Following the Environment Agencies release of further controls on the exploitation of migratory fish, particularly salmon. The Angling Trust have published a set of guidelines for those anglers who wish to respond to the proposals.
The following are the views of the Angling Trust and not necessarily the views of anglers in general who as individuals will have their own particular opinions.
The notes however are a useful tool in helping anyone intent on completing the response.
Please note that the closing date for all returns is 12th April 2017.
- We support the proposed moratorium on mixed-stock netting which was a key part of the Angling Trust’s Save Our Salmon campaign and has been an international embarrassment for decades.
- We also support reductions in estuary netting on At Risk and Probably At Risk rivers.
- We have concerns about commercial netting for sea trout continuing in places where there will be a significant catch of salmon to be released, especially from nets with knotted mesh because these cause significant damage to scales and fins. To allow the continued use of knotted nets when regulations are being proposed regarding the size of anglers hooks appears asymmetric and perverse.
- We recognise that salmon anglers have a continuing role to play in reducing mortality to salmon by releasing more fish and reducing the damage that is done to fish which are released. Anglers have made enormous progress over the past 20 years with catch and release of salmon on a voluntary basis, rising from single figures in the 1990s to an average of 80% nationally in recent years. On many rivers the release rate is well over 90%.
- However, we are very disappointed that the Environment Agency Board departed from the voluntary approach which had been developed at great length by the Angling Trust in discussion with the Agency’s fisheries team and agreed with representatives from river associations throughout the country as an acceptable way forward. We therefore object to the mandatory imposition of 100% catch and release on AT Risk rivers.
- We do not believe that the mandatory measures will be enforceable by the under-staffed and under-resourced Environment Agency who will rely on anglers, fishery owners and clubs to impose the new rules, the majority of whom do not support the new measures, which places them in a very difficult position. There will also be fewer anglers on the riverbank to report poaching and pollution and to scare away predatory birds. Fisheries and clubs have worked very hard to increase voluntary catch and release to very high levels on rivers where stocks have declined steeply to avoid such mandatory measures being imposed. The loss of goodwill resulting from mandatory measures will have an impact on willingness to undertake voluntary work and to invest time and money in the restoration of the water environment.
- We call on the Minister to revert to the voluntary approach proposed by the Angling Trust and its member associations, which would set an aspirational target of 100% voluntary catch and release for At Risk rivers, rather than criminalising anglers for taking a very occasional fish. The imposition of mandatory measures may lead to some clubs and fishery owners losing significant revenue and damage to the local economy.
- A number of regional fisheries are questioning the stock assessment methodology and modelling used to classify the current year and predicted five year forward stock status in rivers. Particular concerns are raised with the numerous estimated values and assumptions in determining spawning stock egg depositions, but also importantly the use of trending and extrapolated five year forward data in relation to conservation targets.
- We believe there is a need for a review of river classification modelling and greater harmonisation of English and adjoining country methodologies for setting of conservation targets and measures.
- Many anglers may have already renewed their annual rod licences for £80 this year without being aware of the new proposed measures, which are intended to be introduced by June 2018. Many clubs will have sold subscriptions and fishery owners sold season rods and day tickets without being aware that these measures are to be imposed. We believe it would be unreasonable to introduce any new regulations in the 2018 calendar year and note that some netting regulations are being delayed until 2019. Ministers and officials need to recognise that there are numerous businesses and jobs that rely directly and indirectly on salmon angling. Changes to regulations have significant impacts on these businesses and jobs and should not be introduced without due notice being given.
- We also object to the detailed regulatory measures involving hook sizes and methods which we believe will be very difficult to enforce and will place an unreasonable burden on anglers, angling clubs and fishery owners compared to the number of fish that will be saved by these rules. Many anglers will have purchased tackle and shops will have bought stock (and published catalogues) containing equipment which the government is now proposing should be illegal.
- We recommend that instead of imposing unenforceable regulations, best practice should be promoted by communication through the Angling Trust and its member river associations, clubs, fishery owners and individual anglers. The only exception is that we support the mandatory requirement of single hooks on Flying ‘C’ spinners because there is good evidence to suggest significant damage to fish from the use of trebles on these lures.
- The imposition of a zero-tolerance approach to catch and release and the regulation of the size of anglers’ hooks is completely at odds with the light touch regulation of pollution, hydropower and river habitat damage that is leading to the death of far more salmon than anglers could ever catch.
- The imposition of mandatory 100% catch and release on rivers where anglers are already releasing more than 90% of the fish they catch is hard to reconcile with the refusal of the government to allow fishery owners more freedom to control cormorant and goosander predation at sustainable levels. There is evidence to suggest that these birds eat as many as 40% – 50% of salmon smolts on their migration out to sea.
- Similarly, the government’s continued failure to introduce regulations drafted more than a decade ago to require owners of barriers to migration to make them passable to fish does not match the draconian nature of the proposed new regulations for the angling community and the many businesses and jobs it supports.
Every angler should be aware that some of these measures will come into force by mid June 2018 and once introduced are likely to be operative for the next 10 years.
If you are unhappy with any particular proposal then the time to make your voice heard is now!!!!!!