Mike Ashwin Chairman NWATFCC North West Angling Trust Fisheries Consultative Council to Lesley Griffiths

North West Angling Trust Fisheries Consultative Council part of the Angling Trust and AT North West Freshwater Forum

8 th February 2020

To: Lesley Griffiths AM, Cabinet Secretary, Welsh Assembly Government


Cc Peter Gough, NRW Principal Fisheries Adviser Heidi Stone, EA Salmon Programme Manager Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPWF Approval of Cross border Welsh Dee & Wye byelaws & Implementation of All Wales Byelaws

Dear Lesley,

Thank you for your letter of the 4th February 2020 and with it, comments and clarification of the Cross Border approval decision process. We note your approval of these Byelaws on the 29th January, the day after receiving our request to carefully review this intended action and our strong recommendation to introduce interim arrangements until the two imminent national (NRW, EA & Cefas) stock review processes are concluded. We find it difficult to comprehend this decision in the light of the information we provided and questions we have raised over the Welsh Dee Index river methodology and outputs that determine other Welsh river stocks. The national England & Wales Stock reporting and Assessment system may have been found to be “Fit for Purpose” at the local Inquiry by the Planning Inspector. But I can assure you, it is certainly not fit for purpose, has not undergone validation when introduced in 2004 or subsequently been QA reviewed since that time. The substance and scope of the two national review processes testify to that and we anticipate the system will undergo major overhaul which will make historic assessments unsafe. I refer you to NWATFCC correspondence (attached) with NRW, EA & Cefas that sets out the vision of those improvements that rod fisheries expect to see addressed in the NASCO 2019 – 24 IP and separate national Rod exploitation rate review. 2020 enacted Byelaws carry a penalty that 5 year mid-term review arrangements will lag 3-4 years behind these national review improvement implementations. The enforceability of the All Wales byelaws is a major and unforeseen consideration and Cross Border Rivers, where E & W national measures are not aligned and diametrically opposed pose additional complexity and resource allocation that is not available. This at a time when stocks will be threatened by increased poaching activity through reducing angler presence and supervision. In view of the significant impact the All Wales and Cross Border Byelaws are expected to have on migratory licence sales and rod effort, and here we are anticipating a 25% – 35% reduction in 2020 on top of a 40% – 50% reduction in both over the last 9 years,

NWATFCC , PAAS & CPWF are now taking legal advice over the approval of the Cross Border byelaws.

With kind regards Mike Ashwin Chairman NWATFCC North West Angling Trust Fisheries Consultative Council The Barn, Skirwith, Penrith, Cumbria CA10 1RH. Tel 01768 879047 mob 07926 489764

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