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The Irish Drift Net Fishery for Salmon and its impact on the


									    Submission to the Joint Oireacthtas Committee on
     Communications, Marine and Natural Resources
    review of Salmon Angling and Commercial Netting

Stop Salmon Drift Nets Now was established in July 2004. It is supported by all of the
national and regional game angling federations, by fishery owners, operators and managers and by angling
tourist interests. It has a single focus for its research, information dissemination and campaigning
activities: the bringing about of the end of the mixed stock exploitation of salmon in Irish waters by drift
nets. It has close connections with the North Atlantic Salmon Fund which has extensive experience of the
negotiation and funding of drift net cessation in Canada, the United States, Greenland, the Faroe Islands,
Norway, the North East of England, Wales and Northern Ireland.

24 March 2004



Summary                                          3

Introduction                                     4

The Drift Net Fishery                            4

The Current State of Irish Salmon Stocks         8

The Necessity for Single Stock Management       12

The International Dimension to the Drift
Netting Question                                13

What is to be done?                             14

Appendix One - The Decline of Atlantic, North
East Atlantic and Irish salmon stocks           17

Appendix Two – The Causes of the Decline of
Irish Salmon Stocks                             19

References                                      21


   Drift nets intercept streams of salmon at sea that are returning to many rivers and catch these
    fish irrespective of the state of salmon stocks in individual rivers. It constitutes, therefore, an
    unsustainable form of exploitation of the salmon resource.

   This mixed-stock exploitation characteristic of drift netting makes it impossible to integrate it
    into any meaningful salmon conservation programme and, in fact, results in serious damage
    to conservation measures undertaken in rivers where stocks are threatened.

   The existence of a large scale drift net fishery in Ireland, the only one left in the entire North
    Atlantic, gives rise to very strong political pressure for the continuation of unsustainably
    large quotas, far in excess of the scientific advice.

   A mechanism must be found urgently, and preferably in consultation with the drift net
    community, to start bringing an end to drift netting in Irish waters in a planned way, if the
    salmon is to be maintained (and in most rivers restored) as a sustainable economic, social and
    recreational resource.

   There is ample evidence that many drift net operators would exit the business if they could
    retire or be assisted to adapt to other sources of income and given fair income protection
    while the adapting. This could be achieved at only a fraction of the cost frequently referred
    to by the Minister of State for the Marine.

   In 2004 the number of spawning salmon returning to the rivers was insufficient to meet their
    Conservation Limits in thirteen of Ireland’s seventeen fishery districts. The endangered
    rivers cover 86% of Ireland’s salmon production capacity.

   Failure to meet Conservation Limits on a consistent basis is a ground for a species being
    described as being “below safe biological limits” by the International Council for the
    Exploration of the Seas and the North Atlantic Salmon Conservation Organisation.

   Ireland urgently needs to start managing its salmon stocks on a river-by-river basis, curtailing
    exploitation to levels that are commensurate with the attainment of Conservation Limits.

   While the ending of drift netting is an essential component of any programme to restore
    stocks, it is not of itself a sufficient means for restoring abundance – habitat restoration, water
    quality, control of predators, scientific management of stocks, adequate protection services
    and curtailment of exploitation in the estuaries and rivers are all vital components.

   Currently Ireland is probably in breach of its obligations for salmon conservation under the
    EU Habitats Directive, is failing to manage the migratory life of the salmon in conformity
    with the UN Law of the Sea and has, generally, failed to recognise the international
    ramifications of its management of the Irish salmon fishery.

According to the latest scientific advice1, the returns of spawning salmon in 2004 were
below the levels required to meet their Conservation Limits in fourteen of the seventeen
Irish fishery districts. Eight of the fourteen districts were so far below their Conservation
Limits that the scientific advice was that there no exploitable surplus of salmon - in other
words, there should be no fishing of any kind.

The Atlantic salmon, as measured in catch returns, has been in decline for decades2. The
reasons for this are many and complex and some are beyond the scope of short-term
human intervention3. Precisely because some factors are beyond human intervention it is
essential that man-made threats to the survival of the species are mitigated to the greatest
extent possible.

This submission argues that, because of its nature and scale, drift netting for salmon at
sea contributes directly to the continuing decline of Irish salmon stocks and is inhibiting
efforts to conserve and restore those stocks. Measures need to be taken urgently,
preferably in consultation with the drift net community, to bring it to an end.

                                The Drift Net Fishery
The Mixed Stock Interceptory Effects of the Irish Drift Net Fishery

Drift netting is distinguished from other forms of commercial netting for salmon by the
fact that each net intercepts streams of fish returning to many rivers. For this reason draft
netting is often described as a being a “mixed stock fishery”.

