Last edit: 11th May 2022

CEO’s reply

From: CEO <ChiefExecutivesOffice@cyfoethnaturiolcymru.gov.uk>
Sent: 10 May 2022 08:42
To: Mike Ashwin <oneoffdesignandbuild@hotmail.com>
Subject: RE: NRW – Formal request – Assessment of Impact – 2020 All Wales Byelaws 

Dear Mr Ashwin,

Thank you for your letter in relation to the above dated the 09/05/2022 addressed to Clare Pillman, Chief Executive.

I can confirm that my colleagues are liaising on this matter. Your comments are being considered and a detailed reply will be sent to you in due course.

If you have any queries regarding this issue in the interim, please do not hesitate to contact us.

Many thanks,

Lauren

Lauren Hughes
Cynorthwyydd Personol i’r Cadeirydd a’r Prif Weithredwr / Personal Assistant to the Chair and Chief Executive

Cyfoeth Naturiol Cymru / Natural Resources Wales 
Swyddfa / Mobile: 07977 141346

Tŷ Cambria, Heol Casnewydd, Caerdydd, CF24 0TP

Tŷ Cambria, Newport Road, Cardiff, CF24 0TP

Request for an Assessment of the Impact of the 2020 All Wales Byelaws.

FAO Clare Pillman – CEO Natural Resources Wales,

Dear Clare,

Please receive a Formal request from PAAS Prince Albert Angling Society, CPWF Campaign for Protection of Welsh Fisheries & SFG Severn Fisheries Group with extensive waters in Wales for an Assessment of the Impact of the 2020 All Wales Byelaws.

The attached Report provides the reasons and justification for this request together with recommended criteria and metrics for quantifying the impact. 

The request is consistent with monitoring outcomes in NRW`s 2020 Salmon & sea trout Plan of Action and NASCO Guidelines for the Management of Salmon Fisheries in England & Wales.

If you would kindly respond to myself (advisor and representing PAAS, CPWF & SFG).

Further Cc. Welsh Government, DEFRA and Conservation NGO`s – Angling Trust, Fish Legal, Salmon & Trout Conservation UK, Atlantic Salmon Trust, Wild Trout Trust.

With regards,  

Mike Ashwin,

The Barn, Skirwith, Penrith, Cumbria, CA10 1RH 

Minister for Rural Affairs, North Wales and Trefnydd (via email)
15 February 2022


Conservation Officer
Chris White
57 Normanby Drive
Connahs Quay
Flintshire
CH5 4JX
Email:chriswhite.cohite@gmail.com
CPWF has the support of freshwater and sea anglers in Wales.
Visit our website at www.cpwf.co.uk

Minister for Rural Affairs, North Wales and Trefnydd (via email)
15 February 2022

Re: Releasing Beavers into the ‘Wild’: Environmental engineer or a waterway menace?

Dear Minister,
On behalf of CPWF on the 8 February one of our members (John Eardley) took part in the
Welsh Beaver Project: Consultation Workshop at which Alicia Leow-Dyke (Welsh Beaver
Project Officer with Wildlife Trusts Wales) outlined the benefits of releasing 10 pairs of Beavers
into the Dyfi Valley saying that beavers had been absent since at least the 16th century. Of
course, over the intervening 400 years population density in the valley has increased, and
changes in agricultural practices have seen rivers and streams managed.
Whilst beavers may bring some benefits to the overall ecology of rivers this should not be at
the expense of migratory fish stocks particularly as in Wales these stocks are declared as
either ‘At Risk’ or Probably at Risk’


Alicia’s presentation focused only on the positives including stating that beavers “only build
dams on smaller tributary streams when the water is not deep enough for them to swim”, the
wonderful benefits they bring to the hydrological cycle and the biodiversity of the catchment.
This statement ignores the fact that these smaller streams are the spawning and nursery
grounds for migratory fish. It should be noted that the NRW Executive and Board were told
that the ‘All Wales Bylaws’, restricting angling methods, were necessary “in order that stocks
can recover in the shortest possible time”. Introducing beavers on a river deemed to be ‘at risk’
for salmon or sea trout would be 100% counterproductive and fly in the face of the oft-quoted
Precautionary Principle. This would also make a mockery of the work at present being
undertaken by Rivers Trusts on river restoration projects funded via the Salmon Action Fund
or the Dee LIFE fund where barriers to migration are being removed.
There are claims by supporters of beaver re-introduction with respect to fisheries that:
“A wide range of evidence from Scandinavia and North America suggests that most beaver
dams are passable to salmonids most of the time and that there is no clear evidence of a
negative relationship between beaver activity and salmonids at a catchment level”.
And: “Without appropriate management there could be negative effects on salmonid migration
during dry autumns on smaller side streams with active beaver dams though this effect is likely
to be highly site-specific based upon Scandinavian and North American”.
It should be noted that this is only a ‘suggestion’ there is no harm i.e. this is opinion and not
based upon any evidence and in addition this opinion is based upon a catchment basis. You
cannot compare North American or Scandinavian River catchments with the much smaller
Welsh river catchments where the negative impacts will be significant.

t is noted in the final report of the River Otter Beaver Trial – ROBT (download link: The River
Otter Beaver Trial | Devon Wildlife Trust) that the effect of beaver dams on migratory fish was
given scant regard. In the title of this letter, I have used the heading Environmental engineer
or a waterway menace? from a paper by Dylan Roberts of the Game and Wildlife
Conservation Trust (www.gwct.org.uk ) which expresses caution on the release of beavers
into the wild.
Within the ROBT report the evidence from electrofishing above and below beaver dams clearly
shows the marked decline in salmonid juveniles above beaver dams whilst claiming fish
populations had increased, these were mainly minnows, brook lamprey etc.
Photographs in the ROBT report to demonstrate that beaver dams do not obstruct upstream
migration (in high flows) show sea trout leaping the dam which is then claimed that beaver
dams are not a barrier to upstream migration. Whilst adult migratory fish may be capable of
negotiating beaver dams, juveniles cannot pass these on their downstream migration to the
sea as there is no clear flow for them to follow i.e. water percolates through beaver dams.
It has been claimed in several papers that beavers improve fisheries as trout above beaver
dams are larger (in one report it claims these are the fish anglers want to catch!), trout are
predators so any juveniles dropping back into the impoundment caused by a beaver dam are
rapidly eaten, which is why the trout are larger, this is short lived as there are no longer suitable
spawning areas for these larger trout!
It was interesting in the ROBT report that they identified the lack of/reduction in bullheads
above beaver dams stating that this is due to bullheads requiring clean gravel and rifles to
spawn, this also applies to migratory fish who need clean gravels. There is a reference in the
ROBT report to the requirement for further studies on the effect of beavers on fisheries. The
ROBT project was only funded for 5 years which ended in 2020.
It should also be noted the need for ongoing maintenance due to beavers blocking culverts on
drainage ditches resulting in unintentional flooding of fields, roads, and properties. During the
ROBT project this maintenance work was carried out by volunteers. The ongoing burden of
damage caused by beavers will fall on riparian owners and local councils. In Scotland the
spread of beavers due to population growth is now causing issues and beavers are being
trapped and relocated, I believe the 10 pairs proposed for the Dyfi valley will be from Scotland.
There is a time and a place for the re-introduction of beavers but not at the expense of
migratory fish, who at this present time are declared by NRW to be at severe risk. The
Precautionary Principle must be applied until the long-term effects on migratory fish stocks
caused by beavers is fully understood. There must be a moratorium on the release of beavers
into the wild on Welsh Rivers until such time as there is clear evidence that our stocks of
salmon and sea trout are well on the road to recovery.
Regards


Chris White
Conservation Officer: Campaign for the protection of Welsh fisheries

CC via email:
Clare Pillman: CEO Natural Resources Wales
David Henshaw: Chairman – NRW Board
Ben Wilson: Principal fisheries officer NRW

Supermarket salmon

Where does it come from? Check this link.

https://mail.google.com/mail/u/0/?tab=wm#inbox/WhctKKXPjnQVWWldgksvJcCcthksNfqhXWMcQHjCvwBSZBVpMcxnnDghJGDWMTnvtKGPScQ

WE HAVE A PROBLEM!

