Friday, 29 May 2020
No need to mention really the desperate conditions we have at the moment with the lower river described as a green dirty ditch and barely worth the effort of tryingt even to fish. No doubt fresh fish might still be trying to access the river as they probably won't be much safer held up in the estuary for too long. Looks like a year best written off to me
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See below recommendations by the Local fisheries Group to be put to NRW and WAG. Reading it, and its a long read, one has to wonder what the hell has been going on, or not to be more precise, over the last couple of decades, to get us into the position we are seemingly now in.
For years before disbanding the RWGA were telling those that all was not well but no one would listen would they. Pidgeons come home to roost I reckon.
Wye LFG Salmon Action List
From a study of the final ‘consolidated’ LFG document [LFG Action Matrix 7.3 Responses_iss4] plus [WCC Response to LFG Jan 2020] there appears to be a consensus (a general agreement], within the current responding LFG members, that the following should be suggested as the basis for a salmon action plan. The action list is supported by, and should be read in conjunction with, a covering letter from the LFG Chairman
Preface
All actions suggested in this document require consideration of whether they are likely to have significant effects on the river designations, flora, fauna, ecology or otherwise. This should consider the potential effects both of the project itself and in combination with other projects. Where an adverse effect cannot be ruled out, and where there are no proven alternative solutions, the project can only proceed if there are imperative reasons of over-riding public interest and if the necessary compensatory measures can be secured.
Disagreement over a proposal can be subject to a transparent, documented review. If detailed proposals for these actions are submitted they should be discussed further supported by an evidence base of scientific research and or data. This review to be subject to scrutiny and may be rebutted with clear evidence in support of that rebuttal.
The next stage is actions to be worked up and made SMART [Specific, Measurable, Achievable, Realistic & Timebound] and a system of review established. Any adjustments to any action should be made only when supporting evidence identifies where and how those adjustments are to be made
Each LFG member has a right to question and be allowed to scrutinise actions and seek clarification should it be necessary.
1.0 Governance
1.1 That a revised method of fishery governance was required for the River Wye Local Fisheries Group.
The greatest consensus was for a change in the management of the Wye Local fisheries Group.
Structured to provide focus on delivery of results, through sound leadership, and improved representation of stakeholders. Its role should be to ensure good alignment with the work of non-fishery organisations and implementation of agreed actions, monitoring progress and evaluating effectiveness of approach.
It would be incorporated through the Wye Catchment Partnership (WCP) via reports from WCP at the LFG and representatives of the LFG attending the WCP
Deliverables: a] Review of TOR. b] The provision of a focussed stakeholder team capable of driving NRW towards delivery of their target Management Levels [ML} of egg deposition. c] Visibility in the angling and local tourism communities of recovery progress. d] Accountability
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 2
2.0 In River Actions
2.1 Fish Passage
2.1.1 Fish Passage past weirs – immediate actions (and delivery partner)
• Finish Ballsgate formal fish pass (Lugg) (WUF)
• Lower or remove Dolley Green weir (Lugg Wales) (WUF)
• Remove/lower Stanton weir Honddu (Monnow system) (WUF/NRW)
• Remove Mahollam Weir (Arrow, England) (WCC/WUF)
• Fix Grove Baulk easement (Arrow England) (WUF)
• Remove Mousenatch and other Lugg level control weirs (EA)
• Determine and deliver the required changes to Osbaston FP to improve efficacy (Monnow) (WUF/NRW)
2.1.2 Fish Passage past weirs – longer term aspirations
• Foundry and Floodgates weirs (Gilwern brook, tributary of river Arrow England)
• Dolau weir on a tributary of the river Aran
• Garren System: Review and update 2010 survey There are potentially seven sites presenting problems for ascending fish from Forge Mill to Trereece
2.1.3 To review fish passage by observing attempts by fish to ascend during autumn 2020.
Observations of salmon and trout jumping to be made by LFG members and their respective supporter base in Lugg & Arrow to determine if there are further barriers to migration,. This is to be co-ordinated through the Summer LFG meeting and put in place plan for implementation for autumn of 2021.
