Re: Damage to migratory fish stocks by Fish-eating Birds

President Allan Cuthbert, 7 Norton Avenue, Prestatyn, Denbighshire, LL19 7NL Email:

Strategy Officer John Eardley c/o Vanner Farm & Caravan Site. Llanelltyd, Dolgellau, Gwynedd, LL40 2HE Email:

Conservation Officer; Chris White, 57 Normanby Drive, Connahs Quay’ Flintshire, CH5 4JX

Sir David Henshaw NRW Chairman

Via email:

18 May 2020

Dear Sir David,

I recently received an email from Ruth Jenkins accusing me of publicly criticising an NRW Board member. There were no details in the email as to when and where this had supposedly taken place. I attend the Welsh Fisheries Forum on behalf of CPWF and as such I represent anglers from across Wales, many of whom have expressed concerns about the actions (or rather in-action) of NRW and perceived conflict of interests of NRW Board members due to their membership of the RSPB when considering controls on avian predation of salmonids. In my response to Ruth I explained that I cannot be held responsible for any comments made at meetings by CPWF supporters when I was not present.

I am not aware of any public criticism either verbally or in writing that I have made.

In her email Ruth accused me of publicly criticising an NRW Board member and asked me to withdraw this or if I wished to raise this issue with you as Chair of the NRW Board. As I have yet to receive a response from Ruth to my reply perhaps it is now time to take this to the next level. My preference is to have an open and honest discussion about the issues around avian predation rather than to go public through a press release. The issue of avian predation has been talked about for more than 10 years but all we get from NRW and its predecessor is procrastination on this issue for fear of upsetting the RSPB and latterly Wild Justice.

One thing that seems to unite anglers is concern over the impact of increasing numbers of Goosanders and Cormorants on our rivers. At the last Welsh Fisheries Forum a paper was presented from the Fish Eating Birds Advisory Group (FEB’s) on behalf of Natural Resources Wales in which graphs taken from the Wetland Bird Survey (WeBS) conducted by the British Trust for Ornithology (BTO) “suggests” breeding pairs of goosander and cormorant are in

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decline whilst accepting that over wintering birds had steadily increased from the 1980’s. The implication from these graphs is that these FEB’s are not the cause of the decline in ‘fish stocks’ and particularly salmonids. To a lay person who supports the RSPB this is what they want to hear. The presentation was interesting in that there was more concern about a legal challenge from ‘Wild Justice’ than in the protection of fish stocks. Apparently there needs to be a detailed study (12 Months) almost certainly followed by a public consultation before any controls can be recommended let alone be put in place.

NRW are fond of claiming that they are ‘evidence lead’ so let us look at the evidence. In the first instance we need to look at the graphs taken from the Webs survey:

Note: We understand the 100 Index line in the graphs to be the average or mean of the years I995 – 2015. It would be more meaningful to the reader if the graph illustrated the actual population in order to present actual year population plots and trend.

You will see that the trend line in red for both species is showing a decline this gives the wrong message as it is referring to breeding pairs and not numbers of feeding birds over the winter period. The presentation made no reference to the fact that overwintering birds are on the increase. In the following I only consider the damage to fisheries from goosander over the winter period but the same applies to cormorants who are consuming the same or more salmonids.

The following graph is taken from the latest Wetland Bird Survey (WeBS) survey which uses data from the British Trust for Ornithology (BTO) Waterbirds in the UK 2018/19. Note the trend (blue line) in this graph is upwards this includes overwintering birds and is not restricted to breeding pairs. This graph may mirror the decline in migratory fish stocks from electro fishing surveys; the decline is at the moment attributed to climate change and pollution.

Note on graph scale:

This 1970 – 2015/16 Wales graph of goosander illustrates the rising longer trend of recorded goosander, from no population in pre 1970 to its present 2015/16 population expressed as the 100 Index.

“Contains Wetland Bird Survey (WeBS) data from Waterbirds in the UK 2018/19 © copyright and database right 2020.

So let us now consider the case against goosanders. According to the BTO an adult goosander needs to consume 400gm of fish per day and to raise a single chick from egg to adulthood requires 33kg of fish (goosanders typically have 10 chicks to feed) – these birds primarily eat fish to live. The graphs above do not declare numbers, they refer to an index. However it is clear in the graph for Wales that annual goosander numbers are increasing. According to the BTO the Status Summary for goosanders is as follows:

Status summary

Goosanders were first discovered to have colonised the UK in Perthshire in 1871, and spread from Scotland into northern England in the 1940s. Between the first two breeding atlases, the species expanded its range in northern England, and colonised Wales and southwest England. WBS samples became large enough for annual monitoring in 1980, and showed sustained population increase, apart from a slight dip in the late 1990s. The BTO’s two national surveys of sawbills demonstrated an average increase in population size of 3% per annum between 1987 and 1997. There has been considerable further range expansion since 1990. Reasons for the colonisation of the UK, and the subsequent range expansion and population increase, are unknown. The species’ winter trend in Britain, comprising British breeders and continental visitors, rose steeply from the late 1960s and peaked in the mid 1990s, before falling back, and now stands at early 1990s levels).

