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Opening Stance | Fisheries & Conservation Issues | Biodiversity Action Plan | How to Kill a 30lb Carp | Report Two

18th January 1999

PRESS RELEASE
ON OTTER PREDATION 

SACG are pleased to announce that broad agreement was reached between anglers and other conservationists on the subject of otter predation of specimen coarse fish (particularly still-water carp). The meeting took place at the headquarters of the Salmon & Trout Association, on the 27th of November. It comprised representatives from the Environment Agency, Wildlife Trusts, the Otter Trust, ACA, English Nature, MAFF, DETR, S & TA, Carp Society and SACG.

With water quality and bank-side habitat improving there is a resurgence of otters throughout the UK. This is mainly due to natural recolonisation from their Western and Northern strongholds, aided by the long term reintroduction programme of the Otter Trust, Vincent Wildlife Trust and English Nature. The increase in numbers, and return of these wonderful animals to their old haunts in the wild, will continue over the next decade or so, aided of course by their protection as a species under both EU and UK law, and continuing efforts to protect and improve river and wetland environments.

It is imperative however to take every possible step to avoid potential conflicts with anglers through otters making any major inroads into stocks of large, valuable fish. Whilst challenges remain on funding the protection needed by fisheries, those at the meeting were in full agreement on a common path and the way forward.

• Avoid conflict between anglers & conservation bodies.
• Encourage sustainable otter populations in the UK.
• Protection of large valuable fish, which are particularly vulnerable on still-waters.

• otters are a protected species under EU and UK law
• assuming Government targets are met otters will be fully established throughout all areas of the UK by the year 2010
• principal food sources of otters are eels and fish generally, but big carp and pike are also taken, as are chub and barbel etc.
• otters will locate any water even through tiny streams, so otters will find most fisheries
• on rivers with low fish stocks, restoration of the fish habitat will be needed in order to sustain otters without damage to the fishery
• on waters adversely affected by cormorants specimen fish are often the only remaining target
• otters have spread both through from reintroduction’s and recolonisation, although the reintroduction programme is now mostly complete

• The EA Guide on otter predation and still-water fisheries will be published in the Spring. SACG will fully endorse this document.
• Wildlife Trust Otter Officers to be trained to give practical advice to fisheries regarding the need or otherwise for protection from otters on their water. although it should be noted this will often involve the use of fencing.
• We aim to establish funding sources for fishery protection. To this end we will be looking to Government grants, Lottery funding, and Corporate Bodies currently funding otter projects, backed and supported by the Wildlife Trusts UK, to establish funding in order to avoid conflict between anglers and other conservationists.

For further information please contact:

Chris Burt Vice-Chairman SACG
3 Great Cob
Springfield
Chelmsford
Essex
CM1 6LA

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5th June 2000

• Introduction

• "OTTER ISSUES - SECTION A" a report from Paul Elsegood whose advice to SACG has given us a unique and valuable insight into many conservation issues, including parts of our "Code of Conduct for Specialist Coarse Anglers." Given his background I felt it helpful to advance his views in their entirety rather than amalgamate it with my own comments.

• Comments on your Press Release of 5th June 2000.

• "OTTER ISSUES - SECTION B" is some additional comment from myself on issues over and above those raised in section 1.

• Conclusions

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Response to SACG document
'Otters in the UK: Fisheries and Conservation Issues’

The Specialist Anglers' Conservation group paper 'Otters in the UK: Fisheries and Conservation Issues', identifies and repeats a number of issues concerning possible conflicts between otter conservation interests and stillwater fishery interests. Our views on these are given below, together with further information that clarifies the Steering Group's position.

1 Status of the otter and its conservation

We feel that a number of points made in the SACG paper are based on limited information about the aims and practice of otter conservation in the UK, and we seek to clarify this below.

1. 1 Otter ecology

The otter is a natural and legitimate part of any river ecosystem in the UK, and one of Britain's largest carnivores, The home range for an otter on any particular river system will depend on food availability, quality of habitat and social interaction with any neighbouring otters, and can range from 1 to over 40 km. A typical home range may include a river, side streams, ponds and adjacent woodlands and wetlands. The major component of the otter's diet is fish, with eels other slower-moving species naturally preferred.

