Peter Gough replies

Address:                                                           Our Ref:

Your Ref:

Mr Mike Ashwin

By e-mail                                                          Date: 30.11.20

Dear Mike,

River salmon stock estimates Re Cross Border & National Byelaw measures implementation

Thank you for your letter of the 23rd July on your subject above. Firstly, may I apologise for not having responded to that before now – this appears to have been an administrative error that only surfaced when I reviewed your email and attachments of 21st November.

This response will address the issues you raised in your letter of the 23rd July. It includes observations relevant to NRW, and not those which fall under the remit of the Environment Agency – such as questions about the Severn NLO and byelaws.

Firstly, paragraph 6 of your opening page appears to imply that the Local Inquiry in 2019 was in some way flawed in its failure to fully consider the pending review of stock assessment procedures. However, the pending review was referred to in evidence submitted to the Inquiry by NRW and others (including in your own evidence), so the Inspector was aware of it in reporting his findings.

Regarding the review of stock assessment procedures outlined in Action F2 of the NASCO IP 2019-2024: our previous correspondence of the 12th July 2020 addressed this area in some detail. To reiterate, NGOs participating in the Wales Fisheries Forum and the England Fisheries Group will have the opportunity to comment on proposals arising from that review. These NGOs include, for example, the Angling Trust.

For the latter part of your letter headed: Dee index RSE programme…etc.: in part, this re-visits issues raised and addressed in previous correspondence, so I won’t seek to repeat these. NRW does not disagree that declining salmon runs and catches (and the complex of factors potentially influencing the relationship between the two) will, if this trend continues, make estimation procedures which rely on catch data increasingly uncertain. This point was made in our previous correspondence, as was our aim to

seek to strengthen catch-independent methods to assess stocks alongside more established procedures. My colleague Ian Davidson has been in correspondence with Emeritus Professor Brian Revell regarding analyses by Professor Revell pertaining to some of these matters which he’s kindly shared with us (although we are not familiar with the quotations from Professor Revell referred to in your text, which presumably originate from other correspondence?).

Declining stocks and catches also effect the degree of uncertainty around mark- recapture estimates obtained for the Dee. This is largely unavoidable, given that, as fewer salmon return to the river, there are fewer to tag at Chester and fewer fish available to be caught by anglers. Because of this, estimates become less precise as fewer tags are recovered in absolute terms. To address this, we are looking at the possibility of reinforcing the established mark-recapture programme with deployment of automated tag screening facilities and counters associated with fish passage structures – including structures constructed in the coming years as part of the Dee LIFE project.

The use of angling exploitation rate estimates from the Dee in deriving run figures for non-counted rivers in Wales is as described in the FOI response to John Eardley of December 2018 (I presume this is the FOI you are referring to?). The regression models ‘1’ and ‘2’ you refer to are based on exploitation rate data obtained from a number of counted rivers, not just the Dee. Future model developments will also draw on data from all validated counted rivers in England and Wales. Relative differences between angling exploitation rate data obtained for 1SW and MSW salmon on the Dee are, as you indicate, used to adjust exploitation rate estimates derived for all fish to produce sea age specific values. This ‘default’ adjustment is currently applied across E&W.

Regarding your concerns about Dee salmon run estimates based on catches and tags returned by logbook holders, as opposed to the wider angling population: logbook anglers don’t ‘catch 2/3/4 times the proportion of tagged fish in their returns’ as you state. From the mid-1990s to date, the proportion of tagged fish in the reported catch has averaged 18.6% in logbook returns and 16.8% in the returns of all anglers. Those proportions have varied over time, but for the wider angling population, tag reporting rates are not accurately known – hence our focus on logbook returns.

Trap efficiency for salmon (and sea trout) at Chester has been declining gradually since the programme began in the early 1990s. Structurally, the trap has changed little since that time, however, the hours fished per year have reduced – from a 5-year average of ~5,000 hours in the early 1990s to ~4,200 hours in recent times. Trapping continues to be carried out year-round (January – December). These small changes

should not significantly affect the provision of run estimates or other key outputs from the Dee programme.

Salmon run estimates at Chester obtained from the start of the year to mid-October are based on tagging and angling recaptures. Numbers of fish entering after the end of the angling season are estimated from trap catches and average trap efficiencies. Out-of- season trap catches at Chester represent ~10% or less of the annual total.

Where tag recaptures allow, part-season run estimates have been obtained based on blocks of months, but not all individual months. In 2018, for example, the earliest period for which a part-season run estimate was obtained was January – June (684 fish). This compared to an annual run estimate of 3,796 salmon for that year. Annual rod catches and run estimates are strongly correlated.

The sea age, size and sex composition of the run at Chester (along with fishing and natural mortality estimates) are used to evaluate the proportion of the Dee run which survives to spawn and their likely egg contribution.

Monthly age-weight keys for the Dee (and more recently the Tamar) have been widely used on rivers without counters to assign rod caught fish into 1SW and MSW sea age groups as part of the general process for estimating annual egg deposition levels.

I hope this addresses the specific points you raised in July. We will aim to respond to your email communication of 21st November later this week.

Yours sincerely


Response to NRW correspondence of 30.11.20 & 03.12.20 ref NWATFCC information requests & recommendations on Welsh Stock reporting & Byelaw Impact

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum


Peter Gough, NRW Principal Fisheries Advisor David Mee, NRW Snr Fisheries Advisor,

Ian Davidson, NRW Snr Environmental Assessment Officer, Dr Alan Walker, Cefas Snr Scientific Officer,

Grant Horsburgh, Defra Freshwater & Migratory Fisheries Team, Mark Owen, AT Freshwater Campaigns

Cc NWATFCC, CPWF & PAAS representatives Dear Peter,

Response to NRW correspondence of 30.11.20 & 03.12.20 ref NWATFCC information requests & recommendations on Welsh Stock reporting & Byelaw Impact

We very much appreciate your detailed responses to our communications of the 23.07.20 & 03.11.20.

I am conscious you are also midway in responding to our letter of 02.12.20 concerning the recent publication of the 2019 Salmon stock performance in Wales report. With this in mind I would like to make a full NWATFCC combined response to those three communications once we have received your last response. I expect to complete our final response within the next 10 days.

Please consider four important points in your final reply:

  • NRW & EA Rationale for reverting to using a historic 1.1 raising factor in 2019 angler declared under reported salmon rod catches. You refer specifically to correspondence between Simon Toms (EA) and myself of 4th August as explaining this. As you are now aware this correspondence has been registered as a Formal Complaint by NWATFCC to EA this week. I have provided this correspondence for you and in our view this does not provide a satisfactory explanation for a revision from 1.51 in 2018 to 1.1 in 2019. Our NWATFCC analysis of four major NW Rivers fisheries catch returns demonstrate that there is still significant angler declared catch under-reporting which we estimate to be 1.68 and higher than the 2018 factor applied. This is a major factor in NWATFCC, PAAS & CPWF formally writing to the EA, NRW & Cefas that we are unable to accept or agree with the 2019 published River stock assessments.

