A statistical summary review of the NRW technical conservation case - - PowerPoint PPT Presentation

A statistical summary review of the NRW technical conservation case for introducing THE WALES ROD AND LINE (SALMON AND SEA TROUT) BYELAWS 2017 THE WALES NET FISHING (SALMON AND SEA TROUT) BYELAWS 2017 Mike Ashwin, Chris White & John Eardley presenting Objections for CPWF

In the short window period (20-30 years) since formal stock assessments were introduced, scientists and fisheries have yet to monitor or experience the longer span climatic and ecological impacts on our migratory stocks. We are only now beginning to see the major 1SW & MSW component transitions emerging and predicted over 50 – 60 year cycles . Our monitoring of migratory life cycle populations are at best incomplete and we have major resourcing issues to

• vercome. Parties need to work together.

Monitoring and stock assessments reporting systems must be reviewed, tune in and adapt to these big trend changes if individual river stock performance & health can be used with confidence to guide and set Regulatory measures.

Significant trend changes reported in the 2017 Cefas (NRW & EA) National Assessment & Fisheries Statistics report

“True” exploitation by Net & Rod fisheries ( salmon caught and killed) has reduced by 90% since 1970 In Wales the number of rod caught salmon released annually has improved dramatically from 7% in 1993 to 86% in 2017. Anglers have been guided by peer pressure and are observing and adopting conservation codes Over that same period Angler Days fished for Salmon & Sea Trout in Wales has dropped by 60% from 118,862 (1994) to 47,092 in 2017 Yet over the long term angler Rod licence sales in England & Wales have remained reasonably constant 37,728 in 1994 compared with 35,162 in 2017 Most noticeably marine smolt survival rates have crashed by 90% - WHY ? 1970`s 1SW - 25% & MSW - 15% 2017 1SW - 2-4% & MSW - 1-2% (Dee, Tamar, Frome estimates) A tenfold decrease

CPWF Objections and concerns are presented in four sections. In simple terms the four stages of determining a rivers stock assessment The report will conclude with presentational issues and a short analysis of alternate modelled systems - summarising recommendations made to Defra and Welsh Ministers to improve and harmonize Welsh & English systems and introduce a single conservation strategy

• 1. the principles and methods adopted for setting and monitoring

conservation targets - Conservation limit setting (CL), salmon stock dynamics and River smolt deficits

• 2. identifying and highlighting concerns with the capture and use of

core data for reporting Annual River egg deposition estimates to Conservation limit (CL)

• 3. explaining weaknesses and flaws in the methodology and systems

procedures where the national River Classification model is used to designate River Stock status

• 4. the final decision structure process and measures applied

1. Conservation Limits, salmon stock dynamics and River smolt deficits Conservation Limit (CL) principles for setting Biological Reference Points (BRP) for managing and maintaining sustainable salmon stocks were adopted in England & Wales for monitored salmon rivers, following transportation of the River Bush statistical model in the 1990`s. Revised model principles being adopted from the 1997 EA commissioned Wyatt & Barnard Technical reports The setting of BRP`s established minimum sustainable CL targets (River egg depositions and juvenile recruitment from spawning stock) above which stocks should be maintained in the long term with higher advisory Management Targets (MT) for managers to aim for. In terms of physically assessing stocks  we are unable to actually monitor or estimate whole river smolt output  and Actual Spawning River egg depositions are estimates, either :-

• from declared Welsh rod angler catches (21 of 23 individual Rivers)

based on estimates and assumptions that the declared rod catch is a rod exploitation factor of the total spawning run

