CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

8 August 2018

Re: NRW fisheries bylaw proposals

Dear Minister,

Thank you for your response on 18 July (Your Ref: LG/01334/18) to my letter dated 10 July 2018 in which you say you are unable to meet with stakeholders at this juncture in the process and that you will keep us advised via NRW.

Unfortunately NRW has declared in a press release that there will be no further debate and we are therefore being kept in the dark on progress on this important issue.  I have written to the Chief Executive of NRW requesting a meeting to try and resolve the lack of communication; however I would draw your attention to what is happening across the border in England.

The Environment Agency, following improvements in the 2017 rod catches on many rivers, together with uplift to account for angler under reported catch returns, has updated the 2017 to 2021 river status classifications into its 2019 Byelaw proposals.  As a consequence the number of “At Risk” Rivers to which mandatory measures will be applied has dropped from 10 to 4.

Together with English anglers we funded an independent review of the statistical river classification methodology used by both NRW and EA.  This independent review raised some serious concerns on the interpretation of the data from the model being used.  An email exchange between CEFAS & NRW in July 2015 stated that: “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 looking at the comparative NRW & EA 2017 angler declared catch returns that generate spawning stock estimates we are particularly concerned that the average under reported catch uplift applied to WelshRiver catches is 16.76% whilst for English Rivers the uplift was 31.5%. This mirrors concerns we have with NRW rod catch estimates used in comparison to the more realistic rod fisheries catch totals on a number of managed fisheries.

The 2017 and 2018 juvenile salmon surveys provide further evidence that the data being used by NRW is flawed as these are higher than the predicted numbers from the river classification model.  A number of North Wales rivers have shown above average numbers of salmon parr, with some rivers recording their “best ever” results.  Despite this, NRW prefers to take the easy option of imposing blanket restrictions on all rivers in Wales and dismisses a voluntary solution which will potentially deliver better outcomes for both our stocks and fisheries. If the proposals are introduced without giving a voluntary solution a chance it will be a travesty, particularly given that there are clear signs that a significant number of rivers are now showing a steady improvement.

There is no evidence that Catch & Release (C&R) is effective based on the National Salmon Regulations introduced in 1999.  It is therefore unlikely that the proposals put forward by NRW for a period of 10 years will not have any effect in increasing the numbers of salmon returning to our rivers.  You may be told that without the 1999 regulations things may have been much worse and that not to approve the proposals could be seen as negligent; the reality is that this is little more than speculation and cannot be substantiated.  The decline is due to many things but angling is not one of them. However, high on the list of poor recruitment is agricultural pollution and predation by fish eating birds.

It has not gone unnoticed that many of the responses from your office, although signed by you, were probably drafted by fisheries officers.

A recent request from Lynne Neagle AM about the proposed bylaws on behalf of one of her constituents to Clare Pillman (CEO of NRW) is yet another example of the reply not being written by the person who signed it.  The response to Lynne Neagle AM was designed to demonstrate that the complaint from the constituent was wrong.  The response uses inaccurate and emotional data i.e. claiming that the number of anglers “killing all of their salmon” is 30% and yet in a recent note from NRW to members of Local Fisheries Advisory Groups it was said that there were 24% of anglers, based upon catch returns, who killed all of their salmon, this fails to recognise that these anglers may have only caught one fish.  These figures do not match the declared 80% of salmon in Wales which had been released, on some rivers the release rate is more than 90% i.e. voluntary measures can work.

I note you prefer not to legislate on agricultural pollution but prefer a co-operative approach with farmers, an option which is being denied to anglers.

You prefer to deny anglers an opportunity to meet with you or your Environment Minister in order to put forward alternatives despite the evidence that we have presented to you that the data used by NRW is flawed.  Anglers are not the root cause of the decline in fish stocks and yet you are being told by your advisors that the only way forward is to impose further restrictions on anglers.  The greatest fear amongst anglers is that you will sign off the NRW Bylaw proposals during the summer recess and in so doing avoid any debate in the Senedd from AM’s who support the anglers in their constituents.  If this is the case we will insist on an inquiry.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries

Representing, but not limited to the following: