Submission by the Eastern Regional Fisheries Board

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Observations on Salmon Stocks by the Eastern Regional Fisheries
Board to the Joint Committee on Communications Marine and Natural
Resources
THE INTERCEPTORY SALMON FISHERY
Taking into account the production capacity of the east coast rivers and applying
the national quota, the total allowable catch in the eastern region should be over
20,000 salmon. The drift net fishery is an opportunist fishery and whereas the
East coast salmon fisheries do not benefit to the extent of their capacity to
produce. In determining the TAC the current catch model depends on the catch in
the district not on the productive capacity of the districts rivers.
The only quantifiable information available to the Board on the impact of the west
coast drift net fishery is as a result of the smolt production from Virginia hatchery
in the early 1980s and occasional smolt releases into the River Liffey During the
period 1980-1986 over 100,000 of these smolts were tagged and released into the
River Boyne. The recaptures indicate a percentage distribution of these tagged
fish returned from around the coast as shown in the figure below. In summary,
the percentage of those fish caught on the west coast was 65% as opposed to 35%
from the Boyne catchment.
Recapture of Tagged Salmon released as
smolts from Virginia Hatchery into the
River Boyne 1980-1986
70%
Other Regions
60%
50%
Boyne
40%
30%
20%
10%
0%
Other Regions
Boyne
In the case of the Liffey almost all were captured outside the Region as indicated
in the graph below.
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Percentage of
commercial catch
Dis tribution of fis h caught from m onitore d rive rs 1980 to
2003
35.0
30.0
25.0
Lif f ey
20.0
15.0
10.0
5.0
0.0
Are a
ANGLING PRESSURE
The major East Coast Rivers were traditionally spring salmon rivers. The Boyne,
the Liffey and the Slaney historically had the best of their fishing over by the end
of May. The Slaney is the only fishery, which still holds true to this tradition.
The figure below indicates that this still to be the case in the 1990’s. Based on
the information available, the Slaney has produced catches of spring salmon
catches as good as any of the country’s fisheries. The indication is anglers are
now the only licenced fishery exploiting the spring multi-sea winter strain of
salmon, now that seasons have amended commercial fishing cannot access the
early running stocks. Studies elsewhere (Wye) indicate that angling alone can
take up to 80% of this spring stock. There has been a growing following for catch
and release methods amongst the more enlightened salmon anglers. The future of
spring salmon strain is very much in the hands of anglers.
SLANEY ROD CATCH FIGURES Average 1991-1996
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
UP TO MAY
JUNE
JULY
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AUGUST
It is essential that this Board adopt policies to restrict the capture of these
vulnerable spring salmon strains. It is essential that methods, which increase the
vulnerability of salmon to over exploitation such as the prawn and shrimp, should
be banned. They provide the angler with the means of taking salmon on
occasions when no other method could succeed.
THE COMMERCIAL SALMON FISHERY
It is many years since there was a truly commercial salmon fishery on the east
coast. Nevertheless, it is still important to some fishermen and as a traditional or
heritage fishery there is a high degree of compliance throughout the East coast
fishery. Thankfully it is many years since it has been necessary to take a case
against a commercial fisherman for infringing the regulations.
STOCK MEASUREMENT
In order to manage any natural resource, particularly wild fish stocks, it is
important to know their biology, understand the factors, which limit their
production and quantify the stocks. An effective fish counter system is essential
to monitor the movement of salmon. Regular but not too intrusive assessment of
the production of salmon smolts from the nursery habitats is also important. The
series of reports prepared by the CFB on juvenile salmon and trout populations in
the River Slaney is valuable for fishery management purposes. Optimum salmon
production is the target of this Board in its fisheries region.
