Last update: 12th October 2019

Dear Ms Pillman,

12th October 2019

Clare Pillman – Chief Executive, Natural Resources Wales By email to Clare.Pillman@cyfoethnaturiolcymru.gov.uk

Dear Ms Pillman,

Thank you for your letter Ref: CX19-187 dated 8th October. Whilst your response makes further correspondence seem rather futile there are nevertheless certain points that cannot go unchallenged.

There has been a clear failure on the part of NRW to recognise that a voluntary solution is a realistic and sustainable solution to any threat to our salmon stocks. That option has never been discussed in any meaningful way and is conspicuous by its absence in any of the board papers leading to the byelaws decision. You will also be aware from other correspondence that there is considerable variation in stocks of both salmon and sea trout across Wales. The picture is not one of universal decline.

You refer to the “urgency of the situation in which we now find ourselves” yet the reality is that the situation is already being dealt with voluntarily. Analysis of the recently released “Salmonid and Freshwater Fisheries Statistics for England and Wales, 2018”, produced jointly by NRW & EA, reveals that the voluntary release rate has risen yet again and now stands at 88% across Wales. Furthermore 100% of the salmon were voluntarily released on 8 of the 22 principal salmon rivers with a further 2, Dee (94%) and Conwy (91%), being fully compliant with NASCO Policy.

Most significantly you state that those anglers who release all of the fish they catch “will note little difference under the new regime”. This is not true. A significant number of anglers, local and visiting alike, no longer fish when Mandatory Catch & Release is introduced and as a result clubs lose both members and revenue. As a result they can no longer afford to rent some of their waters and those who wish to continue fishing “under the new regime” are denied access. The very future of smaller community based angling clubs is under threat.

Unless the above issues are recognised and addressed there is little prospect of constructive dialogue. Yours sincerely

John Eardley – Strategy Officer, Campaign for the Protection of Welsh Fisheries

Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group

Mervyn Williams – Chair, Dee Local Fisheries Advisory Group

On behalf of:

Bangor on Dee Salmon Angling Association

Campaign for the Protection of Welsh Fisheries

Capenhurst Angling Club

Chirk Syndicate

Clwyd Federation of Angling Clubs

Corwen and District Angling Club

Dee Fisheries Association

Dolgellau Angling Association

Dolwyddelan Angling Association

Llanbrynmair Angling Association

Llangollen Maelor Angling

Llyn Guides

New Dovey Fishery Association (1929) Ltd

Ogwen Valley Angling Association

Penrhyn Fishing Club

Prince Albert Angling Society

Rhagatt Estate

Rhyl & St. Asaph Angling Association

Rossett and Gresford Fly Fishers

Seiont Gwyrfai & Llyfni Fishing Society

Vale of Clwyd Angling Club

Wirral Game Fishing Club

A note from our Conservation Officer

All,

I have just received the NRW Board paper on FEB’s, don’t hold your breath on any meaningful action on FEB’s!  There is no acknowledgement that goosanders were not a native British bird and were not recorded on Welsh rivers until the 1970’s.  Whilst goosander did overwinter on the East Coast of Scotland they are now present on all UK rivers as overwintered birds stayed on Scottish rivers and started to breed.  Looking at the numbers in the report with 1300 pairs of overwinter birds (3 months?) assuming they eat 400gm of fish per day then in 3 months between them they would potentially consume circa 1 Tonne of fish much of which in Wales will be made up of salmonids.  Feel free to circulate to your members.

Chris

REPLY FROM CLARE PILLMAN

Ein cyf/Our ref: CX19-187 Your Ref:

Ty Cambria / Cambria House

29 Heol Casnewydd / 29 Newport Road Caerdydd / Cardiff

CF24 0TP / CF24 0TP

Ebost/Email: Chiefexecutivesoffice@cyfoethnaturiolcymru.gov.uk Chiefexecutivesoffice@naturalresourceswales.gov.uk

John Eardley

c/o Vanner Farm & Caravan Site Llanelltyd

Dolgellau Gwynedd LL40 2HE

E-mail: johneardley@btinternet.com

08 October 2019 Dear Mr Eardley,

Re. Your correspondence of 27th September 2019

Ffôn/Phone: 0300 065 4453

Thank you for your letter of 27th September, received by e-mail. I am aware that you have corresponded with NRW and the Minister on the same subject on several occasions recently. In responding I am not repeating our responses to the matters that you have already brought to my attention.

It is worth repeating that Wales is facing the most substantial threat yet to the future of our salmon populations, and it appears that the same worrying trend is becoming apparent for sea trout. I note the same appears to be true in many other countries. You express your concern that the management response in Wales appears harsher than that elsewhere in the British Isles, however I understand that Ireland has elected to close rivers to fishing and that statutory C&R fishing applies in many rivers in Scotland and England. The more flexible approach in Scotland and Ireland to which you refer is known to us and, as you are aware, is an area that we are exploring with the Environment Agency. We are clear however that the measures now confirmed by the Minister are necessary, proportionate and reasonable in view of the salmon and sea trout stocks throughout Wales.

I am genuinely sorry that you see little point in future engagement with NRW on the difficult matters surrounding our salmon and sea trout. This is a formative time and, as you will know, the Minister is ensuring not only that her staff engage fully in the process leading to a plan of action but has also encouraged engagement by all stakeholders.

I welcome the fact that most anglers across Wales release the fish they catch – either voluntarily or following the requirements of existing Byelaws. These anglers will note little

Tŷ Cambria · 29 Heol Casnewydd · Caerdydd · CF24 0TP Cambria House · 29 Newport Road · Cardiff · CF24 0TP

difference under the new regime, however those who have declined to follow the practice will now be required to do so. This will provide certainty for all of what is required. NASCO guidelines that encourage one years’ voluntary C&R prior to any mandatory measures have been complied with, as has their encouragement to adopt their ‘precautionary approach’ to salmon management.

I do not support your request for support of a deferral of the byelaws, because of the urgency of the situation in which we now find ourselves. However, this would be a matter for the Minister.

Finally, I will be at the meeting of the Dee and Clwyd LFG on 4th December, and I hope to be able to welcome you to that event.

Yours sincerely

Clare Pillman

Prif Weithredwr, Cyfoeth Naturiol Cymru Chief Executive, Natural Resources Wales

Dear Ms Pillman,

27th September 2019

Clare Pillman

Chief Executive, Natural Resources Wales Ty Cambria

29 Newport Road Cardiff

CF24 0TP

By email to Clare.Pillman@cyfoethnaturiolcymru.gov.uk

Dear Ms Pillman,

Having been one of the recipients of our letter to the NRW Board dated 16th September 2019, as well as being copied in to both today’s letter to the Minister for Environment, Energy and Rural Affairs and recent correspondence from the Minister to CPWF1, you will be fully aware of the frustration and anger expressed by Angling Stakeholders from both the Dee and Gwynedd Local LFGs2 and which was so apparent at our meeting in Corwen on 7th September.

Whilst we appreciate that you will be taking the time and trouble to address a joint meeting of the Dee and Gwynedd Local LFGs on the 4th December, that is far too late in the day to effect meaningful change and on that basis there is a very real risk that a significant number of angling representatives will see little point in bothering to attend.

In addition to the information contained in both our letter to the NRW Board and today’s correspondence to the Minister, we would wish to draw your attention to the following serious concerns:

  1. At the NRW Board Meeting held at Canolfan Cae Cymro, Clawdd Newydd on 9th July 2015 the Chair, Prof Peter Matthews, closed discussion on “management options to address the decline in stocks of salmon and some sea trout in wales” by stating that he hoped their aims “could be achieved without resorting to statutory legislation”. Despite that there has never been any attempt whatsoever to work with us in order to develop a collective and resilient voluntary solution.
  2. NASCO3 International (North Atlantic) Conservation Policy and common Wales & England National Policy has not been followed leading to very different outcomes on either side of the border despite having legally binding common policy and sharing the same shared stock assessment methodology.
  3. Anglers in Wales now face the harshest conservation measures in the British Isles with the prospect of Byelaws lasting for a 10 year period whilst our counterparts in England have been offered the opportunity of a Voluntary Solution as a result of the Environment Agency’s correct application of NASCO Policy. In both Scotland and Ireland annual reviews provide a much more flexible and reasonable approach which, unlike Wales, do not extinguish all hope.

1 Campaign for the Protection of Welsh Fisheries

2 Local Fisheries Groups

3 North Atlantic Salmon Conservation Organisation

  • The legitimate concerns that have been raised by those of us with great knowledge and experience of not only our own waters but also the attitude and behaviour of our members have been dismissed. These include:
    • Many anglers choose to cease fishing when Mandatory C&R4 is introduced
    • The Byelaws cannot be effectively policed. Despite Board Paper NRW B B 40.15 identifying a “Potential need to re-direct or increase fisheries enforcement resources to enforce any new regulation” the 16.25 FTE5 Enforcement Officers have been reorganised into 10 teams.
    • There is a very real threat to the existence of angling clubs brought about by NRW’s Approach. Those most at risk here are the smaller community based clubs who cannot afford to rent waters as their membership declines
    • There is a serious risk to recruit volunteers to participate in habitat improvement work through the Rivers Trusts
  • What are regarded by Senior Fisheries staff as evidence of having “listened to anglers” and made concessions, namely allowing the use of a single worm for sea trout and the use of a shrimp after 1st September, are in fact clumsy and ill-conceived attempts to ensure that the byelaws are implemented. The following correspondence from Heidi Stone , EA6 National Salmon Programme Manager, takes a very different line:

“The fishing restriction byelaw was withdrawn. We took a very close look at all of the responses we received back and I made the call that, although the intention was sound, the delivery was flawed. To prohibit flying Cs and other methods was impossible to set out legally. The intention to fish with care and empathy cannot be set out in a byelaw and, we have made the decision to proceed with improving angler handling, equipment, methods and (I hope) the ultimate safe release of salmon through codes of practice”.

  • NRW has chosen to adopt a confrontational approach which is entirely counterproductive.
  • NRW chose to instruct Counsel to act in a way which caused untold damage to any future working relationship with angling stakeholders. The following quote from Mark Lloyd, former Chief Executive of the Angling Trust & Fish Legal and a key supporter of a voluntary solution makes that very clear:

“The barrister employed by NRW has been consistently aggressive and patronising to witnesses, the majority of whom represent community angling groups and all of whom have the best interests of fish and fishing in the forefront of their minds. We have been treated like criminals and belittled by the barrister. This has caused many of us significant distress.”

  • Those of us who have worked in partnership with both NRW in so many ways including collecting broodstock, planting out fry and parr, spraying invasive weeds, surveying feeder streams etc. feel that our efforts count for nothing. That threatens future cooperation.
  • Dr Guy Mawle, much quoted at the Inquiry by NRW’s Principal Fisheries Advisor as an experienced EA Fisheries Officer, hardly makes a convincing case for statutory legislation “The byelaws are therefore unlikely to achieve very much on their own to protect and improve the stock”.
  • When there has been constant rebuttal of our knowledge and evidence throughout the past 4 years it is difficult for many of us to see why it should suddenly be such a vital component of a “Salmon and Sea Trout Plan of Action”

We recognise that you have inherited a very difficult situation that has not been of your making. However we cannot move forward until our concerns have been addressed. Those represented by this letter have been at the forefront of salmon conservation within their own organisations and without their participation a worthwhile “Salmon and Sea Trout Plan of Action” is less likely to become a reality.

4 Catch & Release

5 Full-time equivalent

6 Environment Agency

For you to support a deferral of the byelaws whilst a voluntary solution, fully compliant with NASCO policy, is implemented for a 12 month period would send a very clear message to angling stakeholders and help unlock the current impasse.

There is nothing to lose and everything to gain and we look forward to your response.

We would of course welcome the opportunity to discuss this with you in a face to face meeting in the near future.

