Re: NRW fisheries bylaw proposals



PresidentAllan Cuthbert7 Norton AvenuePrestatynDenbighshire

LL19 7NL



Strategy OfficerJohn Eardleyc/o Vanner Farm & Caravan SiteLlanelltydDolgellau


LL40 2HE



Conservation OfficerChris White57 Normanby DriveConnahs QuayFlintshire


An Open Letter to Kevin Ingram (Interim Chief Executive, Natural Resources Wales) and Lesley Griffiths AM (Cabinet Secretary for Energy, Planning and Rural Affairs)


14th February 2018


Dear Sir & Madam,


At the NRW Board Meeting on 18th January a decision was made to apply to Welsh Government for confirmation of new fishing byelaws re fishing controls for salmon and sea trout in Wales.

Although a number of board members had major concerns that failure to work with stakeholders would result in the proposals failing to deliver their intended outcome, ultimately 2 other factors narrowly won the day:

  1. The need to be seen to support the Executive Team who have been advised by NRW Fisheries
  2. The feeling that to step back from taking a decision would be perceived as negligent, particularly in light of the bleak picture painted of salmon and sea trout stocks in the Technical Case document used to support the proposals

At the end of the meeting, in an atmosphere reminiscent of a wake, there were no fist pumping scenes of jubilation since now there were only losers; the NRW Fisheries Team who have so alienated stakeholders that their ill-conceived proposals are now unworkable, angling organisations who as well as feeling both disempowered and disenfranchised face a loss of membership, loss of income & loss of waters and, perhaps most significantly, the rivers and watercourses of Wales who have been deprived of a collaborative approach which could have delivered so much more.


Had we been able to present the following information to the Board we believe that the decision might have been somewhat different:


  1. The NASCO Implementation Plan for England and Wales states that “Compliance against the management objective (that a river must meet its Conservation Limit four years out of five) is assessed annually for each principal salmon river together with a forecast of that assessment in 5 years time.” Whilst there are rivers which are failing to meet their Conservation Limits, that is not a universal issue. In fact the Conwy, Glaslyn, Mawddach, Ogwen & Usk have all met their conservation limits and Management Objective according to the NASCO criteria.
  2. The 5 Year Forecast Projections for the last 3 verifiable periods (2009 › 2014, 2010 › 2015 and 2011 › 2016) are only 41%, 27% and 18% accurate!
  3. Table 7 on Page 49 of the NRW Technical Case Structure shows that the Management Target rather than the Conservation Limit has been used to assess stock status. The Management Target is not an applied measure in the formal Compliance procedures for Assessing Stocks. Correct applicationof the Conservation Limit would result in a very different picture for a number of Welsh rivers.
  4. Between 2010 and 2014 an average of 37.2% of anglers failed to submit a catch return. By 2017 the figure had reached 45%. It is impossible to adjust the stock status model to accurately reflect that amount of missing data.
  5. The numbers of rod caught salmon officially reported by NRW from the Rivers Wye & Dyfi over a 5 year period are significantly lower (Wye – 28.13%, Dyfi – 28.3%) than reliable figures collected by angling associations and river keepers. The addition of those numbers would have a huge impact on whether those rivers have met their Conservation Limit and Management Objective.


This information is at best misleading and in some areas may be open to legal challenge. In the meantime the 2 sides, despite sharing a common goal, remain as far apart as ever.


There is a feeling amongst the angling community that having invested so much time and so many resources in pursuit of its “preferred option” the NRW Fisheries Team has backed itself into a corner and has had no option but to continue along the same path. However, even if one has invested a great deal of time, effort and money in purchasing a battlefield tank to deal with the problem mouse behind the skirting board, that would not in itself be a justifiable reason for firing it when others have made you very much aware of the likely outcome of your actions.


In the meantime we have put forward an alternative solution to the Cabinet Secretary which has not only the support of angling clubs from all areas of Wales but also the North Wales Rivers Trusts and Afonydd Cymru. We believe that the proposed voluntary approach would deliver similar, if not better, results than the proposed statutory legislation and would also facilitate the delivery of River Restoration plans.


The current situation was brought into sharp focus by 2 events towards the end of last week. The first was reading a copy of Dr Malcolm Greenhalgh’s excellent open letter to Sir James Bevan (CEO Environment Agency), Michael Gove and Lesley Griffiths, which highlights the threat posed by changes in dairy farming practices to our aquatic ecosystems. The second was a lengthy telephone conversation that I had with Ceri Davies (NRW Executive Director for Evidence, Policy and Permitting). In a conversation that was at all times courteous and professional (there is too much mutual respect for it to be otherwise), two telling points emerged. The first is that it is in the best interests of both sides to work in a meaningful partnership. The second was the question as to whether angling organisations would be prepared to support NRW in order to increase pressure for change in those farming practices which are causing damage to the aquatic environment in Wales. Of course that type of co-operative approach is exactly what is needed but unfortunately a very large and obvious stumbling block has been placed in its path. In fact the situation would be laughable were it not so serious. Anglers want Welsh Government to side with them against NRW. NRW wants Welsh Government to side with them by imposing restrictions on anglers and NRW also wants anglers to side with them in order to put pressure on Welsh Government!


The road ahead is fraught with difficulties but one thing that is very clear is that it cannot be tackled by any one party in isolation. There is a choice to be made between either a collaborative approach which has the support of stakeholders and which would produce the desired results, or a heavy handed, dictatorial option which alienates the very people who NRW so much needs on its side. That decision does not rest with us but must either be made quickly or deferred, as in the meantime a number of angling clubs are already seeing a significant reduction in applications for membership as visiting and local anglers alike wait to find out just what the future holds for them in Wales.


Yours sincerely


John Eardley


Strategy Officer: Campaign for the protection of Welsh fisheries

CPWF has the support of freshwater and sea anglers in Wales.

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