Venue: Skype Present: David Mee (NRW) Emma Keenan (NRW) Patrick Lindley (NRW) Peter Gough (NRW) Robert Vaughan (NRW) Steve Ormerod (Chair, NRW) Adrian Simpson (Countryside Alliance) for Rachel Evans Alan Winstone (Afonydd Cymru) Chris White (Campaign for the Protection of Welsh Fisheries; North Wales LFGs) Creighton Harvey (SW LFGs) Dylan Roberts (Game & Wildlife Conservation Trust) James Legge (Countryside Alliance) John O’Connor (Angling Cymru) for Carl Tonner Julian Bray (Welsh Government) Mark Owen (Angling Trust) Mark Tilling (Welsh Government) Nicola Teague (IFM) Paul Edwards (Welsh Salmon and Trout Angling Association) Richard Garner Williams (Salmon & Trout Conservation Cymru) Shaun Leonard (Wild Trout Trust) for Denise Ashton Stephen Marsh Smith (Afonydd Cymru) Tony Harrington (DCWW)

Apologies: Ruth Jenkins (NRW)

1. Welcome, introductions and apologies for absence • Steve Ormerod (SO) opened the meeting, welcomed several new participants and deputies and gave a brief overview of how the meeting would-be run-in order that participants could get the most out of using Skype.

2. Admin Matters • Minutes from November 2019 were approved – any outstanding actions were addressed. • Approval of minutes is now to be streamlined – draft minutes are to be sent to members within two weeks of each meeting and then amended where necessary prior to approval Page 2 of 11 via email comment. If no comments are received within two weeks of despatch, the minutes will be approved to enable them to be circulated more widely and more quickly. • The forum was reminded that members are expected to discuss the issues to be raised at the meetings with others, where appropriate, so that their views may also be brought to the meetings. Members were asked to note that documents marked as ‘draft’ or ‘not for further circulation’ are not to be passed on – including minutes prior to approval. • The ToR has been amended to reflect the current membership list. Reference to the General Data Protection Regulations (GDPR) has been added to reflect issues around prevention of public sharing of members private email addresses Email addresses may be shared amongst the forum only if consent has been given, and email addresses from forum must not be shared publicly. – ACTION ALL – please consider, and then if you agree, sign and return Annex 2 form from the ToR to EK. Electronic copies and signatures are acceptable. • New membership – NRW supports representation of all LFGs (Local Fishery Groups) at the WFF. One new nominated LFG member, CH, recently joined the forum to represent LFGs in SW Wales, and existing WFF members SMS and CW agreed to represent SE and N Wales respectively.as representatives. Some LFGs have since expressed a desire for specific representation and this will be discussed at forthcoming meetings of each LFG and reported back to the WFF. – SMS – we should only be accepting representatives from groups where appropriate process is followed. – ACTION CH and PG to discuss SW LFG representation; PG to report back on any nominations from LFGs It was noted that there is currently there is no overall ToR for LFGs. • ACTION DM and PG to develop a working ToR for LFGs. It was noted that NRW CEO Clare Pillman will attend the second combined LFG meetings in SE Wales, for Taff, Usk and Wye members, on 2nd June.

3. Introduction of new member • Dylan Roberts from GWCT gave a presentation on GWCT Salmon & Trout research work – this will be circulated to members with the minutes. • Questions: – PG When carrying out the netting procedure described, the commercial netsmen would have presumably been doing their best to catch sea trout and this might overrepresent the scale of bycatch in the fishery ▪ DR – We’re looking to catch fish for genetics and were fishing in areas were fishermen could fish and were likely to catch sea trout as bycatch. We will seek to scale this work up next year off the North Cornwall and North Devon coast. Difficult to quantify bycatch. Looking to see if there needs to be tighter regulation. – PG Could you share the evidence from the North Devon report? – Shaun Leonard: Where is the information from SAMARCH available? ▪ Still in the data collection phase and this will be pulled together and put into a report. Page 3 of 11 • ACTION DR to provide information referred to above.

4. Agricultural Regulations • Bob Vaughan from NRW gave a presentation and updated the Forum on Water Regulations: – September 2016 Welsh Government reviewed NVZ; – December 2017 WG decided to go for an all Wales approach; – November 2018 WG decided that regulations would come into place in January 2020; – 8 th April 2020 Minister made a statement on the draft regulations for stakeholders. A final decision as to whether these will be introduced is yet to be made and is likely to be delayed due to Covid19. – The DRAFT regulations may be found here: Draft Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2020 – The draft regs include a requirement for WG to review them and consider any proposals for an alternative suite of measures within 18 months of regulations coming into force to help regs fit better and be more effective. – The WLMF sub group members put forward their comments on the regulations and the Regulatory Impact assessment (RIA) prepared to support the Regulations. These comments parallel the earlier report provided by the group to the Minister. This report developed 5 components, including regulatory improvements, which all the members of the sub group believe are needed to tackle agricultural pollution and nutrient management. Progress report by the Wales Land Management Forum (WLMF) sub-group on agricultural pollution – WG has been developing a replacement for the Basic Payment Scheme, the Glastir Scheme and the Economic Resilience Scheme to promote a Sustainable Land Management Scheme which would need to dovetail with the new regulations; – An all Wales approach: – ▪ places requirements on farmers to invest in storage; ▪ places restrictions on when they can spread; ▪ only focuses on nitrogen. – The RIA undertaken appears to suggest that the regulations will primarily reduce the production of greenhouse gases rather than impacts on water quality. It had been commended that all nutrient management should be covered. – There are concerns that farms will look to avoid slurry produced indoors by putting stock out over winter to reduce slurry production and this could create an unforeseen increased pollution risk which would have negative impacts on soil and water resources. • COMMENTS: MO – Transition period without regulation, how long will it be? ▪ A: It will be 18 months. The transition period will be slightly longer as it will be expensive and time consuming for farms to build new infrastructure. RG – Main comment is of some dismay. The initial announcement came from the Minister without consultation and was that regs would be brought in by Jan 2020. But Page 4 of 11 there has been more delay and an additional transition period. Will we ever see anything realistic brought in that will make a difference? ▪ A: The regulations are a step forward but there is still a lot of work to do before we see any impact on reducing pollution risk.. DR – is there capacity within the guidelines, or to develop guidelines, to prevent farmers from upscaling their production and have a greater number of animals on their fields unless they have the capacity to deal with the additional slurry storage? ▪ A: This has been discussed at WLMF sub group and within NRW and we are reviewing the existing legislation to explore how we may use the powers more effectively rather than waiting until a pollution has occurred. We are looking at a wide range of issues, including planning and regulation, so that we can put into place controls that will work. Once we can identify gaps that need to be filled, we can approach WG with a means to fix this so that we can use the regulation we have to its best effect MO – is this regulation going to be seen as a measure in river basin management plans? ▪ A: We use WFD monitoring as a way of identifying problems across Wales, homing in on those areas to work with farmers to prevent these issues and to help farmers to understand the impact of their actions. SL – Was concerned that NRW appeared to have consented the dumping of milk which is being dumped in large quantities ▪ A: The Covid19 response has had a marked impact on farming. Many farms have contracts with processing plants and those who have contracts with the hospitality market have seen demand stop overnight which is why you’ve seen news items about the possibility of milk being poured away. Many farms already have a waste permit (U10) to allow disposal of milk on site but there are controls on what and how this is safely done. This is a last resort action. WG, with support from NRW, have also been working with processing plants to find alternative markets for this milk to be used. Where you have been seeing dumping it has mostly been going into slurry tanks and where it is spread on land it must be greatly diluted. The waste hierarchy comes into play very early on before produce is disposed of. SMS – A comment: throughout the time on WLMF it is evident that it is not representative of the full picture: members are either NRW or farmers and only 2 NGO members are there. There has been a history of voluntary schemes over regulation. Teams have identified diffuse pollution problems at many farms and there isn’t a mechanism to deal effectively with slurry when they are over-capacity. We as a fisheries group depend on good water quality which isn’t being tackled appropriately. The regulations in place are not enough to control the problems that are ongoing. ▪ A: The WLMF is the only place where we are trying to pull together an approach to deal with this and to guide the sector to see that what is happening is not acceptable. Not just regulation but there are other methods being considered. Regulation needs to be firm enough to deal with those who are not following guidance and advice. There also needs to be a level of professionalism in the Page 5 of 11 sector. We need to work with the sector so that they can see the impacts of their actions rather than solving their problems for them. The forum itself was set up the same way as this forum and has brought in other members to give us another perspective. This forum has come about as the sector itself also sees that there needs to be a change. • There was strong and resolute feeling from the forum that the announcement was disappointing, both in terms of the proposed regulations and the further delays in bringing in effective regulation and the resources to ensure we see a sustained reduction in pollution incidents and diffuse pollution from agriculture. – ACTION: SO will write to the CEO and Chairman of NRW to express the angst and deep frustration that is felt in this forum so that they can bring this up with the Minister. • CH: The work that has been done is under the assumption that the pollution problem is wholly a nutrients issue. The minutes from the WLMF subgroup have been published up until September 2019. As the subsequent minutes are yet to be approved (awaiting information from WG) and placed on the website however, (he could report that) those meetings (October and November) picked up on other issues including bad practice. There is a transition period in relation to the new regulations, and there is also the review period. Will we be satisfied that those two provisions will have been enforced once the 18 months closes? ▪ A: The 18 months won’t start until the pandemic ends ACTION: SO, PG and RV to pursue the points that SMS and CH raised outside the meeting, to raise the issues to NRW Chair/CEO and to inform Welsh Government. • SO also concerned over ability to detect issues in our waterbodies but also any beneficial effects of any changes implemented.