Other forms of commercial exploitation (draft and loop and snap nets) are largely
confined to the catching of salmon running into a particular river. Consequently, drift
netting does not distinguish between fish attempting to return to rivers with adequate
numbers of spawning fish and those returning to rivers with seriously depleted stocks.
It is this feature, coupled with the very large number of salmon taken by this method,
which makes it so damaging to conservation measures. The effect of drift netting is to
seriously negate the value of conservation measures taken within the river system.

Since 1980 Irish scientists4 in the Marine Institute and the Central Fisheries Board have
been collecting data on the fate of hatchery reared smolts that have been tagged before

  “Provisional Catch Advice for 2005 from the Standing Scientific Committee of the National Salmon
Commission to the Commission”, 30 November 2004
  For a fuller discussion see Appendix One
  For a brief outline of the factors see Appendix Two
  Irish scientists, from both the Republic and Northern Ireland, have been major contributors to the
development of methodologies for measuring the size of salmon flows and catches, the determination of
conservation limits and the design of rehabilitation programmes

going to sea. These extensive tagging progammes, which involve the subsequent
sampling of up to 50% of all fish taken in the commercial fisheries are an essential tool in
the management of the Irish salmon fishery. They provide a basis for calculating the
marine survival data of the entire stock, an estimate of spawners returning to Irish rivers
and illuminate patterns of exploitation of the total stock.

There are currently eight rivers into which tagged smolts are released annually and there
is also data from tagging programmes on two other rivers from the 1980s. With the
exception of the River Lee in the South and the Liffey in the East all of the current
release locations are on the West coast. The sampling of the commercial catch (at
fourteen landing points around Ireland) results in the identification of the river of origin,
(and, therefore, the destination river) of tagged salmon caught and the location of their

Table 1 below sets out the most recent data available from the Marine Institute on the
distribution of the point of capture of micro-tagged salmon returning to spawn. The
interceptory nature of the fishery is clearly illustrated in these numbers. While it is not
surprising that a high per centage of the catch is in the area closest to the river estuary
(particularly when there is a draft, snap or loop net fishery operating within the estuary),
there are extremely high numbers of fish taken in places very distant from the
origin/destination rivers.

The picture illuminated by these surveys is striking. For instance, almost 55% of all
Boyne salmon caught were landed in Donegal and Donegal also consistently catches
32% of all Liffey salmon taken; Kerry and West Cork take respectively 23% and
30% of all salmon caught while returning to the Lee.

This longterm study of Irish salmon net catches establishes conclusively that it has a
major mixed stock interceptory impact in contravention of the guidelines adopted by the
International Council for the Exploration of the Seas (“ICES”) and the North Atlantic
Salmon Conservation Organisation (“NASCO”)5.

Table 1
Distribution (%) of tagged fish caught in Irish commercial fisheries -

Place of capture                      Donegal       Mayo     Gal/Lim Kerry    W Cork South Sth East Other N Ire Draft       Trap

Sample period      River of release

All years          Erne                    48.1       24.4       4.8   10.5       3.3   3.7        0   1.8   0.2   3.3         0
All years          Burrishoole             13.4       40.7      29.8    7.8       3.8   3.6        0     1     0        0      0
All years          Delphi                   6.7       37.1      48.9    1.5       1.2   0.1        0   0.9     0   3.5         0
All years          Corrib Wild                  7     14.5      41.8   13.3       0.5   2.7        0   0.2     0        0     20
All years          Corrib Hatchery          7.6       15.8      42.5   13.3       1.9   3.5        0   0.5     0        0     15

    See p 9 et seq below

All years      Shannon              5.1    17.9    51.2     11     5.9    4.9    0.1   0.6     0    3.2   0
All years      Lee                  3.1     5.1     1.5    23.5   30.7   33.2    0.6   2.3     0     0    0
1985           Slaney               8.9    10.7     1.8    14.3    8.9   55.4      0     0     0     0    0
All years      Liffey              32.5    17.5     15      30      0      5       0     0     0     0    0
1980-1986      Boyne               54.9     14       0      6.7     0     2.4      0     0     0    22    0

Source: Marine Institute

A paper written by Marine Institute scientists in 20026 summarised the results of the
interception of foreign-tagged fish caught in Irish drift nets in the period 1984 to 2000. A
fuller study on the issue of foreign originating salmon caught in Irish nets will be
published in April following a joint study by the Marine Institute and CEFAS of the UK.