Yours sincerely

John Eardley – Strategy Officer, Campaign for the Protection of Welsh Fisheries

Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group

Mervyn Williams – Chair, Dee Local Fisheries Advisory Group

On behalf of:

Bangor on Dee Salmon Angling Association

Campaign for the Protection of Welsh Fisheries

Capenhurst Angling Club

Chirk Syndicate

Clwyd Federation of Angling Clubs

Corwen and District Angling Club

Dee Fisheries Association

Dolgellau Angling Association

Dolwyddelan Angling Association

Llanbrynmair Angling Association

Llangollen Maelor Angling

Llyn Guides

New Dovey Fishery Association (1929) Ltd

Ogwen Valley Angling Association

Penrhyn Fishing Club

Prince Albert Angling Society

Rhagatt Estate

Rhyl & St. Asaph Angling Association

Rossett and Gresford Fly Fishers

Seiont Gwyrfai & Llyfni Fishing Society

Vale of Clwyd Angling Club

Wirral Game Fishing Club

To Lesley Griffiths AM from John Eardley

27th September 2019

Lesley Griffiths AM

Minister for Environment, Energy 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 Minister for Environment, Energy and Rural Affairs)

Copies to:

Rt Hon Mark Drakeford AM (First Minister of Wales) Clare Pillman (Chief Executive, Natural Resources Wales)

Dear Minister,

We wish to make you aware of the serious concerns that were raised at a meeting of angling representatives from the Dee and Gwynedd Local Fisheries Groups held at the Owain Glyndwr Hotel, Corwen on Saturday 7th September. There were 19 Fishing Clubs/Organisations present at this meeting with a combined membership of several thousand anglers.

The meeting was called as a result of the anger and frustration that has arisen following your decision to confirm Natural Resources Wales’ (NRW) proposed Wales Rod and Line (Salmon and Sea Trout) Byelaws 2017.

Those present at the Corwen Meeting are respected figures within both their own organisations and the angling community in North Wales and beyond, having extensive knowledge of their own rivers and an exemplary track record in working in partnership with both NRW and their predecessors, Environment Agency Wales. That such people are talking in terms of militant action and civil disobedience should be a great cause for concern.

At the close of the NRW Board Meeting on 18th January 2018 there was clear recognition by both the NRW executive and NRW board members that “we have failed to engage with stakeholders”. Unfortunately events at the Inquiry into the All Wales Byelaws during January and March of this year when Counsel for NRW saw fit to attempt to discredit ordinary decent people who sought only to protect their own fisheries from NRW’s actions has plunged that already fractured relationship to new depths. The end result is that there are a number of angling clubs who will no longer engage in any future meetings with NRW whilst their concerns are treated in such a dismissive way and that in turn poses a real threat to the development of a “Salmon and Sea Trout Plan of Action” that you have asked NRW to take the lead on.

A number of the angling clubs present at the Corwen meeting reported that they will no longer instruct their bailiffs to check that their members have purchased a rod licence and will only enforce their own clubs’ rules. Further concerns related to the decline in the number of both local and visiting anglers despite the encouraging

numbers of both salmon and sea trout that have been observed in some of our rivers this year despite the statistical predictions made by NRW. This will have repercussions on the ability of smaller community based clubs to afford to rent waters in the future and be a threat to their very existence. The presence of anglers on the riverbank also acts as both a deterrent to poachers and a source of intelligence for NRW’s Enforcement Officers and it is therefore unsurprising that increasing illegal activity has been a major concern for us during the year.

The alienation of those very stakeholders whose knowledge of their own rivers is so necessary for their recovery is a great cause for concern for those of us who are actively involved with both Rivers Trusts in North Wales. NRW may recognise that “we have able partners in the rivers trusts and need to maintain a productive relationship with them” but is making it ever more difficult for those organisations to recruit volunteers.

However our greatest concerns are reserved for these 3 key issues:

1.               Confirmation of the The Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019 would be a clear contravention of NASCO1 policy.

Full supporting evidence is listed in Appendix 1 on P4

2.               The confirmation of the All Wales Byelaws for introduction on 1st January 2020 for all rivers in Wales which have a mean catch of less than 20 salmon is a clear contravention of NASCO policy

Full supporting evidence is listed in Appendix 2 on P5

3.               We make a formal request that the introduction of the All Wales Byelaws is deferred until such time as voluntary C&R has been promoted for 1 year as set out in the NASCO Decision Making Structure.

Full supporting evidence is listed in Appendix 3 on Ps 6&7

The witness presenting key evidence at the Inquiry re NASCO Policy on behalf of CPWF2 was repeatedly interrupted by both Counsel for NRW and the Inspector himself which may go some way towards explaining the failure by the Inspector to recognise that the NRW proposals were breaching their own national and NASCO International Decision Structure Policy in England & Wales

The result is that following the Inspector’s decision and, in spite of having both common NASCO Policy and shared Stock Assessment Methodology, we now have two opposing conservation strategies with England adopting NASCO and shared E & W policy with Voluntary measures being applied to PaR3 rivers while in Wales the Byelaws propose Mandatory measures for all rivers.

Whilst we appreciate that Brexit may be a far more pressing issue for you at the moment, the issues surrounding the Byelaws have been a major concern for us since July 2015 and are posing a significant threat to our fisheries, the survival of community based angling clubs and angling tourism in rural areas. To that end a “no deal” outcome for angling must be avoided at all costs, particularly when there is no evidence that the Byelaws will do anything to increase the numbers of salmon and sea trout returning to our rivers.

Our track record of partnership and co-operation makes us fully deserving of the chance of a voluntary solution. Irrespective of that, the promotion of Voluntary C&R is a key part of compliance with NASCO Policy and cannot be dismissed.

1 North Atlantic Salmon Conservation Organisation

2 Campaign for the Protection of Welsh Fisheries

3 Probably at Risk

This has not happened up to now and therefore should be widely publicised to all anglers and clubs for the 2020 season, with the target 90% release rate made absolutely clear and the warning that “If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered”.

This should be the starting point for the “Salmon and Sea Trout Plan of Action” in 2020 and would play a key role in encouraging key stakeholders to participate in its development.

We cannot stress strongly enough that we have always endeavoured to work with NRW and really do want that to continue. However for that to happen bridges must be built and most significantly the 3 key issues identified on Page 2 must be addressed.

We would of course welcome the opportunity to discuss the contents of our letter with you in a face to face meeting but in the meantime await your response with interest.

Yours sincerely

John Eardley – Strategy Officer, Campaign for the Protection of Welsh Fisheries

Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group

Mervyn Williams – Chair, Dee Local Fisheries Advisory Group

On behalf of:

Bangor on Dee Salmon Angling Association

Campaign for the Protection of Welsh Fisheries

Capenhurst Angling Club

Chirk Syndicate

Clwyd Federation of Angling Clubs

Corwen and District Angling Club

Dee Fisheries Association

Dolgellau Angling Association

Dolwyddelan Angling Association

Llanbrynmair Angling Association

Llangollen Maelor Angling

Llyn Guides

New Dovey Fishery Association (1929) Ltd

Ogwen Valley Angling Association

Penrhyn Fishing Club

Prince Albert Angling Society Rhagatt Estate

Rhyl & St. Asaph Angling Association

Rossett and Gresford Fly Fishers

Seiont Gwyrfai & Llyfni Fishing Society

Vale of Clwyd Angling Club

Wirral Game Fishing Club

Appendix 1

Confirmation of the The Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019 would be a clear contravention of NASCO policy

  1. NRW have indicated at their Board meeting held on 19th September that they will shortly be making an application to you for confirmation of new rod fishing byelaws for the rivers Dee and Wye. Confirmation of those byelaws would breach NASCO Conservation Policy.
  1. Wales, along with other countries as signatures to NASCO Conservation Policy, adopted this in Regulatory undertakings as common and shared Wales & England Atlantic salmon management policy. This is defined in the 2018 Assessment of Salmon Stocks & Fisheries in England & Wales (Background Report) Annexe 7 – Salmon Management Procedures in England & Wales, Page 77 & 78 – Decision Structure in E & W.
  2. The decision making structure set out in the report is very clear:

3. Third stage – option evaluation (purple boxes)

The purpose of this stage is to set out and evaluate options to realise the required changes in exploitation.

For rivers where 50%≤p<95% (where p= probability of failing the management objective) and the trend is down and with an annual catch of >20 salmon and C&R4 rate < 90%, then voluntary C&R will promoted for 1 year. If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered. Protected rivers such as SACs (Special Areas of Conservation) are given particular emphasis”

  1. This is recognised in NRW Board Paper B B 40.15 Annex 2, TECHNICAL REPORT: MANAGEMENT OPTIONS TO ADDRESS THE DECLINE IN STOCKS OF SALMON AND SOME SEA TROUT IN WALES which states quite correctly that:

The decision structure is currently not applied to:-

  • rivers where the voluntary C&R rate is greater than 90%, as it has been felt that the extra benefit on any individual river does not warrant the costs of pursuing statutory control.
  • The 5 year forward predicted Compliance for the Dee has improved in 2018. Whereas in 2017 it was predicted to be AR5 in 2022 it is now predicted to be PaR in 2013. The stock assessment has changed and therefore Voluntary 90% C & R is the correct application of the NASCO decision structure
  • NRW’s 2017 “Know your river document” for the Dee makes the following statement:

“The release rate in 2017 was 91%. This is an excellent result and needs to be maintained”

Put simply the River Dee is fully compliant with NASCO policy and according to NRW’s own documentation “does not warrant the costs of pursuing statutory control”.

On that basis the introduction of statutory legislation for the Dee would be a clear breach of NASCO policy and something that we would contest most strongly. We would also have the support of our English colleagues who will mount a similar challenge to the EA given that NRW states that “It has previously been agreed with the EA that they will make a simultaneous matching application to DEFRA for confirmation of complementary byelaws in the English parts of these two cross-border rivers”.

We therefore make a formal request that you do not confirm any application by NRW for new byelaws for the Dee.

4 Catch & Release

5 At Risk

Appendix 2

The confirmation of the All Wales Byelaws for introduction on 1st January 2020 for all rivers in Wales which have a mean catch of less than 20 salmon is a clear contravention of NASCO policy

In addition to that aspect of the decision structure described Appendix 1 iii on Page 4, the 3rd stage of the decision structure also states:

“For rivers where the above criteria apply, except that the annual mean salmon catch is <20 salmon, voluntary measures will be promoted.”

In North Wales that would include not only smaller rivers such as the Afon Aber, Gwyrfai, Llyfni, Artro etc but also at least one of the principal salmon rivers, the Afon Dysynni.

NRW’s 2017 “Know your river document” for the Dysynni makes the following statement:

“….the river is predominantly a sea trout river. The release rate in 2017 was 100% which is an excellent result and needs to continue”.

It is quite clear that to apply the All Wales Byelaws to any river in Wales which has a mean catch of less than 20 salmon would be an obvious breach of NASCO policy.

We therefore make a formal request that all rivers in Wales with a mean catch of less than 20 salmon are excluded from the All Wales Byelaws.

Appendix 3

We make a formal request that the introduction of the All Wales Byelaws is deferred until such time as voluntary C&R has been promoted for 1 year as set out in the NASCO Decision Making Structure.

We make our request on the following grounds:

  1. The NASCO Decision making structure, previously referred to in Appendix 1 iii on Page 4, states quite clearly that for both PaR and AR rivers (all principal salmon river in Wales with the exception of the River Usk) that “voluntary C&R will be promoted for 1 year”.

However on page 93 of the Technical Case Structure, the document which underpins the byelaws, NRW conjures up its own version and states that “The combined kill of salmon by both the net and rod fisheries should therefore cease in order to help to improve the status of the stock in the short term”.

The full transcript of both statements is contained in Annex 1 on Page 7.

  1. We note in your Written Statement on the Outcome of the Local Inquiry that you say that “there is common ground between NRW and objectors that salmon and sea trout stocks in Wales are suffering an ongoing decline”

We must make you aware that the picture across Wales is not one of universal decline. 8 of the Principal Salmon Rivers in Wales, show a year on year improvement in the 3 years 2015 – 2017. 4 of those rivers, have exceeded their Conservation Limit in each of the last 3 years with 3 rivers achieving more than 200% of their CL in 2017. Furthermore the most recent juvenile surveys in North Wales were most encouraging with one rivers results being described by NRW as “the best on record!”

  1. NRW’s own “Know Your River” documents clearly show that there has never been any active promotion of Voluntary C&R as set out in the NASCO Decision Making Structure. Rather than “a release rate of 90% is necessary in order to avoid the introduction of Mandatory C&R” we find instead comments such as “This is excellent and is the best on record”, “This is an excellent improvement” and “This is an excellent result and needs to be maintained”.

All of the comments concerning voluntary release rates can be viewed and verified via the following link: NRW Know your rivers – salmon and sea trout catchment summaries.