. Too many vested interests but no overview that’s worth serious consideration.

  1. Natural Resources Wales (NRW), who are trying to please everybody
  2. The proliferation of Otters
  3. The introduction of Beavers
  4. Polluters.
  5. The Welsh Government.
  6. Paddlers who want access to all waters but at no cost and without responsibility

The list goes on and on and on

NRW, has dedicated and hard-working staff, but is grossly underfunded and massively understaffed and are failing. Remember the old saying? : “You can please some of the people all of the time, you can please all of the people some of the time, but you can’t please all of the people all of the time”. It seems to me that they are succeeding in very limited areas and pleasing very few. It is not good enough that they respond only to political directives. If it was not for the River Wye and wild swimmers pointing out the high levels of sewage pollution and the publicity that has subsequently ensued then little would have been planned to address the issue. This is no way to manage our rivers: they are too important.

Otters: I have nothing against otters, in fact, one of my fishing seasons was “made”, and I will never forget that time an otter stepped on my boot and its reaction when I said “Hello beautiful, what are you doing here?” The otter looked up at me, obviously surprised, before tuning and disappearing, I wished him well and thanked him for the encounter, Why do some anglers anglers curse these charming creatures? Is it because of the lack of fish in the rivers because of the water quality? Anglers feel that otters are feeding on a very limited supply of fish. There should be enough fish in our river to satisfy us both.

Beavers: It may be that beavers once roamed the thickly wooded banks of our then crystal clear rivers, and helped thin out our woodlands, However our rivers are no longer crystal clear, and our woods are now all but diapered. They may be furry, beautiful and fascinating, but our countryside has changed massively since the days when beavers roamed free, the country is no longer massively wooded. it is intensively farmed, and we need land for housing. The current re-wilding initiatives fall far short of providing suitable habitat for a growing population of beavers, their numbers would have to be seriously controlled and how would beaver culling be regarded.

Pollution: It is difficult to justify pouring untreated sewage into our rivers, except in a carefully monitored way and only in exceptional and exceeding limited and controlled circumstances. Why then is there no planning requirement for developers to pay for the expansion required to water treatment plants as a consequence of the increased load imposed on the system. This pollution will include concentrations of the chemicals we ingest as medication and then discharge into the drainage system, which is, for the greater part, unable to separate such pollutants from the waste water Why are farmers allowed to submit planning application for a 4,000 chicken production unit, that is required to comply with few regulation, when another family member submits a similar application for a unit on the same piece of land, thus avoiding the need to comply with the legal obligations imposed on the larger 80,000 bird unit. The waste products from these great numbers of birds are often spread over the land in unmonitored quantities and much ends up in the watercourses and thence to the river

The Welsh Government, is responsible for the quality of the water in our rivers. It must address the problem and discharge its obligations. It has been reported that the Welsh Government want Wales to become second only to Switzerland as the outdoor pursuit centre of Europe, perhaps we should act, regardless of damage to the environment

Pollution: It is difficult to justify pouring untreated sewage into our rivers, except in a carefully monitored way and only in exceptional and exceeding limited and controlled circumstances. Why then is there no planning requirement for developers to pay for the expansion required to water treatment plants because of the increased load imposed on the system. This pollution will include concentrations of the chemicals we ingest as medication and then discharge into the drainage system, which is, for the greater part, unable to separate such pollutants from the waste water Why are farmers allowed to submit planning application for a 4,000 chicken production unit, that is required to comply with few regulation, when another family member submits a similar application for a unit on the same piece of land, thus avoiding the need to comply with the legal obligations imposed on the larger 80,000 bird unit. The waste products from these great numbers of birds are often spread over the land in unmonitored quantities and much ends up in the watercourses and thence to the river