5. Fish-eating Birds PL gave a presentation on the NRW Fish-eating Birds Advisory Group set in the context of the previous work undertaken by the Group and of the need to reconvene the Group as part of the review of NRWs approach to the shooting and trapping of wild birds in Wales • Reference was made to the Wild Trout Trust FEB Paper. • COMMENTS SMS – in this presentation there was a slowing down in bird population growth. Do you think this is down to a decrease fish populations or to recording? Do you think there may be a legal challenge from those whose income comes from fisheries if no action is taken? ▪ A: The trend data is sourced from the BTOs UK Breeding Bird Survey (BBS) and Wales Wetland Bird Survey (WeBS)The next stage will be to look at Wales only data. The UK BBS trends suggests a decrease in breeding goosanders and cormorants but the WeBS (Wales) trends show increasing wintering cormorant and goosander, though we have to be careful of wintering trends as WeBS do not sufficiently cover all inland waterways. All statutory nature conservation bodies (SNCBs), including NRW are under Page 6 of 11 close legal scrutiny from current campaign groups, such as Wild Justice, at the moment and it seems to be in relation to challenges on any weakness or our interpretation of current environmental legislation. DR – I never saw FEBs in SW Wales, but now they are everywhere so there has been an expansion in numbers and range. Can you clarify the review is going to be a literature review of current work and for the whole of the UK? ▪ A: Final agreement of the scope of the delivery programme is very much down to the NRW FEB Advisory Group.. Both policy and evidence reviews have been undertaken in Scotland and England, we have assessed these reviews for their applicability to Wales to help us determine the indicative scope of our work in Wales AW – You refer to non-lethal methods of controlling FEBS, will this involve habitat quality and protecting habitat? ▪ A: As in any licencing of lethal controls, NRW as the competent licensing authority must be satisfied that there are no other satisfactory solution and dependent on the licence type the applicant must provide evidence that suitable, legal non-lethal methods for control have been tried. NRW has reviewed and assessed that there are no satisfactory solution when we issued our new general licences on 1 January 2019,. With regard to FEBs, individual licence applicants generally feel that birds quickly become habituated to non-lethal scaring methods and are just moved further down/up stream. PG – There is a lot of experience using habitat adjustments to protect fish, largely in still water fisheries. We will be making use of long experience in that field, so we won’t be starting from scratch. We are also looking at wild and stocked fisheries as there are also problems in non-salmonid fisheries across Wales. We have seen the activities of Wild Justice, is there any scope to engage them with this process? ▪ A: We have extended invitations to engage with Wild Justice, firstly as an opening meeting to understand their general concerns. They feel that environmental legislation has not been legally abided by. Initial response was favourable, but since then they have declined to meet with NRW. It is something we should possibly pursue to engage in positive dialogue. This approach would be sensible during our wider review. SO – there is a conservation issue around salmonid protection under the Habitat Regulations, and this seriously tests an organisation making a position on controlling FEBs.

6. Plan of Action for Salmon and Sea Trout – Paper • The PoA represents contributions from this Forum’s working group and from LFG and other stakeholders brought together on this topic. The PoA has now been signed off by the minister. NRW would like to thank all those that took time and engaged in the process to help produce the plan. • There are 9 ‘themes” represented by the all-important Action Tables – The issues covered are: – Page 7 of 11

1. Evidence – understanding the status of stocks;

2. Managing exploitation;

3. Protecting stocks through effective enforcement;

4. Tackling physical habitat constraints in the freshwater environment;

5. Safeguarding water quality and quantity;

6. Addressing land management, and associated risks to water quality;

7. Addressing predation on salmonids: fish-eating birds and seals;

8. Understanding marine Pressures;

9. Understanding new and emerging potential pressures.

COMMENTS RGW – We need to aim to return to sustainable harvest, relevant for West Wales fisheries (nets). Not just socio-economical but protected geographical indication also and value of migratory fisheries to local economies. Include final ambition of returning to harvestable population for all methods not just rod and line. SO – Need to consider not just resourcing the plan but the potential investment of the plan too. DR – avoid falling into trap of blaming climate change. There are lots of other pressures that we can target. DM – in the action tables we are not blaming climate change, but also lots of other issues: effective stock management and exploitation controls, ensuring our stocks are sustainable. There is focus on environmental pressures such as water quality, agricultural issues and habitat as well as bird predation. We will need to consider what reporting we will be doing on the plan of action, both to Welsh Government and the pivotal role the WFF will play in progressing the plan and future implementation of the actions. The plan is now publicly available, will be circulated and discussed in the forthcoming rounds of Local Fishery Groups. It will also be available through our web site. 7. Provisional Stock Assessments – Papers • These are still in draft format: we will share more widely once these have been confirmed. • The annual report to ICES on the status of salmon stocks is normally published by CEFAS at the end of May. ACTION We will circulate to the Forum along with the two summary documents for salmon and sea trout that we provide each year. • These assessments do not form part of WFD classification and focuses solely on the adult component of the stock. They were implemented following Ministerial Direction and are an integral part of our reporting to ICES and commitment to NASCO. They are based on estimates of spawner abundance against conservation limits – and this metric isn’t considered in the WFD process. These assessments are catchment-scale rather than for individual waterbodies. WFD only considers the juvenile component of the stock. COMMENTS Page 8 of 11 SMS – when you were considering bringing in the byelaws for salmon, it was more optimistic than it is now for sea trout, will you bring in more restrictions for sea trout? ▪ A: PG – this is an annual process which is extremely time consuming. We will also be looking at the decision structure. As and when we need, we identify a need for further restraint, such as that suggested, we will not hesitate to bring in stakeholders and take action that is needed. AW – Looking at catchments around the Llyn Peninsula, the assessments are more optimistic, but they only have small salmon catches which may give a more misleading picture of improvement? ▪ A: PG – This has to interpreted carefully and this is why we are also looking at a more sophisticated stock assessment tool that uses juvenile stocks. There will be a report on that work. SO – Looking at these maps is worrying and looking at the pressures we have it won’t be long that we can hang on to our salmon and sea trout stocks in Wales.

8. Angling Promotion • DM provided a brief update on the Fishing in Wales Project and played an example promotional video. • The ‘Fishing in Wales’ website is nearing completion and content is currently being uploaded. Were it not for Covid-19 it would have been launched this month; • Therefore, due to the current situation the site launch will be delayed until it is appropriate for us to promote angling again. • The initiative has been funded by Visit Wales (VW) and NRW. VW has scaled down their own promotional activity in light of COVID 19 and has advised the project to do the same. • Upon launch, the website will include information on all angling club waters, private fisheries and sea fishing locations in Wales (a total of over 1200 entries). • Some parts of the project are already up and running more information in the links below: Fishing Wales Facebook Fishing in Wales Instagram Wales Fishing Instagram Angling Trust Fishing in Wales Info (news release) COMMENTS CW – Would like to highlight an issue with NRW’s website concerning simplification of the byelaws. The information is extremely difficult to find: i.e. how close you can fish to obstructions. This information is under ‘safety near obstructions’ rather than restrictions by river. ▪ A: Due to the nature of site traffic being mainly through mobile devices, the site needs to be laid out in this way to improve accessibility. It can be improved, and we will continue to make adjustments to help improve it. SO – Images on the video and often in angling magazines can often portray images of anglers of similar demographics. What can be done to increase diversity of representation in the way we promote angling? ▪ A: DM – yes this is something we are mindful of, and there are various initiatives to take people fishing. We will ensure that the project address this. Page 9 of 11 MO –There are members who would fit the missed demographics that would be willing to be in videos or photographs. All countries are seeing a decline in rod licences, but it is improving in countries where they have done similar tourist style initiatives. PE – are there any initiatives to target youths to encourage them to take up fishing? ▪ A: DM – at the moment there are not many. Unfortunately, we only have a few projects and initiatives around angling participation. JO – Groups in SW and N Wales are addressing these issues, encouraging youth participation, although we were not involved in this project. These schemes are funded through Sport Wales and NRW There are a number of issues around introducing youths to angling to be considered, and clubs are struggling to engage with younger members. There is a lack of uptake in areas where there are more options to keep youths busy. Additionally, with the lack of fish it is difficult to hold their attention and encourage them to take up the sport. Angling coaches are being deterred by the qualifications required by Sport Wales due to costs and the expectations that come with having a qualification. However, Level 1 is important as this covers child protection. SMS – the uptake in angling is correlated with the numbers of fish. As the numbers of fish continue to fall, so will angling uptake. If the rivers aren’t in a good condition, they won’t be very appealing. JO – This is also reflecting in sea angling. We tend to take youngsters to coarse fisheries where they can much more easily catch fish which gets them more involved and keener on angling as they can catch fish. AW – EA used to put a lot of resource into angling participation which has now ended, is there likely to be a similar scheme? FiW doesn’t address the work on the ground required. ▪ A: PG – there has been some investment from Visit Wales however these initiatives are only as good as the upkeep. SL – reflecting on the stock status maps. When those maps land on WG desks, do you sense any appreciation among policy makers of the enormity of the picture they paint? We might look at them as anglers and/or conservationists but of course they’re indicative of a massive environmental issue. ▪ A: JB – WG have seen the status maps and the direction of travel. For this reason, the Minister asked NRW to bring together the Plan of Action and additional resources have recently been offered.