The Scale of the Irish Drift Net Fishery

Irish drift netting was expanded hugely by the Government issuing new licences in the
1970s. In the 1960s approximately 320 licenced drift nets caught about 20% of the Irish
salmon tonnage.7 A major expansion of licences then took place to the point where there
were 1,156 licences in 1972. This has been gradually reduced to the current 877 licences.

While there is no scientific advice that directly links the two there is a strong coincidental
relationship between the expansion of drift netting in the 1970s and the timing of the
commencement of a serious decline in the number of spawning salmon.8

Some 70% of the Irish salmon taken by all methods of exploitation (including
recreational angling) fall to the drift nets9. Details of legally caught salmon since a
tagging system for salmon was introduced in 2001 are set out in Table 2 below.

Table 2
Catch Returns 2001/2003 in numbers
of fish

                                2001        2002          2003     2004

Drift nets                    197,172 179,177 141,222 120,303

% of Total catch                75.99        75.82 71.00           69.30

nets                           36,229 27,722 25,652                23,303

  O’Maoileidigh, Cullen and Mc Dermott, “The Occurrence of non-Irish coded wire tagged salmon in Irish
commercial fisheries”, dated 6 February, 2002
  “An economic/socio-economic evaluation of wild salmon in Ireland” (2003), report by Indecon
International Economic Consultants for the Central Fisheries Board at p20
  “Provisional Catch Advice for 2005 from the Standing Scientific Committee of the National Salmon
Commission to the Commission”, 30 November 2004, p5.
   “Wild Salmon and Sea Trout Tagging Scheme Fisheries Statistics Report, 2001-2003”, (2004) Central
Fisheries Board, Dublin

% of Total catch                    13.96         11.73       12.90         13.42

Angling                             26,074 29,408 32,017                   30,000

% of Total catch                     10.05        12.44       16.10        17.28

catch                              259,475 236,307 198,891 173,606

NOTE: The angling catch for 2004 is an estimate

Source: Central Fisheries Board

Drift net fishing for salmon is only part of a diverse range of fisheries undertaken by
inshore fishermen and while the amount of income derived from salmon fishing varies
from one fisherman to another, it is not the sole source of income for any.10

Pressure for High Quotas

The sheer scale of the drift net fishery is such as to create very strong political pressure
for the maintenance of high levels of Total Allowable Catch – well above those
recommended by the Standing Scientific Committee. Table 3 sets out the Precautionary
Catch Advice of the Committee for each of the past five years and the TAC actually
determined by the Minister of the day.

Table 3
Commercial Total Allowable Catch Precautionary Advice
and Ministerial Authorisations

     Year       Scientific                                    Ministerial
                 Advice                                      Authorisation
     2001                                                      267,099
     2002       147,000                                        249,649
     2003       139,751                                        211,000
     2004       158,929                                        191,965
     2005       122,305                                        169,900

NOTE: Each of the Ministerial Authorisation numbers includes 30,000 salmon for
angling to enable comparison with the Scientific Advice. The 2005 Ministerial
Authorisation is still the subject of public consulation.

          Sources: National Salmon Commission and Department of CMNR

     “A submission by BIM on the Indecon Report”, undated, Bord Iascaigh Mhara, Dublin

        The Current State of Irish Salmon Stocks11
The most uptodate picture of the state of Irish salmon stocks is that contained in the
Precautionary Catch Advice to the National Salmon Commission (“NSC”) from its
Standing Scientific Committee (“the Committee”) as their contribution to the
determination of the 2005 Total Allowable Catch (“TAC”). Table 4 below sets out the
Committee’s estimate of the extent to which each of the seventeen fishery districts
achieved the aggregate Conservation Limit for rivers in the area in 2004.

Table 4
Conservation Limit Attainment in 2004

     Fishery        Fishery Board                  %
     District          Region

 Dundalk                 East                    51
 Drogheda                East                    45
   Dublin                East                    12
 Wexford                 East                    53
 Waterford              South                    30
  Lismore               South                    77
    Cork              South West                 100
   Kerry              South West                 100
 Shannon               Shannon                   41
  Galway                West                     59
Connemara               West                     100
 Ballinakill            West                     100
  Bangor              North West                 95
   Ballina            North West                 76
    Sligo             North West                 41
B’shannon               North                    94
Letterkenny             North                    69
Source: Standing Scientific Committee of the NSC

From the table it can be seen that only four of seventeen fishery districts met their
Conservation Limits in 2004 (based on the low threshold of a 50% probability of meeting
the Conservation Limit).

