Response of Inland Fisheries Review IFO

Irish Fishermen’s Organisation
Cumberland House, Fenian St., Dublin 2
Tel: (353-1) 6612400; Fax: (353-1) 6612424
E-mail: [email protected]
Salmon Division
16 January, 2004
Molyneux House
Bride Street
Dublin 8
“Review of the Inland Fisheries Sector in Ireland”
Dear Sirs,
We wish to make the following observations with respect to the above.
Terms of Reference
The fact that the Review is focused on inland fisheries may give the impression that seagoing
activities are unaffected by its remit. In practice, commercial sea fishermen are the main
stakeholders involved in the salmon fishery and any policy decisions relating to salmon and, to
some extent, sea trout have very direct and serious implications for the commercial sector.
Consequently, it is essential that the sector's views be fully taken into account.
Ireland has an abundance of good sea and freshwater fisheries resources as a valuable natural asset.
It is incumbent upon the State to conserve and protect our natural fisheries heritage for present
and future generations.
The current review of the inland fisheries sector must be seen as an opportunity to reinforce the
commercial community and stakeholder involvement while enhancing recreational and
environmental return to the state on the inland fisheries resource.
The management structure at present, from the Minister downwards to the Regional Fisheries
Boards is a simple and basic structure which has many weaknesses as well as strengths.
The Central and Regional Fisheries Boards, established in the eighties have carried out their
responsibilities in spite of the lack of clear State Policies, Departmental support, sustained funding
shortages, policy logjams at CFB level, and insufficient resources.
The survival of the inshore commercial fishing sector is largely dependent on good management
within the inland fisheries sector.
The main requirements of any structure are that it is seen by those who are affected by and
who have to utilise it, to be transparent, fair and trustworthy. The present structure does
not fit into this category. (See attached criticism by European Ombudsman).
The present financial constraints within the system (e.g.: lack of finance for Regional
Fisheries Boards and their consequent difficulties in exercising effective control of the
regulations) make it impossible to achieve the targets that are required.
Many of the problems relating to good fisheries management (e.g.: damage caused by
predators (seals, etc.); drainage) lie outside the scope of the present structure and therefore
are impacting adversely on any management measures.
The present system is too rigid to cope with a naturally evolving environment.
Despite the recommendations of the Salmon Management Task Force Report (1996) - not
to mention consistent requests from the commercial sector through the IFO over some 20
years - the Department of the Marine & Natural Resources has seriously failed to
determine the actual state of salmon stocks. The official catch figures have long been, and
continue to be, completely inaccurate and are certainly not credible. Lack of accurate
information at this basic level makes it impossible to develop a realistic salmon policy.
“The life history and biology of salmon is so complex that no biologist in his right mind would forecast the
size of Irish salmon runs in advance. It is not even possible to explain the occurrence of good and bad years
with the information known about the fishery. This, of course, does not stand in the way of the "salmon
experts" who know why runs are good, bad or indifferent and exactly whose fault it is", Mr. John
Browne, former Departmental Scientific Adviser
Members of Boards collectively have an enormous range of experience and knowledge,
which if harnessed correctly provides a knowledge base that would be nearly impossible to
provide from a salaried workforce.
Any policies or legislation emanating from a group that is transparent and open, consisting
of elected peers will have far greater support and require less enforcement and finance.
Department of Communications, Marine & Natural Resources.
Historically, the Department (under any of its previous titles) has not shown interest in salmon, at
least from the commercial perspective. It was not until the Salmon Management Task Force was
created that any realistic attempt was made to assess the issues involved. Even then, virtually
nothing was done for a considerable period, and then only selectively and piecemeal - to
correspond to political rather than biological requirements. This has been one of the main
problems in the management of fisheries. The Department is opaque by nature and accordingly
there is a lack of transparency in its dealings with those concerned in fisheries. One major concern
lies in the fact that none of the personnel within the Department have any actual experience in
earning a living from fishing or fisheries management.
National Salmon Commission
Given the right leadership, the basic structure of the NSC is workable, but the terms of reference
need adjusting to compel the Commission to seek out and make recommendations to resolve
problems relating to salmon production and conservation, including predator control and habitat
It has been the experience of the commercial representatives on the Salmon Commission that
discussion is frequently ruled out of order (for no good or logical reason) on basic aspects relating
to the proper management of salmon. It is now evident that the Commission is not
independent, but is expected to follow, and rubber stamp, predetermined political /
administrative positions.
This is a very serious departure from the original purposes for which the Commission was
established, and the matter urgently needs to be rectified.
Central Fisheries Board
The role of the Central Fisheries Board changed slightly in recent years. Prior to that change, its
role was that of an undemocratic policy group that was totally orientated towards angling, and
unsympathetic to commercial fishing. Unfortunately, under the new regime little has changed
other than the creation of a liaison group that still perpetuates divisions amongst the other fishing
disciplines, including the commercial sector.
In fact, the commercial sector has long regarded the CFB as a lobby group for leisure interests.