May we ask that NRW clarify which Welsh River fisheries do provide reliable rod catch data that is used by NRW to set individual river estimates used for total catch and egg deposition estimates.

  • Fisheries engagement in national reviews (rod exploitation rate RER & 3 year stock assessment & decision structure process). Again to re-emphasise, rod fisheries have had no confirmation of the conclusion of the RER findings which we were assured would influence and correct 2018 & 2019 assessments. Nor a timetable and proposed content/scope of the 3 year review to which we have made some very progressive and substantive proposals. We do expect to see and be a part of those formative discussions and certainly not have finished and final proposals presented to us. That has been communicated to the Angling Trust and we look forward to a commitment and further dialogue on this.

Again, this is a factor in NWATFCC, PAAS & CPWF not accepting 2018 & 2019 assessments.

  • The Index Dee assessments and estimates. In earlier correspondence with the EA the Dee Index assessment and estimates for determining whole run size, RER proportions by 1SW/MSW components(annual and 5/10 year MAT) has been mentioned as a potential model for incorporation into the 3 year review proposals. The angler log book programme, trapping, tagging and recapture estimates may well be the best angler recapture programme in E & W, of which there are few. But the system presents some concerns and you kindly offered a site visit to discuss these with you. We would welcome this.

These concerns arise from:

  • tagged fish being generated from operational trapping that has reduced to approx 50% of the available annual hours (4,200 hours of 8544 annually. This was 5,000 on average in the 1990`s)
    • the trapped proportion of total run falling to below 15% in some years. The Dee report refers to this proportion being 20 – 30 %.of the run.
    • a 5 or 10 year average Dee RER being used on the Wye & Usk when individual year RER can fall by as much as 50% year to year e.g. 2017 to 2018.
    • that the Dee anglers in the log book scheme catch 2/3/4 times the proportion of tagged to untagged salmon in their reported catch to those reported by non log book anglers. You have responded that this does not happen. I would ask you refer to the NRW Index data below that I have summarised for years 2016 -18 that does show there is a 2/3/4 times variation between these angler groups.
  • Ranking Rivers by the strength of negative trend in the latest 10 year-time series of egg depositions (Salmon stock performance in Wales 2019 report). I have discussed this with colleagues and statisticians and we are unsure as to how this data has been derived and unconvinced of the conclusions that are being drawn from this. What trend is this and what is  the equation for estimating the trend ? How are the “p” values and eight category rankings derived?. From our analysis of 6 of the best performing Welsh Rivers the published ranking categories do not correspond with our findings. We would welcome a response to these points.

Once again thank you for your patience and assistance in addressing these important discussions.

Best regards Mike Ashwin,

Chair NWATFCC North West Angling Trust Fisheries Consultative Council & on behalf of

CPWF Campaign for Protection of Welsh Fisheries & PAAS Prince Albert Angling Society.

Formal Complaint raised by NWATFCC & LWFA with presentation and reporting of River Lune stock assessment and use of Lune Index counter data

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum

6th December 2020

Sharon Kennedy, EA Environment Manager Cumbria, Keith Ashcroft, EA Director Cumbria & Lancashire,

Brian Shields, Simon Toms, Lawrence Talks, Heidi Stone EA Dr Alan Walker, Cefas Senior Scientific Officer

Mark Owen, Angling Trust

Andy Hurst & John Whitham, NWATFCC

Vic Price, Alan Edny & Brian James, L&WFA & LDAA

Formal Complaint raised by NWATFCC & LWFA with presentation and reporting of River Lune stock assessment and use of Lune Index counter data

Dear Sharon,

Further to registering our initial Formal Complaint letter of the 28th August and our later conversations over your wish that this might be dealt with as part of the EA – Response to Representations in the Lune consultation process we confirm these serious concerns have not been managed or explained in EA responses and ask that the Formal Complaint is now progressed.

NWATFCC & LWFA has consistently warned the EA of serious errors and incorrect interpretation in use of Lune Index data in stock estimates and assessments in the NLO & Byelaw Consultation.

There is no recourse for NWATFCC & LWFA to respond to incorrect statements or interpretation made by EA advisors in the final Response to Representation, without a Public Inquiry or Judicial Review. That is a wholly unsatisfactory and costly process and has resulted in our decision to raise this Complaint.

We request your national Salmonid Fisheries team answer the key and significant issues outstanding and take appropriate steps to consider whether you can recommend the proposed NLO & Byelaw measures to the Minister. We have formally written to the EA on a number of occasions this year and latterly the Defra Minister asking for the Consultation to be suspended so that a proper review and recalculation of the Lune historic estimates takes place and revised assessment and stock status published. Again we recommend that interim voluntary measures are agreed with LWFA & NWATFCC Officers in the event that the national RER and stock reviews remain inconclusive.

NWATFCC provide a short summary of the key issues arising for this complaint

  • Invalid EA assumption and premise that the historic Lune counter data and comparative rod catch based egg deposition spawning stock assessments are independent and that their pre 2015 close correlation makes use of post 2014 rod based catch assessments reliable.

The EA Fisheries specialist in the Lune Consultation Response to Representations and presumably the same person in the Byelaw Review makes the claim that the pre 2015 Lune counter data egg deposition estimates and rod catch based egg deposition estimates are independent of each other and so closely correlated over the years 1996 – 2014 (page 28 Fig 2.15 of the Review document) that this makes the rod catch data in the 2015 – 18 “reliable to use for estimating stock”, even after applying an average rod exploitation rate in those years. Page 28 states:

Importantly, the two methods consistently produce near identical assessments. The reliance solely on the rod-catch assessment method since 2015 can therefore be considered a sufficiently robust description of the stock, in the absence of the counter data.

In fact anyone observing the correlation in Fig 2.15 in each of the years 1996 – 2014 would find them so closely correlated to be wholly improbable they are independent of each other.

The fact is that the rod and counter egg deposition estimates ARE NOT independent of each other. Rod based egg deposition spawning estimates are actually derived using the annual rod exploitation factor estimate in each year, which IS DEPENDENT on the direct calculation between annual rod catch and counter numbers. They are by definition DEPENDENT estimates.

It is therefore NOT reliable to use the reported 2015 -18 rod catch using a constant average RER. That is the reason a national review of RER is underway with the purpose of introducing annually revising RER`s for individual Rivers. It is also the reason for the NWATFCC Formal Complaint and Parliamentary Ombudsman case concerning the EA`s policy in the NW to apply fixed RER`s and in the case of the River Eden the same RER for 20 years.

•             Unexplained divergence in historic Age-Weight table applications

The EA explained in their February 2020 Consultation Review document that their original incorrect Age – Weight table calculations were corrected in Lune estimates prior to release of this Consultation Review document as referred to on page 28. Even up to the last month before release we were notifying the EA of corrections that had to be made and that the unusual and wide annual divergence between individual NW Rivers and the national average (affecting 1SW/MSW proportions and their vastly different female proportions).