The Welsh Government, is responsible for the quality of the water in our rivers. It must address the problem and discharge its obligations. It has been reported that the Welsh Government want Wales to become second only to Switzerland as the outdoor pursuit centre of Europe, perhaps we should act, regardless of damage to the environment.

Paddlers who want unrestricted access to our rivers. No, I do not believe anglers should have sole access to our rivers, but paddlers should be required to have appropriate permission and pay, just as others have to. They have little awareness of their legal responsibilities about the disturbance of breeding salmonids, a fact that is ignored, for the most part, as enforcement of the requirements is non-existent.

The answer lies in the quality of our waters. Water is a necessity for the development of all life on earth, without it we could not exist, the same goes for the smallest of the invertebrates that inhabit our rivers, and they are the the foundation of all life in our rivers: no invertebrates, no fish, no life that relies on fish for it’s sustenance. We should be putting all our efforts into stopping pollution, all pollution from whatever source. Millions have been spent on the River Wye and still the salmon stocks are only a fraction of those in days past. Why? because the river suffers from pollution from any number of sources. We need to stop squabbling and spend all our available funds on anti pollution measures.

Chris White on Beavers in the wild

Minister for Rural Affairs, North Wales and Trefnydd (via email)

15 February 2022

Re: Releasing Beavers into the ‘Wild’: Environmental engineer or a waterway menace?

Dear Minister,

On behalf of CPWF on the 8 February one of our members (John Eardley) took part in the Welsh Beaver Project: Consultation Workshop at which Alicia Leow-Dyke (Welsh Beaver Project Officer with Wildlife Trusts Wales) outlined the benefits of releasing 10 pairs of Beavers into the Dyfi Valley saying that beavers had been absent since at least the 16th century.  Of course, over the intervening 400 years population density in the valley has increased, and changes in agricultural practices have seen rivers and streams managed.

Whilst beavers may bring some benefits to the overall ecology of rivers this should not be at the expense of migratory fish stocks particularly as in Wales these stocks are declared as either ‘At Risk’ or Probably at Risk’

Alicia’s presentation focused only on the positives including stating that beavers “only build dams on smaller tributary streams when the water is not deep enough for them to swim”, the wonderful benefits they bring to the hydrological cycle and the biodiversity of the catchment.  This statement ignores the fact that these smaller streams are the spawning and nursery grounds for migratory fish.  It should be noted that the NRW Executive and Board were told that the ‘All Wales Bylaws’, restricting angling methods, were necessary “in order that stocks can recover in the shortest possible time”. Introducing beavers on a river deemed to be ‘at risk’ for salmon or sea trout would be 100% counterproductive and fly in the face of the oft-quoted Precautionary Principle.  This would also make a mockery of the work at present being undertaken by Rivers Trusts on river restoration projects funded via the Salmon Action Fund or the Dee LIFE fund where barriers to migration are being removed.

There are claims by supporters of beaver re-introduction with respect to fisheries that:

“A wide range of evidence from Scandinavia and North America suggests that most beaver dams are passable to salmonids most of the time and that there is no clear evidence of a negative relationship between beaver activity and salmonids at a catchment level”.

And:   “Without appropriate management there could be negative effects on salmonid migration during dry autumns on smaller side streams with active beaver dams though this effect is likely to be highly site-specific based upon Scandinavian and North American”.

It should be noted that this is only a ‘suggestion’ there is no harm i.e. this is opinion and not based upon any evidence and in addition this opinion is based upon a catchment basis.  You cannot compare North American or Scandinavian River catchments with the much smaller Welsh river catchments where the negative impacts will be significant. 

