To: Chair and members of the NRW Board

Campaign For The Protection Of Welsh Fisheries

 

To: Chair and members of the NRW Board

Re: January NRW Board meeting 18 January 2018 – Fisheries presentation

At the Board meeting on Thursday 18 January the NRW Board will be asked to approve the recommendations from NRW Fisheries Officers to impose draconian bylaws which are supposed to protect and stop the decline in salmon and some sea trout stocks in Welsh rivers.  Whilst nobody disputes that there has been a serious decline in salmon stocks this is not unique to Welsh rivers with all of the UK rivers (with some exceptions) experiencing a similar decline.  You will be told that there is a need to increase the number of fish spawning but the real problem is the survival of egg to smolts reaching the sea (smolts are young salmon ready to migrate). Whilst the NRW acknowledge that anglers are not the main cause of the decline in fish stocks they are being targeted as if they were. There are many causes for this decline some of which is due to the conditions in the North Atlantic, the following are the key issues which we believe should be addressed before legislation is used as a blunt instrument:

  • There is no evidence that compulsory catch and release (C&R) is effective in improving recruitment of salmon.  This was raised at the 2015 NRW Board meeting when the proposals were originally presented.  Lynda Warren explained that in 1998 a National Salmon Fisheries Regulation was introduced which required all salmon to be returned until 16 June in order to protect spring fish stocks, Lynda had been part of the committee who made this decision.  After 18 years this regulation has seen little or no improvement in salmon stocks so why do NRW consider that extending this will have any effect?  Several Scottish rivers adopted a voluntary C&R policy more than 20 years ago with a 98% compliance rate and yet salmon stocks still declined.
  • In 2012 NRW introduced a bylaw on the river Wye extending the C&R regulation for the whole season.  You will be told that the Wye is recovering but it should also be kept in mind that some £12M has been spent over the past 10 years on the Wye on habitat improvements – the NRW Ecosystem approach.  Whilst the fishing on the Wye is mostly controlled by landowners and sold on the basis of named days, the majority of the fishing in Wales is controlled by local angling clubs, who have seen little or no money spent on other Welsh rivers and where fishing effort is on a more ad hoc basis and thus very difficult to compare.
  • Between 2013 and 2016 there were circa 3000 pollution incidents in Welsh rivers and yet the Cabinet Secretary has been quoted in a BBC report on 13 December on agricultural pollution as saying that she wants “the right balance of regulation, voluntary measures and investment to tackle pollution from farming” and although backing an “all-Wales approach” she will look at giving farmers flexibility to “achieve the same or better outcomes” than with regulation, flexibility should apply to angling.  Pollution incidents have a far greater effect on recruitment of salmon than angling.
  • The data complied by NRW is based upon angler catch returns which are notoriously inaccurate as there is sadly a culture of not reporting what is caught due to the fear of the costs of fishing increasing if actual numbers are declared.  We have been told that to account for this a factor of 1.3 has been applied, but this still does not fairly reflect the numbers caught, it is a good guess but is not evidence, and this has skewed the results.
  • You will note that 89.9% of respondents are from North Wales, there is good reason for this as local angling clubs have much to lose as the restrictions, even in the amended form, will restrict angling activity and will result in clubs losing members and revenue.  You cannot use the Wye as a benchmark; every river system is different, most are unlike the Wye, as reflected in the individual bylaws at present.
  • There is a claim that NRW has contacted licence holders in Wales with the caveat that this had only been when they had contact details.  The reality is that the majority of licence holders have not been contacted.  In North Wales there has been a concerted effort to ensure that these proposals were disseminated to as many anglers as possible, this is reflected in the response rate i.e. 89.9% of respondents were from North Wales.  The concerns expressed about the proposals at the Local Fisheries Advisory Group meetings, and their effects have been ignored.  You will be told that a decline in angling activity is acceptable as, based upon the Wye this will only be transient, you cannot use the Wye as a benchmark for smaller river systems.  It seems that some concession has now been made with amendments to the original proposals.  Had NRW engaged with its major stakeholders it could have saved a lot of time and money.
  • The proposal is to introduce a whole of Wales bylaw to replace the individual bylaws which now exist.  The existing bylaws are fair and proportionate as they reflect local conditions.   Introducing a pan-Wales bylaw is open to legal challenge.  There is not a one size fits all solution, each river system is different and should be treated on its own merits.
  • The overall voluntary C&R rate in Wales for 2016 is declared by NRW as 72%, this result is skewed due to some rivers with very small catches only returning 50% of the salmon caught. The NRW mathematics are misleading. If looking at just the Wye (828 fish) and the Seiont (2 fish) they would tell the Board that with 2016 return rates of 99.6% and 50% respectively, the mean return rate was 74.8% implying that 212 salmon were killed when the reality is that just 4 were not returned. It is rightly claimed by NRW that some West Coast rivers are killing too many salmon but instead of dealing with these rivers they are being used as an excuse to impose the present proposals on all rivers.
  • Over the past 5 years the weather patterns have had a significant effect on both angler catches (due to low flows) and recruitment (due to flood events).  The poor fry and parr results in 2016 are being used to justify the proposals even though NRW acknowledges the effect of the weather on recruitment over the past 5 years.
  • One of the major contributors to smolts failing to reach the sea is due to avian predation (goosanders and cormorants), it is estimated that this accounts for 40% of the migrating smolts during low flow conditions.  Control of avian predation would have a far greater impact than anything in the NRW proposals and yet the NRW have publicly stated that they have no plans in increase licenced culls and recommend scaring predators away from a fishery……onto the next fishery!

