Response 1036094895

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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.
Refer to response from Southwest Rivers Association with which the DFA fully agrees.

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
Partially
Ticked 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.
(a) The Dart has no netsmen operating on its estuary having bought out all its netsmen (b) Anglers have supported voluntarily the EA's recommendation that 90% of all salmon caught after 15/16 be released and have achieved this objective in the majority of the last 10 years. It is likely in 2017 that 100% of salmon caught will have been released. (c) Attached is our code of conduct agreed by our committee

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
Ticked Wholly
Partially
Not at all

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

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.
Refer SWRA response with which the DFA agrees insofar as it applies to the socio. economic value of rod fisheries as compared to netting operations.

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
Permanently
Please provide details of why you have given this answer.
- the relative socio. economic value of a rod fishery far exceeds that of netting operations - Netsmen kill the fish they catch reducing significantly the stocks of salmon and sea trout returning to the rivers whereas in the majority of cases anglers return the salmon they catch

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.
Refer SWRA response

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.
Significant benefit to the rivers, (to which net caught fish would otherwise have returned to) and their rural economies benefiting from increases in stocks of salmon and sea trout.

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.
Voluntary measures to increase catch and release of both salmon and sea trout have been supported by our anglers and have therefore worked - although our code of conduct recommends 90% C&R in recent years nearer 100% has been achieved.

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.
Refer SWRA response with which the DFA agree

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.
90% for the River Dart

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.
Increased involvement of the angling community in the management of their fisheries in view of the decline of the EA's ability to manage and carry out their statutory requirements (respect fisheries).

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
At Risk
At Risk and Probably at Risk
At Risk, Probably at Risk and Probably Not at Risk
Ticked 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.
We do support our current code of conduct which aims at achieving 90% catch & release - an aim achieved in recent years.

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
Ticked No (I wouldn’t stop fishing whichever option was implemented)
Yes, if Option 1 was implemented
Yes, if Option 2 was implemented
Yes, if Option 3 was implemented
Yes, if Option 4 was implemented
Please tell us which river(s) you fish for salmon on.
River Dart & Tyne

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
If you wish, please provide us with your reasons for your answer.
It is likely that some of our members would consider moving

Q6.2i (This question is for owners/lessees of salmon rod fisheries). What would the impact of these catch and release proposals be on your fishery (see Section 6.2: Table 6)?

Please select one item
No impact as a result of any of the options
Ticked A significant impact as a result of one or more of the options
I don’t know
Please provide us with details of which of the possible option(s) would result in a significant difference to your fishery. Please provide us with details of financial and social impacts.
Any increase in recommended catch and release % would reduce angling effort, increase illegal fishing activity, reduce interest in the management of the fisheries by anglers and reduced income to the EA from the value of licences.

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.
It is preferable, if possible, to take the hook out of a fish's mouth without touching it or getting it into a net. it is difficult in a small spate river with hourly differences in water temp. in different parts of the river to recommend stopping fishing when water reaches 18C. Anglers do not normally fish in 'hot conditions'

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.
Stopping the use of large treble hooks, particularly on Flying ‘C’ spinners,.
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.
temperature of river rarely exceeds 18C

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
Ticked Yes
No
I don't know
If yes, please provide us with the details of these and your reasons why.
Avoid beaching of fish. Dragging fish onto land which will result in damage to fishes' scales. Remove hook from fish's mouths without removing fish from water or netting them.

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?
Our code of conduct does recommend use of barbless hooks on voluntary basis. E.g. if fishing for sea trout at night which intend to keep for the pot barbed hooks acceptable.

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
Ticked Yes, but only large treble hooks greater than size 8 should be banned
No, these should not be banned
I don't know

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
Ticked Yes
No
I don't know

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
Ticked Yes, Flying ‘Cs’ should only be allowed with single hooks
No, restrictions should not apply to the use of Flying ‘Cs’
I don't know

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.
Not clear which equipment would apply

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.
The consultation should not have combined references to the (north) east nets with angling for salmon and sea trout. N.E. nets are a commercial mixed stock fishery clearly damaging returning stocks of salmon and sea trout to northern rivers. Whereas angling is generally specific to individual rivers and is not commercial insofar as fish cannot be sold. The Agency's stock assessment of individual rivers which is likely to determine restrictions on angling going forward is flawed as has been pointed out by AST STC(uk) and WTT in a recent submission to the Agency (to heidi).