9. Updates from Other Fora – Papers (taken as read) • Wales Water Management Forum COMMENT: SMS – Planning needs to be considered to prevent too many chicken sheds being built as these don’t just affect air quality but also water quality. • Wales Land Management Forum – COMMENT: CH – there is an amount of evidence that will change views on agricultural pollution, and it is important that the industry changes the way that matters should be addressed. – See previous comments in Section 4 • National Access Forum for Wales – COMMENTS: SMS – access to navigation on waterways is a concern at the moment as we need to find a solution to this ongoing problem. The consideration of any future access needs Page 10 of 11 to take into consideration riparian owners views. There is an opportunity to change things but not take the attitude that there should be no activity on rivers but outline areas that are more suited to these activities. – RGW – No specific mention that biodiversity of freshwater and conservation should take priority over access. – CW – It’s not anglers trying to arrange voluntary access agreements but other members of the access forum who refuse to engage unless they are allowed 24/7 access 365 days a year. There needs to be more emphasis to protect spawning fish that are continuously disturbed by adventure activities prior to them being able to spawn. This needs to be addressed. There have been angling byelaws to protect fish, but it needs to go further to protect the fish once they return to the river. I am concerned that fish are not being fully protected especially when they are vulnerable in the small upland streams. ▪ NOTE: PG – this is featured as an action in the PoA – SMS – Access has been successfully agreed in some areas noting however, that not all parties had been involved.

10.Other Updates • Government directions in relation to Covid19 and outdoor activities has effectively closed fishing. The requirements on social distancing mean you should not be leaving your house in order to go fishing recreationally. We have received a number of reports of people fishing: these issues have been passed onto the police rather than NRW enforcement and they have dealt with some of them. See: Angling Trust Covid19 Support Hub This is a good resource of guidance and information for anglers and angling clubs. Whilst primarily aimed at English anglers it also contains information relevant to Wales: “We must all do what is required of us by the Government for the benefit of our own health and that of our communities, and we should therefore refrain from fishing and work together to fight this pandemic and save lives.” See also: https://www.anglingcymru.org.uk/ • Licence sales have been much reduced since the Covid 19 restrictions were introduced. NRW are currently discussing with EA the implications of this, as this will effect the rod licence income to NRW for fisheries work. Once measures are lifted there will be communications around buying licences and getting people out angling again. There have also been some enquires on rebates for fishing licences and as it stands nothing is in place, but this is being discussed with EA. Following discussion, the general view of members is that they would not support any approach to refund fishing licence fees, as the income from licences is vital for positive work and supporting fisheries. However, there may be a need to consider a different approach for fishing leases and angling clubs. • The NASCO Implementation Plan is currently being revised, largely in relation to aquaculture matters that are not relevant to Wales. ACTION To be circulated when finalised The annual progress report is in draft (draft was circulated with original meeting content (members are requested not to circulate further). This will be finalised soon. Page 11 of 11 ACTION: NRW will circulate final copy as soon as possible COMMENT CW – there has been a stock assessment working group set up, has there been any input from angling clubs or NGO interests? ▪ A: DM – There are no NGOs on that group. Our commitments to review the stock assessment were set out in the implementation plan and once this has been completed, we will be able to seek comments.

11.AOB • CH – Concerns regarding Incident Reporting. Since 2016 incidents have been reported however incident/reference numbers have not been received as a matter of course – they often need to be asked for. This can create a feeling of mistrust of NRW on the ground. It would help engender greater confidence in the system and NRW if the reference numbers were given out automatically without asking for them. – reassuring the callers that the incident was being logged and acted upon. – ▪ A: Agreed that reference numbers should be given as a matter of recourse when reporting incidents, but callers should request them if not offered. – ACTION: NRW – DM and PG, to raise issue with incident management team to look at protocol and to review this. • MO – There has been an Angling Pathway Plan developed to prevent the spread of INNS (Invasive non-native species), can we discuss actions from this in our next meeting? • Date of next meeting: 19th November (proposed). – Members generally gave positive feedback from the Skype meeting noting that in these unprecedented times face to face meetings are not possible. – Venue of next meeting to be determined in future and dependant upon restrictions on social distasting being relaxed CLOSING COMMENT • JO Closing comments: regarding agriculture regulations – Voluntary measures don’t work. – Will new regulations be policed? – Minister is responsible for both the environment and land use which are a conflict of interest. • CH – Commented that enforceability should not affect whether you bring in regulations or not.