In order to determine the biomass consumed by goosanders and to keep the arithmetic simple consider 100 goosanders feeding over the winter period from November to March approximately 126 days. Assuming each goosander consumes on average 400gm of fish per day then over 126 days 100 goosanders can consume approximately 5 Tonne of fish during this period. Admittedly these birds may not feed every day but they tend to gorge feed so allowing for none feeding periods let us say these birds consume 3 Tonne of fish. On rivers which do not have coarse fish present they will only be eating salmonids (and maybe minnows, sticklebacks, loach and bullhead if present).

A typical smolt ready for migration is approx 100gm but during the winter period most fish eaten will be parr or fry with a likely average weight of 30gm which would indicate that the number of fish eaten is circa 100,000 over this period. We will refer to these as smolt equivalents. Over

the winter period goosanders can be found feeding on upland spawning streams i.e. feeding on smolt equivalents and once the food source is depleted in one stream they simply fly to the next. No doubt it will be claimed there is no evidence to demonstrate harm from goosanders to ‘fish stocks’. I use the term fish stocks as goosanders will also feed on rivers containing coarse fish (and on marine fish in estuaries) and by including these in the biomass consumed it is easy to show there is little damage to overall fish stocks. This is not the case on rivers which do not contain coarse fish.

The focus of NRW and other agencies in the UK has been on avian predation during smolt migration on the basis that a smolt lost on its migration to the sea cannot be replaced whereas a parr lost in a spawning stream can be replaced! The migrating smolt studies tend to indicate significant smolt losses on upper reaches of rivers but whether this is due to avian or other predation is not clear. The theory that we only need to consider losses to migrating smolts is that it is larger parr which smolt (they need to attain approx 100gm in weight) and these larger parr take up the best feeding stations. If these larger parr are eaten then their place will be taken by a smaller parr who will grow large enough to smolt once they have taken up the recently vacated feeding station and so there is no problem. I am not sure if this is a logical statement but it seems to be the one that ‘scientific opinion supports’ and therefore only investigation into predation during smolt migration is considered vital. However studying migrating smolts, important as this is, is an after the event study as recruitment of juveniles has already been decimated over the winter months.

The problem we face is the conflict between two protected species, on the one hand goosanders which are not endangered, not native (but who have naturalised in the UK) and which have no known predators in the UK and salmon and sea trout which are regarded as being ‘at risk’. In fear of reactions from the RSPB and Wild Justice birds are therefore treated as sacrosanct by UK agencies. Unless and until the biomass consumed by FEB’s is recognised as damaging there is little prospect of a recovery in our stocks of salmon and sea trout. Many angling clubs have counts of FEB’s on their rivers and from this it is possible to estimate the biomass loss to these birds but it seems we are not to be trusted to provide unbiased data for fear of a legal challenge from those who have no concern for our fisheries or the damage FEB’s are inflicting on migratory fish stocks. Both I and supporters of CPWF believe that the criticism of NRW is entirely justified and I would welcome the opportunity to discuss both this and other fisheries concerns with you in a face to face meeting.


Chris White

Conservation Officer: Campaign for the Protection of Welsh Fisheries (CPWF)

"Angling light up my life." No idea who singer is but the song is brilliant and says it all: thank you.

Thanks to John Eardley!

quote in “Fishing Wit” by Richard Benson:
“Never doubt the environmental knowledge of a consistently successful fisherman. Always doubt the motives of a consistently argumentative environmental bureaucrat”

To NRW re FEB's


Further to yesterdays LFAG meeting debate on FEB’s (note my title – other than Pike I don’t know of any fish eating birds!).  As you will have noted there is overwhelming frustration due to the procrastination on this subject.  NRW were quick enough to impose restrictions on anglers in order to conserve fish stocks and yet shy away from one of the root causes for the decline. 

In the presentation by Pat Lindley at the fisheries forum he raised the conservation conflict between salmonids and FEB’s.  The difference is salmonids are all declared as ‘at risk’ whereas FEB’s are increasing, I refer here to the attached the BTO Wetland Bird Survey 2018 -19 and would direct you to page 12 which shows the trend for all wetland birds – goosanders don’t seem to be in decline.  Neither are cormorants in decline which have their own section on page 28.  The problem with the BTO survey it does not declare numbers instead it refers to trends and indexes I have attached my notes from the Fisheries Forum sent to CPWF supporters re FEB’s which shows the upward trend of goosander in Wales.  The graphs are scaled as an index without a reference datum to numbers.  Without knowing the numbers it is difficult to determine the damage to a fisheries biomass assuming each bird consumes at least 400gm of fish per day.  Is there anyway you can put numbers to the graphs shown in my meeting notes as these graphs are Wales specific, having said this I suspect that counts are for wetland i.e. coastal observations and maybe some main river stems in Wales. 

I can’t remember if it was Chris Porteous or Ian Macdonald who raised the issue of angler participation in bird counts the response did nothing to build confidence in NRW going forward with respect to avian predation. 

