From: Paul Cawthorne <paulcawthorne1966@gmail.com>
Date: 25 August 2022 at 08:51:58 BST
To: Ruth.Jenkins@cyfoethnaturiolcymru.gov.uk, “Wilson, Ben” <Ben.Wilson@cyfoethnaturiolcymru.gov.uk>, clare.pillman@cyfoethnaturiolcymru.gov.uk
Cc: Gail Davies-Walsh <Gail@afonyddcymru.org>, Alicia Leow-Dyke <alicia@rwtwales.org>
Subject: Welsh Dovey beaver plans under-researched and under-strategised
Dear Ruth,
Further to meeting on the Dovey yesterday. Following Alicia’s kind agreement to a meeting, it was good to meet several workers on beaver issues- a researcher, a consultant and a lead implementer if we understood correctly. It is clear the science of barriers to migration, fry to adulthood survival determinants and environmental damage are highly contested as soon as specifics are reached. We were able to identity parameters where more clarity was needed and perhaps achievable. It would be good to have those more fully discussed before any further movement on this issue, especially as there is a distinct whiff of attempted fait accompli about the present juncture, which you are well-placed to bring back into proper relationship. Without the apparent present rush to authorisation, consensus does look achievable by prioritising proper research in an agreed framing between interested parties. Space still exists for that until you authorise beaver release, but clearly will not after the event.
In the Dovey valley, anglers are deeply scarred by the severe power imbalance of the departmental inspector’s unsafe report based on an expensive barrister’s non-angling analysis, which prepared the way for draconian restrictions on angling which have led to an exodus of anglers from migratory salmonid angling in Wales recently. This is evidenced by the spread of licences purchased, as the repeatedly refused impact review would display clearly. That is the sad, and wholly avoidable, context we find ourselves in. We are reluctant to speak for Dovey farmers but after speaking with NFU reps and press associates and with one of our alliance being a farmer, initial indications are clear that farmers feel similarly marginalised to anglers. We understand that there was a very strong rejection of the beaver release proposal by valley farmers collective reflection and so the stage seems set for more of the kind of vigilante activity which is happening in Scotland.
This of course mirrors the officially blindeyed prior vigilante activity which has already led to unenclosed beaver presence on the Dovey with observable damage to trees. The lack of official activity in response to that vigilantism is glaring and diagnostic of the apparent fait accompli attempted framing. As the Director of the Wild Trout Trust writes: “We have, from the very outset, challenged NE on illegal (what they call unauthorised) releases, but there’s little or no appetite for action…..Of course, it’s emboldened the illegal releasers since they’ve no chance of being pursued or caught…”
The official disdain and lack of listening is summed up for us by two reported occurrences:
1. the Dovey enclosure being reportedly built a month before the consultation finished. If true (please confirm for the record), this seems unacceptable behaviour, yet where is the accountability? The Minister deserves better from her arms-length helpers.
2. Richard Evans relates how he walked the banks with members of your team pinpointing barriers to migration and coming up with a consensus plan for their removal, yet now you seem intent on allowing FRESH barriers to be created. Where is the NRW policy coherence?
So it really brings us to the point of asking whether you, as NRW policy director, want a regulated situation or a free-for-all, where the remaining vestigial respect for official process and the integrity of officials who determine process evaporates altogether.
It is not clear to our alliance what process led to the selection of the Dovey as a setting for this experiment. We were not consulted (were we, please confirm to the Minister) and are now being expected to meekly trust that same officialdom will agree with us on the same riverbank which particular barriers to migration are problematic and then remediate them. In this jaded setting of lost trust among politicians and farming and angling organisations Natural Resources Wales criticised in Senedd over ‘lack of trust’ | The National Wales , that is a big ask, which will become well-nigh impossible if you just plough on with authorising release before a proper debate about illegal releases (rather than a commissioned all-clear from a Beaver Trust young researcher who talks about the Cowx review being “ridiculed”).Without a consensus consultative review of the salmonid migration barriers issues actually happening in a catchment-specific way prior to authorisation, NRW’s lack of clothes will be evident for all to see and you will have burnt your remaining bridges with our alliance.
We really do not want to spend the coming decades having to try to find beaver dams within the fortnight to be allowed to remove them or face the same insanely cumbersome paper chase licensing system that currently applies for goosanders. Promising it will be sorted soon simply doesn’t cut the mustard. Once it is sorted, then we can start to trust again. So it was poignant that there was a flock of eleven goosander sat at the tail of the bridge pool as we met and a shoal of smolts obviously too scared to descend and shoaled vulnerably in shallow water above the tail.
We noted from America the strange and tiresome new human activity of putting chickenwire round numbers of important trees to reduce damage and our alliance is not convinced that will happen sufficiently reliably through a volunteer squad. Please ensure protocols are completed in writing before any authorisation or it will lead to an appearance of being ultra vires and this will be fully scrutinised.
We are not clear the freelance ecologist understood the crucial technical point that descending smolts taken by FEBs are not a loss compensated from elsewhere in the river system, in the way that some parr losses can arguably be considered. This was disappointing to our technical people. To add more dinner tables by fresh beaver dams closer to the spawning grounds higher up the system intuitively seems foolish at best. It was stated that FEBs won’t learn to fish them, which showed a profound ignorance of the Dovey system where cormorants and goosanders are often encountered up the sidestreams and with a very clear preference for the deeper sections for hunting. We know more than academics at times about our rivers due to the time spent quietly learning along the banks, without fuss or plaudits but with deep expertise. To say that FEBs won’t learn to use fresh dams much was a dangerously self-interested statement. The extra time descending smolts will remain trapped above such dams in times of low flow such as this year’s is obvious to anyone with eyes to see and it is perhaps disingenuous or wishful to say it will average out across an ecosystem or across years. It was good that the lead implementer yesterday recorded his “concern” about descending smolt losses. There will almost certainly be substantial net smolt loss. Your own organisation recognises this issue “migratory fish past the age of smoltification have no such compensatory mechanism and any loss due to predation then is a net loss to the population” Natural Resources Wales / Salmon and sea trout plan of action for Wales 2020: areas for action, so what are you going to do, add to it ? !
Potential support for hatcheries was given by the team, as a trade off to compensate for the anticipated smolt losses. Please would you clarify to them and us at this early juncture whether that would be looked on favourably by NRW. It is a possible area of helpful joint enterprise as long as not kyboshed by NRW, so your early comment will be appreciated.
At the meeting, we asked for proposed management protocols to be made open to discussion and finalised by consensus PRIOR to authorisation (particularly agility and light touch guiding of dam removal with autonomy retained, such as short lead-in time to dam removal, a key issue identified by STC). Again, if it doesn’t happen that way round, our scepticism will have been justified. Please reflect on the full implications of these sentences, as they are wide and deep well beyond the specific issue.
Please see the attached formal complaint to IEPAW, which probes the legal situation and NRW’s evident conflicting objectives, and requests expert scrutiny of the apparent present mess.
We look forward to your involvement in helping the dialogue tentatively begun to flourish rather than fail as your team’s much vaunted “working more effectively with anglers” (P. Gough Jan 2018) in practice so disastrously did.
You have the chance to do better this time round and we respectfully urge you to take it.
Yours sincerely,
Mark Frey, Paul Cawthorne, Karl Humphries, Richard Evans