Deliverable: Maximise area of egg deposition and subsequent survival
2.1.4 To review, assess and establish the impact of remaining barriers to down and upstream migration
Survey of Lugg and Arrow is complete, extend this to rest of the catchment. A list of actions to address and complete to agree future projects to be included in this management process. It is suspected that there are additional barriers to fish migration in the catchment
Deliverable: Maximise area of egg deposition and subsequent survival
2.1.5 To maintain areas prone to becoming impassable to migrating salmon
WUF maintain register of sites prone to blocking and ensure they are inspected and removed before and during autumn spawning run. LFG members to supply any records to WUF.
Deliverable: Salmon access to all suitable spawning areas maintained. Increased fry-smolt conversion.
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 3
2.2 Habitat Restoration – Restoration of Historic Spawning & Nursery Habitats
2.2.1 Re-gravelling of historical spawning areas
A further 4,000t of gravel to the Elan is required, followed by top ups of around 500t every 2 years. This is currently managed by WUF. There are other streams that would benefit from gravel retainers to hold gravel in areas that have deficits. (WUF/NRW)
Deliverable: This could increase late summer fry population by 60,000 = C240,000 smolts over 10 years for the Elan.
2.2.2 Continued liming action on parts of upper Irfon and other significant spawning/potential spawning tributaries where acidification is a problem.
Currently carried out by WUF who annually monitor the effects. We would like to see continuous monitoring (Sonde) and doses adjusted to reflect wash out/flow/ recorded pH.
Deliverable: Upper Irfon, Tarennig, Upper Wye and Bidno maintained in a state in which is can support salmon populations of greater than FCS C
2.2.3 Riparian habitat restoration
The habitat of 148km of nursery streams is in degraded state, most of the degraded habitat worth improving (where habitat is the primary limiting factor) is to be found in the Llynfi, middle/lower Ithon, Upper Wye, Duhonw and Edw catchments. to be monitored within this plan.
There are additional benefits in protecting by keeping the rivers cool; tree planting in unshaded tributaries to reduce temperatures where alder regeneration does not provide cover.
Deliverable: Doubling of late summer fry numbers a net increase of 150,000 late summer parr = C600,000 extra smolts over 10 years.
2.2.4 Stop replanting forestry on deep drained peat.
Plant the ffridd (upland fringe) instead. This is highly desirable and if it were linked with wetland restoration in the upper river plantations there would be considerable advantages in both flood prevention and better summer flows (WCP)
Deliverable: Recovery of 2,740ha of deep peat from plantation forestry in Upper Wye and Irfon. More naturalised flows, improved water quality, reduced acidification, (Plus saving of £11k per year of donations being spent of ameliorating acidity).
2.2.5 To establish a mechanism for habitat maintenance
Supported by regulation, for 40km of maintenance per annum
Deliverable: Maintain healthy juvenile numbers and conversion to smolts in upper catchment
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 4
3.0 Wider Issues
3.1 Juvenile Enhancement
The majority of LFG Members request NRW to reconsider its policy, at this point in time, and provide for a holistic approach to salmon management. Minimum Viable Population [MVP] calculations [50/500 rule] already suggest stock depletion threatening genetic variability. NRW Fishery Team to meet with WSA to agree best and most appropriate methodology and controls for implementing the juvenile enhancement programme.
WSA to prepare a full juvenile enhancement programme proposal, based on that contained in sections 3.8 & 3.9 of the document [bold and urgent action Full Report V18 Final] publish 04/12/19. In conjunction with NRW Fishery Team.
Deliverable: Dependant on scale of enhancement and success rate.