Adrian Simpson (Countryside Alliance) for Rachel Evans Alan Winstone (Afonydd Cymru) Chris White (Campaign for the Protection of Welsh Fisheries; North Wales LFGs) Creighton Harvey (SW LFGs) Dylan Roberts (Game & Wildlife Conservation Trust) James Legge (Countryside Alliance) John O’Connor (Angling Cymru) for Carl Tonner Julian Bray (Welsh Government) Mark Owen (Angling Trust) Mark Tilling (Welsh Government) Nicola Teague (IFM) Paul Edwards (Welsh Salmon and Trout Angling Association) Richard Garner Williams (Salmon & Trout Conservation Cymru) Shaun Leonard (Wild Trout Trust) for Denise Ashton Stephen Marsh Smith (Afonydd Cymru) Tony Harrington (DCWW) Apologies: Ruth Jenkins (NRW) 1. Welcome, introductions and apologies for absence • Steve Ormerod (SO) opened the meeting, welcomed several new participants and deputies and gave a brief overview of how the meeting would-be run-in order that participants could get the most out of using Skype. 2. Admin Matters • Minutes from November 2019 were approved – any outstanding actions were addressed. • Approval of minutes is now to be streamlined – draft minutes are to be sent to members within two weeks of each meeting and then amended where necessary prior to approval Page 2 of 11 via email comment. If no comments are received within two weeks of despatch, the minutes will be approved to enable them to be circulated more widely and more quickly. • The forum was reminded that members are expected to discuss the issues to be raised at the meetings with others, where appropriate, so that their views may also be brought to the meetings. Members were asked to note that documents marked as ‘draft’ or ‘not for further circulation’ are not to be passed on – including minutes prior to approval. • The ToR has been amended to reflect the current membership list. Reference to the General Data Protection Regulations (GDPR) has been added to reflect issues around prevention of public sharing of members private email addresses Email addresses may be shared amongst the forum only if consent has been given, and email addresses from forum must not be shared publicly. – ACTION ALL – please consider, and then if you agree, sign and return Annex 2 form from the ToR to EK. Electronic copies and signatures are acceptable. • New membership – NRW supports representation of all LFGs (Local Fishery Groups) at the WFF. One new nominated LFG member, CH, recently joined the forum to represent LFGs in SW Wales, and existing WFF members SMS and CW agreed to represent SE and N Wales respectively.as representatives. Some LFGs have since expressed a desire for specific representation and this will be discussed at forthcoming meetings of each LFG and reported back to the WFF. – SMS – we should only be accepting representatives from groups where appropriate process is followed. – ACTION CH and PG to discuss SW LFG representation; PG to report back on any nominations from LFGs It was noted that there is currently there is no overall ToR for LFGs. • ACTION DM and PG to develop a working ToR for LFGs. It was noted that NRW CEO Clare Pillman will attend the second combined LFG meetings in SE Wales, for Taff, Usk and Wye members, on 2nd June. 3. Introduction of new member • Dylan Roberts from GWCT gave a presentation on GWCT Salmon & Trout research work – this will be circulated to members with the minutes. • Questions: – PG When carrying out the netting procedure described, the commercial netsmen would have presumably been doing their best to catch sea trout and this might overrepresent the scale of bycatch in the fishery ▪ DR – We’re looking to catch fish for genetics and were fishing in areas were fishermen could fish and were likely to catch sea trout as bycatch. We will seek to scale this work up next year off the North Cornwall and North Devon coast. Difficult to quantify bycatch. Looking to see if there needs to be tighter regulation. – PG Could you share the evidence from the North Devon report? – Shaun Leonard: Where is the information from SAMARCH available? ▪ Still in the data collection phase and this will be pulled together and put into a report. Page 3 of 11 • ACTION DR to provide information referred to above. 4. Agricultural Regulations • Bob Vaughan from NRW gave a presentation and updated the Forum on Water Regulations: – September 2016 Welsh Government reviewed NVZ; – December 2017 WG decided to go for an all Wales approach; – November 2018 WG decided that regulations would come into place in January 2020; – 8 th April 2020 Minister made a statement on the draft regulations for stakeholders. A final decision as to whether these will be introduced is yet to be made and is likely to be delayed due to Covid19. – The DRAFT regulations may be found here: Draft Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2020 – The draft regs include a requirement for WG to review them and consider any proposals for an alternative suite of measures within 18 months of regulations coming into force to help regs fit better and be more effective. – The WLMF sub group members put forward their comments on the regulations and the Regulatory Impact assessment (RIA) prepared to support the Regulations. These comments parallel the earlier report provided by the group to the Minister. This report developed 5 components, including regulatory improvements, which all the members of the sub group believe are needed to tackle agricultural pollution and nutrient management. Progress report by the Wales Land Management Forum (WLMF) sub-group on agricultural pollution – WG has been developing a replacement for the Basic Payment Scheme, the Glastir Scheme and the Economic Resilience Scheme to promote a Sustainable Land Management Scheme which would need to dovetail with the new regulations; – An all Wales approach: – ▪ places requirements on farmers to invest in storage; ▪ places restrictions on when they can spread; ▪ only focuses on nitrogen. – The RIA undertaken appears to suggest that the regulations will primarily reduce the production of greenhouse gases rather than impacts on water quality. It had been commended that all nutrient management should be covered. – There are concerns that farms will look to avoid slurry produced indoors by putting stock out over winter to reduce slurry production and this could create an unforeseen increased pollution risk which would have negative impacts on soil and water resources. • COMMENTS: MO – Transition period without regulation, how long will it be? ▪ A: It will be 18 months. The transition period will be slightly longer as it will be expensive and time consuming for farms to build new infrastructure. RG – Main comment is of some dismay. The initial announcement came from the Minister without consultation and was that regs would be brought in by Jan 2020. But Page 4 of 11 there has been more delay and an additional transition period. Will we ever see anything realistic brought in that will make a difference? ▪ A: The regulations are a step forward but there is still a lot of work to do before we see any impact on reducing pollution risk.. DR – is there capacity within the guidelines, or to develop guidelines, to prevent farmers from upscaling their production and have a greater number of animals on their fields unless they have the capacity to deal with the additional slurry storage? ▪ A: This has been discussed at WLMF sub group and within NRW and we are reviewing the existing legislation to explore how we may use the powers more effectively rather than waiting until a pollution has occurred. We are looking at a wide range of issues, including planning and regulation, so that we can put into place controls that will work. Once we can identify gaps that need to be filled, we can approach WG with a means to fix this so that we can use the regulation we have to its best effect MO – is this regulation going to be seen as a measure in river basin management plans? ▪ A: We use WFD monitoring as a way of identifying problems across Wales, homing in on those areas to work with farmers to prevent these issues and to help farmers to understand the impact of their actions. SL – Was concerned that NRW appeared to have consented the dumping of milk which is being dumped in large quantities ▪ A: The Covid19 response has had a marked impact on farming. Many farms have contracts with processing plants and those who have contracts with the hospitality market have seen demand stop overnight which is why you’ve seen news items about the possibility of milk being poured away. Many farms already have a waste permit (U10) to allow disposal of milk on site but there are controls on what and how this is safely done. This is a last resort action. WG, with support from NRW, have also been working with processing plants to find alternative markets for this milk to be used. Where you have been seeing dumping it has mostly been going into slurry tanks and where it is spread on land it must be greatly diluted. The waste hierarchy comes into play very early on before produce is disposed of. SMS – A comment: throughout the time on WLMF it is evident that it is not representative of the full picture: members are either NRW or farmers and only 2 NGO members are there. There has been a history of voluntary schemes over regulation. Teams have identified diffuse pollution problems at many farms and there isn’t a mechanism to deal effectively with slurry when they are over-capacity. We as a fisheries group depend on good water quality which isn’t being tackled appropriately. The regulations in place are not enough to control the problems that are ongoing. ▪ A: The WLMF is the only place where we are trying to pull together an approach to deal with this and to guide the sector to see that what is happening is not acceptable. Not just regulation but there are other methods being considered. Regulation needs to be firm enough to deal with those who are not following guidance and advice. There also needs to be a level of professionalism in the Page 5 of 11 sector. We need to work with the sector so that they can see the impacts of their actions rather than solving their problems for them. The forum itself was set up the same way as this forum and has brought in other members to give us another perspective. This forum has come about as the sector itself also sees that there needs to be a change. • There was strong and resolute feeling from the forum that the announcement was disappointing, both in terms of the proposed regulations and the further delays in bringing in effective regulation and the resources to ensure we see a sustained reduction in pollution incidents and diffuse pollution from agriculture. – ACTION: SO will write to the CEO and Chairman of NRW to express the angst and deep frustration that is felt in this forum so that they can bring this up with the Minister. • CH: The work that has been done is under the assumption that the pollution problem is wholly a nutrients issue. The minutes from the WLMF subgroup have been published up until September 2019. As the subsequent minutes are yet to be approved (awaiting information from WG) and placed on the website however, (he could report that) those meetings (October and November) picked up on other issues including bad practice. There is a transition period in relation to the new regulations, and there is also the review period. Will we be satisfied that those two provisions will have been enforced once the 18 months closes? ▪ A: The 18 months won’t start until the pandemic ends ACTION: SO, PG and RV to pursue the points that SMS and CH raised outside the meeting, to raise the issues to NRW Chair/CEO and to inform Welsh Government. • SO also concerned over ability to detect issues in our waterbodies but also any beneficial effects of any changes implemented. 5. Fish-eating Birds PL gave a presentation on the NRW Fish-eating Birds Advisory Group set in the context of the previous work undertaken by the Group and of the need to reconvene the Group as part of the review of NRWs approach to the shooting and trapping of wild birds in Wales • Reference was made to the Wild Trout Trust FEB Paper. • COMMENTS SMS – in this presentation there was a slowing down in bird population growth. Do you think this is down to a decrease fish populations or to recording? Do you think there may be a legal challenge from those whose income comes from fisheries if no action is taken? ▪ A: The trend data is sourced from the BTOs UK Breeding Bird Survey (BBS) and Wales Wetland Bird Survey (WeBS)The next stage will be to look at Wales only data. The UK BBS trends suggests a decrease in breeding goosanders and cormorants but the WeBS (Wales) trends show increasing wintering cormorant and goosander, though we have to be careful of wintering trends as WeBS do not sufficiently cover all inland waterways. All statutory nature conservation bodies (SNCBs), including NRW are under Page 6 of 11 close legal scrutiny from current campaign groups, such as Wild Justice, at the moment and it seems to be in relation to challenges on any weakness or our interpretation of current environmental legislation. DR – I never saw FEBs in SW Wales, but now they are everywhere so there has been an expansion in numbers and range. Can you clarify the review is going to be a literature review of current work and for the whole of the UK? ▪ A: Final agreement of the scope of the delivery programme is very much down to the NRW FEB Advisory Group.. Both policy and evidence reviews have been undertaken in Scotland and England, we have assessed these reviews for their applicability to Wales to help us determine the indicative scope of our work in Wales AW – You refer to non-lethal methods of controlling FEBS, will this involve habitat quality and protecting habitat? ▪ A: As in any licencing of lethal controls, NRW as the competent licensing authority must be satisfied that there are no other satisfactory solution and dependent on the licence type the applicant must provide evidence that suitable, legal non-lethal methods for control have been tried. NRW has reviewed and assessed that there are no satisfactory solution when we issued our new general licences on 1 January 2019,. With regard to FEBs, individual licence applicants generally feel that birds quickly become habituated to non-lethal scaring methods and are just moved further down/up stream. PG – There is a lot of experience using habitat adjustments to protect fish, largely in still water fisheries. We will be making use of long experience in that field, so we won’t be starting from