• or for two Welsh rivers, that the “efficiency” of counters or traps is

accurately monitoring a “validated “ proportion of the adult run

The conservation model in England & Wales used was introduced in the 1990`s and a River Classification trend model added to this in 2003. The 2003 trend model did not undergone Validation and its use for designating five year forward River “trends” and a Rivers stock status in the proposed regulatory measures is hotly contested and under scrutiny Today the Conservation model uses Sea Survival (Replacement Line) estimates that are out of alignment and Annual River assessments that use rod catch and exploitation estimates that require significant correcting or do not correct for important seasonal factors (e.g. rod effort, river flows, closed season runs) The challenges that our salmon stocks face are set out in the NRW conservation case BUT the Technical case document does not assess or quantify “Life Cycle” stage challenges or prioritise these in terms of their total impact on stocks. Doing so would identify strategies that should be prioritised above others Rod exploitation (retained fish) would appear well down that list (1- 2% of spawning stocks) and might not appear at all - given the negative impact mandatory measures would have on rod fisheries activities - fisheries do guard and improving stocks and habitat, and contribute socio/economic benefits

50 100 150 200 5,000 10,000 15,000 20,000 25,000

Adults Smolts (thousands)

Conservation Limit = 5,000 adults Management Target = 6,200 adults Max sustainable catch = 7,700 adults Replacement point = 15,000 adults Max smolt prod = 11,500 adults

An example Conservation model illustrating the SR curve (blue line) and replacement line (red line) to derive Conservation Limits This graph is unusual in that it depicts more tangible spawning adult numbers on the X axis rather than the normal spawning egg deposition values In the SR curve the River Maximum smolt output of 160,000 smolts would be produced from 11,500 spawning adults

The conservation model illustrating how changing sea survival trends impact

• n a rivers smolt output requirement

The strong red line being 10% sea survival (e.g. 50,000 smolts provide 5,000 adults) As sea survival diminishes and the RL steepens we reach a point at 2.5% sea survival (red dotted line – far left) where the smolt output to meet the same 5,000 adults at CL is now 200,000 smolts. And exceeds the Rivers optimum or maximum smolt

• utput - 160,000 smolts

At the example CL target of 5,000 spawning adults the rivers smolt output requirement to meet estimated sea survival losses has increased from 1990`s - 25,000 smolt output (average 20% sea survival) 2000 - 50,000 “ “ “ 10% “ “ 2016 - 200,000 “ “ “ 2.5% “ “ Even with 12,500 spawning adults and a River at pristine juvenile condition the River only has a maximum carrying capacity to produce 160,000 smolts. Sea survival losses are

• utstripping the Rivers ability to compensate even at its
• ptimum carrying capacity

It is widely accepted that sea survival has now reached levels where migratory populations are at risk and may not be sustained even at CL targets.

• 2. Capture and use of core data in reporting Annual River egg

deposition estimates to Conservation limit (CL)

A complex matrix of River datasets and variables are used to produce a Rivers final total estimate of spawning eggs deposited. These include :-

• Rod catch estimates from angler declared catches (or counter/trap data for Dee

& Taff)

• Corrections applied for angler under reporting
• Rod exploitation rate multipliers for rod catch derived Rivers
• Mortality adjustments for natural River losses and C & R handling
• Age/weight scale calculations to estimate the proportion of 1SW & MSW

component stocks

• proportions of female spawners in each 1SW & MSW class
• Fecundity or female egg depositions calculated from the estimated age/weight
• f rod caught fish

We will look at the first three of these as they form the core data or building blocks for stock estimates and directly relate to angler & fisheries activities

!!! How accurate are current Angler rod catch estimates ? !!! Historically and until 2015 NRW & the EA processed angler catch returns and applied a standard 1.1 multiplying factor to take account and correct what was estimated to be under declared catches at 91% of their real value. These are assumed to be anglers that caught little or no catch, predominantly short term licence holders & juniors and for this reason reported as not materially affecting the provisional total declared rod catches. In 2017 in England & Wales 41% - 14390 of the total 35162 season and short term licences issued did not have an angler catch return received or processed At the close of 2015 a number of River fisheries representatives who compiled reliable independent total river fisheries returns started to report unusually high discrepancies between the provisional reported river angler declared catches and their own. The national estimates appeared to be 20 – 40% below their figures No definite explanation was provided for this, but the under reporting error continued into 2016 & 2017 and is now believed to be partly attributable to a new “On line” angler catch reporting system being introduced. Steps were taken for rod catch uplifts to be applied to most Rivers in E & W to compensate for this. On Average : - 2015 - 1.36 uplift (an additional 36% applied) 2016 - 1.32 2017 - 1.28

CPWF & NWATFCC believe the current annual assessments have been compromised by reporting or system failures that are difficult to quantify. Importantly our own investigations on two major fisheries with reliable long term data show that we believe the low reporting at significant levels may pre date the 2015 adjustments.

