Last update: 9th August 2018

Another letter to the Minister: well worth a read.

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

8 August 2018

Re: NRW fisheries bylaw proposals

Dear Minister,

Thank you for your response on 18 July (Your Ref: LG/01334/18) to my letter dated 10 July 2018 in which you say you are unable to meet with stakeholders at this juncture in the process and that you will keep us advised via NRW.

Unfortunately NRW has declared in a press release that there will be no further debate and we are therefore being kept in the dark on progress on this important issue.  I have written to the Chief Executive of NRW requesting a meeting to try and resolve the lack of communication; however I would draw your attention to what is happening across the border in England.

The Environment Agency, following improvements in the 2017 rod catches on many rivers, together with uplift to account for angler under reported catch returns, has updated the 2017 to 2021 river status classifications into its 2019 Byelaw proposals.  As a consequence the number of “At Risk” Rivers to which mandatory measures will be applied has dropped from 10 to 4.

Together with English anglers we funded an independent review of the statistical river classification methodology used by both NRW and EA.  This independent review raised some serious concerns on the interpretation of the data from the model being used.  An email exchange between CEFAS & NRW in July 2015 stated that: “NRW note that the current levels of exploitation are not the primary cause of the current low abundance and that the proposed measures will thus result in relatively modest increases in spawner numbers….”. In looking at the comparative NRW & EA 2017 angler declared catch returns that generate spawning stock estimates we are particularly concerned that the average under reported catch uplift applied to WelshRiver catches is 16.76% whilst for English Rivers the uplift was 31.5%. This mirrors concerns we have with NRW rod catch estimates used in comparison to the more realistic rod fisheries catch totals on a number of managed fisheries.

The 2017 and 2018 juvenile salmon surveys provide further evidence that the data being used by NRW is flawed as these are higher than the predicted numbers from the river classification model.  A number of North Wales rivers have shown above average numbers of salmon parr, with some rivers recording their “best ever” results.  Despite this, NRW prefers to take the easy option of imposing blanket restrictions on all rivers in Wales and dismisses a voluntary solution which will potentially deliver better outcomes for both our stocks and fisheries. If the proposals are introduced without giving a voluntary solution a chance it will be a travesty, particularly given that there are clear signs that a significant number of rivers are now showing a steady improvement.

There is no evidence that Catch & Release (C&R) is effective based on the National Salmon Regulations introduced in 1999.  It is therefore unlikely that the proposals put forward by NRW for a period of 10 years will not have any effect in increasing the numbers of salmon returning to our rivers.  You may be told that without the 1999 regulations things may have been much worse and that not to approve the proposals could be seen as negligent; the reality is that this is little more than speculation and cannot be substantiated.  The decline is due to many things but angling is not one of them. However, high on the list of poor recruitment is agricultural pollution and predation by fish eating birds.

It has not gone unnoticed that many of the responses from your office, although signed by you, were probably drafted by fisheries officers.

A recent request from Lynne Neagle AM about the proposed bylaws on behalf of one of her constituents to Clare Pillman (CEO of NRW) is yet another example of the reply not being written by the person who signed it.  The response to Lynne Neagle AM was designed to demonstrate that the complaint from the constituent was wrong.  The response uses inaccurate and emotional data i.e. claiming that the number of anglers ”killing all of their salmon” is 30% and yet in a recent note from NRW to members of Local Fisheries Advisory Groups it was said that there were 24% of anglers, based upon catch returns, who killed all of their salmon, this fails to recognise that these anglers may have only caught one fish.  These figures do not match the declared 80% of salmon in Wales which had been released, on some rivers the release rate is more than 90% i.e. voluntary measures can work.

I note you prefer not to legislate on agricultural pollution but prefer a co-operative approach with farmers, an option which is being denied to anglers.

