Review of Welsh Fisheries Enforcement Activities

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Report produced for Welsh Assembly Government, April 2007

Enforcement Review Report

Contents

Executive Summary

Part 1
1.0 Introduction
2.0 Background
3.0 Review Process

Part 2
4.0 Stakeholders Concerns

Part 3
5.0 Sources of Funding
6.0 Delivery of Fisheries Work
7.0 Activities of Enforcement Teams
8.0 Monitoring/ Measuring / Recording
9.0 Estimating Level of Illegal Activity
10.0 Customer Communications

Part 4
11.0 Proposed solutions
12.0 Funding Future Work
13.0 Conclusion
14.0 Appendices

Appx A – Inland Fisheries Stakeholder Report Recommendations
Appx B - Outputs from External Workshops
Appx C – Output from Internal Workshop
Appx D – Key Performance Indicators
Appx E – Illegal Exploitation Estimates
Appx F – Tables of Recommended Actions – Ordered by Theme
Appx G – Tables of Recommended Actions – Ordered by Cost and Timescale
Appex H – Other on-going reviews

Acronyms Used in Report
AEP - Area Enforcement Plan
BRITE – Better Regulation Improving the Environment
CEFAS – Centre for Environment, Fisheries and Aquaculture Science
CICS – Common Incident Classification Scheme
EA – Environment Agency
ECT – Environment Crime Team (aka Special Enforcement)
EM – Environment Management
EU – European Union
FERAC – Fisheries, Ecology, Recreation Advisory Committee
FTE - Full Time Equivalent (= 1 person for 1 year)
GIA – Grant in Aid
HIFE – High Impact Fisheries Enforcement
ICES – International Council for the Exploration of the Seas
IFSG – Inland Fisheries Stakeholder Group
ILE – Intelligence Led Enforcement
KPI – Key Performance Indicator
NIRS – National Incident Recording System
NRA – National Rivers Authority
RCC – Regional Control Centre
SAFFA – Salmon and Freshwater Fisheries Act, 1975
SFP - Sustainable Fisheries Programme
WAG – Welsh Assembly Government

Executive Summary
Background

Following instruction from the Welsh Assembly Government, we have reviewed and reported on our existing fisheries enforcement activities and organisational structures. We have also sought the views of our customers on how they would like us to improve our current fisheries enforcement provision.

Fisheries enforcement receives the greatest proportion of our fisheries funding with 45% (£1.33m) of our operational budget allocated to High Impact Fisheries Enforcement and rod and net licence checking.

This Review has provided the opportunity to share good practice across Wales, develop new ideas and identify areas for improvement in our existing enforcement work. It has also provided an opportunity to rectify some perceptions regarding our work, for example, that we are a ‘blue-light’ service able to respond 24 hours-a-day, 365 days a year or that the Fisheries Function is financing waste enforcement work – both of which are inaccurate.

Key Findings

Following the receipt of nearly 1000 comments from external stakeholders and our own staff, we have been able to identify over 80 possible improvement actions. Many of these actions will not require additional resource in order to implement, although phased introduction will be necessary.

Several actions have already been implemented, including: a change in the Agency policy in relation to fish theft; a review of the Regional Control Centres which will result in the retention of a
dedicated centre for Wales; provision of a Fisheries Standby Officer in N.Wales. Our communication with customers has also improved through Area Newsletters – although there is still
more to be done in this important area of work.

Based upon current levels of funding provided by the Assembly we have identified and costed actions to deliver improvements to our enforcement service. These actions include the provision of
an Intelligence Database, improved radio communication systems, training schemes for a new network of volunteer ‘ River Watchers’ and increased staff numbers (both full and part-time). The total cost if all actions are implemented would be £944k with a minimum of £490k required annually thereafter to cover salary and other costs.

However, before significant additional investment is made, we believe that further research is required in order to quantify the level of illegal fishing. We estimate, for the first time, the illegal
capture of salmon and sea trout in Wales to be 2.29 and 2.76 tonnes respectively. The assumptions used to calculate these figures require further testing and their accuracy may need to be improved but they do provide our enforcement teams with a new target against which their future effectiveness could be measured.

The following table provides a brief summary of the possible areas for improvement identified and estimated costs of implementation.



Future Actions

We therefore recommend that the next steps to delivery should be :

(i) Deliver some low cost actions, within our existing budgets that will bring about increased protection for our fisheries and an improved service to our customers.

(ii) Produce an initial Fisheries Enforcement Strategy for Wales supported by customers and partner organisations. This will consider :

• Current level of illegal activity ?
• How best to combat this threat ?
• The approach taken by other enforcement agencies and their lessons learnt.
• How future levels of activity may change and proposals to pre-empt such changes ?
• How much resource is required and how this is best deployed ?

(iii) Produce a Fisheries Communications Strategy to improve our communications with the public and partner organisations.
(iv) Research and develop agreed techniques for quantifying illegal activity to give a true indication of the level of illegal fishing activity.
(v) In light of the results from (iv) above re-evaluate our Enforcement and Communications
Strategies.
(vi) Seek necessary funding and bid for additional funds from WAG at the appropriate time.

This will require wider debate about the level of resource allocation for enforcement work in relation to other areas of fisheries work.

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INTRODUCTION, BACKGROUND AND REVIEW PROCESS

1.0 Introduction

Environment Agency Wales was instructed by Welsh Assembly Government (WAG) to provide a review of current fishery enforcement organisation and activities and proposals to address
perceived stakeholder concerns.

This report provides the background to fisheries enforcement in Wales and identifies the key concerns of our stakeholders. We have explored potential solutions to address these concerns and to ensure our fish stocks are protected and illegal exploitation deterred. Some solutions can be implemented immediately, others will require further evaluation and funding.

1.1 Vision
We want to provide an efficient and effective enforcement service which prevents illegal exploitation of our fish stocks, meets customers expectations and which our staff are proud to
deliver.

1.2 Outcomes we want to achieve :
We will work towards the following outcomes :
• We want protected fisheries and satisfied customers confident in our actions.
• Recognition of the important role that fisheries enforcement plays in fulfilling our statutory duty to maintain, improve and develop fisheries.

To achieve these we need to ensure that:
• The illegal capture of fish in Welsh waters is reduced thus maximising the social, environmental and economic benefits of fish stocks in Wales.

• Fish suppliers/sellers deal only in legally caught fish.

• There is greater awareness of the effectiveness and capabilities of our enforcement teams within our communities.

• We maintain our safe-working, highly skilled and committed workforce.

• Individuals and communities join forces to report illegal fishing activity.

