Last update: 14th July 2018

To the minister Re: NRW fisheries bylaw proposals – Update

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

10 July 2018

Re: NRW fisheries bylaw proposals – Update

Dear Minister,

We note in recent correspondence to both ourselves and various AM’s who are supporting Welsh Anglers that you continually say “I am unable to comment on the proposals at this time” as you are awaiting a response from you officials on the bylaw proposals.

You will undoubtedly be told by NRW that there are only six complainants about the proposed bylaws. The reality is that those six represent all anglers in Wales – we are the Anglers Shop Stewards fighting for the rights of our members.

We commissioned an independent Evaluation Report on the methodology used by both the NRW and EA, the findings in this independent report show that the present river classification system is statistically incorrect, has not been validated since its introduction in 2003 and is deeply flawed.

Our collective view is that the proposed measures and justification set out by the NRW in the Bylaw Consultation conservation case will not reverse the decline in stocks and potentially places salmon and sea trout stocks under greater threat.

Prior to your final decision on the bylaw proposals presented to you by NRW we wish for an opportunity to present our case to you or your Environment Minister for a shared management approach reflecting the important role anglers play in conserving, protecting and enhancing salmon and sea trout stocks. This request is being made as it has become apparent that in making their bylaw recommendations NRW reached the conclusion that none of the reasoned objections to mandatory measures or alternate conservation proposals submitted by anglers in the public consultation were considered as being of sufficient merit to change or amend their original drafted bylaws (The NRW preferred option).  One small consideration has been adopted. However this is more to do with avoidance of disability discrimination, although there still remains a question mark on whether the concessions actually achieve that.

The uncertainties of the introduction of the proposed bylaws are already having an impact on the management and viability of fisheries (reductions in membership and visitor income) and we wish to present our own evidence on the following grounds: -

  • The Consultation Conservation case states that 10-year statutory catch and release measures for salmon are necessary to reverse the current threat to stocks at a time when, according to NRW anglers in Wales already voluntarily return 86% of the salmon they catch.  The implication in the NRW case is that anglers are the cause of the decline; this is patently not the truth.
  • Anglers, Riparian interests and Rivers Trusts undertake a range of important voluntary fish protection and enhancement programmes. The loss of these critical voluntary programmes is imminent as anglers give up fishing or fish elsewhere. Unviable Clubs, fisheries and Riparian owners will be forced to scale down their activities or close altogether. The NRW are not able to back fill these voluntary programmes and the vacuum left will result in greater loss of juvenile and spawning stock due to increased poaching activity, predation and other river related incidents – pollution etc.
  • Anglers have taken a responsible conservation approach, introducing voluntary codes and tagging schemes to meet agreed target catch & release rates in the lead up to the Bylaw review. The C & R rates are at a historic high (appox 90%) and in line with national guidelines.
  • The conservation case is based on questionable stock data assumptions and should not be used to implement statutory measures.
  • Elements of the proposed Bylaws are not enforceable and would rely heavily on angler’s support.  Recent reorganisation within NRW has further weakened fisheries enforcement who will now only be active from 8am to 5pm, poachers operate at night.
  • Little economic or social impact assessment was undertaken with NRW publicly stating there would be a reduction in angling activity.

I would draw your attention to the press statement issued by NRW (Messrs Gough & Mee) following the deferment of proposals in which they say, “there will be no further debate” and that “they were prepared to make themselves unpopular”.  It is clear from these statements that the response from Inland Fisheries/NRW will be for you to support the proposals as published.  The approach in England by the EA is not as draconian as those by NRW with no blanket ban as proposed in Wales i.e. it is easier to blame Welsh anglers than deal with the root cause.  It was agreed at a recent EA meeting (with NRW present) that the way forward for England and the EA was for co-operation with anglers, unlike NRW who prefers to ignore stakeholders.

Our preference is for stakeholder involvement and meaningful discussion, as is happening in England, instead of imposing on Wales the most severe conservation legislation in the whole of the United Kingdom and Ireland.

As Minister we do not expect you to have an in depth knowledge of the issues.  The NRW Fisheries Team has freely acknowledged that anglers know their own rivers better than they do and that alone provides sound basis for our concerns to be heard independently (as recognised at the recent Petitions Committee meeting on 3 July). Your options are therefore to either support your agency and approve their proposals or support anglers, your electorate. To that end we would again request a meeting with either yourself, or your Environment Minister, in order to present our case for a voluntary solution and as a result avoid the need for statutory legislation as a first response.

