Appendix 1: question and response form DSFB Response to EA consultation.pdf · 2016, is presented...

Managing salmon fisheries in England and on the Border Esk

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Appendix 1: question and response form

Q. 1a) - about yourself

X I represent a salmon/sea trout conservation or environmental conservation

organisation (please tell us the name of your organisation

TAY DISTRICT SALMON FISHERIES BOARD

Q. 1b) - What part of the country do you have an interest in?

Please tell us where you primarily fish for salmon/sea trout or where the salmon/sea trout

that support your business are from. You can select more than one option if you wish.

X The North East (Northumberland and Yorkshire)

Other e.g. Ireland / Wales (please specify) …SCOTLAND…………


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Section 2: introduction to the Salmon Five Point Approach

Q. 2.2a) - refers to our technical case that supports this consultation

To what extent do you agree with the summary of the current state of salmon stocks and the

supporting information provided in Appendix 2?

Wholly

X Partially

Not at all

Please give your reasons and any evidence you have to support your answer.

Broadly, we agree with summary of the state of salmon stocks and Appendix 2 so far as trends and

population pressures are concerned. However, we suspect that stocks in some rivers in NE England

may be less healthy than suggested.

Recent decline in grilse abundance

We agree that on the basis of our own experience in the Tay district over the last few years there has

been something of a step decrease in grilse abundance. 2016 was extreme for recent decades and 2017

appears to be even worse. This has not just affected summer grilse. Until very recently, a major part of

the Tay salmon population was fresh run fish (mainly grilse) which continued to enter the river in

September and some even later. In 2016 there were very few such fish after August. In 2017 the same

pattern has repeated again, but possibly even more extreme. We agree that the main driver of this

change appears to be at sea and that this situation is a cause of major concern.

While we also agree there has been some “increase in numbers of MSW fish” for a number of years,

2017 has seen lower numbers of MSW compared to the last few years. We also agree and stress that

even if MSW have generally increased in recent years they do not make up for the loss of grilse, as is

apparent from our overall catch which has fallen in recent years.


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Monthly reported rod catches of salmon in the Tay district, 1952 – 2016.

While full catches are not available yet for 2017, the catches reported to the Fishtay.co.uk website

with one week of the Tay salmon angling season to go indicate that 2017 will be a significantly worse

season than 2016. While not all beats report on fishtay most of the major ones do. It is therefore a

good guide.

We suggest that any increase in MSW may have been a consequence of salmon doing badly in their

first year of sea life and that the maturation of some fish that might previously have returned as grilse

has been delayed, should they survive. If the increase in MSW has been caused by grilse doing badly,

the increase in MSW may not be something that should be taken as a good sign. We fear that, since the

near UK marine environment appears to be hostile to salmon, the possibility must exist that a smolt

year class might experience such a level of initial mortality that few fish of any sea age return. Such

events, were they to occur, cannot be predicted in advance. Therefore we agree that any further

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increase in mortality on MSW (as occurred in 2017) will hit egg deposition disproportionately.

Management must now reflect this potential reality.

We agree with the proposition that, while individual MSW fish may produce more eggs than grilse,

any increase in MSW numbers that has occurred may not have made up for the loss of grilse. We also

suggest that if more fish do in effect delay their maturation, the proportion of males among MSW

salmon may increase. It has previously been considered here that 2SW salmon are largely female, and

that grilse returning in the summer months mainly male. But if an increase in MSW was at least in part

caused by an increase in proportion of male MSW there would obviously be implications for egg

deposition estimates. Also, as male salmon average a little heavier than female salmon for a given

duration at sea (perhaps as much as 25%) any such change could impact on average MSW weights too.

We suggest that the possibility that this might have occurred should be investigated in the Tamar trap

data and any others (Chester Dee?).

We also find that in spring, salmon are later. Any increase in “spring” catches in recent years has

hardly registered in the very early weeks of the season (January – February). The main runs are much

later, often including June, when 2SW fish are bigger than in the weaker earlier runs. We would also

agree that as the distribution of MSW fish has shifted later, this makes them more vulnerable to the NE

drift net fishery starting on 1 June.