scratch. We are also looking at wild and stocked fisheries as there are also problems in non-salmonid fisheries across Wales. We have seen the activities of Wild Justice, is there any scope to engage them with this process? ▪ A: We have extended invitations to engage with Wild Justice, firstly as an opening meeting to understand their general concerns. They feel that environmental legislation has not been legally abided by. Initial response was favourable, but since then they have declined to meet with NRW. It is something we should possibly pursue to engage in positive dialogue. This approach would be sensible during our wider review. SO – there is a conservation issue around salmonid protection under the Habitat Regulations, and this seriously tests an organisation making a position on controlling FEBs. 6. Plan of Action for Salmon and Sea Trout – Paper • The PoA represents contributions from this Forum’s working group and from LFG and other stakeholders brought together on this topic. The PoA has now been signed off by the minister. NRW would like to thank all those that took time and engaged in the process to help produce the plan. • There are 9 ‘themes” represented by the all-important Action Tables – The issues covered are: – Page 7 of 11 1. Evidence – understanding the status of stocks; 2. Managing exploitation; 3. Protecting stocks through effective enforcement; 4. Tackling physical habitat constraints in the freshwater environment; 5. Safeguarding water quality and quantity; 6. Addressing land management, and associated risks to water quality; 7. Addressing predation on salmonids: fish-eating birds and seals; 8. Understanding marine Pressures; 9. Understanding new and emerging potential pressures. COMMENTS RGW – We need to aim to return to sustainable harvest, relevant for West Wales fisheries (nets). Not just socio-economical but protected geographical indication also and value of migratory fisheries to local economies. Include final ambition of returning to harvestable population for all methods not just rod and line. SO – Need to consider not just resourcing the plan but the potential investment of the plan too. DR – avoid falling into trap of blaming climate change. There are lots of other pressures that we can target. DM – in the action tables we are not blaming climate change, but also lots of other issues: effective stock management and exploitation controls, ensuring our stocks are sustainable. There is focus on environmental pressures such as water quality, agricultural issues and habitat as well as bird predation. We will need to consider what reporting we will be doing on the plan of action, both to Welsh Government and the pivotal role the WFF will play in progressing the plan and future implementation of the actions. The plan is now publicly available, will be circulated and discussed in the forthcoming rounds of Local Fishery Groups. It will also be available through our web site. 7. Provisional Stock Assessments – Papers • These are still in draft format: we will share more widely once these have been confirmed. • The annual report to ICES on the status of salmon stocks is normally published by CEFAS at the end of May. ACTION We will circulate to the Forum along with the two summary documents for salmon and sea trout that we provide each year. • These assessments do not form part of WFD classification and focuses solely on the adult component of the stock. They were implemented following Ministerial Direction and are an integral part of our reporting to ICES and commitment to NASCO. They are based on estimates of spawner abundance against conservation limits – and this metric isn’t considered in the WFD process. These assessments are catchment-scale rather than for individual waterbodies. WFD only considers the juvenile component of the stock. COMMENTS Page 8 of 11 SMS – when you were considering bringing in the byelaws for salmon, it was more optimistic than it is now for sea trout, will you bring in more restrictions for sea trout? ▪ A: PG – this is an annual process which is extremely time consuming. We will also be looking at the decision structure. As and when we need, we identify a need for further restraint, such as that suggested, we will not hesitate to bring in stakeholders and take action that is needed. AW – Looking at catchments around the Llyn Peninsula, the assessments are more optimistic, but they only have small salmon catches which may give a more misleading picture of improvement? ▪ A: PG – This has to interpreted carefully and this is why we are also looking at a more sophisticated stock assessment tool that uses juvenile stocks. There will be a report on that work. SO – Looking at these maps is worrying and looking at the pressures we have it won’t be long that we can hang on to our salmon and sea trout stocks in Wales. 8. Angling Promotion • DM provided a brief update on the Fishing in Wales Project and played an example promotional video. • The ‘Fishing in Wales’ website is nearing completion and content is currently being uploaded. Were it not for Covid-19 it would have been launched this month; • Therefore, due to the current situation the site launch will be delayed until it is appropriate for us to promote angling again. • The initiative has been funded by Visit Wales (VW) and NRW. VW has scaled down their own promotional activity in light of COVID 19 and has advised the project to do the same. • Upon launch, the website will include information on all angling club waters, private fisheries and sea fishing locations in Wales (a total of over 1200 entries). • Some parts of the project are already up and running more information in the links below: Fishing Wales Facebook Fishing in Wales Instagram Wales Fishing Instagram Angling Trust Fishing in Wales Info (news release) COMMENTS CW – Would like to highlight an issue with NRW’s website concerning simplification of the byelaws. The information is extremely difficult to find: i.e. how close you can fish to obstructions. This information is under ‘safety near obstructions’ rather than restrictions by river. ▪ A: Due to the nature of site traffic being mainly through mobile devices, the site needs to be laid out in this way to improve accessibility. It can be improved, and we will continue to make adjustments to help improve it. SO – Images on the video and often in angling magazines can often portray images of anglers of similar demographics. What can be done to increase diversity of representation in the way we promote angling? ▪ A: DM – yes this is something we are mindful of, and there are various initiatives to take people fishing. We will ensure that the project address this. Page 9 of 11 MO –There are members who would fit the missed demographics that would be willing to be in videos or photographs. All countries are seeing a decline in rod licences, but it is improving in countries where they have done similar tourist style initiatives. PE – are there any initiatives to target youths to encourage them to take up fishing? ▪ A: DM – at the moment there are not many. Unfortunately, we only have a few projects and initiatives around angling participation. JO – Groups in SW and N Wales are addressing these issues, encouraging youth participation, although we were not involved in this project. These schemes are funded through Sport Wales and NRW There are a number of issues around introducing youths to angling to be considered, and clubs are struggling to engage with younger members. There is a lack of uptake in areas where there are more options to keep youths busy. Additionally, with the lack of fish it is difficult to hold their attention and encourage them to take up the sport. Angling coaches are being deterred by the qualifications required by Sport Wales due to costs and the expectations that come with having a qualification. However, Level 1 is important as this covers child protection. SMS – the uptake in angling is correlated with the numbers of fish. As the numbers of fish continue to fall, so will angling uptake. If the rivers aren’t in a good condition, they won’t be very appealing. JO – This is also reflecting in sea angling. We tend to take youngsters to coarse fisheries where they can much more easily catch fish which gets them more involved and keener on angling as they can catch fish. AW – EA used to put a lot of resource into angling participation which has now ended, is there likely to be a similar scheme? FiW doesn’t address the work on the ground required. ▪ A: PG – there has been some investment from Visit Wales however these initiatives are only as good as the upkeep. SL – reflecting on the stock status maps. When those maps land on WG desks, do you sense any appreciation among policy makers of the enormity of the picture they paint? We might look at them as anglers and/or conservationists but of course they’re indicative of a massive environmental issue. ▪ A: JB – WG have seen the status maps and the direction of travel. For this reason, the Minister asked NRW to bring together the Plan of Action and additional resources have recently been offered. 9. Updates from Other Fora – Papers (taken as read) • Wales Water Management Forum COMMENT: SMS – Planning needs to be considered to prevent too many chicken sheds being built as these don’t just affect air quality but also water quality. • Wales Land Management Forum – COMMENT: CH – there is an amount of evidence that will change views on agricultural pollution, and it is important that the industry changes the way that matters should be addressed. – See previous comments in Section 4 • National Access Forum for Wales – COMMENTS: SMS – access to navigation on waterways is a concern at the moment as we need to find a solution to this ongoing problem. The consideration of any future access needs Page 10 of 11 to take into consideration riparian owners views. There is an opportunity to change things but not take the attitude that there should be no activity on rivers but outline areas that are more suited to these activities. – RGW – No specific mention that biodiversity of freshwater and conservation should take priority over access. – CW – It’s not anglers trying to arrange voluntary access agreements but other members of the access forum who refuse to engage unless they are allowed 24/7 access 365 days a year. There needs to be more emphasis to protect spawning fish that are continuously disturbed by adventure activities prior to them being able to spawn. This needs to be addressed. There have been angling byelaws to protect fish, but it needs to go further to protect the fish once they return to the river. I am concerned that fish are not being fully protected especially when they are vulnerable in the small upland streams. ▪ NOTE: PG – this is featured as an action in the PoA – SMS – Access has been successfully agreed in some areas noting however, that not all parties had been involved. 10.Other Updates • Government directions in relation to Covid19 and outdoor activities has effectively closed fishing. The requirements on social distancing mean you should not be leaving your house in order to go fishing recreationally. We have received a number of reports of people fishing: these issues have been passed onto the police rather than NRW enforcement and they have dealt with some of them. See: Angling Trust Covid19 Support Hub This is a good resource of guidance and information for anglers and angling clubs. Whilst primarily aimed at English anglers it also contains information relevant to Wales: “We must all do what is required of us by the Government for the benefit of our own health and that of our communities, and we should therefore refrain from fishing and work together to fight this pandemic and save lives.” See also: https://www.anglingcymru.org.uk/ • Licence sales have been much reduced since the Covid 19 restrictions were introduced. NRW are currently discussing with EA the implications of this, as this will effect the rod licence income to NRW for fisheries work. Once measures are lifted there will be communications around buying licences and getting people out angling again. There have also been some enquires on rebates for fishing licences and as it stands nothing is in place, but this is being discussed with EA. Following discussion, the general view of members is that they would not support any approach to refund fishing licence fees, as the income from licences is vital for positive work and supporting fisheries. However, there may be a need to consider a different approach for fishing leases and angling clubs. • The NASCO Implementation Plan is currently being revised, largely in relation to aquaculture matters that are not relevant to Wales. ACTION To be circulated when finalised The annual progress report is in draft (draft was circulated with original meeting content (members are requested not to circulate further). This will be finalised soon. Page 11 of 11 ACTION: NRW will circulate final copy as soon as possible COMMENT CW – there has been a stock assessment working group set up, has there been any input from angling clubs or NGO interests? ▪ A: DM – There are no NGOs on that group. Our commitments to review the stock assessment were set out in the implementation plan and once this has been completed, we will be able to seek comments. 11.AOB • CH – Concerns regarding Incident Reporting. Since 2016 incidents have been reported however incident/reference numbers have not been received as a matter of course – they often need to be asked for. This can create a feeling of mistrust of NRW on the ground. It would help engender greater confidence in the system and NRW if the reference numbers were given out automatically without asking for them. – reassuring the callers that the incident was being logged and acted upon. – ▪ A: Agreed that reference numbers should be given as a matter of recourse when reporting incidents, but callers should request them if not offered. – ACTION: NRW – DM and PG, to raise issue with incident management team to look at protocol and to review this. • MO – There has been an Angling Pathway Plan developed to prevent the spread of INNS (Invasive non-native species), can we discuss actions from this in our next meeting? • Date of next meeting: 19th November (proposed). – Members generally gave positive feedback from the Skype meeting noting that in these unprecedented times face to face meetings are not possible. – Venue of next meeting to be determined in future and dependant upon restrictions on social distasting being relaxed

