How much better if there were some insurance in eggs laid down in the safe environment of a hatchery. Ah well.
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See below some pages from the report by CPWF to the forthcoming enquiries on the new proposed byelaws. The full report is 70 pages long. Its comprehensive, well researched, objective and one of the best summings up of the situation in Wales there has ever been. A huge amount of work has taken place and it authors, Chris White' John Eardley and Alan Cuthbert and I suspect many others involved , deserve huge credit
The whole document can be seen here on the link below.
Pages 31/36
Do Catch and Release and method restrictions work?
There is no evidence that catch and release has been effective, had this been the case the net buy-outs on the rivers Clwyd and Dee would have seen a marked improvement in salmon stocks (nets have a 100% kill rate). There has been no improvement in salmon stocks in the Clwyd since the net buy-out 20 years ago or the Dee since the net buy-out 12 years ago. Neither river system saw an improvement in egg deposition; there was no improvement in angler catch returns once the nets removed. It is not the numbers of fish spawning that aDo Catch and Release and method restrictions work?re the key issue it is the survival from egg to smolts reaching the sea (see Fig1 on page 6) and the proposed byelaws do nothing to address this.
The evidence after 20 years of the compulsory catch and release regulations introduced in 1997 on the Wye and nationally in 1999 coupled with method restrictions (on some rivers) has seen little or no improvement in the spring stock or a reversal in the decline of salmon in our rivers. There is no evidence that extending catch and release and more restrictive fishing methods will reverse the decline in salmon numbers. NRW fisheries officers recognised this as did the Centre for Environment, Fisheries and Aquaculture Science (Cefas) who in an email, obtained under an FOI request, dated 6 July 2017 to the head of the Welsh Government Inland Fisheries Department (Jeremy Frost) Cefas said in their review of the NRW technical case:
“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 C&R until 16 June there has been little or no ‘accumulated benefit’. This is hardly an overwhelming endorsement of the proposals and yet Cefas considered that the proposals “…appear proportionate and reasonable”. …”The measures have also clearly been designed to ensure proportionality in balancing the interests of both net and rod fishery sectors…” i.e. anglers have been restricted to. From a purely technical, desktop exercise the proposals may appear to be proportionate and reasonable but in the real world situation the proposed method restrictions are disproportionate as the majority of salmon anglers are voluntarily returning most of their salmon so the proposals are also unreasonable.
In closing their comments Cefas says:
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“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”
Increased dialogue with stakeholders has not happened despite this being requested by the NRW Board at the meeting following the Board approval of the byelaw proposals. In addition, it will be extremely difficult for these byelaws to be enforced due to a lack of resourc5
The claim by NRW that, if catch and release for spring fish had not been imposed the situation could be worse, cannot be substantiated. Despite C&R being imposed on the Wye in 1997 there has only been a moderate improvement, whether this has been due to C&R or habitat improvements is unclear. However if after 20 years of C&R there has been no significant improvement in the Wye salmon stock then extending this restriction makes no sense.
We can find no peer reviews to validate that either C&R or method restrictions are effective. It is noted in the NRW papers that reference is made to three papers (Lennox et al) describing the catching of broodstock at the end of the fishing season and the fitting of radio transmitters to monitor where these fish spawn. The Lennox paper refers to the monitoring of escaped salmon from fish farms in Norwegian rivers with salmon being caught in cold water conditions. Of the 39 salmon caught by rod and line in the Lennox paper two died due to damage from hooks despite the use of fly and spinning baits by experienced anglers. In terms of survival Lennox refers to the radio tracking which took place on the Scottish Dee. The report on the Scottish Dee claims that 80% of the salmon caught survived to spawn (they were all caught on artificial flies), however these fish were caught after the close of the fishing season when river temperatures were low. The Scottish report also records the type of hook (double or single) and the position in the mouth that the fish were hooked. It is not known what the survival rate is for salmon caught mid-season with warmer river temperatures.
The Scottish Dee has operated a voluntary catch and release regime for more than 20 years coupled with a fly fishing only rule and achieves a 99% return rate. Despite these voluntary measures the Scottish Dee has seen a steady decline in the numbers of returning salmon (based on accurate catch returns from estate records who control the fishing) in common with other UK rivers the numbers of avian predators have increased on the Scottish Dee during this period.