WCC View: although proscribed across Wales in 2015, there is still a demand for hatchery reared salmon. The closure of the Wye hatchery allowed DW/WW mitigation fund of £50,000 to be used annually to enhance natural fish reproduction. All scientific investigation points to the need for hatchery closures. If a hatchery is recommenced, a full Habitats Regulation Assessment would be required. The outcome would be extremely unlikely for this to happen. It is important to provide realistic and truthful prospects for those who would like a hatchery to re commence so we can move on to actions that really will restore the salmon fishery.
WUF Position: any future juvenile enhancement plans should be based on chapter 11 of The Atlantic Salmon: Genetics, Conservation and Management: Eric Verspoor (Editor), Lee Stradmeyer (Editor), Jennifer L. Nielsen (Editor).
The chapter is a review of the published papers on hatcheries and framed in the context the increasing knowledge of the rate of genetic adaption within salmon. It details three scenarios where artificial stocking is either ineffective or damaging and one scenario where genetically appropriate hatcheries can play a role in recovering stocks. The scenario where a hatchery could be beneficial does not apply to the current state of salmon stock of the Wye.
3.2 Abstraction & Regulation
Substantial progress in the area of reconciling public water abstraction and the ecology of the river has been made by the UWAG partners. The issue of agricultural abstraction remains
3.2.1 To accelerate inclusion of all existing abstraction within the regulatory framework
This to include trickle and hydro. Introduce ecologically appropriate hands-off flows for both.
Deliverable: An abstraction regime that considers the ecology of the features of the SAC and can be regulated accordingly.
WCC and WUF Note: This is already timetabled but a report from EA to the LFG should confirm this
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 5
3.2.2 Reduce illegal abstraction.
• EA and NRW to publish on the WCP website, daily flows at Redbrook, all legal abstractions within the Wye catchment and their hands-off flow constraints. This will enable LFG members and the wider public to check online the legality of any abstraction they observe.
• EA and NW to visit every licensed offtake (inc. Hydro) within the catchment by end of 2022,check for legality and serve and enforce notice if non-compliant.
Deliverable: A water abstraction regime, legally regulated, accepted, and minimising ecological risk.
3.3 Monitoring and Research
3.3.1 Monitoring of work and peer reviewing of results
Improve post work monitoring and peer reviewing of activities in order to maintain quality standards, improve performance, and provide credibility for completed projects.
One of the world’s most expansive investigations into the benefits of habitat restoration and liming was carried out by NRW and WUF in the Irfon catchment within the LIFE + ISAC project. It proved the positive benefits of reach scale habitat restoration on juvenile salmon, trout and lamprey densities and reduced sediment/soil input. The data was published on WUF’s website. The group would like to see this approach extended to other activities and organisations.
If the funder of a specific activity will not include monitoring and reviewing, in their allocation of funds, other interest groups should be allowed to support monitoring and reviewing.
Deliverable: Verification of results for validation of what works/what does not.
3.3.2 To establish statistically valid monitoring of Phosphates
3.3.2 To establish statistically valid monitoring of Phosphates
Phosphates cause algal blooms and suppress ranunculus, but monitoring is reducing at the time the problem is getting worse. Establish statistically valid monitoring regime reflecting the diversity of water conditions on phosphate loadings in Herefordshire, Monmouthshire, and Powys sections of the rivers. Validation of NMP reported river phosphate loadings.
WUF have 1 continuous monitor in place (just moved from Curl to Frome), and the water companies have several more, data is being brought together through NMP. Additional sondes are required at Glasbury, Aberithon and AberLlynfi.
Deliverable: Quantification of problem to aid delivery of solutions.
3.3.3 Point source pollution.
Sewage Treatment Works [STWs] produce the majority of the Phosphate and over 90% sewage discharged to river. There are other legal and illegal inputs of polluting materials.
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 6
• Chairman to request DCWW attend an LFG and update group on DC/WW plans in this and the next AMP to reduce impact of sewage treatment plants on the river and inform the group of the drivers they work to.
• LFG members to establish a citizen science programme to monitor effect of outfalls identified as a concern, (agricultural, STW and industrial) on the river.
