Last update: 24th September 2020

Chris White: still seeking the truth

Conservation Officer

Chris White

57 Normanby Drive Connahs Quay Flintshire

CH5 4JX

Email:chriswhite.cohite@gmail.com

Chris White

24 September 2020

Deputy Minister for Housing and Local Government (via email)

Re: 14 Sept Press release: ‘Funding boost for the great outdoors’

Dear Minister,

I note in a press release of 14 September 2020 that you say:

“£337,000 has also been awarded to eleven projects to improve recreational access to water ”

I have been unable to find any information about these projects on the Welsh Government website despite extensive searches.

I would therefore request under the Freedom of Information Act details of the location of these eleven projects, individual costs/benefits for each project and time scale for completion.

Regards

Conservation Officer: Campaign for the Protection of Welsh Fisheries

The following sad letter speaks for so many anglers in Wales

It has taken me some time to publish this touching letter from John Eardley, an angler who has worked so hard with NRW and the EA before that, as well as with fellow angles.

To say that John’s resignation from the North Wales River Trust, as well as from his “second home” in Wales, is a tragedy: he will be much missed. Thanks for all your hard work John. I have no words to adequately describe my feeling at loosing John from the Welsh campaigners, but have no doubt that we have more to hear from him. Don’t let the *.* grind you down John!

Dear Alan and fellow Operations Group Colleagues

It is with great sadness and regret that I write to inform you that I can no longer continue in my role as secretary of the North Wales Rivers Trust. I feel that everyone needs to know the full reasons behind my decision and hopefully my letter will bring some understanding of what has led to that decision. I will continue in my post until you are able to find a replacement and would like to attend the next meeting to say my goodbyes formally although Covid 19 may intervene on that front.

It is nigh on 60 years when, armed with a hand me down tank aerial rod, I first cast a worm (unsuccessfully!) into the Mawddach and so began a love affair that I thought would last for ever; sadly that has proved not to be the case. This is my 40th year of having a permanent base at Y Vanner on the banks of the Mawddach but sadly it will also be my last having made the decision to sell our caravan and replace it with a tourer which will enable me to explore areas of North West and North East England where I have access to a number of rivers and a free choice as to which angling methods I choose to use. Sadly the method restrictions within the All Wales Bylaws mean that the majority of the Upper Mawddach and Wnion are now extremely difficult to fish by legal means and, given the difficulty of returning fish ethically and safely, those magical places, never even seen by those responsible for the current debacle, will now be consigned to my memories. The final nail in the coffin is the fact that I have lost every single fish that I have hooked this year on single hooked spinners, an all too common experience for the majority of anglers. For NRW to suggest that the bylaws will make little difference to anglers is an endorsement of just how out of touch with the angling community the organisation has become. It is more than a little ironic that a place that was once such an exciting escape from the pressures of a busy working life has, in retirement, become a place of hopelessness and despair.

When I first represented Prince Albert Angling Society at the Gwynedd LFG it was yourself and Julian Bray who were responsible for fisheries in North Wales. There was a feeling that our voices were heard and in the case of the Mawddach we felt that we were making progress. A genuine spirit of partnership and cooperation, for example with broodstock collection and the stocking out of juveniles, strengthened the working relationship between Environment Agency Wales and PAAS to the benefit of all concerned. Sadly that is the very antithesis of what has happened since the creation of the single body that is NRW. I was also inspired by the work that Chris White and Roger Thomas were undertaking within both the Conwy Valley Fisheries and Conservation Association and the Clwyd and Conwy Rivers Trust and that gave me ideas of just what might be achieved on the Mawddach. I would also like to thank Robin Parry for not only being the calm “voice of reason” as chair of the Gwynedd LFG but in particular for his work in primary schools with the “Finding Torgoch” project. Education is key to our future and in order to do that we have to listen and learn from what others have to say. Kat Marshall has also been a constant source of support.

I would particularly like to thank Rich White for his inspiration, enthusiasm and guidance in initial habitat improvement works within the Mawddach catchment. During an impromptu conversation at a Dee Fisheries Association meeting I expressed envy at the work that had been carried out by the Dee Trust on the Rhug Estate and also works that I was aware of that had been undertaken by the then Clwyd and Conwy Rivers Trust. Rich told me that Afonydd Cymru could carry out works on rivers that were not part of a trust. Following a full day visit to the Mawddach & Wnion we hatched a plan to use volunteer labour from anglers to survey some of the feeder streams using WFD criteria and that these would then inform future sites for habitat improvement works. Volunteers were given basic training and the data gathered was presented in the form of annotated maps, photographs and tables accompanied by a brief written description. I strongly believed that this educational process of visiting parts of the catchment that so many anglers were unfamiliar with would change the way in which anglers view both the river and also the fish that they catch lower down the system. Our efforts received a very positive reception in the Bangor Office and a number of gravel traps were constructed in the Afon Wen. To say that we were delighted when 6 redds were observed on the traps later that year is an understatement. I am afraid that when our knowledge of our own catchment was described by NRW’s Principal Fisheries Advisor at the Bylaws Inquiry as no more than “knowing where the stiles and footpaths are, how to get to the river…” it caused irreparable damage and highlighted the lengths that NRW will stoop to in order to get their own way. That the Inspector believed it speaks volumes about the whole sorry saga.

If it could be demonstrated that the Bylaws were likely to result in any significant improvement in fish stocks and were accompanied by annual reviews they might have been slightly easier to accept. However NRW’s figures show that they will make a negligible difference to the Mawddach system when a recent 5 year average catch of more than 50 salmon and an exploitation rate of 10% would indicate a run size of around 500 salmon p.a. of which 50 are caught on rod and line. However given a return rate in excess of 80% the entire loss due to angling is no more than 10 salmon. The recent NRW email footer “Even relatively small numbers of fish are crucial to recover stocks in as short a time as possible. Every spawning fish matters” is at odds with discussions we have had at the Trust about how, given good habitat and careful management of predation even a relatively small number of salmon can quickly repopulate a spawning stream. In addition NRW’s stock assessments do not reflect what we actually observe in the Mawddach & Wnion and that is also a constant source of frustration. I can only wonder what magic algorithm will be conjured up to account for the large number of fish hooked but no longer landed.

I find it difficult to see how our fisheries can recover from the impacts of what has been foisted upon us. Willing volunteers have left the Mawddach and Wnion whilst those who remain have been well and truly alienated. My own enthusiasm and optimism are now at rock bottom and I suspect that I am not alone when I see just how sparse the current circulation list is for the Gwynedd and Dee LFG’s. Time is not on my side and I am unwilling to wait for the outcome of an interim review of the Bylaws in 5 years’ time and in any case it is difficult to envisage any significant change when the extraordinary lengths that NRW went to in order to secure a legislative solution are taken into account.

I have the greatest respect for everyone at the Trust and wish all of you the very best for the future. I cannot spend my time reflecting on what might have been and so with a heavy heart it is time for me to move on.

Yours sincerely

John Eardley

Another serious pollution and fish kill!!

Dead fish on the affected stretch of the River Llynfi, mid-Wales

Fish Legal is currently advising its members Gwent Angling Society in respect of a major pollution that has hit the River Llynfi in mid-Wales. Literally the day after the last touches were carried out to a remediation project that saw the river put on the road to recovery after a devastating pollution in 2016, yet another wave of pollution saw the obliteration of fish and river life for at least 5 kilometers.

The cause of the latest incident has not yet been confirmed by Natural Resources Wales who are investigating, but what is beyond doubt is the terrible and deadly effect on this Welsh tributary of the River Wye, with tens of thousands of dead brook lamprey, grayling and trout among the casualties.

Clare Pillman replies to John Eardley

Ein cyf/Our ref: CX20-145 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

By e-mail: johneardley@btinternet.com

Ffôn/Phone: 0300 065 4453

29 July 2020

Dear Mr Eardley,

I hope that you and your family are keeping safe and well during these difficult times. Thank you for your letter and observations, we note your continued concerns.

I do not underestimate the changes that are required following the decision taken by the Minister to confirm the fishing byelaws. However, as you know, we are clear that such controls are warranted. For maximum impact, these changes to angling need to work alongside wider measures and action across Wales and this is underway.

I continue to emphasise the importance of working proactively with a range of partners. Despite the challenges involved in changing practices we must work collaboratively if our goals are to be met.

As stated in our ‘Plan of Action’ there is a range of initiatives underway. We are also committed to annual assessments of stocks and a mid-term review of the new byelaws in 2024.

I look forward to working with all our partners to tackle the challenges and seize the opportunities associated with improving and sustaining resilient environments for our iconic fish populations for many years to come.

Best wishes,

Clare Pillman

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

Will Bayer settlement clean up Monsanto's PCB contamination in Wales? Details Published: 10 July 2020

Rev Paul Cawthorne says some of Bayer’s USD650 million given to polluted sites in the US should be used to remediate Monsanto’s toxic legacy in the UK

Following the announcement of a USD650 million settlement by Bayer, destined for areas of the US contaminated by the company’s subsidiary Monsanto with toxic chemicals known as PCBs, GMWatch subscriber Rev Paul Cawthorne has been looking into whether any funds from the settlement will be coming to the UK to clean up Monsanto’s PCB contamination in Wales.

The PCB contamination scandal was investigated in The Ecologist’s Monsanto Brofiscin Files in 2007.

Leaky chemical drums at Stoneyhill



Rev Cawthorne told GMWatch, “It is estimated that many thousands of drums of a wide variety of toxic chemical wastes, including PCBs, PNCBs and acids, were deposited at a number of former quarry waste disposal sites along the Welsh border and near the South Wales coast. Some of these drums will have originated from the former Monsanto factories at Newport and Ruabon. Photographic evidence from a UK site shows drums being deposited off the back of a lorry and empty drums which appear to be evidence of leakage due to split or corrosion. Leaking drums was an international problem for Monsanto, as acknowledged by its own employees.

“Toxic leachate into local ecosystems has been revealed at many of the sites, though only Brofiscin, in South Wales, has so far been fully publicly investigated and remediated at an undisclosed cost. Waste production and disposal sites highlighted by ENDS Report, The Ecologist magazine and local residents include Brofiscin, Maendy, Glebelands and Penrhos in South Wales, several near Ruabon, Sutton Walls in Herefordshire and Stoneyhill near Telford – most of them near watercourses, including the major rivers Severn and Dee. Key lorry manifests for one site, which I studied at the Environment Agency Shrewsbury office a decade ago but have now gone missing, confirm the detail.  

Leachate at Stoneyhill



“Has the UK even included the buried piles of waste PCB stocks in its national inventory within the Stockholm Convention? Several of these sites are, bizarrely, not even yet categorised by local authorities as Contaminated Land, despite a statutory duty to assess them.”

Rev Cawthorne has written to Clare Pillman, the head of Natural Resources Wales (see the text of the letter below), asking for clarification as to whether the USD650 million settlement includes provision to clean up bioaccumulative PCBs in the UK.