The experience of 100% C&R coupled with a fly only rule on the Scottish Dee demonstrates that catch and release and method restrictions proposed by NRW are not the answer to reversing the decline.
The principle of catch and release is well understood but, if a fish genuinely cannot be revived, returning it to the river dead is a shameful waste of a food resource. NRW imply that, without legislation, anglers will not refrain from killing too many fish, but this is not borne out in practice. In the Technical Case prepared by NRW they state that 86% of all salmon caught in Wales were returned alive in 2017 and on some rivers the release rate is over 90% and yet these rivers are declared as ‘being at risk’.
Legislating on method restrictions is seen by many as being a deliberate attempt to drive anglers from rivers and shows little knowledge or concern of the smaller Welsh rivers, decisions seem to be substantially based upon the river Wye which is in many respects unlike almost all other Welsh rivers.
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Angler catch returns are notoriously inaccurate i.e. not all anglers submit a return, some returns are not accurate, so there is no certainty of the actual numbers of salmon caught by anglers and yet this is a key parameter in assessing stock levels. It is clear that NRW are basing their decision on the output from the river classification model which we believe to be flawed.
CPWF are quite clear that the Technical Case options for sustainable management have not fully considered the range of options open to restore sustainable stocks, both in terms of voluntary options and other enforcing measures that will secure rod fisheries’ cooperation for the future management of the fishery. The greatest losses are due to poor water quality, mainly due to diffuse pollution from agriculture in spawning streams, predation and marine survival, angling has least impact and yet this is the only target area for NRW.
Causes for the decline in salmon numbers
Whilst nobody doubts the decline in migratory fish stocks in UK rivers, it must be recognised that there are considerable variations across Wales with, according to NRW statistics, only the rivers Taff, Ely and Ogmore showing a year on year decline over the last 3 years (Decline on the Taff and Ely may be due to the effect of the Cardiff Bay barrage).
A study was carried out on behalf of DEFRA by Cefas between 1990 and 2002 entitled Research on migratory salmonids, eels and freshwater fish stocks and fisheries (Cefas Technical Report No 119) (copy in Appendix E). Amongst other issues the effect of the barrage on the Afon Tawe is described in this report. The study on the Tawe was conducted between 1992 and 1994 and was quoted during the inquiry into the Cardiff bay barrage by the then head of fisheries for EA(W) Dr Chris Mills.
Over the past three years 8 Welsh rivers have shown a year on year improvement in terms of percentage of Conservation Limit (CL) attained with 5 rivers exceeding their conservation limit (some achieved in excess of 200% of their CL, see Appendix C)
There are many contributing factors to declining stocks, two of the most significant being poor spawning habitat and marine conditions.
An Interreg EU funded research project (Salmon Management Around the Chanel – SAMARCH) being carried out by the Game and Wildlife Conservation Trust on the river Frome in Dorset make this statement in their annual report for 2017:
Atlantic salmon stocks (as indicated by catches) are declining. For a long time, the finger of blame has been pointed at the marine environment, where climate change and the processes it influences, such as water temperature, sea-level and spatial and temporal variation in algal blooms, are thought to have rendered the environment hostile to migrating smolts. More recently, however, there has been a growing sense that factors affecting juveniles during their development, i.e. in the freshwater environment, might play a larger role than previously judged.
In 2002 the North Atlantic Salmon Conservation Organisation (NASCO) produced a paper entitled: NASCO Plan of Action for the Application of the Precautionary Approach to the Protection and Restoration of Atlantic Salmon Habitat this paper identifies the need to improve spawning habitat in order to increase the survival from egg to smolt (young salmon going to sea) by increasing the productivity of spawning activity.
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“One of the guiding principles of the Precautionary Approach is that priority must be given to conserving the productive capacity of the resource. It is clear that NASCO’s objective, “to conserve, enhance, restore, and rationally manage salmon stocks”, can only be achieved if habitat is also conserved and restored. It is also clear that over the last 150 years much salmon habitat has been lost and this must be a major contributing factor to the decline in wild salmon stocks”.