1.3 Timing of Review
The timing of the Review is particularly opportune. We are reporting at a time when we expect to see increased numbers of salmon returning to Welsh rivers following the cessation of the
interceptory Irish Drift Net Fishery. This closure may not only increase the number of returning adult salmon, it may lead to a shortage of wild salmon in the market place and premium prices for those available. This may therefore lead to an increase in demand for wild Welsh salmon.

This Review report will also coincide with the production of WAG’s Fisheries Strategy for Wales that will cover both marine and freshwater fisheries.

2.0 Background
Wales has had a reputation of being a leader with regard to fisheries enforcement techniques pioneering many of the methods currently employed across all Environment Agency (EA) regions.

This reputation seems to have decreased in recent years for a variety of reasons including :
• A reduction in the number of high profile poaching cases,

• Reductions in numbers of enforcement staff,

• Fisheries Enforcement, being overshadowed by other high profile projects such as ‘Fishing Wales’.

• Reporting systems and service levels that do not meet with customers expectations.

• A reduced public profile of the Fisheries Enforcement teams.

• Recent organisational changes within the EA have resulted in the integration of Fisheriesservices within other teams. This had reduced the visibility of the Fisheries Function.

Reviews of Fisheries Enforcement by Environment Agency Wales have taken place every four or five years. In the past, these have been driven by the need to save costs as a consequence of
reducing Grant in Aid (GIA) from Government or significant organisational change (eg. Privatisation of water industry in 1989). Cost cutting is not the basis of this review.



Following the BRITE initiative in 2002, a review of all Fisheries Enforcement work was undertaken. In keeping with the principles of BRITE, the High Impact Fisheries Enforcement
(HIFE) Review aimed to provide a consistent approach to our enforcement work across England and Wales ensuring staff were trained, equipped and competent to the same minimum standards.

The HIFE review introduced a two-tier warrant system with the highest level ‘full’ warrant only being awarded upon completion of a specific training programme which included proven fitness
and competency.

3.0 Review Process

The delivery of this Review has involved :
(a) the establishment of an Enforcement Review Group comprising of staff at across all levels within the organisation and in particular from all parts of Wales, including Upper Severn.

(b) talking to external customers and internal staff in order to gain their opinions on what is working and what isn’t with regard to our enforcement work. Importantly, this consultation aimed to seek new ideas from practitioners and those affected by illegal fishing activity.

(c) noting the concerns raised in written correspondence (letters, emails) and in the media relating to enforcement issues.

3.1 External Engagement

In order to clarify customer concerns, a series of six external workshops were held using independent facilitators, The Environment Council, during November 2006.

The purpose of these workshops was to :

• Ensure Inland Fisheries Stakeholder Group (IFSG) recommendations (Appendix A) are complete and, if not, to identify what was missing.

• Identify measures that will address the recommendations of the IFSG.

• Ask how attendees can assist in protecting fish stocks. 130 people attended (excluding Agency staff) representing clubs, riparian owners, fishery businesses and other organisations (eg police ).

3.2 Internal Engagement

In addition to discussion within the Enforcement Review Group meetings and at team meetings of operational enforcement staff in the Areas, a one-day workshop was held with all Fisheries
Enforcement staff.

This event was used to :

• raise greater awareness of the views of the IFSG and customers

• give staff the opportunity to put forward their views on our current enforcement service

• seek appropriate solutions to the issues raised through an Action Planning exercise.

As a result of the internal workshop three Environmental Crime Officers were co-opted onto the Review Group to assist in its deliberations.

3.3 Progress Reports
Feedback, on each of the workshops, was provided in reports produced by The Environment Council. Final reports collating the responses received at all six external workshops were produced
and are included in Appendix B.

Local Fisheries Groups, Fisheries, Ecology, Recreation Advisory Committee (FERAC) and the Agency’s Management Team Wales have been provided with progress reports. An update on progress with the Review was provided to four Local Fisheries Groups in January 2007 with the remaining groups receiving feedback in May 2007.

3.4 Final Report
The purpose of this report is two-fold.

Firstly it aims to present the results of our stakeholder engagement and internal deliberations and identify potential solutions that will address the concerns and issues raised.
Secondly, the report also aims to provide answers to some of the questions raised regarding the provision of our fisheries enforcement service particularly in relation to the allocation of resources, organisational structures and activities undertaken.

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IDENTIFYING STAKEHOLDERS CONCERNS


4.0 Stakeholders Concerns

4.1 External Areas of Concern

Prior to the commencement of this Review, the Inland Fisheries Stakeholder Group (IFSG), formed by WAG, reported that:

“No single issue has caused so much hostility towards the EA as the apparent lack of an adequate force of full-time fishery bailiffs engaged on active front-line enforcement work to combat illegal fishing in rivers, estuaries and coastal waters.”

Concerns raised by the IFSG are shown below in Table 1. The full text can be found in Appendix A.

Six external workshops were held in November 2006 and the 130 attendees were invited to review the recommendations of the IFSG and identify any further issues. Additional recommendations
have been appended to Table 1.

Table 1: Inland Fisheries Stakeholder Group Enforcement Comments plus additional stakeholder concerns.


In addition to the high level issues raised above, the stakeholders attending the workshops provided over 800 comments regarding the current enforcement service provision and ways in which they felt it could be improved. Copies of the workshop outputs can be found in Appendix B.

4.2 Internal Areas of Concern
In addition to the external workshops, our own Fisheries Enforcement staff attended a workshop so that they too could express their views.

These views and suggested actions can be found in full in Appendix C.

The results of the internal workshop concur to a large degree with those raised by our external customers. Additional concerns were raised including :

• Loss of tools of the job (eg dogs).
• Succession planning within the Fisheries Function.
• Potential threat to jobs by use of volunteers.
• Internal communications.
• Fragmented management of the staff resource in Areas.

4.3 Analysis of Comments
Grouping of the comments received both internally and externally resulted in particular topics on which the Review Group were able to focus. These topic areas cut across the IFSG and Stakeholder
recommendations and include :

Incident Reporting
Intelligence Gathering
Communications
Measuring our effectiveness
Volunteers
Full time Staff Numbers
Monitor, Measure and Report back
Health and safety
Joint Working
Equipment and Technology
Constraints

Our recommended actions will fall under the 11 headings above and will be cross-referenced to the IFSG and stakeholder concerns.

In addition to the many comments received in relation to our operational delivery, prior to, during, and since the workshops many observations were made with regard to the behaviours that are expected of the Agency.