NWATFCC highlighted this as a major cause of concern in Lune estimates historically and the reason why the Consultation process should be delayed.

There is no explanation or attention given to 1SW /MSW proportions and their female proportions in either the Consultation Review document or Response to Representations when this has been the biggest factor in altered runs and stock estimates. Neither has there been any explanation provided as to how these table values vary from River to River or where they are derived from. In the Box 1 E & W Index River Policy document (attached) the Age – Weight values applied to individual rivers are derived from Index River outputs. Is this the Lune, the Welsh Dee, Tamar or Tyne. Whichever it is this does not explain the low River Lune & NW Age – Weight values applied which do make a significant difference to the final year estimates.

•             Multiple and significant error in use of rod exploitation rate RER estimates in post 2014 Lune annual egg deposition estimates

The EA explain that in the 5 years since 2014 when the Lune counter was malfunctioning or out of action, using a 5 year historic Lune “average” of 13% was appropriate and provided reliable rod catch based egg deposition estimates.

We refute this completely. This is the substance of the NWATFCC Formal Complaint to the EA re the Solway Byelaw – River Eden RER (unchanged at average 20% RER since 2000) and other NW river RER`s remaining unchanged and also the reason for the national RER review which we were advised by the EA would influence and inform 2018 & 2019 estimates. This review has not concluded, is a year and a half overdue and has not addressed 2018 & 2019 estimates.

Further, the EA applied the 13% RER in 2018, a year when rod catches were acknowledged to be severely impacted by drought and low fishing effort and the two remaining operational Index River counters (Dee & Tamar) reported a fall of 50% RER on 2017. NWATFCC & LWFA warned of this and referred to EA data showing the significant decline in rod effort on the Lune & other NW rivers.

The EA compared this to the Fowey & Teifi counter rivers where RER was claimed to have not been changed in 2018.This is not the case and the national exploitation reports for these years on these smaller salmon rivers show that both had significant and changed RER in 2017, 2018 & 2019.

Further the EA advisors in the Response to Representation state that the NWATFCC & LWFA claim that the actual “average 13% RER” for the Lune in those 2015 – 2018 rod catch years, when applied in year estimates using the actual different proportions of 1SW/MSW stocks demonstrated a higher than 13% average was applied, did not make “mathematical sense”.

We recommend the advisors or specialists undertake the simple calculation and confirm for themselves that the mathematics do agree with the estimates we provided and actually do make sense.

•             Unexplained error in 6th August published 2019 Assessments (2016 as 48% CL attainment)

This is self explanatory and a correction and explanation is requested as to how errors of this kind and magnitude suddenly appear in historic tables? More importantly does this make the 2019 Lune Formal Compliance 5 year forward in 2024 incorrect ?

•             Use of Index Lune Forge weir & Hydro data – its Validation, efficiency and hydro operation

The Lune Forge Weir is a nationally important Index facility. It has not reported validated data for five years due to outage, storm damage and construction of the adjacent Hydro with secondary fish pass. We understand the Hydro counter still requires validation. That is an unacceptable and ongoing state of affairs in a region where other validated and important counter facilities have been withdrawn.

The only outputs provided to Lune fisheries and anglers historically are individual month counts in months when the counters are operational. A wholly unsatisfactory state of affairs when you compare this to counter & trap data and detailed annual reports provided by the Index Welsh Dee and other SW counter rivers.

The Box 1 Index Policy statement (attached) Point 7 for the four E & W Rivers – Lune, Tyne, Tamar & Welsh Dee states that outputs and interpretation and application of Index data will be used for estimating egg deposition as part of Conservation Limit Compliance procedures.

Text Box: 7. To supply information to support Environment Agency R&D/Science and the application of fisheries modelling and assessment methods; including:

•	Initiatives to develop ‘Biological Reference Points’ (BRPs) for sea trout
•	Provision and analysis of stock and recruitment data to improve current SAP methods
•	Production of annual age-weight and rod exploitation data for input into generic models for estimating egg deposition as part of Conservation Limit compliance procedures.

The River Lune is a compromised Index facility that is not producing input to other NW Rivers to revise and influence updated Age -Weight and rod exploitation rate data, yet we are informed this is reliable data on which River Lune 10 year mandatory measures must be applied.

Thank you for your attention in these matters and we look forward to confirmation of the EA Complaint procedures.

With regards,

Mike Ashwin, Chair NWATFCC

Andy Hurst, Chair LWFA and V. Chair NWATFCC

NWATFCC update - 3 Formal EA Complaints

This communication was directed today to the EA`s – NW Fisheries Managers and Technical specialists in the F, B & G teams – Steve Garner, Colette Whiting, Darren Bedworth, David Spiby & Phil Ramsden (Andy Gowan`s replacement. EA Fisheries colleagues,
I am writing to you jointly, because the circumstances warrant this. This is FYI and no response is required. 
NWATFCC has registered 3 Formal Complaints to the EA in the last 18 months (2 this week), all concerning national and local salmon reporting procedures and interpretation of stocks. That level of challenge to stock reporting systems is unheard of. 
Some of these systems may not be your direct responsibility but you will understand and know that incorrect stock estimates have an adverse and significant impact on our major migratory river fisheries (stock status, CL compliance, angler participation, rod effort/catch, Club/Syndicate revenue, tourism income, damage to stock protection & enhancement programmes). 
The Formal Complaints raised through Sharon Kennedy comprise:

  1. June 2019 – Failure to review and revise rod exploitation rate estimates used historically in SAP framed, annual egg deposition calculations to CL. This concerns all NW Rivers estimates in the Solway, Lune & national Byelaw process. This is now with the Parliamentary Ombudsman and an assigned case officer.
  2. 07.12.20 –  Raised by NWATFCC & LWFA concerning presentation and reporting of River Lune stock assessment and use of Lune Index counter data (in River Lune 2020 NLO & Byelaw Consultation, EA Response to Representations, and to inform wider NW egg deposition estimates in CL Compliance procedures)
  3. 08.12.20 – Statements by EA and failure to use NWATFCC 2019 rod catch reports in published national Angler under-reporting catch factors in estimating the NW River estimates to CL.

