A radical overhaul of the State’s involvement in the management of inland fisheries is proposed in a FISSTA submission to consultants appointed by the Minister of the Marine. The consultants have been tasked by the Minister with carrying out a high level review of the inland fisheries sector in Ireland and with carrying out a root and branch examination of the State’s involvement in the governance of the sector. The submission was unanimously adopted by the national executive of FISSTA at its meeting in Birr on 10th January.

The core proposals put forward by FISSTA are:

• A National Inland Fisheries Authority (NIFA) should be created to take over all of the functions currently carried out by the Central Fisheries Board and the eight regional fisheries boards. The regional boards would be disbanded and their offices become part of the local delivery systems for the services of NIFA. The National Salmon Commission (“if it continues to exist at all”) would become an advisory body to NIFA and the inland fisheries functions of the Marine Institute would also transfer to NIFA.

• NIFA would have “an unambiguous commitment to the sustainable development of and the maintenance of genetic diversity within the inland fisheries stocks”. It would have no responsibility for tourism promotion.

• Title to all State owned fisheries (currently vested in bodies such as the central and regional fisheries boards, the ESB, Coillte, the former Duchas, etc) should be transferred to NIFA and the fisheries leased by them to not-for-profit community based organisations in accordance with specific management plans. The FISSTA proposals make it clear that in the vast majority of cases local angling clubs would be the most appropriate such organisations. The NIFA would “encourage” the development of Fisheries Trusts to coordinate the activities of fishery operators and to provide more effective protection emasures.

• A new Inland Fisheries Protection Service would be created which would be “trained, professional and highly mobile”. It would concentrate on “serious breaches of fishery laws and on the commercial trafficking in illegally caught fish”.

In introducing its proposals the FISSTA executive emphasised that no amount of rearranging of fishery management structures “can produce any significant improvement in the sustainability of stocks of migratory fish” without the adoption of measures to bring about:

• “The cessation of drift netting at sea for mixed stock salmon flows as an essential building block in the restoration of salmon stocks.”

• “A new regime of fin-fish farming regulation aimed at reducing the impact on salmon and sea trout fisheries and ensuring that fin-fish farming is itself an ecologically sustainable activity.”

In its critique of current arrangements FISSTA refers to the lack of coherence in the current stated objectives of the Department of the Marine which on the one hand is obliged to “ensure” conservation of stocks but only to “encourage” sustainable development. It also points out that the Central Fisheries Board cannot enforce national policies and programmes; that the current national and regional structure is “either paralysed into inaction or condemned to adopting lowest common denominator “solutions” by conflicts of interest on their boards and inter-organisational rivalries”. FISSTA wants to see the NIFA emerge as a body which “managing” fishery protection and development “in contrast to the CFB’s role of promoting, supporting, facilitating and coordinating”.

FISSTA makes a strong case for the suitability of angling clubs and associations as managers of fisheries, pointing out that some of the best managed fisheries in the country are under such a regime. In addition, it points out generally that “the essential role of anglers and their associations in the conservation of inland fish stocks of all kinds must be adequately acknowledged in this new regime and distinguished from that of the commercial exploiters of inland fisheries stocks”.

The full text of the FISSTA submission can be found below.
 

Submission by the Federation of Irish Salmon and Sea Trout Anglers to the High Level Review of the Inland Fisheries Sector established by the Minister for Communications, Marine and Natural Resources

The Executive Committee of FISSTA adopted this statement at its meeting in Birr on Saturday, 10 January 2004.

1. Introduction

On 2 December 2003 the Minister for Communications, Marine and Natural Resources announced the appointment of consultants and a steering group to “undertake a high level review of the Inland Fisheries sector in Ireland”. The Minister of State for Fisheries at the same time “reaffirmed his intention that this review would not just look at the Central and regional fisheries boards but would be a root and branch examination of his Department and the Government’s involvement in the governance of the sector as well as the involvement of other State agencies including the Marine Institute, BIM, ESB, Duchas, EPA and Board Failte” . The Minister of State called on all stakeholders to cooperate in the review and “to engage fully in the process with a view to building a concensus on a new model for the future” .

