Figure 2: River Wye % share of England & Wales Catch Return

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1 Surveys published by ICES of salmon populations in the North Atlantic through the 196 s, 7s and 8 s indicate that although there was a gradual shift in adult size and run timings, numbers were on the whole relatively stable through the seventies and eighties. Since the early 9 s there has justifiably been concern about the declining numbers. Many different reasons have been put forward for the decline. Indiscriminate high seas netting, poor feeding off the coast of Iceland, over exploitation by rods and estuarial nets in their native rivers, global warming, predation by seals and birds are just a few. However, because no one single reason has been proven to be the causal factor, it has become fashionable these days to state that there was an unexplained event in the north Atlantic in the 199 s which triggered the decline. 3 2 Share % Figure 2: River Wye % share of England & Wales Catch Return Some rivers, notably the Wye on the Wales/Herefordshire border have declined worse than others. Not only losing some 9% of its rod catch in the late 8s & early 9s it also lost its position as the premier salmon river in England & Wales returning around 25% of the total catch and declining, quite dramatically, as shown in fig 2 to below 5%!. If the Wye catch loss can be explained along with other rivers by this unexplained event in the north Atlantic what explains its decline relative to these other rivers

2 England & Wales Catch River Wye Catch Fig 3 Shows relationship of dramatic decline in Wye catches compared with England & Wales overall! The EA responded to the decline by insisting those with an interest in salmonid welfare should reduce exploitation rates and focus on improving riverine habitats. Anglers and netsmen have, in general, responded responsibly to this call and as a result, an ever decreasing number of returning adults are killed each year. Gone are the days of fishmongering and on the odd occasion when anglers are fortunate enough to have a good day, they are comfortable in returning the majority, if not all the fish they catch. For many anglers who were once used to catching and taking tens of fish per year, catch and release is now the norm. Most anglers, myself included, bought into this idea as there appeared to be logic in their case and since the launch of this strategy, there has been good cooperation with the majority of anglers having embraced the need for reduced exploitation and habitat management. Many river systems have adopted the habitat restoration strategy and developed Salmon Action Plans (SAPS) based on it. Several SAPS are now mature and if they haven t already undergone their 1 year review are about to undergo it. With review in mind, it is surely time now to review the effectiveness of these SAP and the questions that have to be asked are: (i) Have they delivered? and (ii) Could the decline in salmon populations occurring since the early nineties been a consequence of this strategy rather than some unexplained event occurring in the North Atlantic in the late eighties and early nineties? (iii) What new measures need to be adopted for the next SAPs Most SAPs include plans for improving degraded habitat. Projects usually take the form of buffer stripping miles of riverbank. Whilst structured and planned improvement of riverine habitats are essential to the long term survival of Salmon and Sea trout, there must be an understanding of what constitutes and may have led to degraded habitat, before corrective action should be undertaken. It is not the purpose of this paper to criticise the goals of habitat improvement but just to question whether projects that have been undertaken have yielded their objectives. Since the launch of the habitat restoration strategy, the Environment Agency has rightly attempted to measure its success by estimating salmon populations from catch returns on some river systems whilst

3 on others it uses coincidence counters. There are 65 rivers in the UK where stocks are estimated from catch returns whilst there are just 1 fortunate in having counters. In April 28 The EA published it s assessment of the state of the Salmon and Sea Trout stocks in 27 in a report aptly entitled. Annual assessment of Salmon stocks and fisheries in England & Wales 27, preliminary assessment prepared for ICES April 28. Written by CEFAS and the EA. In this document they detail their assessment of the stocks in the various river systems in England and Wales and detail the methodology behind their assessment. Having studied the document it is clear that there are some serious flaws in the measurement methodology. Even more disconcerting is that these flawed measuring systems are then being used to formulate future management strategies on the systems from which they have been made. Further to this is the fact that whilst the EA regularly reviews and publishes its measurements, it seems unable or unwilling to review its strategies and accept they may be the causal factor of