Conservation Limits and Safe Biological Limits

Fisheries that do not meet their Conservation Limits12 are considered by ICES to be
“below safe biological limits”. 13

   Appendix 1 describes the decline in salmon catches in the Atlantic, North East Atlantic and Irish salmon
fisheries since the 1970s.

ICES has repeatedly advised that “the only fisheries on maturing salmon should be on
rivers which are shown to be above conservation limits”.14

Exploitable Surpluses and Precautionary Catch Advice for 2005

In the light of the Conservation Limit attainment in 2004 and other data the Committee
advised the NSC that the application of a precautionary approach (involving a
Conservation Limit attainment probability level raised to 75%) would result in eight of
the seventeen fishery districts (Dundalk, Drogheda, Dublin, Wexford, Waterford,
Shannon, Galway and Sligo) having no surplus to be exploited in 2005 and five other
districts in which the catch would be severely reduced below their average catch for the
years 2000/2004. In only four districts was it considered that the surpluses were
sufficiently robust to permit catches in line with the averages achieved over the past three
years. Details of the allocated Precautionary Catch Advice from the Committee are set
out in Table 5 below.

Table 5
Precautionary Catch Advice for 2005 by District

Region               District                    2005 Advice
East                 Dundalk                        No surplus
East                 Drogheda                       No surplus
East                 Dublin                         No surplus
East                 Wexford                        No surplus
South                Waterford                      No surplus
South                Lismore                          7,000
S. West              Cork                            30,024
S. West              Kerry                           31,414
Shannon              Shannon                        No surplus
West                 Galway                         No surplus
West                 Connemara                        2,200
West                 Ballinakill                      7,167
N. West              Bangor                           9,000
N. West              Ballina                         15,000

   ICES defines Conservation Limits (CLs) as “the level of stock that will achieve long term average
maximum sustainable yield (MSY) as derived from the adult to adult stock and recruitment relationship.
NASCO has adopted this definition of CLs” (Working Group on North Atlantic Salmon – ICES CM
   They may also, therefore, be considered to be below the “favourable” conservation status established by
the EU Habitats Directive (Council Directive 92/43/EEC) which requires that the “population dynamics
data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable
component of its natural habitats”.
   ICES “Extract of the Report of the Advisory Committee on Fishery Management to the North Atlantic
Salmon Commission”, May 2004 (“ICES 2004”), p23,24

N. West                Sligo                        No surplus
North                  Ballyshannon                    9,500
North                  Letterkenny                    11,000
                       Total                         122,305

* Based on 75% probability of meeting the CL
Source: Standing Scientific Committee of the NSC

The Committee’s CL attainment assessment for 2004 and Precautionary Catch Advice for
2005 must be considered in the light of the potential productive capacity of the Irish river
systems. In 2003 the Central Fisheries produced an assessment of the quantity of salmon
producing habitat on a national, fisheries district and individual river system basis
(known colloquially as the “wetted area report”).15

Table 6 sets out the results of combining the two analyses.

In only 14% of the total productive capacity of the Irish salmonid river system is it
considered that salmon stocks are not at risk from inadequate returns of spawners. In the
remaining 86% of the capacity stocks are at risk (27%) or at serious risk (59%).

Table 6
Application of 2005 Precautionary Catch Advice to Wetted Areas

       Fishery               Freshwater Habitat       Average Catch           Precautionary      % Reduction
       District               (Square Metres)          2000 - 2004            Salmon Catch       over Average
                                                                           Advice for 2005          Catch

Districts not considered to be at Risk

Ballinakill                       1,934,183               7,167                 7,167                    0%
Connemara                          811,701                2,229                 2,200                    1%
Kerry                             8,522,449               31,414                31,414                   0%
Cork                              4,715,328               30,024                30,024                   0%

Percentage of
Freshwater Habitat                   14%

Districts considered to be at Risk

Letterkenny                       5,337,762               18,887                11,000               42%
Bangor                            8,881,629               10,808                9,000                17%
Ballyshannon                      3,361,359               13,239                9,500                28%
Ballina                           3,239,957               25,740                15,000               42%
Lismore                           9,314,020               14,134                7,000                50%

Percentage of
Freshwater Habitat                   27%

  “Quantification of the Freshwater Salmon Habitat Asset in Ireland”, Central Fisheries Board, Dublin,