It is noted in the final report of the River Otter Beaver Trial – ROBT (download link: The River Otter Beaver Trial | Devon Wildlife Trust) that the effect of beaver dams on migratory fish was given scant regard.  In the title of this letter, I have used the heading Environmental engineer or a waterway menace? from a paper by Dylan Roberts of the Game and Wildlife Conservation Trust (www.gwct.org.uk )  which expresses caution on the release of beavers into the wild. 

Within the ROBT report the evidence from electrofishing above and below beaver dams clearly shows the marked decline in salmonid juveniles above beaver dams whilst claiming fish populations had increased, these were mainly minnows, brook lamprey etc. 

Photographs in the ROBT report to demonstrate that beaver dams do not obstruct upstream migration (in high flows) show sea trout leaping the dam which is then claimed that beaver dams are not a barrier to upstream migration.  Whilst adult migratory fish may be capable of negotiating beaver dams, juveniles cannot pass these on their downstream migration to the sea as there is no clear flow for them to follow i.e. water percolates through beaver dams.

It has been claimed in several papers that beavers improve fisheries as trout above beaver dams are larger (in one report it claims these are the fish anglers want to catch!), trout are predators so any juveniles dropping back into the impoundment caused by a beaver dam are rapidly eaten, which is why the trout are larger, this is short lived as there are no longer suitable spawning areas for these larger trout! 

It was interesting in the ROBT report that they identified the lack of/reduction in bullheads above beaver dams stating that this is due to bullheads requiring clean gravel and rifles to spawn, this also applies to migratory fish who need clean gravels.  There is a reference in the ROBT report to the requirement for further studies on the effect of beavers on fisheries.  The ROBT project was only funded for 5 years which ended in 2020. 

It should also be noted the need for ongoing maintenance due to beavers blocking culverts on drainage ditches resulting in unintentional flooding of fields, roads, and properties.  During the ROBT project this maintenance work was carried out by volunteers. The ongoing burden of damage caused by beavers will fall on riparian owners and local councils.  In Scotland the spread of beavers due to population growth is now causing issues and beavers are being trapped and relocated, I believe the 10 pairs proposed for the Dyfi valley will be from Scotland. 

There is a time and a place for the re-introduction of beavers but not at the expense of migratory fish, who at this present time are declared by NRW to be at severe risk.  The Precautionary Principle must be applied until the long-term effects on migratory fish stocks caused by beavers is fully understood. There must be a moratorium on the release of beavers into the wild on Welsh Rivers until such time as there is clear evidence that our stocks of salmon and sea trout are well on the road to recovery.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

CC via email:

Clare Pillman: CEO Natural Resources Wales

David Henshaw: Chairman – NRW Board

Ben Wilson: Principal fisheries officer NRW

A NEW APPROACH?

Firstly I must apologise for the apparent lack of activity on this site for some time, work has been progressing on the Campaign generally, it’s this website that must appear to have been neglected. Sorry but we are now back!

No To Farmed Atlantic Salmon

You’ve probably been giving some thought to what you will put on your table this Christmas. For many, this festive line-up typically includes farmed salmon. 

However, by making this choice you are supporting an industry that endangers wild salmon and sea trout and severely compromises the integrity of both the marine and freshwater ecosystems of Scotland.
Please support our Christmas Appeal and say no to open-net salmon farming this Christmas.MAKE A DONATIONWith every donation we get one step closer to protecting wild fish from open-net salmon farming practices.

Open-net Scottish farmed salmon is not “sustainable”. It might look appealing, but in eating farmed salmon you are supporting this damaging industry and helping to fuel its expansion, to the detriment of the Scottish environment.

Will you give wild fish and the environment a break by saying no to farmed salmon, including so-called “organic” salmon?

If you haven’t added your name yet, please join us and the many others who have pledged not to buysell or eat farmed salmon this festive season. 

