Dear Ian 

Casework on the Assessment of Salmon Stocks and Fisheries in England and Wales 

We have recently been in touch with the teams involved in the production of the Assessment of Salmon Stocks and Fisheries in England and Wales statistics. This is a joint publication produced by the Centre for Environment, Fisheries & Aquaculture Science (Cefas), the Environment Agency and Natural Resources Wales (NRW). Our engagement was in relation to concerns raised with us by members of the public. While many of these concerns fall outside of our remit, we wanted to share our findings in two areas where we identified opportunities for improvement. 

The first area relates to the approach used within the statistics to estimate rod exploitation rates for unmonitored rivers. The supporting documentation is generally clear about the many parameters that are used within the different estimates and provides detailed descriptions of how they are measured and the impact this can have. However, from our desk research and discussions with the responsible teams, we believe that some elements of the modelling approach, in particular exploitation rates for unmonitored rivers being estimated by Area Fisheries Technical Specialists, could be more clearly described within the supporting documentation. The contextual information on how data gaps are addressed is essential for users to understand the quality, strengths and limitations of the estimates which supports appropriate use of these statistics. 

The second area relates to the ongoing review of the current methodology for assessing salmon stocks. The background documentation for the 2004 report states: 

“An improved procedure is being developed by the Agency to address this problem. This will take account of annual changes in fishing effort, as well as partitioning effort between salmon and sea trout” 

And near identical text is still present in the most recent report which also highlights that work is underway: 

“Ideally, an improved procedure is needed to take account of annual changes in fishing effort, as well as partitioning effort between salmon and sea trout (no distinction is currently made between these species when reporting fishing effort” 

We understand from discussion with the team that the text was originally added for a historical review that did go ahead but led to no substantial changes in approach. Being open about plans and developments is a key part of the trustworthiness pillar in the Code of Practice. While supporting documentation may not change as often as the main publication, it is best practice to periodically review this to maintain confidence and trust in official statistics. In addition, while the current review is now underway, there is a lack of additional links or information in the background reports to inform users as to how they can contribute to this or what the expected timeline for the review is. 

The teams involved must review how they update their publications and supporting documents to ensure any proposed work or reviews are clearly communicated and users are kept appraised of developments or delays. For the ongoing review, the teams must ensure they are considering what level of user engagement is required and whether they have acted to facilitate this, both in terms of transparency and accessibility. Our guidance on Intelligent Transparency and user engagement could help inform how best to do this. As the work proposed in the review is a positive development, the team should ensure to communicate when the new method is rolled out and should consider whether the current background documentation covers all elements of exploitation rate estimation. 

As the Head of Profession for Defra group, we believe it would be beneficial for you to further engage with the relevant teams and their organisations, to share the breadth of experience and support available across the wider Defra statistics community. For example, our review of user engagement within the Defra group highlighted the range of good practice that could aid the teams in the ongoing review. If our staff can offer support or training as part of this increased engagement, then please let us know. 

I am copying this letter to Simon Toms, Environment Agency, David Mee, Natural Resources Wales and Alan Walker, Centre for Environment, Fisheries & Aquaculture Science as representatives of the teams we have engaged with. 

Yours sincerely   

Ed Humpherson
Director General for Regulation