Peter Gough, NRW Principal Fisheries Advisor David Mee, NRW Snr Fisheries Advisor,

Ian Davidson, NRW Snr Environmental Assessment Officer, Dr Alan Walker, Cefas Snr Scientific Officer,

Grant Horsburgh, Defra Freshwater & Migratory Fisheries Team, Mark Owen, AT Freshwater Campaigns

Cc NWATFCC, CPWF & PAAS representatives Dear Peter,

Corrections, explanations and recommendations to the NRW published Salmon stock performance in Wales 2019 Report

May I thank you for your recent confirmation that the NWATFCC, CPWF & PAAS request to NRW & WFF concerning impact of All Wales Byelaws on river catch will be responded to on 4^th December.

In other correspondence received last week the attached NRW – Version 09/06/20 Report on Salmon stock performance in Wales 2019 was included in distributions following a recent LFG. Having asked four WFF – LFG colleagues and other PAAS & CPWF representatives whether they had received this I received a mixed response. Importantly the Report does not appear to have been part of the WFF November Agenda nor does it appear to have been commented on?

My colleagues and I have read the document fully and wish to express our concerns with key elements of its content and presentation. May I ask that these points are responded to and where necessary corrections made and communicated to persons that have received earlier copies and to all WFF representatives. You may wish to add these to the earlier request dated 03.11.20. We appreciate this may require a later response. Would you would please advise on this.

Points are as follows and include coloured text where they appear in the original 2019 stock Report;

1. Use and reference to Management Target in achieving Management Objective Throughout the Report reference is made to achievement and attainment to Management Target MT (approx 30 – 40% higher than CL egg deposition target) when MT has no specific function in setting Management Objective MO and a River`s Formal Compliance.

The England & Wales Annexe 4 – Salmon Stock Management System clearly states;

The Management Target (MT) for each river is a spawning stock level for managers to aim at, to ensure that the objective of exceeding the CL is met four years out of five in the long run (i.e. 80%  of the time).

It is by definition a goal but emphatically not a requirement for managers.

The NRW 2019 Report Page 2 states;

Natural fluctuations in spawner and egg numbers means that on average, stocks must be some way above the CL in order to meet Management Objective. The average stock level equated to an additional layer of protection and is indicated by the Management Target (MT)

The NRW 2019 Report Page 2 states:

It may be desirable for average stock levels to reach or exceed MT but it is NOT a requirement and factually incorrect to state that average stocks must be above MT to achieve MO (Formal Compliance in 5 years time). There are many historic examples of rivers meeting MO – “Probably Not at Risk” or “Not at Risk” status where very few of their historic 10 years estimates actually met CL and certainly did not achieve an average stock level above MT. The Wye being an example.

2.      Management Responses

The 2019 Report page 4 states;

assessment). Where possible (principally on rod fisheries), voluntary measures to control exploitation should be promoted in the first instance before considering mandatory action.                                                                                                        

In view of the fact that in England the EA & Defra did and does observe the stated E & W guidance and NASCO approved Decision Structure Process, NRW`s promotion of Voluntary    C & R measures for “Probably at Risk” and some “At Risk” is at odds with its actual delivery of national Byelaw Policy. Please explain why NRW continues to promote this voluntary option in the 2019 Report when the All Wales Byelaw Consultation and Inquiry provided no such option?

We would recommend and welcome a statement from NRW that clarifies how mandatory C & R and method restriction measures, including those applied all Welsh “At Risk” and Probably at Risk” rivers in 2019 and 2024 (five years time) will be reviewed and communicated to WFF, LFG`s, rod fisheries and anglers during the period of the 10 year Byelaws. Might we suggest that this makes reference to the decision points and notes contained in Pages 6 & 7 of the Annexe 4 – Salmon Stock Management Plan? These are missing in the 2019 Report. We request that these are circulated with the page 5 Decision tree table so that we have a complete set of Decision papers. Additionally, we ask information is provided that informs fisheries and anglers when and in what circumstances changing river assessments will cause Byelaw Measures to be reviewed on an individual river basis.