There is, in reality, no way for commercial interests to become involved at CFB board level as it is
made up of Ministerial appointees. In practice, the current make up of the CFB is totally game
angling orientated.
This situation requires substantial revision. Clearly, it is a ludicrous situation that the major
stakeholders in the salmon fishery have no direct involvement in the deliberations of the CFB
board. Equally, it is not in the CFB's interest to be so alienated from the major stakeholder.
The new role for the Central Fisheries Board should be entirely as a service provider (with no
policy-making functions) for the Regional Fisheries Boards, providing:
A national training scheme for all RFB staffs;
A national training scheme for all those wishing to become water keepers;
A national protection scheme for all inland fisheries;
A chargeable national advisory service for all those who wish to manage private
A scientific support set up for the Regional Fisheries Boards;
A legal support group for all matters in fisheries i.e., Fishery rights, gravel abstraction,
water abstraction etc. These matters usually are too large and quite often affect more
than a single RFB;
Management of state run fish farms to ensure a supply of good quality stockfish of all
types for the RFB’s;
Financial support services.
Some of these services are already provided by the CFB.
Regional Fisheries Boards
Under the present regime, the Regional Fisheries Boards have tended to become mere talking
shops, due mainly to lack of cohesion at the Department of Marine. The role of Regional Boards
has changed drastically over the last number of years but, unfortunately, the lack of policies and
severe financial constraints emanating from the Department of Communications, Marine and
Natural Resources has not kept up with the required methodology and workload of the Regional
Computerisation has helped where trained staff is available, but unfortunately the job descriptions
of new staff applicants do not allow financial inducement for computer trained staff.
Furthermore, many jobs within the Boards are of a field nature and that is time- (and staff)
consuming, especially with all the new legislation currently coming on line.
It should be noted that in some cases Board Management is now starting to supersede many of the
elected board decisions. In the interest of transparency and open management, this trend needs
to be halted.
Also, in the interest of transparency and open management there should be an annual meeting of
all the elected Regional Fisheries Board members, at which matters relating to the Boards
nationally could be discussed.
Marine Institute
The Marine Institute board should be enhanced to encompass stakeholders. It should be managed
by a newer, open and transparent Board, part peer-elected from the various major fishing
organisations concerned with anadromous /catadromous stocks.
The Institute should concentrate on fisheries research and ensure that the fundamental data
required to make policy decisions is accurate and complete. In this regard, there has long been
concern at the apparent inability of the Institute to collect basic data. For example, it has not
performed as expected in installing / operating river counters and has, instead, relied on
extrapolation based on unreliable data.
Bord Iascaigh Mhara
As some of the traditional functions of BIM (such as grant and loan facilities) have become
reduced or redundant, an opportunity exists for it to become more involved with the small-boat /
inshore sector and to maximise the economic returns to the sector. In this regard, greater
emphasis and resources should be placed on enhancing the marketing of wild-caught salmon (for
example). In addition, BIM could be more actively involved in other aspects affecting the salmon
/ inshore sector; i.e. training, gear technology, safety etc.
Environmental Protection Agency
It important to recognise that water quality is a central, and first, issue in any inshore fisheries
management plan. A polluted aquatic environment equates to no aquatic life.
The Environmental Protection Agency should be represented on the Regional Fisheries Boards
and likewise there should be representation at the EPA by a senior staff member of the Regional
Fisheries Boards.
Furthermore, it should be mandatory that the EPA monitor and advise on all planning
applications likely to have an impact on water quality, whether inland or offshore, before a
decision is made on the application. This is especially important in the case of aquacultural
applications - an activity that raises serious concerns regarding both the siting of farms and the
resulting impact on water quality in the area.
EU Directives on Water Quality
All EU Directives should be applied forthwith. It should be noted that many Directives in this
regard are outstanding from the 1970s.
Food Safety Authority
The FSA should be directly involved on an ongoing basis in assessing the quality of farmed
salmon, for two reasons.
1. The potential health impact on consumers of improperly produced animals
2. The adverse impact on the wild product of negative publicity generated by the farmed
Private Hydro-Electric Installations
There has long been concern at the failure of spawning salmon to get upstream and smolts to get
downstream, due to the obstruction caused by hydro-electric installations.
County Councils / Harbour Boards
Similarly, several rivers / estuaries under the control of County Councils or Harbour Boards have
weirs and similar obstructions that create enormous difficulties for migrating fish. In very many
cases these weirs, etc. have long outlived their original purpose and are now redundant, but
continue to present a major problem from a fisheries point of view. All such obstacles should be
removed by order of the relevant Authority.
Drainage Boards
Drainage schemes have, over the last twenty years or more years, been a major problem to
fisheries management. In many areas land drainage has changed the natural flows of rivers turning
them into Spate Rivers in the wet season and leaving them too shallow for fish propagation in the
dry seasons. In effect, rivers have been ruined as a result of drainage schemes.
The power of decision / supervision of these operations should be transferred to the respective
Regional Fisheries Boards.
We would appreciate a detailed discussion with you in due course.
Yours sincerely,
JF Doyle
General Secretary
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