Tuesday 19 May 2015

River fining off ok but some extra colour in the Builth wells area after heavy showers around the Ithon.  Should not affect other areas too much.

Today.
6 fish from Wyesham today. 3 to gillie Ray Morris, one to owner Mike Timmis
One to Nick James on fly and another to Somerset  Moore. All others on spinner. Mostly sea liced fish.
15lb fish from the Spreadeagle to Louie Macdonald Ames/Fly.

Some interesting responses to the EA initiative on diseased fish.



Dear Mr Gamble,

My apologies for not getting back to you sooner.  I have seen your response to Stuart Smith which you omitted to copy to me but Stuart Smith was kind, and efficient enough, to pass to me as an interested party.

Your advice, attached for those who have not seen it,  goes some way to answering the queries in my original e-mail and your guidance on how to handle these kind of incidents is a step forward albeit one which needs more clarification.

I note that you say the fish was stored appropriately but in an earlier e-mail there was a statement that it had been frozen and would likely not be a useful specimen for analysis of the presence of UDN.  Which was it?

Secondly the idea that a fish reported to be in distress and left in the river would ever be found again, particularly given your response time of circa 3-5 hours on this last occasion when Mr Talbot phoned you,  indicates you are not serious about recovering seriously  diseased fish for analysis.  The photos of the fish Mr Talbot recovered was not caught on a line, it was drifting backwards in a near dead condition, and compared to the examples shown in your guidance was grossly affected.  To even the most inexpert observer it had no chance of recovery.  The last time I saw a fish in this condition on our water was in 1976 in warm temperatures and low water conditions so I am not entirely convinced by your low temperature argument.  Low water seems a common factor with perhaps a consequent concentration of pathogens?

In view of this and my continuing uncertainty about your real interests, position on diseased fish I would still like a formal response to my original questions set out below with accompanying notes in blue:

Firstly  whether you are interested in analysing diseased fish/corpses or not for the purposes of identifying the cause of death be it disease or pollution.  If not why not?  Your position that you want us to report but take no action and await your response to the report indicates you are not serious about recovering fish for analysis. The frozen/stored appropriately contradiction indicates you do not have robust procedures well understood by your employees in place.  Please clarify your position.

Secondly whether we have a duty to report and where possible secure corpses and near dead fish which are diseased  for analysis. If we are not to use a net to do this what method should be used.  Your guidance refers to any fish does this include dead ones or are you interested in corpses being recovered for analysis?  I also think that a diseased fish which in so much distress that it can be hand netted in the shallows of the lower Wye main stem is unlikely to recover.  This is a different case from line caught fish with  a small amount of lesions.

Thirdly please tell me where the guidance on handling this sort of incident is laid down by EA/NRW and are the respective actions required consistent with one another?  Also what steps you are going to take to properly publicise this guidance.  I am glad to see that you have attempted to lay out guidance.  It clearly did not exist before.  Does it have the agreement of NRW.  However I find it is insufficiently flexible to deal with the kind of case we had on the Rocklands water.  The position of the EA and its guidance seems to be more concerned with making sure that anglers can be prosecuted for removing fish from the river than sensibly managing the river.  No angler would want to eat a fish in this condition so why would they take it.  There is a tricky element of degree here but you should be able to find a form of words and a policy to accommodate it if you are indeed serious about monitoring incidents of this nature.  Also once you have got your guidance in a clear and unambiguous form, how do you propose to publicise it.  Reporting fin clipped fish in the Wye is another aspect that also needs publicising.

Fourthly whether you will commend Mr Talbot for his  responsible and time consuming actions to collect this sample for analysis.  He rang in at 1300 did exactly as he was told and waited for the corpse to be collected  at circa 1830.  Less conscientious and helpful anglers would have just pushed off having had to wait that long for a response, if they bothered to use their initiative to recover a corpse in the first place.  I have yet to see proper fulsome thanks for Mr Talbot’s actions in raising both  this matter and general awareness of the lack of guidance on this subject.

Fifthly, I should also note for the record that Dougal Ziegler ‘s efforts were of an exemplary and competent nature if a little slow in response.  What is your target for attending at what could be a pollution/disease related incident?  On a weekday, circa 5 hours, as I understand it, seems rather long.  Are you satisfied your response procedures are sufficiently speedy, efficient and robust?  See my earlier comments as to the chances of a response finding a fish 2-3 hours after it has been reported. Keeping the fish in a condition suitable for analysis.  I would still be interested to hear how your monitoring response system works, and targets for time to attend incidents such as this, in order to gain some confidence you have the resources and motivation to implement the kind of response suggested by your guidance.

Hopefully addressing these questions and answering them in a straightforward way will lead to a sensible and workable policy for dealing with these kind of incidents in future.  I do not believe your current proposals and guidance are adequate or clear enough.  If the real reason for the lack of clarity is that you do not have the manpower to deal with this aspect of river management on the Wye then there may be merit in a meeting to discuss how WUF, WSA and WSFOA might be able to help in monitoring disease in the river and trapping diseased fish in a live condition for examination.


Yours sincerely

John Pearson




Dear Mr Gamble,

I am very disappointed and concerned with the integrity of your response. It is extremely inadequate for a Government body presenting a preliminary report of a laboratory analysis in that it uses self protecting phraseology, contains contradictions amounting to nonsense, ignores evidence sent to you for the analysis, and proposes a diagnosis.

I note that you use self protecting phrases such as "stored appropriately", "our experts", "complicated" and "cannot be confirmed", and that you present the laughable phrase that the Environment Agency laboratory found it was "not possible to carry out... a post mortem examination" because the fish was "dead on arrival" : nonsense.

This fish was taken away by your collecting officer without any ice being used in its storage, then later it was frozen, which you state is a reason why you cannot confirm any cause of death, yet you describe its collection and storage as "appropriate" : contradiction. I will quote your earlier email "Our scientists have made us aware that as the fish was dead, and had been frozen, it is unlikely they will be able to provide any conclusive results on the presence of UDN." Your bungling staff have therefore destroyed the opportunity for definitive analysis by inappropriate handling and storage of the sample. Again, sir : contradiction, after the setting up of a scenario that avoids a conclusion.

You make no mention of the many close up photographs I sent to you as evidence showing both the fish and its lesions in the water, and when immediately placed on the bank, that amply demonstrate its condition when alive in detail. Had the fish been alive at the laboratory there is no more that could have been seen beyond what is presented in these 16 images : ignorance of presented data.

In addition to the corpse being present in the laboratory these images provide ample opportunity for visual appraisal which, whilst UDN or a bacterial infection "cannot be confirmed" you state due to "death" and "freezing" by EA staff, you have introduced the laughable suggestion that the "poor condition" of the fish was due to it "returning [to the river] to spawn again". If that was true there would be an awful lot of salmon in that same "poor condition" ie. rotting alive and unable to swim, as you should be aware that ALL salmon return to rivers to spawn : your proposed diagnosis is non scientific and nonsense, and ignores the pathogen that was affecting the fish.

When UDN was last diagnosed in the Wye did that diagnosis require for confirmation the analysis of live specimens, or was it apparent by the presence of living, rotting fish with lesions? Please provide your response attaching the analysis that concluded the last occurrence.

I, along with all salmon anglers, do not want to see UDN. You, sir, as the Government body responsible for the management of the River Wye and its salmon stock, appear to not want to see UDN. However, you have a responsibility to see it when it is there, and safeguard against it should it look likely.

I ask you to amend your recent statement sent to WSA, WUF, WSFOA etc.

Regards,
Steve Roberts.




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