The attached letters and support documents refer to Complaints 2 & 3 only.The NWATFCC estimates of accumulated error in published and underestimated 2019 river salmon stocks for NW river stocks    require an uplift in the order of between an additional 90 -100% on  current published estimates. This comprises a 43% uplift (e.g. NW Rivers with a 20% RER and correction to 13%) and an additional 58% uplift (from NWATFCC River fisheries returns that demonstrate a 1.68 EA angler declared under reporting factor is required and not the 1.1 factor used from the EA published Angler declared rod catch estimates). 
NWATFCC will consider what action it needs to take following these Complaint processes and after receiving the EA response to our request for a written explanation and reply to the NWATFCC tabled Agenda item at the December – England Fisheries Group meeting.
Finally, NWATFCC have raised concerns that the much-reduced 2019 report – Salmonid and Fisheries Statistics in England & Wales (released two months early this year !) fails to contain essential river and regional breakdown of – Migratory Licence purchases by category,  rod effort & CPUE by river, salmon weight/component analysis, monthly river analysis of salmon and sea trout & C & R catch.  At present we have very little detail to compare 2018 and 2019 River performance.
The good news is that in 2019 (and a lesser extent 2018) after all the dire predictions from the 2016 Storm Desmond impacted juvenile survey results that stocks were in critical decline, we have witnessed strong runs of returning salmon.The Derwent 2019 rod catch doubling its 2018 return and on early analysis of Eden reported fisheries catch the beats below Warwick Bridge have already exceeded the whole river 2018 catch. These returning adults from spawning progeny when voluntary C & R of 90% was being observed.
Thank you for your time and we hope you and families keep well through the turn of the season and next year.It`s been a tough year and we hope our joint efforts are rewarded.
Mike AshwinNWATFCC  North West Angling Trust Fisheries Consultative Council

NRW response

Address:                                                           Our Ref:

Your Ref:

Mr Mike Ashwin

By e-mail                                                          Date: 3.12.20

Dear Mike,

Thank you for your letter dated 3rd November 2020.

In response to the first issue you raise, the above letter was not received by Natural Resources Wales (NRW) until your email of the 21st November and hence could not have been addressed in the Wales Fisheries Forum (WFF) meeting which took place on the 19th November.

Regarding stock assessments for 2020 (and byelaw issues aside), we expect COVID19 with associated restrictions on travel and other related matters will have had an impact on angling activity. Given these exceptional circumstances, we are anticipating that some modification to assessment procedures may be necessary in 2020, however we will not take a final decision until a meaningful examination of catch returns is possible early in the New Year (noting that final reminders to submit catch returns are sent out in January). At that stage, we should also be in a position to view those provisional catch data alongside validated counts (on the rivers where we have fish counters or traps). Other factors, including possible byelaw impacts on angling, will also be considered at that time. In carrying out this work we will be liaising closely with the Environment Agency (EA) and Cefas.

The rationale behind the decision to revert back to the single (national) x1.1. raising factor to convert declared angling catches to estimates of total catch, has been covered by my EA colleague Simon Toms in his email correspondence to you of the 4th August 2020. This also addresses some of the specific points you raise about reported catches in the Northwest of England, which, of course, is outside the jurisdiction of NRW.

Simon’s response also refers to the steps we are taking (within the wider review of stock assessment procedures) to improve modelling of angling exploitation rates as a key part of the process of converting catches into estimates of returning stock. That work is progressing but is not complete, and so we do not yet have proposals to share

with WFF or the England Fisheries Group (EFG). However, once we are in position to share that information, we will do so (as we have committed to do in the NASCO IP). The last point above applies to all aspects pertaining to the review of stock assessment procedures, and provides the opportunity for engagement with external fisheries interests, both lay and specialist, including, where we can, through peer-reviewed scientific publication. We will also keep our strategic WFF informed on progress as, I suspect, the EA will do with their EFG. We will also be reporting progress through the Annual Progress Report for the NASCO IP.

Finally, I understand that Simon has previously offered to meet you to discuss some of these matters. NRW will be happy to support such a meeting.

Yours sincerely


Principal Advisor Fisheries

Cc        Simon Toms, Environment Agency Ian Davidson, NRW

Ffôn/Tel            03000 653501


Croesewir gohebiaeth yn y Gymraeg a’r Saesneg Correspondence welcomed in Welsh and English

Corrections, explanations and recommendations to the NRW published Salmon stock performance in Wales 2019 Report

Peter Gough, NRW Principal Fisheries Advisor David Mee, NRW Snr Fisheries Advisor,

Ian Davidson, NRW Snr Environmental Assessment Officer, Dr Alan Walker, Cefas Snr Scientific Officer,

Grant Horsburgh, Defra Freshwater & Migratory Fisheries Team, Mark Owen, AT Freshwater Campaigns

Cc NWATFCC, CPWF & PAAS representatives Dear Peter,

Corrections, explanations and recommendations to the NRW published Salmon stock performance in Wales 2019 Report

May I thank you for your recent confirmation that the NWATFCC, CPWF & PAAS request to NRW & WFF concerning impact of All Wales Byelaws on river catch will be responded to on 4th December.

In other correspondence received last week the attached NRW – Version 09/06/20 Report on Salmon stock performance in Wales 2019 was included in distributions following a recent LFG. Having asked four WFF – LFG colleagues and other PAAS & CPWF representatives whether they had received this I received a mixed response. Importantly the Report does not appear to have been part of the WFF November Agenda nor does it appear to have been commented on?

My colleagues and I have read the document fully and wish to express our concerns with key elements of its content and presentation. May I ask that these points are responded to and where necessary corrections made and communicated to persons that have received earlier copies and to all WFF representatives. You may wish to add these to the earlier request dated 03.11.20. We appreciate this may require a later response. Would you would please advise on this.

Points are as follows and include coloured text where they appear in the original 2019 stock Report;

  1. Use and reference to Management Target in achieving Management Objective Throughout the Report reference is made to achievement and attainment to Management Target MT (approx 30 – 40% higher than CL egg deposition target) when MT has no specific function in setting Management Objective MO and a River`s Formal Compliance.

The England & Wales Annexe 4 – Salmon Stock Management System clearly states;

The Management Target (MT) for each river is a spawning stock level for managers to aim at, to ensure that the objective of exceeding the CL is met four years out of five in the long run (i.e. 80%  of the time).

It is by definition a goal but emphatically not a requirement for managers.

The NRW 2019 Report Page 2 states;

Natural fluctuations in spawner and egg numbers means that on average, stocks must be some way above the CL in order to meet Management Objective. The average stock level equated to an additional layer of protection and is indicated by the Management Target (MT)

The NRW 2019 Report Page 2 states:

It may be desirable for average stock levels to reach or exceed MT but it is NOT a requirement and factually incorrect to state that average stocks must be above MT to achieve MO (Formal Compliance in 5 years time). There are many historic examples of rivers meeting MO – “Probably Not at Risk” or “Not at Risk” status where very few of their historic 10 years estimates actually met CL and certainly did not achieve an average stock level above MT. The Wye being an example.

2.      Management Responses

The 2019 Report page 4 states;

Text Box: In line with the Decision Structure, steps should be taken to significantly reduce or even eliminate net and rod fishery exploitation (i.e. the numbers of fish killed) on those rivers projected to be “at risk’ or “probably at risk” in 5 years time (i.e. 2024 in the current

assessment). Where possible (principally on rod fisheries), voluntary measures to control exploitation should be promoted in the first instance before considering mandatory action.                                                                                                        

In view of the fact that in England the EA & Defra did and does observe the stated E & W guidance and NASCO approved Decision Structure Process, NRW`s promotion of Voluntary    C & R measures for “Probably at Risk” and some “At Risk” is at odds with its actual delivery of national Byelaw Policy. Please explain why NRW continues to promote this voluntary option in the 2019 Report when the All Wales Byelaw Consultation and Inquiry provided no such option?

