Response 1037398938

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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.
I agree that stocks are not as good as they could be however I profoundly disagree with the methods used to come to the view. Rod returns are NOT to be taken as read as they can be seriously affected by weather conditions and levels of angling activity. It may well be that the 2014 assessment is flawed if using this method. Rod returns will only include fish 'banked'. If anglers hook and lose fish they will not be recorded yet it is a fact that that fish is in the river. No account will be taken of that and the numbers will be inaccurate.

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.
I am astounded that no mention is made about the the more serious pressure on stocks posed by predators. My local rivers have seen a dramatic increase in goosander activity. this suggests that there is a lot of available food, ie parr and smolts. The increasing numbers of these birds as well as cormorants needs to be tackled. they will pose a FAR GREATER threat to salmon stocks that the relatively paltry rod take.

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
Ticked Partially
Not at all
Please give your reasons and any evidence you have to support your answer.
Once again my main issue is the accuracy of rod returns and the assumptions made from the figures provided. My experience on local rivers to me is that fishing effort is low prior to June 16th and you could wrongly assume that stocks are down as a result.

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.
I do not believe that 100% catch and release will make any difference. The Leven had a 10 year catch and release in operation and as can be seen is still not performing. Many rod fishermen catch one fish per season and they should have the right to 'one for the pot'. This of course would seriously affect percentages but at the end of the day it is one fish. Those anglers who take into double figures of fish need to be educated. They are few mercifully. Why on earth is there no consideration here to tags being issued to control fish take?
If you don't have a preferred option, please tell us if there is another approach that you consider that we should be taking and why.
I have a preferred option but my tag comments also apply here.

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.
A provision of 2 tags per angler is measurable and in my opinion would reduce overall fish take. The tags should be allocated by reference number to a licence and returned with the Annual return if they have not been used.

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
Yes
Ticked No
I don't know
Please select one item
Higher
Ticked Lower
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.
This is difficult. To maintain the voluntary levels suggested an angler would have to catch10 salmon before he/ she took one for the pot. As we all know very few achieve those figures. The tag system is infinitely better and penalises those greedy fishermen who compulsively knock fish.

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.
I only agree on rivers that are Probably not at risk.

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
Ticked 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

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.
Duddon and Crake

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
No
Ticked I don't know

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 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.
N/A

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
Ticked Yes, all of them
Some of them
None of them
I don't know

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
Yes
Ticked No
I don't know
If you wish, please provide us with your reasons for this answer.
My experience is that a fish to be returned should where possible be kept in the water without the added strain placed on it by trapping in a net. I agree that some rivers do not allow the angler through safety issues and a net is useful on those occasions. Compulsory - No Advisable - Yes

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
No
Ticked 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?
My experience of trout fishing is that a debarbed hook allows it to move around more than a barbed one and can result in a bigger wound. A gentle approach to the release of a barbed hook could be better for the fish but of course some anglers are more gentle than others!

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
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.
I would be comfortable with this having encountered difficulty especially with small sea trout. I generally cut one off.
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?
Minimal. but I am not in Business. Angler only.

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
No
Ticked I don't know
If you wish, please provide us with your reasons for this answer.
I have not yet used one so have no experience to supply a proper answer.
What would the impact be, if any, for you or your business of only allowing the use of circle hooks when using worm as bait when fishing for salmon or sea trout?
N/A

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.
I think a double hook would be reasonable. Flying C's are probably the most widely used lure these days and as a result they catch most fish. Presumably this is why you are targetting them. From my point of view there is no difference between a Flying C and a Devon or a Mepp or a Rapala.
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?
Not applicable

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
Ticked Yes
No
I don't know
Please provide details of what these could be and why you think they should be prohibited or altered.
Shrimp/ Prawn fishing with treble hooks in low water.

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.
To emphasise my point that recurs here. Why do you not implement a tag system to each Angler 2 tags would be enough. It is probably true that 80% of fish are banked by 20% of anglers. If so, their take would be severely diminished and those anglers who catch one fish and keep it would not be penalised. The licence has a number and if tags were numbered and allocated to a particular licence they could not be transferred and if they were the licence holder would have to be penalised. My other main comment is that rod fishermen are the easy target here. This consultation does not tackle predation. Presumably, this is because as an Environment Agency you do not want the bad publicity of arranging culling. We as Anglers are not represented by the RSPB or RSPCA who are powerful but Goosanders and Otters and Crayfish and Seals are all in this problem as well. A Goosander will take more salmon parr in its life than any angler takes an adult fish. Finally, why is there no plan to tackle sea lice problems. Again it is because Fish Farming is a more powerful adversary than the singular rod fisherman we know what th score is. We pay a sum of money every year and all we are getting is persecution when we are looking for support.