John,
In terms of a mandate to represent anglers in Wales CPWF are recognized by angling organizations in Wales i.e. Angling Cymru and the majority (WUF failed to respond!) of angling clubs across Wales agreed that CPWF could represent them. So as an officer of CPWF, albeit resident in England, you do have a mandate to speak on behalf of Welsh anglers. I keep CPWF supporters up to date with what we are doing via email as does Allan Cuthbert via the CPWF website.
You are correct in saying that the NRW consultations are a box ticking exercise and if you remember at the pre hatchery closure meeting at Coed y Brenin we were told that unlike a Welsh Government consultation NRW were not bound by the results. We saw this in action with the hatchery closure consultation, the bylaw consultation was of course a Welsh Government initiative (as it required new legislation) who could not ignore our objections hence the need for an inquiry (the least said about that the better!).
The problem is most of the policies adopted by NRW came from WUF who successfully introduced the C&R bylaw to the 1 June on the Wye which the following year became a national bylaw adopted by the EA with the C&R requirement being extended to 16 June to appease the netsmen. After 20 years of early season C&R, and little or no reversal of the declining salmon stocks, in 2012 WUF convinced NRW to extend C&R for the whole season on the Wye, Usk and Taff laying the foundation for NRW to extend this to all Welsh rivers despite there being no evidence that C&R works. It was the lobbying of WUF who forced through the method restrictions as on the Wye and Usk these had no detrimental effect on angling effort being premier fly fishing waters although many salmon are taken spinning in the early season.
In my recent email I referred to ‘Tinkering with the CL’ I was referring to the EA/NRW/CEFAS trying to justify their river classifications by trying to address the unknows in their methodology. I suspect that they may fall back on the Irish system which now relies heavily on input from angler co-operation and information to fill in some of the unknowns in determining the CL for each individual river system. I will see if I can find the Irish paper on my old PC and forward it to you (you may already have a copy as I think I sent it out prior to the inquiry).
Whilst demonstrating that the present methodology for determining CL is flawed it is important that we need to be seen to be addressing the root cause of the decline in migratory fish stocks which from my perspective seems to be low on the agenda by the agencies who are starved of money and resource. The belief that removing barriers to migration will, by itself, reverse the decline even with habitat restoration is misplaced, the monies spent on the Wye would seem to support this and while there is some improvement on the Wye it has been minimal.
The problem is Government is more focused on farming than in the protection of fish stocks. In Wales the Control of Pollution Act (see attached) is still in draft form despite a promise following the inquiry that this wold be in place in 2020. It seems unlikely that this legislation will be enacted this year (if at all!) despite promises that agricultural pollution would be urgently addressed. The carrying capacity of spawning streams is reduced due to agricultural pollution reducing the invertebrate populations with less food to support fry/parr, the CL is of course dependant upon the carrying capacity of the system to produce smolts.
The improved runs on the upper Conwy are due to the water quality as there is little agriculture (cereal crops requiring pesticides) other than sheep grazing but sadly the arrival of chicken farms on the headwaters could well see a reversal over the next few years.
Demonstrating the error in data is all well and good but we need to go to the table with solutions based upon local knowledge of our own river systems. We need co-operation not confrontation and we need to be seen as enablers who can help EA/NRW in protecting fish stocks, I fear that the recent floods will see most money and resource being directed to flood defence over the next few years and with the potential loss of this years spawning we may see further restrictions on fishing being introduced.
Chris