the decline. It is the intention of this paper to examine the measurement methodology and the conclusions, and ultimately the strategies, which are derived from it. It will also suggest improvements to the measurement methodology strategy and suggest options with reviews. Part 1: Salmon Stock Assessment: 1) Catch Returns Angling catch returns are used for estimating stocks in 65 of the 75 salmon rivers in the UK. A method the EA admit themselves is notoriously inaccurate. To improve accuracy the EA have been actively encouraging anglers to make returns and have been issuing follow up reminders whether needed or not. In using catch returns there are significant opportunities for error in the stock assessment arising from three sources. (i) (ii) Firstly, not all catches are reported. In making the final stock assessment for a river system, the EA make an allowance for under reporting, but this figure is statistically based and at best a guess, and so by this alone there is already substantial error introduced into the stock assessment figure. Increased restrictions lead to the increased probability of under reporting. Secondly, there is no compensation for reduced angling effort. Coincident with the introduction of this methodology, several conservation measures were introduced aimed at reducing exploitation. They have not simply reduced exploitation; they have also resulted in reduced effort. On many English & Welsh rivers such as the Usk and Lune, my local river, there is little or no angling effort now before the 16 th June, this as a direct consequence of the introduction of the National Spring Bye Laws,. The EA in part recognised this effect when correcting catch returns for reduced effort in 21 the year Foot & Mouth restricted angling efforts on most UK rivers. Had 21 assessments been based on the standard catch return methodology the stock figures in many English and Welsh rivers would have been by far the lowest ever recorded. Co-incidence? There is an air of a self fulfilling prophecy when combining the reduced exploitation strategy and the stock assessment methodology. More conservation measures result in less angling pressure, which in turn results in lower catch returns. This is interpreted as arising from a decline in stock, which therefore results in more conservation measures. The net result is a move to total catch and releasea measure being proposed by the EA for 1 rivers in North Wales rivers whose stock assessment is based on it. The Cumbrian Eden, where conservation measures have been introduced to restrict catches to just two per season, is heading down exactly the same route. As a consequence there will be reduced angling effort and under reporting which will be interpreted as further decline resulting in further restrictions.

4 (iii) Thirdly, there is no correction for changes in seasonal conditions (i.e. rainfall) nor for seasonal runs. In recent decades the main salmon runs on most rivers have changed and become later. In dry years, when the main run doesn t appear until after the season has ended, the conclusion is drawn that there are no fish! In 27, when a dry autumn led to unfavourable angling conditions and consequently low angling effort, stock assessments indicate low populations in many rivers. The main run may have failed to arrive until after the season ended, but there was no correction for it! Conclusion The methodology leads to the seriously flawed conclusion that there can be few fish in rivers where either (a) low rainfall, (b) late runs or (c) no one bothers or is allowed to fish! Therefore, rivers with least angling effort and consequently lowest returns are likely to suffer most restrictions and further conservation measures. The EA s assessment of stocks is at best only a measure of the DECLARED numbers being caught following the introduction of conservation measures! It is not possible to conclude that they reflect in any way the actual stock within English and Welsh river systems. To then group these together and report them as the national stock assessment just compounds the errors and makes the final presented figure meaningless. 2). Counters These days I do most of my fishing on the River Lune in North West of England where the number of salmon and sea trout entering the river are recorded by a coincidence counter built into a weir some 4 miles upstream of the tidal limit. The counter operates efficiently in low water, as almost all fish entering have to pass through narrow tubes, which record both numbers and size. Using data from the counter the EA have recently published charts indicating that the Lune is improving as a salmon river, but once again, they make no mention of the potential errors in the collection of data. Although the counter is effective in low flows, it is not effective in high flows as the under the latter conditions fish can pass easily over the crest of the weir and go unrecorded. In wet autumns when peak runs are coincident with high rainfall, the likelihood is the counter will under record giving error in the final assessment. If this