Below are 3 emails 2 from Chris White who is leading the fight against NRW who wish to impose Bye-Laws to impose catch and release on all Migratory fish catches
From Chris White
A freedom of information request was sent by Andy Nicholson to the Centre for Environmental Fisheries and Aquaculture Science (CEFAS) requesting details of communications between CEFAS and NRW/WG as NRW stated that they have the support of CEFAS for their bylaw proposals. The response listed 10 emails between 12 June 2017 and 6 July 2017 these emails refer to acknowledgement of receipt of the technical case and requests for further information. I have attached a copy of the final correspondence from CEFAS to WG dated 6 July 2017. Note that this refers to a public consultation and yet in August 2017 WG issued a statutory notice in the London Gazette of the proposed Bylaws asking for objections. This statutory notification was based upon the original bylaw proposals and not those that were amended following the objections received following the public consultation. We are seeking advice from Fish Legal if there is a need for WG to publish a further statutory notice before the proposed bylaws are put in place this is due to the amendments to the bylaws following the consultation.
There are some interesting observations from CEFAS in that they have taken the data on face value i.e. there has not been any challenge on how this data was produced (we should have the report on the validity of the data from our independent statistician shortly), this was their comment:
“…… However, these documents largely contained tables and figures (N.B. I have taken the raw data provided in these documents at face value), so the few comments I have on these documents have also been listed below.”
There is recognition in item 2 that part of the decline has been due to adverse weather conditions:
2. Further, particular concerns have been raised about the very poor salmon fry levels observed in rivers across Wales (and England) in 2016. This appears to have been caused by a combination of abnormally high winter temperatures and, in some cases, elevated flows, alongside relatively low numbers of spawning fish. The unusual winter conditions experienced in 2015 are consistent with climate change predictions and highlight the increasing uncertainty that stocks are likely to face in the future. The low fry abundance in 2016 is likely to result in reduced smolt output and lower adult returns in coming years.
In item 6 it deals with the need for further conservation measures and recognises the wide range of environmental factors. The elephant in the room is the failure to mention the effect of agricultural pollution or avian predation on recruitment of salmon from egg to smolt and yet it is known from various smolt tracking exercises that up to 40% of smolts fail to reach the sea due mainly to avian predation (70% on the Aberdeenshire Dee in 2017 according to their smolt tracking survey). Addressing this would go a long way in reversing the decline, see attached estimate of the damage due to avian predators on the Tweed system. This is what CEFAS said:
6. The technical case thus makes a compelling case for further urgent conservation action to help arrest the decline in the status of salmon stocks, and to a slightly lesser extent sea trout, and to help restore stocks to healthier and more sustainable levels. The report recognises that both species are facing a wide range of environmental factors and stressors which are constraining productivity and stock status (and details some of the ongoing actions being made to address these). For salmon, the ongoing issues associated with poor survival at sea are a key concern, and highlight the continued importance of ensuring that conditions in freshwater are optimised.
This does not address the losses from river to sea; improving losses during smolt migration would have a far greater effect than imposing draconian measures on anglers and to a lesser degree netsmen.
There is a telling comment in item 7 which identifies that anglers are not the problem, this is what is said:
“7. NRW note that the current levels of exploitation are not the primary cause of the current low abundance and that the proposed measures will thus result in relatively modest increases in spawner numbers, although accumulated benefits would be expected over time. ……”
After 20 years of compulsory catch and release (C&R) for spring salmon there has been little or no improvement i.e. restrictions on angling has made little or no difference in reversing the decline, extending the C&R will not reverse the decline in fish stocks the perception is this being done to stop criticism i.e. it is the easy low cost option and will achieve nothing.
Item 7 then goes on to say:
“….Nonetheless, it is entirely justifiable to aim to maximise spawner numbers in the short term and, while it is clearly important to continue to address the many other factors affecting stocks (e.g. water quality, habitat), it needs to be recognised that such improvements are only likely to be achieved over the longer term. As such, it clearly makes sense to implement appropriate fishery control measures in the short term to increase the numbers of fish surviving to spawn and to facilitate recovery.”
Addressing the survival from egg to smolt will have a far greater impact on restoring salmon stocks than imposing restrictions on anglers. The problem is neither NRW nor WG are addressing the other factors affecting salmon stocks the perception is that this is primarily due to staff and budget constraints.
In item 8 there is a recommendation to re-order the technical case and to effectively ‘bury’ the socio economic effects this is what is said: “…..with some of the other sections (e.g. wider issues, socio-economics) moved towards the back;” this implies a deliberate down playing of the socio economic effects in rural communities.
Item 10 endorses the proposals based upon the evidence presented in the technical case, which as was said at the outset has been taken on face value. The work carried out by John Eardley has demonstrated that the NRW data is deeply flawed and skewed in order to support their proposals. The justification for the bylaws is based upon data which is primarily from the 2014/2015 fry and parr counts which CEFAS have commented had been affected by the prevailing climate over those two spawning seasons, the reliance on Catch per unit effort (CPUE) in order to determine run size has also been skewed due to water conditions during the past few years which were not conducive to successful fishing. It was also declared at the NRW Board meeting in Bangor that the NRW electro fishing sites were those primarily used by grilse, this has again skewed the results in favour of the NRW proposals. There has been no mention of the improvements in fry and parr counts from the 2016 spawning season or for that matter the 2017 spawning season. Unless avian predation and agricultural pollution is addressed there will be no improvement in salmon numbers in our rivers and the CPUE will drop as fewer anglers will be fishing, this will further skew the assessment of salmon stocks in our rivers.
