Thought some of you might like to see a response sent in by a long time Wye angler who has given a lot of thought and taken the time and trouble to make a detailed response to the NRW anti stocking policy. It covers a lot of ground and I just hope they take the time to read it.  Not much of it you could argue with in my opinion.   It does mention photographs Fig 1 to 6 which I have been unable to reproduce so far.


Dear Sir
As an amateur angler and long time passionate observer of the river Wye its habitat and wildlife, I
write in response to the NRW’s review of salmon stocking, and hatcheries. My aged experience and
therefore concern relates specifically to the sustainability of salmon in the Welsh/English River Wye.
Unlike most other British salmon rivers which usually fall fast to the sea over clean bedrock, the Wye
is extremely different, even unique in many aspects. For example few of Britons salmon rivers run on
such a shallow gradient, and so far through the likes of the extensive, flat, thick and fertile Hereford
flood plains. Because so different in made up from those to which you’re scientific evidence relate,
and because of its SAC status, Britten’s favourite river demands a different and therefore greater
degree of specialised consideration and action.
My observations began in 1961when I first noticed the clear colour distinction between each
individual pebble forming in river gravel bars and riffles. All were clean, bright, and almost sparkling
in appearance. Lots of little fishes and other creatures appeared from beneath, or disappeared into the
obvious gaps under, and between these rounded pebbles. In fact these permeable gravel areas were
nothing, if not perfectly suited to the hive of natural aquatic industry forming a thriving ecosystem.
That’s how natural, clean, pure, individual and permeable, the Wye gravels were in the 60s, when
salmon were abundant.
When I stand in the river today the gravels beneath my feet are no longer individual sparkling
grains, but covered in dust, missing only that cement element to qualify in consistency as concreting
aggregate. Despite the Wye and Usk Foundation’s commendable efforts at upstream habitat
improvement for so many years now, the once magnificent river Wye now runs as a disgraceful and
abandoned shambles.

Figure 1 A neglected riverbank bombarded by drift wood at Glasbury. Figure 2 more driftwood at Bredwardine
Figure 3 shows part of a large driftwood bank laying Figure 4 the same driftwood a week later, note the
on top of a gravel beach. In the background the remnants abundance of silt creating Himalayan Balsam. I
of a once prominent crib now lie in ruins. The gravel bar estimate 36,000 plants.
in the river below, is brand new at 2014.
Figure 5, thick silt and driftwood cover yet another Figure 6, clouds of clay only gently stirred
once pristine gravel beach. from the heavily silted Wye gravels.
These are only some of the amateur observations and facts upon which my answers to your
questions are based, never the less, and unlike your facts which do not relate to the river Wye, the
evidence I offer is absolutely true, and highly relevant to the self sustainability of Atlantic salmon in
the unique river Wye.
Q1
I am sure both effective and ineffective mitigation and enhancement stocking evidence, is available
throughout the world. On the Wye there is no evidence available which proves the current SNR
stocking system is ineffective. In fact from over 170 titles within your ‘bibliography of papers
relevant to review of hatcheries and stocking’ only 3 titles refer specifically to the river Wye. So your
definition of effectiveness along with your conclusions which may well apply to other rivers, cannot
possibly apply to the river Wye. From my relentless amateur observations I can however offer some
evidence that SNR stocking is working very well indeed on the Wye. From some 4,500 (roughly
equivalent to 1 salmon brood) smolts released from the first pond in 2012 one female grilse was
caught in 2013 by rod. During that spawning season I personally witnessed 2 other fin clipped and
larger grilse than the one caught, spawning in the Donahug, a tributary which drains the first SNR
pond. If at least 3 grilse returned from the sea, and with the 2 and 3SW adults still to come, and even
if only one of each does so, then SNR stocking on the Wye will achieve a greater return percentage
than many wild salmon spawning in the rivers pathetic gravels. I say SNR stocking must therefore
continue until its efficiency can be proven beyond doubt, one way or the other. You will then have
some factual evidence at your disposal.