Evidence shows that there are many areas where otters and mink coexist, and also areas that otters have recolonised where mink are present. There is some suggestion, yet to be scientifically proven, that mink numbers decline when otters are present. Otherwise few conflicts between the otter and other native species have been identified. A healthy, self- sustaining fishery as part of the natural ecosystem should also be able to support otters, which are relatively low in number as they are the top predator in the food web.

Measures were, taken to halt the decline, of the otter, such as banning of otter hunting and most organochlorine pesticides, and affording the otter high levels of legal protection (see below). Factors continuing to limit otter recovery may include low food supply, lack of suitable habitat, disturbance, road deaths and continued pollution.

The UK's otter population is internationally important, since otters have declined across much of the western European range, The otter has been given full legal protection throughout England and Wales since 1978, in Scotland since 1982 and in Northern Ireland since 1985. It is an offence under the wildlife and Countryside Act to intentionally kill, injure or take an otter from the wild without a licence; to damage or obstruct a holt; or disturb an otter in its resting place. Licences are required for checking holts or for carrying out work that may disturb otters, such as the management of trees that are known to be resting sites. The statutory nature conservation agencies (EN, CCW, SNH and EHSNI) are responsible for issuing these licences. The Conservation Regulations 1994 give broadly parallel protection to the species, but extend the protection so that it is an offence, to deliberately disturb an otter whether it is in a holt or not.

Relatively strong otter populations are now known to occur in Scotland, Northern Ireland, most of Wales, and South-West England, 78% of riparian sites in England were still without otters in 1994, the last date for which we have comprehensive information. Since 1994, local studies have indicated that numbers in England are rising steadily, and that the otter population continues to expand into new areas where it can be supported by good river and wetland habitat. The next National Otter Survey of England is currently underway, and we hope to have a new 'snapshot' of otter distribution in this area by June 2001.

In the past, The Otter Trust and others have released a number of captive-bred otters into English rivers in an attempt to boost populations, mainly in eastern England. The Otter Trusts work on otter releases in East Anglia during the 1980s and 1990s almost certainly prevented the otter from becoming extinct here and provides the basis for recovery in this area.

However, otters are now present in low numbers on the vast majority of rivers in the UK, and are expanding successfully from wild populations, dependent on the conditions available to support them. The Otter Biodiversity Action Plan Steering Group agreed in 1999 that no further release of captive-bred otters is appropriate in the UK. It is our understanding that The Otter Trust have now finished their release program for otter releases in the UK and have no plans for further otter releases in the UK.

However, it is currently within the law to release captive-bred otters into the wild. The UK Otter BAP Group have identified the need to review this legislation in favour of more control over the activity. We are aware that JNCC have indicated to DETR a conservation case for greater control over the release of native species.

1.4 The Otter Biodiversity Action Plan

The Otter Biodiversity Action Plan (BAP) is part of the UK Biodiversity Action Plan, resulting from commitments made by Government under the Convention on Biological Diversity at the Rio Earth Summit in 1992. The, UK BAP outlines the actions needed to sustain and enhance the 'UK's biodiversity, it is based on partnership and co-ordination between those who advocate the sustainable, management of wildlife and wild landscapes, and those whose remit gives them the power to achieve that management.

The UK Otter Biodiversity Action Plan (BAP) Steering Group has the task of promoting and encouraging actions against the UK Otter BAP, directing resources, overseeing implementation and reporting on progress to Government. Current membership of the group reflects a wide spectrum of partners working towards otter conservation as follows:

Countryside Council for Wales
English Nature
Environment Agency
Environmental Heritage, Service, Northern Ireland
Joint Nature Conservation Committee
Scottish Natural Heritage
Scottish Environmental Protection Agency
The Wildlife Trusts
Water UK

The Wildlife Trusts and the Environment Agenecy are joint lead partners driving the otter Biodiversity Action Plan. Water UK are ‘champions' of the plan, contributing major resources towards meeting the BAP target. We liaise closely with a number of other land use sectors whose work involves otter-related issues, including the fishing sector.

The BAP objectives for otters are as follows:

to maintain and expand existing otter populations;

by 2010, restore breeding otters to all catchments and coastal areas where they have been recorded since 1960.

A number of organisations are working actively towards achieving the ambitious Otter BAP objectives above. All work towards improving conditions and reducing threats to otters, to encourage natural recolonisation of rivers from existing populations. Two major areas of work are outlined below.

