From Charlie Abbot: charlie@foxxholdings.co.uk Hywel Bromley Davenport hb-davenport@hotmail.com John Eardley johneardley@btinternet.com Gavin Jones daa.secretary@btinternet.com 3rd January 2017
To: Dafydd Elis-Thomas AM
National Assembly for Wales
Cardiff Bay
Cardiff
CF99 1NA
Copies to:
Liz Saville Roberts MP
Cllr Peredur Jenkins
Cllr Linda Morgan
Cllr Dyfrig L. Siencyn
Mark Lloyd – Angling Trust
NRW Board Members (via NRW Board Secretariat)
Dear Dafydd,
Collectively we represent the vast majority of angling interests on the Mawddach & Wnion and between us have more than 160 years’ experience of fishing these rivers. At the Gwynedd Local Fisheries Advisory Group Meeting at Coed-y-Brenin on 30th November we were made aware of Natural Resources Wales (NRW) proposed decision to implement Mandatory Catch & Release in 2017 for Salmon across Wales and for Sea Trout in the rivers Dysynni, Gwyrfai, Mawddach &Wnion and Seiont. Not only do we have grave concerns about the impact of these decisions on the future of angling in Wales but are also fearful of the serious implications for local tourism.
Anglers across Wales feel that NRW is either not listening or simply choosing to ignore their concerns and we wish to raise a number of issues which we will address separately. Unless otherwise stated all quotes from NRW in this letter are taken from the documents NRW B B 40.15 and NRW B B 40.15 Annex 2 which were presented to the NRW Board Meeting at Canolfan Cae Cymro, Clawdd Newydd on 9th July 2015.
- 1. How the ‘consultation’ has been handled
A number of angling representatives attended the NRW Board Meeting at Canolfan Cae Cymro, Clawdd Newydd on 9th July 2015 following fears that the agenda item “Management Options to Address the Decline in Stocks of Salmon and Some Sea Trout in Wales” could potentially result in a decision being made without ever being discussed by Local Fisheries Advisory Groups. Having contacted the then chairman, Peter Matthews, in advance of the meeting, we were grateful that he took the decision to move the agenda item until after the coffee break so that we had the opportunity to speak to board members prior to the issue being discussed.
The relevant board paper shows that there were already concerns about how their proposals would be perceived:
“External Communications and stakeholder engagement
Risks
34. Criticism of the approach to the consultation.
35. Concerns about the impact of the decision on angling in Wales.
38. Potential need to re-direct or increase fisheries enforcement resources to enforce any new regulation.
41. There has been some dis-content following the consultation and implementation of actions following the review of hatcheries and stocking in Wales. This is because of a perception of pre-determination.
42. There is also significant concern amongst some stakeholders about our commitment to fisheries management and enforcement, as indicated by submissions to the WG scrutiny process.
43. We will prepare a fisheries communications plan to seek to engage stakeholders in deciding the management options necessary to address the decline in stocks of salmon and some sea trout at the same time seeking to address wider fisheries concerns.”
“This is a difficult issue because of the radical nature of the measures proposed, and it will be unpopular.”
“We do not consider that angling or netting in our coastal waters is the cause of the decline in salmon stocks, however restraint here is required to increase the spawning stocks whilst habitat repair and improvements works, following the principle of natural resource management, proceed.”
“Further restrictions on fishing will be unpopular with most and we need a strategy to deal with this.”
During the ensuing discussion one board member made the point that the introduction of the national spring salmon measures in 1999, which requires all rod caught salmon to be released prior to June 16th, had done nothing to address declining stocks and therefore how were these proposals going to do anything different.
In closing the discussion the chairman stated that he “hoped that their aims could be achieved without resorting to statutory legislation” and yet 15 months, more meetings and a “consultation” later the proposals are to introduce Mandatory Catch and Release via statutory legislation. It is little wonder that NRW were concerned that there would be “Criticism of the approach to the consultation” and that anglers have “a perception of pre-determination”.
Angling representatives did have the opportunity to voice their concerns at the Joint Dee and Clwyd and Gwynedd Local Fisheries Advisory Group Meeting at Coed-y-Brenin on 24th November 2015 and this was followed by a written questionnaire (which many felt had questions loaded to obtain the desired outcome) which concluded on 31st January 2016. Despite spending considerable amount of time in both attending the meeting and developing our own responses to the questionnaire it would seem that yet again NRW have chosen to dismiss our responses out of hand, showing no desire to develop and implement any form of alternative conservation strategy.
NRW may profess that it “aims to deliver widespread and positive partnership working” but sadly there is no evidence of it in this instance.
- 2. Concerns surrounding the data used to inform this decision
Whilst it is “…. a statutory requirement for anglers and netsmen to submit catch returns, and the rod catch data is used to assess the status of stocks of both species”, this data is less than robust. During the period 2010 to 2014 an average of 62.8% of anglers submitted a catch return and there is therefore a gaping hole in the figures.
