Response 1003046836

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2. The Salmon Five Point Approach

Q2.2a. To what extent do you agree with the summary of the current state of salmon stocks and the supporting information provided in Appendix 2?

Please select one item
Wholly
Ticked Partially
Not at all
Please give your reasons and any evidence you have to support your answer.
Under Para 2.5.3 it says that sea trout stocks are not a cause for concern. I beg to differ, catches of sea trout in the last 5 years have declined by at least 80 % in my area to the point where a lot o visitors to the area who became members of local clubs to enable them to fish the River Wear have dropped out of the clubs because of declining catches. Nets do not differentiate between sea trout and salmon so it it is not logical to say that the net fishery can differentiate between salmon and sea trout when netting .Fish left in T or J nets will be so stressed as to be dead or badly damaged before they can be released so if netting for sea trout is allowed they are bound to catch salmon. Table 2 gives 4 alternatives but only number one is practical and that is a total ban on the North east Coast fishery. The Environment agency have not the resources to police the alternatives where multiple choices for individual rivers which are AR or PAR. Your document "The Current State of Salmon Stocks " on Page 31 Table 4 shows the Coastal Net fishery killed 93% of the total catch of salmon in England and Wales in 2016 . Logic dictates its closure is the only way forward and this must be in 2018 not 2022 because by then it will be too late .

3. Deciding which salmon stocks need further protection

Q3.2a. 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?

Please select one item
Wholly
Ticked 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.
Although I agree that there should be a policy of catch and release for rods morally that cannot be applied when the net fishery kills salmon a sea trout without control other than a limitation of length of season. Most anglers I know practice catch and release but find it difficult to justify when the nets kill everything. If netting was stopped anglers would accept limitations such as a percentage of catch and release, barbless hooks, etc.

4. Review of existing National Salmon Byelaws

Q4.2a. Do you agree with the proposal to renew without amendments the existing National Salmon Byelaws to protect spring salmon stocks?

Please select one item
Wholly
Partially
Ticked Not at all
Please give your reasons and any evidence you have to support your answer.
All netting should be banned full stop. and anglers should adhere to existing rules prior to 16th June.

5.4. All consultees' views sought on the options for net and fixed engine fisheries

Q5.4a (Seeking all consultees' views on the options for net and fixed fisheries in England and on the Border Esk (except North East Coast Net Fishery Options)). Which is your preferred option for net and fixed engine fisheries as set out in Section 5.2: Table 2?

Please select one item
Ticked Option 1
Option 2
Option 3
Option 4
I don't have a preferred option
Please provide details of why you have given this answer.
It is the only logical answer. Salmon stocks are in great decline so alternatives such as 2, 3 and 4 are fudging the issue. In any case the nets men cannot be relied upon to be self policing and the Environment agency have insufficient staff to police the alternatives. A total ban by 2018 would solve all the problems in one go. The North East Coast fishery affects all the rivers from the North east to Scotland so a total ban would be the simplest solution however politically difficult it may prove to be . Thew fishery was to close in 2022 but the decline is too rapid and therefore it should be shut in 2018. Other industries close and the workforce have to seek alternative employment so why should this be an exception.

Q5.4b (This question is for all consultees to answer and is in reference to the answer that you have given to Q5.4a). What are the benefits, if there are any, which you would see from your preferred option for net and fixed engine fisheries?

These could be economic as well as social/cultural, please provide details if you are able.
A great deal of revenue is generated by sport fishing. If the netting was stopped and stocks increase a lot of tourism would be increased in the North East with revenue generated by hotels, guest houses and fishing tackle trade during the season .

Q5.4c (Seeking all consultees' views on the options for net and fixed engine fisheries in England and on the Border Esk (except North East Coast Net Fishery)). How long do you consider the measures covering a net and / or fixed engine fishery should be in place for?

Please select all that apply
5 Years
10 Years
Ticked Other
If other, please specify
A complete ban forever.
Please provide details of why you have given this answer.
Sufficient salmon is supplied to the UK market and is now exported from salmon farming within the UK. There is no justification for exploiting dwindling wild salmon stocks.

Q5.4d (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?

Please select one item
Ticked Option NE1
Option NE2
Option NE3
I don't have a preferred option
Please provide details of why you have given this answer.
It is the only logical solution.

Q5.4e (This question is for all consultees to answer and is in reference to the answer you have given to Q5.4d). 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.
As I have stated previously angling tourism would increase benefiting the whole of the North east region.