figure is used for stock assessment, errors will be made in the conclusions that are drawn and therefore errors will be made in devising an effective management strategy. Seasonal anomalies have also been allowed to go unexplained or unchallenged. In 24 12,781 salmon were recorded as passing through the counter (>5% above the average and a record high number since the introduction of the SAP). However, the corresponding sea trout count for the same season at 5711 shows an unusually low count (>5% below the average, the lowest recorded since the introduction of the SAP!). Is this coincidence or could a fault have occurred with the counter whereby it was unable to differentiate between the two? Again no explanation is offered or correction made. In 27 we had a dry autumn, so the percentage of fish passing through the counter was higher than in wet years. Again no correction is made. Finally, since 199 there have been several modifications made to improve the efficiency of the counter, and once more no corrections have been made. Using this information the EA then go on to

5 produce a chart and conclude the Lune is improving! The EA are surely guilty here of using unverified information to misrepresent the facts. Why they do this only the EA know. The chart below shows the forge weir counts from The information has been taken from figures published in the Lune & Wyre annual reports using data supplied by the EA and former NRA. Compare it with the chart for the Lune published by the EA in the CEFAs report, reprinted above. It is interesting to note that the EA do not include the counts prior to 1985 in their published data and dismiss them stating counts prior to 1985 were unreliable. Was the information being supplied to the LWFA on an annual basis prior to 1985 incorrect or is the data now being dismissed because it adversely skews the way the results are presented? Forge Weir counts Total declared salmon catch (rods & nets corrected) # stocked total catch The Lune is a mixed fishery. As well as offering good salmon angling throughout its length, it supports an estuarial netting operation. A record of catches has been kept by netsmen and particularly accurate records have been kept by the Lancaster and District Angling Association. These go back many years and if they are analysed over 3 years a picture emerges which indicates that the phenomenon that occurred in the North Atlantic in the late eighties and early nineties resulted in the total catch on the Lune reducing by 5% from which it has never recovered. What is more, it is surprising that the improvement in runs indicated by the counter data has not resulted in increased rod or net catches. If Lune stocks were estimated from catch return data, what conclusion would be drawn? A similar situation exists on the River Wye where the acoustic counter situated on the lower river has been shown, both in the opinion of the local angling community and the EA themselves to be inefficient for many reasons, not least that the huge range of water heights experienced on the Wye and the need to distinguish between salmonids and the very great range of coarse fishes to be found traversing the river. Much of the data is subject to various methods of verification and the results at best a guess. The counter is now considered unreliable and judgement on stocks, egg deposition and achievement of conservation limits being made based upon empirical calculations from rod catch records and assumed exploitation rates!

6 Conclusion Given all the errors with the way the data has been collected, can any accurate information be drawn from the counters? Yes but only under certain conditions the Lune coincidence counter now accurately records the number and size of salmon passing through it under low flow conditions i.e. when there isn t sufficient water passing over the crest to allow fish to get over it! Whilst coincidence counters give a better estimation of the total stock in a river system, any trend analysis from the data is meaningless unless it is corrected for improvements in efficiency and seasonal abnormalities. The Wye, having removed the acoustic counter unreliability, seems to have replaced it with empiricalysed results with no attempt either to demonstrate the methods validity nor to recalculate historical data to reconsider results or resultant actions. Recommendations: When using catch returns to determine salmon stocks, corrections must always be made for: (i) Effort (ii) Over/Under reporting (iii) Run timing (iv) Adverse/abnormal conditions i.e Foot & Mouth and other environmental issues, flooding, pollution, fishing bans etc. (i) Effort & (iii) Run timing. The most pressing need is to correct for these effects. Moderate levels of rainfall favour salmon movement and angling. Therefore effort is inextricably linked to rainfall. As most salmon enter UK rivers in autumn, by comparing actual rainfall in September & October with the average annual rainfall over the same months a figure is obtained for the ratio of rainfall compared to the norm. Multiplying the catch return