The announcement, and one issued the following day by the leader of the consultancy project, FGS Consulting , confirmed that the consultants would be:

• “placing public advertisements calling for submissions from all interested parties in hard or electronic form;

• setting up an FGS website portal dedicated to the Review which will contain the Terms of Reference and provide instructions for making submissions or making comments on the Review for those wishing to use this medium for communications. (Details will be provided in the public advertisements);

• organising a programme of meetings and interviews with key stakeholder interests at national and local level; and

• organising a series of Regional Workshops, the arrangements for which will be published separately at a later date”.

The detailed terms of the reference for the review had earlier been set out by the Department in its document inviting tenders for the project (“the Tender Document”) as follows:

“3.1.1 Consultants are asked to evaluate the adequacy of the current model for the

governance of the inland fisheries sector having regard to the need to have in place structures and approaches which might ensure that:

• the State/management relationship is conducive to the development of an inland fisheries sector, which conserves the inland fisheries resource in its own right and its viability and economic and social contribution at national and local community level;

• the inland fisheries have access to appropriate funding (preferably from their own resources) to provide for conservation and development in the medium to long term;

• there are appropriate incentives to deliver high quality State fisheries to stakeholders, particularly users, and a specified return on assets to the State;

• appropriate conditions exist within the institutional arrangements and management structure that ensure cost effectiveness and value for money in the delivery of services and allow for revenue generation;

• the development of good management and organisational practices including organisational development, flexible work practices, etc.

3.1.2 The consultants will also be required to define the current relationship between the Government, the Department(s) and the inland fisheries sector and suggest new and more effective models.

3.1.3 Finally, the consultants will be required to recommend a structure which will contribute to the optimum development of the inland fisheries resource in Ireland and in doing so might:

• apprise/recommend management/ownership options including enhanced private sector involvement and self-funding options;

• identify other imaginative proposals including the transfer of non-essential activities away from the inland fisheries management to other appropriate service providers with specified service level agreements;

• set out the realistic yet challenging performance indicators and specified outcomes together with expectations of what is to be delivered by the Department(s) and service providers and in the timescale outlined;

• set out the roles of affected stakeholders and how these would change in the new arrangements”.

Overall, it is stated that the Department’s “aim is to have in place, by end 2005, a newly defined relationship between Government and the management structure that contributes to the optimum development of the inland fisheries resources in Ireland, incorporating management and organisational practices, which guarantee cost effectiveness and value for money in the delivery of high quality services to stakeholders” .

The consultants are required to complete their work within six months with a preliminary report to be presented by the end of February 2004.

This statement by the Executive Committee has been prepared in response to the invitation for interested parties to respond to the terms of reference having regard to well settled FISSTA policy on many of the key issues raised in those terms of reference.

2. Background to this submission

The Tender Document summarises a good deal of the legislative, organisational and operational context of inland fisheries management by the State. FISSTA has little quarrel with that presentation but would add a number of other significant issues that form the background to the proposals set out later in this submission.

Major factors influencing FISSTA’s approach to this project include:

Federation of Irish Salmon and Sea Trout Anglers

FISSTA is the largest federation of Irish anglers with 72 affiliated associations spread over all four provinces with some 15,000 members. The Federation was one of the founders of the North Atlantic Salmon Fund and of the European Anglers Alliance and has Non Governmental Observer status with and is an active participant in the North Atlantic Salmon Conservation Organisation. Nationally FISSTA is linked with the Trout Angling Federation of Ireland, the Irish Federation of Pike Anglers, the Irish Federation of Sea Anglers and the National Coarse Fishing Federation in the Angling Council of Ireland. There are FISSTA-affiliated members on most of the regional fishery boards.

FISSTA’s member organisations have a wide range of different relationships with salmon and sea trout fisheries. Some own their own fishery rights, others have leased or licenced waters from State and private owners and yet others are clubs of like minded anglers without access by right to any particular waters. The Federation, therefore, has within its ranks a broad cross section of salmon and sea trout angling interests many of whom have invested heavily over the years, individually and through their associations, in the preservation and development of the fisheries that they control.