Districts considered to be in Serious Trouble

Sligo                           3,990,574                   5,713                  Zero         100%
Galway                          5,307,431                   4,560                  Zero         100%
Limerick                        14,394,975                  17,056                 Zero         100%
Waterford                       24,345,915                  15,380                 Zero         100%
Wexford                         7,032,752                   1,497                  Zero         100%
Dublin                          2,741,828                    108                   Zero         100%
Drogheda                        6,695,412                   2,474                  Zero         100%
Dundalk                         2,372,751                   1,224                  Zero         100%

Percentage of
Freshwater Habitat                 59%

The Freshwater Habitat is the area of River Habitat accessible to Salmon as identified by the
Wetted Area Report 2003, Central Fisheries Board

Source: Standing Scientific Committee of the NSC, Central Fisheries Board and SSDNN analysis

            The Necessity for Single Stock Management
Based on data supplied by national administrations, ICES compiles comprehensive data
on the state of marine fish stocks, including salmon. ICES issues an annual report,
including advice on future catch levels and conservation measures, to NASCO.

NASCO has defined its primary management objective as being: “To contribute through
consultation and co-operation to the conservation, restoration, enhancement and rational
management of salmon stocks taking into account the best scientific advice avilable”16.
In pursuit of this objective NASCO has adopted a precautionary approach17 which holds
that “management measures should be aimed at maintaining all stocks above their
conservation limits… the use of management targets” and defines the precautionary
approach as “an integrated approach [that] requires, inter alia, that stock rebuilding
programmes… developed for stocks that are below conservation limits”.
In its advice to NASCO, ICES states that it “has interpreted stocks to be within safe
biological limits only if the lower bound of the confidence interval of the most recent
spawner estimate is above the [Conservation Limit]”18.

In thirteen of its seventeen fishery districts Ireland falls below that standard.

   NASCO document CNL31.210
   “Action Plan for Application of the Precautionary Approach”, Document CNL(99)48, NASCO 1999
   ICES 2004 (see fn 5)

ICES “recommends that the overall exploitation of the stock complex in mixed stock
fisheries should decrease to the lowest possible level to increase the probability of
meeting the conservation limit of the stock complex….[and] considers that the only
fisheries on maturing 1SW [and MSW]19 salmon should be on the river stocks which are
shown to be above conservation limits”.20

The ICES Working Group on North Atlantic Salmon, which provides the underlying
analysis and detailed data for the ICES advice, stated in its 2004 report, in respect of both
1SW and MSW stocks in the Southern European Area (to which Ireland belongs), that
“this stock complex is outside safe biological limits” and further “that mixed stock
fisheries present particular threats to conservation. Reductions in exploitation rates are
required for as many stocks as possible, except those stocks shown to be above
conservation limits”21

Obviously the adoption of a precautionary approach to Conservation Limit attainment
would also have serious implications for the control of catch levels by single stock draft
net fisheries in estuaries and by angling in rivers and lakes.

       The International Dimension to the Drift Netting
Ireland must manage its salmon fishery in the context of a wide range of international
obligations, legal and moral. It is to a greater or lesser extent failing to meet its
international obligations in a number of significant areas. Chief among these are:

    ICES and NASCO: As already described Ireland is failing to manage its salmon
     stock in accordance with ICES advice and NASCO standards, notwithstanding the
     fact that it is an active participant in the decision making processes of both bodies and
     has never publicly explained the rationale for these deviations.

    EU Habitats Directive: While the salmon is designated under the Habitats Directive
     as an “Animal…of Community interest whose conservation requires the designation
     of special areas of conservation” this status is confined to fresh water. Nonetheless,
     Ireland is obliged under Article 6.3 of the Directive to subject “any plan or project”
     that will have a significant impact on the designated site of a protected species to
     “appropriate assessment of its implications for the site in view of the site’s
     conservation objectives”. It may be argued that the setting of quotas with out regard
     for their impact on the in river status of the salmon is in breach of the Directive and

   A “1SW” salmon is one which has been to sea over one winter; an “MSW” salmon is one which has been
to sea for two or more winters.
   ICES Working Group on North Atlantic Salmon, 2004 (ICES CM 2004/ACFM:20)
   Ibid, at para 3.4 at p24

    Stop Salmon Drift Nets Now (and others) have made such a case to the EU

   UN Law of the Sea: Within the framework of the UN Convention on the Law of the
    Sea, Ireland is a party to the “Agreement for the Implementation of the
    Provisions……Relating to the Conservation and Management of Straddling Fish
    Stocks and Highly Migratory Fish Stocks”. While the fishery management standards
    set out in the Agreement are similar to those of ICES and NASCO, it also imposes an
    obligation on States to cooperate at regional and sub regional level in conservation
    and management measures. The Irish Government have consistently rebuffed efforts
    by the North Atlantic Salmon Fund to establish regional or sub regional management
    organisations for the salmon notwithstanding the clear evidence that the Irish drift
    nets exploit fish running to foreign rivers.

