Dear Carwyn,

Subject: Comments on your letters to AM and MP regarding the future of Welsh Sea Fisheries Committees (SFC)

A number of AM and MP have sent me copies of your letters to them regarding the future of SFC in Wales. They have each asked me to comment on the question as to the extent to which the NWNWSFC was consulted on the future of SFC in Wales prior to your announcement on 15 September that you will be consulting on a proposal to take the management of all Welsh inshore fisheries into the NAW. This announcement has created considerable concern in North Wales among fisheries stakeholders and SFC staff because it is rather unfortunately worded as though a decision has been reached despite a stated intention to consult.

I think it would be helpful to clarify our perspective on this point. I will copy this email to the AM and MP who have so far contacted me and to SFC staff in Wales who have written to you or their AM and/or their MP.

Your letters referred to the 'Net Benefits' and 'Bradley' reports which examined aspects of the management of fisheries in the UK as a basis for your decision in Wales. My understanding is that these reports were not designed to, and did not make specific recommendations for Wales. Regarding the future of SFC in England and Wales as a whole, these studies did not recommend abolition or centralisation of inshore fisheries management. I think a fair summary of the reports' findings is that SFC are a good model, but that they are now founded on out of date legislation and that, today, they have inadequate powers and resources to fulfill their role. The reports broadly recommended modernisation of SFC with strengthened powers, duties and resources in order that today's fisheries could be better managed and stronger regulations for the 21st century could be properly enforced. You will be aware that Mr. Bradshaw has now broadly accepted these recommendations and announced that English SFC will be modernised and strengthened through the proposed Marine Bill. 

The Association of SFC and each SFC separately made detailed submissions to these studies in 2003. The NWNWSFC and the SWSFC have agreed to update those submissions for your consultation and add any points which may be useful for the development of inshore fisheries management in Wales. We will make these submissions available to NAW as soon as possible.

Your letters then refer to contact with the two Welsh SFC in autumn 2005. My take on this is as follows. I recall what I took to be an informal phone call from a NAW official to inform me that NAW were now considering the matter of Welsh inshore fisheries management. I was asked if the information submitted for the Net Benefits and Bradley reports could still be regarded as relevant and I was invited to say if I wanted to add anything to those submissions. I declined this offer because I was not aware that I was being consulted on possible ministerial decision and I was not aware of the scope or context of the question. I do not consider that the ‘phone call could be regarded as giving me a prime opportunity to comment on the relevance of these two detailed and extensive research projects for Wales or that it would limit my future opportunity to provide full ministerial briefing.

Officials did give me notice of your press release although it had leaked earlier which resulted in some concern over the way the announcement was being handled. I and the Chairman were disappointed that you did not respond positively to the request from this Committee and the SWSFC in August, to brief you prior to the announcement being made. I think some of the subsequent concerns could have been avoided.

I am not aware that the NWNWSFC has been requested to give, or given you or your officials any advice in recent years regarding the future of SFC in Wales or the development of a new inshore fisheries management structure. The UK Minister based his decision regarding SFC in England on the research studies mentioned above and a number of others including the most authoritative advice of the Royal Commission on Environmental Pollution study in 2004 'Turning the Tide'. I am not aware of any research that recommends a centralized structure managed by Government directly for inshore fisheries management in Wales or elsewhere. If such studies or reports have been done, I would welcome the opportunity to comment on them and I suggest SFC should be invited to comment on the research which underpins such a major ministerial decision with extensive ramifications.

The Chairman of this Committee is most concerned that this Committee does have the opportunity to give you that advice before any further decisions are taken and has therefore as a first step, invited you to a detailed presentation of the work of the NWNWSFC. The Committee is really very concerned that you should understand as fully as possible the scope of the work carried out by the SFC, the value for money which SFC management provides, the extent to which SFC are valued by local fishing interests and the enormous implications of changing to a centrally managed structure.

I hope you will find this contribution to the debate helpful.

Yours sincerely,

Dr STEPHEN ATKINS 

Chief Executive