We would recommend and welcome a statement from NRW that clarifies how mandatory C & R and method restriction measures, including those applied all Welsh “At Risk” and Probably at Risk” rivers in 2019 and 2024 (five years time) will be reviewed and communicated to WFF, LFG`s, rod fisheries and anglers during the period of the 10 year Byelaws. Might we suggest that this makes reference to the decision points and notes contained in Pages 6 & 7 of the Annexe 4 – Salmon Stock Management Plan? These are missing in the 2019 Report. We request that these are circulated with the page 5 Decision tree table so that we have a complete set of Decision papers. Additionally, we ask information is provided that informs fisheries and anglers when and in what circumstances changing river assessments will cause Byelaw Measures to be reviewed on an individual river basis.

3.      Vulnerability of Stock ranking

We welcome NRW`s policy to measure river stock performance on multiple criteria through a ranking system. However we are particularly concerned that the later two of three ranking tests do not provide an accurate measure or indicator of adult spawning performance. We would expect and recommend the performance tests to include;
  • Individual rivers actual annual Formal Compliance to CL (5 or 10 year % values)
  • A rivers actual average 5 year attainment to CL target (its MAT % ).

Looking at the 2019 Reports second ranking performance test;

Text Box: Rivers are ranked by the strength of negative trend in the latest 10 year-time series of egg deposition.

It is clear that over the last 10 years most rivers will and are exhibiting a negative trend as a result of the significant change in 1SW/MSW run components. It is also not unusual for Rivers to meet CL and MT consistently yet still exhibit a negative trend. In these scenarios trend performance can present a misleading measure of stock health.

Our own analysis of the last 10 year time series egg deposition trend estimates for the 23 individual Welsh rivers does not agree with your own tables which appear to show all Welsh rivers have a negative trend.

The Wye & Severn would appear to display a positive 10 year trend, whilst the Usk, Mawddach, Conwy and Dee negative trend estimates do not appear to fit with the published Table 1 & 2 trend categories. Please would NRW provide confirmation of how the 10 year time series trend graph was calculated with examples in graph form for the 6 rivers mentioned?

Concerning the third ranking test:

We refer to the points raised in Item 1 and above and request that the % egg shortfall/surplus is measured to Conservation Limit target.

  • Page 8, 9 &10 – 23 principal River graphs

We very much welcome NRW`s initiative to present individual river graphs and illustrating these over the long time series history back to 1994.

However the graph illustrations of the 23 Welsh Rivers present a number of interpretation issues for readers that you will be familiar with.

  • The charts are in logarithmic form and do not illustrate actual y axis scale egg deposition values in millions.For the unaccustomed reader they are difficult or nigh impossible to interpret, a point made as far back as the 2017 Telford Stock Assessment Workshop and referred to in the Workshop summary report as a matter for future improvement. Talking with colleagues we feel that for most Rivers the scale of annual variability would allow graphs to be presented to actual scale and this would provide a different and much improved assessment of actual egg deposition performance.
  • Management Target is illustrated with a much bolder and over emphasised line relative to the formal CL line target. Many readers will assume incorrectly, that the MT target line must be the required formal compliance target. This is not the case and we recommend that in future the CL & MT lines are of equal weight.

Finally, the 2019 Report does not refer to the significance of the two national E & W Reviews that are underway which present an opportunity for NRW & rod fisheries to engage in what is a critically important milestone for salmon fisheries. Those reviews being ;

The Rod exploitation rate review for revising estimates used of whole River run stocks for Rivers without validated counter data.

A three year Stock Assessment Review to improve procedures and methodology for setting targets, assessing and reporting annual stocks, and Decision Structure Process conservation measures.

The 2019 Report does not record that NRW, EA & Cefas arbitrarily reverted to using the historic

1.1 Angler under reporting factor in 2019 River estimates and did so without informing Rod fisheries. Disregarding reliable River fisheries catch estimates which showed that in the NW a factor in excess of the previous 2018 estimate of 1.51 needed to be applied to 2019 estimates.

Additionally NRW, EA & Cefas have published and released the outcome of the national Rod exploitation Rate review which was expected to cause revision to recent year assessments. NWATFCC, PAAS & CPWF are still seeking confirmation of the RER review through earlier correspondence with NRW and EA.

We appreciate this is an unwelcome request at a time of additional workload for many organisations, but believe the matters raised are of importance to improvements we are seeking whilst the national reviews are under consideration.

It is hoped those reviews will engage with and include representation of rod fisheries and angler stakeholder interests.

Best regards Mike Ashwin,

Chair  NWATFCC  North West Angling Trust Fisheries Consultative Council & on behalf of

CPWF Campaign for Protection of Welsh Fisheries & PAAS Prince Albert Angling Society.

A bleak future for the Mawddach.

Like others I have not had sight of this document but clearly it helps reinforce the case for the All Wales Byelaws. In the case of the Mawddach & Wnion I have deep concerns that the current stock assessment methodology does not reflect in any meaningful way what we actually observe swimming in the river. Yes, the runs of fish are a shadow of what they were in the 1960’s and 1970’s but in no way are they in the terminal decline that some would have us believe. Mercifully juvenile numbers have also not suffered in the way that other rivers have done with some recent results being described by NRW as “the best on record” (at least there’s one area where we agree with NRW!).

I understand that the Management Target is a figure that managers should aim for in order to ensure that the Management Objective is achieved but why is there so much variation i.e. in the case of the Dee the MT is 1.13x the CL whereas in the case of the Mawddach it is 1.47x greater?

It is hard for me to see how rod catch based stock assessments are ever going to give a meaningful reflection of the state of small spate rivers Mawddach when other local factors are taken into account:

The tidal river was once a thriving low water worm fishery where considerable numbers of both salmon and sea rout were caught by anglers fishing by anglers using lively but static worms. This form of angling has steadily declined in recent years to the point where it is all but extinct and there is little likelihood of newcomers learning the technique. Other than the relevant chapters in Falkus’ Salmon Fishing and Sea Trout Fishing there is precious little in the angling press to point anyone in the right direction.

Likewise anglers prepared to tackle the upper river gorges and pools with a skilfully swum worm are an endangered species these days. Factor in the impact method restrictions within the byelaws and the difficulty of safely and ethically returning a fish and there is little prospect of the numbers of fish recorded by anglers in those lengthy sections of the upper river ever returning to what they once were. I realise that will be of little concern to those who fish those rivers that are much more suited to the fly rod but I have had some wonderful times in such areas in the past and it formed a sizeable part of my angling education.

I suspect that the smaller spate rivers are also prone to considerable error in reporting given the relatively small numbers of catch returns compared with the larger catchments. A relatively small number of anglers catch the majority of fish on rivers such as the Mawddach and the omission of just one anglers catch return can significantly skew the results.

