Response 250312409

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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.
Any assessment based on catch data is totally flawed as depends on rainfall and fishing effort. What is interesting is the different results from counter data. Also any data based on so called juvenile surveys is bound to be influenced by rainfall and where the fish actually spawn. Given that the EA has substantially reduced the number of sites that it conducts such surveys on and conclusions must be extremely dubious. What the expanded data and surveys we have privately funded shows is the numbers o f juveniles can vary hugely by site by year and any one year's data is wholly unreliable on a very small sample basis which is unlikely to be statistically proven

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
Ticked Wholly
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.
Not only agree but it is the EA and DEFRAs legal responsibility to take account of the economic impact of recreational salmon fishing vs the very limited economic benefit of netting. Not that anyone takes any account of legal requirements

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.
There is no evidence this has any effect on salmon stocks whatsoever and given the lack of fishing effort prior to 15 June the EAs own methodology of using catches to determine fish stocks is totally invalid. I no longer fish for salmon before 15 June therefore I will not catch any! The EA and Defra constantly also fail to recognise the importance of anglers on the water to provide protection from poaching and other environmental events that need reporting.

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
Option 4
Ticked I don't have a preferred option
Please provide details of why you have given this answer.
This is a biased consultation as it is clear a decision has already been taken. 1 The 2021 assessment is completely flawed and is merely EA guesswork and nothing else 2 Catch and release will ultimately kill all rivers as there is little doubt angling activity will decline and voluntary investment in rivers whether financial or labour will fall but no doubt the lack of anglers on the river will cause poaching to massively rise. 3 There should be a annual catch limit for fish taken - not an option on the consultation and in my opinion a cessation of salmon fishing once those fish have been taken as I seriously doubt the survival rate of catch and return fish
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.
See above.

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.
None. You assume in your biased consultation there are benefits there are huge and damaging environmental costs - lack of voluntary investment, lack of policing of rivers etc as set out above

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
If no or don't know, please explain your answer and include any dis-benefits that you consider the use of voluntary catch and release would bring.
Because once things become statutory they are never reversed as the ridiculous pre 15 June rules indicate. If any member of the EA or DEFRA had ever bothered to look back in history they would discover salmon runs have waxed and waned over time and that the timing of runs has again followed a massive cycle. Panicking in the short term is just silly and just damaging to angling generally and the health and welfare of rivers in particular.

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.
50% and a maximum of two salmon per angler to be taken per season for a fixed period, say 5 years

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.
None. As above they are all disbenefits as there will be less money and voluntary time invested in angling and the welfare of the 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
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.
See above

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
Ticked Yes, if Option 4 was implemented
Please tell us which river(s) you fish for salmon on.
Teign

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.
Because I do not wish to drive all over the country

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.
The fundamental problem with catch and release is the fishing method. Fly and light spinning tackle is difficult as the tackle is lighter and it takes longer to dominate and bring in a fish and I have found the chances of survival of a released fish to be much lower as they can be exhausted

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.
Do not fish!

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
Yes
No
Ticked 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?
Another chance of losing a fish that I go out and try and catch and I have a large investment in old equipment which would be obsolete. I have never found barbed hooks to be a problem for salmon or larger sea trout

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
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?
A lot of my kit would be obsolete

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 do not know what a circle hook is but the first question that you have not even asked is why prawn and worm are not banned as a form of legal river fishing

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 do not use them anyway but I see no problem with flying Cs - much more with worm and prawn

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.
Worm and prawn as above

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.
1 The outcome appears to have been determined by the questions. 2 Completely questionable assumptions have been made by an organisation, EA, that has never knowingly got anything right in the past over their predictions 3 there is a complete failure to understand the level of demoralisation of anglers with continued overregulation and the ultimate outcome will be even less anglers on the river, less licence fees available and less financial and time resources from fishermen to protect whatb the EA alleges it is trying to protect. 4 LEAVE US ALONE - we are the people who really understand the environment and the local activities, not from some book and some dodgy statistical studies - we are not penpushers who are sitting in London we are actually the people on the river, protecting the river, financing the river and working on the river. 5 Your consultation makes no attempt to evaluate the loss of resources to the river of your proposed actions - financial, administrative or actual physical work 6 Angling clubs are already under severe pressure from declining numbers and restricting fishing will only accentuate those pressures - the ability to take fish is a big driver for fishermen - take away that hope and you take away a lot fishermen