A comparison of the total number of salmon caught between 2010 & 2014 on the 3 main fisheries on the Afon Dyfi (where accurate records are maintained), shows that on average the number of salmon recorded by the official statistics (Salmonid and Freshwater Fisheries Statistics for England and Wales) is 31.17% lower, mirroring what has already been proved in North West England. The actual fisheries total does not include a number of other private stretches and it is highly likely that the discrepancy is even greater! The actual figures are shown in the table below:
|
|
Combined NDFA/PAAS/BrigandsTotal |
Salmonid and Freshwater Fisheries |
%age Difference |
|
2010 |
269 |
168 |
37.55 |
|
2011 |
209 |
188 |
10.05 |
|
2012 |
154 |
116 |
24.68 |
|
2013 |
83 |
44 |
46.99 |
|
2014 |
41 |
26 |
36.59 |
|
|
5 Year Average |
31.17 |
When it comes to Sea Trout the data is even more flawed. Anglers are asked to record the number of days that they have fished each river before and after 16th June. Other than anyone who keeps a meticulous fishing diary, the vast majority of anglers hazard a wild guess. Even then it is debatable what constitutes a day’s fishing. Some anglers fish for an hour or less and record it as a day while others will only record a full day. It is hopelessly flawed and inaccurate and yet this is what informs the ‘Catch per Unit Effort’ which is used to assess whether sea trout stocks are at risk.
To quote NRW:
“……….. (sea trout) assessment is less robust than that for salmon as we have no corresponding biologically-based assessment process. This assessment is therefore based on long-term trends in catch per unit effort.”
“We do not currently have a decision structure for sea trout. This is because we have no comparable method to set egg deposition targets or to assess compliance with any such target. Instead the sea trout assessment tool uses recent trends in catch per unit effort to determine the status of stocks and their temporal trends. Catch over the most recent 3-year period is compared to a reference period of the previous 10 years and categories of risk are assigned depending on the performance of the fishery.”
“In Wales, NRW has also unilaterally applied a principle that a period of three consecutive years ‘At Risk’ or ‘Probably at Risk’ (declining) can be applied to any stock prior to developing statutory fishing controls.”
And so, based on a wild guess as to many ‘days’ 62.8% of fishermen think they have spent on the river, NRW’s 2015 ‘Know Your River – Mawddach Salmon & Sea Trout Catchment Summary’ is able to state that “……..the Mawddach is classified as “probably at risk”; i.e. the fishery appears to be performing reasonably well with no immediate concerns about the status of the adult stock” (those are the words used in the document), which in turn leads to the proposal to introduce Mandatory Catch & Release for a 10 year period.
Furthermore, whilst we appreciate that there are real concerns about salmon numbers, it should also be recognised that drought conditions in 2013, 2014 and autumn 2015 have had a major impact on both the timings of movements of migratory fish and angling effort and this in turn has resulted in depressed catches.
No doubt the 2015 Juvenile Salmonid Summary conducted by NRW will be quoted as further evidence to inform the introduction of Mandatory C & R. However we again have real concerns that just 3 monitoring sites can give us a true picture of what is going on within the catchment, particularly when NRW itself makes the statement that “The Mawddach site is very large and catch efficiency is low”. Although we were fearful of the potential impacts of the severe winter floods in December 2015, which will no doubt have washed out redds and caused juvenile fish to migrate within the catchment, anglers have been encouraged by the significant numbers of both parr and fry observed in other locations such as the Afon Aran and tidal areas of both Mawddach & Wnion.
- 3. The impact of banning worm fishing
NRW intends to ban worm fishing as part of its measures. This causes issues in 2 distinct areas of both the Mawddach & Wnion.
On the upper reaches of both rivers worm fishing is the only effective method of fishing. Spinning is restricted to a few areas and fly fishing all but impossible. To ban worm fishing is effectively to ban angling and as a consequence there would be little point in continuing to rent those waters. One angling club alone pays rents totalling £13,842 on such waters and this money would effectively be removed from the local economy. Furthermore with no legitimate anglers present on the river there is no deterrent for would be poachers and no ‘intelligence gathering’ for NRW’s hardworking but woefully understaffed enforcement team.
On the tidal waters the effects are very different. Here a significant number of elderly and/or less able anglers, local and visiting alike, spend their time on the riverbank during the summer months. These anglers are not physically able to use any method other than worm fishing and so their fishing days are ended at a stroke. So much for the socio-economic benefits of angling.
