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 Correspondence.Lesley.Griffiths@gov.wales (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 (https://www.welshbeaverproject.org), 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