In order to maintain our customer’s confidence we must :

(1) open and honest in our discussions and presentation of information;

(2) consistent in our messages and standards of customer service;

(3) more visible to our customers at all levels of the organisation;

(4) able to demonstrate our effectiveness at tackling illegal enforcement.

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CURRENT RESOURCES, STRUCTURE AND ACTIVITIES.

5.0 Source of Fisheries Funding

The mandatory work of the Fisheries function is funded by
• Rod and net licence revenue,
• Government GIA
• Ad-hoc income from other charges.

In Wales, additional funding is obtained from external sources such as European Union Objective 1 and 2 funds – this is used to fund discretionary work largely consisting of environmental
improvements.

The chart below gives an illustration of the various funding streams into Environment Agency Wales.



A key point to note is that migratory fish rod licence income represents a relatively small proportion of our income and we therefore are reliant upon core Grant in Aid in order to deliver our
enforcement work.

The funding for the Sustainable Fisheries Programme is provided by WAG and used to fund our Angling Participation work together with fishery improvement schemes.

The External funding comprises money from the EU Structural Funds together with additional match funding from WAG (additional to the £800k SFP funding they provide). This money can only be used on specific improvement projects and is not available for enforcement work. Such funding will only be available for a limited period but has so far enabled improvements to be made to over 600km of Welsh rivers.

Our current policy is that income from coarse and trout anglers will not be used to subsidise our work on migratory salmonid fisheries – where most of our enforcement effort is focused. Licence income, from rods and nets, is used to fund services of direct benefit to each group. Given that migratory rod licence income is relatively low (approx. £350k per annum in Wales), we are reliant upon GIA to fund the enforcement service, work undertaken for the wider public good.

5.1 Resource Allocation To Regions

The Fisheries Function receives approximately 4% of the EA operational budget.

Planned Agency Functional Expenditure (2007/8)


The operational budget, across all Agency Functions, comprises of 59% Government (Defra/WAG) funding , 36% in charges (eg. Consents/licences) and 5% through Local Authority Flood Risk
levies.

All fisheries income (with the exception of approximately £200k raised in Wales) money is received by Head Office (approx. £30m). This includes GIA from Defra and WAG as well as rod
licence income.

This central resource is used to fund national teams providing a service to all EA Regions and EA Wales.

These teams include :
• Fisheries Permitting and Enforcement Team
• National fish laboratory at Brampton
• National Environmental Crime Team
• Fisheries Policy and Process staff who deliver across England and Wales
• Marketing and communications

The remaining money is allocated to the 7 Regions and EA Wales using the Fisheries Resource Allocation Model. The split between English regions (average) and Wales is indicated below :

Resource Allocation to English Regions and EA Wales


It is significant that EA Wales receives more funding for all fisheries activities(with exception of rod licence funding) than the average allocation per English Region particularly in relation to antipoaching work and fishery improvements.

Our core budget is supplemented in Wales by the provision of the £800k Sustainable Fisheries Programme (SFP) Funding from WAG. This funding is used predominantly to fund improvement
projects throughout Wales (eg. Fish passes, habitat schemes, angling development) but also club training initiatives and the highly successful Angling Participation Programme.

In addition to the SFP funding, we are currently delivering a £1.4m project in the Objective 2 area of Wales involving habitat improvements and fish passes half of the project costs being met by WAG. This funding is short-term and ring-fenced to specific fishery improvement projects. Under the EU rules, such funding cannot be used for enforcement activities.

5.3 Resource Allocation within the Fisheries Function in EA Wales

The current allocation of fisheries funding within Wales is illustrated in the chart below :

Resource Allocation to Fisheries Activities in Wales



The chart above indicates where our core funding is allocated.
The largest share of the funding is for enforcement with 45% of our core funding being allocated to licence enforcement and anti-poaching work.

In addition to funding for our core activities we also receive funding for discretionary activity including :

(1) Funding from the EU for fishery enhancement projects (eg £5.2m Fishing Wales Project).

(2) Match funding from WAG

(3) Rod licence funding for projects generated from increased licence sales revenue (£240k in 2007/8).

as indicated in the above chart we receive additional funding from WAG and EU for other improvement and development projects. We also receive additional rod licence project funding
recognising the increases in sales – particularly in coarse and trout licences.

6.0 Delivery of Fisheries Work in EA Wales

The table below identifies the principal teams involved in fisheries work within EA Wales and the activities that these undertake. Fisheries enforcement work is delivered by the Environment Crime
Teams (ECT) and the Environment Management Teams (EM) within the 3 operational Areas




6.1 Current Enforcement Staff Structures

Each Area has an ‘Environment Crime Team (ECT) – (or Special Enforcement Team) and several Environment Management (EM) teams. Within the 3 Areas of EA Wales the fisheries enforcement
resource and structures differ slightly as depicted in the diagrams below :



Clearly, the structures in each of the three Areas of EA Wales differ in some respects :

(1) A team of temporary staff is used in North Wales. These staff undertake licence checking duties supporting and supervised by full-time members of staff.

(2) The use of Fisheries and Waste staff is split within the North Wales ECT although support is available to the Waste team from Fisheries and vice versa.

(3) ECT Teams in S.East and S.West Wales use HIFE trained staff extensively to undertake waste enforcement activities. In S.East Area, waste staff are also trained to undertake HIFE activity.

(4) Staff in EM teams in S.West Area are used to undertake licence checks in addition to other fisheries management tasks such as juvenile fish monitoring surveys.

A key concern amongst our customers is the perception that Fisheries money is supporting waste enforcement work. This perception arises because waste and fisheries enforcement work is undertaken within the same Environment Crime Teams in all three Areas although in the North the two areas of work are more distinct. Analysis of staff time spent on each activity during 2006/7 has shown that across EA Wales the Waste enforcement budget has supported Fisheries enforcement providing a Fisheries gain ranging from 4 to 16%. This is not regarded as being unreasonable given that extensive enforcement experience and knowledge of the Fisheries staff.

In addition to the work undertaken by the ECTs, some enforcement activity is carried out by warranted staff within the Environment Management (EM) teams in each Area. These staff
undertake licence checking duties, support ECT staff if required and other routine fisheries management work (eg. Assisting with surveys).

Each year some fisheries budget is allocated to our Environment Management teams throughout Wales to cover the cost of fisheries work that they undertake. Analysis of data has indicated that our Environment Management teams in all three Areas are being over-supported by fisheries budgets by between 22 to 70% .