According to Rev Cawthorne, freedom of information requests have revealed that PCBs are still discharging into the sensitive Severn estuary from Monsanto’s former PCB manufacturing site at Newport. An investigation at Maendy Quarry, promised in Parliament in 1973, is still reportedly unknown to the local council. There remains a worrying fenced-off open toxic lagoon at Llwyneinion, near Ruabon, which caught fire in 1980. Groundwater contamination at Sutton Walls has led to local borehole closures.

Rev Cawthorne adds that the permeability of some site linings and cappings, as well as toxic discharges, such as those at Maendy and Newport, mean that Monsanto’s toxic bioaccumulative legacy in the UK continues to seep into water courses and estuaries, potentially impacting top marine predators and anyone who consumes fish and shellfish from these areas. He says, “Serious remedial action must be taken.”

Rev Cawthorne concludes with a question: “Until proper public accountability is shown, is Bayer’s ethical duty discharged?”

John Eardley still fighting for anglers in Wales

“Ty Newydd”4, Little Moss Lane Scholar Green Stoke-on-Trent ST7 3BL

13th July 2020

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

All Wales Byelaws – the impact on angling

Dear Clare,

With the lifting of travel restrictions in Wales on 6th July and the prospect of favourable river conditions I prepared myself for my first trip of the season. Of course much of my fishing tackle was no longer legal in Wales and I was faced with the prospect of changing all of the hooks on my lures. Research revealed that hardly any companies state the gape size of their hooks and with such variations in the market place it was something of a lottery to ensure the hooks I purchased were legal. Furthermore the cost of suitable hooks varied between 35p and £1.25 each. Nevertheless I made the necessary changes to a few of my lures

although a huge number of hooks still need to be purchased if the rest of my lures are to be legal in Wales.

I ventured to the Afon Dyfi last Wednesday to find a river in perfect condition for spinning and it was then that the harsh reality of the current situation really hit home when, without exception, I failed to land any of the numerous sea trout that I hooked. It is true that an angler will always lose some of the fish that they hook but when “some” becomes “all” angling becomes something of a pointless exercise. Of course I should not be surprised by the outcome given that no parent would purchase a tricycle for their child, remove two of the wheels and then be puzzled why the child kept falling off.

During the day I spoke to 2 other groups of anglers. The first was a father fishing with his 3 sons. They had fared slightly better than me in that they had at least managed to land one of the fish that they had hooked during the day. The second father and son team had landed 6 sea trout between them, the reason for their success being immediately obvious for they had chosen to disregard the byelaws and were both using treble hooks on their spinners. I wonder which of the 4 youngsters will be keenest to head back to the river.

When the river cleared and I changed to fly fishing I did at least manage to hook and land a fish successfully. However you must realise that not every angler is able to fly fish and for those people life is going to be very difficult indeed, particularly when allied to the restrictions applied to worm fishing.

It is very clear to me that yet another angling technique has been rendered all but ineffective in Wales. To achieve any degree of success in the future the options would appear to be either be prepared to be criminalised for disregarding the byelaws or else fish elsewhere in the UK where a more reasonable approach has been taken to method restrictions. To endure the current restrictions for 10 years is a bleak prospect, particularly when it is recognised that anglers are not the cause of the problem. However I am fully aware of what the intransigent response is likely to be in response to any request for an early review of the byelaws.

There is also a serious implication for the already deeply flawed stock assessments if large numbers of fish that would previouslyhave been landed are now lost and hence fail to be recorded on catch returns. Depressed catches will no doubt be attributed to a lack of fish in the river rather than the impact of method restrictions and result in yet further restrictions on anglers. I note that in the Plan of Action the Provisional Sea Trout Stock Assessment for the Dyfi in 2023 is PaR (Probably at Risk). The numbers of fish I witnessed on Wednesday would indicate that nothing could be further from the truth but then again senior fisheries staff would have to actually visit the river in order to know that.

I realise that my letter is unlikely to elicit any positive response but it would be remiss of me not make you fully aware of the farcical situation that legitimate anglers are now having to endure in Wales. The future is indeed grim and that has nothing at all to do with any shortage of fish in most of the rivers that I am familiar with.

Kind regards

John (Eardley)

Mark Isherwood A.M. continues to support anglers: reply from Lesley Griffiths.

Lesley Griffiths AS/MS

Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs Bae Caerdydd • Cardiff Bay Caerdydd • Cardiff CF99 1SN Canolfan Cyswllt Cyntaf / First Point of Contact Centre: 0300 0604400 Gohebiaeth

.Lesley.Griffiths@llyw.cymru

Correspondence.

Lesley.Griffiths@gov.wales

Rydym yn croesawu derbyn gohebiaeth yn Gymraeg. Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg ac ni fydd gohebu yn Gymraeg yn arwain at oedi. We welcome receiving correspondence in Welsh. Any correspondence received in Welsh will be answered in Welsh and corresponding in Welsh will not lead to a delay in responding. Ein

cyf/Our ref LG/01462/20 Mark Isherwood MS

Mark.isherwood@assembly.wales 29 June 2020

Dear Mark Thank you for your letter of 8 June, regarding potential pollution issues to our rivers. The Welsh Government’s commitment to address pollution from agricultural practices and the decline in biodiversity requires decisive action before it is too late. I published draft regulations on 8 April with measures to tackle the unacceptable level of pollution from agriculture in Wales. Clean water and a healthy environment are essential for life in Wales and tackling pollution from agriculture is a priority. Insufficient slurry storage is one of the largest causes of agricultural pollution which continues to have a detrimental impact on waterbodies across Wales. Measures to protect the environment are clearly necessary. The proposed regulations represent a significant increase in the management of agricultural practices across Wales which reflect the seriousness of the present situation. The draft regulations are for information only at this time and any decision on the implementation of regulatory measures to address agricultural pollution will be delayed until after the Coronavirus (COVID-19) pandemic. The draft regulations and an explanatory note have been published on the Welsh Government’s website here. The Welsh Government recognises a strong rural economy is essential to support sustainable and vibrant rural communities. The establishment of new enterprises and the expansion of existing business is crucial to the growth and stability of rural areas. Planning Policy Wales recognises, however, care should be exercised when considering intensive livestock developments when these are proposed in close proximity to sensitive land uses. In particular, the cumulative impacts (including noise and air pollution) resulting from similar developments in the same area should be taken into account. The establishment of the Town and Country Planning Intensive Agriculture Working Group is intended to look at how the challenge can be met. The Group has been looking at what evidence is needed to plan for intensive agriculture development. The work will help develop a draft Technical Advice Note (TAN) for public consultation as soon as possible, which will address the level of information applicants will need to provide to support planning applications. The TAN will help to inform planning decisions benefiting both the industry and local communities. Meanwhile, you may be interested in a consultation being undertaken by NRW which is specifically examining their guidance for carrying out Ammonia and Nitrogen assessments for farm developments require an Environmental Permit or Planning Permission (NRW Guidance Note GN 020). The consultation documents can be found at https://naturalresources.wales/guidance-and-advice/environmental-topics/consultations/ourown-consultations/changes-to-guidance-for-assessing-the-impact-of-ammonia-andnitrogen-from-agricultural-developments/?lang=en The consultation closes on 31st August 2020 and I would encourage you and your constituents to make your views known. Regards Lesley Griffiths AS/MS Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs

Access to Inland Waterways: Welsh Government Outline Policy Intent

National Access Forum

05/11/19

This paper is intended to provide clarity on the Welsh Government’s preferred direction of travel for access to inland waters for recreation purposes. It provides some recent background and context but is not intended to re-produce the detailed history which has been comprehensively documented.

Background

Welsh Government is considering the introduction of legislation to provide for wider access to the countryside for the purposes of recreation.

The proposal to extend Part 1 of CRoW Act access land provisions to rivers and other inland waters (Proposal 14) was contained in the 2017 Sustainable Management of Natural Resources (SMNR) consultation and has created polarised views. https://gov.wales/taking-forward-wales-sustainable-management-natural-resources

Other Access proposals potentially with a direct or indirect impact in this area are:

  • Proposal 11 (removing certain CRoW Schedule 2 restrictions)
  • Proposal 16 (responsible recreation applying to on water as well as on land)
  • Other proposals to make changes to Rights of Way legislation may impact on access across land to inland waterways

A number of responses were received in favour of legislating for access to water for non-motorised activities, including canoeing and swimming.  Many water sports users argue strongly that they already have a historic legal right of navigation on rivers, however, many anglers and other fishery interests refute these rights of navigation; purporting open access to inland waters would create inequality because of fishing licence fees, land ownership and riparian rights, as well as suggesting detrimental environmental impacts to spawning and subsequent fish stocks.

There are currently no general statutory public rights of recreational access in or on inland waters in Wales and very little common law.  Fishing and water sports both deliver significant tourism, socio-economic, health and wellbeing benefits for Wales.  Introducing public rights of access to rivers and other inland waters would provide greater clarity to all users; however, it would have a range of impacts as well as attracting opposition from many sections of the angling community, land managers and land / riparian owners.

Since 2009, the Welsh Government has advocated voluntary access arrangements (VAAs) and supported the use of these and other opportunities on inland waters through the Splash funding scheme (2008-2014). However, there continues to be friction between different stakeholder groups, with a limited number of VAAs currently in place. 

Current Position and wider policy intent

The Deputy Minister, in her Written Statement of April 2019, which framed the Welsh Government approach to the SMNR Access proposals, stated that:

  • ‘Our Natural Resources Policy illustrates that nature-based solutions can support physical and mental health.  That is why we are committed, as a Government, to increasing both access to and enjoyment of our countryside for people – to take advantage of the many health and wellbeing benefits that getting outside can bring.
  • An accessible countryside supports our efforts to boost Wales as a tourism destination and an attraction for walkers, cyclists and thrill-seekers.’

The Deputy Minister has announced the creation of an Access Reform Advisory Group (ARAG) to look in detail at a number of the Access proposals within SMNR. Others will be progressed by officials with some more limited scrutiny by ARAG.

The need to treat Proposal 14 separately to the main Access Reform processes was also set out in her Written Statement: “I will also be asking the National Access Forum to give particular priority in 2019 to laying the ground work for the greater dialogue on inland waters issues that is needed.  I strongly encourage stakeholders to find a practical joint solution.  I have not ruled out future legislation on access, particularly should I not be satisfied of reasonable progression within 18 months.”  

Policy Intent for Access to Water

It is clear that the Deputy Minister wishes to see concerted, collaborative action taken by stakeholders to increase recreational access to inland waters, including the following outcomes:

  • Increased and more frequent participation, across a range of recreation types
  • More inland waters accessible, more of the time

In working towards these outcomes constructive engagement should be facilitated.