 

 

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

Questions for NRW Board Meeting 12th July 2018

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

From: ”JOHN EARDLEY”
To: ”NRW Board Secretariat” <nrwboardsecretariat@cyfoethnaturiolcymru.gov.uk>
Cc:
Sent: Sun, 8 Jul 2018 at 17:39
Subject: Questions for NRW Board Meeting 12th July 2018
Would you please ensure that the 2 questions below are presented to the NRW Board at the Board Meeting to be held in Swansea on 12th July 2018.
1.      Given that there was clear acknowledgement at the Board Meeting on January 18th that NRW, and its Fisheries Team in particular, had failed to properly engage with stakeholders in developing the proposals for new catch controls for salmon and sea trout, that there must be immediate steps taken to put that right and a further 6 months have now passed:
 
When will that engagement with stakeholders actually begin?
 
2.      The Environment Agency is now proposing that “Probably at Risk” rivers in England will not be subjected to mandatory measures, and is instead seeking to engage with stakeholders in order to develop a voluntary solution, something which has been rejected throughout by NRW and which now leaves anglers in Wales facing the most severe conservation legislation in the whole of the United Kingdom and Ireland and looking with envy at their colleagues across the border:
Does that not make engagement with stakeholders even more difficult than it was 6 months ago?
 
Kind regards
John Eardley
Strategy Officer – Campaign for the Protection of Welsh Fisheries

To Lesley Griffiths AM Cabinet Secretary for Energy, Planning and Rural Affairs

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

25th June 2018
Lesley Griffiths AM
Cabinet Secretary for Energy, Planning and Rural Affairs
Welsh Government
5th Floor
Tŷ Hywel
Cardiff Bay
CF99 1NA
By email to Correspondence.Lesley.Griffiths@gov.wales (for the personal attention of the Cabinet
Secretary for Energy, Planning and Rural Affairs)

Dear Minister,
You will be aware from being copied in to emails, which I sent on 30th May and 13 th June to NRW’s Executive Director for Evidence, Policy and Permitting, that the NRW Principal and Senior
Fisheries Advisors would be attending the Angling Advisory Group meeting jointly organised by the Angling Trust and the Environment Agency. The purpose of this meeting, which was held lastTuesday, was to discuss ways of increasing the numbers of salmon which are voluntarily released by anglers. I was invited to attend the meeting to provide input from an angler’s perspective in Wales and was joined by colleagues from various regions of England, all of whom have extensive experience and excellent track records in the conservation of salmon stocks. There was intense discussion throughout the meeting but most importantly a genuine feeling that progress was being made to find solutions in the current byelaw processes in England. The efforts of the Environment Agency in this process were both recognised and appreciated. A number of key points emerged during the day which you need to be made aware of:
 It was widely accepted that a dictatorial approach neither works, nor allows us to achieve shared conservation goals. Indeed, it is often counterproductive when anglers feel that their concerns go unheeded and as a result they resort to a “bloody minded” approach. Education, peer group pressure and developing a culture of “we all need to do our bit” are what have delivered results in areas where voluntary return rates are notably high.

 Anglers need to see that steps are being taken to tackle areas which are a far greater threat to the future of our migratory fish stocks than legitimate angling ever can be. To that end we do welcome the setting up of working groups on both fish eating birds and agricultural pollution here in Wales. However the irony of a voluntary solution to agricultural problems is not lost on us.
 Bridges must be built with the angling community if we are to make real progress. Along with a genuine shared approach, the language that is used to deliver the message is extremely important. It was a colleague from England who pointed out to NRW’s Principal Fisheries Advisor that his comment of “There will be no further debate” in a recent press release was a shining example of how to further alienate the angling community. We would of course add “We are prepared to make ourselves deeply unpopular” to that, although the NRW Fisheries Team have clearly delivered on that front.
2

