Page 4.

See below the document submitted by Mr Jerome Vaughan and note how he so easily disassembles the EA guidelines and exposes their falibility when given proper expert scrutiny.

The arguments against hatcheries

Schemes to stock river with salmon, sea trout and brown trout from locally sourced broodstock

EA Guidance 15.03.2011

Ref Page	Section	Document quotes	Comment
1	What’s this document about?	This guidance helps staff determine fish removal and fish introduction applications to stock salmon, sea trout and brown trout derived from local broodstock rearing schemes.	Noted
3	Disadvantages explained	Reference to Ferguson, 2007 “Population specific smolt development, migration and maturity schedules in Atlantic salmon in a natural river environment” Reference to Fraser, 2008 “Mixed evidence for reduced local adaptation in wild salmon resulting from interbreeding with escaped farmed salmon: complexities in hybrid fitness”	It is not clear which papers are being referenced, the two provided are all I was able to find. The Fraser 2008 paper does not deal with hatcheries raising wild salmon, rather cross breeding of salmon escaped from farms. Please confirm which papers are being reference in this paragraph
3	Advantages explained	None given	Please confirm why a corresponding section has not been added, with appropriate literature references, to give possible advantages
17	Scheme consents	We will only consent schemes which give rise to less than 1% of any component of a salmonid stock, since we believe that the risks involved in such small interventions are negligible.	Restricting scheme sizes to this level is de minimis in relation to the river and cannot be considered a true test of stocking efforts.
Please confirm how this document can claim any scientific basis to its conclusion and policies if, it has chosen to only reference arguments and data against stocking. If there is no scientific basis for support of stocking, this should be explicitly stated.  If there are scientific papers providing support for stocking programmes, why have these been neither discussed nor referenced?
Environment Agency, The role of stocking in the recovery of the River Tyne salmon fisheries
5	Introduction	However, some accounts have emphasised the role of the hatchery (Marshall, 1992; Carlton & Francis 1992; Carrick and Gray, 2001) while others have suggested its role may be less important than natural processes (Champion, 1991; Environment Agency, 1997).	This account does not tally with the Papers produced by Natural Resource Wales  v.4:  10.3.14, which shows overwhelming scientific support for Hatcheries (25-papers for 10-against)
	Introduction Para 2	An objective description of the recovery, evaluating the influence of the stocking programme and other factors, has never been carried out.	1.       Objective evaluations have been carried out and are referenced in the paragraph above 2.       The EA can hardly call itself objective given it has published its own paper in 1997 seeking to reduce the emphasis on the role of the hatchery Please explain how such an absurd statement as this can be treated as rational.
5	Basis of research	No formal monitoring of the Tyne stocking programme has been carried out and this presents some difficulties in this evaluation.	If you haven’t got data you shouldn’t be carrying out a study, let along basing a nationwide strategy on the findings
	Basis of research	A further complication is several factors have been changing simultaneously during the period of recovery, each having potential impacts on its trajectory	OK, so no data and no baselines. Not a promising start for any scientific investigation
6	Basis of research	2.       Exploration of long term rod catches…and the timing of environmental improvements. These are compared with some hypothetical recovery profiles that might be expected under alternative scenarios.	My italics on this. So the report is going to base its findings on no formal data from the hatchery programme and guesses as to what might have happened? I fail to see how this can be considered logical.
Comment: I find I’ve reached page 6 of this report and, consider the basis on which the report and logic underpinning it are presented to be amateur in the extreme. This would be mildly amusing, were it not for the fact, the findings and use of this report, are being used to justify decisions which impact on a significant number of people.
New approach to protecting wild salmon 02.10.14
Page 1	Sentence 2	A comprehensive review of scientific research found that hatchery-reared young salmon have a much lower survival rate than young wild fish, and can harm existing wild salmon populations.	This is simply a lie. It is not supported by the survey of literature produced by Natural Resources Wales v.4:  10.3.14