The timescale for assessment of action against ministerial aspiration is determined by the remit of ARAG, with clear, identifiable evidence of progress towards Welsh Government’s aims by March 2021. NAFW will report the outcomes of its sub-group discussions, and associated conclusions and recommendations.

To allow for a climate of open debate, legislative proposals will not be introduced within this period.

Principles of Engagement

Discussions should be led by and driven by stakeholders. However, these discussions may need to be initially facilitated by Welsh Government and NRW as its statutory advisers on access matters.

A sub-group of the National Access Forum should be created comprising a balanced representation of different interests including anglers, canoeists, landowners and public bodies.

This group will be tasked with assessing different options to increase access, while respecting differing views and interests, demonstrating evidence of progress and reporting back to the NAFW regularly.

An initial facilitated meeting will be chaired by WG and NRW to ensure formation, remit and chairing of the sub-group is agreed at the first meeting. A document agreeing this will be produced after the facilitated meeting and agreed by members at the first subsequent meeting of the sub-group.

The areas for discussions and possible options should be agreed at the first facilitated meeting.

These options should then be discussed further and tested against criteria used by the wider Access Reform Programme, namely:

  1. Extent of access
    1. Quality of access
    1. Permanency
    1. Clarity and Certainty
    1. Cost
    1. Monitoring and Enforcement
    1. Equity of Access
    1. Greater efficiency and transparency

Options may focus on extending the coverage of waters covered by VAAs via different means, and legislating for limited access such as named rivers, seasonal access, access based on river level, or other ways of targeting access provision to have most benefit.

The sub-group could also focus on actions and initiatives likely to promote greater co-operation and consensus between different user groups, such as those focussed on monitoring or improving the health of rivers.

For this process the sub-group is not being asked to consider:

  • A ‘do nothing’ option
  • Legislation for a general statutory rights of recreational access

Meeting note Wales Fisheries Forum Date of Meeting: 9 th April 2020

Venue: Skype Present: David Mee (NRW) Emma Keenan (NRW) Patrick Lindley (NRW) Peter Gough (NRW) Robert Vaughan (NRW) Steve Ormerod (Chair, NRW) Adrian Simpson (Countryside Alliance) for Rachel Evans Alan Winstone (Afonydd Cymru) Chris White (Campaign for the Protection of Welsh Fisheries; North Wales LFGs) Creighton Harvey (SW LFGs) Dylan Roberts (Game & Wildlife Conservation Trust) James Legge (Countryside Alliance) John O’Connor (Angling Cymru) for Carl Tonner Julian Bray (Welsh Government) Mark Owen (Angling Trust) Mark Tilling (Welsh Government) Nicola Teague (IFM) Paul Edwards (Welsh Salmon and Trout Angling Association) Richard Garner Williams (Salmon & Trout Conservation Cymru) Shaun Leonard (Wild Trout Trust) for Denise Ashton Stephen Marsh Smith (Afonydd Cymru) Tony Harrington (DCWW)

Apologies: Ruth Jenkins (NRW)

1. Welcome, introductions and apologies for absence • Steve Ormerod (SO) opened the meeting, welcomed several new participants and deputies and gave a brief overview of how the meeting would-be run-in order that participants could get the most out of using Skype.

2. Admin Matters • Minutes from November 2019 were approved – any outstanding actions were addressed. • Approval of minutes is now to be streamlined – draft minutes are to be sent to members within two weeks of each meeting and then amended where necessary prior to approval Page 2 of 11 via email comment. If no comments are received within two weeks of despatch, the minutes will be approved to enable them to be circulated more widely and more quickly. • The forum was reminded that members are expected to discuss the issues to be raised at the meetings with others, where appropriate, so that their views may also be brought to the meetings. Members were asked to note that documents marked as ‘draft’ or ‘not for further circulation’ are not to be passed on – including minutes prior to approval. • The ToR has been amended to reflect the current membership list. Reference to the General Data Protection Regulations (GDPR) has been added to reflect issues around prevention of public sharing of members private email addresses Email addresses may be shared amongst the forum only if consent has been given, and email addresses from forum must not be shared publicly. – ACTION ALL – please consider, and then if you agree, sign and return Annex 2 form from the ToR to EK. Electronic copies and signatures are acceptable. • New membership – NRW supports representation of all LFGs (Local Fishery Groups) at the WFF. One new nominated LFG member, CH, recently joined the forum to represent LFGs in SW Wales, and existing WFF members SMS and CW agreed to represent SE and N Wales respectively.as representatives. Some LFGs have since expressed a desire for specific representation and this will be discussed at forthcoming meetings of each LFG and reported back to the WFF. – SMS – we should only be accepting representatives from groups where appropriate process is followed. – ACTION CH and PG to discuss SW LFG representation; PG to report back on any nominations from LFGs It was noted that there is currently there is no overall ToR for LFGs. • ACTION DM and PG to develop a working ToR for LFGs. It was noted that NRW CEO Clare Pillman will attend the second combined LFG meetings in SE Wales, for Taff, Usk and Wye members, on 2nd June.

3. Introduction of new member • Dylan Roberts from GWCT gave a presentation on GWCT Salmon & Trout research work – this will be circulated to members with the minutes. • Questions: – PG When carrying out the netting procedure described, the commercial netsmen would have presumably been doing their best to catch sea trout and this might overrepresent the scale of bycatch in the fishery ▪ DR – We’re looking to catch fish for genetics and were fishing in areas were fishermen could fish and were likely to catch sea trout as bycatch. We will seek to scale this work up next year off the North Cornwall and North Devon coast. Difficult to quantify bycatch. Looking to see if there needs to be tighter regulation. – PG Could you share the evidence from the North Devon report? – Shaun Leonard: Where is the information from SAMARCH available? ▪ Still in the data collection phase and this will be pulled together and put into a report. Page 3 of 11 • ACTION DR to provide information referred to above.

4. Agricultural Regulations • Bob Vaughan from NRW gave a presentation and updated the Forum on Water Regulations: – September 2016 Welsh Government reviewed NVZ; – December 2017 WG decided to go for an all Wales approach; – November 2018 WG decided that regulations would come into place in January 2020; – 8 th April 2020 Minister made a statement on the draft regulations for stakeholders. A final decision as to whether these will be introduced is yet to be made and is likely to be delayed due to Covid19. – The DRAFT regulations may be found here: Draft Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2020 – The draft regs include a requirement for WG to review them and consider any proposals for an alternative suite of measures within 18 months of regulations coming into force to help regs fit better and be more effective. – The WLMF sub group members put forward their comments on the regulations and the Regulatory Impact assessment (RIA) prepared to support the Regulations. These comments parallel the earlier report provided by the group to the Minister. This report developed 5 components, including regulatory improvements, which all the members of the sub group believe are needed to tackle agricultural pollution and nutrient management. Progress report by the Wales Land Management Forum (WLMF) sub-group on agricultural pollution – WG has been developing a replacement for the Basic Payment Scheme, the Glastir Scheme and the Economic Resilience Scheme to promote a Sustainable Land Management Scheme which would need to dovetail with the new regulations; – An all Wales approach: – ▪ places requirements on farmers to invest in storage; ▪ places restrictions on when they can spread; ▪ only focuses on nitrogen. – The RIA undertaken appears to suggest that the regulations will primarily reduce the production of greenhouse gases rather than impacts on water quality. It had been commended that all nutrient management should be covered. – There are concerns that farms will look to avoid slurry produced indoors by putting stock out over winter to reduce slurry production and this could create an unforeseen increased pollution risk which would have negative impacts on soil and water resources. • COMMENTS: MO – Transition period without regulation, how long will it be? ▪ A: It will be 18 months. The transition period will be slightly longer as it will be expensive and time consuming for farms to build new infrastructure. RG – Main comment is of some dismay. The initial announcement came from the Minister without consultation and was that regs would be brought in by Jan 2020. But Page 4 of 11 there has been more delay and an additional transition period. Will we ever see anything realistic brought in that will make a difference? ▪ A: The regulations are a step forward but there is still a lot of work to do before we see any impact on reducing pollution risk.. DR – is there capacity within the guidelines, or to develop guidelines, to prevent farmers from upscaling their production and have a greater number of animals on their fields unless they have the capacity to deal with the additional slurry storage? ▪ A: This has been discussed at WLMF sub group and within NRW and we are reviewing the existing legislation to explore how we may use the powers more effectively rather than waiting until a pollution has occurred. We are looking at a wide range of issues, including planning and regulation, so that we can put into place controls that will work. Once we can identify gaps that need to be filled, we can approach WG with a means to fix this so that we can use the regulation we have to its best effect MO – is this regulation going to be seen as a measure in river basin management plans? ▪ A: We use WFD monitoring as a way of identifying problems across Wales, homing in on those areas to work with farmers to prevent these issues and to help farmers to understand the impact of their actions. SL – Was concerned that NRW appeared to have consented the dumping of milk which is being dumped in large quantities ▪ A: The Covid19 response has had a marked impact on farming. Many farms have contracts with processing plants and those who have contracts with the hospitality market have seen demand stop overnight which is why you’ve seen news items about the possibility of milk being poured away. Many farms already have a waste permit (U10) to allow disposal of milk on site but there are controls on what and how this is safely done. This is a last resort action. WG, with support from NRW, have also been working with processing plants to find alternative markets for this milk to be used. Where you have been seeing dumping it has mostly been going into slurry tanks and where it is spread on land it must be greatly diluted. The waste hierarchy comes into play very early on before produce is disposed of. SMS – A comment: throughout the time on WLMF it is evident that it is not representative of the full picture: members are either NRW or farmers and only 2 NGO members are there. There has been a history of voluntary schemes over regulation. Teams have identified diffuse pollution problems at many farms and there isn’t a mechanism to deal effectively with slurry when they are over-capacity. We as a fisheries group depend on good water quality which isn’t being tackled appropriately. The regulations in place are not enough to control the problems that are ongoing. ▪ A: The WLMF is the only place where we are trying to pull together an approach to deal with this and to guide the sector to see that what is happening is not acceptable. Not just regulation but there are other methods being considered. Regulation needs to be firm enough to deal with those who are not following guidance and advice. There also needs to be a level of professionalism in the Page 5 of 11 sector. We need to work with the sector so that they can see the impacts of their actions rather than solving their problems for them. The forum itself was set up the same way as this forum and has brought in other members to give us another perspective. This forum has come about as the sector itself also sees that there needs to be a change. • There was strong and resolute feeling from the forum that the announcement was disappointing, both in terms of the proposed regulations and the further delays in bringing in effective regulation and the resources to ensure we see a sustained reduction in pollution incidents and diffuse pollution from agriculture. – ACTION: SO will write to the CEO and Chairman of NRW to express the angst and deep frustration that is felt in this forum so that they can bring this up with the Minister. • CH: The work that has been done is under the assumption that the pollution problem is wholly a nutrients issue. The minutes from the WLMF subgroup have been published up until September 2019. As the subsequent minutes are yet to be approved (awaiting information from WG) and placed on the website however, (he could report that) those meetings (October and November) picked up on other issues including bad practice. There is a transition period in relation to the new regulations, and there is also the review period. Will we be satisfied that those two provisions will have been enforced once the 18 months closes? ▪ A: The 18 months won’t start until the pandemic ends ACTION: SO, PG and RV to pursue the points that SMS and CH raised outside the meeting, to raise the issues to NRW Chair/CEO and to inform Welsh Government. • SO also concerned over ability to detect issues in our waterbodies but also any beneficial effects of any changes implemented.