You prefer to deny anglers an opportunity to meet with you or your Environment Minister in order to put forward alternatives despite the evidence that we have presented to you that the data used by NRW is flawed.  Anglers are not the root cause of the decline in fish stocks and yet you are being told by your advisors that the only way forward is to impose further restrictions on anglers.  The greatest fear amongst anglers is that you will sign off the NRW Bylaw proposals during the summer recess and in so doing avoid any debate in the Senedd from AM’s who support the anglers in their constituents.  If this is the case we will insist on an inquiry.

 

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

Representing, but not limited to the following:

 

Angling Cymru

Betws-y-Coed Fishing Club

Seiont, Gwyrfai and Llyfni Anglers’ Society

OgwenValley Angling Association

Penrhyn Fishing Club

Rhyl & District Anglers

Vale of Clwyd Anglers

Corwen & District Angling Club

Llangollen Maelor Angling Club

Dolgellau Angling Association

  Dee Fisheries Association

Federation of Clwyd Anglers

Wye Salmon Association

Bangor on Dee Angling Association

Merthyr Tydfil Angling Association

Crickhowell & District Angling Society

Usk Fishery Association

Brecon Angling Society

New Dovey Fishery Association

Prince Albert Angling Society

Wirral Game Fishing Club

 

To: Chief Executive Officer of NRW

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES                                          30 July 2018

Re: NRW fisheries bylaw proposals

Dear Ms Pillman,

The Campaign for the protection of Welsh fisheries represents, and is supported by, all angling disciplines in Wales and is a major NRW stakeholder, we write on behalf of all Welsh anglers.

At the January 2018 NRW Board meeting held in Bangor the proposed bylaws were presented to the NRW Board for approval.  Although we had requested the opportunity to explain our concerns to board members ahead of any discussion, this was refused and we had to resort to speaking to a few members during the short lunch break, the majority of them subsequently speaking up on our behalf during the ensuing presentation.

When the Board reconvened after the lunch break the Chair (Diane McCrea) announced to the Board that, whilst the Board members may contribute to the discussions on the proposals, there would be no vote and she would have the final say.

The general feeling from the Board members was that further time should be given for the NRW fisheries team to meet with stakeholders and look for alternatives.  It was surprising that, despite the overwhelming feeling of the Board who felt that further discussion with stakeholders should take place, the Chair sided with the management team and approved the bylaw proposals, hardly democracy in action.   However, as a concession it was agreed by the Board that there had been a clear failure to properly engage with stakeholders and immediate steps should be taken to put this right.  We are now six months on and nothing has happened. In fact the NRW fisheries officers made a press statement following the announcement of the deferment of the bylaw proposals until 2019 in which they said “there would be no further debate” and “we are prepared to make ourselves unpopular” when referring to the bylaw proposals

The failure of NRW to engage with stakeholders was clearly recognised by the Petitions Committee on 3rd July during their consideration of two petitions from angling organisations.

The decline in migratory fish stocks is not disputed, this has been ongoing for over 20 years, but little or no effective action has been undertaken by the predecessor agencies to NRW to reverse this decline.  The introduction of the National Salmon Regulation in 1999 made it mandatory for anglers to return all salmon caught prior to 16 June (coupled with method restrictions) for a period of 10 years in order to protect the stock of ‘spring’ salmon.  This measure has been extended for a further 10 years as it has had little or no effect in reducing the decline in salmon but has had a marked effect on the numbers of anglers fishing prior to 16 June.

We now see NRW wanting to extend the National Salmon restrictions beyond 16 June, for a minimum period of 10 years, and to introduce more severe method restrictions on all Welsh rivers.  If introduced, the proposals will inevitably severely impact the number of anglers salmon fishing in Wales.  Several Welsh clubs have already seen their membership decline by 20-25% due to the uncertainty of the effects of the proposed bylaws.   Perhaps more significantly, there has been a decline of up to 75% in volunteers who carry out habitat improvement and maintenance work that is vital to the future survival of our fisheries. This demonstrates that NRW has lost the support of its stakeholders due to its failure to engage with or listen to them.