6.2. Possible options for rod fisheries - catch and release of salmon

Q6.2a (This question is for all consultees to answer and we are seeking your views on the possible options that have been developed). Which is your preferred option for the catch and release of salmon by rod fisheries from those that are set out in Section 6.2: Table 6?

Please select one item
Option 1
Option 2
Option 3
Ticked Option 4
I don't have a preferred option
Please provide details of why you have given this answer.
Clubs, organisations could establish individual quotas for catch and release for each river and be self policing . If this does not work then by statutory means.

Q6.2b (This questions is for all consultees to answer and is in reference to the answer that you have given to Q6.2a). What are the benefits, if there are any, which you would see from your preferred option for the catch and release of salmon by rod fisheries?

These could be economic as well as social/cultural, please provide details if you are able.
As an organisation we already allow members to keep 2 salmon and 4 sea trout a year for home consumption. Many anglers don't keep any but those that enjoy fish get a reward for their effort and expense.

Q6.2c (We would like to seek all consultees' views on the use of a voluntary (as opposed to mandatory) approach to deliver increased levels of catch and release). Do you agree with using a voluntary approach to deliver improved catch and release of salmon by rod fisheries?

Please select one item
Ticked Yes
No
I don't know

Q6.2d (If you answered yes to Q6.2c please answer these questions). Do you support the proposed levels of voluntary catch and release for rivers whose salmon populations are either At Risk, Probably at Risk or Probably Not at Risk (see Section 6.2: Table 6: Option 4)?

Please select one item
Ticked Yes
No
I don't know
If you wish, please provide us with what you think the levels of voluntary catch and release should be and the reasons for your answers.
Many anglers fish only a few days of the year for a variety of reasons. If catch and return was 90% does that mean he can keep the first one and must release the next 9 or vice versa. It can only be done on a voluntary basis.

Q6.2e (If you answered yes to Q6.2c please also answer this question). What are the benefits that you would see in voluntary catch and release?

These could be economic as well as social/cultural, please provide details if you are able.
Obviously catch and release would increase the spawning potential of our rivers.

Q6.2f (This question is for all consultees). Would you support the voluntary catch and release of all salmon caught (100%) on rivers whose salmon populations are either?

Please select one item
Ticked At Risk
At Risk and Probably at Risk
At Risk, Probably at Risk and Probably Not at Risk
I would not support the voluntary catch and release of all salmon caught
If you wish, please provide us with the reason for your answer.
Fish should not be taken from fisheries where stocks are depleted.

Q6.2g (This question is for salmon anglers). Would you stop fishing for salmon if the proposed levels of catch and release were implemented (see Section 6.2: Table 6)?

Please select all that apply
No (I wouldn’t stop fishing whichever option was implemented)
Ticked Yes, if Option 1 was implemented
Ticked Yes, if Option 2 was implemented
Ticked Yes, if Option 3 was implemented
Yes, if Option 4 was implemented
Please tell us which river(s) you fish for salmon on.
Wear

Q6.2h (This question is for salmon anglers). Would you consider moving to a river where lower levels of catch and release were required?

Please select one item
Yes
Ticked No
I don't know

6.3. Possible options for rod fisheries - improving survival of released salmon (voluntary measures)

Q6.3a (This question is for all consultees to answer and is about the best practice recommendations for catch and release). Do you agree with the catch and release best practice recommendations?

Please select one item
Yes, all of them
Ticked Some of them
None of them
I don't know
If you wish, please tell us which of them you agree/disagree with and provide us with further information to support your answer.
Rather than trying to discriminate against particular spinners like Flying C or Rapala it would be sufficient to say all hooks shall be rendered barbless whether single, double or treble.

Q6.3b (This question is for angling club and fishery owners). With reference to the catch and release best practice recommendations in Section 6.3.3, which, if any, of these would you have difficulty applying to the waters under your control?

Please select all that apply
Ticked Stopping angling at high water temperatures (where they exceed 18 °C in the mid-morning).
Only allowing the use of single or double barbless hooks to minimise risk of injury.
Ticked Stopping the use of large treble hooks, particularly on Flying ‘C’ spinners,.
Ticked Only allowing the use of the least harmful bait/lure type (e.g. artificial flies with minimal, appropriately sized, barbless hooks fished actively),
Identifying safe landing areas and promoting their use to anglers before commencing fishing.
Minimising air exposure, by promoting that fish are not removed from the water during landing, unhooking and photographing.
Stopping fish being taken out of the river and onto the bank prior to release.
Only allowing the use of fish-friendly landing nets.
Stopping the practice of holding the fish up clear of the water by the tail only.
Please provides us with the details of your reasons why.
Impossible to police because on many occasions anglers are alone. For instance in relation to treble hooks what size is "large".