The vast majority of salmon fishers now voluntarily return their fish, some clubs achieving 98% in 2107, there are a few who will still take too many fish but these are in a minority and are normally dealt with by their angling clubs, most of whom impose strict catch quotas.

If the proposals are accepted it will be almost impossible for NRW to enforce them, there is neither the enforcement staff nor the budget to ensure the regulations are followed i.e. there is a reliance on anglers doing the right thing.  It is far better to work with angling organisations and rely on voluntary C&R and method restrictions managed by local angling clubs.  This option has been dismissed in the proposals.

 

Regards

Chris White

Conservation Officer: Campaign For The Protection Of Welsh Fisheries

Natural Resources Wales Board Ignores 83% Consultation Response and Supports Mandatory Catch and Release of Salmon

Press release from The Angling Trust, for which we are most grateful. It would seem that NRW continue to treat anglers with contempt!    AT press release follows

Natural Resources Wales Board Ignores 83% Consultation Response and Supports Mandatory Catch and Release of Salmon

 Anglers reacted in dismay when the Board of Natural Resources Wales supported its executive’s proposals for imposition of mandatory 100% catch and release for salmon anglers throughout Wales at a meeting on January 18th. The Board will now recommend to Welsh Government that this is implemented with effect from the 2018 fishing season, ignoring the 83% of respondents to the public consultation who did not agree with the catch and release proposals.

Angling’s representative body, the Angling Trust, has written to Welsh Government urging it to adopt a voluntary approach to catch and release salmon angling in line with the Environment Agency in England and to address urgently the real reasons for the decline in salmon populations in Wales, which are pollution and unsustainable predation by cormorants and goosanders.

The Trust highlighted the fact that Welsh Government is currently taking a voluntary approach to the regulation of agricultural pollution, which is in stark contrast to the tough line on anglers, who are not responsible for the decline in stocks.  It also pointed out that several major pollution incidents in the past two years, which have killed far more salmon and sea trout than all the anglers in Wales catch in an entire year, have still not led to prosecutions by Natural Resources Wales.  The Angling Trust has in recent years repeatedly called for an urgent action plan to tackle pollution and unsustainable predation by cormorants and goosanders but very little has been done on either issue.

The NRW board acknowledged that it had lost the trust of the angling community and that 83% of respondents to the consultation were opposed to the catch and release proposals.  They were rightly concerned that the new rules would be unenforceable due to a loss of support from anglers, who act as the eyes and ears of NRW for offences on the riverbank.

The NRW Chair Diane McCrea stressed the need for urgent action to restore rivers to good health.  Many anglers feel that Welsh Government and NRW are seeking to destroy angling after recent proposals to open all rivers to canoes and other vessels, an abject failure to promote angling to tourists by Visit Wales and a failure by NRW to recognise the importance of angling to the economy and society of Wales.