We have requested meetings with the Cabinet Secretary (Lesley Griffiths) or her Environment Minister (Hannah Blythyn) to put forward voluntary solutions which we believe would be more effective, only to be repeatedly told that she is unable to meet with stakeholders but will keep us informed of progress via NRW. Consequently, we still don’t know what is happening and the damage to our fisheries, and the rural economies which they support, continues.

I note in your blog when you took over as Chief Executive of NRW that you say:

“….To do that we need to take people with us – customers, stakeholders, politicians, decision-makers and the people of Wales.   I look forward to meeting them, hearing their views, and working with them over the coming years to make sure that we hand on the environment of Wales in the best possible condition to our children and grandchildren”.

On behalf of stakeholders I would therefore request a meeting with you in order to present alternatives which, although they potentially deliver better outcomes for both our fish stocks and fisheries, have been consistently rejected by the senior NRW Fisheries Team in their relentless pursuit of legislative approach.

 

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

 

Representing, but not limited to, the following major stakeholders who fish Welsh rivers:

 

Angling Cymru

Betws-y-Coed Fishing Club

Seiont, Gwyrfai and Llyfni Anglers’ Society

OgwenValley Angling Association

Penrhyn Fishing Club

Rhyl & District Anglers

Vale of Clwyd Anglers

Corwen & District Angling Club

Llangollen Maelor Angling Club

Dolgellau Angling Association

Dee Fisheries Association

Federation of Clwyd Anglers

Wye Salmon Association

Bangor on Dee Angling Association

Merthyr Tydfil Angling Association

Crickhowell & District Angling Society

Brecon Angling Society

New Dovey Fishery Association

Prince Albert Angling Society

Wirral Game Fishing Club

Janet Finch-Saunders AM. Thanks for your support during Petitions Committee discussions on 3rd July.

CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

29th July 2018

Additional information in support of the petition “Save Salmon & Sea Trout & Fishing Clubs in Wales” started by Reuben Woodford

Dear Janet,

Having watched the footage from the Senedd TV on 3rd July, when the 2 petitions opposing NRW’s proposed introduction of new Catch Controls for salmon and sea trout were discussed by the Petitions Committee, I wish to express my gratitude for the support that you and your fellow committee members showed for the angling community in Wales. I have been involved in challenging NRW’s proposals for more than 3 years and have worked closely with Chris White and Reuben Woodford in order to represent our fellow anglers. For the first time we feel that someone is not only listening to, but also making a genuine effort to understand, our concerns so once again thank you.

The following points may be helpful in highlighting some of our concerns.

A fair hearing for stakeholders?

  • We first became aware of the proposals at the NRW Board Meeting in July 2015. Having contacted the then chairman, Peter Matthews, in advance of the meeting, we were grateful that he took the decision to move the agenda item until after the coffee break so that we had the opportunity to speak to board members prior to the issue being discussed. Without that we would have had no opportunity to raise our initial concerns. In closing the discussion the chairman stated that he “hoped that their aims could be achieved without resorting to statutory legislation”. Unfortunately for our fisheries, the NRW Fisheries Team chose to ignore that request.
  • NRW held meetings with angling groups in November 2015 and October 2017 and circulated a questionnaire in December 2015. The final consultation ended in November 2017 with 83% of respondents opposing the proposals. Despite NRW’s Principal and Senior Fisheries Advisors admitting that we know our own rivers better than they do, they have repeatedly dismissed our concerns and at no stage do we ever feel that we have been listened to. Instead, the NRW Fisheries Team has relentlessly pursued its “Preferred Option” of statutory legislation.
  • We asked to be able to briefly raise our concerns to Board Members in advance of discussion at the January 2018 Board Meeting but that request was denied. Those Board Members who we were able to address informally during the short lunch break spoke up on our behalf. We were also extremely concerned that the Chair, Diane McCrea, decided that there would be no vote on the proposals and she alone would make the decision.
  • At the end of the Board Meeting there was much talk of how “we have failed to engage with stakeholders” and must take immediate steps to put this right. Six months later we are still waiting.
  • All of our correspondence with both the Cabinet Secretary for Energy, Planning & Rural Affairs and the Minister for Environment has been acknowledged but we have repeatedly been denied the opportunity of a meeting to explain our concerns. Siân Gwenllian AM was also denied a meeting with the Cabinet Secretary to raise stakeholders concerns following a public meeting of angling groups.
  • The NRW Senior Fisheries Advisor has stated that all of our correspondence to the Cabinet Secretary is diverted to Jeremy Frost at Inland Fisheries Strategy who responds on her behalf. We have serious concerns in this respect given that Jeremy was involved with NRW and CEFAS in the construction of the Technical Case for the new byelaws. We are not confident of an unbiased response.