There were (and still are) sufficient numbers of adults returning, despite angling exploitation, to re-populate rivers, but it is poor survival from egg to smolt coupled with increased in-river predation and marine mortality that prevents any significant reversal in the decline. Marine survival has declined from about 20% to a current figure of less than 5% it is unclear how these marine losses have been calculated. There is a risk that the marine losses are being based upon estimated recruitment from pristine rivers based upon flawed data for the number of smolts which reach the sea.
Increasing the survival rate of smolts journeying to the sea would go a long way in mitigating for marine losses. The marine losses are outside the scope of NRW or anglers.
The precautionary principle and the need for significant habitat improvement was re-enforced at the 2013 NASCO conference in Glasgow which claimed that to get more fish retuning, smolt production must be increased, more fish spawning does not necessarily equate to more smolts getting to sea and it is generally agreed that the key to increasing adult numbers is to maximise the number of smolts getting to sea. According to a research paper by Dr Graham Harris, in the wild survival from egg to smolt is 0.4% from which it can be seen that the ‘in river’ losses amount to a massive 99.6% with further losses during the migration of the smolts to sea, mainly from avian predators. Use of hatcheries could mitigate for the ‘in river’ losses as hatcheries can rear from egg to smolt with only a 10% loss. There is however a body of scientific opinion that hatcheries are harmful as they dilute the gene pool, NRW support this theory and have closed all their hatcheries (despite some being run under Acts of Parliament to mitigate for impoundments) and also prevented third party hatcheries from stocking migratory fish on all Welsh rivers. There is no objective evidence to support the argument that hatcheries are harmful when using local broodstock other than the ability to trace the interbreeding of hatchery bred fish with wild fish populations. There are few, if any Welsh rivers which have not been stocked in the past with broodstock taken from other English and Scottish rivers; the use of genetics to demonstrate harm is therefore a convenient excuse for not funding expensive hatcheries where migratory fish stocks are failing to meet their conservation limits.
Due to austerity measures the resulting lack of funding for fisheries has seen little or no improvement in spawning habitat. In Wales the bulk of fisheries monies have been directed to improvements on the Wye and Usk catchments only and the claims made by NRW on habitat improvement and removal of barriers to migration is only applicable to South and Mid-Wales rivers.
Whilst more effort is now being given to North Wales rivers (primarily due to the Water Framework Directive – WFD) it is too little too late and it is now convenient to put the burden on anglers i.e. a zero cost option which agencies such as NRW consider demonstrates they are meeting their statutory obligations, NRW have actually stated that angler exploitation is not to blame for the decline, it seems that anglers are just an easy low cost target.
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Effects of agricultural pollution
Over the past 30 years there has been an increase in the use of fertilisers and insecticides in agriculture both of which, when they enter water courses, have a detrimental effect. In addition, the move from open pasture grazing to cereal crop production sees millions of tons of top soil being washed into rivers and streams. This fine silt washed from fields left bare over winter after the crop is harvested covers river gravels in which migratory fish lay their eggs reducing flows through the gravel and therefore oxygen to the eggs, this results in many eggs failing to hatch. Spraying slurry from intensive dairy farming onto fields, or escapes from anaerobic digesters, will cause a rapid depletion of oxygen if it enters a water course resulting in the death of fish and invertebrates. The spreading of chicken litter from intensive poultry farms is possibly more damaging than slurry as it is rich in ammonia, as is the effect of large free range chicken farms sited close to water courses. There have been too many fish kills on Welsh rivers to ignore this form of pollution and yet the Welsh Government is only just intending to act due to public pressure and now proposes to introduce legislation to minimise the effects of agricultural pollution. NRW are insisting on the need for legislation to restrict anglers whilst potentially ignoring agricultural pollution which is one of the root causes of the decline in migratory fish.
Effects of avian predation
Increased control of fish eating birds (FEBs) would have a greater impact in reversing the decline in migratory fish than the proposed restrictions on anglers, particularly in helping more smolts get to sea.