LOSS OF HABITAT
Water Quality
The latest report from the EPA (Ireland’s Environment 2004) states that in
general, the East coast rivers are in poorer condition than those in other parts of
the country. The Environmental Protection Agency – EPA assesses water quality
in all the major rivers and streams throughout the country on a periodic basis
normally a three-year cycle. As a result we now have a picture of water quality
for over 25 years nationally. The potential impact of pollution on salmon
production as indicated in the wetted area study is significant particularly in the
Boyne Catchment where salmon recruitment is at risk in over 40% of the
catchment. The main concern to the board is the loss of productive habitat as a
result of poor water quality. This pollution is not generally point source pollution;
it is from diffuse sources often giving rise to elevated nutrients levels. Following
the introduction of Fresh Water Fish Directive, water quality management plans
were prepared; one of the assessments made was the potential of rivers to carry
organic waste to the sea. The rivers still carry a substantial organic load from
domestic sewage. A river such as the River Liffey carries the treated effluent of a
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quarter of a million person equivalents daily. Already two thirds of the water
from the Liffey catchment is abstracted for domestic use. There is a clash in the
balance between the ability of the clean water to carry the organic/nutrient load
(from the treated effluent and diffuse sources) and to sustain healthy fish stocks.
The existing practice of disposing of large amounts of farmyard effluent on land
must be re-examined. Nutrients should only be spread to the extent to which they
are needed for crops production. In general, P levels in soil have risen over the
past century from barely perceptible levels to excessive levels in some parts of
Ireland at present. It is not a simple matter as much depends on the crop, the soil
type and other factors. Even the most ardent advocates for the spreading
farmyard wastes on land admit that in some cases, spreading has been excessive.
Where the backgrounds levels of P levels in soil are high (above15 parts per
million), the ability of the soil and crops to benefit from further applications
decreases as and run-off is liable to increase. Alternatives to the traditional
method for the disposal of farmyard effluent by land spreading require
reappraisal. Options for the farming community are limited and overspreading
or spreading in poor weather conditions or spreading during the non-growing
season, acerbate the nutrient load liable to reach water courses.
In line with the Boards statutory responsibility, enforcement has been a key
activity for Regional Fisheries Boards in limiting the damage caused by direct and
point source pollution.
Developments, which fail to take account of the needs of the environment, have
drawn agencies such as fisheries boards into an opposition role. Unsustainable
and potentially damaging developments to the environment; in the board’s
opinion should not receive the tacit support of the primary protectors of the
environment. Ideally the activity of the Eastern Board in this area should not be
necessary.
COMPETING INTESTS
Water is a much-valued resource with many competing interests and the list for
demands on water is almost limitless. Industrial and domestic use is a primary
need for this resource. Fisheries come towards the end of a long line of water
rights, which includes hydropower, navigation, mill rights, riparian, abstraction,
irrigation, livestock, etc. In the Fisheries Acts other water rights are possibly
better protected than fisheries where competition occurs. Fishery habitat requires
positive protection against abstraction, drainage, road and other infrastructural
developments.
Another competing use, which has been mentioned earlier, is the use of our rivers
to convey large quantities of treated effluent to the sea.
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However, whither water is used for navigation, recreation agricultural purposes
etc. all require the same high standards and quality assurance. Arguably large and
small-scale hydro schemes have been perceived as being amongst the most
damaging to the fish stocks in many rivers. Salmon stocks in the major rivers
supplying electricity to the national grid such as the Shannon, Lee, Liffey, Erne
and Claddy/Crolly have been adversely affected by this development. Numerous
small hydro-schemes, have adapted rights, which were there originally to provide
power for the mills. These mill wheels, which worked intermittently, now are
replaced by turbines, which never stop, and in many cases the generation of
electricity is given priority of the needs of the natural environment. (Ch V Part
XVII F©A 1959)
WATER ABSTRACTION
Ireland has a low population and a relatively high rainfall. Consequently, on the
face of it, there should be little difficulty in providing for the domestic and
industrial water needs of the country without creating any conflict with the needs
of the aquatic environment. Sustainable water supply need not be at the expense
of all other users.
The provisions of the Water Supply Act 1942 as amended allows for comment
and enquiry into the supply of domestic water resources. The same is not true for
the supply of water for private use. The abstraction of private supplies is not
subject to adequate control. Buildings structures and plant involved are subject to
planning, as are in-river works, however, the water use itself is not controlled.
There is a provision under the Water Pollution Acts to register abstractions but
this appears to be voluntary. It is the intention of this Board that every abstraction
should be subject to license by the appropriate Minister. All in river works that is
liable to affect fish or fisheries habitat should be the subject to regulation.
Already there are massive abstractions from most the major rivers on the East
coast: the River Fane to supply Dundalk and the surrounding area.