Table 4 Independent Rod Fisheries catch comparisons to NRW Angler declared catch illustrating variance to NRW Underreported angler catch corrections in River CL estimates

CPWF & NWATFCC have made recommendations to NRW & the EA that effective penalties should be introduced for anglers failing to report

• catches. Reporting of paper and On line system need to be integrated so

that the national reporting offices at Bristol work to real time information where only non reporting anglers are sent reminders and penalties as required. We have already expressed serious concern that a new licence system, introducing 12 month migratory licenses that can be purchased at any time in the calendar year will cause considerable confusion as anglers are required to submit two returns over split years. NWATFCC worked with the EA to self audit their system providing 40 NW angler contacts who resubmitted their 2015 & 2016 returns to the EA.

We are not confident the cause or causes have been identified or measures are now in place to provide reliable and accurate capture of rod catch data

Do rod exploitation rate multipliers accurately reflect individual river estimates ?

Once rod catch estimates are corrected and fish grouped by age/weight proportions of 1SW & MSW component stocks, rod catch is flexed by individual rod exploitation factors to arrive at the estimated total numbers of male and female salmon spawners in the river (this is before mortality losses are deducted) It is widely recognised and reported in the NRW, EA & Cefas Salmon Stocks Assessment of 2017 and Annual reports going back to 2004 that rod exploitation rates do not account for a number of key factors that influence rod catch as the baseline metric for spawning estimates. The EA & Cefas undertook to improve the application of these factors in 2004 and restated their intention to introduce procedures post 2008. However no systems have been introduced to quantify what are significant trends in fishing effort and weather conditions.

The 2008 & 2017 National Background Assessment report states as follows: “Annual compliance with the CL is estimated using egg deposition figures. These are derived from returning stock estimates (Table 27), where such data are available. However, for rivers without traps or counters, the usual procedure for estimating egg deposition involves derivation of run size from rod catch using estimates of exploitation. Currently, these procedures do not take into account annual changes in fishing effort. In years when effort was low – such as the ‘low-flow’ year of 2003 and the foot-and- mouth disease year of 2001 – this approach has probably resulted in rod exploitation being over-estimated on a number of rivers and hence escapement and egg deposition being under-estimated. In wetter years, when conditions are more favourable for angling and fishing effort increases, the opposite is likely to be true. An improved procedure is being developed by the Environment Agency to take account

• f annual changes in fishing effort, as well as partitioning effort between salmon and

sea trout (no distinction is currently made between these species when reporting fishing effort, but see analysis in Section 1.2.4). This procedure will be used to improve assessments in future reports. Many rivers, and particularly some of the smaller catchments on the west coast of Wales, support relatively small salmon stocks and are principally regarded as sea trout

• rivers. Current procedures may also fail to take adequate account of this”.

5000 10000 15000 20000 25000 30000 20000 40000 60000 80000 100000 120000 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Salmon & S/T Days fished Salmon declared catch Sea trout dec catch

Angler Days fished combin ed salmon & sea Angler Declared Catch

Welsh River Days Fished and Angler Declared Catch 1994 - 2017

Table 5. Reducing Angler Rod effort - figures supplied by Environment Agency Wales for the Rivers Mawddach & Wnion between 1994 - 2009 to illustrate its trend and impact on reported rod catch

As acknowledged above, these omissions are principally Rod Effort (time & species split), Weather/River conditions and actual numbers of fish that may be “missed” in river spawning estimates when they run the river after the season closes. It is very clear that rod effort has declined significantly and potentially exploitation rates also. These trends need to be reviewed and where necessary flexed annually so that rod catch and total spawning estimates take account of these seasonal changes. Appendix A Table 2 CPWF`s own analysis of species rod effort by individual River show that there is considerable variation in angler effort between salmon and sea trout and that this adds another layer of uncertainty to reported catches and the accuracy of River rod exploitation estimates. This variation reflects the wide diversity

