To NRW Board Members

Sir David Henshaw
NRW Chairman
Via email: nrwboardsecretariat@naturalresourceswales.gov.uk
12 September 2019

Re: NRW fisheries bylaw proposals

Dear Sir David,
We note on the agenda that the Board will be asked to approve the Fisheries Byelaws relating to cross border rivers and the emergency byelaw to cover the cessation of the National Salmon Regulations which expired in October 2018 after some 20 years.
We wish to draw your attention to the fact that after 20 years of the National Salmon Regulations there has been little or no improvement in migratory fish stocks i.e. there is no evidence that the byelaw proposals will have any effect in reversing the decline in migratory fish stocks. It is recognised that anglers are not the problem and after 20 years of regulation there has been little or no improvement.
The original proposals were presented to the NRW Board which at that time was chaired by Sir Peter Mathews on 9 July 2015 at this meeting the Board rejected the byelaw proposals with Prof Linda Warren who had been a member of the committee which drafted the National Salmon Regulations in 1998 saying as there was no evidence of the effectiveness of the existing regulations why did the fisheries officers consider that extending the byelaws would make any difference. All of the concerns of anglers expressed during the consultation were dismissed as were our very valid arguments at the Public Inquiry.
The issue is not solely related to Catch and Release which the majority of anglers already practice voluntarily, there are also major concerns surrounding method restrictions which will effectively prevent anglers from fishing their local rivers and may see the closure of community fishing clubs due to the loss of membership. It should also be noted that angler exploitation of salmon is estimated between 10% and 13% of the annual number of salmon entering a river. The number of salmon caught is dependent on water conditions i.e. catches are better in high flows and poorer in drought conditions. As anglers catch less than 20% of the salmon which enter a river there are therefore at least 80% of the fish which are not caught by anglers and survive to spawn even if anglers killed every salmon that they caught. However 86% of those salmon that are caught are returned voluntarily and therefore the problem is nothing to do with angling. In fact we are just being used as scapegoats to cover the failure of NRW and previous agencies to address the decline in migratory fish over the past 20 plus years, the reasons for which are fully known i.e. pollution, predation and barriers to migration.
There would be more support from anglers if it was believed that this would in fact reverse the decline in migratory fish stocks but it will not. In fact some rivers have seen a significant improvement in migratory fish numbers since the original technical paper was written in 2014/15 and had the proposals been accepted and implemented in 2016 a review would have been carried out in 2021. To this end CPWF has written to the Minister requesting a deferment of the byelaws for 12 months i.e. until 2021 to enable a review of the status of individual rivers to be assessed, as it stands the byelaws are a blanket approach which covers all rivers.
At the inquiry CPWF raised the issue of disturbance of spawning fish by adventure activity i.e. mainly paddlesport as there is little point in imposing restrictions on anglers only for any increase in fish reaching their spawning ground to be disturbed by such activity (this also applies to anglers wading whilst coarse fishing on cross border rivers – our North Wales rivers do not have any coarse fish populations). Disturbance of spawning grounds equivalent to bird nesting sites would not be acceptable to the RSPB and yet this is not only acceptable to NRW but due to the misinformation on the NRW website is positively encouraged.

Regards

Chris White
Conservation Officer: Campaign for the Protection of Welsh Fisheries

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