Sadly there is an unwillingness on the part of NRW to take any of this on board and the current situation seems unlikely to change. Until there is a river by river catchment based solution instead of the current one size fits all “All Wales Byelaws” that have been foisted upon us, sadly I can only see a bleak future for the Mawddach.

John Eardley

2019 Salmon stats and comments

Many thanks for comments thus far – Chris, Guy & John. Can I quickly re-emphasis why I will be writing to Peter Gough later today and asking that this letter and information request is tagged to the earlier communication asking for the stock reporting/assessment answers to be responded to.
It is apparent the June – NRW – Salmon Stock Performance in Wales 2019 Report has not been distributed widely and appears to have not been included in the last WFF Agenda, which I find quite amazing.
There are incorrect statements that require explanation and correction and we do need to know who is the author of this report.
The central thrust of the Report is to reflect Welsh River performance against the higher egg deposition “Management Target” and not the Formal Compliance – “Conservation Limit”.  As a rule the MT is 30 – 40% higher than the CL. In our view this is contentious and presents an incorrect assessment of Welsh River health.
But also fundamental elements of Stock Assessment procedures and methodology are subject to two national review processes to which we have submitted detailed proposals and have been excluded from representation. 
Can or should they do this ? – they used the MT performance trend framework in the Byelaw Consultation and at the Welsh Inquiry and produced and enforced mandatory C & R and method restrictions outwith the Decision Structure process. 
It may be helpful to grasp some of the key proposals NWATFCC, PAAS & CPWF presented to NASCO as part of drafting the NASCO 2019 -2024 Implementation Plan, which led into formation of the 3 year stock Assessment review ; 

  • Revision of CL & MT to a single CL for Rivers
  • Removal of the use of 10 year historic and 5 year forward – Linear Regression trend and Bayesian Analysis to project 5 year forward stock status – the probability of meeting Management Objective (exceeding CL in 4 out 5 years on average in the long term).          Replacing this with a simple 5 year rolling average River attainment to CL – the Scottish model.
  • replacing the current Decision Structure Process with a much simpler C & R measures set in 3 or 4 banded categories with each River reporting its actual 5 year % attainment to CL.
  • A new and fuller national fisheries reporting document that shows all the 6-7 variables applied by the EA & NRW to each River to produce the final annual stock estimate a draft of this has been developed and submitted)

Hope that helps in understanding the background to this process and how rod fisheries as principal stakeholders should be consulted and engaged in these decisions. 
Mike AshwinNWATFCC  North West Angling Trust Fisheries Consultative Council

Chris White: still seeking the truth

Conservation Officer

Chris White

57 Normanby Drive Connahs Quay Flintshire


Chris White

24 September 2020

Deputy Minister for Housing and Local Government (via email)

Re: 14 Sept Press release: ‘Funding boost for the great outdoors’

Dear Minister,

I note in a press release of 14 September 2020 that you say:

“£337,000 has also been awarded to eleven projects to improve recreational access to water ”

I have been unable to find any information about these projects on the Welsh Government website despite extensive searches.

I would therefore request under the Freedom of Information Act details of the location of these eleven projects, individual costs/benefits for each project and time scale for completion.


Conservation Officer: Campaign for the Protection of Welsh Fisheries

The following sad letter speaks for so many anglers in Wales

It has taken me some time to publish this touching letter from John Eardley, an angler who has worked so hard with NRW and the EA before that, as well as with fellow angles.

To say that John’s resignation from the North Wales River Trust, as well as from his “second home” in Wales, is a tragedy: he will be much missed. Thanks for all your hard work John. I have no words to adequately describe my feeling at loosing John from the Welsh campaigners, but have no doubt that we have more to hear from him. Don’t let the *.* grind you down John!

Dear Alan and fellow Operations Group Colleagues

It is with great sadness and regret that I write to inform you that I can no longer continue in my role as secretary of the North Wales Rivers Trust. I feel that everyone needs to know the full reasons behind my decision and hopefully my letter will bring some understanding of what has led to that decision. I will continue in my post until you are able to find a replacement and would like to attend the next meeting to say my goodbyes formally although Covid 19 may intervene on that front.

It is nigh on 60 years when, armed with a hand me down tank aerial rod, I first cast a worm (unsuccessfully!) into the Mawddach and so began a love affair that I thought would last for ever; sadly that has proved not to be the case. This is my 40th year of having a permanent base at Y Vanner on the banks of the Mawddach but sadly it will also be my last having made the decision to sell our caravan and replace it with a tourer which will enable me to explore areas of North West and North East England where I have access to a number of rivers and a free choice as to which angling methods I choose to use. Sadly the method restrictions within the All Wales Bylaws mean that the majority of the Upper Mawddach and Wnion are now extremely difficult to fish by legal means and, given the difficulty of returning fish ethically and safely, those magical places, never even seen by those responsible for the current debacle, will now be consigned to my memories. The final nail in the coffin is the fact that I have lost every single fish that I have hooked this year on single hooked spinners, an all too common experience for the majority of anglers. For NRW to suggest that the bylaws will make little difference to anglers is an endorsement of just how out of touch with the angling community the organisation has become. It is more than a little ironic that a place that was once such an exciting escape from the pressures of a busy working life has, in retirement, become a place of hopelessness and despair.

When I first represented Prince Albert Angling Society at the Gwynedd LFG it was yourself and Julian Bray who were responsible for fisheries in North Wales. There was a feeling that our voices were heard and in the case of the Mawddach we felt that we were making progress. A genuine spirit of partnership and cooperation, for example with broodstock collection and the stocking out of juveniles, strengthened the working relationship between Environment Agency Wales and PAAS to the benefit of all concerned. Sadly that is the very antithesis of what has happened since the creation of the single body that is NRW. I was also inspired by the work that Chris White and Roger Thomas were undertaking within both the Conwy Valley Fisheries and Conservation Association and the Clwyd and Conwy Rivers Trust and that gave me ideas of just what might be achieved on the Mawddach. I would also like to thank Robin Parry for not only being the calm “voice of reason” as chair of the Gwynedd LFG but in particular for his work in primary schools with the “Finding Torgoch” project. Education is key to our future and in order to do that we have to listen and learn from what others have to say. Kat Marshall has also been a constant source of support.

