Submission from the South Western Regional Fisheries Board to the
Joint Committee on Communications, Marine, and Natural Resources
1.0 Principles of fishery management
There are just two principles of fishery management. Both are equally important.
Firstly you protect your stock so that you have optimum spawning. This is so that you
can generate the maximum surplus. In relation to salmon this means that you must protect
against habitat degradation, destructive physical work in rivers, excessive water
abstraction, pollution, theft (poaching) and excessive predation from predators such as
cormorants, mink, seals, fishermen and anglers.
The second principle is that you maximise the benefits you get from the surplus you
produce. This means you get the best use out of the resource - the highest value from the
product from the most cost effective inputs.
While these two principles may appear obvious and sequential they are regularly
confused.
2.0 Clarity of objectives
So let’s reduce predation – buy out a fishery –why? Is it because we are not getting the
highest value from our salmon or because we are not optimising spawning? These are
two entirely different objectives and we need to analyse which of these objectives, (if
either or both), would be efficiently achieved by the proposed buy out. Ireland has
fisheries in surplus and fisheries where we have yet to optimise spawning. The primary
management objective is different in both circumstances and we need to clearly recognise
this from the outset.
From one perspective fishermen and anglers are primarily predators that must be
controlled but from the other they are the key partners in delivering the highest value
from the surplus.
3.0 Policy -generating the best climate
Where necessary fishery managers must be prepared to work against the short-term
interests of stakeholders who want to exploit the stock when it is not in surplus. However
it is much more effective and efficient to work with these interests persuading,
demonstrating and producing the longer term benefits which they will be needed to
deliver. This means that a policy climate needs to be maintained where cooperation can
flourish, where your partners see their interests persisting into the longer term, and where
there can be a reasonable expectation that everyone will benefit from the necessary
sacrifices and contributions.
The South Western Region has the biggest commercial fishery in the country at present.
This fishery is scientifically sustainable. Based on the models used by scientists the quota
for the southwest should be about 60% higher than it is currently. However the scientists
recommend that there should be no increase over the average catches for the past five
years even though their model supports such an increase. This is a management
recommendation rather than scientific advice. From a management perspective it sets a
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disturbing precedent. It signals that even where sacrifices have been made, discipline
agreed and applied, and benefits result, those benefits are not to be shared. This
undermines a co-operative approach to salmon management and therefore discourages a
long term responsible approach being adopted by stakeholders.
4.0 The buy out debate
Our angling industry wants more of the resource. This is to be expected. If the angling
industry value fish more highly than commercial fishermen you could expect that the
parties would try to do a deal and when done they would then request the State to
facilitate it. The State would either facilitate the deal or not depending on the implications
for the public interest. This has not happened, fundamentally because the angling sector
is not generating the resources that render it capable of mounting a ‘take over’. In these
circumstances the angling sector wants the tax payer to buy out the commercial
fishermen to enable this transfer. They support their case by presenting arguments on
environmental, economic and social grounds. If these arguments are valid then the tax
payer could consider their investment worthwhile.
However many of the arguments presented to date do not stand up to in-depth analysis.
4.1 The environmental arguments:
The first principle of fishery management outlined above applies.
In those parts of the country where we need more fish to spawn, we have to limit the
killing of fish by all sectors. Transferring a point of kill has no beneficial effect. The
environmental requirement in these districts puts the State, as the conservators of the
resource, at odds with the short term objectives of both commercial fishermen and rod
angling interests. Regulation is the prime management tool and the State can either
enforce at high cost or gain the assistance of the sectors it is regulating. To be successful
in achieving its objective efficiently it is necessary that the State applies necessary
restrictions in an impartial and even handed manner and therefore must resist and be seen
to resist unilateral efforts from either side to pass their burden on to the other.