  1. 2.1 Decision Structure on Page 10 of the 2018 Assessment of Salmon Stocks & Fisheries in England & Wales contains the following information:

“A review is underway to re-examine the current methodology for assessing salmon stocks, along with the associated compliance scheme and decision structure; this will consider the need for possible improvements. The aim is to complete this within the next three years with the likelihood that improvements will be introduced in stages as developments allow.”

It makes no sense to introduce Byelaws when there is so much uncertainty surrounding the current methodology.

  • 90 – 95% of the salmon that enter Welsh rivers are not caught by anglers. Given that anglers currently return 86% of that relatively small %age of salmon that they do catch, it makes no sense whatsoever to drive them away. The lay person is unlikely to comprehend just how much time anglers spend on our rivers, day and night, throughout the year, not only fishing but carrying out essential bank maintenance work, checking on spawning activity or often simply enjoying a walk. Their very presence over the years has protected fish stocks with virtually all reports to NRW of poaching, sewage discharge, agricultural pollution and their resulting fish kills coming from anglers. The limited enforcement activity of NRW can never replace the protective effect of local anglers on their own rivers and to alienate those people, and threaten the very existence of the community

angling clubs to which they belong, poses a direct threat to our fish stocks and is short sighted in the extreme.

  • Deferment would help stem the decline in membership that smaller community based angling clubs are currently experiencing. Without their survival the heritage of angling being passed from father to son will be lost for ever.
  • It is education, co-operation, empowerment and partnership which has seen Voluntary Return Rates rise year on year to an all-time high of 86% across Wales. Failure to recognise that alienates those very stakeholders whose knowledge of their own rivers is so necessary for their recovery.
  • It would send a very clear message to our members that we are being listened to and our concerns are being addressed. In so doing there would be far greater willingness on the part of our members to participate in the development of a “Salmon and Sea Trout Plan of Action”.
  1. If any river fails to achieve a 90% Voluntary C&R rate then, in accordance with the NASCO decision making structure, legislation remains as a backstop. However this must be on a river by river basis and not include any river which has a mean catch of less than 20 salmon

We therefore make a formal request that the introduction of the All Wales Byelaws is deferred until such time as voluntary C&R has been promoted for 1 year as set out in the NASCO Decision Making Structure.

……………………………………….

Annex 1

CNL(14)71

NASCO Implementation Plan for the period 2013-18 EU – UK (England and Wales)

P 26 3. Third stage – option evaluation (purple boxes)

The purpose of this stage is to set out and evaluate options to realise the required changes in exploitation.

For rivers where 50%≤p<95% (where p= probability of failing the management objective) and the trend is down and with an annual catch of >20 salmon and C&R rate < 90%, then voluntary C&R will promoted for 1 year. If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered. Protected rivers such as SACs (Special Areas of Conservation) are given particular emphasis

For rivers where the above criteria apply, except that the annual mean salmon catch is <20 salmon, voluntary measures will be promoted

NRW Technical Case Structure Final P93 6.7 Options for salmon

As identified in Section 5, the salmon stocks across Wales (with the exception of the R. Usk) are classified as either “At risk” or “Probably at Risk” of failing to meet the management objective, based on the 2016 stock assessment, and are also predicted to remain in that category in five years-time.

As such, our Decision Structure guides us to “Identify a range of options to ensure sufficient spawning escapement to move to <50% probability of failure (of meeting the management objective) within five years (Probably not at risk category) while looking to maintain socio-economic benefits where possible.”

The combined kill of salmon by both the net and rod fisheries should therefore cease in order to help to improve the status of the stock in the short term.

Latest letter from the Minister.

Lesley Griffiths AC/AM

Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs

Ein cyf/Our ref LG/06787/19

Llywod raeth Cymru Welsh Government

Chris White Conservation Officer

Campaign for the Protection of Welsh Fisheries

chriswhite.cohite@gmail.com

      C/vVJ
1( September 2019

Thank you for your further letter of 23 August, regarding my response to your appeal letter in light of my decision to confirm the Wales Rod and line (Salmon and Sea Trout) Byelaws.

As part of the local inquiry I provided all parties with the opportunity to present evidence to an independent inspector in accordance with clearly outlined regulations. To ensure there was no bias, I declined all invitations to meet and hear independent representations from anyone prior to or after the inquiry.

Having reflected carefully on all the evidence and arguments put forward, the Planning Inspector considered the proposed Byelaws to be a measured response to· decliningfish stocks in Wales. Accordingly, he found them to be necessary, proportionate and reasonable in view of the decline of salmon and sea trout stocks in Wales and his recommendation was to confirm the Byelaws.

After consideration of the report and recent stock assessments I published my decision in a written statement on 16 July 2019 to confirm the Byelaws which will come into force from 1 January 2020. As you are aware, I am now looking for all parties to come together and concentrate their efforts on positive actions to help safeguard stocks as part of a Plan of Action for Salmon and Sea Trout.

I have asked Natural Resources Wales to lead on this Plan of Action, however, to maximise the chances of our salmon of sea trout stocks recovering all parties, including the Campaign for the Protection of Welsh Fisheries, will need to engage and contribute. I hope you will take this opportunity to contribute your views about how any threats to salmon and sea trout from issues such as water sports or any other issue can be managed to improve the status of these important fish stocks.

My advice to you regarding litigation was to highlight this option is available to you.

NRW have managed to change "partnership working" to "partnership alienation" A new low.

The following is a copy of an email sent to Joel Rees Jones in response to NRW’s request for angling representatives to work in partnership with NRW in compiling their “Salmon Action Plan”. It speaks for itself. My only comment is that it’s a shame that Joel is the recipient as he is surely “one of the good guys” I hope the management are copied in to this email: and the rest in a similar tone.

My thanks to John Eardley for allowing me to publish his email. John has dedicated himself to working with NRW as well as on and in his rivers for years. Latterly he has been in teh forefront of those challenging the imposition of compulsory catch and release and other bye-law changes. Thank you John.

Good afternoon Joel,

It is with deep regret and sadness that at this point in time I am unwilling to participate in this initiative. You are of course well aware that ever since I joined the Gwynedd LFG back in 2010 I have only ever missed one meeting and at all times have endeavoured to work in a meaningful partnership with both NRW and their predecessors, EAW. Like many of my colleagues copied into this email I have collected broodstock, planted out fry/parr, sprayed invasives, surveyed feeder streams etc. etc. I did this in the belief that by working together we could achieve so much more and saw education, cooperation and empowerment as key drivers for both the future of our waterways and the fisheries which they support. I realise now that those values count for nothing with those who are in charge of fisheries policy at NRW and for me personally that has been very hard to come to terms with. Furthermore, when our knowledge of our own rivers is dismissed by the Principal Fisheries Advisor at the Inquiry as “knowing the stiles and footpaths” in order to gain access, it would seem that there is very little of  meaningful substance that I could contribute anyway.

I have enjoyed, and valued, working with many NRW staff and they will know and recognise that. However those that know me well will know that I am a man of principle and that this is a decision that I will not have taken lightly.

In the extremely unlikely event that there should be a major change of policy in the near future in how NRW seek to engage with angling stakeholders then you know that I would be a more than willing participant.

Kind regards

John

From North West Angling Trust Fisheries Consultative Council

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum
14h September 2019 NWATFCC & CPWF recommendations to drafting of NASCO 2019 – 24 Implementation Plans
re: Improvements to Conservation targets, Stock reporting, Methodology and Decision process

Purpose; A short discussion paper to identify and highlight the scope of improvements to proposing a Quality Assured, open to view system and opportunity to harmonise mainland UK conservation principles and strategy

Validation – Independent validation of existing or new system procedures is required with periodic review to provide quality assurance.
Reason – the present system of river classification and decision structure process first introduced in 2004 (and updates) is not validated or subject to periodic review. The present systems frame recently introduced Regulatory measures and are both open to and currently being challenged.
In implementing National England & Wales Salmon Byelaws, the EA & NRW share common regulatory undertakings framed by NASCO approved salmon conservation objectives, reporting methodology and decision process, yet have introduced quite separate national conservation strategies in relation to fisheries management of stocks. Specifically C & R measures and method restrictions.

Reaching a single Biological Reference Point interpretation of a Rivers spawning target (Conservation Limit, Management Target etc)
Reason – a single BRP will provide clearer focus to meeting and achieving conservation objectives. Conservation Limit and higher river specific Management Target is frequently misquoted and misunderstood in relation to river Management Objectives and incorrectly associated in generic terms with reporting “management targets”.
Scotland and Ireland have undergone this process, defining MSY (Minimum Sustainable Yield) as the single spawning CL biological reference point.

Review and revision of individual River CL`s
Reason – in both the stock recruitment curve (SRC – egg to smolt) and replacement line (RL – marine, post smolt to returning adult) phase, assumptions in setting and defining CL are being questioned as regards the need for updating Salmon Action Plan estimates and targets. The accuracy of RL & SRC model principles and predictions in times of significant trend change has to reassessed, as with decisions made in 2004 to reduce national River CL to lowering marine survival estimates that have significantly worsened since that time. The mechanism of estimating actual individual CL from total wetted area and density (eggs /100m2) has to somehow balance and take a account of waterbodies that are not and unlikely to meeting WQ standards, suffer from degraded spawning/nursery habitat and significant un-quantified predation losses.

Redefining and simplifying Management Objectives and River Status methodology
Reason – set out below are the fundamental weaknesses and flaws with the current River classification methodology – use of the Linear Regression trend and five year forward prediction of probability of meeting Management objectives.

1. What is a rivers Management Objective and is it statistical precise ? Originally defined as a River that meets or exceeds its CL in 4 years out of 5 on average or 80% of the time. Found to be statistically imprecise and has recently been amended in the published 2018 Stocks Assessment Report to exceeding CL in 4 years out of 5 or 80% of the time. The question that is asked is whether the regressed Linear trend actually expresses MO ?
The alternate model being proposed is that a rivers MO exceeds CL on average in the last 5 historic years. This is statistically precise and provides the best mean actual 5 year trend data to an exact % CL attainment. Appropriate river classification management decisions and C & R measures can then be framed around precise real time trend performance.

2. Applying Variable corrections to spawning stock and River egg deposition estimates. Seven variables are applied to the majority of rivers reliant on rod catch returns to quantify final female 1SW/MSW component numbers and their weight/egg bearing capacity to estimate a Rivers total spawning egg deposition to CL. The original 2004 methodology and subsequent annual Assessment reports clearly state the accuracy of egg deposition estimates and predictive trend forecasting required incorporation of revising seasonal variations of rod exploitation on individual rivers, as one of seven variables. In relation to annual reviewing of rod exploitation rate variables, these are specifically rod effort, river flow conditions and run timing/out of season proportions of the run. Rod exploitation rate estimates have not been reviewed and revised nationally in a time series 1994 – 2018 when Salmon Action Plans and CL were originally framed around 2000. Rod effort regionally and nationally has dropped alarmingly to 27 – 35% of 1994 estimate. The Appendix Tables 6, 8 & 21 indicate that reduced rod effort is the major and principle cause of declining rod catch and CL attainment performance. River flows are threatened by abstraction pressures and extreme rainfall events and extended periods of rainfall shortage. These in turn shorten the window of angler participation and perceived favourable salmon running and take conditions. A quality assured system has to place periodic reviews at the heart of its system procedures and with it the accuracy of species rod effort, catch reporting, weight scale determination of components and fecundity. We recommend a single reporting statement of key River variables along similar lines to the Table.22 Information request to NRW of their annual review and revising policy for assessing stocks.

3. What is the 20 percentile of the linear regression trend and is it expressing a Rivers MO ? Hugely complex area of Bayesian analysis of time series trend distribution which few fisheries managers can interpret or explain. In my simple terms the Linear regression trend line is depicting a rivers 10 year historic performance where 80% of a Rivers annual attainment in its moving 10 year timeframe is above its 20th percentile trend line. Concern being that the trend line is not statistically expressing MO (its median or midpoint value in its best 80% years attainment), but as we know a much reduced precautionary trend based on higher management target. The proposed alternate model – 5 year MAT of % CL (Table 24 Option 2 with current model comparisons) simplifies and precisely maps actual river attainment.
4. Should we continue to use current methodology where “predicted” trend forecasts map a 15 year Linear (straight-line) projections ? No, River trends are not linear and if we make that assumption there is a high risk that predictions will fail. Salmon River performance map cycles of abundance, with good years followed by low or lower abundance. Fig. 6, 7 & 8 illustrate how 15 year linear predictions fail with rivers that exhibit longer and stronger salmon cycles. The NW river graphs for the Eden, Ribble & Lune illustrate these trough predictions in comparison with the River Wye in that same timeframe with over optimistic predictions of improving stocks. Rivers with good CL attainment performance over 10 historic years do not become extinct in a short 5 year forward projection window as predicted in several NW Rivers over the years 2014, 2015 & 2016. The use of the proposed 5 year historic average or mean CL River attainment makes no forward prediction of stock performance, relying on most recent real time data.
The model produces the necessary dampening effect in strong cycles and assurance required in decision making to account for seasonal variations that in some years can be significant.