 The rejection of a voluntary approach requires a considerable enforcement resource which the Environment Agency (and NRW) do not have.
 Proposals for England will be based upon the 2017 – 2022 river classifications and these have been upgraded to account for significant under reporting. The result of this is that the number of English rivers classified as “At Risk” has been reduced from 10 to 4. I am told that the figures for Wales have been upgraded in a similar way but until I have received the copy
promised by the NRW Fisheries Team, and had chance to scrutinise it, I am unable to comment further.
 Most crucially is that “Probably at Risk” rivers in England will not be subjected to mandatory measures. The fact that 5 of the 6 rivers moved from “At Risk” to “Probably at Risk” are located in North West England poses a very real threat to both angling clubs and angling tourism in Wales, given their proximity to both the border and large centres of population. A failure to address the legitimate concerns of anglers, the rejection of any form of voluntary solution and the relentless pursuit of the “preferred option” of a legislative approach is the very antithesis of what was seen as the way forward at the meeting. Of course, the decision on the future of both salmon and sea trout angling conservation and
angling is now out of NRW’s hands and rests with Welsh Government. Whilst this is clearly a devolved decision, it would seem unwise not to take into account what is happening in England and also fail to take advantage of shared expertise, particularly when there is both a common stock assessment and fishing licence. In any case, should a voluntary approach fail to deliver, legislation would still remain a viable, though unpopular, option. There is a real opportunity here to seize the moment and deliver a solution which would not only have far more of a sustainable element of the Sustainable Management of Natural Resources to it, but also, by empowering the fishing community, contribute greatly to the vision set out in the Well-being of Future Generations Act. Furthermore, immediate action would save more salmon in 2018, during the main runs of fish from August onwards, than allowing this current conflict to continue. It would also go a long way towards alleviating some of the damage which was highlighted in my previous
email.

We really would like to work with both Welsh Government and NRW to deliver something which the rivers of Wales deserve. Let us take the first steps down that path now.

Yours sincerley
John Eardley
Strategy Officer: Campaign for the protection of Welsh fisheries

PROPOSED NEW FISHING CONTROLS TO ADDRESS THE DECLINE IN STOCKS OF SALMON AND SOME SEA TROUT IN WALES – AN UPDATE

NRW have issues a document as titled above, the introduction of which is posted below. The full document is 13 pages long, so would have swamped the site, so if you wish to read the whole document, click on the link below.

Click on NRW update.

 

 

PROPOSED NEW FISHING CONTROLS TO ADDRESS THE DECLINE IN STOCKS OF SALMON AND SOME SEA TROUT IN WALES – AN UPDATE

 

NRW Fisheries Team.

INTRODUCTION

 

Our salmon stocks are in serious trouble, having declined to historically low levels.  The same is true of about half of our sea trout stocks.  Neither can sustain uncontrolled killing of fish, as it is essential that we ensure all fish have the chance to survive and breed.

 

This phenomenon is widespread across the North Atlantic range of salmon, and the other jurisdictions in the British Isles and beyond are each currently addressing the same issue in broadly the same way.

 

Although there are several contributory reasons to stock decline, including mortality of fish at sea and poor conditions in our rivers including unacceptable agricultural pollution incidents, it is a fundamental requirement to protect our valuable breeding resource of wild fish.

 

Although most fishermen have accepted and adapted to the urgent requirement to return the fish they catch, so that they may survive to spawn, some have not.  About a quarter of anglers do not practice so-called Catch-and Release fishing (C&R), preferring to kill the fish they catch. In more normal circumstances this would be acceptable, however the great shortfall in fish now means that currently, killing them is not sustainable.

 

To ensure the conservation of our stocks, NRW concluded that new statutory fishing controls were required.  We talked extensively to fishermen and other stakeholders during a two-year process, and this culminated in a statutory consultation in the latter half of 2017 on proposals for new fishing controls.  Our proposals are for all salmon to be returned, alive and well, to the river by rod and net fishermen, together with restrictions on methods to those commensurate with effective C&R fishing.  Similar constraints are proposed for the poorly performing sea trout stocks.

 

This note sets out the background to this.

The Minister replies to Chris's letter

Click on The minister replies to Chris’s letter below.

Chris White continues the challenge!

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

10 April 2018

 

Re: NRW fisheries bylaw proposals – request for an Inquiry

Dear Minister,

We note in your recent correspondence that you say you will be following the requirements of the Water Resources Act 1991.  We draw your attention to Schedules 2 and 26 of this Act and formally request an inquiry as the objections from the majority of the respondents to the consultation have not been withdrawn.