   The Greenland and Faroese Commercial Salmon Fisheries: For some years now,
    due mainly to the efforts of the North Atlantic Salmon Fund, commercial fishermen
    in Greenland and the Faroe Islands have totally set aside their right to catch Atlantic
    salmon in return for an annual payment. Despite the greatly reduced pressure on
    these feeding grounds for Irish salmon, the Irish government has consistently refused
    to make any contribution to the cost of this set aside.

   Interception of Fish Running to Other EU Countries: Reference has already been
    made to the interceptory effect of drift netting on fish running along the Irish coast
    and destined for rivers in the S W England, Wales, Germany, France and Spain. The
    full extent of this problem is likely to be illuminated by a joint Irish/UK study which
    it is understood will be published in April.

                              What is to be done?

From the earlier part of this submission it is clear that doing nothing about drift netting
is not an option if the salmon is to be maintained (and in most rivers restored) as an
important part of our bio-diversity and as an economic, social and recreational resource.
The failure to adopt a precautionary approach to the survival of the salmon at this critical
time would be to put the species at serious risk of being a curiousity confined to a very
small number of rivers within a very short space of time.

The Elements of a Programme

Stop Salmon Drift Nets Now believes that a comprehensive programme of salmon
conservation involving exploitation at sustainable levels would include the following:

    A firm commitment from Government to have the salmon fishery managed in future
     in accordance with precautionary principles and on the basis of the developing
     scientific advice;

    The introduction in 2006 of a scheme that would incentivise drift net fishermen who
     earn all or substantially all of their income from inshore fishing to exit the salmon

    The establishment of a vehicle for financing and managing that process funded by a
     mixture of state, licence holder, fishery owner/operator and tourism sector sourced

    A declaration by the Government that drift netting will be phased out over a short
     period and all commercial exploitation confined to single stock estuaries. This would
     involve a facility whereby drift net operators could convert to draft netting where
     stocks permit;

    There would be an active process of transferring quotas from the remaining drift net
     fishery to the draft/loop/snap sector in rivers which have stocks that are robust

    Developing alternative sources of income specifically for those exiting the drift net
     fishery, including salmon ranching in suitable rivers22;

    Establishing a programme to be implemented in no more than three years that would
     provide a sound basis for the scientific determination of exploitation levels on a river-
     by-river basis. The ingredients of such a programme would include provision for the
     installation and operation of fish counters on all significant salmonid rivers and the
     allocation of funding to enable Marine Institute/CFB scientists accelerate the
     transition from smolt micro-tagging to genetic fingerprinting as a basis of data

    The initiation of an active programme of habitat enhancement, water quality
     improvement and augmented protection measures against all forms of illegal

    A major drive to develop the game angling tourism product on rivers which can
     sustain angling exploitation.

  The recently published report by the Commercial Fishing Representatives on the South West Regional
Fisheries Board, “Our Marine Salmon Fishery – Sustainable vision for the future”, sets out an extensive list
of alternative income possibilities in that region, some or all of which may have application elsewhere.

Discussions with Drift Net Operators

Stop Salmon Drift Nets Now has had wide ranging discussions on an informal basis with
drift net operators around the coast over the past six months. Some of these discussions
have been initiated by the fishermen themselves and all of them have focused on means
by which the fishermen could either be assisted to retire or helped to adapt to other forms
of income either within the inshore fishing sector or otherwise.

In general it can be said that the main factors motivating those who favoured an exit
strategy, if not always for themselves then for others, was:

   Decreasing and uncertain levels of catches and a developing view that “something has
    to be done”;

   A recognition that quotas will continue to go down and further depress catches;

   A concern that ever lower quotas could lead to a return to something akin to the
    conflict between fishermen and the Regional Fisheries Boards’ protection staff that
    characterised the 1970s and 1980s;

   The high average age of the operators making it less attractive for them to continue in
    the business. An informal survey of fishermen by fishermen has estimated that the
    average age is in the mid-fifties.

Some groups have already well developed ideas about the structuring of adaptation,
withdrawal and retirement schemes but it would be a breach of confidence with those
with whom discussions are still continuing to publicly reveal the details at this point.