- 4. The impact on angling tourism and the local economy and environment
One of our greatest concerns is the impact of these proposals on the local tourist economy. NRW of course is well aware of this as is evidenced by the following quotes:
- i. “Salmon and sea trout are iconic and important species in our rivers. They support recreational fisheries that bring economic benefit (in excess of £74 million annual expenditure in Wales, supporting around 1,500 Welsh jobs and £32 million in household income, Mawle and Peirson, 2009), often to rural communities”
- ii. “Welsh Government has set objectives for NRW to contribute to objectives for freshwater fisheries management, broadly by promotion of the conservation and maintenance of the diversity of migratory and freshwater fish, and by enhancing the contribution that migratory and freshwater fisheries make to the economy, particularly in remote rural areas and in areas with low levels of income.”
- iii. “We need to manage our natural resources in a way that provides multiple benefits for people and nature now and in the future. As part of that we need to ensure that fish stocks are managed sustainably to provide maximum socio-economic benefits.”
- iv. “We have a range of roles and duties for fisheries that are relevant to our management of salmon and sea trout stocks, noting that policy responsibility for Welsh fisheries is devolved to WG.
- to enhance the contribution that fish make to the economy, particularly in rural areas
- to enhance the social value of fishing as a healthy form of recreation”
One caravan site adjacent to the Mawddach has a total of 24 static caravans and 7 permanent touring caravans which are owned by visiting anglers who are members of Dolgellau Angling Association and/or Prince Albert Angling Society. These anglers pay a total of £24,623.59 to the site owner which includes £4,421.35 in rates to the local authority. This figure does not include ‘short stay’ visiting anglers and there are many other caravan sites, both in the Dolgellau are and across Wales, where anglers make similar contributions. The total spend in local shops, restaurants, petrol stations and tourist attractions etc is immense.
A questionnaire survey of 70 anglers on the Mawddach in 2010 (All of the original survey and analysis sheets are available for inspection should anyone wish to question the validity of the data) showed that only 22.86% of anglers would continue to fish if Mandatory C&R was introduced (a number of these were local anglers who said that they would only buy a trout licence in the circumstances). There is nothing to suggest that this will have changed in 2016 and this, in conjunction with the previous figures, highlights the threat to the local economy and environment from a decline in angling tourism.
Both angling clubs also spend considerable sums of money in the local economy in order to maintain their waters. During 2016 that total is well in excess of £3500, spread across a variety of businesses including Huws Gray (Dolgellau), Wynnstay (Dolgellau), Travis Perkins (Machynlleth), Major Owen (Penrhyndeudraeth) and Coleg Meirion Dwyfor (Glynllifon). Riparian owners have also spent in excess of £2000 in recent years for the same purpose.
We also make a significant contribution to the local environment by tackling both Japanese Knotweed and Himalayan Balsam on the banks of both the Mawddach & Wnion. Both angling clubs are currently involved in a partnership project with the local Rotary Club and Snowdonia National Park which is delivering a catchment based approach. This is both skilled (members have undergone the appropriate City & Guilds Training in their own time) and physical work and it is hard to see where the will and motivation to continue will come from if anglers feel that they have been driven off the rivers.
We have also participated in partnership working with NRW in order to deliver habitat improvement schemes in order to improve the juvenile recruitment of both salmon and sea trout within the catchment of both rivers. Again enthusiasm and commitment can only be stifled by NRW’s proposals.
- 5. Why we oppose the introduction of Mandatory Catch & Release
We are fully supportive of measures to conserve our stocks of salmon and sea trout; what we disagree with is how this is being conducted. We know that Mandatory C&R drives anglers away, one only has to look on the banks of the Welsh Dee and Severn prior to June 16th to see that anglers are indeed an endangered species.
The ‘Background Salmon Report 2014 (CEFAS EA NRW)’ provides clear evidence to support this:
- “On average, pre-June catches, including fish released, comprised 11% of the total declared rod catch in the five years prior to the measures (1994–1998), while this has fallen to a mean of less than 6% since 1999.
- Changes in rod licence costs and the imposition of compulsory catch-and-release may also have affected the take-up of licences and effort.
- The national spring salmon measures, ban on sale of rod-caught fish and catch and release requirements are all thought to have influenced angling effort in recent years.
- the number of annual licences has changed more markedly, decreasing from ~27,000 in 1994 to ~15,000 in 2001 (down 44%), mainly due to the decline in salmon stocks and the introduction of restrictions on angling, especially those to protect early-run MSW fish (compulsory catch and release before 16 June)”.
The 2015 document adds further evidence: “The number of days fished by anglers in Wales has fallen by 50% since 1994”.
Unfortunately what NRW are failing to grasp is that Mandatory C&R drives anglers away and this was perhaps best illustrated when NRW Principal Fisheries Advisor, Peter Gough stated at the joint Dee & Gwynedd LFAG held at Coed y Brenin visitor centre on Tuesday 24th November 2015, that anglers would continue to fish because they are already putting 80% of their fish back anyway. This completely misses the point! Anglers will fish and return most, and in some cases all, of their fish but when they are told that they cannot even retain one fish, the majority stop fishing altogether.