6.2 Full Time Staff Numbers

The chart below shows the reduced number of Fisheries Enforcement staff since 1988. The blue bars indicate the number of staff theoretically available for Fisheries work if needed whilst the red bars are the corrected figures showing actual staff resources deployed on fisheries enforcement specific work. In 1988, for example, there were 69 Fisheries staff able to undertake enforcement duties, however they spent approximately 30% of their time on fish rescues, surveys etc. so the actual figure was nearer 48 staff on enforcement.

By comparison, 33 staff were available in 2006 (plus 2 in Upper Severn) but, because their timewas spent on both fisheries and waste enforcement, the actual fisheries effort was equivalent to 23 members of staff (23 FTEs).



In Wales, the HIFE Review created some serious short-term consequences. For example, several members of staff were unable to be issued with the warrants necessary to undertake serious antipoaching work as they did not attain the necessary fitness level. This resulted in a temporary drop in the number of warranted staff available in 2003. Several of these staff subsequently attained the required level of fitness and received their ‘full’ warrant.

6.3 Honorary Bailiffs
In the past, we paid for as many as 69 Honorary Bailiffs, each receiving £200 (after tax) for their services.

Recent Legal Counsel’s advice recommended that the use of paid volunteers be stopped as they were deemed to be employees of the Agency and consequently would require the same level of
training and protection as our full-time staff. Such action was deemed to be prohibitively expensive and the use of the Honorary staff was ended.

The use of volunteers to support full-time staff enabled double-manning on many occasions, particularly when visiting high risk sites where hostile behaviour, or other dangerous occurrences,
had been encountered in the past.

The Honorary support meant that full-time staff did not have to pair-up with each other to visit such waters, as is the case in many areas now due to Health and Safety concerns. This results in increased travel time and loss of coverage of some areas and consequential loss of customer contact.

Some Areas have invested in Temporary staff, paid hourly for the work that they do. Although fewer in number than the predecessor Honorary Bailiffs they are seen as beneficial to the
enforcement teams work, particularly during peak periods of activity.

6.4 Voluntary Bailiffing Groups

Many clubs and private fisheries employ voluntary or paid River Keepers/Club Bailiffs. Although such people do not have the same powers as Agency warranted staff they do play a significant role in the protection of fisheries in Wales. Whilst liaison groups are established in selected areas of Wales (eg Tywi valley) there is little co-ordination of the activities or sharing of information between different organisations. During 2006, our Environmental Crimewatch initiative was expanded to include fisheries enforcement. This has been undertaken on a trial basis in the Conwy catchment.

7.0 Activities of Enforcement Teams

In order to be able to undertake High Impact Fisheries Enforcement (HIFE) work, all staff are required to attain particular standards of fitness and competency in a range of disciplines. This
includes conflict resolution and the use of handcuffs and batons.
The principal duties in relation to HIFE work are to prevent :

(i) The illegal exploitation of salmon and sea trout.
(ii) The illegal exploitation of eel and elver stocks.
(iii) The illegal movement, introduction, removal and importation of freshwater fish.
(iv) Any other illegal activity carried out contrary to freshwater fisheries legislation.

This work takes place in all areas over which the Agency has jurisdiction including inland waters, coastal waters (up to 6 miles) and estuaries.

We are the Sea Fisheries Committee in the Dee and Severn estuaries and in several other estuaries around the Welsh coast work for which we currently do not receive any funding yet incur costs relating to enforcement and management.

Routine rod licence enforcement work is undertaken at present by staff in Environment Management teams and staff undertaking this work do not require the same level of training as for the HIFE. Two Areas use part-time licence checkers employed on temporary contracts.

The legislation that staff are required to implement includes :

Salmon and Freshwater Fisheries Act 1975 (SAFFA)
Salmon Act 1986 (SA)
Import of Live Fish Act 1980
Diseases of Fish Act 1963
Wildlife and Countryside Act 1981
Water Resources Act 1991
Environment Act 1995

Staff are deemed to act as police constables when enforcing the Salmon and Freshwater Fisheries Act (SAFFA) and must abide by the same legislation as the police in respect of powers of arrest,
access, search, surveillance, treatment of prisoners and interviewing. In recent years, new legislation has been introduced in relation to the investigation and prosecution of offences and offenders.

This has included :
Police and Criminal Evidence Act 1984 (PACE)
Criminal Procedures and Investigations Act 1996 (CPIA)
Regulation of Investigatory Powers Act (2000) (RIPA)
Human Rights Act 1998 (HRA)
Data Protection Act 1998 (DPA)

Changes in team structure, legislation and enforcement techniques have resulted in our teams undertaking more targeted pro-active operations This work tends to be more covert in nature than previous high profile riverbank patrols. The value of the latter is recognised particularly in relation to gaining first-hand information from, and disseminating information to, our customers.

7.1 Area Enforcement Plans

An Area Enforcement Plan (AEP) lays down the proposed activities of the Environment Crime Teams and others involved in fisheries enforcement activity. It is based on past experiences and predicted future priorities. Clearly, the teams have to react to changes in circumstances.

The enforcement work typically undertaken includes :
Rod licence checking
Targeted coastal and estuarine enforcement
Targeted in-river and spawning protection
Fish dealer checks.
Fish introduction checks
PR – targeted campaigns and reporting of results
Administration
Court work

Each ECT Team Leader produces an AEP that takes into consideration the availability of staff, budgetary resources and the areas at greatest risk from illegal activity. This then helps other Team Leaders and managers to better plan, prioritise and target the use of resources for fisheries enforcement across the Area through the year.

The AEP is presented to our Local Fisheries Groups and updates on progress provided at quarterly meetings.

7.2 National Team Support

Our Area operations are supported by two Enforcement Teams as part of National Operations in addition to an Incident Support Team. The two Enforcement teams are the Technical Support and
Process Team and the National Environmental Crime Team , the latter being involved inintelligence gathering and sharing with other enforcement agencies such as the Police.

8.0 Measuring/Monitoring /Recording

Currently our enforcement work is measured using a set of Key Performance Indicators (KPIs).

Those relating to our enforcement work include :
% increase in Rod Licence Sales

% of target Rod licence checks made (excluding multiple checks)
Rod Licence Checks – Evasion rate (%)

% of reports of illegal fishing responded to within target time

% progress against enforcement plans

% of reports of Cat 1 & 2 fish kills responded to in target time

% number of high-risk fish introductions field checked.

% of fish movement consents determined within standard of service Further details can be found in Appendix D.

Our Corporate Plan – Creating a Better Wales (2006-2009) states that we will improve fish stocks by carrying out the measures identified from the salmon stock conservation review, and, working with others, follow an annual prioritised programme of Salmon Action Plan actions.

