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

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