The following representation is from Merthyr Tydfil Angling Association and represents views brought up in both the Usk and Taff Local Fishery Groups. Not all those in the Usk Group had the same views but some did agree with us.
These Groups although not Statutory are recognised by Natural Resources Wales as sounding boards for advice.
Catch Controls: byelaws for Nets and Rods 2017
The general opinion from both these committees, we do not claim all are in agreement but in general the comments reflect that Anglers are not in total agreement with the proposals.
All those who sit on these committees have many years of knowledge of the Usk system and in some cases feel that other factors that are equally damaging to fish stocks, the answers to which have been avoided for years should be considered. One of these is Fish eating birds and their control. Natural Resources Wales have now stated that at least 50% from surveys of sea running smolts are lost to these predators.
The current staffing of Natural Resources Wales on enforcement is totally inadequate due to cut backs and unless adequate protection is afforded to the current Salmon/Seatrout stock then any restrictions on anglers will not achieve any benefit.
The current spate during 2016 and early 2017 of agricultural pollution incidents is another problem
There appears to be reluctance by NRW, and indeed the Welsh Government, to recognise this.
Do you agree with Natural Resources Wales salmon and sea trout stock assessments?
Not on some rivers as the figures do not bear out claims being made by Natural Resources Wales. The blunt approach is neither scientific nor proportionate and appears to be a catch all so Natural Resources Wales can appear to be doing something. Natural Resources Wales have agreed that the problem is not with the fishermen but yet again they expect, without mentioning or even attempting to tackle other problems, that the anglers must bear the brunt of the new restrictions.
There is ample evidence that increasingly fish aquaculture farms are causing major problems but no effort is being made to control it. Why?
Please tell us if have any evidence to support a different stock assessment conclusion.
The current catch returns are showing evidence of more fish entering some river in 2017 making the catch all restrictions as just being a method for Natural Resources Wales to simplify the new bylaws and not act as the evidence based organisation they profess to be.
Do you support the proposed Net fishing byelaws? Byelaw 4 – Catch and release with nets (salmon).
Some proposals for restricting the netting season and fish sizes will make a difference. However the Environment Agency in England and many other countries have taken far more drastic action against netting imposed bans.
The proposal and acceptance of the netsmen to return all net caught salmon goes against all the guidelines issued by Natural Resources Wales to anglers on the release of fish. The care they ask anglers to take cannot, due to the way net fishing is carried out, result in any net caught salmon surviving. We would ask that Natural Resources Wales produce any evidence they have of research to prove this?
Q(3b.) Do you support the proposed rod fishing byelaws?
We support elements in the proposals but feel again that some are being put forward without the necessary scientific evidence so often asked for by Natural Resources Wales when anglers make suggestions.
Angling brings added value to both conservation and to the local economy that both support local angling and improve conservation of stocks. The heritage argument to preserve the status quo regarding net exploitation has been the main reason given for the last twenty years and before when any new bylaws are proposed. This only protects the interests of a very limited number of individuals to exploit a diminishing stock, the catch returns for the nets show how many fish could be saved if as in England, Wales was prepared to act in the same manner. We cannot see any added value from the net fishery either in terms of the local economy or the measures. The promise to return all net caught salmon, a questionable promise, taken by the net fishery to aid conservation is to coin a phrase a Red Herring.
We will deal with this in some of our answers below.
Byelaw 4 – catch and release with rod and line (salmon)
We are opposed to the mandatory catch and release proposal due to the fact that the current use of it as a tool to saving more fish is not borne out by the two rivers that already have it in Wales the Taff and the Wye. The figures for the Taff this year are very low and the Wye has not done as well as the previous two years. On this basis catch and release is not the problem. It is very quickly showing that some of the problems highlighted by Anglers in the last ten years not tackled by either Environment Agency or Natural Resources Wales are more of a problem than anglers.
Anglers do much to help the conservation of salmon and sea trout as well as the aquatic and riparian environment. The removal of in river obstructions to upward migration as well as being a presence that discourages poachers. The fact that more and more Natural Resources Wales are asking the angler for intelligence for them to carry out their statutory duties shows that they are understaffed. If and we suspect that this will happen on many rivers if Catch and Release is adopted, anglers stop fishing, then the intelligence will also come to an end.
Byelaw 5 – catch and release with rod and line (sea trout)
WE think that those who fish those rivers that have a sea trout run are best to respond to this.