5. Fish-eating Birds PL gave a presentation on the NRW Fish-eating Birds Advisory Group set in the context of the previous work undertaken by the Group and of the need to reconvene the Group as part of the review of NRWs approach to the shooting and trapping of wild birds in Wales • Reference was made to the Wild Trout Trust FEB Paper. • COMMENTS SMS – in this presentation there was a slowing down in bird population growth. Do you think this is down to a decrease fish populations or to recording? Do you think there may be a legal challenge from those whose income comes from fisheries if no action is taken? ▪ A: The trend data is sourced from the BTOs UK Breeding Bird Survey (BBS) and Wales Wetland Bird Survey (WeBS)The next stage will be to look at Wales only data. The UK BBS trends suggests a decrease in breeding goosanders and cormorants but the WeBS (Wales) trends show increasing wintering cormorant and goosander, though we have to be careful of wintering trends as WeBS do not sufficiently cover all inland waterways. All statutory nature conservation bodies (SNCBs), including NRW are under Page 6 of 11 close legal scrutiny from current campaign groups, such as Wild Justice, at the moment and it seems to be in relation to challenges on any weakness or our interpretation of current environmental legislation. DR – I never saw FEBs in SW Wales, but now they are everywhere so there has been an expansion in numbers and range. Can you clarify the review is going to be a literature review of current work and for the whole of the UK? ▪ A: Final agreement of the scope of the delivery programme is very much down to the NRW FEB Advisory Group.. Both policy and evidence reviews have been undertaken in Scotland and England, we have assessed these reviews for their applicability to Wales to help us determine the indicative scope of our work in Wales AW – You refer to non-lethal methods of controlling FEBS, will this involve habitat quality and protecting habitat? ▪ A: As in any licencing of lethal controls, NRW as the competent licensing authority must be satisfied that there are no other satisfactory solution and dependent on the licence type the applicant must provide evidence that suitable, legal non-lethal methods for control have been tried. NRW has reviewed and assessed that there are no satisfactory solution when we issued our new general licences on 1 January 2019,. With regard to FEBs, individual licence applicants generally feel that birds quickly become habituated to non-lethal scaring methods and are just moved further down/up stream. PG – There is a lot of experience using habitat adjustments to protect fish, largely in still water fisheries. We will be making use of long experience in that field, so we won’t be starting from scratch. We are also looking at wild and stocked fisheries as there are also problems in non-salmonid fisheries across Wales. We have seen the activities of Wild Justice, is there any scope to engage them with this process? ▪ A: We have extended invitations to engage with Wild Justice, firstly as an opening meeting to understand their general concerns. They feel that environmental legislation has not been legally abided by. Initial response was favourable, but since then they have declined to meet with NRW. It is something we should possibly pursue to engage in positive dialogue. This approach would be sensible during our wider review. SO – there is a conservation issue around salmonid protection under the Habitat Regulations, and this seriously tests an organisation making a position on controlling FEBs.

6. Plan of Action for Salmon and Sea Trout – Paper • The PoA represents contributions from this Forum’s working group and from LFG and other stakeholders brought together on this topic. The PoA has now been signed off by the minister. NRW would like to thank all those that took time and engaged in the process to help produce the plan. • There are 9 ‘themes” represented by the all-important Action Tables – The issues covered are: – Page 7 of 11

1. Evidence – understanding the status of stocks;

2. Managing exploitation;

3. Protecting stocks through effective enforcement;

4. Tackling physical habitat constraints in the freshwater environment;

5. Safeguarding water quality and quantity;

6. Addressing land management, and associated risks to water quality;

7. Addressing predation on salmonids: fish-eating birds and seals;

8. Understanding marine Pressures;

9. Understanding new and emerging potential pressures.

COMMENTS RGW – We need to aim to return to sustainable harvest, relevant for West Wales fisheries (nets). Not just socio-economical but protected geographical indication also and value of migratory fisheries to local economies. Include final ambition of returning to harvestable population for all methods not just rod and line. SO – Need to consider not just resourcing the plan but the potential investment of the plan too. DR – avoid falling into trap of blaming climate change. There are lots of other pressures that we can target. DM – in the action tables we are not blaming climate change, but also lots of other issues: effective stock management and exploitation controls, ensuring our stocks are sustainable. There is focus on environmental pressures such as water quality, agricultural issues and habitat as well as bird predation. We will need to consider what reporting we will be doing on the plan of action, both to Welsh Government and the pivotal role the WFF will play in progressing the plan and future implementation of the actions. The plan is now publicly available, will be circulated and discussed in the forthcoming rounds of Local Fishery Groups. It will also be available through our web site. 7. Provisional Stock Assessments – Papers • These are still in draft format: we will share more widely once these have been confirmed. • The annual report to ICES on the status of salmon stocks is normally published by CEFAS at the end of May. ACTION We will circulate to the Forum along with the two summary documents for salmon and sea trout that we provide each year. • These assessments do not form part of WFD classification and focuses solely on the adult component of the stock. They were implemented following Ministerial Direction and are an integral part of our reporting to ICES and commitment to NASCO. They are based on estimates of spawner abundance against conservation limits – and this metric isn’t considered in the WFD process. These assessments are catchment-scale rather than for individual waterbodies. WFD only considers the juvenile component of the stock. COMMENTS Page 8 of 11 SMS – when you were considering bringing in the byelaws for salmon, it was more optimistic than it is now for sea trout, will you bring in more restrictions for sea trout? ▪ A: PG – this is an annual process which is extremely time consuming. We will also be looking at the decision structure. As and when we need, we identify a need for further restraint, such as that suggested, we will not hesitate to bring in stakeholders and take action that is needed. AW – Looking at catchments around the Llyn Peninsula, the assessments are more optimistic, but they only have small salmon catches which may give a more misleading picture of improvement? ▪ A: PG – This has to interpreted carefully and this is why we are also looking at a more sophisticated stock assessment tool that uses juvenile stocks. There will be a report on that work. SO – Looking at these maps is worrying and looking at the pressures we have it won’t be long that we can hang on to our salmon and sea trout stocks in Wales.

8. Angling Promotion • DM provided a brief update on the Fishing in Wales Project and played an example promotional video. • The ‘Fishing in Wales’ website is nearing completion and content is currently being uploaded. Were it not for Covid-19 it would have been launched this month; • Therefore, due to the current situation the site launch will be delayed until it is appropriate for us to promote angling again. • The initiative has been funded by Visit Wales (VW) and NRW. VW has scaled down their own promotional activity in light of COVID 19 and has advised the project to do the same. • Upon launch, the website will include information on all angling club waters, private fisheries and sea fishing locations in Wales (a total of over 1200 entries). • Some parts of the project are already up and running more information in the links below: Fishing Wales Facebook Fishing in Wales Instagram Wales Fishing Instagram Angling Trust Fishing in Wales Info (news release) COMMENTS CW – Would like to highlight an issue with NRW’s website concerning simplification of the byelaws. The information is extremely difficult to find: i.e. how close you can fish to obstructions. This information is under ‘safety near obstructions’ rather than restrictions by river. ▪ A: Due to the nature of site traffic being mainly through mobile devices, the site needs to be laid out in this way to improve accessibility. It can be improved, and we will continue to make adjustments to help improve it. SO – Images on the video and often in angling magazines can often portray images of anglers of similar demographics. What can be done to increase diversity of representation in the way we promote angling? ▪ A: DM – yes this is something we are mindful of, and there are various initiatives to take people fishing. We will ensure that the project address this. Page 9 of 11 MO –There are members who would fit the missed demographics that would be willing to be in videos or photographs. All countries are seeing a decline in rod licences, but it is improving in countries where they have done similar tourist style initiatives. PE – are there any initiatives to target youths to encourage them to take up fishing? ▪ A: DM – at the moment there are not many. Unfortunately, we only have a few projects and initiatives around angling participation. JO – Groups in SW and N Wales are addressing these issues, encouraging youth participation, although we were not involved in this project. These schemes are funded through Sport Wales and NRW There are a number of issues around introducing youths to angling to be considered, and clubs are struggling to engage with younger members. There is a lack of uptake in areas where there are more options to keep youths busy. Additionally, with the lack of fish it is difficult to hold their attention and encourage them to take up the sport. Angling coaches are being deterred by the qualifications required by Sport Wales due to costs and the expectations that come with having a qualification. However, Level 1 is important as this covers child protection. SMS – the uptake in angling is correlated with the numbers of fish. As the numbers of fish continue to fall, so will angling uptake. If the rivers aren’t in a good condition, they won’t be very appealing. JO – This is also reflecting in sea angling. We tend to take youngsters to coarse fisheries where they can much more easily catch fish which gets them more involved and keener on angling as they can catch fish. AW – EA used to put a lot of resource into angling participation which has now ended, is there likely to be a similar scheme? FiW doesn’t address the work on the ground required. ▪ A: PG – there has been some investment from Visit Wales however these initiatives are only as good as the upkeep. SL – reflecting on the stock status maps. When those maps land on WG desks, do you sense any appreciation among policy makers of the enormity of the picture they paint? We might look at them as anglers and/or conservationists but of course they’re indicative of a massive environmental issue. ▪ A: JB – WG have seen the status maps and the direction of travel. For this reason, the Minister asked NRW to bring together the Plan of Action and additional resources have recently been offered.

9. Updates from Other Fora – Papers (taken as read) • Wales Water Management Forum COMMENT: SMS – Planning needs to be considered to prevent too many chicken sheds being built as these don’t just affect air quality but also water quality. • Wales Land Management Forum – COMMENT: CH – there is an amount of evidence that will change views on agricultural pollution, and it is important that the industry changes the way that matters should be addressed. – See previous comments in Section 4 • National Access Forum for Wales – COMMENTS: SMS – access to navigation on waterways is a concern at the moment as we need to find a solution to this ongoing problem. The consideration of any future access needs Page 10 of 11 to take into consideration riparian owners views. There is an opportunity to change things but not take the attitude that there should be no activity on rivers but outline areas that are more suited to these activities. – RGW – No specific mention that biodiversity of freshwater and conservation should take priority over access. – CW – It’s not anglers trying to arrange voluntary access agreements but other members of the access forum who refuse to engage unless they are allowed 24/7 access 365 days a year. There needs to be more emphasis to protect spawning fish that are continuously disturbed by adventure activities prior to them being able to spawn. This needs to be addressed. There have been angling byelaws to protect fish, but it needs to go further to protect the fish once they return to the river. I am concerned that fish are not being fully protected especially when they are vulnerable in the small upland streams. ▪ NOTE: PG – this is featured as an action in the PoA – SMS – Access has been successfully agreed in some areas noting however, that not all parties had been involved.

10.Other Updates • Government directions in relation to Covid19 and outdoor activities has effectively closed fishing. The requirements on social distancing mean you should not be leaving your house in order to go fishing recreationally. We have received a number of reports of people fishing: these issues have been passed onto the police rather than NRW enforcement and they have dealt with some of them. See: Angling Trust Covid19 Support Hub This is a good resource of guidance and information for anglers and angling clubs. Whilst primarily aimed at English anglers it also contains information relevant to Wales: “We must all do what is required of us by the Government for the benefit of our own health and that of our communities, and we should therefore refrain from fishing and work together to fight this pandemic and save lives.” See also: https://www.anglingcymru.org.uk/ • Licence sales have been much reduced since the Covid 19 restrictions were introduced. NRW are currently discussing with EA the implications of this, as this will effect the rod licence income to NRW for fisheries work. Once measures are lifted there will be communications around buying licences and getting people out angling again. There have also been some enquires on rebates for fishing licences and as it stands nothing is in place, but this is being discussed with EA. Following discussion, the general view of members is that they would not support any approach to refund fishing licence fees, as the income from licences is vital for positive work and supporting fisheries. However, there may be a need to consider a different approach for fishing leases and angling clubs. • The NASCO Implementation Plan is currently being revised, largely in relation to aquaculture matters that are not relevant to Wales. ACTION To be circulated when finalised The annual progress report is in draft (draft was circulated with original meeting content (members are requested not to circulate further). This will be finalised soon. Page 11 of 11 ACTION: NRW will circulate final copy as soon as possible COMMENT CW – there has been a stock assessment working group set up, has there been any input from angling clubs or NGO interests? ▪ A: DM – There are no NGOs on that group. Our commitments to review the stock assessment were set out in the implementation plan and once this has been completed, we will be able to seek comments.

11.AOB • CH – Concerns regarding Incident Reporting. Since 2016 incidents have been reported however incident/reference numbers have not been received as a matter of course – they often need to be asked for. This can create a feeling of mistrust of NRW on the ground. It would help engender greater confidence in the system and NRW if the reference numbers were given out automatically without asking for them. – reassuring the callers that the incident was being logged and acted upon. – ▪ A: Agreed that reference numbers should be given as a matter of recourse when reporting incidents, but callers should request them if not offered. – ACTION: NRW – DM and PG, to raise issue with incident management team to look at protocol and to review this. • MO – There has been an Angling Pathway Plan developed to prevent the spread of INNS (Invasive non-native species), can we discuss actions from this in our next meeting? • Date of next meeting: 19th November (proposed). – Members generally gave positive feedback from the Skype meeting noting that in these unprecedented times face to face meetings are not possible. – Venue of next meeting to be determined in future and dependant upon restrictions on social distasting being relaxed CLOSING COMMENT • JO Closing comments: regarding agriculture regulations – Voluntary measures don’t work. – Will new regulations be policed? – Minister is responsible for both the environment and land use which are a conflict of interest. • CH – Commented that enforceability should not affect whether you bring in regulations or not.

Adrian Simpson (Countryside Alliance) for Rachel Evans Alan Winstone (Afonydd Cymru) Chris White (Campaign for the Protection of Welsh Fisheries; North Wales LFGs) Creighton Harvey (SW LFGs) Dylan Roberts (Game & Wildlife Conservation Trust) James Legge (Countryside Alliance) John O’Connor (Angling Cymru) for Carl Tonner Julian Bray (Welsh Government) Mark Owen (Angling Trust) Mark Tilling (Welsh Government) Nicola Teague (IFM) Paul Edwards (Welsh Salmon and Trout Angling Association) Richard Garner Williams (Salmon & Trout Conservation Cymru) Shaun Leonard (Wild Trout Trust) for Denise Ashton Stephen Marsh Smith (Afonydd Cymru) Tony Harrington (DCWW) Apologies: Ruth Jenkins (NRW) 1. Welcome, introductions and apologies for absence • Steve Ormerod (SO) opened the meeting, welcomed several new participants and deputies and gave a brief overview of how the meeting would-be run-in order that participants could get the most out of using Skype. 2. Admin Matters • Minutes from November 2019 were approved – any outstanding actions were addressed. • Approval of minutes is now to be streamlined – draft minutes are to be sent to members within two weeks of each meeting and then amended where necessary prior to approval Page 2 of 11 via email comment. If no comments are received within two weeks of despatch, the minutes will be approved to enable them to be circulated more widely and more quickly. • The forum was reminded that members are expected to discuss the issues to be raised at the meetings with others, where appropriate, so that their views may also be brought to the meetings. Members were asked to note that documents marked as ‘draft’ or ‘not for further circulation’ are not to be passed on – including minutes prior to approval. • The ToR has been amended to reflect the current membership list. Reference to the General Data Protection Regulations (GDPR) has been added to reflect issues around prevention of public sharing of members private email addresses Email addresses may be shared amongst the forum only if consent has been given, and email addresses from forum must not be shared publicly. – ACTION ALL – please consider, and then if you agree, sign and return Annex 2 form from the ToR to EK. Electronic copies and signatures are acceptable. • New membership – NRW supports representation of all LFGs (Local Fishery Groups) at the WFF. One new nominated LFG member, CH, recently joined the forum to represent LFGs in SW Wales, and existing WFF members SMS and CW agreed to represent SE and N Wales respectively.as representatives. Some LFGs have since expressed a desire for specific representation and this will be discussed at forthcoming meetings of each LFG and reported back to the WFF. – SMS – we should only be accepting representatives from groups where appropriate process is followed. – ACTION CH and PG to discuss SW LFG representation; PG to report back on any nominations from LFGs It was noted that there is currently there is no overall ToR for LFGs. • ACTION DM and PG to develop a working ToR for LFGs. It was noted that NRW CEO Clare Pillman will attend the second combined LFG meetings in SE Wales, for Taff, Usk and Wye members, on 2nd June. 3. Introduction of new member • Dylan Roberts from GWCT gave a presentation on GWCT Salmon & Trout research work – this will be circulated to members with the minutes. • Questions: – PG When carrying out the netting procedure described, the commercial netsmen would have presumably been doing their best to catch sea trout and this might overrepresent the scale of bycatch in the fishery ▪ DR – We’re looking to catch fish for genetics and were fishing in areas were fishermen could fish and were likely to catch sea trout as bycatch. We will seek to scale this work up next year off the North Cornwall and North Devon coast. Difficult to quantify bycatch. Looking to see if there needs to be tighter regulation. – PG Could you share the evidence from the North Devon report? – Shaun Leonard: Where is the information from SAMARCH available? ▪ Still in the data collection phase and this will be pulled together and put into a report. Page 3 of 11 • ACTION DR to provide information referred to above. 4. Agricultural Regulations • Bob Vaughan from NRW gave a presentation and updated the Forum on Water Regulations: – September 2016 Welsh Government reviewed NVZ; – December 2017 WG decided to go for an all Wales approach; – November 2018 WG decided that regulations would come into place in January 2020; – 8 th April 2020 Minister made a statement on the draft regulations for stakeholders. A final decision as to whether these will be introduced is yet to be made and is likely to be delayed due to Covid19. – The DRAFT regulations may be found here: Draft Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2020 – The draft regs include a requirement for WG to review them and consider any proposals for an alternative suite of measures within 18 months of regulations coming into force to help regs fit better and be more effective. – The WLMF sub group members put forward their comments on the regulations and the Regulatory Impact assessment (RIA) prepared to support the Regulations. These comments parallel the earlier report provided by the group to the Minister. This report developed 5 components, including regulatory improvements, which all the members of the sub group believe are needed to tackle agricultural pollution and nutrient management. Progress report by the Wales Land Management Forum (WLMF) sub-group on agricultural pollution – WG has been developing a replacement for the Basic Payment Scheme, the Glastir Scheme and the Economic Resilience Scheme to promote a Sustainable Land Management Scheme which would need to dovetail with the new regulations; – An all Wales approach: – ▪ places requirements on farmers to invest in storage; ▪ places restrictions on when they can spread; ▪ only focuses on nitrogen. – The RIA undertaken appears to suggest that the regulations will primarily reduce the production of greenhouse gases rather than impacts on water quality. It had been commended that all nutrient management should be covered. – There are concerns that farms will look to avoid slurry produced indoors by putting stock out over winter to reduce slurry production and this could create an unforeseen increased pollution risk which would have negative impacts on soil and water resources. • COMMENTS: MO – Transition period without regulation, how long will it be? ▪ A: It will be 18 months. The transition period will be slightly longer as it will be expensive and time consuming for farms to build new infrastructure. RG – Main comment is of some dismay. The initial announcement came from the Minister without consultation and was that regs would be brought in by Jan 2020. But Page 4 of 11 there has been more delay and an additional transition period. Will we ever see anything realistic brought in that will make a difference? ▪ A: The regulations are a step forward but there is still a lot of work to do before we see any impact on reducing pollution risk.. DR – is there capacity within the guidelines, or to develop guidelines, to prevent farmers from upscaling their production and have a greater number of animals on their fields unless they have the capacity to deal with the additional slurry storage? ▪ A: This has been discussed at WLMF sub group and within NRW and we are reviewing the existing legislation to explore how we may use the powers more effectively rather than waiting until a pollution has occurred. We are looking at a wide range of issues, including planning and regulation, so that we can put into place controls that will work. Once we can identify gaps that need to be filled, we can approach WG with a means to fix this so that we can use the regulation we have to its best effect MO – is this regulation going to be seen as a measure in river basin management plans? ▪ A: We use WFD monitoring as a way of identifying problems across Wales, homing in on those areas to work with farmers to prevent these issues and to help farmers to understand the impact of their actions. SL – Was concerned that NRW appeared to have consented the dumping of milk which is being dumped in large quantities ▪ A: The Covid19 response has had a marked impact on farming. Many farms have contracts with processing plants and those who have contracts with the hospitality market have seen demand stop overnight which is why you’ve seen news items about the possibility of milk being poured away. Many farms already have a waste permit (U10) to allow disposal of milk on site but there are controls on what and how this is safely done. This is a last resort action. WG, with support from NRW, have also been working with processing plants to find alternative markets for this milk to be used. Where you have been seeing dumping it has mostly been going into slurry tanks and where it is spread on land it must be greatly diluted. The waste hierarchy comes into play very early on before produce is disposed of. SMS – A comment: throughout the time on WLMF it is evident that it is not representative of the full picture: members are either NRW or farmers and only 2 NGO members are there. There has been a history of voluntary schemes over regulation. Teams have identified diffuse pollution problems at many farms and there isn’t a mechanism to deal effectively with slurry when they are over-capacity. We as a fisheries group depend on good water quality which isn’t being tackled appropriately. The regulations in place are not enough to control the problems that are ongoing. ▪ A: The WLMF is the only place where we are trying to pull together an approach to deal with this and to guide the sector to see that what is happening is not acceptable. Not just regulation but there are other methods being considered. Regulation needs to be firm enough to deal with those who are not following guidance and advice. There also needs to be a level of professionalism in the Page 5 of 11 sector. We need to work with the sector so that they can see the impacts of their actions rather than solving their problems for them. The forum itself was set up the same way as this forum and has brought in other members to give us another perspective. This forum has come about as the sector itself also sees that there needs to be a change. • There was strong and resolute feeling from the forum that the announcement was disappointing, both in terms of the proposed regulations and the further delays in bringing in effective regulation and the resources to ensure we see a sustained reduction in pollution incidents and diffuse pollution from agriculture. – ACTION: SO will write to the CEO and Chairman of NRW to express the angst and deep frustration that is felt in this forum so that they can bring this up with the Minister. • CH: The work that has been done is under the assumption that the pollution problem is wholly a nutrients issue. The minutes from the WLMF subgroup have been published up until September 2019. As the subsequent minutes are yet to be approved (awaiting information from WG) and placed on the website however, (he could report that) those meetings (October and November) picked up on other issues including bad practice. There is a transition period in relation to the new regulations, and there is also the review period. Will we be satisfied that those two provisions will have been enforced once the 18 months closes? ▪ A: The 18 months won’t start until the pandemic ends ACTION: SO, PG and RV to pursue the points that SMS and CH raised outside the meeting, to raise the issues to NRW Chair/CEO and to inform Welsh Government. • SO also concerned over ability to detect issues in our waterbodies but also any beneficial effects of any changes implemented. 5. Fish-eating Birds PL gave a presentation on the NRW Fish-eating Birds Advisory Group set in the context of the previous work undertaken by the Group and of the need to reconvene the Group as part of the review of NRWs approach to the shooting and trapping of wild birds in Wales • Reference was made to the Wild Trout Trust FEB Paper. • COMMENTS SMS – in this presentation there was a slowing down in bird population growth. Do you think this is down to a decrease fish populations or to recording? Do you think there may be a legal challenge from those whose income comes from fisheries if no action is taken? ▪ A: The trend data is sourced from the BTOs UK Breeding Bird Survey (BBS) and Wales Wetland Bird Survey (WeBS)The next stage will be to look at Wales only data. The UK BBS trends suggests a decrease in breeding goosanders and cormorants but the WeBS (Wales) trends show increasing wintering cormorant and goosander, though we have to be careful of wintering trends as WeBS do not sufficiently cover all inland waterways. All statutory nature conservation bodies (SNCBs), including NRW are under Page 6 of 11 close legal scrutiny from current campaign groups, such as Wild Justice, at the moment and it seems to be in relation to challenges on any weakness or our interpretation of current environmental legislation. DR – I never saw FEBs in SW Wales, but now they are everywhere so there has been an expansion in numbers and range. Can you clarify the review is going to be a literature review of current work and for the whole of the UK? ▪ A: Final agreement of the scope of the delivery programme is very much down to the NRW FEB Advisory Group.. Both policy and evidence reviews have been undertaken in Scotland and England, we have assessed these reviews for their applicability to Wales to help us determine the indicative scope of our work in Wales AW – You refer to non-lethal methods of controlling FEBS, will this involve habitat quality and protecting habitat? ▪ A: As in any licencing of lethal controls, NRW as the competent licensing authority must be satisfied that there are no other satisfactory solution and dependent on the licence type the applicant must provide evidence that suitable, legal non-lethal methods for control have been tried. NRW has reviewed and assessed that there are no satisfactory solution when we issued our new general licences on 1 January 2019,. With regard to FEBs, individual licence applicants generally feel that birds quickly become habituated to non-lethal scaring methods and are just moved further down/up stream. PG – There is a lot of experience using habitat adjustments to protect fish, largely in still water fisheries. We will be making use of long experience in that field, so we won’t be starting from scratch. We are also looking at wild and stocked fisheries as there are also problems in non-salmonid fisheries across Wales. We have seen the activities of Wild Justice, is there any scope to engage them with this process? ▪ A: We have extended invitations to engage with Wild Justice, firstly as an opening meeting to understand their general concerns. They feel that environmental legislation has not been legally abided by. Initial response was favourable, but since then they have declined to meet with NRW. It is something we should possibly pursue to engage in positive dialogue. This approach would be sensible during our wider review. SO – there is a conservation issue around salmonid protection under the Habitat Regulations, and this seriously tests an organisation making a position on controlling FEBs. 6. Plan of Action for Salmon and Sea Trout – Paper • The PoA represents contributions from this Forum’s working group and from LFG and other stakeholders brought together on this topic. The PoA has now been signed off by the minister. NRW would like to thank all those that took time and engaged in the process to help produce the plan. • There are 9 ‘themes” represented by the all-important Action Tables – The issues covered are: – Page 7 of 11 1. Evidence – understanding the status of stocks; 2. Managing exploitation; 3. Protecting stocks through effective enforcement; 4. Tackling physical habitat constraints in the freshwater environment; 5. Safeguarding water quality and quantity; 6. Addressing land management, and associated risks to water quality; 7. Addressing predation on salmonids: fish-eating birds and seals; 8. Understanding marine Pressures; 9. Understanding new and emerging potential pressures. COMMENTS RGW – We need to aim to return to sustainable harvest, relevant for West Wales fisheries (nets). Not just socio-economical but protected geographical indication also and value of migratory fisheries to local economies. Include final ambition of returning to harvestable population for all methods not just rod and line. SO – Need to consider not just resourcing the plan but the potential investment of the plan too. DR – avoid falling into trap of blaming climate change. There are lots of other pressures that we can target. DM – in the action tables we are not blaming climate change, but also lots of other issues: effective stock management and exploitation controls, ensuring our stocks are sustainable. There is focus on environmental pressures such as water quality, agricultural issues and habitat as well as bird predation. We will need to consider what reporting we will be doing on the plan of action, both to Welsh Government and the pivotal role the WFF will play in progressing the plan and future implementation of the actions. The plan is now publicly available, will be circulated and discussed in the forthcoming rounds of Local Fishery Groups. It will also be available through our web site. 7. Provisional Stock Assessments – Papers • These are still in draft format: we will share more widely once these have been confirmed. • The annual report to ICES on the status of salmon stocks is normally published by CEFAS at the end of May. ACTION We will circulate to the Forum along with the two summary documents for salmon and sea trout that we provide each year. • These assessments do not form part of WFD classification and focuses solely on the adult component of the stock. They were implemented following Ministerial Direction and are an integral part of our reporting to ICES and commitment to NASCO. They are based on estimates of spawner abundance against conservation limits – and this metric isn’t considered in the WFD process. These assessments are catchment-scale rather than for individual waterbodies. WFD only considers the juvenile component of the stock. COMMENTS Page 8 of 11 SMS – when you were considering bringing in the byelaws for salmon, it was more optimistic than it is now for sea trout, will you bring in more restrictions for sea trout? ▪ A: PG – this is an annual process which is extremely time consuming. We will also be looking at the decision structure. As and when we need, we identify a need for further restraint, such as that suggested, we will not hesitate to bring in stakeholders and take action that is needed. AW – Looking at catchments around the Llyn Peninsula, the assessments are more optimistic, but they only have small salmon catches which may give a more misleading picture of improvement? ▪ A: PG – This has to interpreted carefully and this is why we are also looking at a more sophisticated stock assessment tool that uses juvenile stocks. There will be a report on that work. SO – Looking at these maps is worrying and looking at the pressures we have it won’t be long that we can hang on to our salmon and sea trout stocks in Wales. 8. Angling Promotion • DM provided a brief update on the Fishing in Wales Project and played an example promotional video. • The ‘Fishing in Wales’ website is nearing completion and content is currently being uploaded. Were it not for Covid-19 it would have been launched this month; • Therefore, due to the current situation the site launch will be delayed until it is appropriate for us to promote angling again. • The initiative has been funded by Visit Wales (VW) and NRW. VW has scaled down their own promotional activity in light of COVID 19 and has advised the project to do the same. • Upon launch, the website will include information on all angling club waters, private fisheries and sea fishing locations in Wales (a total of over 1200 entries). • Some parts of the project are already up and running more information in the links below: Fishing Wales Facebook Fishing in Wales Instagram Wales Fishing Instagram Angling Trust Fishing in Wales Info (news release) COMMENTS CW – Would like to highlight an issue with NRW’s website concerning simplification of the byelaws. The information is extremely difficult to find: i.e. how close you can fish to obstructions. This information is under ‘safety near obstructions’ rather than restrictions by river. ▪ A: Due to the nature of site traffic being mainly through mobile devices, the site needs to be laid out in this way to improve accessibility. It can be improved, and we will continue to make adjustments to help improve it. SO – Images on the video and often in angling magazines can often portray images of anglers of similar demographics. What can be done to increase diversity of representation in the way we promote angling? ▪ A: DM – yes this is something we are mindful of, and there are various initiatives to take people fishing. We will ensure that the project address this. Page 9 of 11 MO –There are members who would fit the missed demographics that would be willing to be in videos or photographs. All countries are seeing a decline in rod licences, but it is improving in countries where they have done similar tourist style initiatives. PE – are there any initiatives to target youths to encourage them to take up fishing? ▪ A: DM – at the moment there are not many. Unfortunately, we only have a few projects and initiatives around angling participation. JO – Groups in SW and N Wales are addressing these issues, encouraging youth participation, although we were not involved in this project. These schemes are funded through Sport Wales and NRW There are a number of issues around introducing youths to angling to be considered, and clubs are struggling to engage with younger members. There is a lack of uptake in areas where there are more options to keep youths busy. Additionally, with the lack of fish it is difficult to hold their attention and encourage them to take up the sport. Angling coaches are being deterred by the qualifications required by Sport Wales due to costs and the expectations that come with having a qualification. However, Level 1 is important as this covers child protection. SMS – the uptake in angling is correlated with the numbers of fish. As the numbers of fish continue to fall, so will angling uptake. If the rivers aren’t in a good condition, they won’t be very appealing. JO – This is also reflecting in sea angling. We tend to take youngsters to coarse fisheries where they can much more easily catch fish which gets them more involved and keener on angling as they can catch fish. AW – EA used to put a lot of resource into angling participation which has now ended, is there likely to be a similar scheme? FiW doesn’t address the work on the ground required. ▪ A: PG – there has been some investment from Visit Wales however these initiatives are only as good as the upkeep. SL – reflecting on the stock status maps. When those maps land on WG desks, do you sense any appreciation among policy makers of the enormity of the picture they paint? We might look at them as anglers and/or conservationists but of course they’re indicative of a massive environmental issue. ▪ A: JB – WG have seen the status maps and the direction of travel. For this reason, the Minister asked NRW to bring together the Plan of Action and additional resources have recently been offered. 9. Updates from Other Fora – Papers (taken as read) • Wales Water Management Forum COMMENT: SMS – Planning needs to be considered to prevent too many chicken sheds being built as these don’t just affect air quality but also water quality. • Wales Land Management Forum – COMMENT: CH – there is an amount of evidence that will change views on agricultural pollution, and it is important that the industry changes the way that matters should be addressed. – See previous comments in Section 4 • National Access Forum for Wales – COMMENTS: SMS – access to navigation on waterways is a concern at the moment as we need to find a solution to this ongoing problem. The consideration of any future access needs Page 10 of 11 to take into consideration riparian owners views. There is an opportunity to change things but not take the attitude that there should be no activity on rivers but outline areas that are more suited to these activities. – RGW – No specific mention that biodiversity of freshwater and conservation should take priority over access. – CW – It’s not anglers trying to arrange voluntary access agreements but other members of the access forum who refuse to engage unless they are allowed 24/7 access 365 days a year. There needs to be more emphasis to protect spawning fish that are continuously disturbed by adventure activities prior to them being able to spawn. This needs to be addressed. There have been angling byelaws to protect fish, but it needs to go further to protect the fish once they return to the river. I am concerned that fish are not being fully protected especially when they are vulnerable in the small upland streams. ▪ NOTE: PG – this is featured as an action in the PoA – SMS – Access has been successfully agreed in some areas noting however, that not all parties had been involved. 10.Other Updates • Government directions in relation to Covid19 and outdoor activities has effectively closed fishing. The requirements on social distancing mean you should not be leaving your house in order to go fishing recreationally. We have received a number of reports of people fishing: these issues have been passed onto the police rather than NRW enforcement and they have dealt with some of them. See: Angling Trust Covid19 Support Hub This is a good resource of guidance and information for anglers and angling clubs. Whilst primarily aimed at English anglers it also contains information relevant to Wales: “We must all do what is required of us by the Government for the benefit of our own health and that of our communities, and we should therefore refrain from fishing and work together to fight this pandemic and save lives.” See also: https://www.anglingcymru.org.uk/ • Licence sales have been much reduced since the Covid 19 restrictions were introduced. NRW are currently discussing with EA the implications of this, as this will effect the rod licence income to NRW for fisheries work. Once measures are lifted there will be communications around buying licences and getting people out angling again. There have also been some enquires on rebates for fishing licences and as it stands nothing is in place, but this is being discussed with EA. Following discussion, the general view of members is that they would not support any approach to refund fishing licence fees, as the income from licences is vital for positive work and supporting fisheries. However, there may be a need to consider a different approach for fishing leases and angling clubs. • The NASCO Implementation Plan is currently being revised, largely in relation to aquaculture matters that are not relevant to Wales. ACTION To be circulated when finalised The annual progress report is in draft (draft was circulated with original meeting content (members are requested not to circulate further). This will be finalised soon. Page 11 of 11 ACTION: NRW will circulate final copy as soon as possible COMMENT CW – there has been a stock assessment working group set up, has there been any input from angling clubs or NGO interests? ▪ A: DM – There are no NGOs on that group. Our commitments to review the stock assessment were set out in the implementation plan and once this has been completed, we will be able to seek comments. 11.AOB • CH – Concerns regarding Incident Reporting. Since 2016 incidents have been reported however incident/reference numbers have not been received as a matter of course – they often need to be asked for. This can create a feeling of mistrust of NRW on the ground. It would help engender greater confidence in the system and NRW if the reference numbers were given out automatically without asking for them. – reassuring the callers that the incident was being logged and acted upon. – ▪ A: Agreed that reference numbers should be given as a matter of recourse when reporting incidents, but callers should request them if not offered. – ACTION: NRW – DM and PG, to raise issue with incident management team to look at protocol and to review this. • MO – There has been an Angling Pathway Plan developed to prevent the spread of INNS (Invasive non-native species), can we discuss actions from this in our next meeting? • Date of next meeting: 19th November (proposed). – Members generally gave positive feedback from the Skype meeting noting that in these unprecedented times face to face meetings are not possible. – Venue of next meeting to be determined in future and dependant upon restrictions on social distasting being relaxed

CLOSING COMMENT • JO Closing comments: regarding agriculture regulations – Voluntary measures don’t work. – Will new regulations be policed? – Minister is responsible for both the environment and land use which are a conflict of interest. • CH – Commented that enforceability should not affect whether you bring in regulations or not.

Chris White to Ruth Jenkins (NRW): 3rd June

Ruth,

I find it sad that we are both taking time to defend our positions, a reflection perhaps on the poor NRW relationship with one of its major stakeholders who are treated with contempt.  The anger and frustration of the angling community is a result of NRW being more concerned with a legal challenge from Wild Justice/RSPB rather than accepting that [a major] part of the decline in migratory fish stocks is due to avian predation.  We have been raising this issue for more than 10 years and yet we are now expected to accept the ‘need of a study’ simply to defend NRW from potential legal action.

I can confirm that I was part of the Skype combined Dee & Clwyd and Gwynedd LFG meeting and in attendance at the other meetings.  You seem to have misconstrued my comments about not being responsible for comments made in my name at meetings which I was not present.  My concern was that my name had ben mentioned re FEB’s at the  Mid and South Wales joint LFG meetings at which Clare Pillman also participated (and in the recent T&S report for the Dee).  

It is interesting that you say you have the notes of the LFG meetings as these have not yet been forwarded to the Dee & Clwyd/Gwynedd LFG members. 

It is unclear if the Skype meeting was recorded if it was there should be a transcript and perhaps this will demonstrate that I did not criticise Steve Ormerod but I may well have raised issues about the FEB presentation at the Fisheries Forum. 

I am not aware of publicly criticising Steve Ormerod and the impression is that NRW are trying to defend the criticism of the report from the FEB group by attacking me simply to draw attention away for the inaccuracies in FEB report which to a lay person suggests that goosander numbers are in decline and therefore there is no need for any action.   

In my letter to Sir David Henshaw I provide evidence from the BTO which clearly shows the increase in goosander numbers in Wales over the winter period when significant damage is done to migratory fish stocks on upland spawning streams.  Information on overwintering goosander numbers in Wales was [deliberately] omitted in the FEB report and therefore any criticism levelled at NRW is justifiable either by me or others.  My perception is there was been no challenge to the accuracy of the information presented and it has been accepted on face value as it causes no issues with the RSPB.     

The issue of the damage being inflicted to migratory fish stocks by FEB’s has been raised at LFG meetings for more than 10 years but has been dismissed for fear of upsetting the RSPB by NRW and its predecessor resulting in considerable frustration and anger within the angling community due to the continued procrastination on this subject. 

I talked to Mervyn Williams who chairs the Dee & Clwyd LFG last night and asked him for his recollection of what was said re FEB’s.  Mervyn reminded me that due to his remote location and poor broadband he could not join the Skype meeting from his home and that I had linked him via my connection using my mobile so that he could take part in the meeting.  Mervyn said that he had raised issues regarding FEB’s and may well have brought up the potential conflict of interest of Steve Ormerod due to his association with the RSPB (Mervyn is a member of the RSPB), others (Chris Porteous?) may also have raised this issue but without the transcript it is difficult from memory to know who said what.  As I have not had sight of the minutes of this meeting I am not in a position to challenge what was said or how it was recorded in the minutes. 

I suspect that Steve’s appointment to Chair both the fisheries forum and FEB group was made based upon his background i.e. he was the most suitable candidate of all the NRW Board members.  I doubt that any consideration was given to a potential conflict of interest which could compromise him.  NRW now seems to want to retrospectively declare this and other potential conflicts going forward – a step in the right direction albeit a little late. 

I pointed out in my initial reply to you I do not challenge the integrity of Steve Ormerod and I stand by this.

The accusation that I public criticised Steve Ormerod is unfounded and I await the response from Sir David Henshaw before I take this any further. 

Until I receive the response from Sir David Henshaw there is little point in further dialogue.  My preference is to have an open and honest conversation as having an argument via email is not very constructive.

Chris

Re: Damage to migratory fish stocks by Fish-eating Birds

President Allan Cuthbert, 7 Norton Avenue, Prestatyn, Denbighshire, LL19 7NL Email: highplains@gmail.com

Strategy Officer John Eardley c/o Vanner Farm & Caravan Site. Llanelltyd, Dolgellau, Gwynedd, LL40 2HE Email: johneardley@btinternet.com

Conservation Officer; Chris White, 57 Normanby Drive, Connahs Quay’ Flintshire, CH5 4JX Email:chriswhite.cohite@gmail.com

Sir David Henshaw NRW Chairman

Via email: nrwboardsecretariat@naturalresourceswales.gov.uk

18 May 2020

Dear Sir David,

I recently received an email from Ruth Jenkins accusing me of publicly criticising an NRW Board member. There were no details in the email as to when and where this had supposedly taken place. I attend the Welsh Fisheries Forum on behalf of CPWF and as such I represent anglers from across Wales, many of whom have expressed concerns about the actions (or rather in-action) of NRW and perceived conflict of interests of NRW Board members due to their membership of the RSPB when considering controls on avian predation of salmonids. In my response to Ruth I explained that I cannot be held responsible for any comments made at meetings by CPWF supporters when I was not present.

I am not aware of any public criticism either verbally or in writing that I have made.

In her email Ruth accused me of publicly criticising an NRW Board member and asked me to withdraw this or if I wished to raise this issue with you as Chair of the NRW Board. As I have yet to receive a response from Ruth to my reply perhaps it is now time to take this to the next level. My preference is to have an open and honest discussion about the issues around avian predation rather than to go public through a press release. The issue of avian predation has been talked about for more than 10 years but all we get from NRW and its predecessor is procrastination on this issue for fear of upsetting the RSPB and latterly Wild Justice.

One thing that seems to unite anglers is concern over the impact of increasing numbers of Goosanders and Cormorants on our rivers. At the last Welsh Fisheries Forum a paper was presented from the Fish Eating Birds Advisory Group (FEB’s) on behalf of Natural Resources Wales in which graphs taken from the Wetland Bird Survey (WeBS) conducted by the British Trust for Ornithology (BTO) “suggests” breeding pairs of goosander and cormorant are in

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

Visit our website at www.cpwf.co.uk

decline whilst accepting that over wintering birds had steadily increased from the 1980’s. The implication from these graphs is that these FEB’s are not the cause of the decline in ‘fish stocks’ and particularly salmonids. To a lay person who supports the RSPB this is what they want to hear. The presentation was interesting in that there was more concern about a legal challenge from ‘Wild Justice’ than in the protection of fish stocks. Apparently there needs to be a detailed study (12 Months) almost certainly followed by a public consultation before any controls can be recommended let alone be put in place.

NRW are fond of claiming that they are ‘evidence lead’ so let us look at the evidence. In the first instance we need to look at the graphs taken from the Webs survey:

Note: We understand the 100 Index line in the graphs to be the average or mean of the years I995 – 2015. It would be more meaningful to the reader if the graph illustrated the actual population in order to present actual year population plots and trend.

You will see that the trend line in red for both species is showing a decline this gives the wrong message as it is referring to breeding pairs and not numbers of feeding birds over the winter period. The presentation made no reference to the fact that overwintering birds are on the increase. In the following I only consider the damage to fisheries from goosander over the winter period but the same applies to cormorants who are consuming the same or more salmonids.

The following graph is taken from the latest Wetland Bird Survey (WeBS) survey which uses data from the British Trust for Ornithology (BTO) Waterbirds in the UK 2018/19. Note the trend (blue line) in this graph is upwards this includes overwintering birds and is not restricted to breeding pairs. This graph may mirror the decline in migratory fish stocks from electro fishing surveys; the decline is at the moment attributed to climate change and pollution.

Note on graph scale:

This 1970 – 2015/16 Wales graph of goosander illustrates the rising longer trend of recorded goosander, from no population in pre 1970 to its present 2015/16 population expressed as the 100 Index.

“Contains Wetland Bird Survey (WeBS) data from Waterbirds in the UK 2018/19 © copyright and database right 2020.

So let us now consider the case against goosanders. According to the BTO an adult goosander needs to consume 400gm of fish per day and to raise a single chick from egg to adulthood requires 33kg of fish (goosanders typically have 10 chicks to feed) – these birds primarily eat fish to live. The graphs above do not declare numbers, they refer to an index. However it is clear in the graph for Wales that annual goosander numbers are increasing. According to the BTO the Status Summary for goosanders is as follows:

Status summary

Goosanders were first discovered to have colonised the UK in Perthshire in 1871, and spread from Scotland into northern England in the 1940s. Between the first two breeding atlases, the species expanded its range in northern England, and colonised Wales and southwest England. WBS samples became large enough for annual monitoring in 1980, and showed sustained population increase, apart from a slight dip in the late 1990s. The BTO’s two national surveys of sawbills demonstrated an average increase in population size of 3% per annum between 1987 and 1997. There has been considerable further range expansion since 1990. Reasons for the colonisation of the UK, and the subsequent range expansion and population increase, are unknown. The species’ winter trend in Britain, comprising British breeders and continental visitors, rose steeply from the late 1960s and peaked in the mid 1990s, before falling back, and now stands at early 1990s levels).

In order to determine the biomass consumed by goosanders and to keep the arithmetic simple consider 100 goosanders feeding over the winter period from November to March approximately 126 days. Assuming each goosander consumes on average 400gm of fish per day then over 126 days 100 goosanders can consume approximately 5 Tonne of fish during this period. Admittedly these birds may not feed every day but they tend to gorge feed so allowing for none feeding periods let us say these birds consume 3 Tonne of fish. On rivers which do not have coarse fish present they will only be eating salmonids (and maybe minnows, sticklebacks, loach and bullhead if present).

A typical smolt ready for migration is approx 100gm but during the winter period most fish eaten will be parr or fry with a likely average weight of 30gm which would indicate that the number of fish eaten is circa 100,000 over this period. We will refer to these as smolt equivalents. Over

the winter period goosanders can be found feeding on upland spawning streams i.e. feeding on smolt equivalents and once the food source is depleted in one stream they simply fly to the next. No doubt it will be claimed there is no evidence to demonstrate harm from goosanders to ‘fish stocks’. I use the term fish stocks as goosanders will also feed on rivers containing coarse fish (and on marine fish in estuaries) and by including these in the biomass consumed it is easy to show there is little damage to overall fish stocks. This is not the case on rivers which do not contain coarse fish.

The focus of NRW and other agencies in the UK has been on avian predation during smolt migration on the basis that a smolt lost on its migration to the sea cannot be replaced whereas a parr lost in a spawning stream can be replaced! The migrating smolt studies tend to indicate significant smolt losses on upper reaches of rivers but whether this is due to avian or other predation is not clear. The theory that we only need to consider losses to migrating smolts is that it is larger parr which smolt (they need to attain approx 100gm in weight) and these larger parr take up the best feeding stations. If these larger parr are eaten then their place will be taken by a smaller parr who will grow large enough to smolt once they have taken up the recently vacated feeding station and so there is no problem. I am not sure if this is a logical statement but it seems to be the one that ‘scientific opinion supports’ and therefore only investigation into predation during smolt migration is considered vital. However studying migrating smolts, important as this is, is an after the event study as recruitment of juveniles has already been decimated over the winter months.

The problem we face is the conflict between two protected species, on the one hand goosanders which are not endangered, not native (but who have naturalised in the UK) and which have no known predators in the UK and salmon and sea trout which are regarded as being ‘at risk’. In fear of reactions from the RSPB and Wild Justice birds are therefore treated as sacrosanct by UK agencies. Unless and until the biomass consumed by FEB’s is recognised as damaging there is little prospect of a recovery in our stocks of salmon and sea trout. Many angling clubs have counts of FEB’s on their rivers and from this it is possible to estimate the biomass loss to these birds but it seems we are not to be trusted to provide unbiased data for fear of a legal challenge from those who have no concern for our fisheries or the damage FEB’s are inflicting on migratory fish stocks. Both I and supporters of CPWF believe that the criticism of NRW is entirely justified and I would welcome the opportunity to discuss both this and other fisheries concerns with you in a face to face meeting.

Regards

Chris White

Conservation Officer: Campaign for the Protection of Welsh Fisheries (CPWF)

"Angling light up my life." No idea who singer is but the song is brilliant and says it all: thank you.

Thanks to John Eardley!

quote in “Fishing Wit” by Richard Benson:
“Never doubt the environmental knowledge of a consistently successful fisherman. Always doubt the motives of a consistently argumentative environmental bureaucrat”

To NRW re FEB's

Rich/Joel,

Further to yesterdays LFAG meeting debate on FEB’s (note my title – other than Pike I don’t know of any fish eating birds!).  As you will have noted there is overwhelming frustration due to the procrastination on this subject.  NRW were quick enough to impose restrictions on anglers in order to conserve fish stocks and yet shy away from one of the root causes for the decline. 

In the presentation by Pat Lindley at the fisheries forum he raised the conservation conflict between salmonids and FEB’s.  The difference is salmonids are all declared as ‘at risk’ whereas FEB’s are increasing, I refer here to the attached the BTO Wetland Bird Survey 2018 -19 and would direct you to page 12 which shows the trend for all wetland birds – goosanders don’t seem to be in decline.  Neither are cormorants in decline which have their own section on page 28.  The problem with the BTO survey it does not declare numbers instead it refers to trends and indexes I have attached my notes from the Fisheries Forum sent to CPWF supporters re FEB’s which shows the upward trend of goosander in Wales.  The graphs are scaled as an index without a reference datum to numbers.  Without knowing the numbers it is difficult to determine the damage to a fisheries biomass assuming each bird consumes at least 400gm of fish per day.  Is there anyway you can put numbers to the graphs shown in my meeting notes as these graphs are Wales specific, having said this I suspect that counts are for wetland i.e. coastal observations and maybe some main river stems in Wales. 

I can’t remember if it was Chris Porteous or Ian Macdonald who raised the issue of angler participation in bird counts the response did nothing to build confidence in NRW going forward with respect to avian predation. 

During my time as Secretary of Conwy Valley Fisheries & Conservation Association in 2012 I organised an FEB survey using BTO methodology, we sectioned the Conwy system from Llanrwst up to Betws but stopped at Tyn-y-Cae i.e. excluded the Lledr and upper Conwy system although we did include the Llugwy as far as Miners Bridge.  I was unable to take part in the survey due to work commitments and this was carried out by volunteers under the guidance of the late Bob Wilson who was at that time living in Betws as fisheries manager for the Gwydyr Fishery.  From the counts that Bob gave me, based upon a goosander eating 400gm of fish per day and a cormorant 500gm per day I estimated we lost upwards of 20,000 smolt equivalents per year. 

Unfortunately Bob kept the count records and since his death these are no longer available.  However this demonstrates our ability to conduct FEB surveys and provide results.  Once CVF&CA could no longer operate our stocking programme it was dissolved and surplus funds transferred to the Clwyd, Conwy & Gwynedd Rivers Trust (now NWRT) ring fenced for use on Conwy restoration projects. 

I have attached a copy of the FEB survey conducted on the River Eden (this mirrors what we did on the Conwy) which clearly demonstrates the ability of anglers and riparian owners to gather information on FEB’s.  There may have been some double counting in this survey due to birds in flight but the numbers counted are enough to demonstrate damage that can be done due to FEB’s.  Between November 2019 and March 2020 the average count is 463 for goosander and 231 for cormorants allowing for 50% error there could have been 400 FEB’s feeding on the Eden over this period.  Assuming each bird consumes 400gm of fish per day then 160Kg of fish per day could be eaten; over the 18 week period (November to March) this equates to 20 Tonne.  Whilst the numbers may be inaccurate the point is well made in terms of the effect that these birds can have on fish stocks.  For the Eden the diet will not be exclusively salmonids – this is not the case for North Wales rivers (other than the Dee) which only have salmonids (excluding minnows and loach).

For NRW to say that you need to study FEB’s to provide evidence of harm beggars belief, these birds eat fish or as one of our supporters put it ‘they don’t eat salads’.  There seems to be more concern about a legal challenge than in doing something to reduce the level of salmonid predation, action is needed now.

There is perhaps a simple and cost effective way of gathering data on FEB numbers across Wales and that is by engaging with riparian owners and anglers in order to assess numbers as has been done on the Eden.  It may be possible for some of this to be carried out using drones to overfly rivers and film birds for counting later particularly in upland spawning areas where access is limited.  Perhaps it would also be prudent to install camera traps (which are relatively inexpensive) at electro fishing sites any sightings of FEB’s at these sites could  perhaps explain the variability of counts, this could go some way to verify the accuracy of the data used to estimate the conservation limits.

We are not the enemy but we are treated with contempt when we suggest anything which goes against the NRW policy of treating bird populations as sacrosanct not to be touch for fear of the RSPB or Wild Justice raising a legal challenge.  If our salmonid fish stocks are to be restored then action needs to be taken now – not in two years time.  It is time for NRW to fully engage with its stakeholders and commit to carrying out some positive action, we are willing to help but NRW needs to take the lead sooner rather than later.

Chris White