Q2
The crux of this question seems to rely on providing evidence that stocked salmon do not impact
negatively on wild salmon, and unless sufficient evidence is forthcoming within this consultation, you
might feel justified in ending all stocking. That threat seems grossly unjust when you know there is
absolutely no convincing evidence yet available one way or the other, on the Wye.
We do know Wye salmon both wild and stocked do not reach the sea in sustainable numbers, because
things are drastically wrong in the river. If your claim that hatchery reared stocked salmon return as
adults to spawn in even less numbers than wild salmon, and also impact negatively on wild stocks is
correct, them something must also be drastically wrong with the hatchery system. Surely your first
aim through your declared ‘principles of sustainable development from the outset’ must be to identify
any and every potential problem within the entire stocking system. This new approach should be
aimed at no longer breeding out that natural wild fitness ingredient, but strive to retain the fitness
within all artificially reared stock. That to me would be a positive way forward from the onset, not a
negative backward step by yet another new authority.
To this end I belief, the practise of catch up, hatching and release, even from SNR ponds, is so
lacking in expertise it probably does contribute to the partial domestication of hatchery grown salmon,
and perhaps to that degenerative loss of fitness your evidence declares.
This is how I see the failure of the present practise on the Wye. We begin by catching up Wye
salmon, fine. Then the system begins to fall apart. We ship the brood stock to a hatchery fed by the
different scented waters of the Usk catchment. Things then go really haywire. We place the fertilised
eggs in flat bottomed incubators, and then cram the hatched fry to grow on to the parr stage, in
singular, boring, and completely alien, plastic containers. Eventually, we subject these pars to another
highly stressful overland journey from Usk scented waters, and release them into the strange, and
what must be bewildering scents of the Wye catchment waters. To me, and I am sure to every other
concerned layman, this entire system forms a crazy, unnatural, and surely genetically upsetting
practise, and one which has little option, other than to lower the infants in built ability to evolve into a
purely wild creature.
I firmly believe the NRW through a new and more purposeful change in stocking practise; have at
their disposal a golden opportunity, not only to fix the problems your declared evidence uses against
stocking, but in doing so to become world leaders in the field of ongoing salmon hatchery
management. Mitigation stocking initially arose to compensate for the loss of habitat above the Elan
dam. The reason for stocking now a day’s, must be to compensate for all the other ongoing damage
we have done, and are still doing to the salmon’s environment. It is exactly in this dam location I
think that golden opportunity can arise. Therefore, and at last to truly make amends for the salmon’s
inability to sustain their population throughout the entire and generally degenerated catchment area.
The Elan complex already encompasses many established organisations, operating in several different
fields, and attracts hundreds of thousands of interested visitors annually. It even encompasses a well
attended and established modern learning centre. This entire site is conveniently aquatic based of
course, and usually manned. So, with the WSA funders, helpers and volunteers, the declared
commitments of the WUF, support from the WSFOA, along with the interests of international angling
organisations, local business, local angling clubs, the water authority, recreation, tourism, etc, etc, and
of course the inquisitive public who travel to Wales from far and wide. All these could well form part
of that collaboration you say you particularly welcome in Q8. I feel sure; a new innovating hatchery
here, and at other similar public sites I have identified, would not only generate huge public,
specialised, and perhaps even worldwide interest, but through good management, also provide
funding for a new stile hatchery. This golden opportunity to develop your skills, grow your
knowledge, and at last repay the salmon for the devastating neglect we are still causing, is surely up
for your, or third party grabs.
I am of course unqualified to describe the exact workings of my imaginary hatchery/growing
media, and of course if I can imagine it, then others must have done at least the same before. I
envisage its creation, working, and initial purpose as follows. Catch up would continue, but from the
mid/lower parts of the river where spawning gravels are shamefully saturated with life threatening
clay and sand, and egg mortalities highest. Initially the numbers of catch up would suit the hatchery
capacity, say 12 of each gender. These fish would be placed in a new narrow and artificial river
channel constructed within the local flood plains below the dam, or other up river waterfalls, and of
course maintained to the salmon’s absolute needs. That local head of water could then feed and
regulate channel flows, while water quality is manually controlled. This narrow channel, say wide
enough for 2 reds, would empty into the Elan, or a main stream, and contain deeper holding
pool/pools/SNR ponds as well. Above/between the holding pools, pristine gravel areas would
comprise of exactly the adult salmons spawning requirements. Those introduced ripe caught up
salmon would then wait in the holding pool until they alone naturally decided when ready to spawn.
Rather than beginning the transportation to and from the Abercynrig hatchery, the stripping and
fertilising of eggs would take place at each individual site. Finally I envisage the fertile eggs, at some
stage of development being carefully introduced into the pristine gravels, and allowed to hatch
naturally through perfect gravel beds, no longer found in the river.
If eggs can be hatched, fed on, and reared successfully to parr in common plastic tanks with a
survival rate of about 80%, then surely a similar survival success rate can be achieved in this more
natural, but pristine, and protected artificial channel environment. This more natural rearing would
surely result in the retention, not the abstraction of far greater amounts of wild instincts. If the excess
of naturally grown on channel parr were then stocked into the numerous existing SNR ponds, I feel
sure these parr would be far superior in wild instinct than the present hatchery reared stock. The
returning rate of adult prodigy would surely also increase beyond that of hatchery reared stock. Even
when mating between subsequent SNR reared and wild salmon takes place naturally, the impact upon
the laid eggs should also be far less negative than your present claims.
The overall purpose of this type of system is by retaining the wild fitness within stocked salmon, to
restore the population’s self sustainability. If this fitness can be monitored through the modern means
your bibliography mentions, then surely, a far greater percentage of channel/SNR reared than wild
smolts, will head for the sea. A far greater number of more viable adults should return to naturally
stock the river on a healthier ongoing basis. Only then will you hold sufficient hard and fast evidence
to justify the future need for SNR stocking.

