Monday, 23 November 2015

Sea Trust letter to Welsh Assembley...

Sea Trust as an organisation with over 12 years experience of monitoring Marine Mega-fauna in Welsh Waters and considerable knowledge of the situation regarding the  scallop fishery and the Bottlenose Dolphins Tursiops truncates which are one of the main candidates for protection within the Cardigan Bay Marine  SAC, would like to draw your attention to the following facts.
  1. The SAC  is a European designation set up under the Habitats and Species Directive. Scallop Dredging is acknowledged as one of the most damaging forms of fishing The Government has a duty to maintain and improve any such SAC's. To allow Scallop Fishing to continue in the SAC is totally in conflict with this designation.
  2. Scallop dredging has been banned in several other SAC's, it is inconceivable that The Welsh Government would consider allowing vessels that have been banned from dredging their own waters to do so here.
  3. There is evidence from reports commissioned by CCW/NRW that Bottlenose Dolphins are dispersing from the SAC and Scallop Dredging is named as a possible reason for this change in their habits. Under the "Precautionary Principle" as defined in the EU Habitats and Species Directive, Scalloping should be banned from the SAC and environmental  assessments should be carried out with the option of extending the SAC and the degree of protection within the SAC being considered.
  4. This year between June and November,  a pod of up 20 Bottlenose Dolphins took up residence in Fishguard Bay to the South of The Cardigan Bay  SAC. These included mothers with dependent calves. This is unprecedented in the 12 years we have been monitoring this area and may well be a sign that The dolphins are having to look further afield for prey due to the degradation of Cardigan Bay due to increase there of scalloping in the past ten years.
  5. The catch of scallops in Cardigan Bay either inside or outside the SAC  has clearly not been sustainable as evidenced by decreasing catch rates and falling numbers of boats travelling here to fish Cardigan Bay.
  6. The vast majority of the boats fishing Cardigan Bay are not local but arrive here mainly from the south coast of England and.Scotland consequently  little of the profit actually finds it way into the local economy. or indeed the Welsh economy.
  7. The penalties imposed on rogue fishermen who have made huge profits by flouting the law are derisory. Any boat found to be fishing outside of permitted areas should be banned and its gear seized. .

Therefore, taking all these facts into consideration and the Welsh Governments risk of finding itself in contravention of the  EU Habitats and Species directive, we would strongly recommend that the integrity of the  Cardigan Bay SAC be upheld  and that scallop dredging be prohibited within the SAC. and also that the SAC boundaries be
enlarged to cover Fishguard Bay..