Mark Lloyd, Chief Executive of the Angling Trust & Fish Legal, said: “The blame for declining stocks of salmon and sea trout lies firmly at the door of Natural Resources Wales and Welsh Government for their mismanagement of the environment.  It is grossly unfair to make criminals of anglers wanting to take the occasional fish home for their family while they allow polluters to pour poisons into rivers on a regular basis and fail to prosecute serious offenders.  These proposals will drive away visiting anglers and destroy the amenity value of fishing for thousands of local anglers who have fished these rivers all their lives.  We demand urgent action to tackle pollution and unsustainable predation and urge Welsh Government to take a voluntary approach in line with the Environment Agency in England.”

Draft letter from the Angling Trust to Lesley Griffths AM Cabinet Secretary for Energy, Planning and Rural Affairs.

Unfortunately the system will not let me add the Angling Trust Logo                                                                                                                                                                                              Angling Trust

Eastwood House

6 Rainbow Street

Leominster

Herefordshire HR6 8DQ

17th May 2018 By email to: Correspondence.Lesley.Griffiths@gov.wales

 Dear Ms Griffiths,

As you know, the Angling Trust is the representative body for all disciplines of angling with thousands of individual members and members of affiliated clubs in Wales. It is united in a collaborative relationship with Fish Legal, a separate membership association that uses the law to protect fish stocks and the rights of its members throughout the UK.  Freshwater angling is one of the Wales’s most popular pastimes and also makes an important contribution to the economy, generating at least £150 million in revenue, attracting visitors from throughout the world and supporting countless jobs either directly or indirectly.  Angling also has numerous social benefits for individuals and communities and for many local anglers it is their only leisure activity. A large proportion of this angling is for game fish: salmon, sea trout, trout and grayling.

The Angling Trust responded, along with hundreds of anglers, to the recent consultation by Natural Resources Wales regarding the exploitation of salmon and sea trout in Wales.  The overwhelming majority (83%) of responses were opposed to the imposition of mandatory catch and release on the angling community.  We also attended the NRW board meeting where this was discussed on the 18th of January.  We were very disappointed that the board decided to recommend to Welsh Government that the views of the anglers who pay their wages should be ignored and that they should go ahead with banning the taking of fish by anglers, which is something they have been doing for centuries.

Anglers have greatly increased the rates of catch and release in recent decades and they also invest countless volunteer hours and substantial funds into the restoration and protection of our nation’s rivers.  Anglers are often the first to report pollution incidents, poaching and other illegal activity.  The NRW board was rightly concerned from the responses to the consultation that anglers had lost confidence in NRW as an organisation and in Welsh government’s recognition of the importance of angling.

In addition to this consultation, anglers have been faced with your government’s recent consultation which proposed opening up all rivers to navigation, which would destroy our members’ property rights, and a complete failure by NRW and Visit Wales to promote what is left of Welsh freshwater fishing to visitors.  A decade ago, the Fishing Wales initiative generated a massive return on investment, but since it was axed there has been an apparently deliberate attempt to hide the opportunities to fish on Welsh rivers from potential visitors.  It is understandable that many now believe that Welsh Government is deliberately trying to destroy angling.

The NRW board also recognised that anglers are not the cause of declining fish stocks and that the reasons are mismanagement of the natural environment and that urgent action was now required to correct that failure.  Whilst climate change is a factor affecting all salmon stocks, some rivers are still managing to maintain or even increase their populations by successfully managing the other human pressures on the water environment.  However these are very much the exception in Wales.

I have written to you several times about the endemic levels of slurry pollution from the intensive dairy farming areas of Wales, but you have declined to meet with me to discuss this on several occasions and have failed to take the necessary urgent and comprehensive action required to tackle this dire situation, which is getting worse.  In the last decade I have also witnessed in Wales a huge expansion of the area of maize, stubble turnips and over-grazing of pasture that are causing an increase in flood risk and heaping costs on the rest of society.