• f river habitats and species populations that characterise Welsh game rivers. “No

two rivers are the same” Catch per Unit Effort (CPUE – number of days per salmon or sea trout caught) is used as a national indicator of rod effort/stock presence in the river but uses an aggregated salmon & sea trout number of days fished. Angling effort by species is not recorded and the CPUE output is of limited value. CPWF and NWATFCC have recommended that in future angler returns include separate sections for reporting day’s effort by species.

CPWF note in Ian Davidson Rebuttal evidence - January 2019 (NRW/2R) on failure by the EA & NRW to review River exploitation rates (for Rivers without counters & traps) that a review is now being reported as being underway. It states :- 3.8 A review of the models used hitherto to derive angling exploitation rates on rivers without traps or counters is currently underway. This is being conducted jointly by NRW, EA and Cefas, and is supported by a statistical modeller working with the Game and Wildlife Conservation Trust (“GWCT”). The review aims to develop a single model to apply to all rivers - building on and refining existing procedures with the aim of utilising a version of this model in the 2018 assessment. 3.9 This refined model will draw on recent developments by NRW in this area; namely the exploitation rate model used to derive sea trout returns/spawner numbers from rod catch

• data. The sea trout model responds to annual changes in species-specific fishing effort and

includes a variable to account for in-season flow conditions. 28 The model can be readily adapted for salmon but (pending the above review) hasn’t yet been formally applied to this species. However this will Not Correct historic Assessments contained in the Welsh Byelaw proposals which are acknowledged as being calculated on exploitation rates that are inaccurate.

This is the reason that CPWF wrote to the Minister in April & Sept 2018 requesting that interim Byelaw measures are introduced until new assessment procedures are agreed and in place.

Welsh Dee Chester Weir trap operations & validated river estimates

• how the Dee Angler log Book system & trap operations defines the efficiency of the

counter and the Rivers whole validated run size estimates

• determines and sets rod exploitation rates for other Rivers

The Index River Dee are critical to National stock monitoring, providing the longest E & W River datasets and trends. Welsh Dee exploitation rates are used for estimating CL for the Wye & Usk ( using 5 year rolling averages), Dyfi, Mawddach, Galsyn, Dwyfawr, Seoint, Ogwen, Clwyd (10% early year estimates) and other welsh Rivers based regression modelled effect of fishing effort to its exploitation rate. The Dee also provides and sets rate estimates used for NW Rivers. And nationally age/weight and smolt survival trend data Information requests made by CPWF to NRW reveal that rod exploitation variables for the Welsh Dee are flexed annually on total rod catch estimates of 1SW & MSW rod caught salmon based on their proportions to the whole river estimates determined by the log book/trap operations. NRW in their 2017 Stock Assessment Programme Angler Report indicate that rod exploitation estimates for the Dee (to produce the total run size estimates) only use the core rod catches from anglers using the Dee Log book scheme. It is not reported how many Dee log book anglers use the scheme, what the total scheme annual catch is or whether this is a suitable sample size in relation to what are understood to be substantial numbers of other Dee anglers not in the scheme. In 2017 the national Statistics report 656 Dee anglers declared rod effort and 5835 rod days were fished.

There is NO other whole river independent count data to verify or control whether this whole River run size estimate is accurate. Bear in mind the Dee trap is not operational for 40% of the time and with an unquantified sample size of log book scheme anglers or details of their effort (time & location) it is clear why rod fisheries are questioning the counter efficiency, its total run size estimates and the final exploitation rates derived from the larger whole angler catch returns. Seasonal factors including weather/river patterns, high tides topping the weir and total rod effort adds further doubt.