Fundamental errors

  • An email between CEFAS & NRW in July 2015 contains the following quote: NRW note that the current levels of exploitation are not the primary cause of the current low abundance and that the proposed measures will thus result in relatively modest increases in spawner numbers….”  In other words the proposed measures will not deliver the results that NRW claim, particularly when anglers already release upwards of 80% of their fish anyway.

NRW has also failed to realise that it is the people who have driven the conservation agenda within their own clubs and organisations who are so opposed to these proposals because they realise that the potential gains will be far outweighed by the losses incurred by driving anglers away from the riverbank.

  • The statement that “NRW has a responsibility – on behalf of the people and environment of Wales, including our angling community, to act as custodians for our rivers and fish. By acting now we are taking the first steps in ensuring their survival for our children and beyond” does not stand close scrutiny. If NRW, and their predecessors, had worked in partnership with stakeholders and acted to protect fish stocks in the past, the current situation might have been avoided. Instead, angling organisations have worked independently to introduce, and police, their own conservation measures

Furthermore emasculating angling clubs will mean that the skills and enjoyment of angling will not be passed on to our “children and beyond”.

  • “Probably at Risk” rivers in England will not be subjected to mandatory measures. The same response in Wales would remove 12 rivers from the current proposals.

Furthermore, unlike Scotland and Ireland, which annually assess the health of individual rivers, reflecting fluctuating stocks in a reasonably accurate and fair process, NRW is proposing a blanket ban on all rivers for ten years. This extinguishes all hope amongst anglers and drives people away from the sport. NRW says it has “looked at similar actions taken elsewhere” but fails to explain why the Scottish or Irish model is unsuitable in Wales.

  • We have proposed a voluntary solution which potentially delivers better results in terms of allowing more salmon and sea trout to spawn and pays far greater attention to the need to establish a sustainable and resilient framework that supports the SMNR policy. By empowering anglers, our solution delivers much better outcomes for the Well-being of Future Generations Act and offers a means of delivering progressive, positive actions in partnership, something the new Chair of NRW has stated must happen to achieve future outcomes.
  • NRW’s technical case structure sates that “We believe that any decline in uptake of fishing will be small and transient, and that this should be acceptable to the overall fishing community as an investment for future stock improvements.” The strategy is heavily based on the Wye, a river which is very different to other rivers in Wales as well as having in excess of £1million per annum spent on habitat improvement for the last 12 years

NRW’s actions are already having a significant impact in 2018 on both our fisheries and the angling tourism which they support. A number of clubs have seen a drop in membership of 20% -25%, whilst others that previously had waiting lists for membership now have vacancies. More significantly some clubs have seen the numbers of volunteers for Working Parties fall by up to 75%. Without these volunteers habitat improvement and maintenance work, which is vital for the future survival of our fisheries, cannot be carried out.

If new byelaws are implemented without stakeholders’ concerns being heard first hand by someone other than the NRW Fisheries team, Welsh Government will have presided over a situation that is not appropriate for a 21st century western democracy. To that end we seek representation at any discussion that takes place between the Petitions Committee and Natural Resources Wales.

 

Yours sincerely

 

John Eardley

Strategy Officer – Campaign for the Protection of Welsh Fisheries

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