5. Comparisons of predictive to actual recorded status in 5 years time forecasts have been poor. Table. 23 is an analysis of the accuracy of EA & NRW five year forward predictive stock status forecast for the current 64 English & Welsh monitored Rivers in the 2008 – 2017 timeframe, illustrating low accuracy on which regulatory stock management decisions are made

6. Use of log transformed and non log assessment charts – in recent years Log transformed charts have superseded actual scale log assessment charts. The visual scale of actual trend prediction and a Rivers annual CL attainment has been lost in this process. Log scale assessments are clearly masking Linear regression trends that for some Rivers cause unrealistic and extreme predictive stock forecasts. See Fig. 6, 7 & 8 again.
7. Do the four risk status groups and specifically PaR & PNaR status that form the 90% range of probability that a river will meet its MO in 5 years time, provide a good interpretation of a Rivers performance? Rivers that can report an exact % estimate of actual historic 5 year MAT attainment as proposed, will provide clearer and more accurate interpretation of actual trend performance with greater clarity in national/regional trend reporting. Precise Rivers stock assessment classifications bands (e.g. 10% bands) can then more clearly define decision making step procedures. An example of this model classification option with applied Decision process – C & R measures is set out in Table. 24 The Option 2 model was produced in February 2018. In essence, similar to the “Scottish style” grading approach with classification assessments that can be reviewed annually, based on 5 year MAT % CL river performance and visible and easily interpreted by fisheries managers and anglers.
The Option 2 model example guidelines for the 64 English & Wales monitored Rivers are set out below and framed on current CL target values and applied variables and SAP estimates.
Rivers exceeding 5 year MAT of CL target (> 100%) – required to meet 80% C & R target

“ 80 to 100% 5 year MAT of CL target (80 >100%) “ “ “ 90% C & R target

“ below 80% 5 year MAT of CL target (< 80%) “ “ “ 100% Mandatory C & R

Resetting the Decision Structure Process framework – using clear precise river classification status & C & R measures strategies
For England and Wales the Decision Structure Process can be reset in the decision flow chart to a Rivers MAT % CL attainment, whilst maintaining and reviewing the CL principles & targets and applied variables. Annual review of river performance to CL attainment will flow visibly from simplified annual assessments and the focus and effort can shift to ensuring River data (rod catch, rod effort/river conditions/rod exploitation rates, weight, fecundity etc) are clean and accurate.
In tandem that Index River counter/trap datasets are providing outputs that are reviewed and revised to linked reference Rivers and SAP`s.
The Scottish grading system underwent a consultation process that generated a 5 year MAT CL equivalent model, on clear lines with yearly review of river Status and applied measures. The Scottish model accounts for seasonal factors – river flow, out of season runs etc and the Consultation enabled a review and major revision of wetted area River estimates, with MSY defining River CL targets.

Conclusion
These proposals and model suggestion allows UK jurisdictions to maintain existing CL setting and annual attainment to CL and then build in appropriate break points for setting probability or risk of meeting a precise MO as the Rivers actual 5 year MAT performance. Annual revision of status will flow from this and necessary revision of seasonal factors and variable corrections.
The new methodology procedures would remove the Linear Regression trend and 5 year forward predictive forecasting that is widely criticised.
Focus can then concentrate on ensuring rod catch, counter/trap, variable and seasonal data is clean and accurate.
An opportunity might then be realised to harmonise mainland conservation strategies and systems with obvious potential operational and reporting benefits. Mike Ashwin. redfa/nwatfcc 14.09.19

To Chairman of NRW Board

Mr Reuben Woodford
Ffrancon House
Tyn-y-Maes
Nant Ffrancon
Bangor
Gwynedd. LL57 3LX
reubenwoodford@gmail.com

17th September 2019

Sir David Henshaw (NRW Board – Interim Chair)
NRW Board Members

Via email: nrwboardsecretariat@naturalresourceswales.gov.uk

Re: Implementation of ‘All Wales Byelaws’ – Discordant with NASCO Guidelines

Dear Sir David and Board Members,
We are aware that at the forthcoming NRW Board meeting on September 19th, the Board will be asked to approve or note implementation of the ‘All Wales Byelaws’ (Fisheries). The exact undertaking placed upon the Board seems unclear.
There is no evidence the byelaw measures would have any effect on reversing the decline in migratory fish stocks. There is clear evidence, the measures are discordant with the NASCO (North Atlantic Salmon Organisation) guidance stipulations on a catchment by catchment basis across Wales. There are rivers across Wales where under this guidance mandatory measures, categorically, should not be applied and yet this is NRW’s intention – it is critical the Board consider this position.
The use of a broad brush-stroke and expedient application of a ‘precautionary approach’ as opposed to a defined ‘precautionary principle’, one which is underlined by robust protocols has, resulted in senior NRW Fisheries officers effecting their preference upon all rivers in Wales in a blanket application of prohibition. This move poses a direct risk to the future of angling clubs and the stock assessment and river classification system i.e. the evidence based system underpinning policy.
At the Public Inquiry (2018/19), the Inspector sought NRW’s re-assurance that ‘The Byelaws’ were enforceable. No such re-assurance has been given. Since the Public Inquiry, NRW has announced it is cutting the number of specialised fisheries enforcement officers across the country. During ‘The Byelaw’ development process we spoke to enforcement officers and neither had they been consulted upon, nor did they view the ‘the byelaws’ as enforceable. NRW have cited the ‘deterrent effect’ as the primary function of the measures and yet 83% of respondents to ‘The Byelaws’ consultation opposed the measures and since then objectors have identified in detail the risk the ‘The Byelaws’ pose; to angling, angling clubs, the stock assessment process and the viability of preventing poaching activity.
It is clear, that rather than underpinning the way forwards, the byelaws would undermine our collective ability to manage fisheries. Furthermore, the Environment Agency in England have stipulated that method restrictions cannot be set out legally. It is also evident that were method restrictions to be imposed upon anglers, compensation could be sought – cited within the Water Resources Act 1991.
Improving the validity of evidence and strengthening the way NRW work with the angling community as partners should be a priority and yet it has become a forced add-on in the wake of the cabinet secretary’s decision. The stark contrast with which our views and co-operation now seem eagerly sought in comparison with the blanket rejection of our evidence at the Public Inquiry shows total disregard for the angling community’s long standing role and our sincere commitment to establish a workable way forward. Implementation of ‘The Byelaws’ is now being seen as a block to future partnership working for representatives of angling clubs who now call time on NRW’s dictatorial approach.
At the NRW Board Meeting on the 18th January 2018 in Bangor, non-executive members of the Board highlighted the rift between NRW’s stance and that of the angling community. Those concerns were effectively rejected by the chairperson Diane McCrae, with little consideration of consequence. That decision was made conditionally with Board Members, who sought reassurance from the Chair that the relationship between NRW and partners would be healed – that condition was and has not been honoured and instead of working with the angling community, NRW’s chief Fisheries Officers have since further alienated us in an act of obtuse provocation marked by the Public Inquiry.
Board members in 2018 also sought re-assurance from the Chair that a wider strategy should be initiated without delay – as the angling community have highlighted, banning of angling activities has been NRW’s primary focus all along and to the detriment of actions to tackle the actual causative factors placing risk upon salmon fish stocks in particular. At the Public Inquiry Dr Maule provided a cautionary note to remind NRW that supplementary measures such as the byelaws could only be effective if the causative factors of stock decline were treated in a timely manner at catchment scale. Little re-assurance was given by the head of NRW Fisheries at the Public Inquiry in relation to achieving wide scale catchment actions to manage the risks to Salmon due to limited resource.
There are numerous reasons why the ‘All Wales Byelaws’ can be shown as being a disproportionate response, however their temporal impropriety is the most destructive and disproportionate element of them.
There is very little recognition by senior Fisheries staff, that what angling clubs have already achieved is significant and progressive. Anglers across Wales currently return 86% of their catch. What anglers catch represents 5-10% of the salmon in Wales rivers. The angling community are not the problem, however, with ‘The All Wales Byelaws’ implemented, we would be disabled from being a meaningful part of the solution when all along we have illustrated our willingness and ability to do so.
At the public Inquiry, NRWs legal counsel spent an exhaustive period, dumbing down pivotal evidence until there was no hope of objectors putting it and the disproportionality of the byelaws in full context. The cost of the Inquiry, £350,827.48 plus VAT, bought the taxpayer – an affront on volunteers; volunteers that have worked in partnership with environmental regulators for decades.
The All Wales Byelaws have been sold to the Cabinet Secretary and the NRW Board on the basis of incomplete evidence and an inference of acceptability that is untrue. The inequalities of the overall process has denied the angling community a voice; the angling community’s evidence appropriate exposure and denied the Cabinet Secretary the ability to gauge the consequence of implementing the byelaws within a regulatory environment already fraught with uncertainty.
As they stand, the ‘All Wales Byelaws’ will not deliver progress. Prioritising a mechanism with no proven benefit nor assessment of risk (NRW have done neither) over actions to tackle the causative factors influencing fish stock decline, is a failure of NRW’s statutory duties and simply relying on blind faith.
Implementation of the ‘All Wales Byelaws’ now, is an action discordant with NASCO guidelines.
We are now seeking deferment of the all Wales Byelaws until such a time as voluntary Catch & Release has been formally promoted for 1 year in accordance with NASCO Guidelines.
The Board should be made aware that a review is already underway to re-examine the current methodology for assessing salmon stocks, along with the associated compliance scheme and decision structure used in England and Wales. As a consequence of this review improvements are likely to be recommended. The angling community in Wales are seeking phasing and interim arrangements are considered and incorporated in the Welsh Byelaws until such reviews are completed and the accuracy of current and historic salmon stock assessments are assured.
A phased approach could provide the critical transitionary state to turn this situation around – without it, it is the fear of many that key representatives from the angling community will, disillusioned by NRW’s dictatorial and myopic stance leave the arena for good. We must not allow this to happen as the future of fisheries, fish stocks and community fishing clubs in Wales are at stake.
Yours Sincerely,

Reuben Woodford
On Behalf of: Afon Ogwen Anglers in association with CPWF
Petitioners – petition presented to the Welsh Assembly ‘Give Welsh Fishing Clubs & Salmon & Sea-trout a chance’, on behalf of 1719 signatories

Letter to NRW Board

16th September 2019

Sir David Henshaw – NRW Board (interim Chair) NRW Board Members
Via email: nrwboardsecretariat@naturalresourceswales.gov.uk

Re: NRW fisheries bylaw proposals

Dear Sir David and fellow Board Members,

We find it necessary to make you aware of the serious concerns that were raised at a meeting of angling representatives from the Dee and Gwynedd Local Fisheries Groups held at the Owain Glyndwr Hotel, Corwen on Saturday 7th September. 19 Fishing Clubs/Organisations with a combined membership of several thousand anglers were represented at this meeting which was called as a result of the anger and frustration that is being caused by the actions of NRW in its relentless pursuit of a legislative solution in the case of both the All Wales Byelaws and Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019, both of which are referred to in Paper 19-09-B14 which will be presented to you during your meeting on Thursday of this week.

