Campaign For The Protection Of Welsh Fisheries

Dear Minister,

Re: January NRW Board meeting 18 January 2018 – Fisheries presentation

At the Board meeting on Thursday 18 January the Chair of the NRW Board approved the proposed changes to fishing regulations in Wales.  For the sake of clarity what is proposed is a National, Wales only, salmon and sea trout regulation.  At present each individual river system has bylaws to reflect the differing characteristics of the rivers they refer to e.g. differing start dates to the fishing season and different method restrictions, including sanctuary areas where fishing is not permitted. These bylaws are fair and proportionate as they reflect the conditions on each river.  The NRW proposals are neither fair nor proportionate.

Whilst it is accepted that some rivers are in serious decline, rather than deal on a river by river basis, working with stakeholders, NRW has chosen to take the easy (cost effective?) route of applying blanket restrictions which will do little or nothing to reverse the decline but will have a significant impact on the rural economy.  The socio economic effect of these proposals, and the effect that this will have on the health and well being of the community, particularly in North Wales where many angling clubs are community based should not be underestimated.  These clubs provide cost effective recreation to both locals and visitors alike.  Legislation as proposed will see membership of these local clubs reduce as method restrictions will mean many rivers become substantially unfishable; this will result in their closure due to lack of funds.

Most angling clubs in Wales impose strict conditions on their members and most well run clubs have more control over member’s actions than any statutory regulations and in many cases club rules are far more stringent than the bylaws.

In North Wales anglers and riparian owners contributed significantly to the buyout of nets on the rivers Clwyd and Dee, as nets killed more salmon than anglers, there should have been a reversal of the decline in salmon numbers.  There has been no improvement in angler catches and salmon stocks have declined further despite the removal of nets. The NRW admit that anglers are not the problem and also admit that the draconian measures proposed   will not reverse this decline.  After over 18 years of compulsory catch and release for spring salmon there has been no significant improvement in spring fish stocks.

It was noted that in terms of agricultural pollution, which has a significant impact on the recruitment of salmon and sea trout, that on 13 December 2017 as Cabinet Secretary you were quoted in the press as saying that you want “the right balance of regulation, voluntary measures and investment to tackle pollution from farming” and although backing an “all-Wales approach” you will look at giving farmers flexibility to “achieve the same or better outcomes” than with regulation, this same flexibility should apply to angling which is already well regulated.

At the NRW Board meeting on the 18 January several Board members suggested that there should be a deferment on the proposal as it was clear from the responses to the consultation that NRW had failed to engage with its major stakeholders i.e. there had been no consultation with stakeholders on effective voluntary controls.  The issue of enforcement was also discussed as the reduction in enforcement officers, who now multitask, means that there will be ineffective enforcement of the proposed regulations.  We are told that any transgression reported to NRW will be treated as a priority, as happens now with poaching incidents, this just means sticking a pin in a map (the intelligence lead approach).  When we do report poaching incidents we get no response; poachers probably take more salmon from our rivers than licensed anglers, knowing that they will never be caught.  Any new regulations will rely upon the honesty of anglers to abide by them.  NRW has dismissed an opportunity to work with and educate those clubs who are perceived to be taking too many fish.

It was the Chair of the meeting (Diane McCrea) who made the final decision as she deferred to the NRW Executive team who claimed that they could not afford any more salmon to be taken from our rivers and the Executive, not surprisingly, supported their fisheries staff.  One executive member, Tim Jones, had previously made a statement, prior to the consultation on hatchery closures, at a joint Local Fisheries Advisory Group meeting telling those present that, unlike the Government, NRW were not bound by any responses to the consultation they receive.  It was clear from the 549 responses received in respect of the proposed fisheries regulations that the majority were opposed to the measures.  The members of the NRW Board recognised this but their suggestion for a deferral to seek voluntary measures working with the major stakeholders was discounted in favour of the executive team who not surprisingly supported the proposals.

You may well be told that there is some urgency in passing the proposed legislation due to the perilous state of salmon stocks at a time where there is a natural recovery on some rivers.  It may be mentioned that in Northern Ireland they instituted changes to their fisheries regulations in a matter of four days.  However, in Northern Ireland they have not issued a blanket regulation, they have assessed their rivers and chosen the most appropriate action for each river; in some case this is to close the rivers to fishing for a twelve month period.  In Scotland compulsory catch and release extends to 30 June and they assess fish stocks annually carrying out categorisation of their rivers and amend the regulations as fishing conditions change, allowing fish to be taken on Category 1 rivers.