During my time as Secretary of Conwy Valley Fisheries & Conservation Association in 2012 I organised an FEB survey using BTO methodology, we sectioned the Conwy system from Llanrwst up to Betws but stopped at Tyn-y-Cae i.e. excluded the Lledr and upper Conwy system although we did include the Llugwy as far as Miners Bridge.  I was unable to take part in the survey due to work commitments and this was carried out by volunteers under the guidance of the late Bob Wilson who was at that time living in Betws as fisheries manager for the Gwydyr Fishery.  From the counts that Bob gave me, based upon a goosander eating 400gm of fish per day and a cormorant 500gm per day I estimated we lost upwards of 20,000 smolt equivalents per year. 

Unfortunately Bob kept the count records and since his death these are no longer available.  However this demonstrates our ability to conduct FEB surveys and provide results.  Once CVF&CA could no longer operate our stocking programme it was dissolved and surplus funds transferred to the Clwyd, Conwy & Gwynedd Rivers Trust (now NWRT) ring fenced for use on Conwy restoration projects. 

I have attached a copy of the FEB survey conducted on the River Eden (this mirrors what we did on the Conwy) which clearly demonstrates the ability of anglers and riparian owners to gather information on FEB’s.  There may have been some double counting in this survey due to birds in flight but the numbers counted are enough to demonstrate damage that can be done due to FEB’s.  Between November 2019 and March 2020 the average count is 463 for goosander and 231 for cormorants allowing for 50% error there could have been 400 FEB’s feeding on the Eden over this period.  Assuming each bird consumes 400gm of fish per day then 160Kg of fish per day could be eaten; over the 18 week period (November to March) this equates to 20 Tonne.  Whilst the numbers may be inaccurate the point is well made in terms of the effect that these birds can have on fish stocks.  For the Eden the diet will not be exclusively salmonids – this is not the case for North Wales rivers (other than the Dee) which only have salmonids (excluding minnows and loach).

For NRW to say that you need to study FEB’s to provide evidence of harm beggars belief, these birds eat fish or as one of our supporters put it ‘they don’t eat salads’.  There seems to be more concern about a legal challenge than in doing something to reduce the level of salmonid predation, action is needed now.

There is perhaps a simple and cost effective way of gathering data on FEB numbers across Wales and that is by engaging with riparian owners and anglers in order to assess numbers as has been done on the Eden.  It may be possible for some of this to be carried out using drones to overfly rivers and film birds for counting later particularly in upland spawning areas where access is limited.  Perhaps it would also be prudent to install camera traps (which are relatively inexpensive) at electro fishing sites any sightings of FEB’s at these sites could  perhaps explain the variability of counts, this could go some way to verify the accuracy of the data used to estimate the conservation limits.

We are not the enemy but we are treated with contempt when we suggest anything which goes against the NRW policy of treating bird populations as sacrosanct not to be touch for fear of the RSPB or Wild Justice raising a legal challenge.  If our salmonid fish stocks are to be restored then action needs to be taken now – not in two years time.  It is time for NRW to fully engage with its stakeholders and commit to carrying out some positive action, we are willing to help but NRW needs to take the lead sooner rather than later.

Chris White

FEB's: Chris White is "on it": Thanks Chris

I raised the FEB issue at the Skype joint LFAG meeting yesterday pointing out the frustration about the delay in addressing FEB predation.  Dave Mee took part in this meeting and he explained the NRW/WG position which is basically they are scared of a legal challenge from ‘Wild Justice’ (Packham et al) so they need to have clear evidence of harm before they introduce any controls – hence the delay until 2022 at the earliest.  In response to a question about who and how the FEB study will be carried out and why anglers cannot carry this out DM said that if the estimated cost of the study is over £5K this would have to be tendered (they will fudge this to keep below the need to tender i.e. split into phases and areas) and there would need to be creditable evidence that those who tender are qualified for the work (the impression was that anglers are not qualified).  I suspect that this work will be carried out by a university (Cardiff/Swansea/Bangor maybe through contracts placed by rivers trusts).  I questioned why the Scottish study was not being considered and from what DM said apparently the Scottish study did not conclude that FEB’s had any impact on fish stocks – note the term ‘fish stocks’ I have seen this used to justify paddling over spawning grounds in the past (Brighton and EA reports on the effect of canoeing on ‘fish stocks’) as the term ‘fish stocks’ covers all species and not just salmonids.  Many of the larger Scottish rivers have large coarse fish stocks (roach/grayling) so you need to know which rivers were used in the studies.  I pointed out that much of the damage by FEB’s is on upland spawning streams and that the investigations to date seems to have been focused on main river counts (DM mentioned the Usk and Wye, both have coarse fish stocks).  The majority of our North Wales rivers do not have coarse fish (other than minnows and loach) so FEB predation has a disproportionate effect on salmonids, there is not a one size fits all solution and studies need to be on a river by river basis (we have said this before re byelaws and have been ignored).  Any study must include upland spawning streams over at least a 3 month period i.e. through the winter when flocks of FEB’s search out an easy feed.  I pointed out that these birds are mobile and may visit more than one site in a day and if disturbed they simply move to another site, most of which are remote and not easily accessible (remote wildlife cameras are better than people in these remote locations).   

