Letter to NRW Board

16th September 2019

Sir David Henshaw – NRW Board (interim Chair) NRW Board Members
Via email: nrwboardsecretariat@naturalresourceswales.gov.uk

Re: NRW fisheries bylaw proposals

Dear Sir David and fellow Board Members,

We find it necessary to make you aware of the serious concerns that were raised at a meeting of angling representatives from the Dee and Gwynedd Local Fisheries Groups held at the Owain Glyndwr Hotel, Corwen on Saturday 7th September. 19 Fishing Clubs/Organisations with a combined membership of several thousand anglers were represented at this meeting which was called as a result of the anger and frustration that is being caused by the actions of NRW in its relentless pursuit of a legislative solution in the case of both the All Wales Byelaws and Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019, both of which are referred to in Paper 19-09-B14 which will be presented to you during your meeting on Thursday of this week.

You should also be aware that those present at the Corwen Meeting are well respected figures within both their own organisations and the angling community in North Wales in general and furthermore have extensive knowledge of their own rivers. That such people are talking in terms of militant action and civil disobedience should give you great cause for concern

At the close of the NRW Board Meeting on 18th January 2018 the gulf between angling stakeholders and NRW was highlighted by board member Zoe Henderson and this was followed by much talk of how “we have failed to engage with stakeholders” and must take immediate steps to put this right. Subsequent events at the Inquiry into the All Wales Byelaws during January and March of this year when Counsel for NRW saw fit to attempt to discredit ordinary decent people who sought only to protect their own fisheries from NRW’s actions has plunged that already fractured relationship to new depths. The fact that Counsel and External Solicitors were paid the princely sum of £259,978.26 to carry out these actions only adds insult to injury. That the Principal Fisheries Advisor explained at the Inquiry that in a previous acknowledgment that anglers know their own rivers better than NRW what he really meant was that they know the location of the stiles and footpaths is laughable as well as insulting. The end result is that there are a number of angling clubs who will no longer engage in any future meetings with NRW whilst their concerns are treated in such a dismissive way. Furthermore they will instruct their bailiffs to no longer check that their members have purchased a rod licence and to only enforce their own clubs’ rules. Further concerns related to the decline in the number of both local and visiting anglers despite the encouraging numbers of both salmon and sea trout that have been observed in our rivers this year. This will have repercussions on the ability of smaller community based clubs to afford to rent waters in the future and be a threat to their very existence. The presence of anglers on the riverbank also acts as both a deterrent to poachers and a source of intelligence for NRW’s Enforcement Officers and it is therefore unsurprising that increasing illegal activity has been a major concern for us during the year.

Education, co-operation, empowerment and partnership has seen Voluntary Return Rates rise year on year to an all-time high of 86% across Wales yet NRW has chosen to turn its back on those values which have brought us so far, in the pursuit of an autocratic solution. In so doing it has alienated those very stakeholders whose knowledge of their own rivers is so necessary for their recovery and that is a great concern for those of us who are actively involved with both Rivers Trusts in North Wales. NRW may recognise that “we have able partners in the rivers trusts and need to maintain a productive relationship with them” but is making it ever more difficult for those organisations to recruit volunteers.

The following should give great cause for concern.
We note in Paper 19-09-B14

Arrangements for the cross-border rivers Dee and Wye
4. Following Board approval in July 2018, an application will shortly be made to the Minister for confirmation of new rod fishing byelaws for the rivers Dee and Wye (The Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019). Because these byelaws have been dependent on ministerial confirmation of the All Wales Byelaws, this application could not have been made prior to receipt of that confirmation.

Wales, along with all other countries which have runs of Atlantic Salmon, is duty bound to follow NASCO (North Atlantic Salmon Conservation Organisation) policy.
NASCO International (North Atlantic) Conservation Policy and common Wales & England national Policy is defined in the 2018 Assessment of Salmon Stocks & Fisheries in England & Wales
(Background report), Annexe 7 – Salmon Management Procedures in England & Wales, Page 77 & 78 – Decision Structure in E & W.
The decision making structure set out in the report is very clear

“3. Third stage – option evaluation (purple boxes)
The purpose of this stage is to set out and evaluate options to realise the required changes in exploitation. For rivers where 50%≤p<95% (where p= probability of failing the management objective) and the trend is down and with an annual catch of >20 salmon and C&R rate < 90%, then voluntary C&R will promoted for 1 year. If this fails to significantly improve C&R rates, mandatory C&R or closure of the fishery will be considered. Protected rivers such as SACs (Special Areas of Conservation) are given particular emphasis”

This is recognised in NRW Board Paper B B 40.15 Annex 2, TECHNICAL REPORT: MANAGEMENT OPTIONS TO ADDRESS THE DECLINE IN STOCKS OF SALMON AND SOME SEA TROUT IN WALES
which states quite correctly that:
The decision structure is currently not applied to:-
• rivers where the voluntary C&R rate is greater than 90%, as it has been felt that the extra benefit on any individual river does not warrant the costs of pursuing statutory control.

Furthermore NRW’s 2017 “Know your river document” for the Dee makes the following statement: “The release rate in 2017 was 91%. This is an excellent result and needs to be maintained”
Put simply the River Dee is fully compliant with NASCO policy and according to NRW’s own documentation “does not warrant the costs of pursuing statutory control”.

On that basis the introduction of statutory legislation would be a clear breach of NASCO policy.

You will not be surprised that we will be challenging any application to the Minister for confirmation of new rod fishing byelaws for the cross border Dee most strongly and furthermore will have the support of our English colleagues who will mount a similar challenge to the EA given that “It has previously been agreed

with the EA that they will make a simultaneous matching application to DEFRA for confirmation of complementary byelaws in the English parts of these two cross-border rivers”. We also believe that there will be considerable support from AMs for this action.
Furthermore we will also seek deferment of the All Wales Byelaws until such time as voluntary C&R has been promoted for 1 year in accordance with NASCO guidelines. NRW’s Know Your River documents clearly show that no active promotion has ever taken place.

90 – 95% of the salmon that enter Welsh rivers are not caught by anglers. Given that anglers currently return 86% of that relatively small %age of salmon that they do catch, it makes no sense whatsoever to drive them away and allow poachers to fill the vacuum, particularly as this will result in significantly greater losses.

Anglers, and the revenue which they generate, are vital if our fisheries are to survive and a worthwhile Salmon and Sea Trout Plan of Action is to become a reality. NRW has to stop being so dismissive of our concerns and be prepared to participate in a meaningful partnership. That in itself requires a significant change of policy.

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
Dolgellau Angling Association
Dolwyddelan Angling Association
Llanbrynmair Angling Association
Llangollen Maelor Angling
Llyn Guides
Ogwen Valley Angling Association
Penrhyn Fishing Club
Prince Albert Angling Society
Rhyl and St. Asaph Angling Association
Rossett and Gresford Fly Fishers
Seiont Gwyrfai and Llyfni Fishing Society
Vale of Clwyd Angling Club
Wirral Game Fishing Club

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