appendix 1: question and response form dsfb response to ea consultation.pdf · 2016, is presented...
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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.
Managing salmon fisheries in England and on the Border Esk
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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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Managing salmon fisheries in England and on the Border Esk
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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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Managing salmon fisheries in England and on the Border Esk
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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.
Managing salmon fisheries in England and on the Border Esk
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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.
Managing salmon fisheries in England and on the Border Esk
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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.
Managing salmon fisheries in England and on the Border Esk
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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.
Managing salmon fisheries in England and on the Border Esk
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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.
Managing salmon fisheries in England and on the Border Esk
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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.