Response to NRW correspondence of 30.11.20 & 03.12.20 ref NWATFCC information requests & recommendations on Welsh Stock reporting & Byelaw Impact

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum


Peter Gough, NRW Principal Fisheries Advisor David Mee, NRW Snr Fisheries Advisor,

Ian Davidson, NRW Snr Environmental Assessment Officer, Dr Alan Walker, Cefas Snr Scientific Officer,

Grant Horsburgh, Defra Freshwater & Migratory Fisheries Team, Mark Owen, AT Freshwater Campaigns

Cc NWATFCC, CPWF & PAAS representatives Dear Peter,

Response to NRW correspondence of 30.11.20 & 03.12.20 ref NWATFCC information requests & recommendations on Welsh Stock reporting & Byelaw Impact

We very much appreciate your detailed responses to our communications of the 23.07.20 & 03.11.20.

I am conscious you are also midway in responding to our letter of 02.12.20 concerning the recent publication of the 2019 Salmon stock performance in Wales report. With this in mind I would like to make a full NWATFCC combined response to those three communications once we have received your last response. I expect to complete our final response within the next 10 days.

Please consider four important points in your final reply:

  • NRW & EA Rationale for reverting to using a historic 1.1 raising factor in 2019 angler declared under reported salmon rod catches. You refer specifically to correspondence between Simon Toms (EA) and myself of 4th August as explaining this. As you are now aware this correspondence has been registered as a Formal Complaint by NWATFCC to EA this week. I have provided this correspondence for you and in our view this does not provide a satisfactory explanation for a revision from 1.51 in 2018 to 1.1 in 2019. Our NWATFCC analysis of four major NW Rivers fisheries catch returns demonstrate that there is still significant angler declared catch under-reporting which we estimate to be 1.68 and higher than the 2018 factor applied. This is a major factor in NWATFCC, PAAS & CPWF formally writing to the EA, NRW & Cefas that we are unable to accept or agree with the 2019 published River stock assessments.

May we ask that NRW clarify which Welsh River fisheries do provide reliable rod catch data that is used by NRW to set individual river estimates used for total catch and egg deposition estimates.

  • Fisheries engagement in national reviews (rod exploitation rate RER & 3 year stock assessment & decision structure process). Again to re-emphasise, rod fisheries have had no confirmation of the conclusion of the RER findings which we were assured would influence and correct 2018 & 2019 assessments. Nor a timetable and proposed content/scope of the 3 year review to which we have made some very progressive and substantive proposals. We do expect to see and be a part of those formative discussions and certainly not have finished and final proposals presented to us. That has been communicated to the Angling Trust and we look forward to a commitment and further dialogue on this.

Again, this is a factor in NWATFCC, PAAS & CPWF not accepting 2018 & 2019 assessments.

  • The Index Dee assessments and estimates. In earlier correspondence with the EA the Dee Index assessment and estimates for determining whole run size, RER proportions by 1SW/MSW components(annual and 5/10 year MAT) has been mentioned as a potential model for incorporation into the 3 year review proposals. The angler log book programme, trapping, tagging and recapture estimates may well be the best angler recapture programme in E & W, of which there are few. But the system presents some concerns and you kindly offered a site visit to discuss these with you. We would welcome this.

These concerns arise from:

  • tagged fish being generated from operational trapping that has reduced to approx 50% of the available annual hours (4,200 hours of 8544 annually. This was 5,000 on average in the 1990`s)
    • the trapped proportion of total run falling to below 15% in some years. The Dee report refers to this proportion being 20 – 30 %.of the run.
    • a 5 or 10 year average Dee RER being used on the Wye & Usk when individual year RER can fall by as much as 50% year to year e.g. 2017 to 2018.
    • that the Dee anglers in the log book scheme catch 2/3/4 times the proportion of tagged to untagged salmon in their reported catch to those reported by non log book anglers. You have responded that this does not happen. I would ask you refer to the NRW Index data below that I have summarised for years 2016 -18 that does show there is a 2/3/4 times variation between these angler groups.
  • Ranking Rivers by the strength of negative trend in the latest 10 year-time series of egg depositions (Salmon stock performance in Wales 2019 report). I have discussed this with colleagues and statisticians and we are unsure as to how this data has been derived and unconvinced of the conclusions that are being drawn from this. What trend is this and what is  the equation for estimating the trend ? How are the ā€œpā€ values and eight category rankings derived?. From our analysis of 6 of the best performing Welsh Rivers the published ranking categories do not correspond with our findings. We would welcome a response to these points.

Once again thank you for your patience and assistance in addressing these important discussions.

Best regards Mike Ashwin,

Chair NWATFCC North West Angling Trust Fisheries Consultative Council & on behalf of

CPWF Campaign for Protection of Welsh Fisheries & PAAS Prince Albert Angling Society.

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