Im up at crazy O’clock and it is actually too dark to say what kind of morning it is in Foxford, but, Good morning anyway. The week has been nasty enough on the weather front. We had storm Bram on Tuesday, it wasn’t a bad storm however it did bring a lot of rain. Water levels are very high now and the Loughs are brim full so levels will stay high for a good while. Hopefully not too high for a bit of fishing over the Christmas period, lets see what happens. Two weeks ago I mentioned draft regulations regarding Salmon fishing in Ireland for the coming season. I suggested at that time that we should all submit some form of response. In this weeks blog I am going to share our submission which we submitted yesterday, enjoy reading it and as always if you have a comment, my email address is at the bottom.

Submission to the Public Consultation on the Draft Wild Salmon and Sea Trout Tagging Scheme Regulations 2025

From: Tiernan Brothers Fishing Tackle Shop, Foxford, Co. Mayo.

Date: 11/12/2025

To: The Department of the Environment, Climate and Communications / Inland Fisheries Ireland (IFI)

Subject: Formal Submission regarding the Draft Wild Salmon and Sea Trout Tagging Scheme Regulations 2025.

Introduction

Tiernan Brothers, situated on the banks of the River Moy in Foxford, has been a cornerstone of the angling community and the national license distribution system for over 30 years. As a small, family-run business combining a tackle shop, guiding services, and license provision, we have a deep, multi-generational commitment to the sustainable future of Ireland’s wild salmon and sea trout fisheries. We welcome this consultation as a necessary step towards modernising management and securing fish stocks for future generations. We submit this response in a spirit of constructive engagement, seeking to ensure that conservation measures are effective, equitable, and scientifically grounded, while recognising the profound socio-economic role of angling in rural Ireland.

1. Support for Reform & Our Role in a Future System

We acknowledge the requirement for change and agree that the current licensing, tagging, logbook and distribution system is outdated. We are willing and eager partners in developing a more efficient, modernised system.

Our Vital Role: For three decades, we have been the public face of the licensing system in the Moy region. We handle complex queries, assist hundreds of visiting domestic and international anglers (often overcoming language barriers), and provide a critical service seven days a week during peak season, including early mornings and holidays when state bodies are not directly accessible. We are knowledgeable, trusted, and embedded in the angling community.

A Necessary Function: The distributor role we fulfil is not merely transactional; it is educational and supportive, ensuring compliance and enhancing the visitor experience. Any new system that eliminates established, professional local distributors would cause significant disruption, reduce compliance oversight at the point of sale, and negatively impact angler satisfaction.

Commitment to Engagement: We seek an active seat at the table in negotiations regarding the future shape of the licensing, tagging, logbook and distribution.  Our practical, on-the-ground experience is an invaluable resource for designing a workable and effective model.

2. Serious Concerns Regarding the Draft Regulations as a “Blunt Instrument”

While we support the principle of conservation, we have significant reservations about the proposed regulations, which we believe are premature and not sufficiently evidence-based for the River Moy.

The draft measures appear to be a blanket, one-size-fits-all approach that fails to account for the specific dynamics of individual river systems. For the Moy, several critical data gaps make the proposed restrictions questionable:

• No Definitive Baseline: There is no agreed, definitive figure for the number of adult salmon entering the Moy system annually—a fundamental metric for setting catch limits.
• Unknown Smolt Output: The number of smolts leaving the system annually is not accurately known, preventing a proper understanding of stock productivity.
• Uncertain Catch Data: The true number of salmon caught annually (including catch-and-release) is not comprehensively known.
• Unknown Spawning Survival: Accurate data on the number of salmon that survive to spawn is lacking.
• Shifting Run Timing: There is empirical evidence from anglers and guides suggesting salmon runs are now occurring later, often after the official angling season has closed. This critical trend is not reflected in the management calendar.

Without addressing these fundamental knowledge gaps, imposing severe restrictions is not prudent conservation but potentially unnecessary socio-economic damage. We urge a pause in implementing the most restrictive measures for the Moy until a robust, scientific baseline is established through enhanced monitoring.

3. A Constructive, Angler-Proposed Alternative for the Moy

Our engagement with the angling community reveals a strong consensus for a balanced, conservation-minded approach that also recognises the tradition of harvesting a fish. Based on widespread discussion, we propose the following framework for the Moy, which we believe would secure greater public compliance and support:

• A harvestable number of three salmon per licence for the season.
• A defined harvest window from 12th May to 12th August to protect early-running multi-sea-winter fish and resident (Red) fish.
• A mandatory catch-and-release policy for all salmon over 65cm at any time of year, to protect the most endangered multi sea winter fish.

However, any tagging scheme, regardless of its design, is fundamentally undermined without effective enforcement. It is irrelevant how many tags are issued if compliance monitoring and on-the-ground enforcement by IFI management and staff are perceived as inconsistent or inadequate. A total review of IFI’s financial structure and resource allocation for frontline enforcement is necessary—a point we have previously raised in prior submissions. Confidence in the system depends on visible, fair, and consistent application of the rules.