Principally due to diffuse pollution and avian predation, it is estimated that at least 40% of the smolts fail to reach the sea and up to 50% of the eggs fail to hatch (and more in some years) due to water conditions (warm winters/floods/diffuse pollution).

By 1999 most of our salmon fisheries had seen a dramatic decline in the numbers of multi sea winter (MSW) salmon returning to our rivers. The impact of the Irish Sea driftnets on the numbers of salmon destined for Welsh rivers has not been taken into consideration.  Since the closure of the Irish driftnet fishery we are now seeing more MSW salmon arriving back in our rivers as they are not being netted at sea, this may well lead to a rapid recovery in many rivers as being larger than grilse MWS salmon lay more eggs.

The NRW approach is to implement a pan-Wales regulation for a 10 year period irrespective of the river conditions with a review after a 5 year period i.e. a do nothing and wait and see approach.  This appears to be more to do with cost cutting than reversing the decline in fish stocks.  Nothing in the NRW proposals will improve the decline in fish stocks; it is the survival from egg to smolt which has the greatest effect on salmon numbers; getting more smolts to sea is the answer but the NRW proposals will not achieve this (we can do little about marine survival).

The loss of grilse (salmon spending one winter at sea) is primarily due to climatic changes in the North Atlantic (the North Atlantic Oscillation); there is historical data from Scottish netting stations dating from 1572 which demonstrates the cyclic nature of salmon abundance, with frequent decline in the numbers of grilse recorded.

In summary:

• There is no evidence that compulsory catch and release (C&R) is effective in improving recruitment of salmon.  This was raised at the 2015 NRW Board meeting when it was explained that in 1998 a National Salmon Fisheries Regulation was introduced which required all salmon to be returned until 16 June in order to protect spring fish stocks, After 18 years this regulation has seen little or no improvement in salmon stocks so why do NRW consider that extending this will have any effect?
• Several Scottish rivers adopted a voluntary C&R policy more than 20 years ago with a 98% compliance rate and yet salmon stocks still declined.
• Between 2013 and 2016 there were circa 3000 pollution incidents in Welsh rivers, but only 1% of incidents were prosecuted.  Pollution incidents have a far greater effect on recruitment of salmon than angling.
• The data complied by NRW is based upon angler catch returns which are notoriously inaccurate as there is sadly a culture of not reporting what is caught due to the fear of the costs of fishing increasing if actual numbers are declared.
• Had NRW engaged with its major stakeholders to implement voluntary measures it could have saved a lot of time and money.
• Over the past 5 years the weather patterns have had a significant effect on both angler catches (due to varying flows) and recruitment (due to flood events).  The poor fry and parr results in 2016 are being used to justify the proposals even though NRW acknowledges the effect of the weather on recruitment over the past 5 years. With good rainfall during the 2017 fishing season catches on some rivers were significantly improved as were parr counts.
• One of the major contributors to smolts failing to reach the sea is due to avian predation (goosanders and cormorants), it is estimated that this accounts for 40% of the migrating smolts during low flow conditions.  Avian predation occurs throughout the year with goosanders eating eggs/fry/parr as well as migrating smolts.  Goosanders are not a native bird they arrived in Scotland in the 1950’s, there were just 10 breeding pairs in Wales by 1977 and they have since spread throughout the UK, damaging fisheries as they have multiplied with over 1,000 pairs distributed throughout Wales.  Increased control of avian predation would have a far greater impact than anything in the NRW proposals and yet the NRW have publicly stated that they have no plans to increase licensed culls and recommend scaring predators away from a fishery, this is almost risible as the fish eating birds will just fly to the next fishery and continue to eat fish.

The vast majority of salmon fishers now voluntarily return their fish, some clubs achieving 98% in 2107, there are a few who will still take too many fish but these are in a minority and are normally dealt with by their angling clubs, most of whom impose strict catch quotas.

If legislation, as proposed, is introduced it will be almost impossible for NRW to enforce, there is neither the enforcement staff nor the budget to ensure the regulations are followed i.e. there is a reliance on anglers doing the right thing.  It is far better to work with angling organisations and rely on voluntary method restrictions managed by local angling clubs.  If this legislation is progressed it will effectively risk the closure of some fishing clubs in Wales and signal the end of game fishing on some North Wales rivers.

Anglers are not the root cause of the decline in fish stocks and yet they are being targeted as if they were.

Regards

Chris White

Conservation Officer: Campaign For The Protection Of Welsh Fisheries