The Water UK and The Wildlife Trusts' Otters and Rivers Project (OARP) is a network of conservation officers and volunteers based at Wildlife Trusts across England and Wales, working to improve wildlife habitats associated with rivers, and hence encourage the return of a healthy otter population. The project is supported by Water UK at the national level, and by water companies, the Environment Agency and other commercial sponsors at regional level.

OARP is delivering much of the otter BAP through an ambitious work programme of action 'on the ground'. This includes surveying, practical conservation work, advising and working with landowners and river managers (including the fishing sector) and campaigning locally and nationally on issues affecting otters, rivers and wetlands.

The Environment Agency has statutory duties in relation to pollution control, waste management, water resources, flood defence, fisheries, recreation, conservation and navigation. It is required to use its powers to contribute to the Government's objectives of achieving sustainable development, One of its nine key environmental themes is ‘enhancing biodiversity'. Achieving this for rivers includes promoting good habitat management, improving air and water quality, encouraging the wise use of water and advising on developments sensitive to wildlife. The overall improvement of the aquatic environment will be critical in supporting otter populations into the future.

The restoration of the the native otter population to its original state across the UK is a Government-endorsed target as part of the Biodiversity Action Plan process. Conservation work to achieve this target is undertaken in partnership with a wide range of interests and land users, including fishing interests.

The UK Otter BAP Group agree that stricter legislation is needed to control the release of captive-bred otters on rivers in the UK.

2 The impact of otters on fisheries

2.1 Otter conservation and fishing interests

In the course of otter conservation work, conservation bodies often work closely with fishing clubs and river restoration schemes initiated by fishing interests. As interest groups, we also have a great deal to learn from each other. In a large number of cases we share common goals: to improve the quality of the river ecosystem, encouraging self-sustaining and diverse populations of native fish and other wildlife. Such a system would be able to support otters, as it would support other natural predators.

In the majority of cases until recently, we have perceived little conflict and much support between fishing interests and otter conservation interests, except where intensive management of a fishery for a particular species has left little room for wildlife.

However, recently there has been increasing concern about the impact of otter predation on stillwater fisheries (particularly artificially-stocked ones) and fish farms. Such land uses have arisen while otter numbers were low, and as otters naturally recolonise their old haunts they can be, perceived as a ‘new' predator by fishery owners, not as a natural part of the ecosystem.

In particular, large valuable carp-stocked ponds, gravel pits and lakes represent easy sources of food for otters, particularly when their natural food stocks (eels, coarse fish) are low or difficult to obtain. Incidences of predation by otters tend to increase during the winter months for this reason. The risk of otter predation also increases if fisheries are situated near wetland habitats or if breeding females are present. However, we have, no evidence to suggest that incidences of predation at stillwater fisheries will artificially increase the carrying capacity of any river catchment for otters in the longer term.

As the otter population increases through natural recolonisation of rivers, (not through reintroduction), predation at stillwater fisheries looks set to continue.

Together with a number of fishermen and fishery owners and other otter specialists, the Otters and Rivers Project have recently researched the subject of otter predation, how big a problem it is and positive solutions to prevent fish losses. A considerable amount of effort has been put into training and information on otter predation, so that we can provide a specialist advisory network for fishery owners across the country should the problem arise.

Although (as with many things in nature) there appear to be no hard and fast rules, permanent specially-designed fencing is a solution to otter predation, which has been shown to work. In the majority of cases this fencing should include electric wires to ensure successful exclusion of the otter. Other measures included 'decoy ponds' stocked with low-value fish, which have also worked to deter the otters from valuable fish in some cases.

It is essential that advice is available on the risk of otter predation when deciding where new fisheries should be sited. OARP and Environment Agency fisheries departments are working closely to ‘spread the word' on these issues.

Over the last winter (October 1999 - March 2000), OARP has tried to establish some idea of the current scale of conflict between otter conservation and stillwater fishery owners. Over 70 sites have been visited as a result of requests for advice on possible otter predation during this period. Where otter predation was found to be occurring, OARP have achieved considerable success in excluding otters from many fisheries, and have also found that many fishery owners are delighted that otters are present at their site!

Following a constructive meeting between angling groups and conservation groups on the issue in November 1998, EA have also produced a leaflet for fishery owners outlining the issues and solutions to the problem. Over the coming year OARP and the Environment Agency aim to continue working in an advisory capacity to minimise the potential for conflict between otters and fisheries. We consider this a positive measure to help avoid conflict between fishing and conservation interests.

