Consultation response IFI Oct 2026
It is encouraging that IFI have reached out to the wider angling community regarding Salmon management proposals.
It is hoped that IFI and government ministers will listen to and analyse the responses carefully and respond appropriately by implementing measures that will result in sustainable management of anglers and the fish they love to fish for. That would include local angling and the tourist angling market.
There have been many investments in fish counting technologies, tagging schemes, habitat improvements to police and improve the potential salmon harvest in Ireland.
Juvenile Habitat Protection
Although my response focuses on juvenile habitat protection, I recognise that sea survival of smolts is a challenge. However, without juvenile habitat in rivers there would be no prospect of fish, and without fish there would be no viable angling/ fishing opportunities. A great heritage and culture identify within Ireland would be greatly diminished or lost.
This consultation should be the start of a success story for Atlantic salmon if statutory bodies, government ministers, local angling clubs and community groups all supported a coherent strategy that ensured freshwater habitat for Atlantic salmon is protected and where possible enhanced.
Whilst there is a consensus that problems at sea limit adult returns from smolt, some rivers are producing more salmon than others despite small fluvial areas. The reasons and explanations should be fully investigated and described. Discrepancies between potential productivity in relation to the unique hydro geomorphological (HGM) profile need to be considered in addition to water quality problems, riparian problems, drainage problems, forestry, hydro generating schemes.
I am of the view that smolt output when all other things are equal is related to quantities of specific habitats such as spawning and nursery habitat. The productivity of a river is not always related to its angling opportunities and or total fluvial area but a more specific definition of its HGM profile.
Scientific Assessment
Ultimately juvenile habitat is a limiting factor for smolt output.
Scientific assessments, (whether statutory or citizen) must be used to provide improved outcomes and implementation of actions which ensure individual freshwater habitats, and individual fish population are protected.
For example, it would make sense to continue to utilise the EF data supplied by TEGOS. It is suggested that the use of the EF data collection could be made more efficient by auditing the HGM habitat profiles in terms of Life Cycle Unit Analysis ( LCUA) i.e. spawning, nursery and holding habitat of individual salmon rivers and selecting site to fish on that basis.
Assessments currently utilise fluvial area as a proxy for juvenile to smolt output. While fluvial area is useful as a base parameter for individual rivers (big, medium or small) many rivers have unique characteristics suited to salmon ecology. Many small rivers for example may have a greater share (proportion) of spawning, nursery, pools when compared to larger rivers. Therefore, by incorporating a life cycle unit habitat analysis (ova deposition habitat, fry habitat, parr habitat, pool habitat,) reflective of an individual rivers unique Hydro Geomorphological ( HGM ) profile, accurate assessments can be made of an individual rivers’ productivity potential for Atlantic salmon. A life cycle unit habitat analysis would provide a quantifiable proxy measures of potential smolt output, conservation limit, and management targets. Electro-fishing assessments, adult fish counter data, angling logbook returns, redd counts etc provide verification measures of habitat productivity. Just because a river has a small in fluvial area doesn’t mean it should be ignored as a salmon resource. Likewise, some larger rivers may have limited habitat suited to wild salmon productivity.
MSY
Reducing the risk to individual river populations by applying Conservation Limit and Management Targets above CL is critical to ensure salmon productivity of individual rivers towards a maximum sustainable yield of adult fish from individual rivers.
Resource Provision
A positive outcome would be the provision of supporting resources from IFI such as communication meetings, outreach, engagement. Identifying where salmon habitat can be protected and enhanced and facilitating getting the work done in catchments is key. However, it needs to be recognised that in some cases all that needs to be done is to let the river be wild and do nothing that will interfere with juvenile salmon habitat.
National /Local
Angling opportunities for the visiting angler and the local angler need to function alongside each other. It would be reasonable for local anglers/fishers to fully support limited and precautionary harvesting considering diminished returns of recent years. The consultation discusses the traditions of salmon in terms of netting salmon as a key community role. However, if these traditional activities are to continue, they must do so in a precautionary manner.
Management Targets
A management target surplus above the CL would be precautionary. The total output of smolts from an individual river can be defined by the availability of juvenile habitat. There needs to be a CL surplus (i.e. a management target) of adult salmon with ova and attendant males in particular rivers to ensure an angler’s share. Therefore protection, enhancement and development of salmon habitat is essential to ensure traditional salmon angling and salmon fishing can continue. All of those interested in maintaining the traditions of salmon angling or other means of capture need to be responsible for that future, supported by statutory bodies and government ministers and local community clubs. Catch and release is a useful conservation measure too without reducing angling prospects and would also add value to the angling experience. Provision for both local and visiting anglers would provide a sustainable solution when they are considered collaboratively.
Outreach and Engagement
It will be important to support and resource actions that are state funded and community based. Enhancing salmon stocks and individual river populations should provide the mission statement to define work programmes and anticipated outcomes.
Therefore, it will be necessary for the statutory bodies (IFI) to communicate and engage with the local groups to successfully implement their desired aims and outcomes and strive for compatibility with local and international groups such as North Atlantic Salmon Conservation Organisation (NASCO). Protecting Salmon populations and their habitats deserve investment at a level desired in angling clubs and community interests.
Community and angling club engagement at a local level is critical to support a strong conservation and quality angling experience.
Allocation of catch or Catch and release
Where surpluses are identified by Conservation Limit or Management Target these should be allocated fairly and to the best socio-economic and ecological value which would include opportunities for successful angling. Catch and release ensures that more anglers enjoy the chance (better odds ) of catching a fish or two. Where catch and release is implemented carefully there are more fish in the rivers to catch resulting in better angling for more anglers rather than a reap harvest by a few.
Cross Cutting Initiatives
The influence and value of protecting salmon populations needs to be factored into decision making re infrastructure, WFD and other cross cutting initiatives with sufficient weighting.
Working group
The guidelines identified in the consultation need to be implemented and it is hoped that the challenge will be met by appropriate scientific research, analysis and community angling club implementation.
The headings given in the consultation, of Scientific Stock Assessment, Managing exploitation, Environmental protection are key.
It would be useful have more input to TEGOS beyond the 4 suggested and at the very least there should be a facility for observer status and communication of potential plans.
There should be resources deployed to ensure regional and local engagement and beyond the angling community to the cross-cutting issues such as Infrastructure and WFD , farming, forestry etc.
TEGOS should aim to improve wetted area assessment in terms of HGM and life cycle habitats to estimate and mange smolt outputs ( CLs and MTs )
There are three main Consultation recommendations
Maximising smolt output by protecting and restoring habitat
Addressing issues with Habitat such as sediment load
And conservation measures including reduced exploitation
Continuing to acquire scientific data is essential but the application of common sense would also be helpful where the evidence for action is clear.
Relying on WFD and SACs and other environmental programmes etc to protect salmon habitat will only provide limited help. Therefore, a mechanism to integrate salmon management conservation and protection measures into crosscutting decision making such as drainage, forestry, upland, management etc to protect local unique salmon populations is required.
It must be asked if IFI can do better even though IFI has provided a communication and engagement platform via this consultation but any perception that IFI falls short of its strategic aims due to poor management structures needs consideration.
Whilst it will be critical to gain ministerial support the goal strategy and tactics of protecting and enhancing salmon stocks needs to function beyond politics to achieve its goal.
Brendan Kerr Oct 2026