by this figure will at least give some correction for effort and run timing. See below: Average Rainfall Sept - Oct x Catch return = Corrected catch return Actual Rainfall Sept Oct Whilst this would be a crude correction, it would be better than at present and may give a better reflection of numbers present in systems during years of low rainfall. (ii) Over/Under reporting -. This can be achieved by comparing catch returns submitted to the EA with those collected by angling clubs and Riparian owners. Focus on a representative sample of rivers and gain co-operation of all the angling representatives. Whilst there is no guarantee that the figure returned by angling clubs will be 1% correct, it is likely to be a truer figure compared to the catch data collected by the EA. Comparisons of the two figures will give a correction ratio. It is only by gaining a more accurate assessment of the stock in river systems can the true impact of improvement activity be measured. The current method is seriously flawed and cannot be used as a basis for formulating future stock management. Part 2 Conservation limits and Spawning escapement targets. All Salmon Action Plans in England and Wales, and there are 65 in all, use Conservation limits (CLs) in their approach to managing salmon stocks. Their use has developed in line with the requirement of ICES and NASCO to set criteria against which to give advice on stock status and the need to manage individual river stocks. Conservation limits are defined on page 93 of the CEFAS/EA document as follows: Conservation limits(cls) indicate the minimum desirable spawning stock levels below which stocks should not be allowed to fall. The CL is set at a stock size below which further reduction in spawner

7 numbers are likely to result in significant reductions in the number of juvenile fish produced in the next generation. The management objective for all river systems is stated on p94 of the CEFAS/EA report as: the stock should meet or exceed the CL in at least four years out of five. In deriving the conservation limit for a river, two basic factors are considered. They are: (i) Survival in the freshwater phase. The percentage number of eggs surviving through the fry and parr stages to become smolt and migrate to sea. In EA terms the Stock recruitment curve. (ii) Survival at Sea. The percentage number of smolts surviving at sea to return as adults to spawn. In EA terms the Replacement line. The Stock Recruitment curve. The derivation of the Stock Recruitment Curve for salmon is described in the EA R&D technical report W65 dated It is complex and difficult to understand but put simply, data collected from the River Bush in Ireland between 1974 and 1994 was used to produce a model for the conversion of eggs to smolts. The resultant model was validated by comparing data from the Ginnock Burn obtained between 1966 and The report concludes that there was good agreement between the numbers predicted by the model for the Ginnock Burn compared to that derived from the River Bush. The model is claimed to have been validated and has been adopted by the EA to predict conversion rates on all river systems in England and Wales. To establish a figure for the number of parr a river is capable of supporting ( The carrying capacity ) and hence the number of smolts it produces, the EA uses a complex relationship between the quality of the habitat (Stream Order), the average river width and the national average parr densities for the given quality of habitat. Typical parr density values being 8.62 to 24.5 parr per 1m 2. In order to obtain the figure for a given river, the river is first divided into an array of categories (lengths) potentially 42 in all. The area of each category is then is then worked out assuming an average width for it. These areas are then assessed for habitat quality and the area is then multiplied by average parr density for that habitat quality. The numbers for each category are totalled giving smolt production number (the carrying capacity) for the river. The stock recruitment curve derived from the River Bush is then applied to this number and this yields the number of recruits (smolts) required to keep the population self sustaining. This is next translated into a spawning escapement target using data on fish size collated from anglers catch returns. From them an estimate is made of the average size of fish returning to spawn and using a weight to egg calibration chart, this is converted to the number of adult hen fish needed to reach the spawning grounds. An equivalent number of cock fish are added to this number and the final figure then becomes the spawning escapement target. Hilbourn and Walters (1992) conclude: number of traps for the unwary Analysis of stock-recruitment data provides an enormous The Replacement Line: Having established the number of adult salmon required to keep the run self sustaining, the second measurement used in the management of salmonid fisheries takes account of the losses occurring at sea. In essence if the number of smolts leaving the river is above the CL limit and mortality at sea is low, there should be sufficient adult salmon returning to keep the population self sustaining. If mortality at sea is high, numbers returning to many rivers may be below the CL and populations not be self sustaining. Hence the need to manage salmon exploitation at sea and the important role of NASCO in proposing and applying conservation measures. The Replacement Line relationship is derived from experimental tagging data collected from the North Esk in the 196s and 197s. Survival values of 25% for 1SW fish and 15% for MSW fish were observed and these used by the EA in their model from 1998 to 23. However, in 23 the EA rounded down the