3.      Vulnerability of Stock ranking

We welcome NRW`s policy to measure river stock performance on multiple criteria through a ranking system. However we are particularly concerned that the later two of three ranking tests do not provide an accurate measure or indicator of adult spawning performance. We would expect and recommend the performance tests to include;

• Individual rivers actual annual Formal Compliance to CL (5 or 10 year % values)
• A rivers actual average 5 year attainment to CL target (its MAT % ).

Looking at the 2019 Reports second ranking performance test;

It is clear that over the last 10 years most rivers will and are exhibiting a negative trend as a result of the significant change in 1SW/MSW run components. It is also not unusual for Rivers to meet CL and MT consistently yet still exhibit a negative trend. In these scenarios trend performance can present a misleading measure of stock health.

Our own analysis of the last 10 year time series egg deposition trend estimates for the 23 individual Welsh rivers does not agree with your own tables which appear to show all Welsh rivers have a negative trend.

The Wye & Severn would appear to display a positive 10 year trend, whilst the Usk, Mawddach, Conwy and Dee negative trend estimates do not appear to fit with the published Table 1 & 2 trend categories. Please would NRW provide confirmation of how the 10 year time series trend graph was calculated with examples in graph form for the 6 rivers mentioned?

Concerning the third ranking test:

We refer to the points raised in Item 1 and above and request that the % egg shortfall/surplus is measured to Conservation Limit target.

• Page 8, 9 &10 – 23 principal River graphs

We very much welcome NRW`s initiative to present individual river graphs and illustrating these over the long time series history back to 1994.

However the graph illustrations of the 23 Welsh Rivers present a number of interpretation issues for readers that you will be familiar with.

• The charts are in logarithmic form and do not illustrate actual y axis scale egg deposition values in millions.For the unaccustomed reader they are difficult or nigh impossible to interpret, a point made as far back as the 2017 Telford Stock Assessment Workshop and referred to in the Workshop summary report as a matter for future improvement. Talking with colleagues we feel that for most Rivers the scale of annual variability would allow graphs to be presented to actual scale and this would provide a different and much improved assessment of actual egg deposition performance.

• Management Target is illustrated with a much bolder and over emphasised line relative to the formal CL line target. Many readers will assume incorrectly, that the MT target line must be the required formal compliance target. This is not the case and we recommend that in future the CL & MT lines are of equal weight.

Finally, the 2019 Report does not refer to the significance of the two national E & W Reviews that are underway which present an opportunity for NRW & rod fisheries to engage in what is a critically important milestone for salmon fisheries. Those reviews being ;

The Rod exploitation rate review for revising estimates used of whole River run stocks for Rivers without validated counter data.

A three year Stock Assessment Review to improve procedures and methodology for setting targets, assessing and reporting annual stocks, and Decision Structure Process conservation measures.

The 2019 Report does not record that NRW, EA & Cefas arbitrarily reverted to using the historic

1.1 Angler under reporting factor in 2019 River estimates and did so without informing Rod fisheries. Disregarding reliable River fisheries catch estimates which showed that in the NW a factor in excess of the previous 2018 estimate of 1.51 needed to be applied to 2019 estimates.

Additionally NRW, EA & Cefas have published and released the outcome of the national Rod exploitation Rate review which was expected to cause revision to recent year assessments. NWATFCC, PAAS & CPWF are still seeking confirmation of the RER review through earlier correspondence with NRW and EA.

We appreciate this is an unwelcome request at a time of additional workload for many organisations, but believe the matters raised are of importance to improvements we are seeking whilst the national reviews are under consideration.

It is hoped those reviews will engage with and include representation of rod fisheries and angler stakeholder interests.

Best regards Mike Ashwin,

Chair  NWATFCC  North West Angling Trust Fisheries Consultative Council & on behalf of

CPWF Campaign for Protection of Welsh Fisheries & PAAS Prince Albert Angling Society.