Finally in item 11 there is a comment that recognises the need for stakeholder support for these proposals, the way the stakeholder objections have been dismissed by NRW means that it is unlikely that NRW will get any co-operation from its stakeholders. This is what item 11 says:
11. In view of the detailed nature of the proposals, it seems likely that there will be a need for increased dialogue with stakeholders and enforcement effort once the measure come into force and become embedded.
Feel free to distribute this, it may be useful to send a copy to you local AM’s.
Email reply to Chris from Guy Mawle
Chris asserts that: ‘After 20 years of compulsory catch and release (C&R) for spring salmon there has been little or no improvement i.e. restrictions on angling has made little or no difference in reversing the decline,..’
and in his letter to the Minister that: ‘The evidence from 20 years of compulsory catch and release for spring salmon demonstrates the futility of the recommendations in achieving the desired outcome’.
These claims are misleading and don’t stand up to scrutiny across the country. They are similar to a comment made in an article in Trout & Salmon last year, which I responded to in the letters column, see attached. On a local level, here’s a sample of last year’s fly fishing on Isca Angling Club’s waters on the Usk: https://www.youtube.com/watch?v=8D7bUQ4ugxw , as filmed by the club chairman; most are multi-sea winter (MSW) fish which would have entered the river before 16 June. The grilse runs have crashed.
However, the real issue for me is what action NRW and Welsh Government are going to take other than restricting angling. If it’s little or nothing, then I agree that there’s little point in pursuing mandatory c&r all season, as the gain will be relatively small on many rivers. In the face of poor marine survival, for grilse now, and extreme conditions in-river, as in November/December 2015, we need to make all the gains we can across a range of factors. Though the gains may be small individually, together they may be enough to sustain our fishing and the wider benefits.
In relation to the Usk, one gain that is being ignored by NRW, and more especially the Environment Agency, is the benefit of further restraining the Severn Estuary fisheries. A substantial proportion of the catch in this mixed stock, cross-border fishery is destined for the Usk. Indeed, I believe that the EA even intends to allow an increase in the allowable catch in 2018. I’ve formally objected to the EA byelaws myself and provided a document for the Usk Fishing Association, the Angling Trust, and others in support their own objections to these byelaws.
Email Reply from Chris White to Guy Mawle
I accept that there has been an upturn in MSW fish entering our rivers the problem is the claim that this due to C&R to 16 June cannot be substantiated. There is very little fishing effort until after 16 June and by then the fish which enter the river in Feb/march are almost impossible to catch once they take up residence in the deeper pools. The fish that run in May/June do get caught as do the summer salmon which arrive in July/August. I fish on Scottish rivers (Dee/Spey/Tweed) the Dee and Spey operate C&R and have been doing for the past 20 years – their salmon are also in decline. The sudden lost of grilse and 2 SW fish which return in the autumn tends to indicate major loss at sea. If this has been due to climate changes there should have been a variation in the numbers returning. In the case of the Tweed there was total collapse of the autumn run 4 years ago and this has continued into 2017. This tends to indicate the possibility of high seas netting on the migration routes. There are many pelagic trawlers operating in the Norwegian Sea fishing for mackerel and blue herring. Some of these trawlers operate in pairs with bag nets which can be up to 20Km with GPS these trawlers once they find a migration path can set their nets in the same place every year, if the migration routes are those used by both mackerel and salmon then a by catch of salmon may be occurring, whether this is a deliberate of accidental catch will never be known. Lets assume salmon are intercepted by paired trawlers using a bag net set at say 50ft when the bag is drawn closed any fish caught will be damaged (crushed) so even if they return salmon accidental caught the chance of survival will be slim.
I attended the salmon seminar in Penrith organised by the Angling Trust at which the Atlantic Salmon Trust presented a paper on the radio tracking of smolts from the Deveron it was believed that the smolts on entering the sea would turn left and head North, they don’t they turn right and head south before heading across the North sea towards Norway. I suspect that returning salmon will follow the same route. The work of the SALSEA project demonstrated that smolts from West coast rivers travel around Scotland to their feeding grounds in the Norwegian Sea around the Faroe Islands. The return of adult salmon presumably follows the same route, this exposes them to Pelagic trawlers intercepting the mackerel shoals.
The MSW fish feed initially around the Faroe Islands but then head North West to feeding grounds around Greenland. The MSW fish return prior to the operation of Pelagic trawlers and so there is no accidental catches. In terms of evidence I have downloaded many research papers on salmon. I have attached one paper which looks at the effect of stopping the drift nest around Norway and Russia and how the Baltic rivers recovered. What is significant about this paper is it describes what we are seeing in our rivers i.e. the loss of grilse and 2SW salmon.
We have enough spawners returning to exceed the conservation limit on most rivers, I have attached two papers from consultants which we engaged to look at the statistical model used by the EA/NRW, I am not a statistician but the results hinge around the use of Bayesian techniques and regression curves. I have pointed out to both NRW and the EA that the issue is the survival from egg to smolts reaching the sea, this is what needs to be addressed but there is no appetite to take on agricultural pollution or saw billed duck predation, instead they impose draconian measures on anglers. I agree that we should return all of our fish but this should be voluntary, most already do this. The fishmongers will continue to kill fish irrespective on any byelaws in the sure knowledge that they won’t be caught.