To date our correspondence with your office has been put on hold with no indicative time scale for you to make your decision.  In Schedule 2 of the Act it clearly states that you can only confirm or reject the proposals once all of the objections have been dealt with.  To this end all that has been received from your agency (NRW) is a request that objectors withdraw their objections based upon their technical case which is flawed.  NRW have simply dismissed our objections claiming that we have not presented any evidence; In March CPWF together with the North West Angling Trust Fisheries Consultative Committee (NWATFCC) jointly commissioned an Independent Evaluation of the rivers Classification methodology which has been used to justify the proposals (see attached report).

The findings and conclusions of this Evaluation by Consultant Statisticians are of such concern that we have requested that the Angling Trust write to NRW, EA, Cefas and NASCO requesting that the proposed 2018 measures are suspended based upon the contents of the evaluation.  In our correspondence with your office we have provided draft proposals on alternate and interim measures which will achieve better results than the proposed bylaws.  It was clear from the outset that there has been pre-determination by NRW in the outcome of the consultation; a similar situation exists in England.

Nothing in the NRW proposals will reverse the decline in salmon stocks in the short or medium or even long term as the proposals do not address the root cause of the decline, they simply disadvantage the stakeholders.   The evidence from 20 years of compulsory catch and release for spring salmon demonstrates the futility of the recommendations in achieving the desired outcome.

We would refer you to the comments made by Cefas on this issue who advised you that the proposals will have little impact but may be worth doing as there may be some improvement in the long term i.e. it is accepted by NRW that these proposals will do little or nothing to reverse the decline.

We would draw your attention that in August 2017 a public notice was placed in the London Gazette by the Welsh Government under its seal based upon the original bylaw proposals which have been subsequently amended.  We have taken legal advice concerning the publishing and formal notification in the London Gazette asking for objections whilst at the same time running a consultation i.e. were we objecting to bylaws which you had already approved or were we consulting on other options.  I would refer you to Schedule 26 and the requirement for formal notification following a consultation for a period of 28 days for objections to be lodged, this has not been complied with, there has been no opportunity to object to the amended proposals and you are not therefore in a position to approve the proposals.

The present fisheries bylaws are river specific and are to be replaced with a bylaw which covers all rivers i.e. a national Welsh fisheries regulation and not a bylaw.  I would again refer you to Schedule 26 and the need to revoke the existing bylaws before the new bylaws are enacted, I am not aware of any notice of revocation.

It is our preference to hold meaningful discussions on how salmon stocks can be conserved after all as stakeholders we know our own rivers best and are their guardians, it is not in our best interest to destroy our fish stocks as implied in the proposed NRW bylaws.

The draft interim proposals and pausing of the proposed Consultation Bylaw measures gives all parties the opportunity to engage and frame a constructive partnership approach that will conserve and benefit fish stocks, fisheries and communities for the long term.

 

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

Appeal from the Campaign for the Protection of Rural Wales Brecon & Radnor Committee

Dear Mr Eardley and Mr White

 

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES – Intensive poultry units and river pollution

 I am writing to you about a petition which the Brecon and Radnor branch of The Campaign for the Protection of Rural Wales (CPRW) have submitted to the Welsh Assembly Petitions Committee and to ask you whether you would be able to help us to achieve our goal of 5000 signatures. We have taken this action after a number of meetings with Powys County Council and Natural Resources Wales to discuss the environmental impacts of intensive poultry units, chief among these being impacts on water quality from run-off, manure storage, transport and spreading. NRW are taking steps to limit airborne pollution but are hampered by severe budget cuts. Many of the intensive poultry units applied for fall below the threshold for NRW permitting and regulation.  We have been very disappointed that Powys Council planners still show no signs of wanting to recognise any of the potential impacts of this type of development, despite expressions of concern from many local environmental bodies, and continue to pass planning applications without adequate scrutiny. We understand that similar problems are being experienced around the country.  If we can achieve 5000 signatures, the petition will be recommended for debate by the Senedd. Our hope is that a Senedd debate of the issues (including the severe cuts to Natural Resources Wales’ budget) would be a step towards improvements in planning practice and regulation.  This is a link to the petition site: https://www.assembly.wales/en/gethome/e-petitions/Pages/petitiondetail.aspx?PetitionID=1305 .  There is also an abbreviated link http://brecon-and-radnor-cprw.wales/ipu-petition . The petition is wordy, but we had to set out the issues at some length for the consideration of the Petitions Committee. We are also collecting paper petitions and I attach the paper petition form. Anyone can sign. It’s not a requirement to be resident in Wales, and anyone downstream of Welsh water pollution has a very strong interest.