CLOSING COMMENT • JO Closing comments: regarding agriculture regulations – Voluntary measures don’t work. – Will new regulations be policed? – Minister is responsible for both the environment and land use which are a conflict of interest. • CH – Commented that enforceability should not affect whether you bring in regulations or not.

President Allan Cuthbert, 7 Norton Avenue, Prestatyn, Denbighshire, LL19 7NL Email: highplains@gmail.com

Strategy Officer John Eardley c/o Vanner Farm & Caravan Site. Llanelltyd, Dolgellau, Gwynedd, LL40 2HE Email: johneardley@btinternet.com

Conservation Officer; Chris White, 57 Normanby Drive, Connahs Quay’ Flintshire, CH5 4JX Email:chriswhite.cohite@gmail.com

Sir David Henshaw NRW Chairman

Via email: nrwboardsecretariat@naturalresourceswales.gov.uk

18 May 2020

Dear Sir David,

I recently received an email from Ruth Jenkins accusing me of publicly criticising an NRW Board member. There were no details in the email as to when and where this had supposedly taken place. I attend the Welsh Fisheries Forum on behalf of CPWF and as such I represent anglers from across Wales, many of whom have expressed concerns about the actions (or rather in-action) of NRW and perceived conflict of interests of NRW Board members due to their membership of the RSPB when considering controls on avian predation of salmonids. In my response to Ruth I explained that I cannot be held responsible for any comments made at meetings by CPWF supporters when I was not present.

I am not aware of any public criticism either verbally or in writing that I have made.

In her email Ruth accused me of publicly criticising an NRW Board member and asked me to withdraw this or if I wished to raise this issue with you as Chair of the NRW Board. As I have yet to receive a response from Ruth to my reply perhaps it is now time to take this to the next level. My preference is to have an open and honest discussion about the issues around avian predation rather than to go public through a press release. The issue of avian predation has been talked about for more than 10 years but all we get from NRW and its predecessor is procrastination on this issue for fear of upsetting the RSPB and latterly Wild Justice.

One thing that seems to unite anglers is concern over the impact of increasing numbers of Goosanders and Cormorants on our rivers. At the last Welsh Fisheries Forum a paper was presented from the Fish Eating Birds Advisory Group (FEB’s) on behalf of Natural Resources Wales in which graphs taken from the Wetland Bird Survey (WeBS) conducted by the British Trust for Ornithology (BTO) “suggests” breeding pairs of goosander and cormorant are in

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

Visit our website at www.cpwf.co.uk

decline whilst accepting that over wintering birds had steadily increased from the 1980’s. The implication from these graphs is that these FEB’s are not the cause of the decline in ‘fish stocks’ and particularly salmonids. To a lay person who supports the RSPB this is what they want to hear. The presentation was interesting in that there was more concern about a legal challenge from ‘Wild Justice’ than in the protection of fish stocks. Apparently there needs to be a detailed study (12 Months) almost certainly followed by a public consultation before any controls can be recommended let alone be put in place.

NRW are fond of claiming that they are ‘evidence lead’ so let us look at the evidence. In the first instance we need to look at the graphs taken from the Webs survey:

Note: We understand the 100 Index line in the graphs to be the average or mean of the years I995 – 2015. It would be more meaningful to the reader if the graph illustrated the actual population in order to present actual year population plots and trend.

You will see that the trend line in red for both species is showing a decline this gives the wrong message as it is referring to breeding pairs and not numbers of feeding birds over the winter period. The presentation made no reference to the fact that overwintering birds are on the increase. In the following I only consider the damage to fisheries from goosander over the winter period but the same applies to cormorants who are consuming the same or more salmonids.

The following graph is taken from the latest Wetland Bird Survey (WeBS) survey which uses data from the British Trust for Ornithology (BTO) Waterbirds in the UK 2018/19. Note the trend (blue line) in this graph is upwards this includes overwintering birds and is not restricted to breeding pairs. This graph may mirror the decline in migratory fish stocks from electro fishing surveys; the decline is at the moment attributed to climate change and pollution.

Note on graph scale:

This 1970 – 2015/16 Wales graph of goosander illustrates the rising longer trend of recorded goosander, from no population in pre 1970 to its present 2015/16 population expressed as the 100 Index.

“Contains Wetland Bird Survey (WeBS) data from Waterbirds in the UK 2018/19 © copyright and database right 2020.

So let us now consider the case against goosanders. According to the BTO an adult goosander needs to consume 400gm of fish per day and to raise a single chick from egg to adulthood requires 33kg of fish (goosanders typically have 10 chicks to feed) – these birds primarily eat fish to live. The graphs above do not declare numbers, they refer to an index. However it is clear in the graph for Wales that annual goosander numbers are increasing. According to the BTO the Status Summary for goosanders is as follows:

Status summary

Goosanders were first discovered to have colonised the UK in Perthshire in 1871, and spread from Scotland into northern England in the 1940s. Between the first two breeding atlases, the species expanded its range in northern England, and colonised Wales and southwest England. WBS samples became large enough for annual monitoring in 1980, and showed sustained population increase, apart from a slight dip in the late 1990s. The BTO’s two national surveys of sawbills demonstrated an average increase in population size of 3% per annum between 1987 and 1997. There has been considerable further range expansion since 1990. Reasons for the colonisation of the UK, and the subsequent range expansion and population increase, are unknown. The species’ winter trend in Britain, comprising British breeders and continental visitors, rose steeply from the late 1960s and peaked in the mid 1990s, before falling back, and now stands at early 1990s levels).

In order to determine the biomass consumed by goosanders and to keep the arithmetic simple consider 100 goosanders feeding over the winter period from November to March approximately 126 days. Assuming each goosander consumes on average 400gm of fish per day then over 126 days 100 goosanders can consume approximately 5 Tonne of fish during this period. Admittedly these birds may not feed every day but they tend to gorge feed so allowing for none feeding periods let us say these birds consume 3 Tonne of fish. On rivers which do not have coarse fish present they will only be eating salmonids (and maybe minnows, sticklebacks, loach and bullhead if present).

A typical smolt ready for migration is approx 100gm but during the winter period most fish eaten will be parr or fry with a likely average weight of 30gm which would indicate that the number of fish eaten is circa 100,000 over this period. We will refer to these as smolt equivalents. Over

the winter period goosanders can be found feeding on upland spawning streams i.e. feeding on smolt equivalents and once the food source is depleted in one stream they simply fly to the next. No doubt it will be claimed there is no evidence to demonstrate harm from goosanders to ‘fish stocks’. I use the term fish stocks as goosanders will also feed on rivers containing coarse fish (and on marine fish in estuaries) and by including these in the biomass consumed it is easy to show there is little damage to overall fish stocks. This is not the case on rivers which do not contain coarse fish.

The focus of NRW and other agencies in the UK has been on avian predation during smolt migration on the basis that a smolt lost on its migration to the sea cannot be replaced whereas a parr lost in a spawning stream can be replaced! The migrating smolt studies tend to indicate significant smolt losses on upper reaches of rivers but whether this is due to avian or other predation is not clear. The theory that we only need to consider losses to migrating smolts is that it is larger parr which smolt (they need to attain approx 100gm in weight) and these larger parr take up the best feeding stations. If these larger parr are eaten then their place will be taken by a smaller parr who will grow large enough to smolt once they have taken up the recently vacated feeding station and so there is no problem. I am not sure if this is a logical statement but it seems to be the one that ‘scientific opinion supports’ and therefore only investigation into predation during smolt migration is considered vital. However studying migrating smolts, important as this is, is an after the event study as recruitment of juveniles has already been decimated over the winter months.

