2016 Submission to Inland Fisheries Ireland on the National Strategy for Angling Development 2015 -2020, NSAD

2016

Submission to Inland Fisheries Ireland on the National
Strategy for Angling Development 2015 -2020, NSAD

                                           Monday 4th January 2016

th
In response to the publication of the draft NSAD and the meeting held in Athlone on the 27 of November

2015, the National Coarse Fishing Federation of Ireland wish to acknowledge the National Strategy for

Angling Development (NSAD) as a major development in identifying the importance of both angling and our

fisheries to the Irish economy. The NCFFI welcomes the identification of pathways to the future growth and

protection of our sport and recreation as well as our angling resources.

The NCFFI recognises the level of work and commitment by Inland Fisheries Ireland, IFI in producing the

National Strategy for Angling Development, NSAD given its complex nature and the numerous elements of

the necessary research required.

The NCFFI has been representing the coarse angling community for over 50 years and organises some of the

longest running National events in Ireland. Our National Executive, clubs, coaches and associates bring with

them a wide field of knowledge and experience in all areas of angling. Our member clubs alone organise the

majority of the coarse angling festivals, including those with the highest profile, that bring many overseas

anglers to Ireland and with them a significant benefit to the Irish economy. We have members who were

involved in the Irish coarse angling mecca of the 90’s and the running of such events as the Angling Times

and Failte Ireland Leagues as well as working with the tourist boards. But we move with the times striving to

be current and have had much success with our social media platforms. As a 32 county organisation we

work closely with agencies in the North of Ireland where we are the NGB for coarse angling working with

Sport Ireland and DCAL Fisheries. Via the Angling Council of Ireland we engage with angling of all types

currently working with 20 multi-discipline Youth Angling Hubs across the island. We believe ourselves to be

a valuable stakeholder and welcome channels for heightened engagement.

However, our organisation does have some concerns and suggestions that we would like to highlight. We

believe that these recommendations if implemented will not only enhance the strategy but also share the

engagement of the IFI with the coarse angling community whom we represent. A partnership approach

based on mutual respect should form the basis of this.

Firstly we would like to raise some concerns in terms of areas we feel need to be addressed in detail by the

NSAD Implementation Group namely in Pollution, Fishery Stocks, Invasive Species and Anti-Social Behaviour

and the impact on the national recreational angling resource.

Much of the following information can be found in more detail in our ‘Policy Document for Coarse Angling’

as present to the board of the IFI in January 2015.

Pollution

In regards to the current state of our waterways, pollution comes from a range of sources including sewage
treatment plants, farm run-off and industrial waste.

There is also the matter of pollution on the bank and the impact on our environment. An area the Angling
Council of Ireland is hoping to address in partnership with Leave No Ireland with the creation of basic Skills &
Ethics for all disciplines incorporating coarse angling via the NCFFI.

The failures around the issues of pollution of the waterways must be addressed at both national and local
level by involving all the relevant responsible state agencies and representatives of the private sector
including the NGB’s of angling. Structures must be put in place, focused on resolution of the problems we
face with low water quality.

We regard the adoption and implementation of international best practice for pollution control of Ireland’s
inland waterways to be a fundamental to the growth of sporting and recreational angling.

Consideration should be given to the following,

    (1) IFI to mandate a specialist working group to identify critical areas in terms of pollution that affect
            our fish stocks. In addition, identify international best practice methods used to eliminate pollution
            of marine and freshwater habitats. Distribute such findings to all relevant agencies and to Angling
            NGB’s

    (2) IFI and angling federations and groups to develop a partnership approach to the prevention and
            amelioration of pollution incidents.

    (3) A review of enforcement strategies is long overdue in this area. A transparent and well published
            approach is needed to promote involvement of the angling community. The use of social media as
            well as the news sections of websites of state, angling and community organisations offers an ideal
            communication opportunity to publicise the strategies, their successes and failures.

Protecting Fish Stocks

While coarse and predator stocks in Ireland are healthier than some other recreational fishery stocks there is
no room for any complacency around stock levels. This very complacency of official Ireland caused the
dramatic and unprecedented stock collapse over recent decades. Despite the sterling work of fishery officers
in countering widespread poaching, both casual and commercial, the simple fact remains that protection of
coarse and predator fisheries has been seriously under resourced heretofore.

A national no fish kill policy is over due to support the coarse and predator angler’s commitment to
conservation of our national stock. The current legal position allowing anglers to take 4 fish per day is
impossible to enforce and sends a poor message to anglers at home and abroad. The removal of this bye-
law would service to benefit angling tourism.