DR GUY MAWLE BA, MSc, PhD, FIFM, CEnv to Sir David Henshaw, Chair, NRW Board

Report: The state of the river Usk – A dying river?

FAO Sir David Henshaw, Chair, NRW Board Dr. Guy Mawle

By email only: chair.office@cyfoethnaturiolcymru.gov.uk guy.mawle@gmail.com


15 November 2021


Dear Sir David,
Report: The state of the river Usk – A dying river?


I attach for your attention a report that I have just completed on the state of the river Usk, one of
Wales’ principal rivers and designated as a Special Area of Conservation (SAC). Please note that this
report has not been commissioned but produced out of personal interest. I have known the river Usk
for over forty years and was once its Fisheries, Conservation and Recreation Officer. In recent years,
I have observed a progressive degradation in its ecology and wished to have more factual
information. This report is the result.
You will see from the one-page summary that many aspects of the ecology of the river are
deteriorating, including protected habitat and species. There is also a chapter at the end with
suggested lessons for the Usk and other rivers.
The Senedd recently declared a Nature Emergency in Wales and rivers and streams are a ‘priority
habitat’ under the Environment (Wales) Act 2016. There are also legal duties under regulations
relating to SAC rivers. Regrettably, this report clearly shows that NRW is failing to deliver the
Sustainable Management of Natural Resources on the River Usk. Furthermore, neither NRW nor
others, such as Welsh Government and the Future Generations Commissioner, seem to be fully
aware of the degradation that has taken place. This reflects, in part, the limitations of NRW’s
monitoring and reporting. For example, the State of Natural Resources Report 2020 (SoNaRR) uses
some data that are now considerably out of date and therefore misleading.
Of particular concern, is the 2020 status of the otter. As reported in SoNaRR 2020, this was the only
SAC feature in ‘favourable status’ across Wales. It is no longer, neither in the Usk SAC nor in other
SACs. The otter relies on the general health of the river so it is not surprising that its status now
reflects those of other SAC features. The Future Generations Commissioner cited the recovery of the
otter as a ‘sign of hope’ in her 2020 report. It would seem that hope could be misplaced.
It is evident to me that the current management of our rivers, under NRW, is not up to the
challenges these now face. This is not a reflection on the commitment of staff on the ground. I
acknowledge that NRW needs more resources, and this needs urgently addressing by Government. I
also appreciate that there are couple of laudable projects about to start that, I hope, will achieve
significant improvements. But whatever they achieve will not be sustained without effective
regulation by NRW which has patently been lacking. There is much more that NRW should and could
be doing especially in relation to enforcement and monitoring.
I do not believe that the title of my report “The state of the River Usk – a dying river?” overstates the
case. Therefore, urgent action is required and I am writing to you as the Chair of the NRW Board to
provide the leadership needed to address the issues I have recorded in my report.
These thoughts and the report are offered in the spirit of positive criticism. I will be sharing both this
letter and the report with others, as indicated below. Thank you for your time.
Yours sincerely


Guy Mawle, BA, MSc, PhD, FIFM, CEnv

Cc: With report
Lesley Griffiths, Minister for Rural Affairs and North Wales, and Trefnydd
Sophie Howe, Future Generations Commissioner
Audit Wales
NRW:
Prof. Steve Ormerod, Vice Chair
Clare Pillman, CEO
Steve Morgan, South East Wales Area
Jon Goldsworthy, South East Wales Area
NGOs:
Afonydd Cymru (with request to forward to Wales Environment Link members)
Wye & Usk Foundation
Gwent Wildlife Trust
Powys Wildlife Trust
Media

THE REPORT

Sign our petition to stop dolphin slaughter in the Faroe Islands

Click to go to the link

https://mail.google.com/mail/u/0/#inbox/WhctKKXHBSshjvBXNklMKmXqXkJBwHNBVWSQgTmlWjMbjddvGcglPlSLxLNnQGdGTzkBfJV

THANK YOU TO THE DAILY TELEGRAPH AND THE ANGLING TRUST

Support the Welsh Dee Trust and help the river: please.

