling campaign to save our wild salmon stocks since our formation in 1984. We
have grown to over 100 registered angling clubs or bodies with 20,000 member anglers,
12,0000 who are on our insurance register. Many, who may not be anglers themselves, join
our cause to support the conservation of our wild Atlantic salmon and seatrout.
Our sport of angling is one which our clubs take an average of 25,000 fish or 7-10% of the
national catch annually (see table page 3 for details on damage of driftnet policy to salmon).
Over 75% of our Irish rod license holders failed to catch a fish in 2003 according to the
Central Fisheries Board. While we make no apology for the taking of this catch, it is
important to state that angling is a fully sustainable and indeed essential conservational
practice as in many cases such cropping has been part of the efficient management of our
fisheries for many generations. Anglers are the victims of this mismanagement of our
salmon and are not the cause of this very serious problem of dwindling stocks. However, we
can offer this Sub Committee the solution to their recovery by appealing to the Minister to
remove the cause that takes the remaining 90% of the national catch. Our key position at
the salmon fishery womb and on the spawning beds of our waters means that Irish Anglers
have the ultimate responsibility to all, including the international community, to ensure this
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
magnificent fish survives as it faces it’s most serious threat ever in the coming months of
this season.
FISSTA summarise the aims of the Irish Angling Sector as follows:
1. We want the return to abundance of our salmon and seatrout. To obtain this goal we seek an
end to commercial netting. We support the North Atlantic Salmon Fund (NASF) buyout model
to achieve this most effectively. Areas such as habitat enhancement, water quality and
pollution must be factored into any agreed plan if we are to succeed.
2. We want the freedom to practice our sport without undue state interference as all other
codes do. Access in the form secure tenure for state waters is essential in the form of 7
year minimum leases as already promised in 2002 by the then Ministers of Tourism, Marine
and Heritage, so that we can all develop the Irish angling product.
3. We acknowledge the right of other countries to demand their right for Ireland to cease the
slaughter and protect their salmon on their way through our waters. For this reason we
append short submissions from NASF and Wessex Salmon Trust as part of our international
partnership with such bodies who share our common aims.
As part of the European Anglers Alliance our affiliated Angling Clubs and Associations have been put
under threat of extinction for many years now and sadly, many have already fallen to mounting
pressure from environmental pollution which has decimated stocks in some European river catchments.
In Ireland, the game fishing sector has also had to deal with the added threat over the last 30
years from the commercial fishing sector on the high seas whose activities have brought stocks of
wild Atlantic salmon to dangerously low levels. Indeed it would be true to say that naturally
regenerating stocks have declined so alarmingly that even their very continued existence is now been
called into question. I attach the most recent table which highlight the plight of our once great
fisheries. These figures are taken from the advice of the Government funded Standing Scientific
Committee to the National Salmon Commission.
In 2004 the number of salmon caught, by both commercial and recreational fishing, may be down by
as much as a third on last year. Many rivers, especially on the East coast, no longer have a
sustainable breeding population of fish. Even before the latest collapse, the Minister of State for
the Marine, Mr John Browne TD, gave a warning in a speech in February 2003, that “the scientific
advice is very clear that if we don’t reduce our exploitation of stocks then we will have no salmon
resource in the near future”. Yet, Minister Gallagher TD allows quotas based on expert scientific
advice to expand from 97,000 fish to 140,000 as the political lobbying is permitted to influence the
breaking of yet another promise at the expense of the wild Atlantic salmon species.
More than two-thirds of the salmon taken from Irish waters are killed at sea by drift-nets – long
entanglements that entrap the fish as they pass homewards to breed in their native rivers. That is
the simplest reason for the campaign and why FISSTA founded the Stop Salmon Driftnets Now
campaign with our other partners in July 2004.
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
We in Ireland have confronted and fought these threats to our angling resource through FISSTA,
without the support of the Irish Government, for many years now. Whilst we have always been willing
to sit down with successive Dept. of the Marine Ministers to have these problems professionally
addressed in a sense of "true partnership", unfortunately sectional interests have been allowed to
dominate within the Department of the Marine to the great cost of our salmon stocks and angling
tourism industry. This policy has excluded the true owners of the resource, their own citizens, from
active participation in development of tourism, environmental and heritage strategies. It is true that
some past governments did attempt to introduce legislation and new measures which would have
improved the lot of the salmon. But sadly, by the time the commercial and aquaculture interests had
their lobbying done, the effectiveness of these proposed measures were so seriously undermined,
they left them virtually meaningless. One of the first proposals that came to fruition from the
"Salmon Task Force Report" was the legalising of "monofilament nets", despite the fact that they
would only be introduced "as part of a comprehensive package of 'tags and quotas' for the
commercial sector".