The BTO survey is focused on ‘Wetland’ i.e. coastal areas and does not reflect what is happening on inland waterways, they may include some of the major river stems but they do not extend to counts on upland spawning streams I would suggest that this is where the study should be focused.  I will write to NRW and see if I can get some accurate numbers for overwintering goosanders as it is these birds which, in my opinion are causing most damage.  The BTO on its website states that adult goosanders will eat 400gm of fish per day so a flock of just 10 FEBs descending on a river or spawning stream can eat 4Kg of fish in a day – that’s a lot of parr!  The problem is it has been suggested that any parr that are left will take the place of those eaten and it is only predation of smolts which is an issue!  I will bang the drum but doubt that NRW will take any notice!

Chris White

Mervyn Williams to David Jones MP

Tan y Graig



Denbighshire CH7 5TG

20th April 2020

Rt.Hon David Jones MP

Dear Mr. Jones

You will see from my address at the head of this letter that I write to you as a one of your constituents. As such I’m copying Darren Millar as my AM

As a conservationist concerned with pollution of water courses from agricultural practices I have concerns that you appear to consider that legislation to reduce this pollution is not required.  I Chair the Dee and Clwyd Local Fisheries Advisory Group and I am a Trustee to the Welsh Dee Trust. Both organisations have been lobbying for protection from diffuse pollution from agriculture, which is causing so much damage to our water courses’ for many years.

I refer to the letter (dated 16th April) sent by the Conservative Group of Welsh MPs to Lesley Griffiths (Welsh Minister for the Environment, Energy and Rural Affairs). Having read the above letter, I make the following observations.

There are issues with the Welsh Intense Farming industry, most notably in this case, that of agricultural pollution. Pollution incidents of water courses are well documented over the recent years in the media. The Intensive Farming Industry has developed to an extent that it must regard its bye products of slurry, chicken and pig manure as industrial waste. It is the dealing with this growing amount of industrial waste that has led to the aquatic environment often failing to meet the Water Framework Directive (WFD) standards to the detriment of water quality, with consequent negative effect on aquatic life. 

The damage from diffuse pollution is not something that has just happened – it has increased over the past 20 years due to changes in agriculture practices with no significant action being taken either by the Welsh Government or by the Farming Industry as a whole. Both need to take a long hard look at their lack of action. It is disappointing that your letter fails to acknowledge the problem.

Throughout the expansion of factory farming, water quality in Welsh rivers has declined dramatically. This has had a significant effect on the recruitment of migratory fish (salmon and sea trout) in Wales, which have declined markedly.  While there are various reasons for the decline in migratory fish stocks – agricultural pollution must take a major proportion of the blame for this.

The issue of agricultural pollution has been raised in the majority of fishery related meetings I have attended over the past three years.  At the 2019 Inquiry re the New Fishery Bye Laws much play was made by NRW that the updated Bye Laws were part of a raft of regulations to improve migratory fish stocks.  Agricultural pollution controls were part of these regulations. Following the Inquiry Lesley Griffiths has instructed NRW to produce a Plan of Action for Salmon and Sea Trout.  In order to identify major issues affecting migratory fish stocks NRW organised meetings across Wales with local fishery groups (LFG’s). At all of these meetings the minutes record the issue of problems due to agricultural pollution reducing recruitment of juveniles.

Despite the impression you give in your letter, these regulations have been long expected and consequently anticipated by the Farming Industry. The Welsh Government had set up a Land Management Forum. Meetings with farmers and their organisations have been held across Wales. The impression in your letter is that farmers have been unaware of the proposed legislation and have had no input, this is not the case.

There are very valid reasons why there are dates and conditions for which there should be no spreading of slurry. This should have little or no impact on small farms who bed their animals on straw.  It is the holding of live stock on concrete surfaces and the washing down of these surfaces which cause the storage and pollution issues. There are valid concerns about the overuse of nitrates etc. The Vale of Clwyd has been declared a Nitrate Vulnerable Zone for more than 20 years.  Similarly there should be no issue over ensuring that storage for slurry is adequate to meet unforeseen circumstances as not all weather conditions are suitable to ensure that spreading does not impact on the aquatic environment.

I refer to the third paragraph in your letter where you seem to confuse environmental protection with environmental standards. Whilst farm equipment, barns and environs might be kept clean and to a high environmental standard, the storage of waste and its disposal is the issue.

I am sure that not all farms in Wales are polluters and that there are examples of good practice. Your biggest and major criticism seems to be over making the whole of Wales a Nitrate Vulnerable Zone.  This might be a valid argument to take up with the Welsh Minister but is lost by not acknowledging that Welsh farming (as an industry) has huge pollution problems. It’s also not helped by making the industry a special case in these trying times.  We are all suffering due to the current crisis and as for adding lambing as a valid argument against the legislation this beggars belief and shows just how little you understand of the problem.

Please feel free to share this letter with your fellow Welsh Conservative MPs

Your sincerely

Mervyn Williams

Notes from the Fisheries Forum meeting on 9 April


I hope you are all safe and well and not to depressed due to the lack of fishing opportunities. 

