Dear Ms Pillman,

27th September 2019

Clare Pillman

Chief Executive, Natural Resources Wales Ty Cambria

29 Newport Road Cardiff

CF24 0TP

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

Dear Ms Pillman,

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

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

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

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

1 Campaign for the Protection of Welsh Fisheries

2 Local Fisheries Groups

3 North Atlantic Salmon Conservation Organisation

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

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

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

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

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

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

4 Catch & Release

5 Full-time equivalent

6 Environment Agency

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

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

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

Yours sincerely

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

Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group

Mervyn Williams – Chair, Dee Local Fisheries Advisory Group

On behalf of:

Bangor on Dee Salmon Angling Association

Campaign for the Protection of Welsh Fisheries

Capenhurst Angling Club

Chirk Syndicate

Clwyd Federation of Angling Clubs

Corwen and District Angling Club

Dee Fisheries Association

Dolgellau Angling Association

Dolwyddelan Angling Association

Llanbrynmair Angling Association

Llangollen Maelor Angling

Llyn Guides

New Dovey Fishery Association (1929) Ltd

Ogwen Valley Angling Association

Penrhyn Fishing Club

Prince Albert Angling Society

Rhagatt Estate

Rhyl & St. Asaph Angling Association

Rossett and Gresford Fly Fishers

Seiont Gwyrfai & Llyfni Fishing Society

Vale of Clwyd Angling Club

Wirral Game Fishing Club

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