P-05-778 Protect the Razor Clams on Llanfairfechan Beach – Correspondence from the Petitioner to the Committee, 26.09.17 

NFORMATION IN SUPPORT OF PETITION 1229

PROTECT THE RAZOR CLAMS ON LLANFAIRFECHAN BEACH

PREFACE

It is important to make clear to the Petition Committee that ideas set out in these supporting notes have been canvassed from as wide and as representative of the local populace, as possible , working within the time limits of preparing the petition.

BACKGROUND

1.1 Razor Clams in brief

Razor clams are bivalve molluscs which look like old fashioned razors, (hence the name). Information garnered from different sources; including correspondence from Conwy Council and Janet Finch-Saunders (AM); specifies that razor clams live up to twenty years taking some time to mature. It is believed that the clam bed on Llanfairfechan beach is one of the finest in the country, and it acts as a nursery for up to six different species of clams.

1.2 Current controls, regulations and thoughts about quotas

(a) Current legislation dictates that any razor clams harvested should only be used for personal consumption or as fish bait, and cannot be used in a food business i.e. commercially. (M.Frankcom Public Protection Manager 2016). In addition, they must achieve a landing length of at least 10 cm.

(b) Information gleaned from Head of Regulatory Services CCBC,states that:  

“Razor clams are (subject to) the requirements of food hygiene regulations including Regulation 853/2004 for LBMs would therefore apply. The primary requirements if they are harvested for commercial purposes are:

Ø The shellfish harvesting area must be classified.......................

Ø The classification given to the bed would then determine what could happen to the shellfish once gathered.  If the bed was determined to be a category A bed, the shellfish could be consumed immediately; a category b bed would need to go for further treatment...etc. etc.

Currently, Llanfairfechan is not a classified for Razor Shells and any gathering for commercial purposes would not be permitted. A section of the beach at Llanfairfechan is classified for Cockles (under Traeth lafan) however; this would not automatically mean it would be classified for razors.

(c) In respect of collecting cockles the “fisheries do permit an individual to gather up to 5kg of shell fish per day”. However, if Llanfairfechan beach was ‘classified’ for razor clams, and given the number of ‘individuals’ involved in removing razor clams, this 5kg benchmark would appear to be too generous. For example, using a hypothetical number of 50 gatherers with each taking 5 kg the amount taken would be nearly half a ton. This is a moot point given that many gatherers visiting Llanfairfechan beach go well beyond a 5 kg quota, with some using large wheelie trollies.

2. CONTINUING CONCERNS  

Over the last 4 – 5 years it has been noted the numbers of people harvesting razor clams on Llanfairfechan beach has escalated, with, sometimes, up to 100 people involved (Weekly news 26^th August 2013 – reported by Tom Davidson). Large scale harvesting of the razor clams has continued up to the present time, with gatherers coming at low tides. Video and photographic evidence of the harvesting, along with discussion posts highlighting ongoing concerns, has been shared on social media, most recently: (Facebook - Llanfairfechan Noticeboard group – 27^th April, 8^th May, 25th June, and 1st August 2017).

Here are a few points selected from these on-line posts. “Lads fishing in the beach are not allowed to take any bass…..until July 1^st, then only one a day. Yet these people are allowed to take as much as they want with no thought for conservation of the fish stock and food chain”. 

“Doesn’t anybody have the power to stop them?”

“The razor clams will be gone before any petition will do anything…….”

Each time the gathering takes place there is a corresponding ground swell of debate on social media, along with many residents contacting the various authorities which oversee these activities.  The evident lack of regulations leaves residents frustrated and disempowered as they watch the regular, and seemingly, perfectly legal, removal of an important environmental resource.

3. AUTHORITIES INVOLVED

Since, 2015 multi-agency operations have been conducted involving the Food Safety & Standards Team of Conwy Council, Harbour Master Conwy Council, Welsh Food Fraud Co-ordination unit (FSA Wales), North Wales Police, Gang-masters Licensing Authority, Border Agency, North Wales Anti-slavery team and the Welsh Assembly Government Inshore Fisheries Unit and Natural Resources Wales. During this operation, investigations were carried out including identity checks on gatherers and identifying any potential links to food businesses. The operations, so far, have not exposed evidence that would indicate that the clams were being harvested for commercial purposes. These investigations have also allayed concerns that some of gatherers may have been being used as part of modern slavery operation. However, the continuing systematic removal of the clams remains unresolved.

4. ASSEMBLY QUESTION TO THE FIRST MINISTER on 23^rd May 2016

Last year Janet Finch-Saunders(AM) raised questions and concerns in the Welsh Assembly about this activity and here is part of the response from  Carwyn Jones: Hand gathering of shellfish (including razor clams), on beaches such as Llanfairfechan, is not restricted as regards the quantities that may be collected. We do not have any evidence that such activity represents a significant threat to the stock of razor clams around the Welsh coast, nor to the ecosystem which they inhabit, nor to other environmental features that we might wish or need to protect. On that basis, we do not currently intend to regulate this activity”.

