FASTA Response to the Loughs Agency Consultation Document on Angling Regulations 2013 for Foyle & Carlingford (abridged)

Posted by admin on January 29th, 2013 - Comments Off on FASTA Response to the Loughs Agency Consultation Document on Angling Regulations 2013 for Foyle & Carlingford (abridged)

Submitted 10 January 2013

At FASTA’s invitation, on 12 December 2012, FASTA affiliates met with Mr John McCartney, Director of Conservation and Protection, to discuss with him the reasons for the introduction of yet another set of angling regulations, namely the proposal that anglers be restricted to retaining no more than three fish in a calendar year or declared fishing season and the consolidation of previous regulations.

After a short presentation, there followed a question and answer session which was enlightening. It seems that the main reason for this reduction in retained fish from twenty-five to three was the fear that, because the number of retained fish had been reduced in the DCAL area of Northern Ireland, there was a danger of a major influx of anglers from east of the province and therefore fish stocks could become depleted. The figure of three retained fish seemed to be arbitrary and not based on any scientific formula. (The latest DCAL letter to licence distributors appears to confirm this “one size fits all” approach across the Province.)

This reasoning left the audience perplexed as the restrictions on the number of fish that could be retained in the DCAL area had been in place a year previously without an invasion of anglers from that area. Clubs in the Lough Agency’s area do control the number of visitors to their waters and, where necessary, the number of fish that can be taken.

 

The FASTA Perspective on the Proposals covered by the Consultation

This matter was discussed by the FASTA affiliates and the organisation was charged with preparing a collective submission as a unified response on behalf of its membership. The names of the affiliates appear at the end of this paper.

Key Points

  1. FASTA totally rejects the regulation of retaining no more than three fish. It supports the reduction in retained fish from twenty five to ten. This number is to be made up of eleven tags in total, i.e. two tags for spring fish, eight tags for grilse and one tag (ideally a different colour) to cover the possibility of a failed C&R but only used when all other tags have been exhausted. That’s an average of just over 1 fish per month over the angling season.
  2. It is also proposed that the number of tags be issued in one batch at the beginning of the season.
  3. It is also proposed that anglers have the option of exchanging unused spring tags for summer tags if they wish.
  4. The number of tags that should be made available to three-day and fourteen-day licences is proposed to be three (one black, two blue) and ten (two blue, eight black).
  5. The number of sea trout over forty centimetres is minimal and should not be subject to tagging at all. In fact, the inclusion of sea trout in the proposed regulation is irrelevant as that population has effectively crashed. The failure of the Agency to introduce restocking to kick-start that species is an indictment of the senior management of the Agency.
  6. It is the FASTA view that this regulation should be reviewed on a regular basis subject to an accurate assessment of salmon stocks. The review should be conducted in conjunction with anglers and their representatives at least annually and as soon as possible at the end of each season, and revisions made without delay as mutually agreed.
  7. FASTA views with increasing concern the use of statistics by the Agency in coming to certain conclusions as to the state of the system. These statistics are deeply flawed. The fish counters are deeply flawed. The Sion Mills counter is not fit for purpose. The counter at Corrick has not worked for three years. The two counters in the Omagh area are demonstrably not fit for purpose, having shown conflicting information on the same dates.

 

The attempt to reduce the number of retained fish to three is unworkable as it will be honoured in the breach. It cannot be policed and is unnecessary for a number of reasons, including the following:

  1. Anglers, in conjunction with FASTA, have taken a number of self-imposed, voluntary conservation measures and initiatives to enhance the number of fish reaching the spawning beds.
  2. Castlederg anglers agreed to catch and release from the first of September and also to stop issuing visitor tickets from 1 October.
  3. Omagh angling club agreed to reduce its salmon catch to six per member for the season/adopted catch and release throughout the season and closed their fishery on 10 October.
  4. The Finn anglers closed its fishery on 31 August.
  5. Baronscourt Estate return all hen fish and restrict the number of fish that visitors can take.
  6. The Dennet anglers delay the start of the season to allow the smolts to clear the river.
  7. The Feddens Association allows one spring fish and two summer fish to be caught per day and then angling must cease even if practising C&R.
  8. FASTA encouraged all anglers to adopt catch and release with some very positive results. The Agency’s own figures indicate that over thirty per cent of the fish landed were returned to the river in the 2012 season, and that the average number of fish retained to be circa 1.4 per angler.
  9. It should be noted that there are credible reports of an excellent redd count on most if not all of the head-waters as well as anecdotal evidence of a healthy run of fish on the Mourne system as well as the Finn catchment.
  10. At the FASTA meeting on 12 December 2012, Mr McCartney declined to give either a figure or estimated figure of the number of salmon being illegally netted in Lough Foyle. Whether this is hundreds or thousands, it is a major leak of returning fish which, if they were allowed to continue their journey, would have the Foyle system in even better health. These ‘lost’ fish have to be taken into account in the reckoning as they appear to be completely ignored for this exercise. It also highlights the need for the poaching problem to be tackled with a fresh approach and additional resources.

 

Given the extent of conservation that anglers have embraced and the return to health of the system, there is absolutely no need to have such a drastic reduction in the number of fish to be retained.

 

FASTA Overview and Summary

The vast majority of anglers reject this regulation. It is not open to horse-trading. The consensus is that a total of ten tags plus one is fair and reasonable. As managers of their rivers, anglers are responsible and have a vested interest in ensuring that the system is healthy and remains so for future generations. It must be remembered that angling is a recreational pursuit. There is a danger that over-prescription will spoil that leisure pursuit. It is therefore incumbent on the Agency to bear these facts in mind this and consider very carefully before introducing regulations which have so little support among the stakeholders. It is ironic that those in breach of fishery regulations could find themselves with a criminal record. What other leisure pursuit has such a draconian regime?

This response is endorsed and supported by the FASTA affiliates which collectively represent an estimated 4,000 anglers made up from their membership and other visitors using their waters:

Baronscourt Estates • Finn Angling Club • Brookborough Estate • Omagh Angling Association • Castlederg Angling Club • Sion Mills Angling Association • Dennet Angling Club • Strabane Angling Association • Feddens Association

Signed for and behalf of FASTA

F. J. Curran

Chairman

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