In the early 1950’s goosanders, that up until then were winter migrants, mostly coastal, started to breed in Scotland and can now be found in substantial numbers on most UK game rivers. Whilst these FEBs are not native to the British Isles they have now become established. In Wales the RSPB (Roger Lovegrove) reported that goosanders first bred in 1970 and by 1977 there were a minimum of 10 breeding pairs of goosanders, now there are over 1,000 pairs on Welsh rivers i.e. 1,000 hen goosanders plus their broods of up to 11, each eating a minimum of 400gm (1lb) of fish per day, in Wales the diet is primarily made up of salmonids. The rate of decline in migratory fish stocks closely correlates to the rate of FEBs increase on our rivers. Effective control of FEBs would have a far greater effect in reversing the decline in migratory fish than the NRW byelaw proposals and yet the NRW as the licensing authority for culling FEBs will not address this.
Recent studies on the Scottish Dee by radio tracking smolts on their migration to the sea demonstrate that there are significant losses to avian predators before they reach the sea; this avian predation is not being addressed effectively. The official policy of NRW is that no more than 10% of an approved count of FEBs will be licensed for a cull with completely ineffective non-lethal scaring tactics adopted in the first instance. Results from the Scottish Dee during their monitoring of smolt migration in 2017 where they used lasers to scare FEBs demonstrated that non-lethal methods are ineffective. Surely it must be obvious to anyone that FEBs scared from one location would simply fly to another location and continue to eat fish. More spawning fish will result in higher numbers of avian predators due to an increase in the food supply.
According to the British Trust for Ornithology (BTO) a goosander chick will eat 33Kg of fish before it reaches maturity, goosanders typically have broods of between 8 and 11,
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so assuming survival to adulthood, a brood of 10 potentially consumes up to 330Kg of fish and in almost all Welsh rivers a large proportion would be salmonids. A typical migrating smolt will weigh approx 28gm. It is estimated that a single chick will eat 1,165 smolt equivalents to reach adulthood. For a typical brood it would take 10,500 smolt equivalents to reach adulthood. At a consumption rate of approx 5 smolts per day 100 goosanders would eat approx 28,600 smolts in a month. During the two month smolt migration period it is estimated that 100 goosanders alone could reduce the smolt output from a river by 42% and there is further avian predation from other birds i.e. herons and cormorants.
As previously stated, on the Welsh Dee, imposing mandatory catch and release in 2017 would have put a maximum of just 39 additional adult salmon on the redds, producing around 156,000 additional eggs resulting in possibly 1,800 additional smolts (due to losses to natural events, predation and pollution) but just one average goosander brood could have eaten all of the resulting smolts in 3 months. The last official count recorded over 140 FEBs on the Welsh Dee.
Effects of mammalian predation
Over the past 15 years there has been a steady increase in the numbers of otters seen on Welsh rivers. Otters mainly eat fish, their preferred prey is eels (they are easier to catch), but the downturn in the eel population sees otters preying more on salmonids. An adult otter will eat approximately 10% of its own weight in food each day and a typical otter will weigh circa 7Kg. A family of otters will kill more salmon on a river than anglers do in a fishing season, many adult salmon will be taken when the fish commence to spawn as they are easier to catch on the shallow spawning grounds. Whilst otters are a natural predator, as their primary food source (eels) is reduced, they now take a disproportionate number of salmonids.
In addition to otters there are now large seal colonies around the coast of Wales that intercept both migrating smolt and retuning adults. There are an estimated 600 seals on Hilbre Island in the Dee/Mersey estuary. We now have a large population of small cetaceans (dolphins and porpoises) feeding around the coast of Wales and these also exploit salmon and sea trout stocks at sea, more recently Orca and Minke Whales have also been observed. All of these predators have an impact on salmon stocks which far outweighs that of recreational angling.
Existing Byelaws
We draw your attention to the existing byelaws which are both proportionate and reasonable. The existing byelaws are river/region specific with each river system having its own unique set of byelaws which recognises local conditions e.g. differing season start and finish dates; method restrictions appropriate for each river and closed sections above and below natural obstructions. The existing byelaws cover 12 regions/river systems (a full copy can be found in the NRW document POL_26 Rod Fishing Byelaws 2018 – A guide for anglers in Wales) and are used by local clubs to set rules for the fishing under their control, anglers are well controlled and fully understand the regulations they abide by. Below is a part copy of the table defining the fishing season for salmon on the rivers shown:
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