So why are anglers so vital to the survival of our salmon and sea trout stocks?
- Firstly anglers have a vested interest in the stocks of migratory fish. To the ordinary member of the public the countryside of Wales is just as attractive whether there are any fish swimming in the rivers or not. Unfortunately fish are not as visible and do not have the same appeal to the general public as many mammals.
- Secondly the presence of anglers on the riverbank acts as a deterrent to poachers. If we drive anglers away fewer fish will survive to spawn.
- Thirdly those anglers are the eyes and ears that provide intelligence for NRW’s Enforcement Officers (who we have the utmost respect for). We are sure that NRW’s records will indicate that the percentage of calls that from anglers far exceeds that from the general public. Without intelligence an already overstretched Enforcement Team cannot hope to protect our fish stocks, indeed they have consistently implored anglers in recent times to provide good intelligence. Indeed when we surveyed 70 anglers on the Mawddach in 2010 75.71% of anglers told us that they had never been approached on the riverbank by an Environment Agency Wales bailiff whilst fishing the Mawddach and Wnion during the previous 5 years. With the Enforcement Team reduced further since that date it is patently obvious that fish stocks cannot be protected effectively unless we work in partnership with one another. Indeed if Mandatory Catch and Release is introduced, NRW Enforcement Officers cannot police it. On the other hand, angling organisations can, and do, police their own rules both through club bailiffs and peer pressure from other members.
- Fourthly with the closure of hatcheries and ending of third party stocking, habitat improvement has an even more significant role in the restoration of fish stocks. River Trusts and organisations such as our own are keen to work in partnership with NRW to deliver this work. However it is going to be much more difficult to recruit volunteers when anglers either feel that they are not being listened to or have decided to fish elsewhere.
- Fifthly there has been a steady increase in the number of predators which are a threat to both adult and juvenile salmonids. A particular problem has been with cormorants, mergansers & goosanders and it is largely angling organisations that have applied for culling licences. If anglers are driven away predator numbers will increase with a corresponding reduction in the fish population.
- Sixthly the revenue from migratory fish licences is vital to fund both habitat improvement and to provide resources to protect fish stocks. With fewer licences sold, those anglers who remain deciding to purchase only a trout licence (the cost of a full licence is set to rise from £72 to £82 in 2017) there can only be less money available to improve matters
We as anglers are also particularly frustrated that NRW is proposing to change the ruling from no catch restrictions at all to 100% release, without any intermediate measures to protect stocks adequately. NRW does however acknowledge that angling clubs have introduced their own conservation measures:
“There have been great advances in the uptake of voluntary catch-and-release (C&R) fishing by anglers across Wales, moving from close to zero two decades ago to a declared Welsh national average in 2014 of about 78% for salmon and sea trout.”
“Non-statutory restrictions on methods and fishing areas imposed by fishery owners and angling associations include weekly and seasonal bag limits, and there are ongoing efforts to promote catch and release (C&R). As a consequence, the proportion of salmon released by anglers has increased steadily from 10% in 1993 to at or above 60% in the last six years (79%, provisionally, in 2015, the highest in the time series)”.
In 2010 we asked Environment Agency Wales to consider a tagging system for the Mawddach, similar to that which is used on the Ribble in England. We were told that it would be better for angling clubs to introduce and police their own conservation measures as the agency did not have the staff to operate such a scheme. The Environment Agency in England ultimately passed a specific bylaw to reinforce the tagging scheme which has mainly been policed by angling associations. The Ribble has benefitted from this scheme with lower exploitation rates and a less marked decline than nearby rivers such as the Lune and Welsh Dee. It clearly works!
We feel that the local community must be made aware of the consequences of NRW’s proposals. As has already been stated angling organisations have taken a responsible stance and sought to conserve fish stocks by introducing and policing their own rules, whilst NRW has stood on the side lines and then stepped in at the eleventh hour with a simplistic, “what more can we do?” solution that incurs little cost and which they do not have the means to police.
Anglers want to work in a real partnership and that of course is a 2 way process. The way forward is to engage anglers and promote the education process that has already seen Voluntary C&R rise to unprecedented levels. NRW must not be allowed to stubbornly proceed with its doctrinal and draconian proposals which have already been tried and tested and proved to be ineffectual in the restoration of fish stocks and which will only serve to drive anglers away from Welsh rivers and thereby further threaten fish stocks and reduce income derived from tourism.
Yours sincerely
John Eardley – Gwynedd Local Fisheries Advisory Group Representative – Prince Albert Angling Society
Gavin Jones – Secretary, Dolgellau Angling Association
Charlie Abbott – Riparian Owner, Afon Mawddach
Hywel Bromley Davenport – Riparian Owner, Afon Mawddach
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