Chris White to the Minister: again!

President

Allan Cuthbert Email: 1highplains@gmail.com

Strategy Officer

John Eardley: Email: johneardley@btinternet.com

Conservation Officer

Chris White Email:chriswhite.cohite@gmail.com

10 December 2019

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

Dear Minister,

At the recent joint (Dee/Gwynedd) Local Fisheries Advisory Group meeting held in Bala the Chief Executive of NRW (Ms Pillman) attended to answer questions on how NRW can carryout their statutory duties with respect to fisheries and how the impending byelaws will reverse the decline in migratory fish stocks. The first agenda item for the meeting was an update on enforcement activity. The enforcement officer responsible for North West Wales reported that the current situation with respect to enforcement is a disaster with most of his team gone. With 45% of the reported fisheries incidents in Wales since July being from North West Wales and only 2 staff available to cover the whole area, he made a desperate plea to those present for help, sadly co-operation from anglers is unlikely to occur due to the byelaws effectively stopping fishing on many North Wales rivers.

I note in the Labour manifesto that should they be elected in England Labour intends to: “Introduce a ‘rural proofing’ process so that all our laws, policies and programmes consider their impact on rural communities” and yet the Labour Government in Wales has ignored the impact that the fisheries byelaws will have on rural communities and intend to implement legislation which is effectively un-enforceable and will do nothing to reverse the decline in migratory fish stocks.

In my previous correspondence I referred to the inquiry which accused objectors of not presenting any evidence. The problem was the inspector failed to understand the evidence we presented i.e. there are enough salmon and sea trout spawning it is the in-river losses due to pollution and predation which are the main issues (50% of smolts never get to sea). With respect to the challenge on the statistical  methodology used by EA/CEFAS/NRW to determine conservation limits the inspector, at the insistence of the NRW barrister, refused to admit this as evidence and completely ignored this in his findings.

Over the past few months the North West Angling Trust Fisheries Consultative Council with the assistance of Prof Brian Revel has been carrying out further analysis of the methodology used by the EA/CEFAS/NRW in assessing the river stock levels and the findings have now been presented to NRW and the other agencies to demonstrate the flaws in their statistical analysis and how the data has been skewed

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

Visit our website at www.cpwf.co.uk

by ignoring certain variables i.e. drought/flood, reduction in the number of anglers fishing etc. We can provide copies of the relevant documents should you so wish.

Since the salmon season closed anglers have been reporting salmon ascending the Dee/Conwy in large numbers, there is no exploitation of these fish and they are therefore not included in the calculation of conservation limits. Photographs of these fish ascending barriers are available if required.

It is unclear how your instruction to NRW to produce a ‘Plan of Action for salmon and sea trout’ will help in reversing the decline in migratory fish stocks. We have had various ‘Salmon Action Plans’ over the past 20 years none of which has reversed the decline. The key feature from most LFG workshops for input into the Plan of Action identified fish eating birds (FEB’s-mainly goosander) as a major contributor to the decline in fish stocks on Welsh rivers. To put this into perspective according to the NRW FEB forum there are 305 pairs of nesting goosanders in Wales (610 goosanders). Each of these birds consumes 400gm of fish per day and assuming they are resident all year these birds will consume circa 90 Tonne of fish per year. In addition there are an estimated 5,394 overwintering goosanders in Wales all consuming fish. It should not come as surprise therefore that fish numbers in Wales are in decline – goosanders used to be rare but have now established themselves in the UK, they are not a native bird but since the 1950’s have become ‘naturalised’. It  is interesting to note that according to the Wetland Bird survey goosanders are in decline probably as they have eaten all the available fish!

I would yet again request a meeting with you to discuss this issue, I accept that this is low on your agenda and you have to take advice from your advisors but your electorate deserve a chance of putting their case to you, at least Ms Pillman faced her stakeholders and listened to our concerns. We are all working to reverse the decline in migratory fish stocks, this is about conservation and not more fish for anglers to catch; the byelaws will simply drive a wedge between anglers and NRW and is unlikely to reverse the decline. After 25 years of restrictions on the Wye and millions of pounds spent on restoration/barrier removal there has been no noticeable improvement in migratory fish stocks, the 2019 salmon catches on the Wye are the lowest in recorded history with only 344 reported salmon caught by anglers.

As Prof Lynda Warren said at the 2015 NRW Board meeting held at Clawdd-Newydd extending restrictions which have been demonstrated not to work is futile and yet this is the route being taken by NRW. Anglers are not the problem; we are just being used as a scapegoat to detract from the failure of agencies to address the root causes.

Regards

Chris White

Conservation Officer: Campaign for the Protection of Welsh Fisheries

cc Mark Drakeford – First Minister

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