We have gathered a great deal of information about the rapid expansion of the intensive poultry industry in Powys and this can be found on our website:http://www.brecon-and-radnor-cprw.wales/ I also attach a short flyer we have prepared summarising our principal concerns.  I really hope you can help us by sharing this petition with members and supporters. The petition end date is 22nd May so there is not a great deal of time left.

Please do get in touch if there is anything I haven’t explained, or any more information you need.  

Best wishes

 

 

Margaret Tregear

CPRW Brecon & Radnor Committee

01497 821668

http://www.brecon-and-radnor-cprw.wales/

 

THE VOICE OF REASON: Chris White.

President

Allan Cuthbert

7 Norton Avenue

Prestatyn

Denbighshire

LL19 7NL

 

Email: 1highplains@gmail.com

Strategy Officer

John Eardley

c/o Vanner Farm & Caravan Site

Llanelltyd

Dolgellau

Gwynedd

LL40 2HE

Email: johneardley@btinternet.com

 

Conservation Officer

Chris White

57 Normanby Drive

Connahs Quay

Flintshire

CH5 4JX

 

Email:chriswhite.cohite@gmail.com

 

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

Re: NRW fisheries bylaw proposals

Dear Minister,

Thank you for your response LG/00305/18 (21/02/2018) on my suggestion of a way forward which does not require legislation.

I am aware that your Inland Fisheries are now in possession of the NRW proposals and I have no doubt that the recommendation to you will be that to prevent further decline in salmon stocks you must legislate to provide greater protection to the present salmon stock.  However, the proposals do little or nothing to increase salmon stocks, this is just a sticking plaster to avoid dealing with the main issues, and even the NRW agree that anglers are not the problem but they neither have the staff or the funds to deal with the root causes.

It is possible to restore salmon stocks in our rivers and I will use the Conwy as an example of what can be achieved by local conservation organisations.  For over 10 years I was secretary of the Conwy Valley Fisheries & Conservation Association and was responsible for managing a stocking program for the Conwy system.  This was self funded, we could not stock on a large scale but could afford to purchase 8000 parr from the EA(W) hatchery, and these were from local broodstock donated by anglers to the stocking programme.  The broodstock were taken to the EA(W) hatchery where eggs were stripped and, once the fish recovered, they were returned to the river.  The hatchery incubated the eggs and grew on the fry until the resulting parr were big enough to be stocked into our three semi-natural rearing ponds.  The parr were protected from predators until they were ready to migrate to the sea as smolts and were not fed more than twice a week and so had to forage for their food and were consequently as fit and healthy as any wild smolts.  The Conwy is now seeing the benefit of this stocking program with electro fishing results showing the highest number of fry and parr ever recorded and yet NRW claims that the Conwy is ‘probably at risk’, however this is based on the poor recruitment in 2015 following the effects of Storm Frank which had a devastating effect on all UK rivers.  During 2016 and 2017 we have seen more salmon and increased spawning activity, so the Conwy is not actually at risk.  Similar successful schemes were carried out on other Welsh rivers such as the Dyfi. The NRW proposed bylaws are disproportionate as they are to be applied to all rivers regardless of present conditions.

The salmon season is now underway and the lack of a decision on the implementation of the NRW proposals has resulted in many anglers not renewing their club membership, the knock on effect is that clubs may not have sufficient funds to pay their rents.  A statement deferring any implementation to 2019 (as per England) would be appreciated.  This would then provide a breathing space during which alternatives to legislation can be explored in more detail.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

Another petition against the proposed rule changes

Another petition has been launched on the Welsh Government website. We do not advise doing this again because the support shown by anglers is so limited that it gives the government the impression that we are not supportive of the petitions aims. Please sign on this link because we have to get the numbers. Anglers are getting petition averse, so please NO MORE.   Click here    This petition is a pain to sign, so when you think you’ve signed, please page down and check. If and when you are successful the site will tell you.