You mention that there is no a large difference in the monthly average size of MSW fish caught by

anglers throughout the year. We caution how such data are interpreted. If there has been a decline in

numbers of genuine fresh running “autumn” fish (such fish have been almost absent in 2016 and

2017), a greater proportion of fish caught by anglers in the autumn will be fish that entered earlier in

the year. If autumn angling catches comprise mainly coloured fish then angling catches will not be

reflective of genuine biological changes in salmon over the year. They are better deduced from

facilities such as the Tamar trap.

We agree with the Tamar data that grilse have been getting smaller and there is a considerable body of

data in Scotland mainly collected by Marine Scotland Science confirming this. While we have only

collected limited data from the River Tay, we also suspect that for fish of a given sex and duration at

sea, MSW fish have also become smaller. This might not always be apparent from catch data because

these are often compounded by changes in run timing, sea-age and perhaps sex ratio, described earlier.

For example, if Tamar 2SW salmon are getting later, like “spring” salmon here, then the fact that

weights appear to have held up may just be a consequence of fish being at sea longer while weight for

an equivalent time at sea could have decreased.

We suspect that performance over the last few years may have varied across geographic populations. A

well monitored Tay tributary with a fish counter, the River Tummel, held up well to 2016 with more

MSW (things have changed dramatically in 2017). This is a tributary that has always had a significant

early running MSW component as well as grilse. On another tributary with which we are very familiar

which has a reputation for largely producing mainly late summer / early autumn grilse, casual

observations (there is no counter) do not suggest any large compensatory swing to MSW. Some recent

electrofishing surveys in the upper extremity of this tributary suggest a possible impact on juvenile

production in some years.


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Conservation Limits

We note that compliance with conservation limits continues to be the major decision making process

in English rivers. In previous correspondence with DEFRA and EA regarding the North East coastal

fisheries we have expressed concern over the accuracy of the methodology for estimating conservation

limits as applied to some of the rivers at least in NE England. The conservation limits may be too low.

In the interests of brevity we will not repeat the previous arguments but we are happy to supply

previous correspondence on the subject.

That said, as you may be aware, Marine Scotland Science have also introduced conservation limits in

Scottish rivers in the last two years. They have adopted a somewhat different methodology to that used

in England and Wales. We thought it might be interesting to compare the two methodologies.

In order to do this we plotted catchment area against conservation limit for a number of rivers up the

east coast of England and Scotland up to the River Spey. This is shown below. While this only makes

use of the area above the lowest gauging station on each river (being readily available on the NRFA

website), the error that might create is clearly masked by big differences between the English and

Scottish rivers shown. The relationship between catchment and conservation limit is much steeper in

Scotland than in NE England.

If the Tyne, for example, was assessed using the method being applied in Scotland its conservation

limit would be something like five times greater than it currently is.

Our feeling is that the method used in Scotland may be reasonably accurate in the more productive

Scottish rivers with abundant salmon habitat, but probably overestimates rivers which naturally have

limited good juvenile salmon habitat (e.g. lowland rivers), but the method used in England probably

greatly underestimates rivers with good habitat.

That this may be the case means that the electrofishing data presented in Figure 10 of Appendix 2 is of

no surprise to us. Fig 10 places catchments into one of four categories. We note that this finds the Tees

in the poorest category. It is also in the poorest conservation limit compliance category. However, we

note that the Tyne and the Wear are both in the second lowest electrofishing category, but are in the

“probably not at risk” category with respect to the conservation limit. We feel that actual electrofishing

data from the ground is a more reliable guide to reality than the abstract conservation limit concept.

We suggest that a fundamental root and branch review should be undertaken of how conservation

limits are estimated in England.


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Conservation limit figures for NE English rivers were obtained from the NE NLO Review 2012

Fisheries Assessment Report.

Changes in CPUE of coastal net fisheries in NE England

Section 7.13 of Appendix 2 mentions that a previous analysis had suggested that lower than average

river flows in July tended to coincide with higher CPUEs in the drift net fishery. This was of interest to

us as the table of CPUE data (Table 6) seemed to indicate higher CPUEs in recent years, and worthy of

further investigation.