5. RAZOR CLAMS – PUBLIC MEETING 24^th July 2017- Janet Finch-Saunders (AM)

Many of those attending the meeting expressed strong feelings regarding the sustainability of the razor clam beds and the environmental and economic

consequences  on this ongoing gathering, such as the possible impact on other

marine life, birds, other fishing activities and reputational damage to tourism within LLanfairfechan.  

The meeting was informed that razor clams can be taken for personal consumption.

Once again the 5kg quota was mentioned, and whilst such a quantity seemed reasonable; on face value; anxieties were voiced about the large numbers of

gatherers involved. Along with the fact that some of the gatherers are now using large back packs of salt dispensers in order to obtain the shellfish. 

A few concerns were raised regarding problems encountered with littering e.g. empty

salt bottles and some incidents of anti-social behaviour exhibited by a few of the gatherers. Further questions were asked as to whether there was any existing

research to provide evidence as to the density and types of the razor clams found within the beds, but the panel were unable to comment. It was suggested that research

should be initiated in order to establish the facts and check the sustainability of the

beds.  Some points were mooted about the possibility of having a closed season for

the clam beds, in a bid to allow recovery of the beds. A number of people called for

new legislation in order to further protect the razor clams.

6. LETTER OUTLINING CONCERNS WAS SENT TO LESLEY GRIFFITHS (AM) Cabinet Secretary for Environment and Rural Affairs after the public meeting

7. TEMPORARY CLOSURE OF RAZOR CLAM BEDS

7.1 Byelaw 16 put in place by the former North Western and North Wales Sea Fisheries Committee

Since 19^th August there has been a temporary closure of the razor clam beds.

7.2  Continuation of gathering

Irrespective of the closure of the razor beds discussion on social media, (22^nd August), indicated that gatherers were still coming to collect razor clams and Fishery officers had to be in attendance a number of times.(See newspaper clip included with these notes).

8. PETITION SUGGESTIONS

We call on the National Assembly for Wales to urge the Welsh Government to:

Ø commission a research study to ascertain the state of the health of the razor clam beds and their viability as a long term natural resource, and put in place a moratorium for fishing of razor clams until the research can report its findings;

Ø ratify a ‘closed’ season for the harvesting of razor clams aligned to the spawning season i.e. May to September;

Ø draw up regulations in addition to the minimum landing size of 10cm to include set quotas that individuals are allowed to take; and bring forward legislation and regulations to protect the razor clams on Llanfairfechan beach

8.1 RESEARCH

It seems inconceivable that the agency set up, in part, to protect and conserve the

marine life around our lovely coastline appeared somewhat hamstrung by the lack of

legislation to protect this particular species. Concerned residents have welcomed the temporary closure of the razor clam beds and assume the closure is in place in order to conduct research on the density and ‘health’ of the razor clam beds?

8.2 CLOSED SEASON

As expressed by a number of attendees at the Public meeting (ITEM 5), there are

closed seasons in place for cockles and for the hunting of wildfowl, but presently

there is no closed season for the razor clam beds. Razor clams are not like

blackberries, they will not return as an annual event. Therefore, instituting a closed season would, at least, allow time for the fish beds to recover. The logical period for

such a closed season should coincide with the spawning period.

8.3 QUOTAS

Clearly, the amounts of razor clams currently being taken may endanger the long term sustainability of the beds, which is likely to affect, and impact on a variety of other

marine and bird life which depend on the presence of the razor clams. Being

conscious of the need to protect those people who gather the clams simply for fishing

bait perhaps ‘classifying’ the beds may not be the most appropriate option to take.

In addition, although, there has been a lack of evidence to support the notion that gatherers are taking the clams for commercial purposes, the fact that the present day prices of razor clams online is around £30 plus per kilo, suggests that potential

gatherers should be supporting the economy by some means of fees or licensing.

9. FINAL COMMENTS

Razor shell fish may not be particularly pretty, interesting or cuddly, but they form part of the unique and beautiful environment of Llanfairfechan beach. The stories about overfishing are being played out across the planet, which resonates with the need to be proactive about what and how we are treating the environment at local and national level. 

Llanfairfechan beach is a stunning visitor attraction which, in turn, brings much needed revenue to the local area.  The impact of seeing large numbers of gatherers on the beach may not provide a good impression for visitors.

There will always be vital and important issues at the forefront of the Government’s agenda, such as ‘Brexit‘, ’Health’ and ‘Education’, but it is hoped that some time and attention can be devoted to devising suitable and robust legislation to protect these razor beds for the future.

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