Mr Patrick Cotter,
Sea Fisheries Conservation Division
DEFRA, Area 7B, 3-8
Whitehall Place, London
SW1A 2HH
01st
August 2006
Dear Patrick,
RE: Proposals
for managing exploitation of tope
I am writing in
response to the DEFRA consultation paper and partial regulatory impact
assessment on Proposals for managing exploitation of tope.
I think the
document is an extremely positive step forward by DEFRA in the hope that
we can protect the tope from commercial exploitation and save the
species for future generations to marvel at and recreational sea
angler’s benefit from the thrill of the catch.
My views are
expressed on the following pages. I am available for further comment
should this be required and look forward to further documentation on the
proposals.
3.1 Explanation
of Options
Option 1
To do nothing would
be disastrous, and as the reports from the tail end of last year
surrounding a possible fishery for tope have suggested a stance we
cannot afford to take.
Spur numbers off
the Welsh coast are still perilously low in comparison to the late 70’s
and early 80’s. In an ideal world the spurs would be left alone to
return to the once fertile packs abundant in the area years ago. This
however I fear is not the case.
Being large pack
fish, continually feeding, it easy to see how commercial long liners can
eradicate this particular species from a given area in a very short
space of time.
What is
particularly alarming and sad is that this will happen around our coast
very soon, as with the return of the spurs, we are also witnessing the
return of a very large number of vessels turning their attentions to the
long lines, some for the first time, and others going back to old ways.
This quick ‘grab a few quid’ while we can scenario will sadly all but
wipe this fishery from the welsh coast very soon.
This cannot be
allowed to happen with tope.
Option 2
I think it is fair
to say that option 2 is the preferred way forward for all anglers.
Point 19
Recreational Sea Anglers
With reference to
the landing of tope simple clarification is required on the term of
‘landing’ as at present it is slightly ambiguous and open to debate and
mis-interpretation by who ever wishes. My thoughts are that the term
‘landing’ is used to describe fish retained aboard a vessel and returned
to port with, be it for weighing in competitions or commercially..
Speaking from
experience of competitions around Wales and a number I know of in
England all tope and smoothound are generally excluded, or taken on the
honesty of the skipper or angler and never brought ashore. If this is
not the case, then this needs to be brought to the attention of that
Nations Federation and acted upon immediately.
The document
mentions scientific advice that implies survival rate of tope is likely
to be high if the tope is removed from the water, and possibly even
higher if the tope is released at the side of the vessel.
My thoughts are
that we should be allowed to boat tope and all sharks; this will
obviously aid the tagging program, but will also allow for a quick
photograph to be taken for the angler concerned. Most anglers this day
and age wish to see their fish returned safely, but also like that
lasting photographic memory of their catch, I include myself in this,
especially if the fish is looking to be a new personal best. If of
course it is viewed to be smaller than previous catches, I will un-hook
at the side of the boat.
I do not agree with
cutting the leader at the side of the vessel unless the hook has sunk
deep. Attempts to remove the hook should be made at all times.
Records
Last year aboard My
Way we caught a tope of 79lb – 5lb heavier than the then WFSA record.
After taking measurements and photographs of the ‘larger than the Welsh
record fish’, the tope was returned safely to the water. It was only a
few weeks after that I learnt the WFSA had changed the rules and allowed
weigh aboard and photographic evidence not only for specimens but now
also for record fish. I informed the chap concerned and he has since
been awarded the new Welsh Record.
Records though are
a contentious issue – If any fish is blatantly over the current record –
can this not be claimed even if required to bring ashore? It is only 1
fish, and pushes the boundary further away from the ‘is it / isn’t it’
potential record. It is a hard decision that only the anglers conscience
can make under the current British Record list rules.
Is the WFSA
standing the way forward? Weigh aboard and hope for continued honesty,
not too sure as this system is obviously open to abuse by the less
honest amongst our community. Again down simply to the conscience of the
anglers concerned.
Option 3
Where as this would
once again protect the tope from commercial fishing, this would then see
no further RSA for the species, tope is a highly sought after fish and
the largest most abundant shark in UK waters.
Tope is a very
large draw for many anglers and to restrict fishing for this species
would have a hard effect on the charter boat industry. There would a
definite reduction in the amount of income into coastal communities, if
a prohibition was imposed.
4 Costs and
Benefits
Point 37
Charter Boat – My
Way, Holyhead Marina
www.goangling.co.uk
Area Anglesey,
North Wales
Catch and release
is practised on every tope caught. The tope is brought aboard the vessel
occasionally for the angler to have a photograph taken.
To charter the boat
costs £260 for 10hrs for up to 10 persons
Bait varies but on
average around £20 per person
Tackle varies but
standard hooks, swivels, line etc around £15 per person
Our customer base
varies from north Wales, north West England, Yorkshire and Midlands.
5 Issues of
equity and fairness & 9 Competition Assessment
Option 2 or 3 if
imposed by DEFRA would have no effect on Member States of Europe.
This as suggested
must be addressed with the European Commission and similar restrictions
imposed to vessels from all member states.
Kind Regards
Gethyn Owen