Your government’s response has been for a voluntary approach to regulation of agriculture, the country’s biggest polluting sector, which kills far more salmon and sea trout than anglers could ever dream of catching, let alone taking home to feed their families.  Two major pollution incidents on the Teifi two years ago killed more salmon and sea trout than the entire annual catch by anglers, but Natural Resources Wales has still not prosecuted either of the perpetrators.  Countless other prosecutions for agricultural pollution are pending.  In this context, the imposition of 100% mandatory catch and release regulations, making it a criminal offence for thousands of anglers to take fish home to feed their family very occasionally looks entirely disproportionate, asymmetric and staggeringly unfair.

I urge you to adopt a voluntary approach to implementing catch and release which would be compatible with the approach that we have negotiated with the Environment Agency in England.  As I wrote to you in a letter in May of 2017, it is now more urgent than ever that your government sets out a clear strategy to tackle the ever-growing problem of agricultural pollution and the impacts it is having on fish stocks, and the wider environment.  Finally, we would like to see a comprehensive programme introduced to manage predation from cormorants and goosanders to reduce the impact that they have on salmon and trout stocks, and coarse fisheries, throughout Wales.

I would like to meet with you and your officials to take this agenda forward.  In England, we meet regularly with the Water and Fisheries Ministers and the Secretary of State for Environment, Food and Rural Affairs and I see no reason why you should not meet with the representative body for one of your largest stakeholder groups in the context I have set out above.

Yours sincerely,

 

 

 

Mark Lloyd

Chief Executive, Angling Trust & Fish Legal

Happy New Year from the Campaign Team

We wish you all a very happy new year, good health and many tight lines.

From the recent activity on this site, you could be forgiven for thinking that wed have ceased activities: not so.

We are actively contacting NRW management, M.P.’s and A.M’s with regard to the proposed changes in salmon and sea trout bye laws. We continue to challenge the validity of the decision to close all Welsh hatcheries. We work closely with the CLA and Angling Trust to fight for anglers rights, to protect our waters from unfettered access by canoeists and champion the cause of voluntary agreements with paddlers. Many of these communications are and will remain sensitive, but as soon as we can we will publish them on this site.

I see that there are petitions about seeking support for various angling/bye law changes. We are greatly concerned that a little over 1,000 signatures have been added to the latest and best supported. There petty numbers create the impression that we anglers are bot concerned or are compliant with teh current NEW onslaught on our support. Please sign teh petition but for goodness sake please do not start another.

Watch this space.

NRW Fisheries Newsletters January 2018

Please click on the link below to view the newsletters

 

Jan 2018 Builtin Cymraeg

Jan 2018 Builtin English

Fish stocks 'not being protected' by Natural Resources Wales

Click this link to see the BBC item on this subject. For the record, NRW enforcement staff are generally hard working and dedicated, there are just far too few and the few working really hard feel they are overworked, under resourced and desperate to be able to do the job properly.  CLICK HERE    Thanks to Wynne Griffiths for the link.

NRW Salmon And Sea Trout Catch Controls 2017 CONSULTATION

This is the link to the consultation documents and response form NRW advise us that you may respond by letter/email but they would prefer you to use the form. We urge you to follow this link and respond: Thank you.

CLICKHERE   When you get to the page, scroll down to the bottom where there is a list of documents, the response form is the second one down on the left: the only word document on the selection.

Sorry we are so late posting this link, I though I did it some time ago.

Otters and predation on fisheries

I thought you may like to look at the two links below, both of which relate to otter predation on fisheries

href=”https://www.predation.co.uk/mission-statement“>Click here

href=”href=”https://www.predation.co.uk/predator-press”>Click here”>Click here

Trout and Salmon Magazine against compulsory C&R

Andrew Flitcorft, the editor of Trout and Salmon Magazine has kindly allowed us to publish his Editors Letter as included in the September issue. Thank you Andrew and Trout and Salmon Magazine

His view:

“Anglers are once again being used as political pawns by authorities
who haven’t got the balls to deal with the big issues”

To read the full letter click on this link    Editors letter

Wales, the first country in the world to leave a species to become extinct? In this case salmonids.

