Notes of meeting with Julian Bray

On Wednesday at the suggestion of the Minister along with John Eardley we met Julian Bray as Head of Inland Fisheries for WG together with Luke Davies who works for Julian, the meeting was held in the Llandudno WG offices between 10:00 and 12:00. 

I had previously worked with Julian when he was EA(W) Fisheries Manger for North Wales he also took over the running of hatcheries from memory around 2012 and John and I worked with him on our stocking programs on the Mawddach and Conwy.  Julian left EA(W) to take up the role of Marine Fisheries Manager for WG prior to the formation of NRW – he sensibly stayed with WG.  Julian was appointed to Inland Fisheries for WG in July 2019 following the retirement (?) of Jeremy Frost in April 2019 and therefore had no involvement in the 2017 Fisheries byelaws.  In his new role he is playing catch-up and as such is ‘keeping his counsel’ on what went on before he took on the Inland Fisheries role. 

I have attached the agenda items we covered at the meeting, Luke took the minutes and as soon as I get these I will forward them to you.  I had printed several documents for the meeting including the two letters that Gary Davies (Merthyr AA) had sent to LG and HB, Julian read these and I passed them to Luke who said he had already received a copy.  I had believed for some time that LG had not read any of our letters and they simply get passed to the back office staff (Luke?) to draft a response which is then top and tailed by the Minister, probably without understanding the contents of the original letter or her response, hence the refusal to meet with us.  Perhaps we have been a bit naïve in believing that LG had read the letters and was taking a personal interest, I have always had my doubts, more so as Julian said that we must take up our issues with NRW.  Perhaps someone should ask their local AM to raise a question about this in the SENNED. 

The following are the responses to the agenda items:

  1. Evidence that the byelaws will reverse the decline in migratory fish  – Reduction in angling days/rod effort skewing results.

We discussed the lack of evidence that the byelaws (with or without legislation on agricultural pollution) would not reverse the decline in migratory fish.  The stock answer was the decline is due to marine conditions and climate change.  We demonstrated from the data that Mike Ashwin has produced that the reduction in angling effort has marked effect on the numbers of fish caught and the calculation of the conservation limits, we were told to take this up with NRW.

  1. Failure of WG to implement promised legislation on agricultural pollution – promises made by NRW under oath at the inquiry

Julian claims that the legislation has just been ‘postponed’ and that it will be implemented at some point in the future.

  1. Lax concern for the aquatic environment in planning applications for chicken farms e.g. Fron Bella farm

We discussed at some length the potential for the chicken farm on the headwaters of the upper Conwy to have a serious impact on water quality.  It was one of Julian’s projects to establish this upper spawning area once the Conwy falls fish pass was constructed in 1993.  I identified the fact that there was no concern for the aquatic environment during the planning approval process and that it was claimed by NRW that no EU species would be affected.  I was directed to take this up with NRW and I am in the process of doing this.  Julian asked if his work on habitat improvements had been successful and I have sent him the fish counts and our Trust 2014 report (see attached) to demonstrate what is now at risk should there be a pollution event from this chicken farm which is sited at 300 M at the top of the catchment (80 M above the Afon Nug a major tributary for the upper Conwy).  Despite the evidence of the increasing numbers of salmon and sea trout ascending the Conwy Falls the Conwy is classified as probably at risk, this is mainly due to the sites NRW electro fish which were damaged by recent floods (one site on the upper Conwy is now to deep to electro fish) it was just convenient to use the 2015 results to support the low fry and parr counts despite this being due to flood events.

  1. Inappropriate approval of hydro schemes 

At the last Fisheries Forum held in Carmarthen we had a presentation on HEP schemes (see attached, the slides on ‘spate clipping’ shows what happens on many HEP schemes) by Gideon Carpenter explaining the NRW guidance for licensing hydropower schemes and the technical background to the approach (the slides were used to support the talk by Gideon).  Julian referred to this presentation to demonstrate NRW is doing a good job!  I pointed out that existing schemes only need to ensure upstream passage of returning adults – the issue is about the downstream migration of smolts, the latest designs in the presentation should enable easier downstream migration but there are no plans for retro fitting existing schemes many of which simply used pre-existing weirs.  I will pursue this via the Fisheries Forum.

