Many thanks for comments thus far – Chris, Guy & John. Can I quickly re-emphasis why I will be writing to Peter Gough later today and asking that this letter and information request is tagged to the earlier communication asking for the stock reporting/assessment answers to be responded to.
It is apparent the June – NRW – Salmon Stock Performance in Wales 2019 Report has not been distributed widely and appears to have not been included in the last WFF Agenda, which I find quite amazing.
There are incorrect statements that require explanation and correction and we do need to know who is the author of this report.
The central thrust of the Report is to reflect Welsh River performance against the higher egg deposition “Management Target” and not the Formal Compliance – “Conservation Limit”. As a rule the MT is 30 – 40% higher than the CL. In our view this is contentious and presents an incorrect assessment of Welsh River health.
But also fundamental elements of Stock Assessment procedures and methodology are subject to two national review processes to which we have submitted detailed proposals and have been excluded from representation.
Can or should they do this ? – they used the MT performance trend framework in the Byelaw Consultation and at the Welsh Inquiry and produced and enforced mandatory C & R and method restrictions outwith the Decision Structure process.
It may be helpful to grasp some of the key proposals NWATFCC, PAAS & CPWF presented to NASCO as part of drafting the NASCO 2019 -2024 Implementation Plan, which led into formation of the 3 year stock Assessment review ;
- Revision of CL & MT to a single CL for Rivers
- Removal of the use of 10 year historic and 5 year forward – Linear Regression trend and Bayesian Analysis to project 5 year forward stock status – the probability of meeting Management Objective (exceeding CL in 4 out 5 years on average in the long term). Replacing this with a simple 5 year rolling average River attainment to CL – the Scottish model.
- replacing the current Decision Structure Process with a much simpler C & R measures set in 3 or 4 banded categories with each River reporting its actual 5 year % attainment to CL.
- A new and fuller national fisheries reporting document that shows all the 6-7 variables applied by the EA & NRW to each River to produce the final annual stock estimate a draft of this has been developed and submitted)
Hope that helps in understanding the background to this process and how rod fisheries as principal stakeholders should be consulted and engaged in these decisions.
Mike AshwinNWATFCC North West Angling Trust Fisheries Consultative Council
Leave a Reply