18th October 2019
Lesley Griffiths AM – Minister for Environment, Energy and Rural Affairs
By email to Correspondence.Lesley.Griffiths@gov.wales (for the personal attention of the Minister for Environment, Energy and Rural Affairs)
Dear Minister,
Thank you for your letter Ref: LG/06996/19 dated 15th October. In our original letter dated 27th September we highlighted 3 key issues:
1. Confirmation of the The Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019 would be a clear contravention of NASCO policy.
- The confirmation of the All Wales Byelaws for introduction on 1st January 2020 for all rivers in Wales which have a mean catch of less than 20 salmon is a clear contravention of NASCO policy
- We make a formal request that the introduction of the All Wales Byelaws is deferred until such time as voluntary C&R has been promoted for 1 year as set out in the NASCO Decision Making Structure.
On the first of these issues your reply does not make any reference to the Cross-Border Rivers Rod and Line (Salmon and Sea Trout) (Wales) Byelaws 2019. Our original letter quoted the following text from NRW’s “Know Your River” document:
“The release rate in 2017 was 91%. This is an excellent result and needs to be maintained”
In fact the recently released 2018 figures show that the voluntary return rate on the Dee has risen yet again to 94%. We must therefore emphasise the point that if you were to approve NRW’s request for new Cross Border Byelaws for the Dee that would be a clear contravention of NASCO policy and would further exacerbate the alienation of angling stakeholders.
On the second issue your letter makes no reference to our formal request that all rivers in Wales with a mean catch of less than 20 salmon are excluded from the All Wales Byelaws. You state that you “are content these byelaws are consistent with the principles and guidance developed by the North Atlantic Salmon Conservation Organisation” yet NASCO policy is quite clear in pointing out that on these rivers “voluntary measures will be promoted”. There should be no follow up measure of considering “Mandatory C&R” or “Closure of the Fishery” and therefore this aspect of the All Wales Byelaws is not consistent with the principles and guidance developed by NASCO.
On the third issue you make it very clear that “deferment is
not an option I am willing to consider”. You support your decision with a
number of points which cannot go unchallenged:
- “salmon and sea trout stocks are declining in Wales”
As we pointed out in our original letter there is considerable variation in stocks of both salmon and sea trout across Wales. The picture is not one of universal decline.
- “I see this as a clear sign local angling clubs will continue to thrive and adapt if this ethos is passed on to new members”.
This is not true. A significant number of anglers, local and visiting alike, no longer fish when Mandatory Catch & Release is introduced and as a result clubs lose both members and revenue. As a result they can no longer afford to rent some of their waters and those who wish to continue fishing are denied access. Local angling clubs do not “thrive” in those circumstances and their future existence very much hangs in the balance. This is further exacerbated by ill-informed method restrictions which make lengthy stretches of many North Wales spate rivers effectively unfishable. Whilst we have been given legal advice that under the terms of the Water Resources Act 1991 compensation may be sought when “the owner or occupier of any fishery by notice to the [appropriate agency] claims that the fishery is injuriously affected by a byelaw”, that is of little comfort when our waters are no longer fishable.
- “NRW have been promoting voluntary catch and release measures since 2014. Although there has been a commendable improvement in the number of fish released by anglers across Wales, the target levels required to give salmon and sea trout the best chance of recovery have not been met.” Analysis of the recently released “Salmonid and Freshwater Fisheries Statistics for England and Wales, 2018”, produced jointly by NRW & EA, reveals that the voluntary release rate has risen yet again and now stands at 88% across Wales. Furthermore 100% of the salmon were voluntarily released on 8 of the 20 principal salmon rivers which are currently subject to voluntary measures. In addition a further 2 of those rivers, Dee (94%) and Conwy (91%), are fully compliant with NASCO Policy. On all of these rivers targets are being met and voluntary measures should continue.
There has been a clear failure on the part of NRW to recognise that a voluntary solution is a realistic and sustainable solution to any threat to our salmon stocks. That option has never been discussed in any meaningful way and is conspicuous by its absence in any of the board papers leading to the byelaws decision. Until that is recognised and properly addressed there can be little prospect of the collaborative solution which our rivers so richly deserve.
Yours sincerely
John Eardley – Strategy Officer, Campaign for the Protection of Welsh Fisheries
Dr Robin Parry – Chair, Gwynedd Local Fisheries Advisory Group
Mervyn Williams – Chair, Dee Local Fisheries Advisory Group
On behalf of:
Bangor on Dee Salmon Angling Association Campaign for the
Protection of Welsh Fisheries
Capenhurst Angling Club Chirk Syndicate
Clwyd Federation of Angling Clubs Corwen and District Angling Club Dee Fisheries Association Dolgellau Angling Association Dolwyddelan Angling Association Llanbrynmair Angling Association Llangollen Maelor Angling
Llyn Guides
New Dovey Fishery Association (1929) Ltd
Ogwen Valley Angling Association
Penrhyn Fishing Club
Prince Albert Angling Society
Rhagatt Estate
Rhyl & St. Asaph Angling Association
Rossett and Gresford Fly Fishers
Seiont Gwyrfai & Llyfni Fishing Society
Vale of Clwyd Angling Club
Wirral Game Fishing Club
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