However the implication from the scientific advice is that sooner rather than later we
must stop all exploitation in seven of our seventeen districts. This should be done with
equity i.e. no killing by either commercial or rod fisheries. There is no legal requirement
on the State to buy out the fishery if the purpose is for conservation from which the
sectors will benefit in the future. Indeed it is in the State’s interest to retain the capacity
of the fisheries for when a surplus is reproduced. However while the rod fishery can
continue on a catch and release basis there will be some hardship resulting for the
commercial sector. While the State has no legal requirement to do so it should alleviate
this hardship by introducing a series of measures. Some of the measures outlined by the
commercial fishermen in the Southwest in their recently published strategy document,
following further development, should be made available on a voluntary basis.
In addition there should be a significant programme on a new scale of habitat
improvement and environmental protection directed primarily at these districts.
While some districts may recover quickly, unfortunately on the eastern coast salmon
productivity has been low over the past fifty years, and there are significant
environmental problems to be addressed. It is unrealistic to expect that some of these
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fisheries will produce surpluses and become commercially viable even in the medium
term and it may be better if these are designated now as conservation areas (no killing
allowed) on a permanent basis. In this context investment in alternative long term
enterprises (such as ranching) is justified to offset income loss for displaced commercial
fishermen.
4.2 The economic arguments:
The second principle of fishery management outlined above applies.
The economic arguments presented by those who advocate the stopping of the
commercial fishery fail, fundamentally, because in those districts where we have a
surplus that we can exploit, the marginal value, i.e. the value of selling another rod
caught fish or another commercially caught fish will change depending on market
conditions but not to the extent that it is better to sell all fish in either way. As availability
of either rod caught fish or commercially caught fish decrease the price per fish increases
to a point which exceeds yet another fish caught by the other method. As the State wishes
to maximise the benefits to the economy it will remain in the State’s economic interest to
maintain both industries.
While this region has one of the best rod fisheries in the Country and the scientists are
indicating we are and have been exceeding our spawning requirements for many years
(and therefore the stock is there to support our rod fishing industry) we consider that the
commercial fishery is currently making a greater contribution to our economy than the
rod fishery. More importantly we consider that its potential for development in the future
is greater than the rod fishery as currently organised. The inherent difficulties in the
organisation of the rod sector (ownership pattern, lack of clarity in relation to ownership,
and lack of respect for ownership including State ownership where established) are such
that this situation is unlikely to change in the short to medium term. However this should
receive prime focus for future policy change.
The Board notes the analysis presented in the strategy statement published recently by the
commercial fishermen in the region as follows:
“State investment is not justified in the transfer of the fishery to the rod sector.
While we reject the premise (based on our economic consultants analysis) outlined in the
Indecon Report we accept that an individual salmon caught by a tourist angler may be
worth more to the economy currently than that fish caught by the commercial sector.
However the frequent extrapolation that therefore it is in the public interest that there
should be a transfer of fish to the angling sector is erroneous. The fact is that if we forgo
100 fish only 3 of them will be taken by tourist anglers. This is because of the way the
inland fishery is organised and we see no likelihood that this inherent inefficiency in the
inland fishery will be addressed. Even if we were to accept that these fish are worth €423
each to the economy (Indecon),the commercial fishery is contributing and can contribute
many times more than a mere €1269 (plus a marginal contribution for the consumption
value of fish caught by locals) for 100 wild salmon. In these circumstances that exist and
will persist in Ireland the transfer of additional fish to the rod fishery is inherently
wasteful and should not be supported by the use of public funds.”
In these circumstances and given the current structure a tourist rod caught fish would
need to be worth more than 33 times a commercially caught one to justify a transfer, and
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it simply is not, nor will it be in the future until a concerted effort is made to create an
environment where investment by fishery owners is allowed to deliver a viable return.
4.3 The Social arguments
The second principle of fishery management outlined above applies.
The social arguments are derived from the economic ones and relate to the importance of
maintaining people and businesses in remote rural areas. These arguments are made by
both industries. Both industries support people from the same or similar communities. In
these circumstances the social interests closely reflect the economic ones – the
maintenance of both industries.