You should also be aware that those present at the Corwen Meeting are well respected figures within both their own organisations and the angling community in North Wales in general and furthermore have extensive knowledge of their own rivers. That such people are talking in terms of militant action and civil disobedience should give you great cause for concern

At the close of the NRW Board Meeting on 18th January 2018 the gulf between angling stakeholders and NRW was highlighted by board member Zoe Henderson and this was followed by much talk of how “we have failed to engage with stakeholders” and must take immediate steps to put this right. Subsequent events at the Inquiry into the All Wales Byelaws during January and March of this year when Counsel for NRW saw fit to attempt to discredit ordinary decent people who sought only to protect their own fisheries from NRW’s actions has plunged that already fractured relationship to new depths. The fact that Counsel and External Solicitors were paid the princely sum of £259,978.26 to carry out these actions only adds insult to injury. That the Principal Fisheries Advisor explained at the Inquiry that in a previous acknowledgment that anglers know their own rivers better than NRW what he really meant was that they know the location of the stiles and footpaths is laughable as well as insulting. The end result is that there are a number of angling clubs who will no longer engage in any future meetings with NRW whilst their concerns are treated in such a dismissive way. Furthermore they will instruct their bailiffs to no longer check that their members have purchased a rod licence and to only enforce their own clubs’ rules. Further concerns related to the decline in the number of both local and visiting anglers despite the encouraging numbers of both salmon and sea trout that have been observed in our rivers this year. This will have repercussions on the ability of smaller community based clubs to afford to rent waters in the future and be a threat to their very existence. The presence of anglers on the riverbank also acts as both a deterrent to poachers and a source of intelligence for NRW’s Enforcement Officers and it is therefore unsurprising that increasing illegal activity has been a major concern for us during the year.

Education, co-operation, empowerment and partnership has seen Voluntary Return Rates rise year on year to an all-time high of 86% across Wales yet NRW has chosen to turn its back on those values which have brought us so far, in the pursuit of an autocratic solution. In so doing it has alienated those very stakeholders whose knowledge of their own rivers is so necessary for their recovery and that is a great concern for those of us who are actively involved with both Rivers Trusts in North Wales. NRW may recognise that “we have able partners in the rivers trusts and need to maintain a productive relationship with them” but is making it ever more difficult for those organisations to recruit volunteers.

The following should give great cause for concern.
We note in Paper 19-09-B14

Arrangements for the cross-border rivers Dee and Wye
4. Following Board approval in July 2018, an application will shortly be made to the Minister for confirmation of new rod fishing byelaws for the rivers Dee and Wye (The Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019). Because these byelaws have been dependent on ministerial confirmation of the All Wales Byelaws, this application could not have been made prior to receipt of that confirmation.

Wales, along with all other countries which have runs of Atlantic Salmon, is duty bound to follow NASCO (North Atlantic Salmon Conservation Organisation) policy.
NASCO International (North Atlantic) Conservation Policy and common Wales & England national Policy is defined in the 2018 Assessment of Salmon Stocks & Fisheries in England & Wales
(Background report), Annexe 7 – Salmon Management Procedures in England & Wales, Page 77 & 78 – Decision Structure in E & W.
The decision making structure set out in the report is very clear

“3. Third stage – option evaluation (purple boxes)
The purpose of this stage is to set out and evaluate options to realise the required changes in exploitation. For rivers where 50%≤p<95% (where p= probability of failing the management objective) and the trend is down and with an annual catch of >20 salmon and C&R rate < 90%, then voluntary C&R will promoted for 1 year. If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered. Protected rivers such as SACs (Special Areas of Conservation) are given particular emphasis”

This is recognised in NRW Board Paper B B 40.15 Annex 2, TECHNICAL REPORT: MANAGEMENT OPTIONS TO ADDRESS THE DECLINE IN STOCKS OF SALMON AND SOME SEA TROUT IN WALES
which states quite correctly that:
The decision structure is currently not applied to:-
• rivers where the voluntary C&R rate is greater than 90%, as it has been felt that the extra benefit on any individual river does not warrant the costs of pursuing statutory control.

Furthermore NRW’s 2017 “Know your river document” for the Dee makes the following statement: “The release rate in 2017 was 91%. This is an excellent result and needs to be maintained”
Put simply the River Dee is fully compliant with NASCO policy and according to NRW’s own documentation “does not warrant the costs of pursuing statutory control”.

On that basis the introduction of statutory legislation would be a clear breach of NASCO policy.

You will not be surprised that we will be challenging any application to the Minister for confirmation of new rod fishing byelaws for the cross border Dee most strongly and furthermore will have the support of our English colleagues who will mount a similar challenge to the EA given that “It has previously been agreed

with the EA that they will make a simultaneous matching application to DEFRA for confirmation of complementary byelaws in the English parts of these two cross-border rivers”. We also believe that there will be considerable support from AMs for this action.
Furthermore we will also seek deferment of the All Wales Byelaws until such time as voluntary C&R has been promoted for 1 year in accordance with NASCO guidelines. NRW’s Know Your River documents clearly show that no active promotion has ever taken place.

90 – 95% of the salmon that enter Welsh rivers are not caught by anglers. Given that anglers currently return 86% of that relatively small %age of salmon that they do catch, it makes no sense whatsoever to drive them away and allow poachers to fill the vacuum, particularly as this will result in significantly greater losses.

Anglers, and the revenue which they generate, are vital if our fisheries are to survive and a worthwhile Salmon and Sea Trout Plan of Action is to become a reality. NRW has to stop being so dismissive of our concerns and be prepared to participate in a meaningful partnership. That in itself requires a significant change of policy.

Yours sincerely

John Eardley – Strategy Officer, Campaign for the Protection of Welsh Fisheries

Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group

Mervyn Williams – Chair, Dee Local Fisheries Advisory Group

On behalf of:
Bangor on Dee Salmon Angling Association
Campaign for the Protection of Welsh Fisheries
Capenhurst Angling Club
Chirk Syndicate
Clwyd Federation of Angling Clubs
Corwen and District Angling Club
Dolgellau Angling Association
Dolwyddelan Angling Association
Llanbrynmair Angling Association
Llangollen Maelor Angling
Llyn Guides
Ogwen Valley Angling Association
Penrhyn Fishing Club
Prince Albert Angling Society
Rhyl and St. Asaph Angling Association
Rossett and Gresford Fly Fishers
Seiont Gwyrfai and Llyfni Fishing Society
Vale of Clwyd Angling Club
Wirral Game Fishing Club

To NRW Board Members

Sir David Henshaw
NRW Chairman
Via email: nrwboardsecretariat@naturalresourceswales.gov.uk
12 September 2019

Re: NRW fisheries bylaw proposals

Dear Sir David,
We note on the agenda that the Board will be asked to approve the Fisheries Byelaws relating to cross border rivers and the emergency byelaw to cover the cessation of the National Salmon Regulations which expired in October 2018 after some 20 years.
We wish to draw your attention to the fact that after 20 years of the National Salmon Regulations there has been little or no improvement in migratory fish stocks i.e. there is no evidence that the byelaw proposals will have any effect in reversing the decline in migratory fish stocks. It is recognised that anglers are not the problem and after 20 years of regulation there has been little or no improvement.
The original proposals were presented to the NRW Board which at that time was chaired by Sir Peter Mathews on 9 July 2015 at this meeting the Board rejected the byelaw proposals with Prof Linda Warren who had been a member of the committee which drafted the National Salmon Regulations in 1998 saying as there was no evidence of the effectiveness of the existing regulations why did the fisheries officers consider that extending the byelaws would make any difference. All of the concerns of anglers expressed during the consultation were dismissed as were our very valid arguments at the Public Inquiry.
The issue is not solely related to Catch and Release which the majority of anglers already practice voluntarily, there are also major concerns surrounding method restrictions which will effectively prevent anglers from fishing their local rivers and may see the closure of community fishing clubs due to the loss of membership. It should also be noted that angler exploitation of salmon is estimated between 10% and 13% of the annual number of salmon entering a river. The number of salmon caught is dependent on water conditions i.e. catches are better in high flows and poorer in drought conditions. As anglers catch less than 20% of the salmon which enter a river there are therefore at least 80% of the fish which are not caught by anglers and survive to spawn even if anglers killed every salmon that they caught. However 86% of those salmon that are caught are returned voluntarily and therefore the problem is nothing to do with angling. In fact we are just being used as scapegoats to cover the failure of NRW and previous agencies to address the decline in migratory fish over the past 20 plus years, the reasons for which are fully known i.e. pollution, predation and barriers to migration.
There would be more support from anglers if it was believed that this would in fact reverse the decline in migratory fish stocks but it will not. In fact some rivers have seen a significant improvement in migratory fish numbers since the original technical paper was written in 2014/15 and had the proposals been accepted and implemented in 2016 a review would have been carried out in 2021. To this end CPWF has written to the Minister requesting a deferment of the byelaws for 12 months i.e. until 2021 to enable a review of the status of individual rivers to be assessed, as it stands the byelaws are a blanket approach which covers all rivers.
At the inquiry CPWF raised the issue of disturbance of spawning fish by adventure activity i.e. mainly paddlesport as there is little point in imposing restrictions on anglers only for any increase in fish reaching their spawning ground to be disturbed by such activity (this also applies to anglers wading whilst coarse fishing on cross border rivers – our North Wales rivers do not have any coarse fish populations). Disturbance of spawning grounds equivalent to bird nesting sites would not be acceptable to the RSPB and yet this is not only acceptable to NRW but due to the misinformation on the NRW website is positively encouraged.

Regards

Chris White
Conservation Officer: Campaign for the Protection of Welsh Fisheries

Minister's response 12th August

Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs

Ein cyf/Our ref LG/06583/19

Llywodraeth Cymru Welsh Government

Chris White chriswhite.cohite@gmail.com
12th August 2019

Thank you for your letters of 26 July to myself and the First Minister, regarding my decision to approve Natural Resources Wales’ (NRW) ‘All Wales’ Byelaw proposals for salmon and sea trout. I am responding to you on both letters, as this subject area falls under my portfolio as Minister for Environment, Energy and Rural Affairs.

I understand some anglers will be disappointed with my decision, but please be assured it was not taken lightly. We all agree there has been an ongoing decline in salmon and sea trout, as you state in your letter, and this has again been confirmed in the recently published stock assessments which unfortunately show stock levels for both species are still a concern. To avoid stocks falling to unsafe levels which may lead to stock collapse, we must take action now.

I recognise, as does the inspector in his report, anglers are not primarily responsible for the decline of salmon and sea trout, but are a contributing factor. As such, my statement on 16 July clearly stated we must also tackle the other contributing factors. I have tasked NRW to lead on a Salmon and Sea Trout Plan of Action, taking forward a significant amount of work to reverse the decline of salmon and sea trout. NRW will work with partners to tackle a// the issues impacting stocks including those highlighted by anglers at the inquiry such as obstructions to migration, water abstraction, fish eating birds and the need for robust enforcement.

The Welsh Government, of course, has a contribution to make to this plan. For example, I will be bringing in new regulations on agricultural pollution in January 2020 to reduce the risks posed to fish stocks and wildlife. I will also consider other proposals as and when they are presented to me within the Plan of Action, and I note in your letter the call for responsible promotion and regulation of paddle sports to avoid the disturbance of spawning fish.

Bae Caerdydd • Cardiff Bay
Caerdydd • Cardiff
CF99 1NA

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If the plan is to succeed, and we are to reverse the decline in salmon and sea trout, everyone with an interest will need to engage and contribute. To achieve our shared goal it will require the combined efforts of all those who care about these magnificent fish to work constructively together and put prior differences aside. I sincerely believe anglers, such as yourself, and supporters of angling have a crucial role to play and I hope you will engage with NRW to develop and help deliver this plan.

I am hugely encouraged by the fact the majority of anglers (86%) already voluntarily return the salmon they catch and this number is increasing. This demonstrates the care and respect anglers show for salmon and their wish to protect them for the future. I see this as a clear sign local angling clubs will continue to thrive and adapt if this approach is passed on to new members.

