2.3 Currently ‘black fish’ is an emotive issue for both the true commercial and recreational fisherman, and it is those that fish illegally who seek to exploit the loopholes in legislation. At a time when the draft Marine Bill and plans for nSFCs are both seeking to more fully inform and therefore integrate the commercial and recreational sectors, I believe such discussions should be grounded on a more even handed application of fishing restrictions. I see no reason why one sector should be allowed to legally remove immature fish, whilst another sector is prohibited from doing so.

2.4 At the April meeting of the Scientific and Byelaws Sub-Committee, Members directed Officers to draft an amended Byelaw 19 which would incorporate most of the species listed in the European legislation. Officers accept that some of the European MLS need modification in order to achieve true conservation status, but advised Members that any changes would require extensive and time consuming consultation with all stakeholders. By maintaining the ‘status quo’, an amended Byelaw could be expedited, and would provide a benchmark for future discussion on the merits of increasing the MLS of some species.

2.5 Additionally, Members suggested that an MLS for Skate and Ray should also be included. Officers suggested that the MLS should mirror those in adjacent Districts

2.6 Officers expect very few, if any, objections to the proposed Byelaw (Annex B), as most recreational sea anglers already respect a landing size often of a larger than minimum size. Any objections would likely come from those intent on illegal fishing or those seeking to exploit legal loopholes.

2.7 A clearly stated Byelaw applicable to all fishermen would undoubtedly ease tensions between sectors, remove uncertainty in enforcement capability, and show that SFCs can be a lead partner in proactive fisheries management.