8 survival at sea figures to 15% 1SW fish and 5% MSW fish as the period of data collection in the 6s & 7s was thought to be one of high marine survival. A default value of 1% survival at sea is now used in stock assessment calculations. There are flaws, too, in this aspect since the model assumes that all smolts will behave and survive at the same rate as those in the North Esk. It assumes that losses to the West Coast rivers will be the same as those to East Coast fisheries. Indeed measurements made on the Welsh Dee smolts carried out by the EA indicate a much smaller survival rate of 3.9% for 1SW and.5% for MSW. It also assumes that Marine exploitation has remained constant at or around the same levels as those measured in the 6 s and 7 s. CL Compliance Assessment and Forward Projections. The management objective for each river is that it should achieve its spawning escapement target 8% of the time i.e four years out of five. How the river is performing against that target is measured using catch return data on the majority of English and Welsh rivers. For all rivers without counters the total number of returning adults is calculated by multiplying the total catch by a rod catch efficiency figure (derived from experimental measurement on the Welsh Dee). The number escaping to spawn is finally estimated by subtracting the total estimated catch from the total estimated run. Once again there are two obvious errors (i) the method uses catch return figures already proven in part 1 of this document to be inaccurate (ii) it assumes rod catch efficiencies on all rivers will be exactly the same as that on the River Dee. The EA uses these figures in stock management by charting them, applying a line of best fit through the points and projecting forward along the line. If it is forecast that there is a high probability is that a river will not meet its spawning escapement target 8% of the time (four years out of five), it is said to be at risk and conservation measures are likely to feature in any plan for stock management. If is meeting its spawning escapement target it is not at risk and the state the surplus stock above the spawning escapement target may be harvested. Conclusions: Most data published by the EA including the CEFAS/EA report is dressed up in statistical terms that make it difficult for the layman to understand and as such not many anglers would have the time nor the inclination to read through it fully. As a consequence there have been very few, if any challenges to the validity of the model, which having examined it in detail, I believe is flawed in many ways. (i) (ii) For the model assumes that all rivers will behave in exactly the same as the River Bush during the 198s when survey work was undertaken. It is now 28 and there is little evidence of any further validation work having been undertaken. The EA assumes a smooth curve between smolts produced and eggs deposited but the data recorded indicates the fit is anything but smooth. For example in 1985,1.71 million eggs produced 21,91 smolts, in M eggs produced 21,216 smolts in million eggs produced 2,963 smolts. (iii) Most academics warn against applying the model without considering changes in environmental conditions as it assumes that the river will produce the same number of smolts irrespective of climatic conditions. A study of rainfall compared to salmon counts on Forge Weir in the river Lune shows a clear link between high rainfall and salmon counts four years later this possibly the consequence of Redd washout. date Rain fall mm 2 nd & 3 rd Jan th & 8 th Dec th & 5 th Dec th & 19 th Dec 5. 3 th & 31 st January th & 9 th January nd & 3 rd Dec

