THE WALES ROD AND LINE (SALMON AND SEA TROUT) BYELAWS 2017 THE WALES NET FISHING (SALMON AND SEA TROUT) BYELAWS 2017 JOHN EARDLEY Personal Background • Strategy Officer - Campaign for the Protection of Welsh Fisheries • Gwynedd Local Fisheries Advisory Group Representative - Prince Albert Angling Society • Secretary - Clwyd, Conwy & Gwynedd Rivers Trust. • Track record of working in partnership with NRW, its predecessors and other partners including: i. Obtaining broodstock for the Mawddach Hatchery ii. Stocking out of juveniles from the Mawddach Hatchery iii. Active participation and partnership working in both habitat improvement schemes and the management of invasives. iv. Water Framework Directive (WFD) Meirionydd Catchment Plan element of the Western Wales River Basin Management Plan. Although I am a visiting angler, I present my evidence with the full backing and support of the 2 major angling clubs and vast majority of riparian owners on the Afon Mawddach & Afon Wnion in the Dolgellau area. Are the measures proposed in the byelaws necessary, proportionate and reasonable in view of fish stocks throughout Wales? August September Wnion Dee River Flows have a significant impact on Migration Patterns – however there can be considerable variations between catchments Extracts from a document sent to NRW staff - November 2014 On 11th May both the Mawddach and Wnion were flowing at the top of their banks. This was to be the last major rise of water until 6th October! On 23rd June Lampreys were observed spawning immediately above Llanelltyd Bridge. This has been a regular event during recent seasons and, given the life cycle of the lamprey, would seem to indicate that there is little wrong with the water quality. Around the same time (and for much of the summer there were large numbers of both parr and fry (50 – 100?) The lack of fresh water meant that the tidal mud continually moved upstream on the flood tide. Throughout the whole season the whole width of the river channel on the tidal water was 20-30cm deep in mud. Fish seemed reluctant to take up residence in much of this area. When salmon did appear they would only stay for one tide. The first proper spate occurred on 6th October and this is the first day that fish were caught on the upper Wnion (although there were few anglers to be seen). On 9th October I watched numbers of fish (both salmon and sea trout) jumping the falls on the Wnion at Bryncoedifor. On the 14th October, during a brief window of lower water levels, I counted 25+ salmon in the Bryncoedifor/Rhydymain areas of the Wnion. There were also good numbers of sea trout in this area. During this last week of the season I hooked 4 salmon in the upper Wnion, losing 2 and returning 2 others. During these last 2 weeks of the season I only saw 1 other angler on the upper river and it is therefore unlikely that catch returns are going to reflect fish stocks. “Salmon Fishing is not, and never can be, an exact science, because the fish enter fresh water to breed, not to feed. The art of catching them cannot be learnt from fact or fancy – though inevitably each fisherman has his own theories – what really counts is experience.” Arthur Oglesby – SALMON “What do they know of fishing who know only one fish and one way to fish for him?” Jack Hargreaves - FISHING FOR A YEAR • Rod and line angling is a relatively inefficient way of fishing, particularly as it is widely accepted that salmon, and to a great extent seatrout, do not feed in freshwater • In the case of both netting and illegal methods of fishing, the fish have no choice in whether they are caught or not. • Fishing for more than 40 years in a small clear river such as the Afon Wnion gives an insight into fish behaviour that will never be revealed to anglers on larger rivers • Salmon may take for a variety of reasons including aggression, a trigger from their past or curiosity. • Often they will simply “nudge” a lure or bait without taking it into their mouth • There will be many days/weeks when fish show no interest whatsoever in a lure or bait and nothing is caught (by legitimate angling) even if there are large numbers of salmon in the river. • There will be certain conditions which are favourable but these can be relatively short lived. • Never are all the fish in a shoal caught by legitimate angling. Even if the most expert anglers were to fish every waking hour it would be impossible to inflict the type of damage on a river suggested by statements such as “Neither species can sustain uncontrolled killing of fish”. • With the reduced angling effort that we are currently witnessing it becomes ever less likely that anglers are going to endanger the stocks of salmon in a river During the NRW Board Meeting at Canolfan Cae Cymro, Clawdd Newydd on 