The problem we face is the conflict between two protected species, on the one hand goosanders which are not endangered, not native (but who have naturalised in the UK) and which have no known predators in the UK and salmon and sea trout which are regarded as being ‘at risk’. In fear of reactions from the RSPB and Wild Justice birds are therefore treated as sacrosanct by UK agencies. Unless and until the biomass consumed by FEB’s is recognised as damaging there is little prospect of a recovery in our stocks of salmon and sea trout. Many angling clubs have counts of FEB’s on their rivers and from this it is possible to estimate the biomass loss to these birds but it seems we are not to be trusted to provide unbiased data for fear of a legal challenge from those who have no concern for our fisheries or the damage FEB’s are inflicting on migratory fish stocks. Both I and supporters of CPWF believe that the criticism of NRW is entirely justified and I would welcome the opportunity to discuss both this and other fisheries concerns with you in a face to face meeting.

Regards

Chris White

Conservation Officer: Campaign for the Protection of Welsh Fisheries (CPWF)

quote in “Fishing Wit” by Richard Benson:
“Never doubt the environmental knowledge of a consistently successful fisherman. Always doubt the motives of a consistently argumentative environmental bureaucrat”

I raised the FEB issue at the Skype joint LFAG meeting yesterday pointing out the frustration about the delay in addressing FEB predation.  Dave Mee took part in this meeting and he explained the NRW/WG position which is basically they are scared of a legal challenge from ‘Wild Justice’ (Packham et al) so they need to have clear evidence of harm before they introduce any controls – hence the delay until 2022 at the earliest.  In response to a question about who and how the FEB study will be carried out and why anglers cannot carry this out DM said that if the estimated cost of the study is over £5K this would have to be tendered (they will fudge this to keep below the need to tender i.e. split into phases and areas) and there would need to be creditable evidence that those who tender are qualified for the work (the impression was that anglers are not qualified).  I suspect that this work will be carried out by a university (Cardiff/Swansea/Bangor maybe through contracts placed by rivers trusts).  I questioned why the Scottish study was not being considered and from what DM said apparently the Scottish study did not conclude that FEB’s had any impact on fish stocks – note the term ‘fish stocks’ I have seen this used to justify paddling over spawning grounds in the past (Brighton and EA reports on the effect of canoeing on ‘fish stocks’) as the term ‘fish stocks’ covers all species and not just salmonids.  Many of the larger Scottish rivers have large coarse fish stocks (roach/grayling) so you need to know which rivers were used in the studies.  I pointed out that much of the damage by FEB’s is on upland spawning streams and that the investigations to date seems to have been focused on main river counts (DM mentioned the Usk and Wye, both have coarse fish stocks).  The majority of our North Wales rivers do not have coarse fish (other than minnows and loach) so FEB predation has a disproportionate effect on salmonids, there is not a one size fits all solution and studies need to be on a river by river basis (we have said this before re byelaws and have been ignored).  Any study must include upland spawning streams over at least a 3 month period i.e. through the winter when flocks of FEB’s search out an easy feed.  I pointed out that these birds are mobile and may visit more than one site in a day and if disturbed they simply move to another site, most of which are remote and not easily accessible (remote wildlife cameras are better than people in these remote locations).   

The BTO survey is focused on ‘Wetland’ i.e. coastal areas and does not reflect what is happening on inland waterways, they may include some of the major river stems but they do not extend to counts on upland spawning streams I would suggest that this is where the study should be focused.  I will write to NRW and see if I can get some accurate numbers for overwintering goosanders as it is these birds which, in my opinion are causing most damage.  The BTO on its website states that adult goosanders will eat 400gm of fish per day so a flock of just 10 FEBs descending on a river or spawning stream can eat 4Kg of fish in a day – that’s a lot of parr!  The problem is it has been suggested that any parr that are left will take the place of those eaten and it is only predation of smolts which is an issue!  I will bang the drum but doubt that NRW will take any notice!

Chris White

All,

I hope you are all safe and well and not to depressed due to the lack of fishing opportunities. 

The fourth Fisheries Forum meeting was held via a Skype conference call on Thursday 9 April this is not a very friendly way to hold a meeting.  There were 22 people signed into the conference call but those who signed in as guests on audio only to a business conference were anonymous so apart from key players I don’t know who else was listening. 

I have attached my meeting notes it has taken me a few days to calm down before I finalised my notes.  The problem is there is an inner clique which have their own agendas and don’t like outsiders who challenge them.  I took exception in the way my very real concerns were dismissed as irrelevant and I have been reflecting on my future involvement in the Forum.  You will see that LFG’s will be asked to nominate representatives for future forum meetings, if you read between the lines of my notes you will see there may be some manipulation to get like minded people to join the present clique.  I have attached the draft agricultural legislation re water quality and the explanatory note which accompany them, it is worth noting that these are still in draft form and may be amended.

Feel free to circulate to your members.

Stay safe.

Chris White

North West Angling Trust Fisheries Consultative Council

part of the Angling Trust and AT North West Freshwater Forum

6^th March 2020

Heidi Stone, EA Salmon Programme Manager Peter Gough, NRW Principal Fisheries Adviser Cc

Sharon Kennedy, Environment Manager Cumbria

David Hudson, EA Environment Manager, Gloucestershire & Warwickshire Dr Alan Walker, Cefas Senior Scientific Offiicer

Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPW

Dear Heidi & Peter,

Summary of current status of NWATFCC, PAAS & CPWF actions/requests to EA & NRW awaiting resolution concerning river & national stock assessments

Highlighted are the responses sought and actions acknowledged on individual matters.

1. Solway & NW River Byelaws & assessments – NWATFCC referral and request to EA following meeting with Defra Minister (4^th February 2019) for incorrect rod exploitation rates used in 2018 and historic assessments to be reviewed, revised and individual River annual compliance to Conservation Limit recalculated. Necessity for an early review of the 2018 Solway byelaws. Following the EA Complaints process and EA Independent Internal Report (received by NWATFCC on 10^th January 2020) the EA handling and decision process was upheld by the independent EA Deputy Director.

NWATFCC & individual Clubs on four NW Rivers have referred this for further Legal advice and action.

• River Severn 2019 Emergency Byelaws – NWATFCC acting for Prince Albert Angling Society produced a detailed report on the 2019 Emergency byelaw Decision Paper, highlighting incorrect 2015 -18 under reported rod estimates used, resulting in underestimation of stock in decision justification. Recommendations made for recalculation of the individual year assessments, trend status and a full 2020 consultation with revised conservation case and applied measures. PAAS letter & NWATFCC Report forwarded to EA on 5^th December 2020. Several communications received concerning the intended EA response to this and expected timescales, but as yet no final response. Some urgency as 2020 Consultation timescales may not be met ?
• Cross Border Welsh Dee & Wye Byelaws.- NWATFCC, PAAS & CPWF request and recommendation in letters 28^th January & 8^th February2020 to the Welsh Cabinet minister Lesley Griffiths, that the Byelaws are not approved and deferred subject to the outcome and findings of the National review on rod exploitation rates & wider NASCO 2019 -24 IP three year review on Improvements to national stock reporting & assessments. The reviews to be undertaken by EA, NRW & Cefas. The Minister declined this request and approved the byelaws the following day, 29^thJanuary 2020. This decision process referred by rod fisheries for legal advice.

• River salmon stock estimates Re Cross Border & National Byelaw measures implementation – Review of Welsh Dee Index River methodology estimates – Request by NWATFCC, PAAS & CPWF as part of analysis undertaken by Prof Brian Revell & M. Ashwin, for rod fisheries engagement concerning the current Welsh Dee – Angler log book scheme methodology providing estimates of whole run Dee spawning estimates and rod exploitation rate estimates for other referenced Welsh rivers. NWATFCC letters to NRW, 8^th December 2019 & 23^rd January 2020. NRW response and letter 6^th January received from Peter Gough, NRW. Confirmation from Peter Gough, NRW that a further and final response to NWATFCC letter of the 23^rd January is being prepared.
• National Review – rod exploitation rates – extensive dialogue by NWATFCC with EA and in recommendations from NWATFCC & CPWF through the Angling Trust in 2018 to Defra & Welsh Cabinet ministers for this Review. Formal notification from NWATFCC (13^th July 2019 to EA) and CPWF (8^th Dec 2019 to NRW) that rod fisheries organisations cannot agree or accept the provisional 2018 published River assessments and await confirmation of the 2019 rod exploitation review findings and necessary corrections being applied.

After initial confirmation and clarification by the EA to M. Ashwin that rod fisheries would be included in this Review process there has been no further invitation or announcement on the Review. NWATFCC , CPWF & Salmon Advisory Group have made a number of requests concerning this, the most recent to Heidi Stone EA & Peter Gough NRW on the 9^th February 2020. We await this response.