9 18 Forge Weir Salmon Counts v's high floods salmon 5 per. Mov. Avg. (salmon) mm 77mm 57mm 5mm 68mm 72.7mm '4 days (iv) (v) The model makes no provision for loss of juveniles through pollution. It assumes there will always be an abundance of food in a defined area of habitat. On the Lune, historical parr surveys have always indicated they are plentiful in the upper river, but less abundant in the middle and lower River. To date no one has come up with a satisfactory answer. However, observations by anglers in North Wales have suggested the absence of fish may be due to occasional incidents of small pollutant discharges destroying their food source, i.e. killing insect larvae and crustaceans. The impact of agricultural use of chlorinated detergents, organic phosphates, pyrithroids and cattle wormers (ememectin benzoate) is not considered. The model makes no provision for loss of juveniles through bird predation. It assumes that losses will be in line with those measured on the Bush more than twenty years ago! The only thing that can be said for certain is that the methodology used in assessing the ability of a river to produce smolts is at best a guess with poor science applied. Part 3: Preserving stock integrity. Maximising a river s natural productivity should always be a prime objective of any river management program. Preventing loss of natural habitat and improving areas of degraded habitat should also feature strongly. But in river systems where there is an abundance of underutilised pristine salmonid habitat, stocking should feature until the reasons for the underutilisation are known and understood. To carry on with programs of habitat improvement in river systems with underutilised pristine habitat is no different to building housing estates on the moon! However, the EA see hatcheries as expensive and in the age of sustainability they are unfashionable. In the late eighties and early 199s the EA closed almost all hatcheries in England and Wales stating they were ineffective and did not work. They stated clearly that their aim was to improve salmon fisheries through preventing loss of, and improving natural habitats. Whilst the strategy was laudable as a long term objective, on most river systems it came with no short term or intermediate plan to offset any impact on salmon populations.

10 Upon closure of the hatcheries, the numbers of smolts going to sea rapidly declined, and consequently so too did the number of returning adults. Total declared salmon catch (rods & nets corrected) With less adults available to spawn and no rearing program to boost the next 12 6 generation, the consequences on the # stocked total catch second generation and third generations 1 5 meant further reductions in adult 8 4 numbers. If the annual stock assessment chart was overlaid by a chart showing 6 3 hatchery output, it would be similar to that 4 2 for the Lune illustrated left when there was a clear link between hatchery 2 1 operations and the numbers of salmon caught (dark line) Quickly realising the need to reduce exploitation of adult numbers to prevent further reduction, the EA have embarked on a program promoting catch and release. It is now pivotal to their strategy as without it their may be little opportunity for populations to stabilise. As mentioned earlier, most, if not all anglers have acted responsibly in responding to the EAs call for a reduction in exploitation and not for one moment would any consider a return to the days of free for all. However, they closed hatcheries with little or no public consultation and spent a great deal of time and effort convincing the angling communities that their strategy was the only one and the correct one. Since then they have waged a national anti hatchery campaign which has become ever more farcical with time. There is ample evidence from the many studies that both sea trout and salmon do stray from their natal river and breed in other rivers. During the period a tagging programme of wild River Wye smolts recorded recaptures in 19 locations in Northern & Southern Ireland Coastal Fisheries, one at Blythe in the North East Coast Drift Nets, one by an angler in the River Eden, one in the River Usk and one in River Parrot! Recently an instance occurred in the river Dee (Wales) where a Lune salmon was trapped. Recent studies of the genetics of netted salmon indicate that almost 4% of the stock examined was found to have originated from other rivers. One has to ask are there any genetically pure strains of migratory fish in any of our rivers? Some scientists are claiming that genetic purity is adversely affected by stocking this of course is nonsense, spring summer and autumn salmon interbreed, salmon from other rivers stray and breed in other rivers indeed the larger the genetic pool the better. The success of stocking rivers such as Tyne, Lochy, Conway, Lune, Dee etc and rivers in Scotland is being ignored. What evidence is there that stocked salmon can harm wild fish? It has been well proven by now that salmon stray into other river systems and that populations are well mixed. I challenge anyone claiming to be an expert on the matter to show conclusive evidence of the stock integrity gene. To date I can find absolutely no evidence that such a gene exists! Whilst the EA seem to be focusing on the possible (not definite) harmful effects of stocking on genetic integrity they are ignoring the plus side which is by introducing new in river strains the existing population may become stronger as a result of new genes/greater variability and improved resistance to negative factors. In England and Wales the EA are coming over as blatantly anti stocking to the point of an obsessions believing that habitat Improvement is the only answer if only it were! There are several examples in the CEFAS/EA report and the EA