The UK Otter BAP group recognises that there is a conflict where otter predation causes financial losses from specimen carp fisheries and fish farms. Solutions have been researched and successful advice given to a number of fishery owners, and we would support the continuation of this work as a positive step towards resolving conflicts.

3 Commercial and fishery considerations

Specially designed fencing, correctly installed, is the major option available to exclude otters from fisheries where they are causing problems, and a viable option in the majority of cases. We consider that it is the responsibility of the fishery owner to protect their fishery with fencing if this is possible, as they would protect their stocks from other natural predators within the law. We also consider that fencing would make sound financial sense, if individual fish being lost are worth thousands of pounds each. If action is taken quickly, or even in anticipation of the problem, then the loss to stillwater fisheries from otter predation can be minimised.

Conservation charities such as The Wildlife Trusts, or their associated projects, are not able to provide financial support for capital works such as fencing to protect commercial interests against impacts from wildlife. Funding would also not be available for this purpose from conservation budgets of the Environment Agency. However, it should be noted that The Wildlife Trusts, Water UK and the Environment Agency are putting resources into advisory work and research on the topic, which we hope will help to resolve conflicts and protect the wildlife in question.

We consider that if there is a possible source of funding to fence commercial fisheries against otter predation, it could be from MAFF. The UK Otter BAP group would be pleased to offer assistance in seeking sources of funding.

conservation bodies are not able to pay for fencing fisheries against commercial losses incurred through otter predation; we consider that this is the responsibility of the fishery owner. However we are happy to help with sourcing other funding for fencing, and offering our support, where appropriate.

At the meeting between fishing bodies and ‘otter interests' in November 1998, it was agreed that the idea of live trapping and moving otters to immediately prevent predation in particular cases was not a viable option. Despite this, SACG appear to continue viewing this idea as a potential solution.

Within the, Wildlife and Countryside Act, MAFF have the power to grant licences to allow otherwise prohibited acts for the purpose of preventing serious damage to fisheries. There is a requirement for MAFF to consult with the conservation agencies before any such licence could be granted.

The UK Otter BAP Group does not consider this measure appropriate for otters, for a number of reasons:

Otters can travel great distances in a short time, and it is likely that this measure would be ineffective in removing the otter for long enough to erect a fence.

Trapping and moving one otter into the territory of another would cause problems within the population, cause stress to the individual in question, and would not be good conservation practice.

Even if successful, such action would he transferring the predation problem elsewhere. Other fishery interests would not be likely to welcome additional predators being artificially introduced.

Promoting the idea of trapping and moving a protected species for such a purpose would set an unacceptable precedent.

This cannot be regarded as a sustainable option to resolve any predation problems.

The UK Otter BAP Group would not support the issuing of 'licences for trapping and moving otters from a fishery, as a measure to prevent predation.

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SACG Response Press Release

HOW TO KILL A 30LB CARP
17th July 2000

We as anglers are peculiar creatures. A title like this gets you all fired up and guarantees you read it, correct? Yet talk about our warnings of the last 20 months that your carp as well as other specimen fish are at risk of being killed by otters and the eyes glaze over. Most of you who attended the last three Carp Society Conferences for instance will have walked by our stand only glancing at all the carp deaths/otter material saying no, it can’t happen to me...... Okay fine, but try the same line now on the Carp Societies Horseshoe Lake members, given the recent fish kills by otters and of course the problem is recognised. Still doesn’t mean it can happen to your carp though, right?

WRONG!

When looking at the distribution map of otters in the UK, as shown on the Environment Agency leaflet relating to otter predation, we are shown where otters were not present in significant numbers, as of 1998. This includes the areas of the Colne Valley, Lea Valley, Oxfordshire lakes such as Orchid, Essex lakes, the list is endless.

By 2010 the EU objective is every last one of these areas will have its full complement of otters. £1.5 million has been given to help ensure it happens. Just think on that for a moment, £1.5 million tax money from various sources to ensure otters are fully re-established on every river system in the UK, and it will then be a lottery which lakes are found by otters, and when and how many of your fish are killed.

So what can you do to avoid this? The only sure protection is to put up a specially designed fence round each and every fishery, at a cost in raw materials alone of circa £700 an acre. So Horseshoe members for instance need to find £56,000!!

SACG stance from the start has been that I believed through education and dialogue with the conservation movement we would eventually convince them that the demands of natural justice meant our pleas for money to be made available to help protect fisheries against the otters they have re-established, would be met. I was wrong. To quote;

In other words, they won’t (can’t) pay; their view is that if your fish are valuable it is up to you to find the money because they won’t.