The river Dee supplies Ardee and the surrounding area.
The Boyne and it tributaries is used to meet the domestic needs within this
catchment. In addition, there are demands to feed the Royal Canal System.
Over 60% of the average flow of the Liffey is currently abstracted to partly supply
the needs of Dublin. The Liffey also supplies the Grand Canal.
The Dodder has a substantial abstraction at it head waters.
The upper catchment of the River Vartry is totally devoted to water supply by
legislation which appeared satisfactory in 1861 but does not meet the standards of
sustainability now Government policy.
There are several small abstractions in the catchment of the Avoca River
supplying the needs of growing towns such as Arklow, etc.
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There are over 12 abstractions from the river Slaney and the major abstraction at
Rathvilly is to supply the domestic needs of water users in the Barrow catchment.
Consequently, discharge is totally lost to this system.
This Board will seek a much more sustainable approach to the management of
water resources in the Eastern Region to ensure that the requirements of all users
are met. The more forward thinking authorities have stored the water during
periods of heavy rainfall to ensure supply for all users during low flow conditions.
In general, the difficulty for all rivers arises at times of low flow. The water
demand is at its highest and fish are under the most stressful conditions.
OBSTRUCTIONS & BARRIERS
Over the centuries all the major rivers on the Eastern seaboard were harnessed for
industrial purposes, some like the Boyne for navigation between Navan and
Drogheda, others like the rivers Liffey, Fane, Glyde & Dee were harnessed to
provide waterpower for mills and other uses.
More recently, the ESB have built three dams on the River Liffey. The upper two
of these are impassable to fish and the lower dam at Leixlip has a Borlin fish lift.
At Poolaphuca, before the dams were built, there was a natural obstruction, which
prevented the free access of fish, however, the downstream migration was always
possible providing a source of juvenile fish for the lower reaches of the Liffey.
No provision for fish access was made through these dams, consequently
permanently isolating the upper catchment from the rest of the River Liffey. This
development has removed the possibility of creating the potential to contribute to
salmon and trout recruitment in the River Liffey. The success of the fish lift at
Lexlip has always been in question; however, it is possibly amongst the most
successful of any in the country. The dam at Leixlip also provides for a major
abstraction point for the local authority. The ESB have a statutory responsibility
to protect the fishery interest and to ensure that salmon have free access to the
spawning grounds.
Many of the weirs that were built to service the mills and millraces along all
rivers, most have fallen into disuse this is particularly true for the River Liffey.
Most are listed structures, consequently limiting the intervention, which any
person can make to repair them. Fish passes were installed; however, the reduced
flows due to abstraction and deterioration of the weirs means that these fish
passes no longer operate effectively and are particularly in low flow conditions.
A major task needs to be undertaken to assess what needs to be done to upgrade
these structures to ensure that they are not a permanent obstruction to fish
passage. Some of these new weirs have been maintained to supply water to small
generating plants. As far as this Board is concerned, the traditional mill right
never extended to power generation and in the board’s opinion is a change of use.
The traditional right to drive a mill wheel is in different use! As a result, the
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Board feels that the Fisheries Acts should be amended to reflect that only the
traditional use is preserved in the legislation – not new uses.
DRAINAGE
Most of the East coast salmon rivers have been drained or partially drained. The
result was a loss of salmonid habitat. The Boyne the largest east coast
catchment has been subject to major arterial drainage commencing in the late
1960s and concluding in the 1980s. Some rehabilitation work followed the
drainage, however, much more work needs to be done. Even rivers such as the
Slaney have had some of the important tributaries straightened and drained by
local landowners. The same applies to the River Liffey although never the subject
to an arterial drainage scheme. The Rye and some of the other Liffey tributaries
have been drained by the OPW.
Apart from any loss of habitat, the main disadvantage is the change in the natural
characteristics of the river. It also makes access more difficult and dangerous for
anglers and landowners. In general it reduces the visual amenity of the water
courses affected.
The Rivers Glyde and Dee were both subject to arterial drainage in the 1950’s,
neither were rehabilitated and much works need to be done on these river systems
to restore them to full production. The study in 1995 indicated that in the region
of IR£750,000 was required to restore the River Dee and Glyde following the
impact of arterial drainage. This project was turned down as being too expensive
by the TAM committee.