The Cost of an Incentive/Retirement/Adaptation Scheme

What can be said is that there is a common thread of unit cost running through what are
on the surface apparently disparate proposals which suggest that if such a scheme or
schemes were to encompass the entire drift net community the total cost of
implementation would be about Euro 25 millions spread over about five years, ie about
Euro 5 million per annum, broadly in line with the landed value in 2004 of drift net
caught salmon. In practice the amount involved in what would initially be a voluntary
scheme would be a good deal less than that.

Financing the Scheme

On the basis of a Euro 5 million annual cost the following indicative means of financing
would it seem reasonable:

Government:                              Euro 2.50 million (See Note 1 below)
Increase in Salmon Licences:             Euro 1.25 million (See Note 2 below)

Owners, tourism sector and other
sources:                                 Euro 1.25 million ( See Note 3 below)


(1) This would be justified on grounds of the States responsibility for conservation and
    on the eventual increase in Exchequer returns from the angling tourism sector;
(2) This assumes a Euro 50 increase in the salmon rod licence with some reduction in
    that amount for the very short period licences. A case can also be made for an
    increase in the licence for estuary nets which will benefit from a withdrawal of drift
(3) Owners (which includes a large State involvement mainly through the Fisheries
    Boards and the ESB and a significant number of angling clubs) will be major
    beneficiaries even with a more rigorous scientific management of the stock as would
    the tourism sector. There is potential for fund raising from foreign
    angling/conservation sources through the North Atlantic Salmon Fund, some EU
    support may be available in respect of fishermen withdrawing entirely from the
    inshore industry, etc.

                                                                         APPENDIX ONE

     The decline of Atlantic, North East Atlantic and Irish
                        salmon catches

North Atlantic Salmon Stocks

Table 1 below chronicles the decline in catches of Atlantic salmon based on ICES
published data.

Table 1

Catches of Atlantic Salmon in

     Year           Total  Index          NEAC      Index
                   NASCO '70=100          S’thern '70=100
                    Area                   Area

       1970         11,286      100        4,048          100

       1980         10,127       90        2,640           65
       1990          4,924       44        1,645           41
       2000          2,913       26        1,210           30
       2003          2,461       22         932            23
Source: ICES

These statistics include fish farm escapees and this to some extent obscure the true state
of the decline in wild salmon particularly since the 1980s. The data do not take account
of reduced fishing effort over the period but this has resulted largely from voluntary
withdrawal of practicioners or from special management measures introduced in the face
of declining stocks and catches. Nonetheless, the declines since 1970 of 70% each in the
total NASCO area and in the NEAC Southern Area (to which Ireland belongs) are

Southern Area stocks below safe biological limits

In relation to the more recent data for overall Atlantic salmon catches ICES comments
that “the prognosis for stocks should reflect the evidence of recent times, that the
probability of rebuilding in the short term is low in most areas and that the main result of
recent management efforts may have been to reduce the rate of decline rather than lead to
any significant stock rebuilding"23.
     ICES 2004 at p 7

In its commentary on the current state of stocks ICES stated that, in respect of the NEAC
Southern Area “1SW and MSW24 stock complexes were estimated to be outside safe
biological limits”25. In respect of both 1SW and MSW fish in the Southern Area, ICES
recommended that:
       “……the overall exploitation of the stock complex in mixed stock fisheries26should
       decrease to the lowest possible level to increase the probability of meeting the
       conservation limit of the stock complex. Moreover, due to the different status of
       individual stocks within the complex ICES considers that the only fisheries on
       maturing [1SW and MSW] salmon should be on rivers which are shown to be
       above conservation limits”27

Irish Salmon Stocks

The total Irish salmon catch for selected years, reported to ICES by the Irish authorities,
is set out in Table 2 below. The catches cover all methods of exploitation.

Table 2

Irish Catches of Atlantic Salmon in

     Year               Irish               Index          % of total % of total
                    Fishery Area         ('70=100)       Atlantic catch NEAC Sth Area

     1970                1,787                100                16                    36
     1980                 947                  53                  9                   36
     1990                 567                  32                12                    34
     2000                 621                  35                21                    51
     2003                 575                  32                 23                   62

It can be seen that at the same time as Irish catches, and by extension stocks, have
declined by 68%, the Irish component of the total Atlantic catch has increased from 16%
to 23% and that of the NEAC Southern Area the Irish catch has gone from 36% of the
total to 62%. This reflects the continuing exploitation of Irish stocks at a level considered
unsustainable elsewhere.