4. Specific Commentary on Key Elements & Impact on Anglers

Brown Tag Allocation for the Moy: The proposed introduction of brown tags (harvest tags) for the Moy appears disproportionately severe given the acknowledged data deficiencies. This drastic measure will:

• Deter visiting anglers, for whom the chance of harvesting a fish is a significant part of the angling tradition and holiday value.
• Shorten the average length of stay, as anglers may choose not to fish for multiple days if the chance of harvesting a fish is minimal.
• Damage the international reputation of the Moy as a premier salmon fishery.
  • Impact on Anglers: The cumulative effect of reduced tags and restrictions on angling methods combined with potential season shortenings or river closures, will create a dramatic decline in angling activity.
  • Anglers will vote with their feet, choosing destinations in Norway, Scotland, or Iceland perceived to offer better value and opportunity.

   

  5. The Socio-Economic Impact on Rural Areas & Our Business

   

  The River Moy is not just an ecological asset; it is the economic lifeblood of towns like Foxford. Salmon angling supports:

   

  • Local Businesses: Hotels, B&Bs, restaurants, pubs, shops, petrol stations, and guiding services.
  • Employment: Direct and indirect employment in the tourism and retail sectors.
  • Community Vitality: It sustains the social fabric of rural areas, bringing domestic and international visitors and revenue to regions often lacking alternative industries. It also offers a sporting & social outlet in rural areas where isolation and loneliness are huge factors in poor mental health.

   

  Potential Loss Figures:

  A conservative estimate of a 30-50% decline in visiting salmon anglers. This is a realistic scenario given the proposed restrictions and would result in a direct loss of tens of thousands of euros in local expenditure in Foxford alone. For our business, this represents an existential threat not only from lost license commission and footfall but also from obsolescent stock.

   

  6. Formal Case for Compensation 

   

  The draft regulations, if implemented in their current form, will render a significant portion of our business inventory unsaleable. We currently hold in excess of €€€ of stock specifically for salmon angling (rods, reels, lines, flies, floats, worm hooks, treble hooks etc.)

  A Government-Mandated Obsolescence: This is not a case of poor business judgement or market evolution. This stock will become obsolete due to a direct change in government policy that effectively closes down a viable sector of our business.

   

  Precedent for Compensation: It is an established principle that where state action directly devalues or destroys private property or business assets, compensation should be considered. We therefore put forward a formal claim for compensation to offset the catastrophic devaluation of our specialist inventory.

   

  Request: We request that the Department engages with us to establish a fair mechanism for inventory audit and compensation as an integral part of the transition to any new management regime.

   

  7. A Holistic Approach to Conservation

   

  We firmly believe that targeting angling alone while ignoring greater marine threats is misguided. The Atlantic salmon’s decline is multi-factorial:

   

  Overfishing: Illegal Drift and Draft netting along the coast and illegal taking of Salmon from freshwater.

   

  By-Catch: Loss of juveniles and adults in other fisheries.

   

  Predation: Uncontrolled exploding populations of seals and cormorants.

   

  Pollution: As witnessed many times recently.

   

  Habitat Loss: Barriers to migration (weirs, hydro dams), water quality issues, and climate change.

   

  A sustainable future requires a bold, holistic strategy addressing all these pressures. To place the entire burden of recovery on inland anglers and rural businesses is neither fair nor scientifically justified.

   

  Conclusion & Summary of Requests

   

  • Delay & Research: Postpone the most severe restrictions on the Moy until a robust, scientific baseline census (adults in, smolts out, spawner survival) is completed.
  • Adopt a Balanced Approach: Consider the angler-proposed alternative of 3 fish per licence, a defined harvest window, and a 65cm maximum kill size as a more palatable and sustainable model for the Moy.
  • Strengthen Enforcement & Review Finances: Commit to a review of IFI’s enforcement capabilities and financial structure to ensure any new scheme is credible and effectively policed.
  • Include Stakeholders: Engage with established license distributors, Angling clubs, fishery owners, and individuals with first hand knowledge of the entire situation in designing a fair and efficient licensing, tagging, logbook and distribution system that retains essential local services.
  • Commit to Holistic Management: Develop and publicly commit to an integrated conservation plan addressing all critical threats to salmon, especially at sea.
  • Establish Compensation Framework: Enter into discussions to establish a fair compensation scheme for businesses facing significant inventory obsolescence due to these regulatory changes.

   

  We thank you for considering our submission. We are committed to the future of salmon and our community, and we stand ready to assist in finding a balanced and sustainable path forward.

   

  Yours sincerely,

  P.J & Michael Tiernan

  Tiernan Brothers

  Main Street

  Foxford

  Co. Mayo

Comments: email mtiern@gmail.com