 

The minister replies

Click on The minister replies to read it

A further letter to the minister

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

PresidentAllan Cuthbert

7 Norton Avenue

Prestatyn

Denbighshire

LL19 7NL

 

Email: 1highplains@gmail.com

Strategy OfficerJohn Eardley

c/o Vanner Farm & Caravan Site

Llanelltyd

Dolgellau

Gwynedd

LL40 2HE

Email: johneardley@btinternet.com

 

Conservation OfficerChris White

57 Normanby Drive

Connahs Quay

Flintshire

CH5 4JX

 

Email:chriswhite.cohite@gmail.com

Re: NRW fisheries bylaw proposals

Dear Minister,

Thank you for your recent response on the above issue I fully appreciate that until NRW presents their proposals you are not in a position to make any comment.  Our concern is that you will be persuaded to approve the proposals without providing the major stakeholders a chance to voice our concerns and offer a solution which does not require legislation.

It was clear from the consultation that 83% of responders opposed the proposed bylaws, the majority from North Wales as they have most to lose.

Since the NRW Board meeting on 18 January stakeholders have met from across North Wales to look for alternatives to the proposed bylaws which will provide the same or better outcome than through legislation.  If legislation is implemented it cannot be policed, local clubs on the other hand can police their own members.

As well as support from many clubs in North Wales, we have the support of several clubs from mid and South Wales, and will be in discussion with other Trusts and clubs across Wales shortly.  Having talked to, and having the support of, both the North Wales Rivers Trusts and Afonydd Cymru, we would offer the following solution.

These are our outline proposals:

  • Use the Rivers Trusts, working in co-operation with stakeholders and NRW to assess stock levels in individual river systems.  Trusts, using their local volunteers, have far better knowledge of their rivers and can obtain accurate catch returns and stock assessments from clubs.  We could then categorise our rivers as has been done in Scotland and Ireland. If rivers require additional restrictions due to low stock levels at least we would have the support of the affected clubs as we will be working in partnership with them.
  • By working with clubs we can involve the local community in assessing the state of their rivers and work with them to ensure workable conservation measures are put in place.
  • Afonydd Cymru would act as the co-ordinator for the Rivers Trusts and would liaise with NRW on technical matters.  This would be cost neutral and would go a long way to bridge the budget gap NRW fisheries are now facing.

There is still a lot of detail to be ironed out but we believe that we have basis of a workable solution without resorting to legislation.  We would be pleased to meet with you or your Environment Minister (Hanna Blythyn) to explain both our concerns and the way forward.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

CPWF has the support of freshwater and sea anglers in Wales.

Visit our website at www.cpwf.co.uk

 

Re: NRW fisheries bylaw proposals

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

 

PresidentAllan Cuthbert7 Norton AvenuePrestatynDenbighshire

LL19 7NL

 

Email: 1highplains@gmail.com

Strategy OfficerJohn Eardleyc/o Vanner Farm & Caravan SiteLlanelltydDolgellau

Gwynedd

LL40 2HE

Email: johneardley@btinternet.com

 

Conservation OfficerChris White57 Normanby DriveConnahs QuayFlintshire

CH5 4JX

 

Email:chriswhite.cohite@gmail.com

An Open Letter to Kevin Ingram (Interim Chief Executive, Natural Resources Wales) and Lesley Griffiths AM (Cabinet Secretary for Energy, Planning and Rural Affairs)

 

14th February 2018

 

Dear Sir & Madam,

 

At the NRW Board Meeting on 18th January a decision was made to apply to Welsh Government for confirmation of new fishing byelaws re fishing controls for salmon and sea trout in Wales.

Although a number of board members had major concerns that failure to work with stakeholders would result in the proposals failing to deliver their intended outcome, ultimately 2 other factors narrowly won the day:

  1. The need to be seen to support the Executive Team who have been advised by NRW Fisheries
  2. The feeling that to step back from taking a decision would be perceived as negligent, particularly in light of the bleak picture painted of salmon and sea trout stocks in the Technical Case document used to support the proposals

At the end of the meeting, in an atmosphere reminiscent of a wake, there were no fist pumping scenes of jubilation since now there were only losers; the NRW Fisheries Team who have so alienated stakeholders that their ill-conceived proposals are now unworkable, angling organisations who as well as feeling both disempowered and disenfranchised face a loss of membership, loss of income & loss of waters and, perhaps most significantly, the rivers and watercourses of Wales who have been deprived of a collaborative approach which could have delivered so much more.