   1SW fish are those which have been to sea for one winter and have then returned to spawn; MSW fish
are those which have been to sea for more than one winter.
   ICES 2004 p 22
   Drift net fishery are mixed stock fisheries
   ICES 2004 p 23, 24

                                                                       APPENDIX TWO

       The Causes of the Decline Irish Salmon Stocks
The causes of the decline in stocks of Atlantic salmon are many and complex and,
particularly in relation to the marine environment many aspects of which are still not
fully understood. They can be summarised under the following headings:

1. Changes in the marine environment affecting the survival rates of maturing salmon
   including apparently increasing losses to predators (eg seals) as fish stocks decline
2. Environmental changes affecting river water quality, the degradation of habitat in the
   river systems and predation on immature fish;
3. Over fishing;
4. Mixed-stock fishing (ie drift netting).

The first of these is beyond the influence of man in the short term – other than perhaps
the over exploitation of feed stock in the ocean. The second and third are being
addressed within existing EU and national programmes. The fourth remains unresolved.

Water and Habitat Quality

Since the adoption of the Local Government (Water Pollution) Act 1977 (and subsequent
amending legislation) Ireland has put in place a comprehensive framework of policies,
regulation and investment designed to upgrade water quality and the reports of the
Environmental Protection Agency suggest that this is having a strongly positive impact
on water courses. The implementation of the Water Framework Directive, now in
progress, provides an integrated management approach to further enhancing water

Ireland has now designated 26 salmonid river SACs giving additional protection to
passages used by salmon en route to spawning areas and to the spawning areas

In addition to normative measures there has been a large investment by the State and the
private sector in salmon conservation in Ireland, a good deal of it supported by EU
Structural Funding and programmes such as Interreg. Restocking with hatchery raised
fry and smolts have been undertaken by the Electricity Supply Board on its rivers and by
many private fishery owners and angling associations. With the current emphasis,
encouraged by the Central Fishery Board, on habitat and spawning area enhancement
many river systems are having their productive capacity augmented through cooperative
programmes between fishery owners, anglers and the state services.


Overfishing in the Irish context is being partially addressed though the Total Allowable
Catch process. This takes account, on the basis of each individual river, the spawning
capacity of the river, the number of salmon actually returning to it, the extent to which it
meets the number of spawning fish needed to maintain an abundant stock in the river and
the surplus (if any) available to be caught.

The TAC provides a framework within which salmon conservation can be managed, in
line with ICES and NASCO advice, on a river-by-river basis.

The TAC approach has, however, been seriously comprised by two major factors:

   The consistent failure of the Minister of the day to follow scientific advice in the
    setting of TACs (see the Table below);

   The TAC is only appropriate to the determination of the number of fish that can be
    prudently taken within each the river catchment - it can offer no effective control
    method for the mixed stock drift net fishery which does not discriminate between fish
    returning to different rivers.

                                   References - “Extract of the Report
of the Advisory Committee on Fishery Management to the North Atlantic Salmon
Commission”, ICES, Copenhagen, 2004 – Report of ICES Working Group
on North Atlantic Salmon, ICES, Copenhagen, 2004 - “Irish
Wild Salmon Fishery Management”, Department of Communications, Marine and
Natural Resources, Dublin, 2004 – “Agreement……relating to the Conservation and
Management of Straddling Stocks and Highly Migratory Fish Stocks”, UN December

“A coordinated approach towards the development of a scientific basis for management
of wild Atlantic salmon in the North-East Atlantic (SALMODEL)”, Queen’s University
of Belfast on behalf of the EU Commission, 2003

“Action Plan for Application of the Precautionary Approach”, Document CNL(99)48,
NASCO, 1999

“An Economic/socio-economic evaluation of wild salmon in Ireland”, INDECON
International Economic Consultants for the Central Fisheries Board, Dublin, 2003

“Application of pre-fishery abundance modelling and Bayesian hierarchical stock and
recruitment analysis to the provision of precautionary catch advice for Irish salmon
(Salmo salar L) fisheries”, ( O’Maoileidigh, Mc Ginnity, Prevost, Potter, Gargan,
Crozier, Mills and Roche) , ICES Journal of Marine Science, 61 p1370-1378

“A submission by BIM on the INDECON report”, Bord Iascaigh Mhara, Dublin, undated

“Our marine salmon fishery – sustainable vision for the future”, Commercial Fishing
Representatives, South Western regional Fisheries Board, Macroom, March 2005

“Quantification of the Freshwater Salmon Habitat Asset in Ireland”, Central Fisheries
Board, Dublin, 2003

“Wild Salmon and Sea Trout Tagging Scheme Fisheries Statistics Report, 2001-2003”,
Central Fisheries Board, Dublin, 2004


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