NWATFCC update - 3 Formal EA Complaints

This communication was directed today to the EA`s – NW Fisheries Managers and Technical specialists in the F, B & G teams – Steve Garner, Colette Whiting, Darren Bedworth, David Spiby & Phil Ramsden (Andy Gowan`s replacement. EA Fisheries colleagues,
I am writing to you jointly, because the circumstances warrant this. This is FYI and no response is required. 
NWATFCC has registered 3 Formal Complaints to the EA in the last 18 months (2 this week), all concerning national and local salmon reporting procedures and interpretation of stocks. That level of challenge to stock reporting systems is unheard of. 
Some of these systems may not be your direct responsibility but you will understand and know that incorrect stock estimates have an adverse and significant impact on our major migratory river fisheries (stock status, CL compliance, angler participation, rod effort/catch, Club/Syndicate revenue, tourism income, damage to stock protection & enhancement programmes). 
The Formal Complaints raised through Sharon Kennedy comprise:

1. June 2019 – Failure to review and revise rod exploitation rate estimates used historically in SAP framed, annual egg deposition calculations to CL. This concerns all NW Rivers estimates in the Solway, Lune & national Byelaw process. This is now with the Parliamentary Ombudsman and an assigned case officer.
2. 07.12.20 –  Raised by NWATFCC & LWFA concerning presentation and reporting of River Lune stock assessment and use of Lune Index counter data (in River Lune 2020 NLO & Byelaw Consultation, EA Response to Representations, and to inform wider NW egg deposition estimates in CL Compliance procedures)
3. 08.12.20 – Statements by EA and failure to use NWATFCC 2019 rod catch reports in published national Angler under-reporting catch factors in estimating the NW River estimates to CL.

The attached letters and support documents refer to Complaints 2 & 3 only.The NWATFCC estimates of accumulated error in published and underestimated 2019 river salmon stocks for NW river stocks    require an uplift in the order of between an additional 90 -100% on  current published estimates. This comprises a 43% uplift (e.g. NW Rivers with a 20% RER and correction to 13%) and an additional 58% uplift (from NWATFCC River fisheries returns that demonstrate a 1.68 EA angler declared under reporting factor is required and not the 1.1 factor used from the EA published Angler declared rod catch estimates). 
NWATFCC will consider what action it needs to take following these Complaint processes and after receiving the EA response to our request for a written explanation and reply to the NWATFCC tabled Agenda item at the December – England Fisheries Group meeting.
Finally, NWATFCC have raised concerns that the much-reduced 2019 report – Salmonid and Fisheries Statistics in England & Wales (released two months early this year !) fails to contain essential river and regional breakdown of – Migratory Licence purchases by category,  rod effort & CPUE by river, salmon weight/component analysis, monthly river analysis of salmon and sea trout & C & R catch.  At present we have very little detail to compare 2018 and 2019 River performance.
The good news is that in 2019 (and a lesser extent 2018) after all the dire predictions from the 2016 Storm Desmond impacted juvenile survey results that stocks were in critical decline, we have witnessed strong runs of returning salmon.The Derwent 2019 rod catch doubling its 2018 return and on early analysis of Eden reported fisheries catch the beats below Warwick Bridge have already exceeded the whole river 2018 catch. These returning adults from spawning progeny when voluntary C & R of 90% was being observed.
Thank you for your time and we hope you and families keep well through the turn of the season and next year.It`s been a tough year and we hope our joint efforts are rewarded.
Mike AshwinNWATFCC  North West Angling Trust Fisheries Consultative Council