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?
“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.
The suggestion that allowing shrimp fishing from the 1 st September to 7 th October (5 weeks) is a reasonable concession to less able anglers when an artificial shrimp pattern can be fished on a fly rod from March 1 st to October 31 st (34 weeks) by someone who is more able bodied.
The reasoning that this avoids the risks associated with higher water temperatures in summer shows a total lack of knowledge of those many North Wales Rivers which have gorge pools that are well oxygenated and where a combination of small surface area relative to volume and extensive riparian shade has a major influence on restricting summer water temperatures. Also, shrimp fishing is acknowledged by all, including NRW, as the least damaging to the fish, most being lightly hooked near the front of the mouth, and is likely to produce the highest survival rates
Restrictions on hook types and sizes when there is so much variation between manufacturers and patterns “The fishing restriction byelaw (Byelaw 13 as advertised) was withdrawn. We took a very close look at all of the responses we received back and I made the call that, although the intention was sound, the delivery was flawed. To prohibit flying Cs and other methods was impossible to set out legally. The intention to fish with care and empathy cannot be set out in a byelaw and, we have made the decision to proceed with improving angler handing, equipment, methods and (I hope) the ultimate safe release of salmon through codes of practice.” Heidi Stone National Salmon Programme Manager Environment and Business Directorate, Environment Agency
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