NRW have replied to the FOI request by saying they did not make any such comment. 4/10/17

This a a quote taken directly from a letter produced by Angling Trust and Afonydd Cymru and sent to Lesley Griffiths A.M. Cabinet Secretary. We are awaiting a response to a freedom of information request for a copy of the document proffering this advice to the Welsh Government. We will keep you posted.

“Our recent meeting with your officials revealed nothing of substance nor any future plans or direction, save to learn that NRW had advised that climate change would bring a premature end to our migratory fisheries, thus making them not worthy of further attention”

Salmon trapped in hydro turbine

Chris, thought you would be interested to see this video on you tube. NRW have been advised that this happens and have been asked to reconsider their fish pass designs on hydro schemes. We await a response.

Click here to see video

Welsh Government Consultation: canoeists again!

The Welsh Government is consulting on

Taking forward Wales’ sustainable management of natural resources

This consultation includes

Page 38. Proposal 11

To amend or revoke the following list of restrictions on access, provided in Schedule 2(1) of the CRoW Act 2000:

(b) uses a vessel or sailboard on any non-tidal water;

(c) has with him any animal other than a dog;

(i) bathes in any non-tidal water; and

(s) engages in any organised games, or in camping , hang-gliding or para-gliding.

ONCE AGAIN THERE IS YET ANOTHER ATTEMPT TO FACILITATE THE FREE ACCESS OF CANOEISTS TO OUR RIVERS. It is important that as many of you as possible respond to this consultation, even if only to this issue. No need to fill in the whole document, just the question relation to free access to waterways, which includes rivers.

Link to consultation page at Welsh Government website click here

Here you can download the documentation     Consultation document   from this site.

If you wiah to read the document and respond on line, then this is the link click here

 

 

 

Mark Isherwood A.M. speaks out for anglers: again

 

Wednesday June 7th 2017

 

PROTECT OUR FISHERIES

 

Following the publication of a report highlighting a “serious decline in fishing in Wales”, North Wales Assembly Member Mark Isherwood has called for a Welsh Government Statement on the protection of fisheries in Wales.

 

Speaking in this week’s Business Statement, Mr Isherwood said issues regarding the failure to protect fisheries in Wales, in consequence of Welsh Government policy, were covered in the national angling paper ‘The Angler’s Mail’.

 

He said:  

 

“This highlighted a serious decline in fishing in Wales. It said that the Welsh equivalent of the Environment Agency, Natural Resources Wales, had been branded no longer fit for purpose by fishing and environmental groups, and that of the 6,886 reports of water pollution that Natural Resources Wales received between 2013 and 2016, only 60 per cent were investigated, and there were just 41 prosecutions and 10 civil sanctions, amounting to less than 1 per cent of incidents reported.

 

“It said ‘There has been a steep decline in fish numbers in recent years in Wales.The regulator needs to take a much tougher stance but…The organisation is unwieldy, too bureaucratic and they don’t seem to have a strategy’.

 

“They did say that they were meeting with officials in the Welsh Assembly, by which I presume they mean the Welsh Government, to demand action, concluding that there’s been a national failure of Welsh Government to tackle the problem. Given particularly their reference to Welsh Government in the article, and their reference to a meeting with officials, could we have a statement to bring us up to date not only on what was concluded, but what actions, if any, have resulted?”

 

The Leader of the House, Jane Hutt, told Mr Isherwood “it would be helpful if you wrote to the Cabinet Secretary on this matter as her officials are already engaged in that discussion,”

GRATEFUL THANKS TO "ANGLERS MAIL" May 9th Edition

It is with great reluctance that I add this item from the Anglers Mail. The fisheries team at EAW work hard and are enthusiastic and  dedicated to their work: there are just too few of them. Our environment is far too important to be neglected!

Please click on the link below to see the Anglers Mail article.

Anglers Mail May 9th 2017

Are NRW to reconsider hatchery closure?

The .pdf document below is a copy of a letter written by Mr John Roe, Chairman of the Dee Fisheries Association, to Mr Tim Jones, Executive Director of Operations North and Mid Wales. The letter includes an attachment, written by Mr Chris White, setting out the arguments against the closure and the basis of his conclusions.

Well worth a read, just click on the link below.

Letter to Tim Jones