Another Mike Ashwin challenge to NRW and EA

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