I would particularly like to thank Rich White for his inspiration, enthusiasm and guidance in initial habitat improvement works within the Mawddach catchment. During an impromptu conversation at a Dee Fisheries Association meeting I expressed envy at the work that had been carried out by the Dee Trust on the Rhug Estate and also works that I was aware of that had been undertaken by the then Clwyd and Conwy Rivers Trust. Rich told me that Afonydd Cymru could carry out works on rivers that were not part of a trust. Following a full day visit to the Mawddach & Wnion we hatched a plan to use volunteer labour from anglers to survey some of the feeder streams using WFD criteria and that these would then inform future sites for habitat improvement works. Volunteers were given basic training and the data gathered was presented in the form of annotated maps, photographs and tables accompanied by a brief written description. I strongly believed that this educational process of visiting parts of the catchment that so many anglers were unfamiliar with would change the way in which anglers view both the river and also the fish that they catch lower down the system. Our efforts received a very positive reception in the Bangor Office and a number of gravel traps were constructed in the Afon Wen. To say that we were delighted when 6 redds were observed on the traps later that year is an understatement. I am afraid that when our knowledge of our own catchment was described by NRW’s Principal Fisheries Advisor at the Bylaws Inquiry as no more than “knowing where the stiles and footpaths are, how to get to the river…” it caused irreparable damage and highlighted the lengths that NRW will stoop to in order to get their own way. That the Inspector believed it speaks volumes about the whole sorry saga.

If it could be demonstrated that the Bylaws were likely to result in any significant improvement in fish stocks and were accompanied by annual reviews they might have been slightly easier to accept. However NRW’s figures show that they will make a negligible difference to the Mawddach system when a recent 5 year average catch of more than 50 salmon and an exploitation rate of 10% would indicate a run size of around 500 salmon p.a. of which 50 are caught on rod and line. However given a return rate in excess of 80% the entire loss due to angling is no more than 10 salmon. The recent NRW email footer “Even relatively small numbers of fish are crucial to recover stocks in as short a time as possible. Every spawning fish matters” is at odds with discussions we have had at the Trust about how, given good habitat and careful management of predation even a relatively small number of salmon can quickly repopulate a spawning stream. In addition NRW’s stock assessments do not reflect what we actually observe in the Mawddach & Wnion and that is also a constant source of frustration. I can only wonder what magic algorithm will be conjured up to account for the large number of fish hooked but no longer landed.

I find it difficult to see how our fisheries can recover from the impacts of what has been foisted upon us. Willing volunteers have left the Mawddach and Wnion whilst those who remain have been well and truly alienated. My own enthusiasm and optimism are now at rock bottom and I suspect that I am not alone when I see just how sparse the current circulation list is for the Gwynedd and Dee LFG’s. Time is not on my side and I am unwilling to wait for the outcome of an interim review of the Bylaws in 5 years’ time and in any case it is difficult to envisage any significant change when the extraordinary lengths that NRW went to in order to secure a legislative solution are taken into account.

I have the greatest respect for everyone at the Trust and wish all of you the very best for the future. I cannot spend my time reflecting on what might have been and so with a heavy heart it is time for me to move on.

Yours sincerely

John Eardley

Another serious pollution and fish kill!!

Dead fish on the affected stretch of the River Llynfi, mid-Wales

Fish Legal is currently advising its members Gwent Angling Society in respect of a major pollution that has hit the River Llynfi in mid-Wales. Literally the day after the last touches were carried out to a remediation project that saw the river put on the road to recovery after a devastating pollution in 2016, yet another wave of pollution saw the obliteration of fish and river life for at least 5 kilometers.

The cause of the latest incident has not yet been confirmed by Natural Resources Wales who are investigating, but what is beyond doubt is the terrible and deadly effect on this Welsh tributary of the River Wye, with tens of thousands of dead brook lamprey, grayling and trout among the casualties.

Clare Pillman replies to John Eardley

Ein cyf/Our ref: CX20-145 Your Ref:

Ty Cambria / Cambria House

29 Heol Casnewydd / 29 Newport Road Caerdydd / Cardiff

CF24 0TP / CF24 0TP


John Eardley

By e-mail:

Ffôn/Phone: 0300 065 4453

29 July 2020

Dear Mr Eardley,

I hope that you and your family are keeping safe and well during these difficult times. Thank you for your letter and observations, we note your continued concerns.

I do not underestimate the changes that are required following the decision taken by the Minister to confirm the fishing byelaws. However, as you know, we are clear that such controls are warranted. For maximum impact, these changes to angling need to work alongside wider measures and action across Wales and this is underway.

I continue to emphasise the importance of working proactively with a range of partners. Despite the challenges involved in changing practices we must work collaboratively if our goals are to be met.

As stated in our ‘Plan of Action’ there is a range of initiatives underway. We are also committed to annual assessments of stocks and a mid-term review of the new byelaws in 2024.

I look forward to working with all our partners to tackle the challenges and seize the opportunities associated with improving and sustaining resilient environments for our iconic fish populations for many years to come.

Best wishes,

Clare Pillman

Prif Weithredwr, Cyfoeth Naturiol Cymru Chief Executive, Natural Resources Wale

Will Bayer settlement clean up Monsanto's PCB contamination in Wales? Details Published: 10 July 2020

Rev Paul Cawthorne says some of Bayer’s USD650 million given to polluted sites in the US should be used to remediate Monsanto’s toxic legacy in the UK

Following the announcement of a USD650 million settlement by Bayer, destined for areas of the US contaminated by the company’s subsidiary Monsanto with toxic chemicals known as PCBs, GMWatch subscriber Rev Paul Cawthorne has been looking into whether any funds from the settlement will be coming to the UK to clean up Monsanto’s PCB contamination in Wales.

The PCB contamination scandal was investigated in The Ecologist’s Monsanto Brofiscin Files in 2007.

Leaky chemical drums at Stoneyhill

Rev Cawthorne told GMWatch, “It is estimated that many thousands of drums of a wide variety of toxic chemical wastes, including PCBs, PNCBs and acids, were deposited at a number of former quarry waste disposal sites along the Welsh border and near the South Wales coast. Some of these drums will have originated from the former Monsanto factories at Newport and Ruabon. Photographic evidence from a UK site shows drums being deposited off the back of a lorry and empty drums which appear to be evidence of leakage due to split or corrosion. Leaking drums was an international problem for Monsanto, as acknowledged by its own employees.

“Toxic leachate into local ecosystems has been revealed at many of the sites, though only Brofiscin, in South Wales, has so far been fully publicly investigated and remediated at an undisclosed cost. Waste production and disposal sites highlighted by ENDS Report, The Ecologist magazine and local residents include Brofiscin, Maendy, Glebelands and Penrhos in South Wales, several near Ruabon, Sutton Walls in Herefordshire and Stoneyhill near Telford – most of them near watercourses, including the major rivers Severn and Dee. Key lorry manifests for one site, which I studied at the Environment Agency Shrewsbury office a decade ago but have now gone missing, confirm the detail.  

Leachate at Stoneyhill

“Has the UK even included the buried piles of waste PCB stocks in its national inventory within the Stockholm Convention? Several of these sites are, bizarrely, not even yet categorised by local authorities as Contaminated Land, despite a statutory duty to assess them.”

Rev Cawthorne has written to Clare Pillman, the head of Natural Resources Wales (see the text of the letter below), asking for clarification as to whether the USD650 million settlement includes provision to clean up bioaccumulative PCBs in the UK.

