I was pleased to be able to speak to you at the recent Welsh Office meeting. I now enclose comments on our various concerns and issues to the perceived effects of aggregate extraction as they relate to the
marine environment / fisheries aspect.
I enclose copies of recent Committee Submissions on applications to either renew or extend aggregate dredging licences for the Nash and Helwick Banks situated locally. The principles contained within our response however, apply equally to other areas or management of the resource as a whole.
In summary, the Committee have put forward the viewpoint that:
l. EXISTING DATA
· Fishing effort and value of fisheries to both local and National economies are extremely difficult to calculate, and due to various shortcomings in the method of collection, and interrelationship between catch and income (taxation etc) are significantly underestimated. This is a national problem that applies to the majority of fisheries. In the 1995 South Wales Sea Fisheries Committee Annual Report (enclosed) we attempt to address some of these shortcomings.
· There are large variations in the state of fish stocks between areas and species. i.e. The fact that for instance, cod in the North Sea is overexploited does not mean that, for example, stocks of bass locally are not in good shape.
· It is agreed by all fisheries scientists that there is the potential for very significant changes year on year for fisheries i.e. Year class strength can be very variable (especially for short lived species), and the spatial distribution of fish can vary (particularly seasonally).
· Data held by MAFF scientists on the abundance and spatial distribution of fish species, particularly on a local or specific area a basis, and / or for species perceived to be of lesser commercial interest, is not as accurate or as complete as they would like it to be. An argument persists amongst some commercial fishermen that, even for some well studied stocks of commercial species, it bears no resemblance to reality. It follows, therefore, that the 'experts', if there are any, on the range of abundance of species situated locally, and the variation between years and historical data, are often the local fishermen themselves. Whether this is a pleasure angler or Commercial fisherman will depend upon the fish species, the period of catching interest (eg Marketability). For example, both would know about bass, commercial fishermen only about lobsters, and anglers would know about small eyed ray, smoothound or trigger fish. The sum knowledge of the scientist would depend upon financial resources at the time and areas of particular interest or research expertise. It is highly unlikely to run at anytime to knowledge of small eyed ray or smoothounds!
To summarise then - treat information from "official" sources on fishing effort, value of fisheries and biological knowledge eg abundance ~~: ~ash species with an open mind.

2. THE PROBLEM
Briefly, the number of sandbanks as a particular habitat type, and in the context of the overall extent of seabed, is extremely small They therefore play a very important part in regard to the diversity of marine ecosystems. The sea bed, itself, has been very little studied and explored when compared to the land, although more effort has been put into this in recent years.
' The marine life on sandbanks is not particularly diverse. However, as banks are formed as a result of the existence of a severe hydrodynamic regime, the animals (principally) present are adapted to live there. They therefore are of the 'r' selected type and tend to be short lived, ie. present often in high numbers, and are highly variable in abundance between successive time periods. Other mobile organisms feed on the resident infauna, and themselves become prey for larger predators, the largest of course being mammals (including man).
The sandbanks themselves are basically relict deposits - formed in the interglacial periods thousands of years ago. Depending on each individual case there may be movement of material from one bank to another, or from open areas to banks systems. (Yet to be fully determined in most cases). However, one point is clear. If you take the sand away, then the banks will not regenerate itself (unlike the harvesting of fish). If sand is removed there may be some compensatory movement of material from other areas to retain the profile of the banks in the short term. Continue to remove sand, and the bank will decrease in size (permanently) reducing the size of the habitat and in doing so having adverse ecological
consequences. The question that requires an answer, for each individual bank is how much material can be removed before irreversible ecological damage takes place? For fisheries this has to be considered against our inadequate knowledge identified under point 1. I trust the modelling of physical changes that would induce ecological change is outwith the scope of this project?
If it is accepted that the removal of any habitat causes ecological damage, the next question is at what point this becomes significant, and the point at which no further removal should be allowed?
My personal opinion is that this position has already been reached for the Nash Bank, but not for the Helwick. However, we should adopt the precautionary approach and act before it is too late. The Committee has said that any sand removal is damaging and therefore must be restricted. Other environmental groups may follow this principle. No doubt many other groups with a financial interest on using the resource would take the other extreme view ie to continue to remove more aggregates until it can be shown that significant irreversible damage is about to (or has already taken) place.
In view of my earlier comments on the limited ability of the resource to renew itself, I would advocate that the precautionary principle apply in such cases.
Sadly, in view of our current lack of biological knowledge of the marine environment and the limited other options available to obtain important sources of aggregate for building (and the MMBY viewpoint surrounding landward extraction), the development of marine aggregates has been a soft option'. I believe the phrase "out of sight out of mind" applies.
3. THE WAY FORWARD (OR THE OUESTIONS TO ANSWER .1
Unfortunately, what I heard on the 16 October does not fill me with confidence that this project will begin to provide the answers to this, the ecological, problem.
We need to know:
1. The physical ~ processes involved with the resource itself. ie. How robust is each ecosystem to change - in the long term, taking into consideration activities taking place elsewhere. This project will start on this, and no doubt produce a further research list.
2. What is the economic importance of fisheries a: a suitable renewable resource of each bank system?