The Welsh Dee Trust have commissioned a map of the salmon pools of the Dee. This has been compiled by Nigel Houldsworth who has completed maps of many other rivers. Beautifully illustrated and printed on quality paper each is  signed by Nigel. They cost £31 and are available from the Welsh Dee Trust shop https://www.welshdeetrust.com/shop/ All proceeds go towards restoration works on the river.

Advice on Pink salmon in Wales.

The purpose of this advice note is to ensure:

1. That all fishery stakeholders, including fishery managers, anglers and netsmen, are alert to the possibility of the return of pink salmon to Welsh rivers during 2021.

2. To ensure that fishery managers, anglers and netsmen know what to do should pink salmon be observed or captured in Wales.

Advice for anglers and netsmen

We are concerned about the state of our native Atlantic salmon stocks: this is why all  Atlantic salmon caught in Welsh waters must be returned alive and well. 

Pacific pink salmon are usually easily distinguished from Atlantic salmon, particularly when mature and in spawning condition.

·      If you are confident that you have caught a Pacific pink salmon, the fish should be humanely dispatched. Please report the capture as soon as possible to NRW on 0300 065 3000  (24 hours day) as this will enable the fish to be formally logged.

·      If you are not confident that you have caught a pink salmon, the fish should be released back to the river alive where it was captured, preferably having been photographed and later reported to NRW. This is to ensure that no Atlantic salmon are retained in error.

·      If you have found a fresh, dead pink salmon, please retain the fish is possible and report this to the Incident Hotline 0300 065 3000 (24 hours day)

Please consider distributing the briefing to your own fisheries contacts in Wales

Rivercide! Chris White's commentary

Chris White

Richard,

I am sending this to you as can you please pass this on as I don’t have the email address for the person who now looks after the Conwy.

I am not sure if you saw the telecast by George Mobiot the other night if not this is now on YouTube (RIVERCIDE with George Monbiot & Charlotte Church – YouTube) this video is 1 hour long (you can skip the end as it is just Charlotte Church singing!). 

The video focuses on the pollution on the Wye, the potential causes of this pollution and the lack of action in controlling the sources of the pollution.  Lesley Griffiths was interviewed but the head of the EA did not respond. 

Whilst the focus was on the Wye it is applicable to all of our rivers.  I raise this as from what Rich White said the Conwy below Betws is Brown which probably indicates high levels of phosphate resulting in an explosion of diatoms.  The sewage treatment plant in Betws is known to release raw and treated sewage into the Llugwy and despite the promise from Welsh Water that they would sort this out it is still happening.  If you remember I also expressed concerns about the Chicken farm at Fron Bella and the spreading of the chicken manure on land above the Afon Nugg, there are also dairy farms on the upper Conwy and overgrazing of sheep to contend with.  The recent heavy rain may well have washed the manure into the feeder streams on the upper Conwy catchment. I doubt that there is anything we can do now as the stable door was left open a long time ago allowing this type of pollution to occur and we now probably just have to watch as the Conwy slowly goes into decline.  It would be interesting if NRW could carryout regular monitoring of phosphate levels in the river or more likely we will have to buy our own monitoring equipment and supply NRW with our findings.  It would be nice to think that NRW will be proactive but I doubt this will happen, as I pointed out at the Byelaw Inquiry it is not the anglers catching fish which is the problem it is the survival from egg to smolts which is the issue I.e. the mortality of fry and parr due to pollution resulting in fewer smolts going to sea.  Sadly despite the work the Trust carries out the source of the pollution is not being effectively addressed, Lesley Griffiths explained that she had introduced legislation but this is too little too late and wont be fully implemented for three years.

Chris

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