Updated:  08/12/2018

NMC Conservation News

 

 

NMC SIFCA Netting Bylaw Consultation Response - Andy Burt

08/12/18:** The deadline for submissions re the SIFCA netting consultation was 07/12/18, and has now passed; please click here to read NMC's response, prepared by Andy Burt.

Many sincere thanks to Andy for all of the time and considerable amount of care that has been expended upon this extremely important document, and thanks also to all others who have contributed and / or responded.

 

SIFCA Notes and Pointers, Andy Burt - last updated 30/11/18

30/11/18: NMC MCRS Information

NMC have now submitted a paper to SIFCA regarding the Minimum Conservation Reference Size (MCRS) for the grey mullet species, which can be read here.

Where are we now?

It must be pointed out that this is a pre-consultation. Nothing has been finalised and the bylaw at the moment is far from finished, a lot can and will change.

So, what should we do now?

We need to respond by Friday 7th December.

We must put forward what we want, to try and steer the bylaw how we want it to go. There will then be an opportunity to give further comments, amendments may be made and then it has to get agreed, but we won't go into that yet!

It is blatantly obvious that this bylaw as it stands is all about appeasing commercial interests and nothing to do with conservation or considering the needs of all stakeholders. Its primary objective appears to be allowing unrestricted and un-managed netting of grey mullet and appeasement of the EA.

Why appease the EA?

All of these bylaws are being reviewed as an obligation after they were transferred from the EA, they have to do this. The EA sit on all the IFCAs and of course form parts of the same government department - Defra. The EA's primary interest is with respect to salmon and sea trout and they take this very seriously! If the bylaw is to become law the IFCA needs the support of the EA.

The importance of this will be explained later!

So, what should I do now?

  • Respond! Tell them about your experiences and what you see with respect to mullet

  • Fill in the new SIFCA questionnaire described in the 'important update' below, for which the deadline is 7th December 2018 - this is not confined to the NMC!

  • Fill in our previous questionnaire if you haven't already, and ask others to; this is also not confined to the NMC

  • Spread the word; ask your fishing mates to reply, get the tackle shops behind us, it is their living at stake, get your clubs to respond

  • Forward our 'Vulnerability and Over-Exploitation of Grey Mullet in UK Waters' document to any parties you believe may be interested and tell them about the consultation. This is not limited to angling groups, it can be anyone

I have talked before about social and economic impact and the importance of evidence and our data. It is laughable that as far as we are aware, the financial justification for allowing ring netting for mullet was the data we (NMC) supplied to show the opposite!

Now the important update!

Last week we had a meeting with the IFCA in Poole, what a s**t of a place to get to! Attending the meeting from the IFCA was Rob Clark - Chief Officer, Simon Pengelly who has the unenviable task of sorting out the bylaw and John Humphreys the IFCA chairman. On our side were myself, Alan Butterworth and Martin Salter.

Since that meeting, the Angling Trust has posted an update on their website - click here to read, also their consultation response.

Martin described the meeting as 'robust', I'll say a few more words, we told them exactly what we thought and I don't think they liked it. SIFCA do seem determined to allow this ring netting and we talked a lot about a managed fishery, not where we want to go - nets out! We have said, and I believe it is the right thing to do, that all we want is a sustainable and well managed mullet fishery.

There are many good arguments that would support mullet as a recreational only species, and if that were on the table, we would of course not turn it down. That is not realistic; a realistic goal should be a sustainable and well managed mullet fishery, managed for all stakeholders with the mullet as the primary beneficiary - is that not both reasonable and common sense?

We have decided to totally oppose the current proposals. This will align the NMC with the Angling Trust and also crucially the Environment Agency and various other mostly salmonid organisations. After consulting the EA we feel this is the correct option, we will all be pushing the same arguments:

  • there is no evidence to support SIFCA's claim there will be no impact on salmonids

  • the BNAs (bass nursery areas) will be completely unprotected and these are also critical for juvenile grey mullet

  • landing data proves there is no massively important mullet fishery in SIFCA (or anywhere else), contrary to commercial voices

  • grey mullet is a species that is extremely vulnerable to overfishing and numbers can be shown as declining, the IFCA have a duty to protect them from over exploitation.

The EA will of course be pushing the salmonid line but are sympathetic to our other arguments.

The most powerful message we can send to SIFCA however is not just through these three responses but through a large number of individual responses, that is why it is so important everyone responds.

You do not have to answer all of the questions on the SIFCA response or even use their .PDF form (questions start on page 18); an alternative Word version is available here, which you can email back to SIFCA. If you use the latter, it will be very helpful if you can copy me in - my own email address is included within the Word document. You may find this easier to complete if you read the Angling Trust consultation response, but please use your own words. From a mullet perspective it is important that you respond with the following points:

  • The social and economic argument is crucial, so tell them how much you spend per year and how important mullet fishing is to you. If you used to fish more, would fish more if sport were improved, use the questions on our questionnaire as a template or even cut and paste if you have already completed it!

  • Report your own landings, include how the size of mullet caught has changed, how many you now catch, bear in mind you may see yourself as a better mullet angler now or have to fish different venues or early in the morning to catch. What you are basically doing here is what in fishery terms is CPUE, or in fisheries and conservation biology, the catch per unit effort (CPUE) is an indirect measure of the abundance of a target species.

  • How many do you now see? Mullet are a species that are as we know often seen so if you now see less, report that, roughly how many, approximate size and rough location!

Anything else you think important, such as your thoughts on netting and enforcement and please tell us if you think there is something that needs a wider audience.

An important point raised in the bylaw is the MCRS, the Minimum Conservation Reference Size. It goes without saying that as mullet anglers we want to see the biggest size mentioned, 47cm, implemented. We actually talked about a voluntary slot size with the minimum set at 47cm and the fishermen releasing all very large mullet. SIFCA stated that they were told that not many big ones were netted (probably already had them!), but did not think that would be a big deal, or so it appeared. The 47cm is an issue due to it covering three species.

SIFCA have been told by one commercial at least that he nets golden greys in Christchurch with no thins or thicks. This seems highly unlikely. We believe that because there is no proper evidence of this, both thicks and thins mature at about the same size, the MCRS should be set at 47cm.

SIFCA have to produce bylaws which are evidence based. At the moment they are simply using what they have been told by commercial fishermen and terming it evidence from expert witnesses. This is unacceptable. It does however provide a precedent at least up until they are required to provide proper evidence, that means we are also expert witnesses and therefore what we say should be taken as evidence with equal status. If you have been fishing in SIFCA for 20 years why should your experience count less than that of a commercial fisherman? It does normally appear that whatever comes out of the mouth of a commercial fisherman is taken as gospel and the revelation written as scripture. Therefore same rule must apply to our experience. So let's write our own scriptures and send them to SIFCA!

If you wish to ask me anything or want any help please call or email me:

      thenationalmulletclub@gmail.com

 

Andy