It is clear to see the depth of feeling and passion on both sides of this debate, and this is reflected in your letter. I believe I have responded to your concerns around my decision and reasoning behind the appointment of the Planning Inspectorate to the Local Inquiry process in our previous correspondence (ref: LG/05045/19). I also confirmed I was content with the regulations put in place for the Inquiry and am satisfied the assigned Inspector was impartial and ensured an open and fair process. If you are still dissatisfied with any aspect of the inquiry process, or my decision, you are entitled to seek a Judicial Review.
Your’s

Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs

Letter to Minister 23 Aug 2019

CPWF
23 August 2019

Re: THE WALES ROD AND LINE (SALMON AND SEA TROUT) BYELAWS 2017 Inquiry

Dear Minister,
Thank you for the response to my appeal letter (Ref LG/06583/19) on your decision to approve the NRW byelaws. Whilst you claim it was a decision which has not been taken lightly your decision is based upon a one-sided conversation as demonstrated by the bias shown by the inspector in his report who dismissed everything we presented out of hand. Your refusal to meet with CPWF and enable us to fully explain our concerns has resulted in you making a decision which has significant impact on anglers across Wales – your electorate.
There would be far more acceptance of the byelaws if there was any evidence that the proposals would have any effect on reversing the decline in migratory fish, I drew your attention to this in my letter of 26 July but it seems that, despite the overwhelming evidence of the proposals not working for the past 20 years, you consider it appropriate to just rubberstamp them. For my part the change in the byelaws will have no impact on the way that I fish but this is not the case for the small community fishing clubs in South West, Mid and North Wales.
These small communities-based angling clubs fish their local rocky rivers, rivers which can only be effectively fished with bait. This is not solely about returning fish to the river, something which anglers are doing voluntarily; this is about the survival of traditional fishing techniques which have been handed down over generations and helped sustain angling in Wales. It is on behalf of these clubs that I write to you as some clubs have already experienced a reduction in membership purely on the threat of new byelaws.
Your letter tends to indicate that you side with the inspector and consider that this is just a philosophical issue as most anglers are already practicing catch and release. Many rivers in Wales are exceeding the 90% release rate recommended by the North Atlantic Salmon Conservation Organisation (NASCO), more on this later. The theory that every salmon (or sea trout for that matter) caught on a worm is a dead fish does not reflect the fishing methods now used by anglers with few fish being deeply hooked. There is as much chance of salmon being deeply hooked when using a fly or spinning bait and single hooks.

CPWF has the support of freshwater and sea anglers in Wales.
Visit our website at www.cpwf.co.uk

There is much talk by your Government of the value of heritage and yet at a stroke you will destroy much of the angling heritage on many rivers in Wales, not only by limiting the diversity of angling methods allowable but by constricting club’s ability to survive.
Our concern is not about returning salmon unharmed i.e. catch and release (although returning mortally wounded fish to the water is beyond most angler and the public’s tolerance), it is about method restrictions which will at a stroke deter anglers from fishing many rivers in Wales.
You say that you have tasked NRW to lead on a Salmon and Sea Trout Plan of Action, but this is nothing new and yet again we will end up with a glossy brochure full of empty promises. We have had more than 20 years of this. It is anglers who care for our rivers and yet our concerns and identification of the problems have been dismissed over the years. This has been primarily due to lack of fisheries funding, resource and commitment from Government. You say there is a need for ‘robust enforcement’ and yet poaching is rife in Wales due to the lack of enforcement staff who are ‘intelligence lead’ – this simply means after the event investigation assuming poaching incidents are in fact investigated. A poacher can, in one evening, remove the bulk of the spawning stock from a small river and once anglers are no longer fishing these rivers poachers will take full advantage and, rather than reversing the decline, this legislation is more likely to make matters worse as there will be no anglers to deter poaching activity.
I mentioned above the NASCO recommendations on the need for legislation. Put simply, this says that for a river which is classified as ‘Probably at Risk’, anglers should be given 12 months to meet a 90% catch and release figure voluntarily. Only if the 90% figure is not achieved should legislation be considered, NASCO say that this should not be applied to rivers with rod catches of less than 20 salmon per year. NRW choose to use all 23 rivers in their justification for the byelaws even though many of these rivers were well below the 20 salmon per year figure, this skewed the overall results in order to justify the proposals.
You recognised that in Wales 86% of all the salmon caught in 2016 were returned on a voluntary basis from catch returns on the 23 principle salmon rivers. The technical case for the byelaws developed by NRW was based on poor angler catch returns and poor fry and parr counts following significant flood events in 2014/15 and based upon these results the 5 year forward [pessimistic] forecast predicted that by 2020 salmon would be ‘At Risk’ in all Welsh rivers. Whilst this may be true for some rivers, this is not the case for all rivers, and we are seeing more salmon in some of our rivers in 2019 when NRW predicted there would be few. Where a river can be identified as having salmon stocks heading for extinction then these rivers should be closed to anglers and for that matter adventure sports. The reality is that many angling clubs are exceeding the 90% catch and release requirement voluntarily and therefore it should only be rivers which are failing to meet this 90% target which should have compulsory enforcement.
As CPWF reported at the Inquiry, NASCO is drafting new proposals to its 2019 to 2024 five-year Implementation Plan for managing salmon stocks in England and Wales.
Central to this is a fundamental stock reporting review, calling for improvements to the current national stock assessment methodology which classifies individual river

risk status. This is a major undertaking over the next three years which we highlighted the need for, in our communications to you, through Mark Lloyd of the Angling Trust on 9th April and 17th Sept 2018.
Through our colleagues in England, fisheries recommendations have been presented to the NASCO representative Paul Knight – CEO of Salmon and Trout Conservation UK (S&TCUK) for consideration at the end of this month.
Additionally, Cefas/EA/NRW are currently undertaking a national England and Wales review of individual river rod exploitation rates to improve weaknesses in the estimates of river stocks. Again, the need for improvements was identified and highlighted to you and the Defra Minister in those same 2018 letters. We envisage these changes and improvements will correct current inconsistencies and weaknesses in stock reporting and adopted measured controls in both England and Wales.
We note that no interim stock review arrangements have been built into the proposed NRW Welsh Byelaws and we strongly recommend phasing arrangements are considered to resolve this oversight. We proposed these arrangements in those early communications. It should be noted that the NRW technical case was presented to the NRW Board in 2015 following significant flood events and over the past 4 years there has been a recovery in some Welsh rivers, this supports the need for interim stock reviews or as happens in Scotland an annual review.
Delaying the implementation of the byelaws for a further 12 months i.e. to 2021 would have little or no impact on salmon stocks but would enable anglers and for that matter tackle dealers to adapt to the byelaw proposals, my understanding is that this approach is to be adopted for the proposed agricultural pollution legislation, pollution which causes far more damage than anglers to fish stocks. A delay to 2021 would also provide more time to develop the Salmon and Sea Trout Plan of Action and would ensure engagement from stakeholders who have been alienated by your decision and at this time are refusing to co-operate with NRW.
You acknowledge my concerns over continual disturbance by adventure activity, mainly paddlesport, on our rivers during the spawning season and under the precautionary principle this must be brought under control. I somehow doubt that you will legislate against adventure activity as it seems that your Government wish to see increased use of rivers by such groups despite the environmental damage they may cause. As I said in my letter of the 26 July the RSPB would not tolerate the continual disturbance of nesting birds and yet NRW seem to consider this acceptable for salmon on their spawning grounds, the equivalent to nesting sites for birds. If our rivers are to recover then under the precautionary principle they must be closed during the spawning season to all invasive activity (including wading by anglers), this is not an attempt to stop paddlesport this is to protect spawning salmon and sea trout.
I would yet again request a meeting with you so that you have a better understanding of the issues from an angling perspective. You recognise we are all working to increase the number of salmon and sea trout in our rivers but legislation which penalises the very people who care about those rivers is not the answer and despite what you seem to believe is unenforceable. We, as volunteers, already have to spend countless days to manage the consequences of your decision upon club resilience. The varied risk carried by the byelaw measures simply has not been

assessed and we all stand to pay the price, now and into the future unless something changes.
Having an argument by letter is not the most constructive way of resolving this issue, you can of course simply ignore us in the same way that NRW has ignored us, but we are not going away, you suggest that litigation is our only recourse and you seem to prefer this route rather than simply listening to our very real concerns. The legal costs for the inquiry were circa £220,000 how much more public money are you prepared to spend in order to defend the indefensible and deprive the anglers of Wales their heritage?

Regards
Chris White
Conservation Officer: Campaign for the Protection of Welsh Fisheries CC Mark Drakeford – First Minister

Response to Petitions Committee WG – All Wales Byelaws (Fisheries) – Public Inquiry – Inspector’s Report

Response to Petitions Committee WG – All Wales Byelaws (Fisheries) – Public Inquiry – Inspector’s Report

Petitioners Response – Mr Reuben Woodford (Afon Ogwen Anglers in conjunction with CPWF/Petitioners) [PetitionP-05-810 Give Welsh Fishing Clubs and Salmon and Sea-Trout a Chance]

To Report [ENV/3209811] 190/16-LG-Written Statement-Marine and Fisheries – Inspectors Report

30 August 2019

Summary of key points:

  • General and specific suppression of objector/CPWF evidence
  • General and specific tendency to adopt NRW stance even when unsubstantiated by objective evidence – an appearance of bias
  • The inspectors report mirrors the dismissive tone and tact adopted by NRW. It should be noted that within the PI proceedings NRW legal team stooped as low as to belittle objectors.
  • In our dealings with NRW it is very apparent there has been little compromise nor is there comprise within this report. At worst, the comments made are based on conjecture, in particular when it comes to ‘fishing’ matters.
  • There are a considerable number of erroneous statements made – therefore the context of numerous arguments is lost.
  • The phrase ‘Notwithstanding’ unfortunately weighs heavily upon us, as used re-iteratively within the report by the inspector it marks the pre-cursory signal that our evidence is to be given a superficial airing only to be superseded by statements reflective of NRWs own, backed up with varying degrees of substantiated evidence. 

Below are key elements of objector evidence, we perceive the report fails to substantiate and therefore fails to apportion requisite weight and influence in the formulation of conclusions and thus ultimately the inspectors decision upon the necessity for; proportionality of and how reasonable the byelaw measures actually are.

Aside from the above, in addition to the substantive evidence we provided at the Inquiry that the byelaws simply cannot be enforced, sources at NRW now indicate they are limiting their enforcement potential even further since the Inquiry to a mere handful of specialist fisheries enforcement officers across Wales. In the absence of regulatory enforcement the angling community currently sit between a rock and hard place, alienated from shaping their future however tasked with an unmanageable and obtuse workload.

The report omits to present critical objector evidence in appropriate context for the following:

  • Shortfalls and implications of 1) Stock Reporting 2) River Classification Model 3) Policy – Decision Making Process
  • Critical relevance of CPWF evidence as a contribution to future statistical reviews – (The very same evidence NRW legal team attempted to quash is now considered highly relevant to the ongoing process) this evidence underpins a number of the objectors arguments and was supressed
  • The River Classification Model underpinning NRW’s evidence – has not been peer reviewed and is not periodically reviewed. This leaves the system open to challenge.
  • The ‘precautionary principle’ is already built into NRWs statistical analysis – manual application of the concept beyond that stage creates an overly precautionary response.
  • Under NASCO Guidance all rivers in Wales should, formally be given the opportunity to achieve 90% return rates for salmon before mandatory measures are considered. This has not happened and is a failure of ministerial direction.
  • CPWF/angling community’s proposals for a community centric alternative to the byelaw measures, conducive with principles of sustainable management and well-being goals.
  • Progress made by the angling community – 86% return rate of salmon across Wales in 2016 – is treated as failure not success.
  • There are rivers within the 23 principal salmon rivers in Wales that are compliant year on year with their Conservation Limits (compliance with NASCO Management Objective) – mandatory measures should not be applied to them under the NASCO Decision Structure.
  • All rivers in Wales outside of the 23 principal salmon rivers are subject to the All Wales Byelaws order. This is in direct contravention of the NASCO Guidance and a contradiction that these are not, pan Wales byelaws as stipulated by NRW. This is clearly application of the organisations institutional preference and is contradicted by their approach to managing sea-trout stocks.
  • Consideration of rivers on a catchment by catchment basis – which is what the Inquiry has been stated to provide – has not been possible. This is illustrated by the blanket and generalised statements made in the report.
  • There has been a critical failure by NRW to ingrain considerations of well-being (WFG Act (Wales) 2016) and principles of sustainable management (Environment Act 2010) (achievement of well-being). In parallel to these statutory requirements NRW have not qualified the socio-economic; socio-cultural risks posed by these measures to community angling clubs and communities. No true evaluation of the byelaw measures has been made.
  • The mandatory byelaws are inequitable; unfavourable and infringe on people’s rights.
  • One of the principal reasons for disagreement between CPWF and the NRW is because their inaction and inability to manage other threats has led to stock decline on certain, but not all rivers.
  • Loss of salmon fishing methods will severely inhibit many anglers fishing for salmon under most water conditions.

Further detailed review of the report is contained in the document below.

The consequence of the above is to disable appropriate consideration and illustration of requisite evidence to make an appropriate decision upon the necessity for; proportionality; how reasonable the byelaw measures are and their enforceability.

