Mike Ashwin Chairman NWATFCC to NRW (again)

North West Angling Trust Fisheries Consultative Council part of the Angling Trust and AT North West Freshwater Forum

9 th February 2020

Heidi Stone, EA Salmon Programme Manager Peter Gough, NRW Principal Fisheries Adviser Cc Dr Alan Walker, Cefas Senior Scientific Officer Lesley Griffiths AM, Cabinet Secretary, Welsh Assembly Government Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPWF Notification of National salmon review timetable & content re England & Wales River assessments and Byelaw Implementation

Dear Heidi & Peter,

I write as representative of the Salmon Anglers Advisory Group, Chairman of NWATFCC and on behalf of CPWF Campaign for Protection of Welsh Fisheries whose member rod fisheries and business interests hold and manage extensive migratory fisheries in England and Wales. There are as you know two national review processes that are now underway that rod fisheries were instrumental in lobbying for and are scheduled as EA, NRW & Cefas commitments. As yet we have received no prior notification regarding their proposed timetable, contents or point at which rod fisheries representatives will be invited to make their contributions. In letters to the Defra and Welsh Cabinet Ministers in April & Sept 2018, NWATFCC & CPWF made strong recommendations that the E & W national Byelaws should be deferred until the necessary improvements to revising stock assessments were agreed and incorporated into Byelaws and that interim conservation measures were introduced to enable those review processes to conclude with agreement by all parties. In the case of the ongoing national Rod Exploitation Rate review, I was informed in April 2019 that invitations would be circulated, but these have not arrived. Those recommendations to Ministers, made through Mark Lloyd of the Angling Trust were to prevent the situation that now confronts us – that revision and activation of necessary rod exploitation rates are being “held” to prevent exposure to historic stock assessments that might be considered unsafe in framing conservation measure justifications in the current national Byelaws. There is the means to overcome the logjam that is blocking urgently required stock revisions and we must not remain blind to this. NWATFCC & CPWF have formally notified the EA, NRW & Cefas that the provisional 2018 assessments released in June 2019 require revision and we could not accept these until the rod exploitation rate review incorporated corrections in “final“ 2018 published reports. We have asked, but received no confirmation of the progress of the final assessments or what the status of individual river stocks are as regards the original provisional stock report. We have also submitted detailed proposals as part of drafting of the NASCO 2019 – 24 IP Improvements to Stock reporting, River Classification and Decision measures. A summary of the subject headings rod fisheries would wish to engage with within the reviews is set out below and supported by reports containing detailed analysis, modelling, alternate methodology and stock reporting proposals; 1. National Rod Exploitation Rate (RER) review  EA & NRW proposals to improve capture of angler rod catch & species rod effort  EA & NRW proposed methodology for estimating individual river RER`s and elements – rod effort, River flows & salmon runs ( timing re rod season and cyclical frequency)  Rod fisheries analysis & modelling – Prof Brian Revell`s research & findings  Managing Rivers with inadequate rod catch data  Index river validated outputs as linked River reference RER applications  Implementation of annual reviews in annual stock assessment procedures 2. NASCO 2019 – 24 IP Improvements Review a) Conservation Limit  CL as a single conservation reference point  Resetting CL in revising SAP`s b) Annual River assessment of egg depositions to CL  Rod catch and under reporting estimates  Age/weight proportions determining ISW/MSW – Index River estimates  Fecundity values & mortality estimates  Use of existing River stock performance as percentile to CL  Proposed River Fisheries report KPI`s c) River Classification  Fault lines & weakness in current 15 year Linear regression methodology  Adoption of alternate & transparent methodology  Transparent River stock performance as actual percentile MAT to CL in classification status bands  Use of Juvenile data to support stock health assessments  System validation  Opportunities for improved stock performance reporting  Integration and harmonisation of a single UK mainland Conservation strategy d) Decision Process  Transparent River measures process based on River Classification status  Annual River Status review & application of C & R measures  Flexibility to change targets and breakpoints We would welcome a positive response to this communication as part of an inclusive and progressive approach to improving reporting of stocks and applying long term conservation strategies in the national review phase. We very much hope this can be responded to as a joint EA & NRW communication for reasons that both organisations and jurisdictions have shared stock reporting system procedures and commitments in the planned reviews.

With regards

Mike Ashwin Chairman NWATFCC North West Angling Trust Fisheries Consultative Council The Barn, Skirwith, Penrith, Cumbria CA10 1RH Tel 01768 879047 mob 07926 489764