CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

29^th July 2018

Additional information in support of the petition “Save Salmon & Sea Trout & Fishing Clubs in Wales” started by Reuben Woodford

Dear Janet,

Having watched the footage from the Senedd TV on 3^rd July, when the 2 petitions opposing NRW’s proposed introduction of new Catch Controls for salmon and sea trout were discussed by the Petitions Committee, I wish to express my gratitude for the support that you and your fellow committee members showed for the angling community in Wales. I have been involved in challenging NRW’s proposals for more than 3 years and have worked closely with Chris White and Reuben Woodford in order to represent our fellow anglers. For the first time we feel that someone is not only listening to, but also making a genuine effort to understand, our concerns so once again thank you.

The following points may be helpful in highlighting some of our concerns.

A fair hearing for stakeholders?

• We first became aware of the proposals at the NRW Board Meeting in July 2015. Having contacted the then chairman, Peter Matthews, in advance of the meeting, we were grateful that he took the decision to move the agenda item until after the coffee break so that we had the opportunity to speak to board members prior to the issue being discussed. Without that we would have had no opportunity to raise our initial concerns. In closing the discussion the chairman stated that he “hoped that their aims could be achieved without resorting to statutory legislation”. Unfortunately for our fisheries, the NRW Fisheries Team chose to ignore that request.

• NRW held meetings with angling groups in November 2015 and October 2017 and circulated a questionnaire in December 2015. The final consultation ended in November 2017 with 83% of respondents opposing the proposals. Despite NRW’s Principal and Senior Fisheries Advisors admitting that we know our own rivers better than they do, they have repeatedly dismissed our concerns and at no stage do we ever feel that we have been listened to. Instead, the NRW Fisheries Team has relentlessly pursued its “Preferred Option” of statutory legislation.

• We asked to be able to briefly raise our concerns to Board Members in advance of discussion at the January 2018 Board Meeting but that request was denied. Those Board Members who we were able to address informally during the short lunch break spoke up on our behalf. We were also extremely concerned that the Chair, Diane McCrea, decided that there would be no vote on the proposals and she alone would make the decision.

• At the end of the Board Meeting there was much talk of how “we have failed to engage with stakeholders” and must take immediate steps to put this right. Six months later we are still waiting.

• All of our correspondence with both the Cabinet Secretary for Energy, Planning & Rural Affairs and the Minister for Environment has been acknowledged but we have repeatedly been denied the opportunity of a meeting to explain our concerns. Siân Gwenllian AM was also denied a meeting with the Cabinet Secretary to raise stakeholders concerns following a public meeting of angling groups.

• The NRW Senior Fisheries Advisor has stated that all of our correspondence to the Cabinet Secretary is diverted to Jeremy Frost at Inland Fisheries Strategy who responds on her behalf. We have serious concerns in this respect given that Jeremy was involved with NRW and CEFAS in the construction of the Technical Case for the new byelaws. We are not confident of an unbiased response.

Fundamental errors

• An email between CEFAS & NRW in July 2015 contains the following quote: “NRW note that the current levels of exploitation are not the primary cause of the current low abundance and that the proposed measures will thus result in relatively modest increases in spawner numbers….”  In other words the proposed measures will not deliver the results that NRW claim, particularly when anglers already release upwards of 80% of their fish anyway.

NRW has also failed to realise that it is the people who have driven the conservation agenda within their own clubs and organisations who are so opposed to these proposals because they realise that the potential gains will be far outweighed by the losses incurred by driving anglers away from the riverbank.

• The statement that “NRW has a responsibility – on behalf of the people and environment of Wales, including our angling community, to act as custodians for our rivers and fish. By acting now we are taking the first steps in ensuring their survival for our children and beyond” does not stand close scrutiny. If NRW, and their predecessors, had worked in partnership with stakeholders and acted to protect fish stocks in the past, the current situation might have been avoided. Instead, angling organisations have worked independently to introduce, and police, their own conservation measures

Furthermore emasculating angling clubs will mean that the skills and enjoyment of angling will not be passed on to our “children and beyond”.

• “Probably at Risk” rivers in England will not be subjected to mandatory measures. The same response in Wales would remove 12 rivers from the current proposals.

Furthermore, unlike Scotland and Ireland, which annually assess the health of individual rivers, reflecting fluctuating stocks in a reasonably accurate and fair process, NRW is proposing a blanket ban on all rivers for ten years. This extinguishes all hope amongst anglers and drives people away from the sport. NRW says it has “looked at similar actions taken elsewhere” but fails to explain why the Scottish or Irish model is unsuitable in Wales.

• We have proposed a voluntary solution which potentially delivers better results in terms of allowing more salmon and sea trout to spawn and pays far greater attention to the need to establish a sustainable and resilient framework that supports the SMNR policy. By empowering anglers, our solution delivers much better outcomes for the Well-being of Future Generations Act and offers a means of delivering progressive, positive actions in partnership, something the new Chair of NRW has stated must happen to achieve future outcomes.

• NRW’s technical case structure sates that “We believe that any decline in uptake of fishing will be small and transient, and that this should be acceptable to the overall fishing community as an investment for future stock improvements.” The strategy is heavily based on the Wye, a river which is very different to other rivers in Wales as well as having in excess of £1million per annum spent on habitat improvement for the last 12 years

NRW’s actions are already having a significant impact in 2018 on both our fisheries and the angling tourism which they support. A number of clubs have seen a drop in membership of 20% -25%, whilst others that previously had waiting lists for membership now have vacancies. More significantly some clubs have seen the numbers of volunteers for Working Parties fall by up to 75%. Without these volunteers habitat improvement and maintenance work, which is vital for the future survival of our fisheries, cannot be carried out.

If new byelaws are implemented without stakeholders’ concerns being heard first hand by someone other than the NRW Fisheries team, Welsh Government will have presided over a situation that is not appropriate for a 21^st century western democracy. To that end we seek representation at any discussion that takes place between the Petitions Committee and Natural Resources Wales.

Yours sincerely

John Eardley

Strategy Officer – Campaign for the Protection of Welsh Fisheries