Deliverable: Definition of the role of LFG members in the identification of monitoring of point source pollution. LFG to be informed so that it can help ensure published remedial programmes are delivered and also identify locations where further action is required.
3.3.4 To implement high water temperature fishing controls
Install online water temp gauges at Bridge Sollars and Ross to supplement the existing data from Erwood and Redbrook on WUF's website. WLFG should agree and publicise an upper temperature limit and if monitoring suggests anglers/owners are not heeding advice to cease fishing should propose mandatory legislation.
Deliverable: A salmon fishing temperature-based regime supported by and signed up to by owners and anglers
3.3.5 To investigate apparent parr losses in tributaries
• Determine if the apparent low fry to parr conversion rate in many tributaries is due to early smoltification due to longer growing season/reduced competition, outmigration to main river, high water temperatures during spawning or predation. Continuation of current WSA temperature monitoring project.
• Design fund and deliver a scale analysis programme to establish data on adult returnees. This could identify age at migration helping to answer the question of missing parr in tributaries
Deliverable: Data output to inform decisions for further action plans and create appropriate deliverables from subsequent actions
3.3.6 Adult & Smolt Counting
LFG partners to review and if required revise monitoring programme annually and present plans at spring LFG to co-ordinate efforts. This is to include adult and smolt counting projects.
Deliverable: Accurate data on migrating smolt and returning adult trends to establish efficacy of actions
3.3.7 To establish suspended sediment monitoring
Establish multi-partner whole catchment suspended sediment monitoring with a network of 12 sondes. Quantify problem and determine spatial and temporal variations of soil loss
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 7
and impact on river.
Deliverable: Provide baseline for restoration efforts
3.3.8 To determine if there is evidence of temperature driven trophic mismatch in Wye salmon.
Climate change is altering the seasonal timing of biological events, effectively rescheduling the timing of their food sources potentially risking starvation forb juvenile salmon.
Deliverable: To inform restoration efforts and ensure funds are targeted effectively
3.4 To finalise WCP Policy on Beavers in Wye.
That WCP policy for Beavers in Wye should be finalised and funds put in place to support its delivery.
Deliverable: Be ahead of the game and deter further illegal introductions.
3.5 To use the current planning moratorium and resultant offsetting to reduce soluble reactive phosphate in water column to less than 0.03mg/l during May-Sept.
The current targets are above the thresholds at which algal blooms occur.
4.0 Predation
Predator control must form part of any recovery plan for salmon on the river Wye.
4.1 Protection of smolts from FEB predation.
• Clarify whether NRW have a statutory responsibility to control salmon eating birds, if so NRW should consider applying for and manage an Area-Based (Wye Catchment) Cormorant and Goosander Management Licence.
• LFG members to support Angling Trust campaign for addition of FEBs to General Shooting license. Annual review of FEB numbers to ensure conservation numbers of FEBs are maintained
• Work within the WCP to gain support and consensus. Increase licenses for 66% of spring bird count of cormorants and goosanders until salmon population recovers to good favourable condition. Prioritise control on lower Ithon, lower Irfon and main stem of Wye in April, May, and June.
• Annual count of FEB's in March. 8 licenses issued, (Wye above Builth, Irfon, Ithon, Builth to Hay, Hay to Hereford, Hereford to Ross, Ross to tide, Lugg and Arrow).
Deliverable: Co-ordinated control of avian predation
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 8
4.2 To trial seal deterrent device at Llandogo
Trial placement of an acoustic deterrent device [ADD] on the weir at Llandogo.
Deliverable: Reduction in loss of adult returning salmon in tidal river
4.3 Illegal Fishing and Poaching at Spawning Times
Ensure at least 30 staff day/nights per year are available for protection of spawning fish. Target: Dernol, Marteg, Clywedog, Clettwr, Chwefru, Newbridge-Llangurig plus any additional sites identified by info in Oct/Nov 2020
Deliverable: Reduction in loss of adult salmon, 50-100 adult salmon saved
4.4 Angling Controls, To reduce risks of damage and mortality to adult and juvenile salmon.
LFG to champion change in attitudes, practises and pursue byelaws to reduce risks of damage and mortality to adult and juvenile salmon. Barbless single hooks on all spinning baits for all species, prohibit use of worms for all species. Education, training & communications aimed at improved fish handling, particularly in warm water conditions.