A graph of average July flow for the River Tyne at Bywell versus CPUE in the drift net fishery, 1997 –

2016, is presented below. Although the trendline fitted by Excel indicates slightly downwards, this is

not statistically significant (p = 0.27). There is no such demonstrated relationship therefore.

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We also tried separating the data into three time periods, 1997-2002 (pre buyout), 2003-2008 (post

buyout but pre carcass tagging) and 2009-2016 (post buyout with carcass tagging). In none of these

periods was there any significant correlation between flow and CPUE. As can be seen below, indeed,

the central period is very much a flat line.

The graph below also shows that at the lower flow end, where most of the points lie, the CPUE post

tagging (i.e. most recently) has been higher than it was in the years immediately after the buyout. The

CPUE in the years pre-buyout under drier conditions appears closer to the CPUE recently. However, a

view has been expressed that the two years of highest CPUE in the pre buyout period (2000 and 2001)

may have been inflated by exaggeration of catches during the time of buyout negotiations (this was

stated in the Tyne Salmon Action Plan Review, although another interpretation was advanced by some

at the time.) If the accuracy of declared catches in 2000 and 2001 differed from immediately preceding

years, then there would possibly also be a clear difference in declared CPUE at lower flows between

more recent times and pre buyout.

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While river flows may well be in the mix of factors which influence declared drift net catches, some

other explanation is required for why CPUE (declared) in lower flow years post 2008 may be higher

than before.

We suggest that the possibility that the accuracy of reported catches has improved since the

introduction of carcass tagging should be considered. Were it to be found that there was greater under-

reporting of catches in this fishery than previously stated in official documents then the historical

impact of this fishery will need to be reassessed.

Scotland

Table 4 on page 26 of the Consultation Document gives a list of Scottish salmon rivers exploited by

the North East fishery. The list includes rivers all the way from the River Tweed to the River Dionard

which in, west Sutherland, is a very long way from Northumbria.

Previous evidence from tagging studies, generally accepted, suggests that the vast majority of these

rivers will be very little affected by the NE fisheries, if at all. The main affected part of Scotland is that

closest. Principally the Tweed. While considerably less than the Tweed, there is evidence that the Tay

is also affected and by inference presumably the rivers in between such as the Earn and Eden in the

Tay district and the rivers of the Forth district.

The rivers shown below are all in the immediate impact zone of the NE fisheries. All have been

proposed as Category 3 for failing to meet conservation limits by Marine Scotland for 2018. All were

omitted from Table 4.

Future documents should be amended to reflect the Scottish rivers actually impacted by this fishery. It

would also be useful to provide estimates of impacts on Scottish rivers, e.g. on Table 5 of the

Consultation Document.


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Section 3: deciding which salmon stocks need further protection

Q. 3.2a) - this question is asking for your views about taking salmon from rivers that

are failing to produce enough salmon to maintain populations

To what extent do you agree that a salmon stock should be subject to additional protection

from net/fixed engine and rod exploitation if it is classified as either At Risk or Probably at

Risk of failing to meet its Management Objective?

X Wholly

Partially

Not at all

Please give your reasons and any evidence you have to support your answer. If you would

like to provide us with an alternative approach then please do so.

By removing or reducing exploitation in failing rivers, particularly rivers which are being cleaned up

which are inherently productive, the recovery of salmon populations will be accelerated, or at least

given the present difficult marine conditions, prevented from declining again.


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Q. 5.4d) - seeking all consultees’ views on the options for the North East Coast Net

Fishery.

Which is your preferred option for the North East Coast Net Fishery as set out in Section 5.3:

Table 3?

X Option NE1

Option NE2

Option NE3

I don’t have a preferred option

Please provide details of why you have given this answer.

.

We prefer full closure in 2018 and do not see any justification for continuing fishing for sea trout using

present methods.

We agree with the proposal that coastal salmon netting in NE England should cease completely from

2018. In our view there never has been any justification for this fishery on the grounds that it mainly

takes Scottish fish and contributes nothing in return towards the production of that resource and that it

has held back and is still holding back recovery of salmon populations both in recovering post-

industrial rivers in eastern England and SE Scotland. The extent to which it has held back recovering

rivers in eastern England has been underestimated because of the underestimation of conservation

limits for those rivers. While we welcomed the decision to close these fisheries in 2022 when it was

made, we consider that the new developing realities of salmon and grilse abundance means that this

decision should be brought forward five years.