Q3
I am unsure of who is responsible to maintain the Wye in a favourable condition for salmon. I think
when those fishing structures (cribs, concrete banks etc) were placed in the river; permission had to be
gained from the authority beforehand. If I am correct then surely the responsibility to ensure their
present collapsing existence does not become harmful to the riverine environment, remains with the
new NRW. Judging from the ongoing degenerative state of the river, I think prosecutions should be
brought against those responsible. The river Wye is most certainly a failure within its designed
legislation.

Q4
This question is unclear because it does not state the desired natural ecosystem balance you are trying
to achieve. If the ecosystem is to cater for the successful breading and life style of invasive fish eating
birds, American Cray fish, egg eating barbel, silt stirring carp, blooming and silt creating Himalayan
Balsam etc, while allowing passing canoeists to de-head vast quantities of Renunculus seed heads,
and create unnatural river draining channels in doing so. Then the current ecosystem seems perfectly
in balance. On the other hand if an ecosystem approach is geared to establish an environment where
indigenous species such as salmon, gudgeon, shad, silver eel, White clawed Cray fish, Bull head, etc,
are to thrive, while protecting river water retaining Renunculus Weed from passing canoeists. Then
the present ecosystem is completely out of balance. Any responsible attempt to replenish any
dwindling indigenous species, or their habitat, cannot possibly be inconsistent with restabilising the
once long standing and highly suitable Ecosystem. An approach the SAC now demands. As long as
the ecosystem continues to change in favour of harmful invasive creatures, and permits mans harmful
interference, then the only way to restore, and maintain the intended workings of that ecosystem, is
through a far better system of rejuvenation stocking. When a new rejuvenated ecosystem can support
a self sustaining population of any threatened indigenous Wye species, only then should that specific
stocking practise, be reconsidered.
Q5

With the Wye habitat in such an abominable state, I most certainly agree that habitat improvement, if
sufficient enough, and in the right place, could not only and quickly, reduce the mortality of wild fish,
but restore the salmon’s capability to sustain their population. Your question however makes no
reference to the actual habitat improvement intended, or to any stated purpose, outcome, or standard
set to be achieved. Because the extent of the habitat improvement needed to create that self sustaining
salmon population in the Wye is so great, I completely disagree that habitat improvement could ever
become cost effective. It is plain to see the entire riverine environment has degenerated to such an
extent the siltation of most spawning gravels are now completely alien to the successful reproduction
of most Wye salmon through the inability of their eggs to hatch. For many past years now the WUF
have attempted to repair and protect some tributaries and head waters, despite the fact that most
salmon in most years never reach these repaired waters. Many obstacles since removed, or made
passable, were actually considered impassable during the salmons hay days when they managed to
reproduce in huge numbers despite. If you ever attempt to restore the river habitat, not to those
pristine days of the 60s and 70s when eggs hatched and parr were seen in vast numbers, but let’s say
to the same habitat state found in the 80s? How will you afford to repair or remove those harmful,
constantly collapsing in river fishing aids and navigation bank structures? How will you afford to
remove and then prevent the recurrence of the masses of destructive drift wood, to no longer pose an
ongoing threat to the natural habitat? How will you afford to convince farmers to change their silt
producing methods, when our food supply industry encourages it? How will you afford to persuade
the highways people to maintain their drains and road side ditches, so run off no longer transports
huge volumes of silt towards the river?
How will you afford to remove the flood confining and therefore silt creating levies aside the river
Lugg, when modern policies demand ever more silt creating flood defences. And of course how will
you ever afford to address all these massif silt creating problems in the face of undoing climate
change? In a nut shell, how will you ever afford to restore the main stem river spawning gravels
where the vast majority of salmon have always spawned, to those suitable enough to naturally sustain
their wild population? I saw the answer is, you will never afford through habitat improvement alone,
to ‘mitigate’ against efficient stocking.
Q6