8.1 Incident Reporting

At present, incidents are mainly reported to the Agency by members of the public – usually through the 0800 807060 number (free to landlines) or by personal contact with local staff.

The 0800 number is shared within the UK. Callers using mobile phones are given the option of dialling ‘1’ for England and Wales, ‘2’ for Scotland and ‘’3’ for N.Ireland. IF ‘1’ is dialled the
caller is then routed to one of the Regional Control Centres (RCC) in England and Wales – this will not necessarily be the RCC in Wales and additionally, it may not be bilingual.

All incident reports are logged on the National Incident Reporting System (NIRS). Unfortunately, this database was not specifically designed for fisheries. This reduces its usefulness for intelligence
analysis or reporting back to customers.

A review of the Regional Control Centres in England and Wales is underway. Future changes in the provision of the reporting system are anticipated including a likelihood that there will be a reduction from eight to two RCCs in future. One of the two proposed RCCs will continue to be based in Wales providing an opportunity for more direct routing of mobile phone calls and a bilingual response as requested by our customers.

On receiving a call from a member of the public, the RCC passes the information to the relevant Area team standby officer who makes an initial assessment of the information. This assessment
includes a classification of the incident in accordance with Agency procedures. For Category 1 and 2 type incidents our standard of service is to attend 90% of incidents within 2 hours during office
hours and within 4 hours at other times. The Common Incident Classification Scheme (CICS) classifies the incident severity (based on environmental impact) and our standards in relation to an operational response.

8.2 Common Incident Classification Scheme (CICS)

All incidents reported to the Agency that may have an environmental and operational impact and that fall within our jurisdiction are categorised. There are two levels of categorisations, firstly, a measure of the Agency’s resource required to deal with the incident (ranging from ‘A’ – major
resource requirement to ‘D’ – no attendance) and secondly, the actual environmental impact of the incident. Whilst the first level is applicable across all Functions the second has specific criteria for fisheries incidents.

Four categories of incident are identified ranging from a major incident (Cat 1) to one with no environmental impact (Cat 4). Within each category there are definitions relating to whether the
incident is one involving Illegal Fishing, Disease, Fish Mortality, Fish Introductions, Habitat (loss or damage).



Our service levels in relation to reported incidents are as follows :
Category 1 or 2: Attend all incidents within 2 hours during office hours and 4 hours at other times.

Category 3 or 4 : Attendance should be based upon risk with a presumption that nonattendance is the norm.

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8.3 Using Incident Report Data

Data recorded in our National Intelligence Recording System (NIRS) can be extracted and presented in various ways, however, caution must be used when interpreting such data. The charts below give an indication of the number of substantiated fisheries incidents since 2003 based on the area in which they occur and also the severity of the incident. The charts indicate that substantiated reports of illegal fishing activity fluctuate from year to year. It would appear that whilst the number of Category 1 and 2 incidents has reduced since 2003 the number of Category 3 and 4 incidents has increased.



8.4 Intelligence Led Enforcement

Many law enforcement agencies are now using intelligence led enforcement (ILE) as one of their methods to target criminal activity. Our ECTs have been using this approach for several years and it has been particularly effective in tackling waste crime. In order to be successful it requires four key steps :

(i) Collection of information from a variety of sources (eg. 0800 incident reports);
(ii) Secure storage and management of the information;
(iii) Analysis of the data collected;
(iv) Dissemination of the analysed information to operational staff;

One of the key principles is that the information can be shared across boundaries and between enforcement agencies as it is recognised that criminals are not necessarily restricted to one locality or a single type of crime.

Whilst we have advocated this approach to enforcement, which enables persistent, serious offenders to be detected and prosecuted, we have lacked a suitable intelligence database capable of storing and importantly, analysing intelligence data. This is a serious limitation which we want to rectify.

8.5 Rod Licence Evasion

The Agency has reduced licence evasion to a low level through a combination of activities but greatly assisted by the fact that we know how many people have licences, the numbers caught
without and therefore the evasion rates year on year or even at particular times of the season. This contrasts with other illegal fishery activity where an ‘evasion’ rate has been, to date, difficult to predict.

The principal activities deployed in order to combat licence evasion include :

• Targeting of venues where evasion is known to be high.

• Investment in marketing campaigns to encourage licence purchase (including TV/radio ads)

• Well publicised, high profile licence blitzes on key weekends (generally bank holidays early in season).

• Good media coverage of licence evasion cases.

• A ‘zero’ tolerance approach to offenders.

• Education schemes encouraging people to fish and do so legally.

Through the above activities, evasion has been reduced to 4 % in England and Wales and licence sales and subsequent revenue has doubled since the mid 1990s now accounting for over £20m of our income.

Our results over the past ten years in Wales are as follows :



Our annual licence blitzes have proved to be particularly beneficial in that they raise the profile of the need for a licence and give an indication of current evasion rates. The use of the ’blitz’ approach will be used in other areas of enforcement work in future.

8.6 Poaching Incidents
Historically, we have reported on the number of erious ‘poaching’ incidents. These involve illegal fishing activity, other than rod licence cases, where offenders are caught and further action taken.

Incidents include offences involving the use of prohibited instruments (gaffs, spears, snatches etc),illegal nets, poisons, explosives and other acts that would cause significant environmental damage.

Also included would be offences in relation to the handling of salmon in suspicious circumstances. The chart below indicates that the number of poaching incidents resulting in a prosecution has decreased in all of EAW since 1996. A similar decline has also been reported in parts of England over the same period.



8.7 Measuring our Enforcement Success

As with most enforcement agencies, we can continue to report our successful apprehensions and prosecutions, and these send important messages to would-be criminals. The number of such cases has been regarded as a measure of success in the past.
In the case of fisheries, we would prefer fish to remain in the rivers contributing to future generations and, in such circumstances, the prevention of all incidents, before environmental damage has occurred, would be our ultimate aim. Measuring our achievement of this remains a challenge and we are discussing how other agencies have approached this predicament of measuring the valuable (yet seemingly unproductive) deterrent effect of their work.

There are several gaps in our knowledge, one of the most significant is that at present we do not know how many cases are going ‘undetected’. Determining estimates of such figures would enable us to report on our ‘clear up’ rate and assign appropriate levels of resource as deemed necessary.

A wide range of factors affect levels of poaching, these include :
• Number of potential poachers.
• Number of fish available to be poached.
• Availability of a market for the fish and their value.
• River / tidal / weather conditions.
• Level of risk to the poacher of being detected and caught
• Availability of other more lucrative crime.