Without further clarification CPWF conclude there is uncertainty of the casual influence of these underlying factors on this important facility for setting Welsh exploitation rates. We recommend a fuller breakdown of the log book scheme is reported in the Annual report is published

NRW in their 2017 Stock Assessment Programme Angler Report indicate that rod exploitation estimates for the Dee (to produce the total run size estimates) only use the rod catches from anglers using the Dee Log book scheme. It is not reported how many Dee log book anglers use the scheme, what the total scheme annual catch is or whether this is a suitable sample size in relation to what are understood to be substantial numbers of other Dee anglers not in the scheme. In 2017 the national Statistics report 656 Dee anglers declared rod effort and 5835 rod days were fished (salmon & sea trout)

The assumption being that the proportion of Log book anglers rod catch of tagged fish to untagged fish mirrors the same proportion of trapped/tagged Chester weir salmon to the whole River run and that this determines the “efficiency “of the counter, reported as being between 20 – 30%

• 3. Validation of the national River Classification stock status Model

The current National River Classification model first introduced in 2003 is not validated and not undergone regular independent scrutiny. CPWF and Welsh fisheries are concerned that the proposed regulatory measures are open to challenge With a national model of this importance to recreational and commercial fisheries, routine validation procedures should take place to provide assurance of the system and accuracy of river Classification model “predictions”. Had validation taken place, improvements to the model would have been identified and appropriate actions taken at an early stage. We believe these concerns are in tune with leading experts who speak of the need for future change and improvement to salmon stock monitoring and River assessments procedures CPWF has collaborated closely with NWATFCC (North West Angling Trust Fisheries Consultative Council) since February 2018 and with support of the Angling Trust commissioned independent statisticians to undertake a statistical evaluation and analysis of the River Classification model.

The Statisticians Qualified Statement & full Report can be found in Appendix B - River Classification Model. This evaluation of the model and its use confirm there are fundamental flaws and weaknesses, which would have become self evident with independent validation. CPWF, NWATFCC believe a review of the current methodology for Stock Assessments is long overdue. Significantly the draft NASCO 2019 to 2024 Implementation Plan for England & Wales circulated for comment in November 2018 incorporates

• bjectives for such a review within a three year timetable, excerpts below :-

CNL (18)50 NASCO Implementation Plan for period 2019 - 2024 What are the objectives for the management of the fisheries for wild salmon? (Max. 200 words) There are plans to review the current methodology for assessing salmon stocks, as well as the associated compliance scheme and decision structure, and to consider the need for possible improvements (see Section 2.8). The aim is to undertake this within the next three years; this Plan will be updated at that time, as necessary, to reflect changes. CNL(18)50 NASCO Implementation Plan for the period 2019 – 2024 See also: Fisheries Management Focus Area Report for EU-UK (England and Wales) (IP(08)05(rev) [ http://www.nasco.int/pdf/far_fisheries/FisheriesFAR_EnglandWales.pdf

NWATFCC & CPWF have submitted a joint response to NASCO with comments and

• ur recommendations concerning the current methodology for assessing stocks and

expressed our wish to be consulted as important stakeholders with a direct interest. The independent statisticians are able and willing to engage in this process We have received assurance from the England & Welsh NASCO representative

• ur submission will be considered, and from the EA , NWATFCC has received

confirmation that we will be invited to participate in the review process The Statistician Statement and conclusions have been forwarded to Defra and NRW, EA & Cefas and one response was received by fisheries from the Defra Minister on the 25.05.18 to a NW Chairman of the Ribble FA containing a Cefas critique of statisticians Report The Cefas critique was forwarded to the Statisticians, who replied and rejected many of the comments it contained. NWATFCC forwarded the Statisticians response to Cefas, EA & NRW and we received no further communications. The comments are set out following the Statisticians report

The national Conservation Limit & Stock Assessment workshop - July 2016

Prior to these events the National Institute of Fisheries Management, Atlantic Salmon Trust and Environment Agency (IFM/AST/EA) held an important national workshop in July 2016 to consider the future of Conservation Limit (CL) and Stock Assessment. Leading experts in this field were present and key note speakers gave presentations focusing on the concerns associated with Assessing Stocks and the need for future changes and improvement to the national Stock Assessment process, including use

• f the River Classification Model. NRW experts and specialists were present and

contributed to presentations by Ted Potter of Cefas. Ivor Llewelyn (Director AST) in his circulated summary workshop paper titled: Possible changes to Conservation limits and Stock assessment in England made a number of key guiding observations and recommendations, excerpts include :- Compliance Assessment The present system is complicated and hard to understand, even for fisheries managers and has important flaws.