The fourth Fisheries Forum meeting was held via a Skype conference call on Thursday 9 April this is not a very friendly way to hold a meeting.  There were 22 people signed into the conference call but those who signed in as guests on audio only to a business conference were anonymous so apart from key players I don’t know who else was listening. 

I have attached my meeting notes it has taken me a few days to calm down before I finalised my notes.  The problem is there is an inner clique which have their own agendas and don’t like outsiders who challenge them.  I took exception in the way my very real concerns were dismissed as irrelevant and I have been reflecting on my future involvement in the Forum.  You will see that LFG’s will be asked to nominate representatives for future forum meetings, if you read between the lines of my notes you will see there may be some manipulation to get like minded people to join the present clique.  I have attached the draft agricultural legislation re water quality and the explanatory note which accompany them, it is worth noting that these are still in draft form and may be amended.

Feel free to circulate to your members.

Stay safe.

Chris White

Richard Evansdeiwood

Sorry to be the bearer of bad news, but have just been informed by Emyr Lewis that Peter has just been told by N.R.W. that netting at Glandyfi on the river Dyfi will commence on the 1st of May. Netting by two nets a Mr Lewis and Gareth Jones.
Peter has been told not to police the netting and to only make an appearance if reports come in that they are infringing the rules, ie. holding the net across the river.
Their reason being that the nets are providing food for the nation.
It makes me feel quite sick that we are dealing with people like the N.R.W.

Another Mike Ashwin challenge to NRW and EA

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum

6th March 2020

Heidi Stone, EA Salmon Programme Manager Peter Gough, NRW Principal Fisheries Adviser Cc

Sharon Kennedy, Environment Manager Cumbria

David Hudson, EA Environment Manager, Gloucestershire & Warwickshire Dr Alan Walker, Cefas Senior Scientific Offiicer

Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPW

Dear Heidi & Peter,

Summary of current status of NWATFCC, PAAS & CPWF actions/requests to EA & NRW awaiting resolution concerning river & national stock assessments

Highlighted are the responses sought and actions acknowledged on individual matters.

  1. Solway & NW River Byelaws & assessments – NWATFCC referral and request to EA following meeting with Defra Minister (4th February 2019) for incorrect rod exploitation rates used in 2018 and historic assessments to be reviewed, revised and individual River annual compliance to Conservation Limit recalculated. Necessity for an early review of the 2018 Solway byelaws. Following the EA Complaints process and EA Independent Internal Report (received by NWATFCC on 10th January 2020) the EA handling and decision process was upheld by the independent EA Deputy Director.

NWATFCC & individual Clubs on four NW Rivers have referred this for further Legal advice and action.

  • River Severn 2019 Emergency Byelaws – NWATFCC acting for Prince Albert Angling Society produced a detailed report on the 2019 Emergency byelaw Decision Paper, highlighting incorrect 2015 -18 under reported rod estimates used, resulting in underestimation of stock in decision justification. Recommendations made for recalculation of the individual year assessments, trend status and a full 2020 consultation with revised conservation case and applied measures. PAAS letter & NWATFCC Report forwarded to EA on 5th December 2020. Several communications received concerning the intended EA response to this and expected timescales, but as yet no final response. Some urgency as 2020 Consultation timescales may not be met ?
  • Cross Border Welsh Dee & Wye Byelaws.- NWATFCC, PAAS & CPWF request and recommendation in letters 28th January & 8th February2020 to the Welsh Cabinet minister Lesley Griffiths, that the Byelaws are not approved and deferred subject to the outcome and findings of the National review on rod exploitation rates & wider NASCO 2019 -24 IP three year review on Improvements to national stock reporting & assessments. The reviews to be undertaken by EA, NRW & Cefas. The Minister declined this request and approved the byelaws the following day, 29thJanuary 2020. This decision process referred by rod fisheries for legal advice.
  • River salmon stock estimates Re Cross Border & National Byelaw measures implementation – Review of Welsh Dee Index River methodology estimates – Request by NWATFCC, PAAS & CPWF as part of analysis undertaken by Prof Brian Revell & M. Ashwin, for rod fisheries engagement concerning the current Welsh Dee – Angler log book scheme methodology providing estimates of whole run Dee spawning estimates and rod exploitation rate estimates for other referenced Welsh rivers. NWATFCC letters to NRW, 8th December 2019 & 23rd January 2020. NRW response and letter 6th January received from Peter Gough, NRW. Confirmation from Peter Gough, NRW that a further and final response to NWATFCC letter of the 23rd January is being prepared.
  • National Review – rod exploitation rates – extensive dialogue by NWATFCC with EA and in recommendations from NWATFCC & CPWF through the Angling Trust in 2018 to Defra & Welsh Cabinet ministers for this Review. Formal notification from NWATFCC (13th July 2019 to EA) and CPWF (8th Dec 2019 to NRW) that rod fisheries organisations cannot agree or accept the provisional 2018 published River assessments and await confirmation of the 2019 rod exploitation review findings and necessary corrections being applied.

After initial confirmation and clarification by the EA to M. Ashwin that rod fisheries would be included in this Review process there has been no further invitation or announcement on the Review. NWATFCC , CPWF & Salmon Advisory Group have made a number of requests concerning this, the most recent to Heidi Stone EA & Peter Gough NRW on the 9th February 2020. We await this response.