Again your question misleadingly refers to ‘mitigation and enhancement stocking’ which relates on
the Wye to the building of dams over a hundred years ago, and also to past angling desires for
excessive so harvestable stock numbers. This question has nothing to do with your responsibilities
through the SAC commitment to solve the problems of the modern decline in salmon stocks in
general. This question seems so cunningly contrived and presumptuous; it merely confirms you have
no ideas how to fix those problems, so the outcome of this entire consultation seems obviously a
calculated fore gone conclusion. I consider this state of affairs as a complete insult to my years of
devotion to the river Wye, and yet another power driven degeneration in our so called democracy. I
am so appalled you have conjured such a contemptible question, I am almost of the opinion; I should
take my fishing efforts and finances out of Wales, and back to Scotland.
Q7

There are many simple but basic fundamental visual features and facts which are currently
contributing to the demise of the river Wye habitat on a daily basis. Most of which I suspect you will
not even have considered. Like how the old council road man armed with only a shovel and broom,
once prevented thousands of tonnes of silt from entering our rivers. He is now long gone. Today if the
spasmodic arrival of the digger can’t manage it, then the attitude is, to hell with it, just leave it alone.
Drift wood during the 70s and 80s was so slight in quantity; it caused only minimal bank, riverbed
erosion, and siltation. The amount of today’s drift wood, and the tremendous damage it does to the
riverine environment, including spawned gravels and creating silt, has exploded probably 50 fold
during the last few years. The disgraceful fact is, much of this modern drift wood can be clearly
identified as purposely dropped litter, from its obviously sawn ends. How will you overcome that
shameful human attitude? The now old fishing cribs, stone and concrete covered banks, along with
more ancient navigation wharfs, were once so well maintained by numerous gillies, the riverine
environment changed little for over 50 years. Today these structures are continually falling apart and
into the river, so the present riverine environment, habitat and ecosystem are constantly degrading as a
result. How will you remove or repair these now neglected and again silt creating structures. My
greatest fear is, that you will blindly attempt to replace mitigation stocking with unachievable habitat
improvements, but then fail to achieve a healthy CL when an improved rejuvenation stocking system
could provide that successful alternative to mitigation stocking.
On the other hand the success rate of the current SNR mitigation stocking system, achieves around
76% survival from egg, not only to parr, but to the smolts stage. I also believe that new, and more
natural replenishing river channel system I mentioned in answer to Q 2 could achieve similarly high
escapement figures. So, if your intention from habitat improvement through efforts and resources is
somehow to achieve the declared CL figure, and if proved successful, then I will eat my shoe.
However for any failure to achieve that appropriate conservation limit through inferior, or insufficient
efforts or resources, I for one will hold the NRW in breach of their inherited ‘special area
conservation commitment’ which relates to the River Wye.
Q8

If to become the only hatchery in Wales, then Abercynrig must remain operational, thus able to cater
for any catastrophe within salmon stocks. With the hatchery currently staffed and operational, I
believe it should not only continue its research work, but expand that experimentation into addressing
better ways of retaining those wild instincts within hatchery salmon before release. There is however
one site that would not only benefit from substantial and specific habitat improvement, but the very
site which created that now outdated mitigation agreement in the first place. It seems so strange after
17 years of WUF efforts at habitat improvement, their efforts happen so far away from the desperate
and neglected river Elan, the instigator of mitigation stocking in the first place. This short little river
has no source of replenishing gravel below the dam. What little has remained in the river is now either
compacted so heavily, or lies in a position where the spawned gravel dries out, that spawning activity
is usually slight, and often completely worthless. I suggest habitat improvement work in the form of
gravel restoration, begins immediately, and regardless of any outcome from this questionnaire.
I feel this sincere amateur response deserves a reply.
Ian Spalding