Below is a reply I received recently from Sophie Gott NRW

It sets out the NRW stocking stance which is the one I thibk we all know,  Plus the rationale, or lack of it regarding survival of returned fish in the latter part of the season.

 

Thank you for getting in touch regarding the Usk and Wye byelaw consultation. I can confirm that this 3 month long consultation closed on the 11^th October and so I am unable to include your comments. However, as you are aware we have had a representation made which does raise the question of closing the Usk and Wye on the 15^th September, so your views are hopefully represented in that.

 

At the start of this process, we liaised extensively with the Local Fisheries Groups on both the Usk and the Wye. We considered and assessed all of the suggestions made by both groups, it is worth noting that at no point was the suggestion made by either LFG to shorten the season. The informal and formal consultation processes were both open and transparent and we looked at every representation made. We try to ensure that what we propose are carefully considered measures based on solid evidence, that protect the fish stocks whilst recognising our duty to protect and enhance fisheries.

 

We fully agree that the salmon stocks on the Usk and Wye are declining, hence our proposals to re-implement C&R and to remove the additional week at the end of the Wye fishing season on the upper river above Llanwrthwl bridge and the tributaries. We also appreciate that there are conservation gains to be had in closing the rivers early. However, we do not agree at this point that there is sufficient will to shorten the season. Catch and release fishing, with the method restrictions imposed under the ‘All Wales’ and ‘Cross Border Rivers’ byelaws to improve survival of fish post release, will help ensure fisheries can continue whilst promoting stock recovery and maintaining much of the socio economic value of those fisheries.

 

You state that the figures for “saved” fish make no sense. I have attached a document which sets out how these figures were calculated to help to clarify these for you. The estimates of fish saved are calculated from a 5-year average (2015-2019) of the fish caught after 15^th September, and allowing for the fact that a certain percentage of these would die post release (please note that the 20% post release mortality includes a 10% figure for natural mortality, the truer figure for fishing mortality post C&R is about 10%). The proportion of fish caught in this last month is calculated for the whole river and tributaries, and not just the upper beats.

 

I have attached a water quality note that we created for the consultation, which may be of interest to you.

 

Regarding your point on stocking. NRW concluded in 2014, after a technical review and public consultation and taking account of expert advice, that it would not carry-out or permit to be carried out stocking of salmon and sea trout in Wales. The review concluded:

• That there had been no new evidence brought to our attention that might amend the conclusions set out in our initial review.
• That there is an increasing resource of publications and new evidence to substantiate our position that the stocking of salmon and sea trout poses a threat to wild populations.
• That stocking is potentially damaging to populations, as removing adults from the wild for hatchery broodstock depletes the resource of potential wild spawners, leading to the depletion of the resource of fit and adapted juveniles.
• That stocking represents a risk to the maintenance of local populations and their adaptations to existing and future conditions. This is because, in hatcheries, adult fish are selected for mating crosses that would not otherwise occur in the wild leading to potential loss of specific adaptations and fitness. Contribution to wild spawning by hatchery-derived adults represents a similar risk to population fitness.

The principle under which we manage migratory salmonids in Wales must be to protect, through best-practice scientific management and the ecosystem approach, the sustainability and productivity of wild salmon and sea trout stocks. It is apparent that this an emerging policy position in many North Atlantic countries.

 

On your point on the lack of Navigation Officers, I would refer you to the Environment Agency as the lead body for navigation on the River Wye. The matter of disturbance of angling by canoe activity is one that should rightly be referred to the statutory Wye Navigation Advisory Committee.

 

Regards

Sophie Gott