Q6.3c (This question is for all consultees to answer and is about other ways that you might improve salmon surviving capture). Are there any other catch and release best practice recommendations that you feel should be included?

Please select one item
Yes
Ticked No
I don't know

6.4. Possible options for rod fisheries - improving survival of released salmon (mandatory measures)

Q6.4a (This question is for all consultees). Do you consider that having a landing net available to use should be required by byelaw whilst fishing for salmon or sea trout in England and Border Esk?

Please select one item
Ticked Yes
No
I don't know

Q6.4b (This question is for all consultees). Do you consider that a landing net used when fishing for salmon and sea trout should be required by byelaw to have a maximum mesh size of 20mm (as measured across the widest point of the stretched mesh)?

Please select one item
Ticked Yes
No
I don't know

Q6.4c (This question is for all consultees). Do you consider that the use of barbed hooks should be prohibited by byelaw when fishing for salmon or sea trout with flies, lures or bait?

Please select one item
Yes
Ticked No
I don't know
What would the impact, if any, be for you or your business of prohibiting the use of barbed hooks when fishing for salmon or sea trout with flies, lures or bait?
Almost impossible to police especially at night. Sea trout especially early in the season are notoriously soft mouthed and few would be successfully caught. Barbed hooks can be debarbed while many thousands of artificial flies and lures exist that are not barbless so a complete prohibition would be a costly affair . Anglers should be allowed to debarb their lures.

Q6.4d (This question is for all consultees). Do you consider that the use of treble hooks should be prohibited by byelaw when fishing for salmon or sea trout with flies, lures or bait?

Please select one item
Yes, all should be banned
Yes, but only large treble hooks greater than size 8 should be banned
Ticked No, these should not be banned
I don't know
If you wish, please provide us with your reasons for this view and if you think that large treble hooks of a different size than greater than size 8 should be banned.
If fish are handled correctly and netted and hooks are barbless or debarbed then release should be easy with minimal damage.
What would the impact be, if any, for you or your business of prohibiting the use of treble hooks (either completely or only large treble hooks) when fishing for salmon or sea trout with flies, lures or bait?
The catching of salmon and sea trout by rod and line is difficult enough and should be governed by simple rules. Too many nit picking rules will deter anglers from fishing for salmon and sea trout altogether.

Q6.4e (This question is for all consultees). Do you consider that the use of circle hooks should be mandatory by byelaw when using worm as bait when fishing for salmon or sea trout?

Please select one item
Yes
Ticked No
I don't know
If you wish, please provide us with your reasons for this answer.
A barbless or debarbed hook should be sufficient.

Q6.4f (This question is for all consultees). Should there be restriction on the use of Flying ‘Cs’ when fishing for salmon or sea trout?

Please select one item
Yes, Flying ‘Cs’ should be banned
Yes, Flying ‘Cs’ should only be allowed with single hooks
Ticked No, restrictions should not apply to the use of Flying ‘Cs’
I don't know
If you wish, please provide us with your reasons for this answer.
Flying C's are no better or worse than any other lure in the right hands so it would be folly to discriminate against them. If you ban one spinner then you would have to ban them all. If a man is good with a method of fishing does that mean we should discriminate against whatever method he chooses. Many anglers spin and never fly fish so if you ban spinning a lot of anglers would not fish for salmon.
What would the impact be, if any, for you or your business of prohibiting the use of Flying 'Cs' or only allowing their use with single hooks when fishing for salmon or sea trout?
A lot of anglers would stop fishing. It should be sufficient to debarb the hooks on existing spinners.

Q6.4g (This question is for all consultees). In your opinion, are there other types of equipment that should be prohibited by byelaw when fishing for salmon and sea trout?

Please select one item
Yes
No
Ticked I don't know
Please provide details of what these could be and why you think they should be prohibited or altered.
What a ridiculous question. You are almost saying that any popular method should be banned.

7. Further comments

Q7 (This is for all consultees). Please tell us if you have any further comments that you would like to provide on this consultation.

Please provide your further comments here.
Some of the questions obviously relay a lack of practical knowledge of angling such as banning Flying C's. If you think they are being used in an illegal way you should be reminded that the vast majority of fish stroke hauled in rivers are taken with fly rods and lead core lines and yet people assume fly fisherman cant be poachers.