Despite protests from FISSTA, our voice as a representative angling body was "ignored". The
factthat "angling tourism" in Ireland makes a huge contribution to the socio economic aspect of life in
this country, has also been ignored, with horrifying consequences for wild salmon being predicted by
some game angling interests.
It is important that the international salmonid community understand that FISSTA seek support from
all international bodies, including NASCO and EAA to achieve our main aim, the conservation of the
wild Atlantic salmon and sea trout.
When FISSTA released the above figures at the June 2003 NASCO meeting in Edinburgh the
Government through the Dept of the Marine rejected them. However, upon further examination by
the Marine Institute the Department appears to have has since accepted them as the RTE PrimeTime
Programme of February 2005 clearly records the same salmon run of 450,000 fish.
WHERE HAVE ALL THE SALMON GONE?
WHERE THE SALMON WENT IN 2002
North Atlantic Salmon Run in 2002 to Ireland & EU = 500,000
Driftnets Method gives 150,000 to seals before capture = LEAVING 350,000
Commercial netting took 206,000 to the quayside= LEAVING 144,000
Commercial Orange tags of 70k unaccounted for in 2002= LEAVING 74,000
Anglers took 25,000 CFB total 260,000 tags used in 2002= LEAVING 49,000
FISSTA estimate total salmon kill in 2002 at 451,000
Sadly less than 49,000 salmon left free for return to spawning IN IRELAND AND EU
NB: While the CFB figures state that anglers took 31,274 fish in 2003 this includes seatrout which also had to be tagged.
While
this amounts to 16.1% of the national catch, FISSTA dispute this figure as it disregards the huge loss of over 150,000 fish taken by
the seals specifically in the drift nets. ie; seal mortality solely due to driftnets and not any other natural way in which seals take
salmon. Please note that despite constant campaigning to state authorities to have this fact scientifically acknowledged or better
still analysed by the Standing Scientific Committee to the National Salmon Commission or even NASCO, no action has been taken
to date which would significantly readjust the huge damage which the state driftnet policy is doing to our stocks.
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
The National Executive is concerned that the resources needed to police the current and proposed
regulations are totally inadequate. Most Fisheries Boards have insufficient resources to mobilise
their protection staff and without their being able to do so control measures will once again this year
be ineffective. Reference from the Irish Times articles and the February 2005 Prime Time
programme detailing the complete failure of the SWRFB to protect fish stocks in the area under
their jurisdiction. FISSTA states unequivocally that their bona fide clubs will continue to fill the
vacuum in providing fish stock protection on the rivers under their control. They also unequivocally
state that their affiliated Clubs will provide voluntary service, at no expense to the State, on State
Fishing Waters which should be immediately transferred to their control, thereby freeing Fisheries
Officers for deployment in our estuaries and at sea. The fact remains that no serious effort on the
part of Government has led to this very serious stocks damage issue being dealt with by either the
RFB or the Gardai. What has happened to the proposed protection programme and poaching hotline as
promised as far back as 2001?
In meetings and correspondence with the Minister of State, FISSTA representatives have argued the
case for commercial quotas and tags, being individual and non-transferable and succeeded in obtaining
the written promise from Minister Frank Fahey TD in January 2002 prior to the May General
election. Sadly, this one of five of our promises that was never delivered on after that election
although we continue to seek these promises to this day. The National Executive is dismayed that
the Minister has not used the opportunity presented by the FGS report to overhaul the entire salmon
management policy as:
 In 2005 Ireland will be the only jurisdiction of any significance permitting the exploitation of
salmon stocks at sea;
 It represents approximately one third of the total annual flow of mixed stock salmon along
the Irish coast that is going to the commercial sector.
 The permitted quota, even discounting the levels of illegal fishing that occur, represents only
part of the total kill levels of drift and draft nets – some drift net fishermen estimate, for
instance, that over 55-60% of the salmon captured by their nets are lost to seal predation
before their can be landed. Based on the entire EU salmon run of 500,000 (CFB Dr. Mc
Ginnity’s Nov. 2002) the commercial netting catch is 97%, while angler catch is 3%.