technical report W65, where there are warnings about using stock enhancement to increase populations stating throughout that artificially reared stock may interfere with genetic purity of native stocks. In all publications the words may, maybe and possibly feature regularly but none are able to provide conclusive evidence of damage to native populations by artificial rearing of native stock! Indeed in one document examined the authors argue against stocking stating that it interferes with the genetic integrity of the stock whilst later in the same article they claim that when river systems with low native populations have been left to repopulate with migrant fish from neighbouring river systems, they have done so successfully! Indeed, they go further to claim this is how

11 the Tyne population recovered and that recovery was independent of restocking! It seems that the anti stocking lobby will make even the most illogical of claims to support their case. In the mid 199 s the Tay governing body also decreed that it too was closing down its hatchery operation and that the future lay in habitat improvement. The folly in this decision was quickly realised and it was reopened within two years. It now boasts the biggest facility in the UK and was filled to its 3 Million egg capacity for the first time in the winter of 27. The Lochy, was another which quickly reopened its hatchery when its stocks crashed following earlier closure. Within 4 yrs of doing so it, too, boasted record catches of MSW salmon and a massively improved spring run. Other Scottish rivers followed suit and many are now in the process of re- opening or building new facilities. On rivers on the eastern sea board of Canada, hatcheries are once more in favour. Why is it when the entire world now acknowledges the folly of the closure of hatcheries, the EA refuses to acknowledge hatcheries do have a role to play in stock enhancement in England and Wales? Is all the rest of the world wrong? It is also worth posing the question on what river/s in the UK has stocking proved to be harmful I am not aware of any. Part 4: ENVIRONMENT AGENCY PERFORMANCE TO DATE It is not the purpose of this document to deny that Atlantic salmon populations are in decline every experienced salmon fisherman will openly acknowledge it. Neither is the purpose to advocate a return to the days of free for all, nor is it to advocate an abandonment of the habitat improvement strategy. It s purpose is to ask questions about methods used to calculate local and national stocks used for determining future strategies, to challenge the validity of the model used for setting targets, to question the effectiveness of current salmon action plans and to propose initiatives for inclusion in future salmon action plans. If the EA chart reproduced on page 1 is a true measure of the national salmon stock and accurately reflects trends then it must be concluded that current SAPs are not working in so far as they are not arresting the decline in numbers. When the EA initially launched their strategy, they said it would take 1 years before their strategy to deliver better fisheries would work. Well 1 years have now passed and have they worked and delivered better fisheries? The answer is clearly no yet they are asking to be given a further 1 years! Where will we be in 1 years and will there be any salmon left swimming in our rivers? What would happen if a corporate business or local authority embarked on a 1 year project resulting in decline rather than promised growth? Surely, in business, the shareholders would dismiss the chairman and board or in the councils case the electorate would dismiss the council. So why should it be different for the EA? It would appear that the EA have embarked on a strategy based on a dubious model. Now they are committed to it. They would rather spend time preserving the integrity of the scientists model rather than enhancing stocks in river systems. They appear to want to misrepresent information and blind anglers with statistical terms in the hope that none shall be able to understand. There is a deep distrust of the EA by the angling community as there is a growing concern that there is a hidden objective of achieving a curtailed angling season and total catch and release. They also often come across as having a we know it all attitude and not wanting to engage with anglers to discuss the issues faced. My challenge to them is to step back and review salmon action plans have they worked. If they too conclude the answer is no, plan what needs to be done. Apply the circle of continuous improvement and don t allow statisticians and scientists lead everyone blindly down a path to extinction. My main concern though is that I am unsure as to whether the EA have either the will or the ability to listen. To date their record is appalling and due consideration should be given to handing the management of salmonid stocks back to the individual fisheries boards and relegating the EA s role to one they may be able to deliver on i.e. one of consultancy and water quality management.