The state of salmon and sea trout stocks

It is not necessary here to go into the long litany of reviews and reports that have been undertaken at international and national levels which chronicle the progressive decline in and the current dire state of salmon and sea trout stocks . The direct causes of the decline of these two populations are different but the foot cause is the same: the lack of a commitment to sustainable development policies for these stocks by successive governments and fishery administrations. In the view of FISSTA, the current review of the organisational features of Irish fisheries management, welcome as it is, is pointless if it does not also address key sustainability issues such as at least:

• The cessation of drift netting at sea for mixed stock salmon flows as an essential building block in the restoration of salmon stocks ;

• A new regime of fin-fish farming regulation aimed at reducing the impact on salmon and sea trout fisheries and ensuring that fin-fish farming is itself an ecologically sustainable activity .

No fishery management structure, national, regional or local, can produce any significant improvement in the sustainability of stocks of migratory fish without such measures being in place.

The FISSTA experience of catchment management pilot projects

In 1998 eight pilot catchment management projects were launched around the country to test the proposition that stakeholders acting in partnership could make better provision for fishery management and development. It is fair to say that virtually all of these pilot projects have failed, leaving anglers, in particular, more than somewhat cynical about what were the real motives behind the exercise.

The three main reasons for the collapse of the catchment management initiative, in the view of this organisation, were:

• In Donegal and Kerry attempts were made to use catchment management to deprive angling associations of their traditional leases/licences of State owned fisheries and to transfer these to control of so-called public private partnerships. The Kerry process was the subject of a highly critical report commissioned by the then Minister of the Marine and as a result a return to the status quo ante is (painfully slowly) in progress. But in Donegal proposals that are highly detrimental to local recreational anglers and of very doubtful benefit in attracting visiting anglers are still being pursued despite the strong countywide opposition of anglers. Both of these projects appear to have been initiated on the basis of some proposition, itself unsustainable, that the management of fisheries by anglers is inimical to tourism angling;

• Many of the other projects made progress in assembling base line data on the state of their respective catchments but gradually withered on the vine because of a lack of commitment and resources from the central and regional boards;

• Underlying the failure of the entire initiative, which arguably was a major set back for the development of the catchment management concept in Ireland (which FISSTA supports in principle) was the fact that it was yet another standalone project, ill thought out and ill managed from the centre. The CFB were unable to control the more crazy aberrations of the basic model that were to emerge in some regional fisheries board areas.

Breakdown of trust with the Department of the Marine

The recent history of relations between FISSTA and the Department of the Marine is one characterised by serial failure to meet commitments and lack of consultation on major initiatives . It is not necessary to go into all of this in detail here but it is necessary to note that the lack of consistent policy and of any real concept of dialogue and partnership with major stakeholders lies at the heart of the many weaknesses of the current system.

The Indecon Report and the future of salmon angling tourism

The Indecon report , commissioned by the Central Fisheries Board, brings up to date the conclusions of earlier reports stretching back to the 1970s, about the value of angling and angling tourism and the relative economic value of exploiting the available stocks for sporting as opposed to commercial netting purposes. The survey techniques employed by Indecon suggest that the returns to the economy (excluding the smoked salmon sector of commercial net fishing) are about equal from angling and from commercial exploitation – but the commercial sector takes 87% of all captured salmon to achieve that equality!

Indecon estimated that the net present value of total Irish salmon exploitation for the period 2002 to 2012 would increase from at Euro 91.6mm to Euro 146.8 mm if 50% of drift net fishing were to be phased out by 2005. In the same period the net present value of commercial net salmon fishing would decline from Euro 35.9mm to Euro 23.9mm under the same assumptions.

FISSTA is aware that there is a level of scepticism in some official circles about the extent to which salmon angling tourism can be substantially expanded but these ratios suggest that there is room for a considerable margin of error in forecasting tourism growth before the balance of advantage begins to swing in favour of commercial exploitation. The fact of the matter is that Ireland has never really been seriously in the business of salmon angling tourism in the way that Iceland, Norway, Scotland and, now, Russia have been because of our declining stocks, poor sporting infrastructure and poor fishery management. Quite apart, therefore, from concerns about the survivability of the Atlantic salmon and the measures necessary to address that phenomenon, there is a fundamental economic case for optimising the exploitation of salmon stocks.