5.0 The interceptory fishery
Much of the pressure applied for a change in policy utilises arguments against the
concept of an interceptory / mixed stock fishery. We are asked to take account of our
international responsibilities. The Board agrees with many of the comments made by the
commercial sector in their recently published strategy document in this regard.
In addition we wish to point out that while there are risks to a mixed stock fishery there
are some safeguards as well. Healthy fisheries contribute most to mixed stocks. If a
fishery is not achieving its spawning requirement you are better off fishing the allocated
quota in a mixed fishery environment where some of the quota will be provided by
healthy fisheries rather than fishing the quota solely from your own depleted stock. If for
instance fisheries on the Northern and Western coastline are taking fish destined for the
Southwest this is preferable to their entire allocated quota coming from their own stock.
In this way the interceptory fishery enables the strength of the southwest fisheries to
support fisheries in other districts.
From a management perspective it would be easier to manage on a single stock basis.
However we are not asked to do what is easy for managers but what is best for our
citizens. The concept of a single stock fishery if taken to its logical conclusion would
bring exploitation down to each tributary as our scientists state that they are genetically
discrete. A move to a single stock management regime would fragment the commercial
fishery and the necessary economies of scale to deliver a viable return on effort and to
ensure efficiency in distribution and marketing would be undermined. While more
difficult it is not beyond our capability to manage fisheries on a mixed stock basis and we
have demonstrated our capacity to do so in the past.
The demand for a single stock management regime ignores the reality that all fisheries in
the sea are potentially mixed stock fisheries and it singles out the salmon for special
treatment for no other reason than we know where it spawns. By the same logic once we
know where any species spawns we should then stop exploiting that species anywhere
except on its spawning area (after we have ensured sufficient spawning). This of course
would negate the traditional fisheries of many maritime nations around the globe.
The United Nations Agreement for the Implementation of the Provisions of the United
Nations Convention on the Law of the Sea of 10th December 1982 relating to the
Conservation and Management of Straddling Fish Stocks and Highly Migratory Fish
Stocks (in force as from 11 December 2001) which arose from Agenda 21 adopted by the
United Nations Conference on Environment and Development deals with these fisheries.
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The agreement recognises in article 7 ‘the sovereign rights of coastal States for the
purposes of exploring and exploiting, conserving and managing the living marine
resources within areas under national jurisdiction as provided for in the convention, and
the rights of all States for their nationals to engage in fishing on the high seas in
accordance with the convention’. It also specifies among its provisions that coastal States
shall ‘take into account the interests of artisanal and subsistence fishers’.
There has been a national effort in Ireland, matched by none, over the past few years to
conserve our salmon. We have done much more than meeting our international
commitments. We are entitled to benefit from our efforts, both at sea and in our rivers.
6.0 Scientific advice
It is important that scientists produce the best advice possible so that the managers of the
resource are enabled to make sound management decisions. These are distinct disciplines
with distinct roles to play. Scientists must point to what ought to be done. Management
must focus on what can be done, what is practicable and deliverable within the
constraints that exist. We all need to maintain confidence and trust in our scientific
advice. It must just not be impartial but be seen to be so. It will be even more important
in the future that there is increased and continued investment in scientific research and
equally important is the presentation of that advice in a manner that builds public
confidence and support.
7.0 Conclusion
Anglers and commercial fishermen must both come to accept that their interests are
secondary to those of society as a whole. Current policy derived from what is considered
best for society is to assist and support both industries and to maximise the collective
benefits. This Board considers that the current policy to share this resource among the
current beneficiaries is the correct one and it advocates the continuation of this policy.
In this context, it is important that where fisheries are well managed or have recovered
that all sectors benefit and are seen to benefit swiftly and in proportion to the contribution
they have made to the recovery effort.
It would be beneficial for this policy to be reaffirmed so that an environment is created
where interest groups would see the need to focus their efforts on working with each
other and with State agencies so that we can protect and develop this resource and
increase the benefits for all.
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