This whole issue now needs far more help and involvement from outside SACG, it is too big, too important, and too costly to you the angler for us to handle alone. I would welcome contributions from anyone who feels they can help, (David Mannall of the Carp Society has already been of considerable help).

Anyone with views to give, or willing to help, please contact me. They are your fish!

For full details of the reports submitted by SACG and the reply from the Otter Biodiversity Action Plan Steering Group, see our web site http://www.anglersnet.co.uk/saa/index.htm

Chris Burt, SACG 3 Great Cob, Springfield, Chelmsford CM1 6LA

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17th July 2000

From: Chris Burt, SACG. Paul Elsegood, SACG.

To: UK OTTER BIODIVERSITY ACTION PLAN STEERING GROUP, Including the Water UK and the Wildlife Trusts Otters and Rivers Project

We have now considered your response on behalf of the Otter BAPS Group to our report of the 7th of June. I have to say it falls far short of both the needs of the situation and our expectations.

We would appreciate clarification on some aspects but would add we have major reservations about the current situation, which will be evident from the following points.

1) Your report does not refer at all to our concerns that the main preventative measure you suggest, fencing, also excludes many other animals and birds.

1. I repeat, have the RSPB been consulted on this, and do they endorse your views? Do you also agree it is acceptable to exclude other wildlife?

2. Has a proper study been conducted on otter predation of other wildlife such as birds, molluscs etc. particularly when no fish are available through unsuitable habitat? (See "Otter Damage", Gloucestershire Standard, article attached).

2) Your Group, and I quote,

"agreed in 1999 that no further release of captive bred otters is appropriate in the UK".

Could you please advise;

1. When in 1999 was your view reached.

2. Were your views communicated to other bodies such as the Otter Trust, what were the responses, and are all such groups in agreement with your views?

3. It has been suggested that 17 otters were introduced in 1999 to the Cotswold Water Park; do you have information on the dates, numbers, and locations of all such introductions since early 1998, the year prior to when your present view was formed, and can you advise the names of the organisations responsible for these from 1998 onwards.

4. Do all the groups identified in c) above work harmoniously and in agreement with yourselves?

5. We would like to take this opportunity to restate that we wholeheartedly endorse any campaign which had improved the river ecosystem to the degree where otters, as one of the UK’s largest carnivores, were naturally recolonising this environment and would recognise that if this were the case, they would form a sustainable part of the natural balance. Our concern is that captive bred otters have formed the basis for this recolonisation and are relying on our managed still water fisheries as a food source rather than the river ecosystem which have not been sufficiently improved and cannot sustain them.

6. We are unaware of any reintroduction programmes whether they be for plants, birds, animals or any other living creature which do not work on the premise that the environment has to be put right first. Indeed it is bringing the environment back up to standard that makes the scheme worthwhile in the first place, as reintroduction’s without the means for them to be self sustaining is meaningless.

3) Our original observation with regard to mink seems to have been dismissed but we would ask that whilst this creature is not part of your remit, its presence as a carnivore which must compete with otters will have a significant impact on the prey stock that both animals rely on. Its exclusion should have been part of the otter reintroduction programme and the issue needs to be raised with MAFF who seem to have given up on its control. If there is evidence that otters successfully displace mink we would welcome seeing details of it.

4) You have my admiration (and envy!) for the degree of EU and UK status and protection you have secured for the otter, plus of course enormous financial backing. Given what you have achieved I believe I too would be most reluctant to offer any major concessions on anything which ran contrary to my interests. Your response however takes no account of the following;

1. Legal protection applies both ways; you cite the EA involvement in the otter project, but they also have a statutory duty to "maintain, improve and develop fisheries".

2. Natural justice; it should not be possible to blithely demand fishing interests find literally millions of pounds for protective fencing to prevent otters eating fish stocks.

3. Common sense demands that before the return of otters to a specific area, (whether captive bred otters, natural recolonisation from modifying habitat, or enhanced legal protection), a proper study of their impact should have been carried out, this is patently not the case or the full financial implications and need for fencing would have been recognised and highlighted back in the early 90’s before your programme was initiated.

4. Funding for your project should have gone hand in hand with a proper understanding of the implications for fisheries, how conflict could be avoided, where the necessary funding was to come from, and not retrospectively as we are now doing.