According to Rev Cawthorne, freedom of information requests have revealed that PCBs are still discharging into the sensitive Severn estuary from Monsanto’s former PCB manufacturing site at Newport. An investigation at Maendy Quarry, promised in Parliament in 1973, is still reportedly unknown to the local council. There remains a worrying fenced-off open toxic lagoon at Llwyneinion, near Ruabon, which caught fire in 1980. Groundwater contamination at Sutton Walls has led to local borehole closures.

Rev Cawthorne adds that the permeability of some site linings and cappings, as well as toxic discharges, such as those at Maendy and Newport, mean that Monsanto’s toxic bioaccumulative legacy in the UK continues to seep into water courses and estuaries, potentially impacting top marine predators and anyone who consumes fish and shellfish from these areas. He says, “Serious remedial action must be taken.”

Rev Cawthorne concludes with a question: “Until proper public accountability is shown, is Bayer’s ethical duty discharged?”

John Eardley still fighting for anglers in Wales

“Ty Newydd”4, Little Moss Lane Scholar Green Stoke-on-Trent ST7 3BL

13th July 2020

By email to:

All Wales Byelaws – the impact on angling

Dear Clare,

With the lifting of travel restrictions in Wales on 6th July and the prospect of favourable river conditions I prepared myself for my first trip of the season. Of course much of my fishing tackle was no longer legal in Wales and I was faced with the prospect of changing all of the hooks on my lures. Research revealed that hardly any companies state the gape size of their hooks and with such variations in the market place it was something of a lottery to ensure the hooks I purchased were legal. Furthermore the cost of suitable hooks varied between 35p and £1.25 each. Nevertheless I made the necessary changes to a few of my lures

although a huge number of hooks still need to be purchased if the rest of my lures are to be legal in Wales.

I ventured to the Afon Dyfi last Wednesday to find a river in perfect condition for spinning and it was then that the harsh reality of the current situation really hit home when, without exception, I failed to land any of the numerous sea trout that I hooked. It is true that an angler will always lose some of the fish that they hook but when “some” becomes “all” angling becomes something of a pointless exercise. Of course I should not be surprised by the outcome given that no parent would purchase a tricycle for their child, remove two of the wheels and then be puzzled why the child kept falling off.

During the day I spoke to 2 other groups of anglers. The first was a father fishing with his 3 sons. They had fared slightly better than me in that they had at least managed to land one of the fish that they had hooked during the day. The second father and son team had landed 6 sea trout between them, the reason for their success being immediately obvious for they had chosen to disregard the byelaws and were both using treble hooks on their spinners. I wonder which of the 4 youngsters will be keenest to head back to the river.

When the river cleared and I changed to fly fishing I did at least manage to hook and land a fish successfully. However you must realise that not every angler is able to fly fish and for those people life is going to be very difficult indeed, particularly when allied to the restrictions applied to worm fishing.

It is very clear to me that yet another angling technique has been rendered all but ineffective in Wales. To achieve any degree of success in the future the options would appear to be either be prepared to be criminalised for disregarding the byelaws or else fish elsewhere in the UK where a more reasonable approach has been taken to method restrictions. To endure the current restrictions for 10 years is a bleak prospect, particularly when it is recognised that anglers are not the cause of the problem. However I am fully aware of what the intransigent response is likely to be in response to any request for an early review of the byelaws.

There is also a serious implication for the already deeply flawed stock assessments if large numbers of fish that would previouslyhave been landed are now lost and hence fail to be recorded on catch returns. Depressed catches will no doubt be attributed to a lack of fish in the river rather than the impact of method restrictions and result in yet further restrictions on anglers. I note that in the Plan of Action the Provisional Sea Trout Stock Assessment for the Dyfi in 2023 is PaR (Probably at Risk). The numbers of fish I witnessed on Wednesday would indicate that nothing could be further from the truth but then again senior fisheries staff would have to actually visit the river in order to know that.

I realise that my letter is unlikely to elicit any positive response but it would be remiss of me not make you fully aware of the farcical situation that legitimate anglers are now having to endure in Wales. The future is indeed grim and that has nothing at all to do with any shortage of fish in most of the rivers that I am familiar with.

Kind regards

John (Eardley)

Mark Isherwood A.M. continues to support anglers: reply from Lesley Griffiths.

Lesley Griffiths AS/MS

Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs Bae Caerdydd • Cardiff Bay Caerdydd • Cardiff CF99 1SN Canolfan Cyswllt Cyntaf / First Point of Contact Centre: 0300 0604400 Gohebiaeth


Rydym yn croesawu derbyn gohebiaeth yn Gymraeg. Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg ac ni fydd gohebu yn Gymraeg yn arwain at oedi. We welcome receiving correspondence in Welsh. Any correspondence received in Welsh will be answered in Welsh and corresponding in Welsh will not lead to a delay in responding. Ein

cyf/Our ref LG/01462/20 Mark Isherwood MS 29 June 2020

Dear Mark Thank you for your letter of 8 June, regarding potential pollution issues to our rivers. The Welsh Government’s commitment to address pollution from agricultural practices and the decline in biodiversity requires decisive action before it is too late. I published draft regulations on 8 April with measures to tackle the unacceptable level of pollution from agriculture in Wales. Clean water and a healthy environment are essential for life in Wales and tackling pollution from agriculture is a priority. Insufficient slurry storage is one of the largest causes of agricultural pollution which continues to have a detrimental impact on waterbodies across Wales. Measures to protect the environment are clearly necessary. The proposed regulations represent a significant increase in the management of agricultural practices across Wales which reflect the seriousness of the present situation. The draft regulations are for information only at this time and any decision on the implementation of regulatory measures to address agricultural pollution will be delayed until after the Coronavirus (COVID-19) pandemic. The draft regulations and an explanatory note have been published on the Welsh Government’s website here. The Welsh Government recognises a strong rural economy is essential to support sustainable and vibrant rural communities. The establishment of new enterprises and the expansion of existing business is crucial to the growth and stability of rural areas. Planning Policy Wales recognises, however, care should be exercised when considering intensive livestock developments when these are proposed in close proximity to sensitive land uses. In particular, the cumulative impacts (including noise and air pollution) resulting from similar developments in the same area should be taken into account. The establishment of the Town and Country Planning Intensive Agriculture Working Group is intended to look at how the challenge can be met. The Group has been looking at what evidence is needed to plan for intensive agriculture development. The work will help develop a draft Technical Advice Note (TAN) for public consultation as soon as possible, which will address the level of information applicants will need to provide to support planning applications. The TAN will help to inform planning decisions benefiting both the industry and local communities. Meanwhile, you may be interested in a consultation being undertaken by NRW which is specifically examining their guidance for carrying out Ammonia and Nitrogen assessments for farm developments require an Environmental Permit or Planning Permission (NRW Guidance Note GN 020). The consultation documents can be found at The consultation closes on 31st August 2020 and I would encourage you and your constituents to make your views known. Regards Lesley Griffiths AS/MS Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs