Another letter to Lesley Griffiths: by John Eardley . Thanks John.

c/o Vanner Farm & Caravan Site




LL40 2HE


26th January 2018

Lesley Griffiths AM

Cabinet Secretary for Energy, Planning and Rural Affairs

National Assembly for Wales



CF99 1NA

By email to (for the personal attention of the Cabinet Secretary for Energy, Planning and Rural Affairs)

 Copies to:

Carwyn Jones (First Minister)

Dafydd Elis-Thomas AM

Siân Gwenllian AM

Liz Saville Roberts MP

Mark Lloyd (Angling Trust)


Dear Minister,

A number of angling representatives attended the Natural Resources Wales Board Meeting at Reichel Hall, BangorUniversity on Thursday 18th January. Our principal concern was that the Board would endorse the proposal to apply to Welsh Government for confirmation of new fishing byelaws. As you will now be aware, our worst fears were realised, albeit in a decision that was far from clear-cut.

Several board members expressed their concerns that although there is a shared goal of seeing an improvement in fish stocks, there is a wide difference between NRW and angling interests as to the best means of achieving this. Furthermore there were very real concerns that failure to work with the angling community would result in the proposals failing to deliver their intended outcome and we believe that a golden opportunity was missed in the rejection of a suggestion to defer the application to Welsh Government whilst seeking a voluntary approach in partnership with stakeholders from the angling community. Ultimately of course 2 other factors narrowly won the day:

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

Whilst our concerns on the negative impact of these proposals on both angling tourism and the very future of angling clubs along with their serious practical shortcomings were well documented in a letter to Hannah Blythyn dated 30th November (to which you replied on 12th December LG/05304/17), you were unable to comment further until NRW had completed their analysis and the board had made their decision.

We request that the Welsh Government do not endorse the NRW Board request to introduce new byelaws relating to Catch Controls for the following reasons:

  1. The evidence that was presented by NRW Fisheries is neither “sound” nor “quality assured” and is so deeply flawed that we are currently taking advice on legal action. Any such action would mirror that which is currently being undertaken in the North West of England against the Environment Agency. Our supporting evidence is contained within the “Evidence case re NRW Stocks Assessment Technical Report” at the end of this letter.
  2. The introduction of Mandatory C&R will not deliver any improvement in fish stocks. This was pointed out by Board Member, Professor Linda Warren, at the July 2015 Board Meeting when these proposals were first discussed. To state that “we don’t know how much worse it would have been” does not constitute evidence of its effectiveness.
  3. The proposals cannot, and will, not deliver the desired outcome. NRW is currently unable to deal with illegal fishing and simply does not have the resources to police any new byelaws. Furthermore with anglers driven away from the riverbank an important deterrent will be removed thereby increasing the amount of illegal activity. In addition a reduction in the number of anglers, together with the alienation of the angling community, will have a negative impact on the intelligence reports that the overworked enforcement officers heavily rely on.
  4. The failure to effectively engage angling stakeholders, and the need to take steps to remedy this, was clearly stated at the end of the Board Meeting. However to do this after a decision has been made which will clearly alienate stakeholders is nonsensical. Many of us, who have led the conservation agenda within our own organisations, see little purpose in attending future meetings with NRW when it would appear that our opinions, together with our experience and knowledge of our own rivers, counts for so little. This has the potential to have a serious adverse impact on the delivery of future River Restoration Plans.
    1. The intrinsic and socio-economic value of Salmon and Sea Trout fishing has been ignored by NRW, who within their remit have a duty to enhance its appeal. They have knowingly, developed measures, including severe fishing method restrictions which, if imposed upon fishermen, would relegate the pursuit and deny its cultural worth. With freedom of choice denied and our ability to shape measures to achieve resilience removed, we face a future of unsustainability and limited ability to proactively improve fish stocks.[r1]
    2. The approach to tackling Agricultural Pollution is to work with farmers to achieve the desired outcome (See “The Approach to Nitrate Pollution from Agriculture” – P7). Despite stating that “we do not believe that anglers are the cause of the problem”, NRW Fisheries Team has adopted a legislative approach . This clear issue of inequality must be addressed.
    3. We completely refute the statement on P95 of the “Technical Case Structure” that “Voluntary measures have been promoted for some considerable time and are unlikely to substantially change further in the short term”. A co-operative approach between the NRW Fisheries Team and angling organisations would deliver a much better outcome than continuing with the introduction of legislation which is doomed to failure from the outset.


NRW has stated that it “aims to deliver widespread and positive partnership working” but in order to do that it must engage with angling stakeholders. There is a feeling that having invested so much time and resources in pursuing its “preferred option” it has backed itself into a corner and the result is an “emperor’s new clothes” scenario which Welsh Government must bring to an end. To achieve that the proposals to introduce new byelaws must be deferred until such time as:


  1. A thorough review of stock status assessment by EA, NRW & CEFAS has been undertaken
  2. A collaborative approach to improving voluntary release rates, effectively tackling illegal activity and implementing River Restoration plans, including a timeline for implementation, has been developed through Local Fisheries Advisory Groups.
  3. Such a collaborative approach has been given a fair chance to work.

If we can reach agreement on this, and start to repair the damage that has been caused to the relationship between the NRW Fisheries Team and angling interests since this whole sorry saga began, then we would of course immediately suspend any planned legal challenge. This has to be the way forward.


Yours sincerely



John Eardley – Gwynedd Local Fisheries Advisory Group Representative – Prince Albert Angling Society


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