 

Had we been able to present the following information to the Board we believe that the decision might have been somewhat different:

 

  1. The NASCO Implementation Plan for England and Wales states that “Compliance against the management objective (that a river must meet its Conservation Limit four years out of five) is assessed annually for each principal salmon river together with a forecast of that assessment in 5 years time.” Whilst there are rivers which are failing to meet their Conservation Limits, that is not a universal issue. In fact the Conwy, Glaslyn, Mawddach, Ogwen & Usk have all met their conservation limits and Management Objective according to the NASCO criteria.
  2. The 5 Year Forecast Projections for the last 3 verifiable periods (2009 › 2014, 2010 › 2015 and 2011 › 2016) are only 41%, 27% and 18% accurate!
  3. Table 7 on Page 49 of the NRW Technical Case Structure shows that the Management Target rather than the Conservation Limit has been used to assess stock status. The Management Target is not an applied measure in the formal Compliance procedures for Assessing Stocks. Correct applicationof the Conservation Limit would result in a very different picture for a number of Welsh rivers.
  4. Between 2010 and 2014 an average of 37.2% of anglers failed to submit a catch return. By 2017 the figure had reached 45%. It is impossible to adjust the stock status model to accurately reflect that amount of missing data.
  5. The numbers of rod caught salmon officially reported by NRW from the Rivers Wye & Dyfi over a 5 year period are significantly lower (Wye – 28.13%, Dyfi – 28.3%) than reliable figures collected by angling associations and river keepers. The addition of those numbers would have a huge impact on whether those rivers have met their Conservation Limit and Management Objective.

 

This information is at best misleading and in some areas may be open to legal challenge. In the meantime the 2 sides, despite sharing a common goal, remain as far apart as ever.

 

There is a feeling amongst the angling community that having invested so much time and so many resources in pursuit of its “preferred option” the NRW Fisheries Team has backed itself into a corner and has had no option but to continue along the same path. However, even if one has invested a great deal of time, effort and money in purchasing a battlefield tank to deal with the problem mouse behind the skirting board, that would not in itself be a justifiable reason for firing it when others have made you very much aware of the likely outcome of your actions.

 

In the meantime we have put forward an alternative solution to the Cabinet Secretary which has not only the support of angling clubs from all areas of Wales but also the North Wales Rivers Trusts and Afonydd Cymru. We believe that the proposed voluntary approach would deliver similar, if not better, results than the proposed statutory legislation and would also facilitate the delivery of River Restoration plans.

 

The current situation was brought into sharp focus by 2 events towards the end of last week. The first was reading a copy of Dr Malcolm Greenhalgh’s excellent open letter to Sir James Bevan (CEO Environment Agency), Michael Gove and Lesley Griffiths, which highlights the threat posed by changes in dairy farming practices to our aquatic ecosystems. The second was a lengthy telephone conversation that I had with Ceri Davies (NRW Executive Director for Evidence, Policy and Permitting). In a conversation that was at all times courteous and professional (there is too much mutual respect for it to be otherwise), two telling points emerged. The first is that it is in the best interests of both sides to work in a meaningful partnership. The second was the question as to whether angling organisations would be prepared to support NRW in order to increase pressure for change in those farming practices which are causing damage to the aquatic environment in Wales. Of course that type of co-operative approach is exactly what is needed but unfortunately a very large and obvious stumbling block has been placed in its path. In fact the situation would be laughable were it not so serious. Anglers want Welsh Government to side with them against NRW. NRW wants Welsh Government to side with them by imposing restrictions on anglers and NRW also wants anglers to side with them in order to put pressure on Welsh Government!

 

The road ahead is fraught with difficulties but one thing that is very clear is that it cannot be tackled by any one party in isolation. There is a choice to be made between either a collaborative approach which has the support of stakeholders and which would produce the desired results, or a heavy handed, dictatorial option which alienates the very people who NRW so much needs on its side. That decision does not rest with us but must either be made quickly or deferred, as in the meantime a number of angling clubs are already seeing a significant reduction in applications for membership as visiting and local anglers alike wait to find out just what the future holds for them in Wales.

 

Yours sincerely

 

John Eardley

 

Strategy Officer: Campaign for the protection of Welsh fisheries

CPWF has the support of freshwater and sea anglers in Wales.

Visit our website at www.cpwf.co.uk

John Eardley writes to Cabinet Minister again!