We also do not consider it in any way acceptable that fishing could continue for sea trout using drift or

T and J nets on the basis that all salmon are released.

When salmon are caught in monofilament/multi-monofilament nylon gill nets they generally are

damaged to some extent. According to Potter (1991) salmon typically thrash strongly for about 30

seconds on hitting a gill net. Having used trammel nets to catch broodstock salmon we confirm such

behaviour. Salmon that have not been “played out” are very strong.


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Salmon thrashing immediately after

striking a trammel net in a river. We

understand this behaviour is typical

of fish striking a gill net in the sea

too.

Given the lengths of net involved etc, even when a net is attended as here, it will never be practically

possible to reach a trashing fish immediately. There will inevitably be a delay. The main thrashing

episode will never be prevented.


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These are the types of net in use, Filey, Yorkshire, July 2017.


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Damage of at least a surface nature is practically unavoidable, whatever is tried. The illustration below

in typical.

Displayed in a fishmonger’s shop in Whitby, July 2017.

Sea trout displays clear “net marks”, concentric rings of scale loss around its body due to

abrasion.


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Smaller salmon. Scale abrasion again very apparent. Split dorsal fin.

Net marks less apparent, but there is some scale loss. Damage to front edge of dorsal fin is a

giveaway.


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It was because of the level of damage sustained by fish that established salmon netsmen in Scotland

did not adopt gill netting in the 1960s. Pressure from them, perhaps more so than from anglers at the

time, led to bans on drift netting in 1962, use of fixed gill nets from boats in 1975 and fixed intertidal

gill nets in 1986.

Some might claim such damage is trivial. We do not think so. While superficial damage (so long as it

is only superficial) may not affect fish much at sea, as claimed by studies of tagged salmon released

from gill nets and recaptured mainly by other net fisheries, such damage is of much more significance

once the fish enters freshwater. While such a concern might not be high in a high seas fishery where

fish may be months away from freshwater, it is in a coastal fishery where fish may only be days or

hours away from entering a river.

We find that in some tributaries in the Tay catchment outbreaks of Saprolegnia fungus are a common

occurrence in late spring and summer if low flows occur. In fact, this year 2017, during a late spring

drought it was also apparent in the main stem of the River Tay. Damaged fish are more vulnerable to

such infections and, if infected, help to spread more spores.

Sanctioning a catch and release salmon fishery using nylon gill nets is simply unacceptable.

If you would like to suggest a different approach and your reasons for suggesting it, please

do so here.

Should it be considered desirable to continue to have a sea trout net fishery then we suggest it should

take place in or around river mouths using beach seine nets only.


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Q. 5.4e) – this question is for all consultees to answer and is in reference to the

answer that you have given to Q. 5.4d

What are the benefits, if there are any, which you would see from your preferred option for

the North East Coast Net Fishery? These could be economic as well as social/cultural,

please provide details if you are able.

Faster recovery of populations of salmon in recovering rivers in E England and SE Scotland. We note

that the Ouse system is not yet part of the compliance scheme. It ought to be as it is already producing

more salmon than some rivers in NE England and has potential to be a major salmon producing river.

It will help sustain salmon populations in established salmon rivers in eastern Scotland, particularly at

this difficult time.

On all these rivers it will either lead to the development of a better angling economy or underpin the

angling economy where these currently exist. This provides jobs across a wide area for a range of

tourism providers.

By removing this issue, it will encourage local fisheries and conservation interests to put more effort

into caring for their rivers locally which is particularly of value in improving rivers. A lot of money,

time and effort is being put into improving access in rivers in eastern England and in SE Scotland.

Those that do so will feel their efforts more rewarded knowing that the fish they produce are not being

taken by a fishery that does not contribute its share.


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Additional views

Q. 7) - this question is for all consultees

Please tell us if you have any further comments that you would like to provide on this

consultation.

With respect to consideration of the NE coastal fisheries, more consideration should be given to its

impact on Scotland.

Appendix 1: question and response form DSFB Response to EA consultation.pdf · 2016, is presented...

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