Reflecting upon the perceived inadequacies of the process (Please see letter to First Minister – included – Originator Chris White CPWF) and weakness of the report to present a seemingly fair and balanced representation of fact and requisite decisions. It is with urgent necessity that we ask members of the Senedds Petitions Committee to make a stand for appropriate judicial and democratic process to prevail.

Without the angling community holding a pivotal role within the management of our fisheries and inappropriate and high risk byelaw measures in place we will all struggle to achieve meaningful progress. Many fishing clubs are currently fire-fighting the consequences of the Cabinet Secretaries decision – our resources are meagre and resilience challenged. Something has to change.  

Thank you for your attention to this matter.

On behalf of representatives from the angling community of Wales (petitioners),

Reuben Woodford

(Afon Ogwen Anglers/Petitioners/Working with CPWF)

   ………………………………………………………………………………………………………………..

Detailed consideration of the Inspectors Report:

{The Inspectors comments are underlined/italic Inspector}

[Our comments – bulleted]

548. [ Deviation from objective evidence at catchment scale] NRW accept that fishing effort i.e. rod days fished, are not taken into account in terms of estimations relating to compliance with Conservation Limit assessments…..In addition, NRW maintain, equally the impact of weather conditions can affect fish migration and angling effort.

However, notwithstanding any shortcomings, in this regard, based on substantive evidence available, it is apparent there has been, overall, a significant and sustained pattern of progressive decline in the majority of salmon and sea trout stocks in Wales.

  • Angler’s behavioural responses have become a key variable in the variability of stock assessment as an extrapolation of catch return information.
  • ‘Rod days fished’, critical to our understanding of the relevance of catch return data to actual stock is not considered by NRW.
  • Generalisation of the pattern of fish stocks in Wales for salmon and sea trout stocks distracts from the catchment by catchment and conservation limit focus necessary to be able to make proportional decisions on a catchment by catchment basis.

555. The electro fishing surveys carried out by NRW indicated a marked and widespread reduction in abundance of salmon and trout fry across a number of catchments in Wales.

  • Electro fishing surveys undertaken by NRW very rarely represent a widespread area of river catchment. It must also be recognised that the inspector’s statement only applies to a single years’ sample.
  • The report fails to state that in some catchments there was no marked reduction in abundance of salmon or trout juveniles and therefore there is the appearance of bias.
  • Without temporal context, there is no attempt to retain objectivity and balance in this statement – however there is apparent bias which suggests a far greater magnitude of phenomenon than the actual evidence illustrates.

558. Neither the above objections, or any others relating to data sources, provided substantive evidence to challenge the validity of NRW’s stock assessment data.

  • This statement has the appearance of bias.
  • The reader must be reminded that the ‘All Wales Byelaws’ Inquiry was responsible in part for considering evidence at a catchment scale.
  • The validity of objective data presented for individual catchments, has been denied by imposition of blanket generic statements.
  • Forming conclusions on this basis illustrates an intent to override a catchment view to this process; to deny the reader visibility of the catchment specific evidence that contradicts the broad brushstroke statements and an intent to ‘cover up’ evidence critical to assessing the proportionality of the byelaw proposals.

571. I would tend to agree with Mr Russell of NRW who expressed the view in oral evidence that ‘the absence of perfection doesn’t stop us acting in a precautionary way’

  • The absence of a fit for purpose stock assessment methodology however provides reasonable doubt that we should all be cautious in the actions we take, as overstepping the mark in terms of the severity of the response imposes additional risks to both the angling and regulatory systems.
  • As the Inquiry progressed and the inspectors report considers the ‘precautionary principle’, it appears the principle itself becomes an ever present all, consuming general rule of thumb that allows NRW to justify each and every decision it makes. The angling community do not oppose precautionary principles, however when the actions proposed are proven to be disproportionate to the evidence and counter to sustaining the resilience of fisheries and angling institutions, those actions in themselves can be seen to undermine the very system we are reliant upon.

574. [CPWF – Dublin Statisticians evidence] The above casts significant doubt as to the veracity of the evidence presented by the Dublin Statisticians via parties such as CPWF. Without significant evidence to indicate otherwise, I prefer the statistical testimony submitted by NRW whose three expert witnesses appeared before the Inquiry, as it was overall much more robust and justified than that of untested third party evidence given via objectors to the proposed byelaws.

  • It has to be questioned, whether the inspector’s ‘preference’ for one statistical testimony over another has any bearing on his personal ability to comprehend the validity of those calculations. The inspector was at full liberty to seek independent expert witnesses to enable fully objective scrutiny of the evidence provided by both parties and yet he chose not to utilise this option. Ultimately, his decision upon very complex and contentious statistical analysis was reliant on the narrative dictated by NRW’s legal team and not necessarily an objective critique of facts.
  • The time spent at the Inquiry by NRW’s barrister attempting to quash CPWF’s Dublin Statistician evidence was excessive and ultimately CPWF were prevented from presenting their evidence in entirety. Whilst the inspector had repeatedly throughout the Inquiry hurried members representing CPWF along, NRW were allowed an inordinate period over which to attempt to discredit a key element of CPWF’s evidence.
  • It is very hard to envisage, how, bias can be thwarted, when ultimately evidence is concealed by manoeuvres unfit for a public inquiry of this nature.
  • A critical fact of significant irony is not exposed by the report – that being, that the assessment process utilised by NRW and the EA in England is not quality assured and validated and both organisations are fully aware the stock assessment model must be revised.

576. Concerns raised by Mr Ashwin of CPWF and others were that NRW were not following NASCO guidance , nor that of its own, in terms of the procedure for the ‘Decision Structure’ for developing salmon fishing controls in Wales and England. That process, it is argued, requires in the first instance, voluntary measures to be adopted for these rivers – not mandatory measures.

  • The requirement for this staged approach is clear. It is unclear therefore why and how NRW have deviated from best practice guidelines.
  • The damage of not following this guidance is not only to bypass a means of empowering fishing clubs, but to leap frog forth into a high risk scenario with certain consequential impacts that NRW have on the basis of personal belief, chosen to play down and in some instances completely ignore.
  • Considerations of proportionality and well-being have been denied by NRWs ‘draconian’ response – the inspector in para 578 unwittingly divulges NRW’s exact tact:

578. The approach taken by NRW is broadly in line with the Decision Structure i.e. they have considered a range of options and then selected their preferred options.

  • NRW’s ‘preferred option’ of mandatory catch and release, which dictates crudely the method adaptions included in the byelaws has been common knowledge for many years.
  • The regulator’s query has always been ‘what should we ban’, rather than ‘what should we promote’.
  • Failing to make appropriate consideration of the proportionality of the measures and the likely consequential impacts upon current and future wellbeing over a transitional period (a statutory requirement placed upon them) has led to decisions not concordant with the decision structure, but mirroring NRW’s long standing ‘preferred option’. The ‘broad’ compliance with the decision structure referred to by the inspector becomes meaningless when behind that broad compliance sits a very specific failure to utilise it in a pragmatic way that assists in ironing out the dearth of problems this set of measures as a mandatory response delivers.
  • What is quite clear in para 578 is that the inspector has failed to grasp 1) the risks posed by the ‘All Wales Byelaws’ to fish stocks and community angling clubs and what they provide to communities and through ecosystem services; 2) the inherent problem of being compliant with C&R targets that have until now been vague, variable and poorly communicated.
  • There is no evidence ‘banning’ elements of fishing are going to result in positive outcomes. There is evidence, empowerment of anglers has wide ranging benefits. To suggest that the ‘precautionary approach’ by default equates to the byelaw measures is simply a misnomer and NRWs red herring of all red herrings reiterated by NRW’s legal and management team without proof of its validity.    

580 ….even if I had reservations about some elements of the statistical methodology employed by NRW , the entirety of the evidence base, would suggest the application of the precautionary approach…..would be prudent in terms of the interpretation of any data….

  • Given a key part of the evidence base provided by NRW is reliant upon a river (risk status) classification system that is proven to be very poor at predicting actual salmon stock status and which the inspector states he has reservations about, it defies logic, that the ‘entirety’ of the evidence base is then seen by him to prove the necessity to apply a precautionary principle.
  • It is quite evident from the reports consideration of the ‘precautionary principle’ that without exception, the byelaw measures as stipulated by NRW in their ‘preferred option’ are considered by the inspector as the only conceivable option which satisfies this requirement. This is simply not the case and it is a construct devised by NRW and substantiated by endless repetition rather than objective substance.

581 The proposed byelaws offer several solutions to the decline in fish stocks…..

  • This is an erroneous statement and a misnomer which has spread like wild fire throughout this debate, being erroneously stated on a number of occasions by NRW management teams. NRW themselves stipulate that the ‘All Wales Byelaws’ are not the solution to the decline in fish stocks. It is exceptionally hard to instil this fact.
  • It remains to be explained therefore why NRW have pursued this version of the byelaws to the extortionate cost, both time, money and resource of the organisation to the detriment of not providing a robust and holistic, course of action to tackling the causes of stock variability.  

589 Therefore, there is substantive and compelling scientific studies, in addition to first-hand anecdotal evidence that C&R is an effective management tool to maintain fish stocks and fisheries.

  • This is an erroneous statement – on two counts.
  • There is not clear evidence to illustrate that early season 100% mandatory C&R leads to increased salmon stock levels in Wales. There is substantive evidence which indicates the primary controls on salmon stock abundance are environmental controls/degradation.
  • The statement also seems to be suggesting that C&R as a stand-alone measure has the propensity to maintain fish stocks – it does not.
  • It is critical therefore that the proportionality of the byelaws is considered in true context and that C&R as a mandatory measure is understood fully in particular given as a proportional measure, it arguably carries greater ability to do widespread good and to support sustainable management principles. NRW’s approach deviates from a sustainable response because it focusses on an ideology which negates to consider the fundamental requirements of a system that retains functionality.

590 A common argument against the introduction of mandatory C&R was that most anglers already practice voluntary high levels of C&R e.g. the figure for 2016 is approximately 86%…..

  • The primary focus of NRWs argument to counter the implications of this statement is that all salmon should be returned to the water. It is not nor should it be, necessary for every salmon caught to be returned to the water in most rivers in Wales.
  • With reference to NASCO guidance, if there is a primary target to focus upon, then it is the 90% return rate. To class an 86% return rate by anglers on a voluntary basis as failure is disingenuous.
  • The action of returning a mortally wounded fish to a river to fester as a carcass lies beyond the moral compass of most if not all anglers and the public at large.

592 Allowing anglers the freedom to continue to intentionally kill those fish would further risk declining stock of these species, and would also introduce inequality between those who voluntarily practice C&R and those who do not…

  • Misleading statement – The primary causal factors of stock decline are perpetuated because of regulatory inaction to manage the environmental inhibitors to optimal fish stocks. The angling community do not seek the ‘freedom’ to kill fish, they seek the ability to apply a proportional system that sustains rather than undermines fisheries management.
  • Angling and the stock assessment system thrive on inequality.

Invariably, the primary inequality is not between those who keep and return fish, but between those who expend hundreds of hours to fish and return fish with the intention of keeping the occasional fish and the casual angler who contributes by a far lesser degree to the catch return statistic that allows NRW to attempt stock assessment. Without that inequality – NRW have no stock management system.

  • There are considerations of equality and fairness to be made, however these are only effectively managed and sustained at club and catchment level.

593 The proposed byelaws will establish a level playing field.

  • It has been illustrated that the byelaw proposals are un-enforceable.
  • NRW have now announced plans to disband most of their specialised fisheries enforcement potential.
  • The disparity between ‘obedient citizen’ and ‘hard-core poacher’ will widen.

596 [Hook Restrictions]

The proposed byelaws……

  • Erroneous statement

Hook size restrictions will reduce the chances of deep penetration and potential fatal injury…

  • Erroneous statement

Restrictions on the use of flying ‘c’ type lures……

  • Erroneous statement

600 [Ban on worm fishing – salmon]Objectors made no significant arguments to counter the ban

  • Erroneous statement
  • CPWF illustrated that it is impossible to fish certain spate conditions for salmon without use of the worm method. It is traditionally the most prized angling experience on the spate, rivers of North Wales. Fishing with worm for salmon is a traditional method applied under all water conditions and seen as a ‘fair method’ during low water conditions when spinning usually is not.
  • Adaption to the worming technique in an early strike makes this a highly favourable method in terms of limiting damage to fish.
  • Omission of this evidence in the report is unacceptable.