ITEM (A)
DREDGING - NASH BANK (PORTHCAWLI
Aggregate dredging has taken place on the Nash Bank since the 1920's, albeit mainly since 1977 according to recorded data. Three dredging companies are already licensed by Crown Estate to take 1.5 million tonnes per year. Individual company tonnages are approaching (or have reached) their limits, and a new application seeks to renew their licences.
Vast quantities of aggregate are required for use by the construction industry for example in house building, road - rail construction, and major capital projects eg 2nd Severn road bridge, Cardiff Barrage etc., and coastal defence works. ,
Government policy is not to take the sand from land sources eg Quarries, or sand dunes or import from other countries but to use marine sources wherever possible.
The Committees previous policy has been to ensure that the marine environment and fisheries are given adequate protection, and are not adversely impacted. The concern has been that marine sourced aggregate has been out of sight, out of mind'. It is true to say that in the early years dredging practices were not adequately monitored by Crown Estate, and they had few accurate records of the quantities and source locations of the removed sand. The public is now generally more environmentally aware, and increasingly focus on the welfare of the environment. As a consequence of this the whole process of licensing the removal of aggregates has been reviewed and previous Committee reports refer. Conditions are now put in place by overseeing Government Department (in Wales it is Welsh Office, Planning Department) which requires the developer to undertake an Environmental appraisal and assessment of coastal impacts, and finance ongoing monitoring conditions. Extracts are enclosed of these two reports which together run to c140 pages.
Aggregate sand for building work is valued at first sale at £9.30 / tonne (£8.50 per tonnes for loads over 10 tonnes.). On the stated amounts extracted and at 1996 prices this would value the sand removed to date at £209 million. At the maximum projected take over the next 10 years of the proposal, a further
100 ~139 million would be generated. It is against this background that the welfare of the environment and ' fisheries importance must be considered. The fishes of the Nash are no longer as important as they allegedly were before dredging commenced, and therefore of £0.25 million each year on a sustainable basis would likely be an overstatement. Anecdotal r reports of the decline in fishing activities on the Nash allegedly as a result of dredging activity, are appended. At the very least they suggest that the removal of irreplaceable marine sand deposits should be treated with caution.
Officers have considered the Environmental statement and have identified various shortcomings in its consideration of fishing aspects.
It is recommended:
1) That the enclosed response is put to Welsh Office drawing their attention to the limitations of the fisheries assessment and suggesting further monitoring requirements.
In particular members should consider:
2) Whether they wish to raise any formal objection to Welsh Office.
P J Coates
12/6196

3. What is the nature importance of the habitat say to benthic species or fish species, in a national and local context?. 4. What are the links between microfauna, macrofauna, small and large predatory fish? 5. What are the natural variations in these components of this mini-ecosystem? You need to know this, , to be able to determine any man made change (eg. of dredging) from natural variations 6. The results of the biological questions raised 2 to 5 will enable us to make an informed decision, on what is an acceptable level of environmental change caused by aggregate dredging. The decisions that are eventually taken may not be acceptable to all, but unless we are able to answer these questions with a degree of confidence, we stand to be criticised for our actions. As I said earlier, if we have insufficient information the precautionary principles should apply.
From our involvement in the promotion of sustainable fisheries on the Helwick and Nash Banks, and the environmental impact assessments undertaken by contractors to date, the specific question that need to answered is "What are the fish types and quantities of species present on the banks, and the ranges in their seasonal and annual variation?" That sounds simple, but it is not.
~ Quantitative survey techniques for demersal fish present on the banks are lacking (eg Turbot), but this is particularly problematical' for sand eels. If we can't undertake this for a specific project, how can we identify comprehensive baseline (pre-dredging) survey information?
The difficulty in quantifying fishing effort and the economic importance of fisheries on the banks to local economies (eg Charter angling, local markets) has been identified. What again are the baseline data?
In the absence of hard information on the above, I feel that the best that we can go on will be anecdotal information from fishermen with long track records. How much weight will this carry in the face of a multimillion pound industry (eg £340m Nash Bank alone) which the Government has an incentive to develop?
If the project merely recognises these short comings, and begins to address them through the provision of adequate data, we will at least be making some small progress.
Yours sincerely P J Coates Director Encs.
PS: The copies of reports that we hold are: Those catch and survey information, that have been used to compile the enclosed Annual Report plus Fisheries Officers activity reports (quarterly)

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