Byelaw 6 – Size limit sea trout
We have some knowledge of this and welcome the introduction of an upper size limit of 60 centimetres it would protect large mature sea trout which are capable of producing large numbers of eggs. We agree the proposal to move the commencement of seine and coracle netting from the 1st March to 1st May however we would prefer that netting is banned. These measures would together provide protection for a stock which appears to have declined in recent years. Many anglers have been releasing such fish for some years and some associations require this and others encourage it.
Byelaw 7 – No bait fishing
This prohibits the use of bait for salmon. It prohibits the use of bait for sea trout before 1st May. Bait fishing for sea trout would be allowed with a single worm on a single hook with a gape of 8 mm or less after 30th April. We question the banning of worm fishing for salmon but allowing worm fishing for sea trout is not what can be described as logical thinking. Fish whether Salmon or other will take a worm. You already have the classic issue of this on the River Usk where worm is allowed for trout fishing but not for Salmon.
All worm fishing for salmon and sea trout fishing should be prohibited until stocks recover. We understand that the survival rate for worm caught fish is very low. The survival rate for fly and spinner caught fish is high.
Shrimp and prawn fishing catches mainly salmon, and a very occasional mature trout. It does not catch immature fish. All fish are hooked in the mouth, usually in the scissors. All can be returned with little harm. We understand that some surveys have been carried out on the use of Prawn and Shrimp in Ireland that show a positive light on these baits. It will also give those who like to fish with bait the opportunity to carry on fishing. This in itself will help to keep more anglers on the rivers of Wales.
The surveys in Ireland by fishery scientists showed that salmon were caught in the upper part of the jaw or lower jar when prawn or shrimp fishing. The salmon were then released with no adverse effects to them. This was far better than worm fishing where the bait is often taken deep within the salmon and has a high mortality rate if tried to be released.
The banning of prawn and shrimp was overturned due to the evidence submitted.
With a number of elderly anglers in the club who have contributed for many years with their licence money. They now find it hard to wade rivers due to being infirm and unsteady on their feet.
They still hold the enjoyment of fishing very high and for them to be able to sit on the river bank for several hours is a pastime that we cannot take from them and should not.
It can also encourage people to fish when club membership is waning and more could be lost due to the constraints imposed by the NRW.
Byelaw 8 – Hooks
This byelaw amends byelaw 10 of the 1995 byelaws and:- only allow fishing for salmon and sea trout with barbless or debarbed hooks prohibits the use of treble hooks.
We are in agreement with this but question and ask how will Natural Resources Wales enforce this and all the other new regulations with current staffing levels? The banning of trebles will certainly save fish.
Please tell us if you have any further comments that haven’t been covered by the previous questions.
We welcome the fact you have asked for further comments:
We feel that the present status of catch and release should be maintained. That the taking of any salmon after the 30th August should be added to the proposals as by this time many fish are gravid in any case. This would reduce the window of when fish can be taken to three months of the year.
The move to bring the new bylaws in for Ten years is not only unrealistic it just looks like another Natural Resources Wales move to reduce their monitoring and assessment of stocks.
In the past the monitoring of fish stocks was viewed and an essential part of the work of body that was set up to improve and maintain fish stocks. We are referring to the National Rivers Authority in the Nineties; the Environment Agency after that. Today monitoring is if carried out is being done on a shoe string. We now more than ever need to carry out the programme of monitoring that was employed over the years. Evidence for the need to do this and to show how critical it is has come to light this year when it was suddenly discovered that in some brooks there were no Salmon fry. What a surprise when, and we do not blame staff on the ground, cost and decisions by people who considered fisheries management as a low priority reduced monitoring.
We suggest therefore that Natural Resources Wales relook at the way they view their remit on the fisheries function. This is critical if they wish to live up to their claim of protecting and enhancing the environment in Wales.
a/ Taff, had prior to the barrage, a substantial (unreported) run of migratory fish. Black weir used to hold a large shoal of salmon which was heavily fished for by illegal “angling”.
b/ Absence of fry etc in spawning brooks. Local intelligence informed the Usk LFG in 2015 & 2016 of heavy predation in these brooks by poachers, namely at, Trecastle, Senni, Yscir and Tarrell. Lack of enforcement on the ground due to cut backs left these areas open to poaching.
Tony Rees P/P Merthyr Anglers. 804 members.
Anthony Rees MBE
13 Alexandra Avenue
Merthyr Tydfil. Mid Glam
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