603 [Bunching of worms]

  • Comments made by the inspector are mere conjecture and make a mockery of the reports repeated reference to the inadequacy of angling representatives anecdotal evidence of methods they and they alone practice.

604 During the cross examination of Mr Gough of NRW by an objector, it was claimed small rivers can only be fished with worms, which in effect would preclude them from angling; Mr Gough’s experience indicated otherwise. I suspect the reality is the effectiveness of fishing such rivers without worm bait is very much down to the skill of the individual angler.

  • Given Mr Gough has as far as we are aware very little if any angling experience, it is apparent this conclusion is drawn upon the basis of predominantly conjecture.
  • There are hundreds of small rivers across Wales which sit outside of the 23 principal Salmon rivers, and yet without explanation apart from a general intent to include them under a ‘precautionary principal’, they are subsumed by the byelaws.

607 In terms of justifying the use of shrimp/prawn to after 1st September, NRW highlight that for a reason currently unknown, salmon will take a shrimp in warm water conditions……

  • Salmon will take any bait/lure under summer conditions if it is presented well. Worm and crustacean baits have the advantage of being naturally alluring to salmon.
  • This element of the byelaws defies logic when considered in context.

.. there was no substantive evidence to challenge NRW’s approach.

  • Erroneous statement

608The overall approach to the use of shrimp/prawn is measured and proportionate.

  • This regulation constitutes a ban on bait fishing for salmon for at least 4 months of a 5.5 month season on average.
  • Most fishing with shrimp/prawn is undertaken in the spring and summer months.
  • The conclusion drawn is based upon erroneous evidence.

611 [Sea-trout slot limit 60cm]

  • Deviation from an evidence based/catchment specific justification for the byelaws.
  • The opportunity to take a ‘trophy fish’ of any kind (traditionally the greatest draw to angling for migratory species) is denied in entirety by this additional step.
  • Science contradicts the importance of these fish stipulating they have done their work (genetically).

613 [Striking a balance – nets/rods]

  • Deviation from an evidence based/catchment specific justification for the byelaws – rivers without nets.

614 [General poor state of sea trout stocks]

  • Deviation from an evidence based/catchment specific justification for the byelaws.

624 [Equality considerations] As regard the ban on worm fishing for salmon, it is argued this would affect people with physical limitations who are not able to fish with either a fly or spinner; this was deemed to be indirect discrimination under the Equality Act 2010.

626 [Adaptions to Byelaws]

  • The adaptions to the byelaws do not mitigate the consequence of ‘indirect discrimination’ imposed upon salmon anglers with physical limitations during the majority of the fishing season.

Furthermore, less physically able anglers would still be able to continue to use bait for coarse fishing which is unaffected by the proposed byelaws.

  • North Wales Rivers are primarily not coarse fisheries.
  • In context this statement implies that less physically able anglers can go elsewhere for their fishing experience – this appears to be direct discrimination against less physically able anglers.

All these measures are a proportionate response given the current state of sea trout and salmon stocks in Wales.

  • Blanket approach.
  • Apparent false justification of discriminatory decision.
  • Deviation from an evidence based/catchment specific justification for the byelaws.
  • This statement does not appear to be appropriate to this paragraph

631 [Enforcement]

I accept there may be challenges to effective enforcement however that is not a defence to doing nothing at all….

  • NRWs statements are given president over CPWF evidence
  • There is substantive evidence to illustrate that the byelaws are not enforceable
  • The unenforceability of the byelaws alone illustrates the non-functional scenario presented to WG
  • The alternative option is not to ‘do nothing at all’. The alternative is the option presented by CPWF to empower angling clubs to optimise sustainable angling practices on their waters

632

I have no reason to doubt the proposed byelaws would not be generally accepted and complied with as per previous byelaws…

  • NRWs statements are given president over CPWF evidence. Critical CPWF evidence is not given exposure.
  • Significant evidence was presented by representatives of CPWF illustrating barriers to the enforceability of the byelaws, not least opposition by the majority of anglers.

635

..there is still a preponderance of other licensed anglers, riparian land owners, other members of the public and other agencies who would still be on the river banks and be likely to report incidents

  • The preponderance of evidence from the angling community does not substantiate this position.
  • The byelaw process has not only alienated the angling community, but many rural communities in Wales.

636 [Socio –Economic Impacts]

  • NRWs statements are given president over CPWF evidence. Critical CPWF evidence is not given exposure.

637 [Socio – Economic Impacts] NRW’s consideration of the socio-economic impacts of the proposed byelaws is detailed in several documents, contrary to the view of a number of objectors who indicated otherwise.

  • The risk to community angling clubs has not been qualified
  • Without the necessary consideration of the direct and indirect consequences of the byelaws, the socio-economic; socio-cultural and thus all well-being considerations cannot and have not been made.
  • Whilst NRW argue over the net worth of angling to Wales at a macro scale, localised impacts and the long-term resilience of clubs remains the key concern to local volunteers fire-fighting to sustain community clubs – the means of access for local anglers to local waters.

641 I concur with NRW’s viewpoint that if nothing is done to eliminate the intentional killing of fish, whilst other initiatives to improve freshwater habitats are pursued, then the timescales for stock recovery will inevitably be prolonged.

  • There is clear evidence that the angling community in Wales have progressively adapted angling practices in a proportional manner to protect vulnerable stocks of salmon and sustain the resilience of angling clubs.  
  • The primary limitation upon stock enhancement is arguably inactivity by NRW and its legacy organisations. As Peter Gough (head of NRW fisheries and NRW manager behind the byelaws) stipulated at the inquiry, catchment improvements would only come to fruition if river restoration plans did not sit on the shelf within an organisation that is clearly resource poor.
  • The byelaws are not a proportional response in relation to the evidence nor the current level of progress made by NRW to restore environments capable of sustaining optimal smolt production.

644

[angler tourism/tourism impacts]

  • Critical CPWF evidence is not given exposure.

645 Overall in terms of the socio-economic impacts of the proposed byelaws, I prefer NRW’S evidence…

  • The All Wales Byelaws impose a risk to community angling clubs.
  • NRW do not have evidence to illustrate the risk or means of mitigation to manage the short to medium term impacts on clubs through lost members and the consequential impacts that brings.

646 [Other measures to address the decline in fish stocks]

  • There is a significant gap between the progress aspired to by NRW and actions on the ground.
  • As indicated at the PI NRWs reputation for developing weighty strategic plans over meaningful outcomes is clear – The State of Natural Resources report (SoNaRR).

650 NRW maintain that if the other measures were pursued in the absence of the proposed byelaws, then there is a risk that on-going catch and kill fishing would increase the risk of further decline of stocks, as the on-going depletion of spawning reserves would continue.

  • On a catchment by catchment basis there is no guarantee other measures will be pursued. (these are catchment by catchment byelaws) As Dr Mawle stipulated at the PI the byelaws serve little purpose if the other habitat improvements are not achieved.
  • The current level of kill by anglers (2016 figures) represents a mere 4% shortfall in the ideological NASCO set threshold. It is not angling with rod and line that poses the significant risks to fish stocks.

652      [Statutory purposes of NRW]

  • The report omits critical CPWF evidence which illustrates NRW has failed to promote:
  • The Sustainable Management Principle
  • Well-being considerations in line with the WFG Act
  • The byelaws pose a significant risk to economic prosperity; socio-cultural/amenity values; health and participation; evidence and analytics; future partnerships and prevention of illegal activity. NRW have played down these risks and undertaken no meaningful risk assessment. Well-being considerations have simply not been ingrained in this process, thus allowing NRW to engineer measures they falsely claim have little consequence in the short term and will bring well-being benefit in the long.
  • The Well-being Act, interprets ‘Sustainable Development as the process of improving well-being.’

This is our joint aim and NRW’s responsibility under ‘the WFG Act’.

As NRW have developed measures that illicit ill-being, then this is not ‘sustainable development’ and those measures through definition should be deemed inappropriate.

653      Despite the reservations of some, there is no substantive evidence to believe that NRW or others would not actively pursue the range of other measures referred to above, particularly bearing in mind its duties under the aforementioned statutory framework.

  • Various NRW managers/technical specialist at the PI indicated the organisation is currently hamstrung by resource deficit.
  • NRW stipulated at the PI they did not have a requirement to consider all 7 well-being goals as stipulated under the WFG Act – No evidence was provided to substantiate this position.
  • SPFST – Core Guidance Document WFG Act – Stipulates  in terms of ‘well-being considerations’ – this is ‘about complex , but real world interconnections between our environment, our economy, our society and culture.’ Without due consideration for the limitations posed by the byelaws, NRW have applied certainty to the ability of these byelaws to stimulate stock recovery and improve future well-being.’ Neither assumption is evidence based.

658      In any event irrespective of the impacts of avian or other predation on Welsh salmon and sea trout fish stocks, the fact of the matter is that those fish are generally in a very vulnerable state, and the deliberate killing of fish is unsustainable and contributes to the problem albeit to a more modest extent. 

  • Erroneous statement
  • Why if this is the case, has gathering evidence in relation to natural predation impacts been an afterthought? Failure to apply proportional response.
  • CPWF evidence supressed. Catchment specific evidence supressed.

661      The proposed byelaws would also apply to a modest number of other non-principal salmon rivers. NRW accept that the inclusion of these other non-principal rivers in the proposed byelaws may give the appearance of a blanket approach.

  • Erroneous statement
  • Clear indication of misuse of precautionary principle – inclusion of all these rivers is a failure to comply with the NASCO Decision Management Structure.
  • This is a ‘blanket approach’.
  • Catchment specific evidence supressed – Ogwen and other rivers exceeding CL year on year in compliance with NASCO Management Objective.
  •  
  • Erroneous statement
  •  
  • Erroneous statement

665      I do not consider direct parallels can be made between NRW’s approach as advanced in the proposed byelaws and that of equivalent agencies in other jurisdictions.

  • NASCO Guidance has not been complied with.
  • The Environment Act/ WFG Act places greater onus on Wales to consider sustainable principles and thus well-being considerations (social, economic, cultural & environment) in the short, medium and long term with the focus on parallel advantages to all. The consequential impacts of the byelaws illicit ill-being.
  • Wales is being put at disadvantage to other jurisdictions.

667 [NASCO Guidance; Conservation Limits; Allowable Angling Practices]

  • NASCO Guidance has not been complied with.

671      Objectors…..considered their views were simply ignored and that the outcome was a fait accompli.

  • There has been no meaningful attempt to reach consensus.
  • Minutes of Local Group Meetings used as evidence at the Inquiry were bias and censored and thus non representative of proceedings during the consultation period.

682 [10 year byelaws; 5 year interim review]

  • The 10 year period compounds the negative consequences of the byelaws.
  • No details of the interim review have been made publicly available.

684 I am satisfied the byelaws have been progressed on a sound legal basis and in accordance with the principles of natural justice, with all interested parties given the opportunity to present their case.

  • Reference – Letter Chris White to First Minister – Copy Included

685 NRW who have assessed the impacts of the proposed byelaws on those likely to be affected in a proportionate manner.

  • Erroneous statement
  • NRW have not assessed the impacts of the byelaws

688 (Well-being Goals)

  • This has not been done by NRW

689 (Well-being Goals)

  • No evidence was presented to substantiate this statement – CPWF presented evidence to illustrate that ill-being is being stimulated by lack of appropriate consideration of well-being goals within this process.

695      There was no convincing arguments that the raft of measures contained within the proposed byelaws were not appropriate, reasonable and proportionate.

  • Critical CPWF evidence is supressed and given undue consideration within the report.
  • Critical CPWF evidence was supressed and given undue consideration within the Inquiry.

697 It should be noted that the proposed byelaws would affect only about 15% of anglers…

  • Erroneous and misleading statement
  • The future of angling on Wales Rivers is at risk – without a fishing club, an angler can invariably not fish.

698      It is only reasonable therefore that anglers and nets men play their part in the solution.

  • NRW and the report are highly disingenuous to the part the angling community already play in instigating sustainable practices.
  • The CPWF proposals for a workable way forward have been given little if any coverage within the report. Anglers aspired way forwards is thus supressed and ousted from consideration.
  • Anglers are a critical component of a progressive means of developing improvement in fisheries – the PI and the report confound the alienation of the angling community from this arena.
  • There has been no attempt by NRW to reach a point of consensus.

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