3. The Role of the State in Inland Fisheries Management

FISSTA would agree generally with the characterisation of the State’s current role in inland fishery management set out in the Tender Document. This states that “the Departments core policy goal in relation to the inland fisheries sector is to conserve the inland fisheries resource in its own right and to maximise its long-term economic and social contribution at national and local community level. In order to achieve this goal, the Department has set out the following key strategic objectives:

• “to ensure effective conservation, primarily through fisheries boards of inland fish habitats and stocks;

• to deliver effective and value for money management of the inland fisheries services;

• to ensure effective legislative and regulatory framework for inland fisheries;

• to encourage sustainable development of the commercial and recreational fishing resource” .

There are nonetheless major problems with this statement as a basis for future strategy. These are primarily that:

• The objectives are not being realised – indeed there is not really much evidence that they are even being pursued;

• There is no national strategy to guide the individual fishery boards;

• Conservation cannot be “ensured” if sustainable development is only to be “encouraged”;

• It is certainly open to serious question as to whether fisheries boards as we now know them are the most effective way to achieve conservation and sustainable development and to respond to changing circumstances;

• The state fisheries management apparatus is burdened by tasks which form no part of the objectives outlined by the Department including that of actually managing fisheries owned by the Central Board and the promotion of angling tourism.

A new basis for State inland fisheries management

In the view of FISSTA, the State stewardship of inland fisheries has to be based on an unambiguous commitment to the sustainable development of and the maintenance of genetic diversity within the inland fisheries stocks. The exploitation of these stocks, whether by the recreational or commercial netting sectors must be encompassed within a subordinate, not a parallel, set of objectives. For the reasons stated above in relation to the Indecon report there is, in FISSTA’s view, an unanswerable economic and social case for recreational angling to be given priority in the allocation of stocks for exploitation.

Such a mission cannot be accomplished within an organisation with conflicting objectives. If, for instance, the clear scientific evidence is that the Erriff fishery, currently managed by a regional fisheries board, should be closed down for conservation reasons in July of some year how is the conflict between that imperative and that of the commercial needs of the fishery board to be resolved? And that is only a microcosm of what are probably many much larger conflicts that must handled within the current structure.

4. A radical new architecture for the management of inland fisheries

An essential outcome of the current review must be the publication of a White Paper setting out the Government’s commitment to a sharply focused mission for the State in the management of inland fisheries such as that proposed in the previous section, outlining the key policy directions to be followed and setting out a new institutional architecture for the fulfilment of that mission and the accomplishment of those policies.

The essential role of anglers and their associations in the conservation of inland fish stocks of all kinds must be adequately acknowledged in this new regime and distinguished from that of the commercial exploiters of inland fishery stocks.

At national and local levels there needs to be put in place effective partnership structures with representative organisations of anglers to ensure that their expertise and commitment is harnessed in the conservation effort.

In FISSTA’s view it is essential that there be an openly expressed and widely understood framework for Government actions in this area as a basis for strategic action by executive agencies and the limiting of arbitrary changes of direction by the Department.

The National Inland Fisheries Authority

In the view of FISSTA current inland fisheries management is bedevilled, not just by a lack of clear objectives, but by a confusing and financially wasteful plethora of organisations. Many of these are either paralysed into inaction or condemned to adopting lowest common denominator “solutions” by conflicts of interest on their boards and inter-organisational rivalries.

FISSTA proposes that a single National Inland Fisheries Authority (referred to as “NIFA” hereafter) be established to replace the Central Fisheries Board and the regional fisheries boards. The current regional fisheries management structures would become part of the local delivery systems for the services of NIFA.