  1. Disturbance of spawning grounds by adventure activity.  Byelaws required to protect these areas, this is within the power of NRW

This something that I had worked on with Julian in 2012 who had produced the ‘know your rivers’ diagrams at the ‘put-ins’ used by paddlers on the Conwy – they ignored them!  I showed Julian the sign that had recently been put up by Gwynedd CC on the Afon y Bala which runs into Llyn Padarn.  We discussed the powers of NRW to introduce byelaws to restrict ‘boating’ under the Water Resources Act 1991 (Schedule 25 if you want to look it up).  Julian suggested that whilst byelaws are possible it may be more sensible to just have warning signs erected at spawning sites rather than introduce byelaws and all that this involves i.e. consultation and who the respondents will be which may not result in byelaws being passed.  Far better to get National Park or Local Authorities to put up warning signs this also gets around the planning permissions which are required for these signs.

  1. Lack of action on control of avian predation

Julian pointed out that there is already a committee looking at this the problem  The problem is there is no action yet but Julian put a lot of faith in Steve Ormerod taking positive action.  I will take this up at the Fisheries Forum.

  1. Failure of NRW to publish in full the 2020 byelaws

I pointed out that all that NRW has published are 2017 amendments to the 1995 Fisheries Byelaws.  The impression given on the NRW website is these are all anglers need to know and this is not the case.  The 1995 Byelaws are river specific and list fishing restrictions near obstructions on each river.  The impression at the moment is that the 1995 Byelaws have been revoked – this is not the case you need to refer to the confirmation by the Minister to see the sections which have been revoked.  I have already taken this up with NRW and will continue to pursue this.  I have attached the compendium of the byelaws which was produced in 2003 this was superseded in 2014 with the glossy brochure ‘A guide to anglers fishing in Wales’ both have now been removed from the NRW website.  NRW should publish the byelaws in their entirety for clarity of what and where we can fish the NRW excuse at the moment is that anything on the website must be ‘accessible’ to all.

  1. Lack of resource and funding within NRW to fulfil their statutory fisheries duties.

Julian said that NRW are now ‘outsourcing’ the river restoration work to Rivers Trusts via Afonydd Cymru due to their lack of in-house resource.  This has the support of WG.

  1. Reliance on self regulation as NRW do not have sufficient resource to enforce the byelaws

Julian was not aware of the reduction in enforcement staff.  We raised the level of poaching which is doing far more damage than anglers to the broodstock in Welsh rivers.  I was advised of one local poacher who declared he had taken 11 salmon from the Lledr he is just one of many poachers who operate with impunity on our North Wales rivers.  The intelligence lead approach (after the event!) does nothing to protect our fish stocks.  In terms of self regulation we pointed out that the majority were already returning all their fish but those who take fish will continue to do so as who is to stop them.

John raised the issue of the Dyfi Beaver Project explaining those who had attended meetings felt that this was being presented by the Welsh Beaver Project Officer (Alicia Leow-Dyke) as a fait accompli with no evidence of risk assessment or due regard to the interests of landowners or those with a vested interest in the river. It seems that the ‘re-wilding’ of Wales is a higher priority than reversing the decline in migratory fish stocks Luke said that this would not be the case.

To end on a positive note Julian asked if we had any comments on the Salmon and Sea Trout Plan Of Action, my only comment was we have seen promises of action over the past 20 years with nothing coming from them.  I suggested that what gets measured gets done and WG should appoint individual project mangers to oversee the work with clear deliverables and definitive time scales.  This seemed to fit what Julian thinks should be done, it remains to be seen how the Minister responds.


Foot note: I was at a Dee mitigation working group meeting yesterday.  A comment from one of the NRW fisheries officers claimed that there was no shortage of fish on the areas which have been ‘restored’ over the past few years the problem is these sites are not yet included in the annual assessment of fish stocks, I suspect the same may apply to other rivers which have undergone restoration.  This puts yet another question mark over the calculation of the conservation limits on rivers.  We may be catching fewer fish due to a reduction in fishing effort/river conditions and not a lack of fish!

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