5. Financing from whatever source you deem viable must be found for fisheries protection if conflict is to be avoided, it is not right that the otter interests ride rough-shod across anglers fisheries.

6. The habitats of rivers need to be properly studied and only those that meet the correct criteria should be considered for otter habitat. It is not acceptable for the fish stocks, nesting birds and the overall riverine habitat generally for its wildlife to be exposed to additional predation from otters, or indeed right for the otters themselves to be encouraged into a habitat which cannot sustain them.

5) Trapping and moving otters.

SACG did reluctantly agree that trapping was considered impractical and potentially ineffective, at the time of our meeting in November 1998. No practical alternative to this emerged however for emergency protection when a fishery which had not installed fencing was faced with severe predation. This is especially relevant since to date no source for financing the protective fencing has emerged, which would avoid the need for any such emergency measures; this was also of course an objective from the same meeting.

6) Separately from your group report I have been advised that "public support for angling will not be maintained or increased if they perceive an anti-otter bias". This offers you the most effective cop-out imaginable of your groups responsibilities, a comprehensive cover-all to hide behind. This is not constructive and it is not acceptable to use as a screen, the publics perception of otters as "warm, cuddly feel-good" animals. A few examples of the corollary to this would include;

1. Possible comments on the adverse effect of otters from the highly funded and vocal bird lobby.

2. Pictures of damage on large fish, carried against comments asking should their local 20 man angling club be expected find £60,000 to protect against this, otters killing the last of the naturally grown big fish in their lake.

3. Public comments such as the Gloucestershire Standard/Daily Telegraph fish farmer/articles likening otters to riverine fox killers etc.

4. Potentially adverse publicity resulting from closure of otter hit fisheries.

Your confirmation would be welcomed that these individuals comments, containing the threat of losing public support unless we fall into line, form no part of your strategy in dealing with anglers.

7) Your report continues to give considerable emphasis to the problem relating to "artificially stocked fisheries", "commercial interests", and "intensive management" of a fishery. You seek to devalue the natural status of our fisheries and attempt to establish the carp themselves as predominantly a commercial concern.

Exactly the same arguments can be used against otters too;

a) Look at how many otters are "artificially stocked".

2. "Commercial interests", do companies invest in your project for altruistic reasons then, or to help negate their own negative impact on the environment, plus of course for publicity purposes to promote their companies.

1. "Intensive management", your whole scheme comes under that same heading, with far more resource than we can ever lay claim to.

So could you please understand that as explained in our report of 7th June page 9 item 3

""Highly stocked fisheries......"

We are accepting many of our fisheries are managed, but then what part of the habitat within a largely urban England is not? Our fisheries are managed in exactly the same way that the RSPB manage their Nature Reserves, and although the natural river ecosystem itself can largely only be brought back to a standard rather than managed, our fisheries must have a perfectly balanced ecosystem to be what they are. As such they are of tremendous value as habitats for the full range of flora and fauna.

Your comments on "artificially stocked fisheries" should more correctly refer to waters with an artificially high stocking level of sometimes 2000lb an acre, (which are not strictly part of our remit). For you to belittle our sometimes managed, sometimes entirely natural fisheries which contain sustainable populations of big fish as though they were some casually stocked fish dump is completely unacceptable. I can show you pictures of carp which were stocked as fingerlings in 1939 which featured in angling books since the early 50’s when they had grown of their own accord to 20 or more pounds, which are alive today and form part of angling folklore, and to dismissively refer to these as "artificial fisheries" which can be either sacrificed to the re-emerging otter or suffer the need for £50,000 worth of protective fencing is untenable. At a guess 90% plus of the fisheries we want to protect are not commercial and we see little justification for destroying the enjoyment of tens of thousands of anglers who cannot possible afford the sums you are casually demanding we fund, simply because of the ill considered planning for the reintroduction of this top predator. Even the "commercial fisheries" in this country are in many instances low key concerns realising a very low income, who would be driven to bankruptcy by either fencing costs or the loss of their fish stocks.

I would strongly suggest that if the concepts I am propounding here are too much for the group to accept at face value then I will ask the Carp Society to organise a tour of waters in say the Colne Valley or the Lea Valley, to substantiate my comments. I am sorry to argue this point so passionately but I do not believe the Otter BAPS Group either perceive or want to acknowledge the scale and true nature of the problems that face us.

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