9th July 2015, Board Member Professor Lynda Warren made the point that the introduction of the national spring salmon measures in 1999, which requires all rod caught salmon to be released prior to June 16th, had done nothing to address declining stocks and therefore how were these proposals going to achieve anything different? The response was “We don’t know how much worse it would have been” The most significant words being “We don’t know…………………………” The River Tyne has been restored from heavy pollution to become the most prolific Salmon River in England and Wales, routinely responsible for around 25% of the total number of rod caught salmon. During the 2017 season 3357salmon were caught on rod and line A MAFF document reveals that between 1951 and 1961 the total rod catch was 59 salmon! There is ongoing debate as to what extent it was habitat improvement or stocking from the Kielder Hatchery that was responsible for this improvement One thing is certain however. Catch & Release would have played no part whatsoever. To suggest that without a legislative approach Salmon will disappear from Welsh Rivers is not supported by the figures from the Tyne The NRW 2014 “Know Your River” document for the Mawddach states that “the Salmon rod catch – release rate in 2014 was 72%. This is excellent and needs to continue to improve to conserve stocks. The North Wales average is 64%.” In 2017 the release rate had increased to 86.5%, largely through education and cooperation by angling clubs and riparian owners alike. At this point, the introduction of Mandatory Catch & Release cannot realise any worthwhile benefits particularly as an increase in illegal activity will result in greater losses. The motivating factors for anglers to pick up a fishing rod and head to the river to try to catch a salmon is no longer as simple as it once was. Unfortunately what NRW are failing to grasp is that Mandatory C&R drives anglers away and this was perhaps best illustrated at the joint Dee & Gwynedd LFAG held at Coed y Brenin visitor centre on Tuesday 24th November 2015 when NRW’s Principal Fisheries Advisor stated, that anglers would continue to fish because they are already putting 80% of their fish back anyway. This completely misses the point! Anglers will fish and return most, and in some cases all, of their fish but when they are told that they cannot even retain one fish, the majority stop fishing altogether. We have been contacted by Laurence Hutchinson (Director of Freshwater Solutions) who is an expert in the field of aquatic ecology. In his evidence, which is included within the CPWF documentation, he points out that NRW’s proposals are counterproductive to the recovery of our rivers. “Removing fish from the river takes the pressure off the remaining fish population also competing for diminished ecological resources. The reduction of inter-specific competition in this case has its benefits and should not be ignored. It would appear that the rod fishermen, coracles and the remaining nets are allowing these small populations of fish to survive and are not in fact the cause of their decline as the NRW claims” The effectiveness of barbless hooks, methods etc. The more difficult we make it to hook and land a salmon, the fewer anglers there will be on our rivers. Therefore decisions must be (to quote NRW) “underpinned by sound and quality-assured evidence” and not based on the opinion of someone who has no real experience of the issue in question. The “occasional” local angler is one of the first to be affected Proposed examples of ill informed method restrictions would include: Applying additional and complicated restrictions on Rapalas (and their equivalent) when simply debarbing the existing hooks will achieve the desired outcome “Each autumn a specified number of adult Salmon and Sea trout were brought into the Mawddach and other hatcheries in Wales specifically for spawning purposes. The hatcheries operated a very strict protocol where only the best quality fish in terms of their physical condition were accepted. One of the methods of capture for these broodstock was by rod fishing with lure. This method of capture became the preferred way of capturing broodstock because these fish were always in top quality condition on arrival at the hatchery.” Keith J Scriven (Former Manager Mawddach & Maerdy Hatcheries) Ill-informed assumptions on worm fishing methodology which gives rise to greater risk to juvenile salmonids and does not take into account the loopholes that arise when anglers can simply claim that they are fishing for another species (in the unlikely event that anyone would ever check). Furthermore the approach to worm fishing can vary considerably from one area of a river to another, let alone between different rivers.