Our Enforcement Strategy and Area Plans need to consider each of the above elements, ways in which they can be impacted by our activity and that of our partners and the resources required.
Given the limited resources available, the cost/benefit of each approach should be considered.

We actively engage with Magistrates throughout Wales in order to highlight to them the significant damage that can be caused by fisheries and environmental crime. This influencing work has paid dividends, We now have an extremely high prosecution success rate with serious cases with very few cases lost in court.

9.0 Estimating the Level of Illegal Exploitation and Activity

At the present time, there is no measure of our achievement in reducing illegal exploitation and until now we have had no estimate of the total illegal catch for Wales.

An attempt has been made to quantify the level of illegal exploitation using data published in Annual Fisheries Reports. In producing such figures a series of assumptions has been made – details of the methodology and calculations can be found in Appendix E. Research will be required to validate and improve this data in the future.

Based on an estimated illegal and unreported homewater capture of 29 tonnes of salmon in England and Wales in 2005 (EA/CEFAS report for ICES) it has been calculated that 4.4 tonnes of salmon and 4.7 tonnes of sea trout are unreported and /or caught illegally in Wales.

If it is assumed that the unreported fish were actually legally caught, and simply failed to be declared in the appropriate manner, then the illegal capture amounts to an estimated 2.29 tonnes of salmon and 2.76 tonnes of sea trout. This is based on under-declaration rates of 10% and 8% for rods and nets respectively.



Having estimated the level of illegal exploitation for the first time, strategies need to be developed to monitor and reduce the illegal take of fish. Such strategies will consider direct (eg. apprehension of offenders) and indirect (eg. fish dealer campaigns) action, the need for different action against
different types of offenders and the cost/benefit of each approach. For example, there may be sea fishermen targeting species other than salmon and sea trout and who accidentally catch a salmon as part of their by-catch and unwisely decide to retain it. Conversely, there may be organised groups of
poachers whose aim is to make money from their illegal activity. Counteracting each type of activity may require a different approach and the targets prioritised and resource allocated as
appropriate.

9.1 Quantifying the Value of Estimated Losses

Assuming that all illegally caught Welsh salmon are sold at premium fish market prices their total value is estimated to be in the order of £156,000 (based on Billingsgate peak prices of £50/kg). It is more likely, however, that the fish will be sold locally for considerably less via the black market. In financial terms the value of lost fish is relatively small.

Of greater significance is the potential annual £500,000 loss of value to the tourism industry in Wales. Each salmon and sea trout caught is worth more to the economy than the actual sale value of the fish. Such a loss equates to a significant number of rural jobs.

The market for wild salmon is extremely small when compared to that for farmed salmon. In 2005, over 133,000 tonnes of farmed fish were produced in Scotland alone. This equates to over 30
million salmon, the total unreported and illegal catch of wild salmon in England and Wales amounts to approximately 7850 fish. It is unclear at present how the closure of the Irish Drift Net Fishery

will affect market conditions. Whilst it may lead to more salmon returning to Welsh rivers market forces may bring about an increase in the demand for, and value of, wild Welsh salmon.

9.2 Environmental Impact of Losses

The environmental impact of the loss of over 2 tonnes of salmon is also significant, with an estimated 1.5 million salmon ova being ‘lost’ from Welsh rivers due to fish being taken illegally.
This compares with an estimated ;

5.5 million eggs lost through fish taken legitimately by anglers.
3.15 million eggs taken legitimately by licensed netsmen.

Support for catch and release as a management tool is increasing and salmon anglers have ensured that 5.5 million eggs remain in the river system as a result of releasing fish back into the river. The rate of catch and release for Welsh salmon has risen from 14% in 1995 to over 50% in 2005.

Recent work by the Environment Agency and its partners through projects such as Fishing Wales has delivered over 640km of improved river for salmon and sea trout. This has been achieved
through habitat restoration, water quality improvements and fish pass construction. It is estimated that the work completed to date will result in over 5 million additional eggs being produced in each future year by spawning salmon and sea trout. By relating the level of illegal activity to the environmental loss, enforcement staff will be able to demonstrate how their work is contributing to
the achievement of our outcomes. We will also be able to compare the cost/ benefit of differing areas of our work to stock
conservation.

10.0 Customer Communications

Liaison with our stakeholders is considered a vitally important part of the Agency’s work in that it enables us to :
(1) Gather information/intelligence from customers.
(2) Share ideas and best practices across our work areas.
(3) Disseminate information about our activities and inform others of our successes.

10.1 Internal Communications
In addition to routine team meetings held in each of the Areas, there are various regional groups that meet to discuss enforcement issues including

Regional Enforcement Panel – membership includes ECT representatives and our legal section.
The Panel reviews significant cases and determines appropriate action.

Enforcement Review Group – established in 2006 to oversee the Review of Fisheries Enforcement. The Group comprises of ECT Team Leaders, Enforcement Officers (from all Areas in Wales including Upper Severn) and HO Policy and Process staff.

10.2 External Communications
We use a number of fora in order to seek advice and guidance on our work and to disseminate information on a variety of issues, including enforcement. The principal groups are :

Fisheries, Ecology, Recreation Advisory Committee (FERAC). Meeting quarterly, membership includes game and coarse fishery representatives who are appointed on the basis of their knowledge and ability to provide advice on our strategies and policies.

Seven Local Fishery Groups receive regular updates on predominantly local issues but are also encouraged to comment on regional and national issues. Membership of the LFGs is drawn from local angling clubs and private fisheries interests.
Angling club liaison – each Area Fisheries team is encouraged to have regular liaison with clubs and fishery owners.

Other Groups/Organisations

Magistrates – our legal team undertake regular presentations with groups of magistrates in order to
inform them about the impacts of environmental crime.

Police - the Agency has developed close links with the police forces throughout Wales sharing intelligence and undertaking joint enforcement operations. In North Wales, a police officer has been seconded to the Agency to work in the Environment Crime Team. This has greatly assisted the
facilitation of joint operations and ensured rapid police support when required.
Sea Fisheries Committees – there are two committees operating in Wales –the South Wales Sea Fisheries Committee (SWSFC) and the North Wales and North West Sea Fisheries Committee
(NWNWSFC). Whilst predominantly focusing on the management of sea fish species the Committees assist our work in protecting salmon and sea trout in coastal waters.

Marine Fisheries Agency – our main area of joint work with the MFA centres on the protection of estuarine areas frequented by bass, salmon and sea trout. Several of our enforcement officers have received training by MFA on bass protection and hold enforcement warrants.