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

Llanelltyd

Dolgellau

Gwynedd

LL40 2HE

9th February 2018

Lesley Griffiths AM

Cabinet Secretary for Energy, Planning and Rural Affairs

National Assembly for Wales

Cardiff Bay

Cardiff

CF99 1NA

 By email to Correspondence.Lesley.Griffiths@gov.wales   (for the personal attention of the Cabinet Secretary for Energy, Planning and Rural Affairs)

Dear Minister,

I contacted you, along with fellow co-signatories representing anglers on the Afon Ogwen, Mawddach & Wnion, by emailed letter on 1st February to raise our concerns at the application by Natural Resources Wales to Welsh Government to introduce new byelaws re catch controls for salmon & sea trout (Letter Ref LG/00271/18).

I have spoken at some length this morning to Ceri Davies (NRW Executive Director for Evidence, Policy and Permitting) who informs me that they have now sent the papers regarding the application to your office. It would therefore be helpful if the serious concerns that we raised in our “Evidence case re NRW Stocks Assessment Technical Report” (P4 onwards) regarding the use by NRW of the Management Target, which is not an applied measure in the formal Compliance procedures for Assessing Stocksand 5 Year forward forecasts which are have declined from 41% to just 18% accuracy in the last validated periods, were considered alongside the data which has been presented by the NRW Fisheries Team.

One of the things that Ceri wanted to talk about was a joint approach by NRW and Angling Stakeholders to help tackle some of the problems associated with Agricultural Pollution. Whilst we have always been keen advocates and participants of partnership working through both our own organisations and Angling Trusts, that relationship can only break down if Welsh Government ratifies the NRW Board decision. One of my colleagues has already written to you on the 7th February (Letter Ref LG/00305/18) with a suggested way forward which would achieve a similar if not better outcome.

I would be more than happy to meet with either yourself and/or members of your team to justify the statements I have made regarding the use of data by the NRW Fisheries Team.

Yours sincerely

 

John Eardley

Strategy Officer: Campaign for the protection of Welsh fisheries

Campaign writes to the minister: again re: NRW fisheries bylaw proposals

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

PresidentAllan Cuthbert

7 Norton Avenue

Prestatyn

Denbighshire

LL19 7NL

 

Email: 1highplains@gmail.com

Strategy OfficerJohn Eardley

c/o Vanner Farm & Caravan Site

Llanelltyd

Dolgellau

Gwynedd

LL40 2HE

Email: johneardley@btinternet.com

 

Conservation OfficerChris White

57 Normanby Drive

Connahs Quay

Flintshire

CH5 4JX

 

Email:chriswhite.cohite@gmail.com

Re: NRW fisheries bylaw proposals                                                          7 February 2018

Dear Minister,

Thank you for your recent response on the above issue I fully appreciate that until NRW presents their proposals you are not in a position to make any comment.  Our concern is that you will be persuaded to approve the proposals without providing the major stakeholders a chance to voice our concerns and offer a solution which does not require legislation.

It was clear from the consultation that 83% of responders opposed the proposed bylaws, the majority from North Wales as they have most to lose.

Since the NRW Board meeting on 18 January stakeholders have met from across North Wales to look for alternatives to the proposed bylaws which will provide the same or better outcome than through legislation.  If legislation is implemented it cannot be policed, local clubs on the other hand can police their own members.

As well as support from many clubs in North Wales, we have the support of several clubs from mid and South Wales, and will be in discussion with other Trusts and clubs across Wales shortly.  Having talked to, and having the support of, both the North Wales Rivers Trusts and Afonydd Cymru, we would offer the following solution.

These are our outline proposals:

  • Use the Rivers Trusts, working in co-operation with stakeholders and NRW to assess stock levels in individual river systems.  Trusts, using their local volunteers, have far better knowledge of their rivers and can obtain accurate catch returns and stock assessments from clubs.  We could then categorise our rivers as has been done in Scotland and Ireland. If rivers require additional restrictions due to low stock levels at least we would have the support of the affected clubs as we will be working in partnership with them.
  • By working with clubs we can involve the local community in assessing the state of their rivers and work with them to ensure workable conservation measures are put in place.
  • Afonydd Cymru would act as the co-ordinator for the Rivers Trusts and would liaise with NRW on technical matters.  This would be cost neutral and would go a long way to bridge the budget gap NRW fisheries are now facing.

There is still a lot of detail to be ironed out but we believe that we have basis of a workable solution without resorting to legislation.  We would be pleased to meet with you or your Environment Minister (Hanna Blythyn) to explain both our concerns and the way forward.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

 

CPWF has the support of freshwater and sea anglers in Wales.

Visit our website at www.cpwf.co.uk