• National Review – NASCO 2019 – 24 IP submissions to drafting of Improvements to stock reporting, assessments and final review process. NWATFCC, CPWF submitted detailed NASCO IP draft recommendations to rod fisheries Representatives to the England Fisheries Group on 23^rd December 2018, and subsequently provided further papers supporting this including reporting accuracy of historic trend forecasting and comparative analysis of alternate and current models and methodology.

The vision of a harmonised UK mainland conservation strategy and shared cross border reporting process is an integral step in this process. Additional academic analysis of factors affecting Salmon run estimates and NWATFCC recommendations to develop a fisheries reporting website accessible platform are key elements to these recommendations. .

Again, we have not been informed of the proposed timetable and NWATFCC & CPWF await a response from the EA & NRW, as part of the joint letter of the 9^th February 2020.

A response to items 2, 4, 5 & 6 are requested by rod fisheries representatives, bearing in mind intended timetables for developing and presenting these.

With kind regards, Mike Ashwin

Chairman of NWATFCC,

The Barn, Skirwith, Penrith, Cumbria CA10 1RH

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

On Wednesday at the suggestion of the Minister along with John Eardley we met Julian Bray as Head of Inland Fisheries for WG together with Luke Davies who works for Julian, the meeting was held in the Llandudno WG offices between 10:00 and 12:00. 

I had previously worked with Julian when he was EA(W) Fisheries Manger for North Wales he also took over the running of hatcheries from memory around 2012 and John and I worked with him on our stocking programs on the Mawddach and Conwy.  Julian left EA(W) to take up the role of Marine Fisheries Manager for WG prior to the formation of NRW – he sensibly stayed with WG.  Julian was appointed to Inland Fisheries for WG in July 2019 following the retirement (?) of Jeremy Frost in April 2019 and therefore had no involvement in the 2017 Fisheries byelaws.  In his new role he is playing catch-up and as such is ‘keeping his counsel’ on what went on before he took on the Inland Fisheries role. 

I have attached the agenda items we covered at the meeting, Luke took the minutes and as soon as I get these I will forward them to you.  I had printed several documents for the meeting including the two letters that Gary Davies (Merthyr AA) had sent to LG and HB, Julian read these and I passed them to Luke who said he had already received a copy.  I had believed for some time that LG had not read any of our letters and they simply get passed to the back office staff (Luke?) to draft a response which is then top and tailed by the Minister, probably without understanding the contents of the original letter or her response, hence the refusal to meet with us.  Perhaps we have been a bit naïve in believing that LG had read the letters and was taking a personal interest, I have always had my doubts, more so as Julian said that we must take up our issues with NRW.  Perhaps someone should ask their local AM to raise a question about this in the SENNED. 

The following are the responses to the agenda items:

1. Evidence that the byelaws will reverse the decline in migratory fish  – Reduction in angling days/rod effort skewing results.

We discussed the lack of evidence that the byelaws (with or without legislation on agricultural pollution) would not reverse the decline in migratory fish.  The stock answer was the decline is due to marine conditions and climate change.  We demonstrated from the data that Mike Ashwin has produced that the reduction in angling effort has marked effect on the numbers of fish caught and the calculation of the conservation limits, we were told to take this up with NRW.

1. Failure of WG to implement promised legislation on agricultural pollution – promises made by NRW under oath at the inquiry

Julian claims that the legislation has just been ‘postponed’ and that it will be implemented at some point in the future.

1. Lax concern for the aquatic environment in planning applications for chicken farms e.g. Fron Bella farm

We discussed at some length the potential for the chicken farm on the headwaters of the upper Conwy to have a serious impact on water quality.  It was one of Julian’s projects to establish this upper spawning area once the Conwy falls fish pass was constructed in 1993.  I identified the fact that there was no concern for the aquatic environment during the planning approval process and that it was claimed by NRW that no EU species would be affected.  I was directed to take this up with NRW and I am in the process of doing this.  Julian asked if his work on habitat improvements had been successful and I have sent him the fish counts and our Trust 2014 report (see attached) to demonstrate what is now at risk should there be a pollution event from this chicken farm which is sited at 300 M at the top of the catchment (80 M above the Afon Nug a major tributary for the upper Conwy).  Despite the evidence of the increasing numbers of salmon and sea trout ascending the Conwy Falls the Conwy is classified as probably at risk, this is mainly due to the sites NRW electro fish which were damaged by recent floods (one site on the upper Conwy is now to deep to electro fish) it was just convenient to use the 2015 results to support the low fry and parr counts despite this being due to flood events.

1. Inappropriate approval of hydro schemes 

At the last Fisheries Forum held in Carmarthen we had a presentation on HEP schemes (see attached, the slides on ‘spate clipping’ shows what happens on many HEP schemes) by Gideon Carpenter explaining the NRW guidance for licensing hydropower schemes and the technical background to the approach (the slides were used to support the talk by Gideon).  Julian referred to this presentation to demonstrate NRW is doing a good job!  I pointed out that existing schemes only need to ensure upstream passage of returning adults – the issue is about the downstream migration of smolts, the latest designs in the presentation should enable easier downstream migration but there are no plans for retro fitting existing schemes many of which simply used pre-existing weirs.  I will pursue this via the Fisheries Forum.

1. Disturbance of spawning grounds by adventure activity.  Byelaws required to protect these areas, this is within the power of NRW

This something that I had worked on with Julian in 2012 who had produced the ‘know your rivers’ diagrams at the ‘put-ins’ used by paddlers on the Conwy – they ignored them!  I showed Julian the sign that had recently been put up by Gwynedd CC on the Afon y Bala which runs into Llyn Padarn.  We discussed the powers of NRW to introduce byelaws to restrict ‘boating’ under the Water Resources Act 1991 (Schedule 25 if you want to look it up).  Julian suggested that whilst byelaws are possible it may be more sensible to just have warning signs erected at spawning sites rather than introduce byelaws and all that this involves i.e. consultation and who the respondents will be which may not result in byelaws being passed.  Far better to get National Park or Local Authorities to put up warning signs this also gets around the planning permissions which are required for these signs.

1. Lack of action on control of avian predation

Julian pointed out that there is already a committee looking at this the problem  The problem is there is no action yet but Julian put a lot of faith in Steve Ormerod taking positive action.  I will take this up at the Fisheries Forum.

1. Failure of NRW to publish in full the 2020 byelaws

I pointed out that all that NRW has published are 2017 amendments to the 1995 Fisheries Byelaws.  The impression given on the NRW website is these are all anglers need to know and this is not the case.  The 1995 Byelaws are river specific and list fishing restrictions near obstructions on each river.  The impression at the moment is that the 1995 Byelaws have been revoked – this is not the case you need to refer to the confirmation by the Minister to see the sections which have been revoked.  I have already taken this up with NRW and will continue to pursue this.  I have attached the compendium of the byelaws which was produced in 2003 this was superseded in 2014 with the glossy brochure ‘A guide to anglers fishing in Wales’ both have now been removed from the NRW website.  NRW should publish the byelaws in their entirety for clarity of what and where we can fish the NRW excuse at the moment is that anything on the website must be ‘accessible’ to all.

1. Lack of resource and funding within NRW to fulfil their statutory fisheries duties.

Julian said that NRW are now ‘outsourcing’ the river restoration work to Rivers Trusts via Afonydd Cymru due to their lack of in-house resource.  This has the support of WG.

1. Reliance on self regulation as NRW do not have sufficient resource to enforce the byelaws

Julian was not aware of the reduction in enforcement staff.  We raised the level of poaching which is doing far more damage than anglers to the broodstock in Welsh rivers.  I was advised of one local poacher who declared he had taken 11 salmon from the Lledr he is just one of many poachers who operate with impunity on our North Wales rivers.  The intelligence lead approach (after the event!) does nothing to protect our fish stocks.  In terms of self regulation we pointed out that the majority were already returning all their fish but those who take fish will continue to do so as who is to stop them.

John raised the issue of the Dyfi Beaver Project explaining those who had attended meetings felt that this was being presented by the Welsh Beaver Project Officer (Alicia Leow-Dyke) as a fait accompli with no evidence of risk assessment or due regard to the interests of landowners or those with a vested interest in the river. It seems that the ‘re-wilding’ of Wales is a higher priority than reversing the decline in migratory fish stocks Luke said that this would not be the case.

To end on a positive note Julian asked if we had any comments on the Salmon and Sea Trout Plan Of Action, my only comment was we have seen promises of action over the past 20 years with nothing coming from them.  I suggested that what gets measured gets done and WG should appoint individual project mangers to oversee the work with clear deliverables and definitive time scales.  This seemed to fit what Julian thinks should be done, it remains to be seen how the Minister responds.

Chris

Foot note: I was at a Dee mitigation working group meeting yesterday.  A comment from one of the NRW fisheries officers claimed that there was no shortage of fish on the areas which have been ‘restored’ over the past few years the problem is these sites are not yet included in the annual assessment of fish stocks, I suspect the same may apply to other rivers which have undergone restoration.  This puts yet another question mark over the calculation of the conservation limits on rivers.  We may be catching fewer fish due to a reduction in fishing effort/river conditions and not a lack of fish!