These comments refer to the Waterbody Information Pack Avon Waterbody (Draft WIP – January 2011)

The WIP states that:

The EA recognise that low pH values leading to a 'moderate' classification for the watercourse are the result of moorland acidification and are unlikely to improve.


In our opinion current fish surveys are out of date and fragmentary. The surveys (on page 5) were conducted between 2004 and 2008 and do not include sites below Cocks Brook.

The suggestion in the conclusions on page 6 that two data points be removed to achieve good status smacks of “data massaging” and risks the report descending to the status of “pseudo-science”. The situation is made worse by suggesting that this would create “a fair reflection of the waterbody as a whole”. The underlying problem remains - the sample size is small and restricted to fish surveys upstream of Cocks Brook.


The EA could carry out fish surveys below Cocks Brook and add this extra data to the database. This relatively low cost approach might improve the "EQR average" figure and provide a more accurate picture of fish stocks in the river.


Due to confusion between the Devonshire Avon and Avons in other counties, the EA admits that there are major errors in the reported number of salmon and sea trout caught by anglers on the river. Rod catch is an important measure of the health of a river.


Therefore we have little confidence in the current EA classification of fish stocks in the Devonshire Avon.


Moreover the present situation is likely to deteriorate even further in light of the weak conditions included in the licence granted by the EA to a hydropower scheme at Gara Bridge.


Increasingly the Avon depends on the goodwill of riparian owners and external not-for-profit organizations to protect the river against the damaging effects of EA hydrogenation policy and the EA’s failure to maintain, develop and improve the fishery.


Paul Kenyon, Chairman Avon Fishing Association.