Deliverable: Reduction in loss of adult salmon through angling.
5.0 Adverse Land Use Issues – Planning & Regulations
5.1 Farm Pollution
5.1.1 LFG members to monitor use of Planning Directorate instruction and NRW environmental permitting controls on Chicken Farms, Anaerobic digesters, and Large Dairy herds.
a] Are they being adhered to by all planning authorities affecting Wye catchment
b] Are they proving effective in controlling situation and
c] Are farm capacity thresholds are being effectively regulated by NRW.
Deliverable: Confirmation Planning Authorities complying with directives and permitting controls. Provision of evidence for regulatory action. Opportunities to encourage phosphate reduction and elimination of algae bloom
5.1.2 Pesticides and endocrine disruptors
• LFG members to work with water companies and farmers to reduce pesticides and endocrine disruptors in river.
• Establish a valid monitoring regime reflecting the diversity of water conditions in Herefordshire and Powys sections of the rivers.
Deliverable: Water sampling regime to identify relevant chemicals & establish baselines for reporting values and confirming success of partnerships with water companies and farmers.
LFG Action List 2020 Final_v5.docx Wye Local Fishery Group May 2020 Page | 9
5.1.3 NRW/EA to extend enforcement of Slurry, Silage and fuel oil regulations checks to whole of Wye catchment and use legislation to reduce risk of pollution.
• Ensure they have sufficient size slurry storage tanks
• Ease consenting for responsible farmers wishing to spread on safe ground in extremis to reduce risk of slurry pit failure/overtopping in very wet winters
• Serve notice through SAFFO/works orders if found to be non-compliant and enforce delivery of change
Deliverable: Reduced risk and incident of slurry storage and farm infrastructure pollution.
WCC Note! A recent report by EA (R Axe report) has shown checks on dairy farm infrastructure to be of limited or no value unless enforced by regulation and/ or works orders. Only a small part of the county is included in an NVZ and so falls outside current regulations. WG has promised these for 2020 and should be pressed to honour their commitment.
5.1.4 Delivery of improved land management practices.
• To adequately resource EA in Herefordshire: so they can enforce basic rules. 2 more staff required (or no staff being taken for Brexit planning)
• To continue funding of farm advisory support and peer to peer support networks in Herefordshire.
• To review current mid-tier spend and ensure mid-tier support from 2020 and targeted at stopping P, soil, and pesticide pollution.
• To expand Courtauld 2025. Ensure production of food sold in major supermarkets does not cause pollution to the Wye
• To adjust objectives of Farming Connect in Wales To ensure they prioritise diffuse water pollution.
5.2 Regulations, Directives, and enforcement that LFG members believe are necessary
5.2.1 To develop new soil regulations for Wales.
By end of 2021 introduce the mothballed basic farming rules for Wales to provide consistency with England (http://www.legislation.gov.uk/uksi/2018/151/made). After short introductory period for awareness raising, regulations to be enforced effectively in both countries from 2022.
Deliverable: Reduced soil and Phosphate input into the Wye, essential step towards the recovery of Trothy and Lower Monnow.
5.2.2 Application of existing Anti-Pollution Regulations for Agriculture and
A recent survey of Monmouthshire dairy farms found 70% were in breach of SAFFO and at high risk of polluting. We are of the view that strong statutory regulation and enforcement including the threat of substantial penalties is the only way forward if we are to substantially reduce the number of pollution incidents. 148 pollution incidents in one year in an SSSI designated river is unacceptable and the Trothy, Monnow and Llynfi have similar risks.
LFG
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