NIFA would absorb all aspects of the States involvement in inland fisheries management and, as a consequence:

• All employees of the CFB and the regional boards would join the new Authority;

• Title to all State owned fisheries (ie those owned by the CFB, the regional boards, the ESB and the Heritage Division of the Department of the Environment, Heritage and Local Government (referred to as “Heritage” in the rest of this submission), Coillte and the Department of Agriculture (former Land Commission fisheries)) would be transferred to NIFA;

• The National Salmon Commission, if it continues to exist at all, would become an advisory body of NIFA but the organisation is so conflicted in its composition that consideration should be given to its total abolition. It does nothing that the National Fisheries Management Executive (see below) could not accomplish in consultation with the interests involved and at much less expense;

• All of the inland fisheries functions of the Marine Institute would transfer to NIFA;

• The current semi-formal National Fisheries Management Executive (the chief executives of the central and regional boards meeting as an advisory board to the Department) would be absorbed within the management structures of the NIFA.

The Functions of the NIFA

The mandate of the NIFA should be substantially different from that of the Central Fisheries Board. The NIFA should be responsible for directly managing the inland fisheries protection and development function in contrast to the CFB’s role of promoting, supporting, facilitating and coordinating . The major functions of NIFA would be to:

• Take responsibility for all of the activities currently carried out by the regional fisheries boards;

• Develop policies and programmes, within the framework set by the White Paper, for the sustainable development of the inland fisheries and to implement and/or procure the implementation of those programmes;

• Advise the Department either on its own initiative or on request on changes in fishery policy and/or legislation;

• Manage all controls on the recreational and commercial exploitation of stocks based on the best available scientific analysis;

• Provide an Inland Fishery Protection Service (see “Inland Fisheries Protection Service” on page 19 below);

• Police the adherence to the terms of their licences by fish farms thus bringing enforcement cohesion to this troubled sector;

• Lease/licence State owned fisheries to suitable not-for-profit organisations (see “The Operation of State Owned Fisheries” on page 15 below);

• Facilitate the creation and development of Fisheries Trusts (see page 18 below);

• Operate the current fish hatcheries and those that would be taken over from the ESB under these proposals. The NIFA would continue the current licencing regime for independently operated hatcheries and provide technical support to them.

It is necessary to emphasise that, in the interests of eliminating (or at least reducing) conflicting objectives and of establishing more clarity in its mission, there are certain things that NIFA should not do. These include:

• Angling tourism promotion should be the task of Tourism Ireland thus enabling NIFA to act more freely in the interests of fishery conservation;

• NIFA should not directly operate individual fisheries as a means of bolstering objective decision-making about fish stocks. Associations of anglers have demonstrated over a long period of time that they are more than capable, as in other countries, of managing fisheries and this is a resource that needs to be built on. (See “The case for angling association management and operation of fisheries” on page 16 below).

Benefits of the new structure

FISSTA believes that the proposed structure would offer considerable advantages over current arrangements in the areas of focus, responsiveness to changing circumstances, cost effectiveness and accountability. It may seem counter-intuitive that an organisation like FISSTA should be arguing for the elimination of the regional boards. In the experience of the FISSTA and its affiliates, however, the local relevance and accountability that the regional boards are claimed to provide is largely illusory.

Focus

There is currently no single-minded drive for the sustainable development of inland fisheries stocks and for the control of exploitation of those stocks. The rationale for the current structure, with virtually no national strategy driving it, implicitly assumes an abundance of stocks without any substantial threats to their continuance. In this world it is considered safe to have eight regional authorities each pursuing their own policies and having their own priorities. The reality is very different with over exploitation and environmental threats rampant and no single focus for the deployment of even the current limited resources available to deal with those threats.

Responsiveness to change

The current system of eight regional boards each with considerable autonomy from the centre creates a situation in which there is a very slow response to changing circumstances and in which a single national approach, where appropriate, may take a very long time indeed to negotiate. It is FISSTA’s belief that a NIFA-type structure operating within a widely accepted framework set out in a White Paper would be in a much better position to drive change within the organisation itself and in the policies and programmes needed to sustain stocks.

Cost effectiveness

The current system is wasteful of scarce financial resources and of management time. The servicing of regional boards is an onerous burden with little apparent positive benefit to fishery conservation. In addition, the rigidity of having to deploy resources within regional demarcations is probably not an optimum use of managerial overhead. FISSTA believes that the structure it is proposing is one that should, within a relatively short period of time, enable the transfer of personnel time and of expenditure to service delivery and away from overhead.