 The scientific advice and the deliberations of the Standing Scientific Committee is interfered
with by unqualified members of the National Fisheries Management Executive who respond to
political lobbying at every opportunity.
THE INTERNATIONAL DIMENSION
The Wild Atlantic Salmon is migratory, born in the river of one nation and feeding in the coastal
areas of several nations before returning to its homewaters. During these travels from birth to it’s
return it has to overcome daunting obstacles to its very survival from habitat degradation pollution,
predators, sea lice infection and diseases from ocean fin fish farming,hunger from commercial
plundering of its food chain, but most damaging of all are walls of legal and illegal interceptory nets
and long lines which indiscriminately kill mixed stocks for different river catchments and indeed
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
salmon bound for other countries.
FISSTA has supported NASF (North Atlantic Salmon Fund) in its efforts to purchase the Greenland
and Faroese Islands Quotas. However, we feel that this yearly 'leasing out' needs to be changed to
an outright purchase ofsuch quotas which should not fall on the shoulders of Orri Vigfusson and his
dedicated committee but should be the responsibility of the various governments of all the salmonid
countries.
FISSTA acknowledges the vital need for and importance of the international salmonid arena regarding
the protection and enhancement of the wild stocks. To this end FISSTA are members of several
international salmonid organisations such as NASCO. We were among the first NGO's (Non
Governmental Organisations) with consultative status, to be admitted to NASCO and played a
pioneering part in advancing the respect for and participation of the NGO's at the annual meeting.
In this context FISSTA has consistently exposed before the salmonid world the gross irresponsible
mismanagement of salmon stocks and finfish farming by the Irish Department of the Marine.
Sadly, as stocks dwindle, the NASCO experiment has failed to date and while FISSTA are currently
reviewing it’s participation as an NGO to NASCO we take great encouragement from the open
acknowledgement of NASF buyout achievements at the Icleandic conference in 2004. This session of
NASCO admitted openly that they have not succeeded in halting the alarming decline in the wild
Atlantic stocks and only success was found where compensation agreements were in place. We must
all redouble our efforts in Ireland to learn from this experience and to embrace the expertise that
NASF can offer to achieve our shared and ultimate objective of wild Atlantic Salmon abundance.
To whom it may concern in Ireland
We are pleased to learn of your joint committee’s aspiration, in regard to salmon, to review angling and
commercial netting. The primary role of Wessex Salmon and Rivers Trust is the restoration and conservation of
the seriously depleted salmon populations of the lowland rivers of southern England.
We wish to ensure that salmon originating from neighbouring E U nations are represented. These include those of
the United Kingdom who, like Ireland, are signatories to the European Habitats Directive. Scientists of both
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
governments co-operate in joint working parties, researching the very matters under review. Important data from
the most recent 2002 joint working party, whilst no doubt available to your committee, is not yet published. In
these circumstances and in the interests of a comprehensive process we respectfully request that our
representation in these matters be allowed.
Nearly all southern English and Welsh rivers that are candidate ‘Special Areas of Conservation’ under the
European Habitats Directive, with salmon as a reason for that designation, are failing to achieve a ‘Favourable
Conservation Status’. It is agreed science that Irish drift nets exploit salmon originating from these cSAC rivers,
some of which allow no exploitation by angling or estuarial netting. Thus the drift nets under review are
contributing to those river’s failure to achieve a Community Objective. It is our contention that the Irish
Government, as the licensing authority for the drift nets, is in infringement of the European Habitats Directive.
In this context we would draw your committee’s attention to complaints laid before the European Commission for
the Environment by this trust and others in the United Kingdom and elsewhere. Resulting interrogatives that have
been submitted by the E U Commission to the Irish Government have generated responses which the Commission
have not accepted. As a result the matters are now the subject of a review process by the whole Commission.
We are confident that your committee’s process will be enhanced when these facts are taken into account. We will
be pleased to be of service to your committee’s deliberations.
Yours sincerely,
Brian Marshall.
Wessex Salmon and Rivers Trust.
MEMORANDUM FROM THE NASF COALITION RE SUBMISSION TO THE JOINT COMMITTEE
ON COMMUNICATION, MARINE AND NATURAL RESOURCES March 22 2005
NASF is greatly concerned at the Irish government’s refusal to accept its international obligation to
protect the migrating salmon of other nations. The path taken by the returning salmon of Ireland’s
EU partners takes the fish down the Irish west and southern coasts. Many of these fish, which are
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Conaidhm na Slat Iascairi Bradan & Breac Geal
“Committed to Conservation”
desperately needed to restore stocks that in many cases are tottering on the verge of extinction,
end up in Irish drift nets.