10.3 Communication Methods
In addition to our reactive communication techniques such as press releases, responses to letters, emails etc a variety of pro-active tools are used when undertaking our communications as indicated below :

• Thematic press campaigns are undertaken and cover a variety of issues. For example, we have a campaign to encourage the purchase of rod licences in early April and May.

• Newsletters are produced by the Area fisheries teams and issued electronically to as many customers as possible.

• Glasydorlan is our annual magazine sent to all rod licence holders. The principal purpose is to promote the sale of licences early in the financial year.

• Industry mailers have been sent to over 1000 clubs and fishery related businesses throughout Wales. These have focussed on our Fishing Wales marketing work but are a potentially
useful means of communicating enforcement information.

• Face to face meetings take place with angling organisations and fishery owners both individually and through our pre-planned Local Fishery Group meetings.

[Hoppy]

SEEKING SOLUTIONS

11.0 Recommended Actions

The comments of stakeholders, operational staff, our Enforcement Review Group, Management Team Wales (MTW) and other agency staff have been analysed and a large number of
recommendations made that, if implemented, could address many of the key concerns raised.

The results are presented in Appendix F and listed under the eleven category headings identified in section 4.3 above.

It must be noted that this list may not be exhaustive (ie. Other ideas may be added) and there is no guarantee that all actions can, or will, be delivered.

11.1 Assessment of Recommendations

The recommended actions have been assessed on the basis of :
How each action would contribute to addressing the key concerns identified by the IFSG and the stakeholders at their workshops.

Likely Cost of implementation – each action will have an associated cost irrespective of its size.

Attempts have been made to quantify costs in terms of cash and man-power. ‘Low’ cost actions are those with negligible cash implications, however there will inevitably be some demands placed on staff time.

Timescales for implementation – each action has been assessed as being deliverable in either short (within 3 months), medium (by end of Financial Year 07/08) or long term (beyond one year 2008+).

Outcomes delivered for fisheries through our enforcement work. It is vital that our actions assist in the delivery of our key outcomes - if they don’t we should not be doing them.

11.2 Stakeholder Involvement in Delivery of Solutions

Attendees at the workshops were asked to make suggestions regarding how they could assist in delivering greater protection for our fisheries.

These suggestions have been considered when developing appropriate actions.

There are several key areas in which our customers have expressed a wish to assist.

These include :
• A wish to be trained as voluntary ‘River Watchers’ and to be involved in schemes such as river fly life monitoring.
• A willingness to assist in promotion of the 0800 number.
• Changing club rules to prevent illegal removal/sale of fish etc.

Whilst there was a wish to be involved, concerns were expressed that volunteers needed to be shown how to do contribute properly and without compromising their own safety.

There was concern expressed that volunteers would not wish to tackle poachers and that this should be left to professional law enforcement staff.

11.3 Cost of Delivering Recommendations

Nearly half (42) of the recommended solutions can potentially be delivered by our existing teams through changes in working practices. However, given the large number of potential solutions
some prioritisation and planning will be necessary so that changes are implemented in the appropriate order.

The remaining recommendations would, if implemented immediately, cost approximately £944k.

Of this cost an estimated £454k would be one-off set-up costs which could not be accommodated within our existing budgets.



11.4 Staff Resource Requirements

One of the principal concerns expressed by stakeholders relates to the size of our current enforcement teams. Many customer believe that the enforcement teams are now too small to be
effective particularly given the Waste/Fisheries cross-functional roles.

Concern has also been expressed about the age profile of staff and loss, without replacement, of team members due to sickness, ill-health and retirement. This creates additional pressure on the limited numbers of remaining staff if replacement resource cannot be provided.

The approach taken by our enforcement teams is that of targeted enforcement. This involves assessing the environmental risk of a range of illegal activities and targeting those where we can have the greatest impact in terms of reducing environmental damage. For example, an unlicensed angler spinning on a river will be regarded as less serious than a group of poachers netting salmon and sea trout. Resources are most likely to be targeted towards the latter – if sufficient staff are available both issues will be tackled.

This targeted approach relies upon the receipt of quality intelligence, from a variety of sources. Single pieces of information may not provide sufficient detail to mount an immediate operational response. However, when several reports link together a more detailed picture of what is taking place emerges and action can be taken.

Targeted enforcement often involves the pro-active planning of covert activities and by their nature it results in staff being less frequently seen by members of the public.

The alternative approach to enforcement is to revert back to the ‘beat’ approach whereby staff would be assigned a stretch of river (or a catchment) and would undertake routine patrols, seeking signs of illegal activity and speaking to those that they meet. This does have some benefits in that there is contact with customers, staff are highly visible and other non-fisheries issues can be reported back to other Functions. Targets can be set relating to the number of patrols undertaken in particular locations and these ‘service levels’ reported to customers.
There are, of course, different options relating to the scale upon which both the ‘targeted’ and ‘beat’ approaches can operate. The following table provides an illustration of a range of options and their associated estimated costs for the two types of enforcement approach in Wales.



To change to option 4 would cost at least an additional £500k. This option would provide a combination of pro-active targeted enforcement coupled with high visibility enforcement work
coupled with Formal Standby Officers and additional temporary staff. This would provide a significantly enhanced level of service.

Options 5 and 6 would require an estimated additional £3.15m and £0.9m respectively. These figures do not include the additional requirement for Team Leaders and/or new managers as part of the structure. Both these approaches, whilst significantly increasing our presence on the riverbank,
would not enable other more targeted work to take place and would not necessarily increase our ability to provide a reactive response to reported incidents.

Before committing to any significant further change, for which funding would be essential, research into the current level of illegal activity will be required and the cost/benefit of each structure option estimated.

Option 4 – Potential Staff Structure.
The diagram below shows a new structure for our Environment Crime Teams that could deliver Option 4 in the table above. Whilst it would make use of the existing ECT staff additional personnel would be required in all three Areas.



The structure above would feature :
(i) A larger HIFE team with support for full-time staff from seasonal Temporary Staff trained to a similar standard. These would be predominantly fisheries focussed.

(ii) A team of ‘High Visibility’ (with Temporary Assistants) staff whose role would be to check licences and meet anglers and others gaining local information in the process. These staff
would be migrated from the Area EM teams into the ECT.

(iii) A team of intelligence analysts, predominantly waste focussed.

(iv) Administrative support, the role of which is to help reduce the burden of paperwork for the operational enforcement staff in (i) and (ii) above. This role could be fulfilled by staff who are no longer able to undertake HIFE work.