Accountability

The regional boards are not an effective way of achieving accountable regional management. They are too big and unwieldy to accomplish anything more than accountability on nitty-gritty issues, particularly in a situation in which the boards operate outside any comprehensive national framework of policy and control. The achievement of programme delivery and the measurement of performance and progress on the key sustainability issues will be facilitated by the creation of a single NIFA-type institution.

5. State ownership of fisheries

FISSTA strongly supports continued State ownership of fisheries and, indeed, supports the progressive expansion of State ownership particularly in cases where significant fisheries are being ill managed from a conservation/development point of view. The NIFA should be given the resources to acquire such fisheries.

Some private sector interests have argued that the State-owned fisheries should be sold off. FISSTA is strongly opposed to such a strategy not for any ideological reasons but because it flies in the face of commercial realities. The fact is that there are only a handful of fisheries in this country that are capable of paying their way based on just meeting operating costs, let alone remunerating acquisition costs. The result of privatisation would be that in the majority of cases the fisheries would decline for lack of investment and the State could very well be obliged to reacquire the fishery rights.

It is preferable, in FISSTA’s view, that the State continue in ownership of the fisheries it currently holds (and, as noted above, to add to that stock), to establish and monitor standards of good practice for operators and to extract a realistic rent based on the productive capacity of the property. The NIFA should maintain a complete overview of the water environment.

It could be argued that a logical extension of FISSTA’s argument that the NIFA should have a single minded focus on conservation and sustainable development would be that the ownership of fisheries should lie elsewhere in the State apparatus rather than within NIFA. FISSTA believes, however, that the limited fishery resources and expertise within the country dictates that that the NIFA be the owning entity and that any conflicts that arise from that will be mitigated by the operating structure recommended below.

6. The Operation of State-Owned Fisheries

Responsibility for the operation of all State owned fisheries (other than perhaps a small number to be retained for research and the development of best practice) should be transferred by way of lease or licence to not-for-profit community-based organisations. The standards that such organisations should be obliged to meet both in respect of their constitution and their operations should be agreed with the operator and be part of the lease/licence conditions. Under no circumstances should fisheries management be entrusted to purely commercial entities irrespective of whether they carry fashionable “public-private-partnership” labels or not. The operating entities would pay rentals and fishery rates to NIFA.

The objective must be to ensure that anglers (including local anglers) have easy access to fisheries at affordable prices and that they do not become ghettos with access being confined to the very well heeled . Apart altogether from issues of equity such a development would be serious inimical to good fishery management, a process in which local support and commitment is vital.

It is FISSTA’s view that in the vast majority of cases the appropriate body to undertake fishery management duties would be the local angling association or a consortium of local angling associations. The experiences with club-operated waters nation-wide is very positive and the clubs involved have shown considerable ability to mobilise local investment in fisheries development and in the curtailment of illegal fishing. Many of the best managed and cared for fisheries in the country are in the hands of local angling associations.

Among the standards which potential lessees/licences should be required to meet are:

• Evidence of strong local community support for their being awarded the lease/licence;

• Undertakings as to substantial access to the fishery by visiting anglers (whether native and overseas);

• The presentation of a rolling five to seven year development plan adequate to the needs of the fishery and evidence of the ability to finance it;

• An effective local anti-poaching programme for the fishery.

Subject to their continuing to meet the agreed standards and their financial obligations, management entities should be allowed to enjoy continued occupation of the fishery for considerable periods of time. Anything akin to a five year bidding process , which might be attractive from a short-term revenue enhancement standpoint, would be entirely inimical to the long-term development needs of the fisheries.

FISSTA acknowledges that in the case of some of the larger fisheries in State ownership their effective management will require the amalgamation of some smaller associations or the establishment of consortia between them.

7. The case for Angling Association management and operation of fisheries

The majority of FISSTA-affiliated associations already either own or (more usually) lease/licence fisheries. Many of those that are subject to lease/licence are owned by State entities (generally the CFB or Heritage). In the main, these are very well managed properties that include some very significant public-access fisheries.