Its essence is genuinely simple however: the current objective of managers in England and Wales (the Management Objective) is that stocks should not fall below their CL’s in more than 1 year out of 5, or 20% of the time over the long term. To achieve this, the stock size that managers aim to achieve (the Management Target) is set well above the CL; it is typically around 35% higher than the CL. However additional complexity has been introduced into the system, linking trends in river stock performance to predictions of future abundance, in order to forecast stock levels against CL’s in five years’ time. “This makes assumptions about continuing linear stock trends which are untenable”. The figures below show the percentages of rivers in the different assessment categories in the two most recent Annual Assessments, with the percentages forecast five years’ previously (in 2009 and 2010 respectively). Given the differences between the ‘forecasts’ and the actual figures, the value of this particular exercise is questionable due to the difference between the predicted and actual forecast after five years. Furthermore, the probabilistic reporting metrics used i.e. probably at risk, probably not at risk, etc. are also confusing. The benefits of the simple compliance test (above) appear to have been lost in the attempt to make the process more comprehensive.

When evaluating the status of a stock it is nevertheless informative to consider the recent trend in stock abundance as well as the current level of abundance, so alternative ways of doing this need to be considered. One option would be to use a 5 year period of observations, and/or non-linear analysis, which would better reflect recent trends in the stock size; this, though, would greatly increase the uncertainty

• f the assessment.

In terms of the decision structure currently, decisions are linked to the forecast probability of falling within a particular category in five years’ time. Given the weakness of the current forecasts (discussed above), consideration could be given to basing decisions on current assessments, with various decision trees linked to the actual status of the stock i.e. At Risk, Probably at Risk etc. CPWF analysis of the accuracy of NRW 5 year forward stock status “predictions” of Welsh rivers in the four years from 2013 to 2016 shows that there has been a high level of inaccuracy, with :

Only 41% correct - 2013, 41% - 2014, 27% - 2015, 18% - 2016

These stock status “predictions” are the central performance indicator of stock health on which the Byelaw measures are proposed and a major cause of concern. Recent Welsh River stock classifications are incorrect in four out of five cases. Basing legislation on a on five year forward ‘prediction’ of stock index trends that have such poor accuracy and correlation to actual stock events is extremely worrying to fisheries

The letter from Mark Lloyd of the Angling Trust to the Welsh AM Cabinet Secretary

• n 17.09.18 (CPWF/12) outlines specific assessment flaws and refers :-

We have reviewed the CEFAS response to the independent statisticians’ critique of the current methodology, but we have outstanding concerns about:

• validation of the system;
• the ambiguous and imprecise compliance to management objective;
• use of linear regression trend and five year forward extrapolation;
• the impact of changes to rod effort, river flow, out of season runs and imprecise rod

angler catch reporting;

• poor correlation between past predicted and actual forward stock performance.

We understand that it takes time to introduce new methodologies, but we need to see a clear acceptance from government that such a change is necessary and a commitment of funding to pay for staff to develop a new system in which there can be greater confidence. We would be happy to work with EA and NRW staff to develop this in partnership.

!!! How reliable are Five year forward extrapolated stock predictions ? !!! The Wye has a history of meeting CL only once in the last 10 years, with stock status predicted to be PNaR in 2022. The 2016 - 2021 stock assessment chart illustrated below, indicates where 2017 & 2018 compliance is anticipated based on 96% compliance in 2017 and rod catch estimates of 50 – 60% Compliance for 2018 As the statisticians conclude - using 10 year Linear Regression trends with an assumed 5 years additional bolted on trend is not a reliable predictors of forward trend where rivers do not exhibit steady trend patterns