12 Part 5: PROPOSALS FOR FUTURE SALMON ACTION PLANS. The aim of this paper was not just to examine the effectiveness of current measurement techniques and management strategies, but to propose some corrections and management options for consideration in future. Listed below are both. The issues in need of correction are: (i) The inaccuracies associated with stock measurement both at local and national level need to be addressed. Corrections must be made for under reporting, seasonal variation, and environmental changes. (ii) The model used for determining spawning escapement targets is severely if not fatally flawed. It too does not take into account environmental nor climatic changes. If it must be used in the future, it must be capable of correcting for these factors. Water quality, correct habitat, and maintaining adequate stock levels are the main components to ensuring survival of the species. Therefore, it is common sense that all salmon action plans should include policies to measure, monitor and manage all three aspects. 1. Monitoring and improving water quality has to be a key objective and action must be aimed at preventing pollution particularly from farming operations and waste disposal. The EA s role should be one of informing and enforcing whereas the angling authorities should accept responsibility for monitoring. There is a great opportunity here for riparian owners and angling boards to follow the follow the examples of anglers in North Wales. Here they monitor water quality by checking the health of insect larva within the river. It is an inexpensive operation and can be highly informative and help to pin point when and where pollutions take place. 2. Improve degraded habitat. Upper river habitat improvement programs should continue, but should be targeted at improving survival from egg deposition to fry. Consideration should be given to not just buffer stripping river bank but also for providing protected spawning sites build gravel traps as per those on the Rivers Mint/Sprint/Kent in Cumbria and those being tested on the Wyres and Hodder in Lancashire. Build these upstream of pristine juvenile habitat. These will serve three purposes: a. Reduce gravel loss from spawning tributaries when full gravel can be dug out and replaced upstream. b. Provide large spawning ponds with good gravel, lower velocities and less likelihood of washout. c. Provide protection against climate change i.e mitigate against increased winter flooding. The deposition of woody debris in feeder stream and tributaries should be encouraged as outlined by Natural England. The provision of Juvenile refuges in the middle and lower stretches of river should also be considered. Habitat improvements are of course now very much in vogue throughout England and Wales, however they are only viable if carried out sympathetically with due regard to each, river, stream and tibutaries needs. Too often it seems to be a one size fits all solution with large areas of a catchment being simply fenced and coppiced, often probably unnecessarily and without thought given to future management. To be truly effective fencing needs to provide a proper buffer strip to the water course and not just a fence a yard or so from the waters edge. Likewise the removal of weirs and perceived blockages which can often result in increased water velocity, especially in times of spate, particularly on upland streams and large losses of valuable spawning gravel occur. Small fish refuges are lost and other aquatic habitat can be simply swept away.

13 River Wye Redd Count This chart seems to suggest that the decline in main river redds precedes the decline in rod catch by 4 years or so! Main River Redds Tributary Redds Rod Catch No of Redds / Fish Caught Year Graph shows significant decline in Wye main river redds compared with cyclic changes in levels of tributary redds. Will habitat improvement recover this loss of redds in main river? Such projects may be partially financed through grants available from the EU habitats directives but anglers must accept that they may have to contribute. Such projects should be led by district angling boards or subsidiaries thereof and the role of the EA should be reduced to one of consultancy only. 3. Enhancing spawning stock. Clearly hatcheries do work and increased use should be made of them until such time as the total river improvement program has delivered its benefits. Areas of under utilised pristine habitat should be restocked until reasons for loss during egg deposition are known and understood. Clearly, there should be a change in the approach to stocking and priority should be given to stocking only with 2SW fish as these yield more fish per returning adult. Once more, the role of the EA should be reduced to one of consultancy only and again anglers should expect to have to contribute towards financing such operations. Ideally, it should be the long term objective of all river systems to phase out hatcheries, but that should only be permitted once it is proven that populations are stable and self sustaining. I finish with a phrase I have used in other publications which is that as I see it we only have temporary ownership of our river systems and need to ensure that we pass them over to the next generation in equally as good a condition as we inherited them. From assessments of current stocks, we have a clearly long way to go!!