Angling associations in Ireland (as in Iceland, Scotland and Norway) bring considerable strengths to fishery management provided they are given adequate technical backup in areas such as habitat improvement, fishery design, policing, etc. . These advantages include:

• The associations are made up of people who, by definition, are themselves anglers with an intimate knowledge of the fishery and concern for its welfare. This provides knowledge and expertise in the management of the fishery that augments professional management skills in a way not available to commercial operators of angling fisheries.

• Association management invariably provides better integration with the local community for whom the fishery is often an important socio-economic resource (through B&Bs, angling shops, ghillies, etc.). The support of local communities for fisheries is an important component in fishery policing and pollution control.

• Associations are simply more efficient operators than purely commercial owners/managers. In addition to being able to call other services on a voluntary basis, as noted above, they have a large police force at their disposal as a by-product of their angling membership.

It has been argued that association management is in many cases inimical to angling tourism development – the indigenous anglers being concerned to protect the fishery for their own benefit. If there are instances of such behaviour, they are very few and far between and constitute the exceptions which highlight the fact that, as in other countries, local anglers are an important tourist resource, greatly enhancing the attractiveness of the fishery. Further, responsibility for a wide range fisheries management functions will bring with it the need to raise substantial revenues from both members and tourists thus creating a powerful incentive to being more tourist friendly in those areas where it may be needed.

A more cogent argument against association management might be that, particularly where larger and more complex fisheries are concerned, the necessary skills and disciplines may be lacking. FISSTA would argue that this problem is not unique to angling associations and is an issue that will have to be addressed no matter what new management entities are put in place. If local communities, through their clubs, can successfully manage golf clubs and other sporting facilities, it is probably the case that they can manage fisheries!

8. Fisheries Trusts

In respect of particular rivers or catchments in which there is more than one fishery operator (whether of privately or State owned fisheries), NIFA should actively encourage the establishment of Fisheries Trusts to coordinate the activities of the various operators and to provide for more effective protection measures. The activities of the Trusts should be largely funded from contributions from the operators but NIFA could encourage the carrying out of research, the adoption of best practices and the augmenting of policing efforts through programmes of targeted grants.

9. Inland Fisheries Protection Service

NIFA should take over all of the fishery protection resources of the current regional boards and create a new Inland Fishery Protection Service. The new service needs, however, to be something more than the simple aggregation of what currently exists; there is, in particular, a need for a trained, professional and highly mobile service capable of being deployed more widely than under the current regional arrangements (although it is obvious that one of the functions of the regional offices would continue to be that of policing within their own areas).

The IFPS would augment the fishery protection services of the local fishery operators but focus in particular on serious breaches of fishery laws and on the commercial trafficking in illegally caught fish.

In a number of areas the Garda Siochana have been successfully involved in aspects of fishery protection and this is a feature of future protection activity that needs to be developed. Given the apparent involvement of organised crime elements in poaching in some places such involvement could bring major benefits. In addition, the whole regime of fines and penalties for illegal catching of fish needs overhaul.

10. The takeover of other State-owned fisheries

It is an essential feature of FISSTA’s proposals that the title to all State-owned fisheries be transferred to NIFA. This will probably come as a relief the ESB and Heritage even though they are unlikely to acknowledge that! With the transfer, and particularly from the ESB, should come a substantial financial package to acknowledge the considerable burden which will have been removed from them. In the case of the ESB this will probably include the removal of the obligations under Section 8 of the Shannon Fisheries Act, 1935 to “maintain, preserve and conduct” the Shannon Fisheries and similar if less onerous obligations in respect of the Liffey, the Lee, the Erne and a number of other smaller rivers.

11. Transitional Measures

Changes along the lines proposed above would represent a major shift in the State’s stance on fishery management. Currently, the State has virtually no discernible policy on sustainability and diversity maintenance in inland fisheries but devotes considerable resources to micro managing individual fisheries. Under the proposed structure the State’s role would be what many argue is the correct one of creating an overall sustainability framework and nurturing it but leaving the on the ground detail to those best equipped to implement it.

The transition will require investment in a number of measures, among the more important of which are:

• The establishment of a structure for partnership with angling interests;

• Training of people, both voluntary and full time, in fishery management;

• Seed funding for start up fishery operators;

• The installation of fish counters on all the main salmon and sea trout rivers to ensure that real time management data is available.

Conclusion