(v) Fisheries resource will be moving from EM teams to ECT.

12.0 Funding Additional Work

As indicated above, many actions can be implemented over a period of time with minimal additional cost. However, if we want to deliver more than the ‘cheap’ and ‘quick’ actions consideration needs to be given to the more costly actions and how these will be funded.

The options available include :
• Reappraise our Resource Allocation
This may involve reducing activity in non-enforcement areas of fisheries work and transfer of the resource. For example, we could reduce our commitment to improvement work or licence
checking. This is likely to result in targets not being met in other areas of work and could seriously compromise our ability to generate income from other sources and we may miss the
‘once in a lifetime’ opportunity presented by the EU structural funds to undertake habitat and fish access improvements.

• Rod Licence Duty Increases
Whilst there are recommendations in this report in relation to the protection of coarse fish stocks, most of the identified actions relate to the protection of salmon and sea trout. It is therefore considered unreasonable for coarse and trout anglers to have to pay for improved salmon enforcement.

Given that approximately 16,000 full season rod licences are sold annually for migratory fish every £80,000 in additional expenditure (the cost of 2 full time staff) would require an average of £5 to be added to the cost of each licence.

This approach would contradict our policy that the public purse should pay for the protection of stocks. This approach is also likely to be counter productive with licence sales and income
falling as a result of any significant duty increase.

• Increased GIA
Any increase in GIA from the Welsh Assembly Government would necessarily be a Ministerial decision.

• Polluter Pays (or Poacher Pays) Principle
We could explore the possibility of recouping more of our costs from those that we apprehend in order to fund additional work. Unfortunately given the relatively small number of cases even
if this option were feasible it is unlikely to raise significant amounts of revenue. Fines imposed by the Courts are not received by ourselves although we receive some, but not all, costs.

• Innovative Solutions
We will continue to investigate alternative means of funding particularly from those beneficiaries who do not currently contribute to our work or from those who wish to receive an
enhanced level of service. This might, as suggested by some of our customers, include consideration of charges against fishery owners in particular catchments.

13.0 Conclusions

The Review process has identified a large range of issues relating to fisheries enforcement provision in Wales and potential solutions to address these. In addition, the Review process has generated new ideas about how we could improve and modernise our Fisheries Enforcement work in Wales.

The Review has acknowledged the concerns of our customers and answered many of their questions.

We have addressed the key perceptions of our customers which included issues such as :
• we are a ‘blue-light’ service able to respond 365 days a year – we are not.

• enforcement should be our most significant area of fisheries work – in terms of budgetary provision it is.

• the Fisheries Function is subsidising our Waste Enforcement work – it is not.

• illegal fishing is ‘out of control’ in many areas – we have no proof of this.

We have provided clarity in relation to the above and considered the other wide-ranging concerns making recommendations as to how these can be addressed.

This Review acknowledges these concerns and seeks to address them by taking appropriate actions categorised as follows :

13.1 Immediate Actions
Some of these actions are already being delivered within existing budgets including :
(i) Provision of stand-by staff in N.Wales.
(ii) Production of Fisheries Newsletters in all Areas.
(iii) Closer working with other marine fisheries enforcement agencies.
(iv) Exploring opportunities for closer working with police forces.
(v) Change in Agency Policy in relation to fish theft
(vi) Moving resource from EM to ECT.
(vii) Each ECT team has a nominated Intelligence Officer.
(vii) Changes to the Regional Control Centres.

13.2 Beneficial Actions requiring Extra Resource (Medium term delivery)

We would like to commence the following actions but have insufficient resource to do so :
(i) Procurement of Intelligence Database and associated training
(ii) Provision of Temporary Enforcement Staff in each Area to assist full time staff during peak .
(iii) Formal training schemes established for volunteers.
(iv) Improve our covert surveillance capability through CCTV etc

13.3 Longer Term Actions Requiring Additional Resource
Before we commit further significant resource to our fisheries enforcement work we need to quantify the actual level of illegal activity and its potential to increase in future.

Once this work has been completed we may wish to :
(i) Increase the size of our Environmental Crime Teams.
Further detail of these actions can be found in Appendices F and G.

14.0 Recommended Next Steps
We recommend that the next steps to delivery should be :
(i) Deliver some low cost actions (13.1 above), within our existing budgets that will bring about increased protection for our fisheries and an improved service to our customers.

(ii) Produce an initial Fisheries Enforcement Strategy for Wales supported by customers and partner organisations. This will consider :

• Current level of illegal activity ?
• How best to combat this threat ?
• The approach taken by other enforcement agencies and their lessons learnt.
• How future levels of activity may change and proposals to pre-empt such changes ?
• How much resource is required and how this is best deployed ?
• Roles of customers and partners.

(iii) Produce a Fisheries Communications Strategy to improve our communications with the public and partner organisations.

(iv) Research and develop agreed techniques for quantifying illegal activity to give a true indication of the level of illegal fishing activity.

(v) In light of the results from (iv) above, re-evaluate both Enforcement and Communications Strategies.

(vi) Seek necessary funding and bid for additional funds from WAG at the appropriate time.

This will require wider debate about the level of resource allocation for enforcement work in relation to other areas of fisheries work.

15.0 Appendices
Appx A – Inland Fisheries Stakeholder Report recommendations
Appx B - Outputs from External Workshops
Appx C – Output from Internal Workshop
Appx D – Key Performance Indicators
Appx E – Illegal Exploitation Estimates
Appx F – Tables of Recommended Actions – Ordered by Theme :

Table 1 – Working with and Assisting Volunteers
Table 2 – Reducing Fish Theft
Table 3 – Ensuring Appropriate Agency Staffing Levels
Table 4 – Improving our Monitoring and Assessment of Illegal Activity
Table 5 – Working More Efficiently with Other Organisations
Table 6 – Improved Gathering and Better use of Intelligence
Table 7 – Responding to Incident Reports more Efficiently
Table 8 - Using Equipment and Technology to Combat Illegal Fishing
Table 9 – Dealing with Constraints on Our Activity
Table 10 – Being More Consistent in Our Work Across Wales
Table 11 – Communicating More Effectively with Our Customers

Appendix G – Tables of Recommended Actions – Ordered by Cost and Timescale :
Table 1 – Short Term Low Cost Actions
Table 2 – Medium Term Low Cost Actions
Table 3 – Short Term Costed Actions
Table 4 – Medium Term Costed Actions
Table 5 – Long Term Costed Actions
Table 6 – uncosted actions
Appendix H – other on-going reviews