Mitigating Water Pollution: A Unique Approach for Salmon Restoration

Dear Mr. Reed,

RE: Salmon/Pollution/Water Companies/solution.

I am writing to you as one of three founders of the Ure Salmon Trust (UST) in Wensleydale, North Yorkshire.

We successfully persuaded the Environment Agency (EA) to permit our smolt restocking programme on the River Ure by arguing the case that our endeavours were necessary to mitigate the effect that a man-made barrier (a dam in our case) that had a significant effect on a wild fish’s ability to exist and breed.

The EA were very difficult to deal with and put up many barriers in the early days of our programme but fortunately we secured a five-year contract that they signed so we ignored their constant negativity and ploughed on and successfully started to reintroduce salmon smolts in increasing numbers.

The adult fish were caught in November from the same river, the eggs were stripped from the hen fish using a gentle anaesthetic and combined with sperm from the adult male. The eggs were then taken to a hatchery, were hatched and then introduced first into a holding tank whilst they grew and then transferred to a semi natural rearing pond where the fish learnt to feed for themselves and became naturally predator-aware.

We maintained accurate records of the significant increase in salmon numbers not only from rod and line catches but also the smolts were all fin clipped on their adipose fin. When capturing adult broodstock in November of each year we could see how many fin clipped fish had returned to the river to breed.

The last records before the EA terminated the programme showed twelve adult salmon caught in one pool, two of these fish were fin clipped which is a substantial return and proved our case that wild salmon can be restocked.

As fishermen, we went into the UST wanting to help the river but always with the intention of stopping the stocking once the fish population was restored to levels that could support itself.

Salmon fishing is supported by many people from all walks of life, it supports direct and indirect jobs in hospitality and other associated businesses. I do not propose to lecture you on the value of salmon fishing as an industry as I am sure you will receive many letters that do!!

I have a solution that comes in two forms; firstly, I propose that you should look at imposing an annual levy on all water companies that goes towards Mitigation stocking in all rivers. Why Mitigation: it is simply because the water companies are mainly responsible for polluting the rivers as we all know. The Mitigation stocking would be funded directly by the annual levy, and it will be delivered by private consortium of local riparian landowners and fishing rights owners who will appoint a river manager, paid by the levy to restock their individual river.

The benefit to Water Companies would be PR; they should be persuaded on the benefits this PR would bring. There would be a contract for each river with a timeline and the term of the contract would be a minimum of 10 years with a review based on water quality. If the water quality reaches an agreed level for a minimum period and salmon stocks have recovered to acceptable and sustainable levels, then the mitigation stocking will cease but only after the full length of the contract term.

Secondly: pre 1930 a role existed known as the Commissioner for Sewers (COS). This person was appointed with the approval of Riparian owners, water companies and by Royal Appointment. The COS remit was to police all waterways and very specifically deal with pollution events and hand out fines to anyone or entity proved to have polluted a waterway be it negligence or carrying out a practise that is likely to cause a pollution event that could be avoided. The COS also appoints local water bailiffs that police and manage waterways from a local level.

This COS and their water bailiffs would be self-financing as they would generate income raised from penalty notices by adding a management fee to the penalty notices in a transparent fashion.

This country needs a COS as they are wholly independent, and I believe it would be necessary to only appoint one. It is also important that the COS does not report into the EA/Defra or any water regulator as it must be able to demonstrate that the role carries no conflict of interests.

We must be proactive and counter the problems in our rivers; it is going to take direct action to Mitigate against water pollution.

I would be delighted to discuss my ideas with you and your colleagues at your convenience and look forward to hearing from you.

Yours Sincerely,

C.J.C Bilborough.

Cc The Right Honourable Rishi Sunak M.P.

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