The drift net fishermen are not to blame. They cannot confine their catches to Irish salmon
because during their homeward journey the Irish fish have become inextricably mixed up with the
salmon of the other European nations and there is no way the fishermen can tell whether they are
catching Irish salmon or those of foreign origin.
The end result of losing so many of their returning fish is disastrous for the countries represented
by the NASF Coalition. They cannot hope to begin successful stock restoration schemes until the
Irish net issue has been resolved.
Following the recent launch of a pilot set-aside scheme in Norway, Ireland is now isolated as the only
country that refuses to implement NASF-type agreements in which commercial fishermen agree to
stop salmon fishing in return for fair compensation. These schemes have been successfully concluded
in Newfoundland, Labrador, Greenland, Iceland, the Faroe Islands, Wales, SW England, the North
Sea and in the Northern Ireland Conservancy area. Ironically, in view of the Irish government’s
refusal to co-operate, Ireland’s salmon all enjoy the protection of one or more of these conservation
agreements.
In the last decade the NASF Coalition has spent millions of euros protecting Irish and non-Irish
salmon. No less than 99% of the salmon quota biomass in Ireland is created on the salmon’s sea
feeding grounds around Greenland, Iceland and the Faroe Islands. The Irish authorities should not
forget that if commercial salmon fishing were not banned in these areas a single ordinary pelagic
fishing vessel would take no more than 12 minutes to intercept the entire annual Irish commercial
salmon quota.
We understand the netting quota is likely to be set at 139,000 salmon this year. We would urge the
members of the sub-committee to say that in view of all the scientific evidence any Minister
prepared to authorise such a high figure would be making a totally reckless decision that could prove
fatal for the many Irish rivers that have already lost most of their stocks to drift netting.
The NASF Coalition represents the salmon stakeholders of France, Spain, Germany, England and
Wales. The UN Law of the Sea Convention, Art. 66, establishes that countries of origin have the
primary interest in and responsibility for their migrating salmon stocks right up to the coast of host
countries. It requires the host countries (in this case Ireland) to cooperate with the countries of
origin to achieve this. In a letter dated November 15, 2002, we formally requested the Irish
Government to comply with this obligation.
We subsequently presented the Ministry with a brief on the NASF Coalition’s management principles
and a proposal for a working relationship. Despite numerous requests we heard nothing further from
the Marine Minister. Following complaints to the Irish Ombudsman at this failure to respond to our
letters we were finally informed in January this year that the NASF claim had not been accepted.
As a signatory of the UN Law of the Sea Treaty, Ireland has an international duty to cooperate on
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“Committed to Conservation”
salmon management inside its fisheries jurisdiction. It is also obliged under the the Bonn Convention
on Migratory Species and the OSPAR Convention to protect stocks belonging to neighbouring
countries. In simple language it means that salmon of non-Irish origin have full protection rights
right up to the Irish coastline.
Despite the dire state of EU salmon stocks (including those of Ireland itself), the Irish driftnets
have been increasing their catches. Ten years ago the Irish drift nets harvested 26% of the total
Southern European salmon catch. Now they are taking well over 50% of the catch and creating an
untenable situation in so doing. While the NASF agreements are building up stocks in the rest of the
rivers that run into the North Atlantic the stocks in Ireland’s own rivers are fast declining to crucial
lows.
There is no international police force to enforce our rights under the UN
Law of the Sea Convention. In any case we would much prefer to resolve this matter amicably.
Despite numerous requests, however, the Irish Government has evaded taking part in a fair and
balanced dialogue or constructive talks with the Coalition.
The inter-governmental NASCO organisation is impeaded by the terms of its treaty from dealing with
this issue. The European nations do not want the EU Commission to become involved in matters inside
the 12-mile limit. This effectively excludes these two bodies from offering possible solutions
because most non-Irish salmon are intercepted within one mile of the Irish coastline.
In the interests of both our Coalition countries and of saving what should be one of Ireland’s most
important natural resources we earnestly request the Joint Committee on Communications, Marine and
Natural Resources to take all steps open to it to ensure that the Irish Government immediately
engages in talks to resolve the matter.
Orri Vigfússon Chairman
NASF Coalition
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“Committed to Conservation”