  • National Review – NASCO 2019 – 24 IP submissions to drafting of Improvements to stock reporting, assessments and final review process. NWATFCC, CPWF submitted detailed NASCO IP draft recommendations to rod fisheries Representatives to the England Fisheries Group on 23rd December 2018, and subsequently provided further papers supporting this including reporting accuracy of historic trend forecasting and comparative analysis of alternate and current models and methodology.

The vision of a harmonised UK mainland conservation strategy and shared cross border reporting process is an integral step in this process. Additional academic analysis of factors affecting Salmon run estimates and NWATFCC recommendations to develop a fisheries reporting website accessible platform are key elements to these recommendations. .

Again, we have not been informed of the proposed timetable and NWATFCC & CPWF await a response from the EA & NRW, as part of the joint letter of the 9th February 2020.

A response to items 2, 4, 5 & 6 are requested by rod fisheries representatives, bearing in mind intended timetables for developing and presenting these.

With kind regards, Mike Ashwin

Chairman of NWATFCC,

The Barn, Skirwith, Penrith, Cumbria CA10 1RH

Wye Salmon Association to NRW

Penyhil Felindre Brecon Powys


25 February 2020


Julian Bray, Head of Inland Fisheries, WAG

Dear Sir,

Wye Salmon Association wish again to register with the Welsh Assembly Government their concern over the significant lack of NRW Fisheries resources.

We have on a number of occasions recently, written to the WAG Environment Minister and NRW CEO & Chair highlighting the plight of Atlantic Salmon in the River Wye. Registering our belief a state of emergency exists with respect to Salmon stocks in the Wye.

We have expressed major misgivings over the current salmon action plans under consideration by WAG/NRW, believing they offer little more than a continuation of existing actions. Actions that have delivered very little in the way of salmon stock recovery over the last 20+ years. Lacking in inspiration, we consider their content short of the mark and a lost opportunity.

As a result, today, we are faced with the potential extinction of Wye salmon, on your watch.

We are certain a lack of resource and funding within NRW is constraining their ability and willingness to fulfil their statutory fisheries duties and develop robust salmon stock recovery plans . Too much reliance on self-regulation, as NRW do not have sufficient resource to enforce in such areas as agricultural and sewage pollution and we suspect even the revised angling byelaws.

In our communication we requested the Minister sought from the NRW an answer to the questions ‘will this plan deliver the required stock Conservation Targets [CL], as are implicit in NASCO Guidelines for Management of Salmon Fisheries, CNL(09)43, and by when. If less than an unequivocal YES, what is required that might?

Whilst receiving a cursory response from The Minister, it did not address the obvious seriousness of this question. We received no response from the CEO and or Chair of NRW to whom this correspondence was also addressed.

The outsourcing of river restoration work, by NRW, a policy supported by WAG it would appear, to Rivers Trusts, in order to compensate for the lack of in-house resource and funding has resulted in the skewing of actions towards task based actions, rather than the ‘bold and

Wye Salmon Association Cymdeithas Eog Gwy. Penyhil, Felindre, Brecon, Powys LD3 0SU

Tel: 07789133263. Email: Website

urgent’, target based initiatives needed. Prevarication and dogma, we suspect, disguised as research, reviewing, consulting etc, wasteful of resource and lacking innovative thinking. Words to raise funding rather than actions to deliver real world solutions.

Evidence; in the 23 years since 1996 of ‘Salmon Action Plans’, the 5 year annual average rod catch has declined from 1852 in the period to 1996 to currently 941 and in the last 15 years the Conservation Target [CL] for egg deposition has only been achieved once! This despite the millions spent on habitat improvement on the Wye.

River trusts, whilst charities and non-profit making, operate by necessity as businesses with an overriding need to fund their payroll and overhead costs as a first consideration. They follow the money sources, and whilst there is much to be commended in many actions and initiatives, often, as a result they lose focus on the end result. The focus that a properly resourced NRW supported by its stakeholder driven Local Fishery Groups [LFGs] could provide.

Engagement of the whole angling community on the river Wye has been compromised by a ‘lack of trust’ in NRW and the organisations charged with recovery, with accusations of not ‘communicating or listening’ and ‘not acting on critical matters’.

The now very visible lack of NRW resources, combined with the failure to achieve a sustained turn round in the fortunes of Wye salmon stocks, and a new salmon action plan considered to be not fit for purpose, will further weaken engagement by stakeholders in river programmes and massively reduce the opportunity to increase support and funding for future river improvements.

A missed opportunity perhaps as WSA believes there is significant funding available from the angling community for a plan aligned with actions they believe likely to deliver recovery of Wye salmon fisheries.