We fully support IFI’s work in this area. We are conscious of the damaging effect of irresponsible and
abusive commentary on social media and condemn it outright. We have however previously made
recommendations in relation to how the reporting of poaching can be improved and would like to see some
progress in this area.

A reserve force of well trained and equipped part time staff is urgently needed to support and supplement
the work of professional IFI staff in combating this scourge of our wildlife. Engaging ratified club members
via the NGB’s would enable referencing of those to be involved and would be an ideal opportunity to engage
the anglers on the ground and enhance their feeling of involvement.

Our freshwater fish are also being impacted by Cormorant predation. Our members are reporting increased
activity in this area and although the rest of the EU reports an increase in the population official figures for
Ireland remain stagnant. We do not agree with these and a number of our clubs have suggested the
collection of data to highlight these inadequacies and we would welcome the support of the IFI in order to
put fishery interests on par with bird protection.

Valuable coarse and predator fish stocks continue to be slaughtered in the name of fishery management.
The NCFFI welcomes a policy on fish movement to provide a licencing mechanism to harvest our resource
and re-home these fish in the reserves of active fisheries.

Invasive Species

Invasive species is one of the most serious threats facing our inland fisheries. IFI has been to the fore in
promoting awareness of the problem as well as leading the way in dealing with the issue. IFI has been
successful in this role but a no small cost, sometimes at the expense of budgets for fishery protection and
development.

IFI is ideally situated to act as lead agency in this area. NCFFI fully supports IFI in this work and would ask that
a separate budget be sought for the work. This budget needs to reflect the extent and risks associated with
aquatic invasive species.

We do believe the agency responsible does require a detailed and up to date researched plan identifying the
geographical range of invasive species in Ireland and it must include ways to manage or eradicate such
species.

We follow IFI recommendations for bio-security at all our National events and encourage our members to
follow. This particular area has been successful and many anglers now accept it as the norm although those
events not organised by affiliated clubs do not follow suit which leads to unnecessary negativity. It would
however be beneficial for NSAD fund to be made available to clubs and organisers to fund bio-security
measures.

Measure 1 - Identify funding for NSAD

Anglers already contribute significant to our national angling resource, through voluntary work, and in some
cases through licenses and permit costs although limited in the area of coarse angling. However the burden
should be shared among all stakeholders that may benefit from the development of angling in Ireland. It is
envisaged that the current estimate of 273,000 domestic anglers is conservative likely to increase. For a
system to be fair the 132,000 angling visitors using the resources should also make some contribution to the
protection, maintenance and development of the resource.

The introduction of a specific fund for the NSAD plan would benefit anglers and IFI, it would produce a
greater understanding of the amount of domestic and tourist anglers participating and benefiting from our
angling resource. Where coarse and predator angling is concerned there is no measure for the anglers on
our banks and the licensing and permit data could be used by the IFI to better understand angler
participation and fulfil the current information deficit. The introduction of the fund would serve to help to
improve angling facilities, accessibility, angling information, angling development, stock recovery projects,
habitat restoration, enhanced fisheries protection and training. It could provide part funding for the plan or
enable it to be enhanced according to the anglers needs and amount of income received.

Any introduction of a specific fund must however be ring-fenced. The various stakeholders willing to
contribute should have opportunities for proactive engagement with IFI in the promotion of our sport &
recreation, as stated in the NSAD the input of stakeholders in supporting the protection of inland fisheries is
essential in delivering its strategy. This we agree with, nevertheless the mechanisms for stakeholder
engagement for input and the level of support required need to be meaningful and clearly identified. Clear
and concise information on ring-fencing of the proposed fund should be publicly available. It should include
details showing how anglers’ contributions to the fund would be maintained separate from public funds
providing assurance that angler’s money is utilised appropriately and fairly.

We recognise the IFI’s allocated funding has been reduced significantly in recent years along with other
public service funding in general. We are of the view, these cuts have had a serious negative effect on
protection and development of fisheries and we see the NSAD as addressing these issues in a structured
way.

The salmon conservation fund and Southern Co-op fund are indicators of how angler’s contributions can
benefit angling overall. Many worthwhile projects have been funded and successfully delivered by clubs and
IFI resulting in improvements to a variety of fisheries. Since these schemes were introduced however, many
                                                                                                        rd
changes have occurred in relation to gaining access to funds (Availing of public funding or managing 3 party
funding) making it difficult for contributing clubs to access them.