River comparisons of CL attainment and trend performance

2016 2021 showing Percentage of Conservation Limit Attainment %

Compl Predicted 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Compl Mawdach 169 148 99 236 199 199 73 75 106 130 PaR PaR 5 year MAT 176 161 156 130 117 Glasyn 96 146 106 78 122 107 193 104 147 68 PaR PaR 5 year MAT 112 121 121 135 124 Ogwen 302 365 216 347 244 231 112 39 135 101 PaR PaR 5 year MAT 281 230 195 152 124 Conwy 207 212 153 331 200 164 107 76 100 135 PaR PaR 5 year MAT 212 191 176 129 116 Wye 40 59 35 25 50 79 79 43 95 131 PaR PNaR 5 year MAT 50 54 55 69 85

This table illustrates other important Welsh Rivers with Good stock performance

• annual CL compliance and 5 year MAT trend yet designated as PAR

(mandatory measures) compared to Wye CL performance and PNaR status

We believe there is every reason to question the use of the model in the proposed byelaws and make again our request for an independent stock reporting review

• 4. Decision Structure Process and NRW presentation of River stock health

performance to support its Option 2 measures Salmon - Egg deposition ranking tests. NRW present a case for mandatory 10 year byelaw measures using a combination

• f stock health indicators ranked in order of weighted significance.

a) River stock status classification b) 10 year long term linear trend egg depositions c) 5 year short term annual egg deposition shortfall comparisons to MT Each of these performance tests actually use the same base River egg deposition

• metric. For b) the 10 year linear trend is already assessed in the River stock status

classification test a). Likewise for c) in b) & a) Using a single metric individual river value (annual egg depositions) and presenting this as three separate ranking tests is unorthodox and is questioned by CPWF. Has this been presented in this way to confer added emphasis that all rivers stocks are vulnerable and require additional regulatory protection ? Why was a the more usual performance test omitted measuring a Rivers Management Objective achievement ? i.e. number of years exceeding CL or an individual years actual 5 or 10 year MAT attainment to CL . Is it that a very different picture would have emerged i.e. many rivers would clearly be meeting their MO of exceeding CL in 4 out of 5 years ?

CPWF notes - the NASCO guidance that English & Welsh fisheries adopts is that CNL(18)50 NASCO Implementation Plan for the period 2019 – 2024 2.1 What are the objectives for the management of the fisheries for wild salmon? The current ‘management objective’ (MO) for each salmon river stock when reviewing management actions and regulations is that the stock should be meeting

• r exceeding its CL in at least four years out of five (i.e. >80% of the time)

Further - NRW Annexe 4 - Salmon Stock Management system Explicitly states in its Decision Structure Process for PAR Rivers (12 in Wales) that

• 2. Second stage – initial screening for potential options (blue boxes)

This stage screens options appropriate to those rivers that have a <50% probability

• f failing the management objective taking into consideration socio-economic

concerns and stakeholder support. Management options that would not be supported by stakeholders can be ruled out. One of the possible options is to ‘do nothing’. For rivers where there is >50% probability of failing the management objective, all

• ptions must be carried through to the next (evaluation) stage.

• 3. Third stage – option evaluation (purple boxes)

The purpose of this stage is to set out and evaluate options to realise the required changes in exploitation. For PAR rivers where 50% ≤ p < 95% (where p= probability of failing the management objective) and the trend is down and with an annual catch of >20 salmon and C&R rate < 90%, then voluntary catch and release (C&R) will be promoted for 1 year. If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered. Protected rivers such as SACs (Special Areas of Conservation) are given particular emphasis. For rivers where the above criteria apply, except that the annual mean salmon catch is <20 salmon, voluntary measures will be promoted.