Yours sincerely

Stuart Smith Chairman

Wye Salmon Association

John Eardley to minister re: River Dyfi - Welsh Beaver Project

26th February 2020

Lesley Griffiths AM

Minister for Environment, Energy and Rural Affairs Welsh Government

5th Floor Tŷ Hywel Cardiff Bay CF99 1NA

By email to (for the personal attention of the Minister for Environment, Energy and Rural Affairs)

Re: Restoring Nature on the River Dyfi – Welsh Beaver Project

Dear Minister,

A series of meetings organised by the Wildlife Trusts Wales are currently being held in the Dyfi Valley with the stated purpose of undertaking a “five-year managed reintroduction of beavers to the River Dyfi and investigating how well beavers fit back into the Welsh countryside”. The reality is that there is absolutely no need for a “managed reintroduction” as there are already 2 adult beavers and 3 kits present on the tidal Dyfi downstream of Machynlleth. Furthermore the damage that they have already inflicted on the banks of the river and riparian vegetation by felling trees and burrowing into banks as shown in the photographs on Page 3, makes it abundantly clear that they do not “fit back into the Welsh countryside”.

Angling stakeholders who have attended the recent community drop in events have expressed concern that the project is being presented as a fait accompli and as a result we must voice our objections in the strongest possible terms. At a time when angling organisations are struggling to come to terms with the damage caused by the introduction of the All Wales Byelaws it is wholly unacceptable to introduce a further unpredictable variable into the equation. By their own admission Natural Resources Wales do not have the funding or manpower to manage their current commitments and are certainly not in a position to properly manage the introduction of a new species into the ecosystem.

According to the project website (, the last natural historic record of living beavers in England and Wales dates back to 1188, a time when the natural environment was a world apart from the Dyfi valley in the 21st century. Along with our most obvious concern that beaver dams pose a major threat to both upstream and downstream migration of salmonids, even a cursory glance at the project website reveals further compulsive evidence of why this proposal should progress no further. Statements such as “the coppicing of trees and other vegetation reduces canopy cover” and “flooding from dams can cause tree deaths” are completely at odds with recent tree planting campaigns in Wales which seek to keep river water cool in salmonid spawning areas. In 2018 drought conditions led to fish mortality in a number of areas within the catchment, a situation that would have been significantly exacerbated had beavers been introduced in the past. Furthermore debris from beaver dams washed away during severe flooding has the potential to cause temporary dams to form against bridges which then burst and significantly increase the flood risk in areas downstream.

We are informed that “beaver prefer living in burrows in banks along slower flowing, unpolluted rivers with good aquatic vegetation” and yet the Dyfi and its tributaries are fast flowing rivers with little weed growth, and in many areas are contained within a rocky channel, in simple terms an unsuitable and hostile environment for beavers. We are also told that “studies show that following release they disperse widely throughout a watershed” and that “breaching of dams” is possible where problems arise whilst “wire fences can also be set across the water course on smaller rivers and streams to prevent beaver passage and limit extension of territory”. Where problems persist “removal by live trapping outside the breeding season is the most effective solution”. Whoever wrote these statements clearly has little knowledge of tributaries such as the North and South Dulas, Twymyn and Cleifion where the nature of the terrain would make such activities completely impossible.

There are far too many negative factors and risks for this project to progress any further and we trust that you will recognise that and take the appropriate action.

Yours sincerely

Richard Evans – Hon. Secretary, New Dovey Fisheries Association (1929) Limited

Karl Humphries – Vice Chairman & Game Fisheries Officer, Prince Albert Angling Society

Julian Glantz – Secretary, Llanbrynmair Angling Association

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

On behalf of:

New Dovey Fisheries Association (1929) Limited

Prince Albert Angling Society

Llanbrynmair Angling Association

Brigands & Bryn Cleifion Fishery

59 Flyfishers

D & R Huntbach Private Fishery

Campaign for the Protection of Welsh Fisheries

Response from Ceri Davies re chicken farms

Ein cyf/Our ref:

Eich cyf/Your ref:

Ty Cambria/Cambria House

29 Hoel Casnewydd/Newport Road Caerdydd/Cardiff

CF24 0TP Ebost/Email: Ffôn/Phone:

Chris White Conservation officer

Campaign for the Protection of Welsh Fisheries (CPWF)

21 February 2020

Dear Chris

Disposal of contaminated water from Fron Bella broiler unit, Pentrefoelas, Conwy

Thank you for your letter, we appreciate your interest in this matter which is also important to us.

An Environmental Permit was issued to GB Jones Ltd in September 2017 to operate Fron Bella Broiler Unit. It allows a maximum of 150,000 birds to be housed at any time and requires the operator to follow best available techniques to minimise the impact from the operation.

Chemicals must be stored in a suitable bunded container to avoid accidental spillages, and contaminated water must be contained.

The standard procedure for cleaning housing after the birds have been removed at the end of the crop is first for the manure and bedding to be removed and then for the building to be washed with water before it is finally damped down with disinfectant. The washwater is contained in a tank before being spread to land. It should not contain any disinfectant.

Our local Environment Team regulates the permit for Fron Bella Farm. A routine inspection visit to the farm will be undertaken within the next month. The inspection visit will check for compliance with conditions on disposal of washwater and confirm the disinfectant procedure and the type used.

An NRW Fisheries Officer will also attend the permit inspection visit to identify any potential issues for fisheries, although it must be noted that we have no evidence of any current fisheries issues arising from this farm’s operations. Planned monitoring of fish populations in the Nug and the Merddwr later this year will provide evidence on the current condition of these tributaries.