Measure 2 – Stakeholder Engagement

The NCFFI recognises the expertise of the IFI in fisheries management, we recommend anglers work closely
with the IFI in terms of all fisheries development projects. However, the IFI must understand that anglers
are best at managing the angling elements and must have a major input into the final criteria especially if
they are to be contributors to any funding.

IFI must also recognise and acknowledge that anglers and the national angling organisations are best placed
to manage the angling elements of the sport & recreation as they have the skills knowledge and experience
to develop this adventure activity that also has a number of health benefits, engages local communities and
like-minded people with no barriers.

IFI as lead proponent in the strategy must ensure recognised National Angling Organisations, such as the
NCFFI and the Angling Council of Ireland, ACI have a voice and are included in terms of decisions that are
made that affect their members angling. We need to work together to deliver on the plan’s objectives. This
will ensure the strategic goals, in terms of angling, are achieved within the lifetime of the plan.

Measure 3 – Sustainable Development of the natural angling resource

The NCFFI recognises the need for the upgrading of our angling infrastructure and a renewals and
enhancement programme for the development of our fisheries.

Stakeholder involvement as per measure 3 is particularly important when it comes to development as
running major national and international events and coaching days allows us to identify the necessary
development requirements for the everyday angler, those being introduced to the sport & recreation and
the higher profile competition angler.

There is evidence of a highly successful partnership model whereby the NCFFI, ACI and IFI along with other
agencies have worked together to develop fisheries. Two examples are the Coachford Greenway Ireland’s
only world class angling venue and the Ballyshunnock reservoir which has facilities for everyone including
the coaching of juniors and the less able.

These developments represent models on which the NSAD may implement their strategy for development.

Both these examples also incorporate our natural environment and provide facilities for non-anglers. The
NCFFI would the opportunity to work in partnership with the IFI in their consultation to such future projects
such as Blueways and Greenways being introduced by local agencies, specific venue developments we have
in the pipeline and the introduction of angling centres of excellence in line with a project being undertaken
in conjunction with Sport Ireland.

There are synergies to be gained in looking at water management maintenance such as the dredging of our
rivers where with the involvement of the anglers the enhancement of angling access can be delivered as the
result of a standard process.

Measure 4 - Protection and conservation of our fishery resources

There is a general view among our federation, Angling Council Ireland and overseas anglers that the
enforcement of inland illegal fishing is beyond the capacity of IFI alone to control. It is feared that the extent
of illegal fishing has grown in recent years due to the reduction in numbers of IFI fishery officers and river
patrols.

Recommendations:

IFI to increase the numbers of Fishery Officers on protection duty on inland waters to ensure the necessary
protection is afforded to wild salmon and sea trout stocks. Ensure a visible presence of fishery staff on the
ground combined with the use of modern surveillance technologies.

IFI should work with angling federations to try to improve protection. NCFFI strongly recommends greater
co-operation between IFI staff and private water-keepers to help eliminate illegal fishing pending the
introduction of the previously mentioned reserve force.

IFI should develop a system that ensures the various angling groups have an active and on-going role in
assisting IFI to control illegal fishing. Improvements are required here and this would lead to greater
relationships being formed which would massively benefit the potential of NSAD. There is a major desire
from relevant stakeholders to engage with IFI to tackle the protection issues and resolve the problems.

It is also noted when prosecutions are brought before the court system, the penalties are not a sufficient
deterrent. It is recommended that IFI seeks to address this issue with the Minister by seeking stricter
penalties for a range of offences in relation fishery protection. This is necessary to ensure penalties are a
deterrent and that those who are convicted of breaking the fisheries laws are penalised adequately.

See Protecting our Fish Stocks. Whilst we welcome designated catch & release fisheries e.g. Waterways
Ireland network we believe this complicates enforcement and a full no kill policy on the island of Ireland is
the solution.

Measure 5 – Standards – fisheries and services

Whilst we respect that the Angling Product Evaluation Criteria and classification of the fisheries is an
extremely useful tool and the venue graph supports our own top level evaluations, it has not been
populated by those who actually use the fisheries. We believe it would be very beneficial for a group of non
venue biased anglers to carry out the same evaluation.

With a large number of travelling anglers within Ireland and overseas it is important to recognise that in
addition to the fishery it is the availability of suitable accommodation, bait availability and local knowledge
that forms the Irish angling product.

Measure 6 – Marketing & Promotion

We are passionate and committed to the promotion of coarse and predator angling and actively encourage
our angling clubs, assisting them with the necessary expertise to create a social media presence on which to
share their activities. We regularly provide the IFI with access to reports along with the local, national and
specialised angling press at home and overseas.