Clearly NRW are not following the Decision Structure Process for the twelve PAR Rivers or those Rivers with an annual salmon catch below 20 fish

Why are NRW proposing Option 2 mandatory measures and method restrictions and rejecting Voluntary Options and engagement with stakeholders & Anglers ? NRW Technical Case - Page 13 - Executive summary Option 2 states:- Reduce exploitation by nets and rods through a combination of byelaw controls on rods and nets and / or fishing method control by voluntary catch-and-release fishing

NRW dismiss the voluntary C & R option with the statement Despite good uptake of this by most anglers in many rivers, it is clear that the urgently required reduction in exploitation is not evident. CPWF refute NRW`s statement. There has been good voluntary C & R observance, (possibly not all rivers) but reaching 86% in 2017 and this can be improved. 90% is a recognised target and is very close and achievable. At 90% C & R and 10% exploitation the impact on spawning stocks is 1%. The contribution of 1-2% is minimal compared to the consequential losses from introducing these measures Stating further page 96 - in their Salmon preferred option The preferred option for salmon at present is Option 2 to reduce exploitation of fish in both the net and rod fisheries, through a considered package of measures so that all salmon are released, and have a good chance of survival. These measures will allow many of the social and economic benefits of the two fisheries to be maintained.

Socioeconomic and social benefits - Page 119 NRW Technical Case NRW study and analyse of the socio-economic assessment refers to 2007 & 2009 EA reports and more recent Celtic Sea Trout (2016) and Substance 2012 “Fishing for Answers” The later providing a comprehensive review of the social and community benefits for angling in the UK. They listed six complex and interrelated benefits: 1) Sports participation, 2) Health and Wellbeing, 3) The Natural Environment 4) Community Development, 5) Rural Communities and Angling Tourism 6) Young People. The contribution salmon and sea trout angling fisheries makes to each of these is unknown, but will depend on a wide range of variables largely on the nature and extent of angling activity and opportunities within catchment areas. The report noted however, in areas where sea trout are more common and abundant than

• ther freshwater fish species, their contribution may be of significant importance

and value.

Further - whilst Wales and England both use identical River classifications models, NRW are proposing more stringent measures with all 20 Rivers (Wye & Usk excluded) being subjected to mandatory C & R measures for salmon and further method restrictions In Wales that is 8 At Risk and 12 Probably at Risk classified Rivers. In England the EA reconsidered their proposals for their 40 monitored Rivers with

• nly four At Risk Rivers have mandatory measures applied with 36 (including PAR

Rivers) under Voluntary measures Page 138 of the Technical Case , NRW makes a commitment Discussions with the EA have resulted in agreement that NRW and EA will seek to agree a single technical case and set of byelaws in the autumn for a further statutory consultation with the intent to introduce new measures prior to the 2018 fishing season. These proposals also seek to ensure an integrated approach to fishery regulation in these catchments.

CPWF would respectively suggest, this has not happened and that the harmonization of E & W Byelaws as recommended is a necessary and desirable objective

Other jurisdictions

Although listing English, Scottish & Irish conservation strategy alternatives, NRW appear not to have considered these CPWF has analysed and considered alternative modelling scenarios and presented three alternate River Classification options in comparison to current River status Classification using historic CL datasets. CPWF Table 8. One being the Scottish style model recently introduced after public based on 5 year historic MAT (using current CL attainment) as one recommendation by the Statisticians. The Scottish style model using the same historic Welsh CL datasets would reclassify eight Welsh rivers into different and less stringent Voluntary measures approach. This system would allow an annual review mechanism We believe that a wider stocks reporting review is now being timetabled and we welcome this development

There are clear operational and communicational benefits from E & W adopting a common Conservation strategy, with cross border rivers part of this single Byelaw approach

Conclusion

An opportunity for anglers to be involved and engaged in a consultation process “with Options” has been missed The real value that rod fisheries bring to managing and improving our fisheries has been overlooked and NRW have lost the support of anglers Voluntary C & R measures, where good gains have been made in recent years have been dismissed . They present the obvious and most viable Option The byelaws lean heavily on stock performance assessments for Rivers that are shaky and need reviewing and improving The mandatory C & R button has been pressed for salmon, reinforced with a range of method restrictions that will impact heavily on angler participation, enjoyment and engagement NRW may see this as a preferred option to “manage the fishery” at minimal cost but it is not the Best Option and crosses clear national and NASCO decision criteria and pathways This Inquiry process can provide a much needed kick start to set parties in a new direction