With respect to your concerns about the use of Virkon, we have not yet had clarification that this is the disinfectant type used at Fron Bella Farm. Virkon is one of a number of approved disinfectants that are biodegradable if applied to land. The inspection visit will clarify that any

Tŷ Cambria · 29 Heol Casnewydd · Caerdydd · CF24 0TP Cambria House · 29 Newport Road · Cardiff · CF24 0TP

disinfectants in use are being applied and disposed of in a manner that is compliant with the permit.

The Protocol you refer to covers disposal of contaminated water resulting from environmental incidents. Routine washwater disposal would not be covered by this but was considered and assessed as part of the permit determination. All farms must comply with the Code of Good Agricultural Practice (CoGAP) to protect water and land from pollution from their activities and our inspection will assess compliance with this.

Yours sincerely

Ceri Davies Executive Director

Evidence, Policy & Permitting

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!

Mike Ashwin Chairman NWATFCC to NRW (again)

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

9 th February 2020

Heidi Stone, EA Salmon Programme Manager Peter Gough, NRW Principal Fisheries Adviser Cc Dr Alan Walker, Cefas Senior Scientific Officer Lesley Griffiths AM, Cabinet Secretary, Welsh Assembly Government 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 Notification of National salmon review timetable & content re England & Wales River assessments and Byelaw Implementation

Dear Heidi & Peter,

I write as representative of the Salmon Anglers Advisory Group, Chairman of NWATFCC and on behalf of CPWF Campaign for Protection of Welsh Fisheries whose member rod fisheries and business interests hold and manage extensive migratory fisheries in England and Wales. There are as you know two national review processes that are now underway that rod fisheries were instrumental in lobbying for and are scheduled as EA, NRW & Cefas commitments. As yet we have received no prior notification regarding their proposed timetable, contents or point at which rod fisheries representatives will be invited to make their contributions. In letters to the Defra and Welsh Cabinet Ministers in April & Sept 2018, NWATFCC & CPWF made strong recommendations that the E & W national Byelaws should be deferred until the necessary improvements to revising stock assessments were agreed and incorporated into Byelaws and that interim conservation measures were introduced to enable those review processes to conclude with agreement by all parties. In the case of the ongoing national Rod Exploitation Rate review, I was informed in April 2019 that invitations would be circulated, but these have not arrived. Those recommendations to Ministers, made through Mark Lloyd of the Angling Trust were to prevent the situation that now confronts us – that revision and activation of necessary rod exploitation rates are being “held” to prevent exposure to historic stock assessments that might be considered unsafe in framing conservation measure justifications in the current national Byelaws. There is the means to overcome the logjam that is blocking urgently required stock revisions and we must not remain blind to this. NWATFCC & CPWF have formally notified the EA, NRW & Cefas that the provisional 2018 assessments released in June 2019 require revision and we could not accept these until the rod exploitation rate review incorporated corrections in “final“ 2018 published reports. We have asked, but received no confirmation of the progress of the final assessments or what the status of individual river stocks are as regards the original provisional stock report. We have also submitted detailed proposals as part of drafting of the NASCO 2019 – 24 IP Improvements to Stock reporting, River Classification and Decision measures. A summary of the subject headings rod fisheries would wish to engage with within the reviews is set out below and supported by reports containing detailed analysis, modelling, alternate methodology and stock reporting proposals; 1. National Rod Exploitation Rate (RER) review  EA & NRW proposals to improve capture of angler rod catch & species rod effort  EA & NRW proposed methodology for estimating individual river RER`s and elements – rod effort, River flows & salmon runs ( timing re rod season and cyclical frequency)  Rod fisheries analysis & modelling – Prof Brian Revell`s research & findings  Managing Rivers with inadequate rod catch data  Index river validated outputs as linked River reference RER applications  Implementation of annual reviews in annual stock assessment procedures 2. NASCO 2019 – 24 IP Improvements Review a) Conservation Limit  CL as a single conservation reference point  Resetting CL in revising SAP`s b) Annual River assessment of egg depositions to CL  Rod catch and under reporting estimates  Age/weight proportions determining ISW/MSW – Index River estimates  Fecundity values & mortality estimates  Use of existing River stock performance as percentile to CL  Proposed River Fisheries report KPI`s c) River Classification  Fault lines & weakness in current 15 year Linear regression methodology  Adoption of alternate & transparent methodology  Transparent River stock performance as actual percentile MAT to CL in classification status bands  Use of Juvenile data to support stock health assessments  System validation  Opportunities for improved stock performance reporting  Integration and harmonisation of a single UK mainland Conservation strategy d) Decision Process  Transparent River measures process based on River Classification status  Annual River Status review & application of C & R measures  Flexibility to change targets and breakpoints We would welcome a positive response to this communication as part of an inclusive and progressive approach to improving reporting of stocks and applying long term conservation strategies in the national review phase. We very much hope this can be responded to as a joint EA & NRW communication for reasons that both organisations and jurisdictions have shared stock reporting system procedures and commitments in the planned reviews.

With 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

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