The best promotion is for an angler to read about the experiences of another angler, particularly, a high
profile one and we are fortunate to have members who support this and help us to work with the angling
press in the promotion of coarse angling in Ireland and support with a particularly high profile angling
competition that is solely dedicated to the promotion of our angling resource.

Once again we would welcome inclusion in the promotional activity of the IFI for coarse and predator
angling as we are fully aware that poor promotion can do more harm than good. Through our relationships
in angling there are many channels by which this promotion need not be costly at all.

In most countries you will find that anglers are usually more amenable to working with an angling federation
that a state agency and with a working partnership we can overcome this.

Measure 7 - Access to Angling for All

In relation to making angling more attractive to younger people or vulnerable adults, NCFFI recognises the
support and resources given by IFI to our federation and clubs in terms of youth angling, in particular the
support given to Angling Council of Ireland for the coaching programme and Angling for Youth Development
Ireland (AFYDI). These programmes we believe are a major step forward for youth angling in Ireland and
have huge potential for growth under the current structure. NCFFI continues to work closely with ACI and
we have formed 12 of the targeted 20 hubs. AFYDI hubs have now been equipped through our own
resources and funding from IFI and under the Sports Capital Programme.

Our coaches now have access to a wide range of equipment however, training and continuous professional
development (CPD) is always necessary and continuous support is required. The Angling Council of Ireland
Coaching Pathway developed with Coaching Ireland involves advancement through the coaching levels, First
Aid for angling, Health & Safety, Safe Wading & River Rescue, Coaching People with Disabilities and
Vulnerable Adults, Casting Instructor Training (GAIA) and Power Boat Training.

These hubs enable young anglers and vulnerable adults to freely participate and enjoy our wide fishery
resource. Already AFYDI hubs have reached out to introduce other groups to angling such as older adults,
disadvantaged groups, immigrant groups etc. In our experience working with such groups over a six week
period creates great experiences and angling is without doubt a great tool for social inclusion. The hubs need
to be supported initially to ensure they become embedded in local communities. The NCFFI has a number
of angling coach tutors and are fully committed to deliver coach training throughout Ireland supporting the
Angling Council of Ireland with whose help has seen 300 of our members achieve Introductory Coaching
certification – essential for the safe supervision of anglers on the bank. Future support for these initiatives
through the NSAD will allow them to flourish.

Summary

To conclude, Inland Fisheries Ireland NSAD is a major development with great potential to improve and
develop our angling resources for the benefit of participating anglers and of the Irish economy.

NCFFI recommend that IFI does all in its power to work with the various angling groups to build up a solid co-
operative relationship in developing the NSAD. The NCFFI has a strong track record in working in
partnership with the IFI and other stakeholders to bring projects to completion. All stakeholders have a
responsibility to contribute to an atmosphere of trust and mutual respect, without this it will be difficult for
for the NSAD to deliver on its full potential.

We encourage IFI to continue to support our federation and the Angling Council of Ireland incorporating
programmes such as ACI coaching structures, Angling for Youth Development Ireland and IFI’s Something
Fishy.

Enhance the Something Fishy programme to include additional angling and biodiversity field trips and to
incorporate all angling disciplines. ACI coaches can partner IFI staff to deliver these enhanced education
programmes.

The NCFFI supports the introduction of angler contributions when participating in coarse angling in Ireland
as per the Coarse Angling Development and Conservation Stamp solution submitted in our Policy Document
for Coarse Angling of January 2015.

Finally, in support of angling tourism and job creation, we in NCFFI support the Irish Angling Industry. We
have plans to host major international competitive events over the next 5 years and a comprehensive
annual programme of domestic angling festivals and events. In addition to this programme attracting tourist
anglers we have an extensive training programme and prestigious international competition structure to
promote our sport among the young. The NCFFI also works closely with our European Angler Alliance and
FIPSed colleagues promoting Ireland as an angling destination.

We look forward to working with the NSAD Implementation Group to develop opportunities and we will
play our part in protecting and developing our natural resources.

The National Coarse Fishing Federation of Ireland invests in affiliations and enjoys working partnerships with

the following bodies necessary to support our sport & recreation, listed in no particular order.

  International Confederation of                                                 Federation of Irish Sport
           Sport Fishing                   Angling Council of Ireland

     International Federation of
                                        Northern Ireland Sports Forum            European Anglers Alliance
      Freshwater Sport Fishing

         Coaching Ireland                   The Irish Sports Council              Sport Northern Ireland

       Leave No Trace Ireland                DCAL Inland Fisheries                   Irish Water Safety

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