URBAN AND ROAD DEVELOPMENT
The growth of the greater Dublin area and the development and improvement of
infrastructure surrounding the major conurbation has impacted adversely on all
the river systems in this area. The main difficulty, experienced by fisheries
during this period, was the lack of protection in the legislation for fishery habitat.
It has been our experience that all the decisions made by developers, the National
Roads Authority and local authorities are based on economics and not on the
needs of the environment. The most economic option is invariably the optimum
choice in all cases. Long unlit culverts and streams being assigned to pipes in
order to gain a few meters of land has been the difficulty facing this Board for
over a decade. We found it necessary to produce publications aimed at informing
developers and others in an effort to try and educate to the needs of fisheries. It
has been a major part of the Board’s work to liaise with developers, and much of
the board’s environmental resources have been assigned to it for many years.
We can recount many successes in our effort to protect the small streams that feed
our fisheries. These are the lifeblood of the river systems.
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FORESTRY
In certain parts of the Eastern region, forestry is having an adverse impact on
salmon and trout recruitment. County Wicklow is one of the most heavily
forested counties in the country. The Wicklow Mountains are formed of igneous
rocks with very little buffering capacity. Many parts of this area, which is now
part of the National Park, is termed environmentally sensitive, however, there are
large tracks of forestry in and bordering this area. The EPA,UCD and the Central
Fisheries Board have carried out several studies, which indicate local adverse
impact. They found a sizable tributary of the Avonmore system devoid of fish as
a result of the impact of forestation on water quality. Solutions are by no means
simple, however, the upper reaches of the River Liffey, Dargle, Vartry, Avoca
and the Slaney require to be treated much more sympathetically when reafforestation is planned in these catchments.
A second more general impact from forestry is the tunneling; the effect of trees
shading large stretches of streams from adequate natural light. Numerous studies
indicate that tunneling adversely affects salmon and trout recruitment by up to
70% where rivers become tunneled by trees.
RECRUITMENT
Survival at Sea
We are advised by the scientists in the Marine Institute and the Central Fisheries
Board that salmon survival at sea has declined in recent years. There are
numerous possible causes, most of which appear to be outside the control of an
agency such as ours. Some of these problems may only be soluble by global
changes in the way we exploit this planet.
Smolt Survival
Those who have ever handled smolts realize how delicate they are and agree that
interference with salmon at this stage of its development is likely to lead to losses.
We have witnessed ourselves smolts mortality in their decent over the hydro-dam
at Leixlip. We have recorded the impact of small-scale hydro-schemes disrupting
the downstream migration of smolts. We have witnessed hundreds of salmon
smolts being killed on the screens on a headrace of a small-scale hydro-scheme on
the River Slaney.
The most significant, is the impact of poor water quality on the production of
viable smolts. For years the middle reaches of the River Liffey were moderately
to seriously polluted and during this time, the production of smolts fell, as did the
subsequent returning salmon. While this was happening, this Board was a lone
voice – we objected to planning applications, which would have exasperated an
already totally un-satisfactory situation. We were cast in the role as watchdog on
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the environment as a result of our statutory responsibility to protect fisheries. The
statutory authority responsible for the environment (Local Authorities) and the
Department for the Environment were in fact the agencies responsible for the
problem. On a number of occasions, we prosecuted for this discharge, and
engaged in lengthy planning appeal processes.
Salmon and trout recruitment is also affected by urban development when lakes
and rivers and streams are lost due to culverting. Some years ago we estimated
that we were losing approximately 2km of streams per year to roads, industrial
and domestic developments. We are not a notify able agency for road
developments covered by the Roads Directive.
The east coast is generally unsuitable for offshore salmon farms but the impact of
these on salmon and trout populations is hotly debated in other regions. There
were up to 12 land-based fish farms in this region, many of these were prosecuted
by the board, prior to 1997 when the prosecution function was transferred to
Director of Public Prosecutions. To the best of my knowledge, no prosecutions
have been taken since this has happened. There are three main areas where the
land based fish farms impact on fisheries, firstly water abstraction, secondly the
provision of adequate screening and thirdly interference with natural fish
populations.
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