Thank you Chris White!
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:
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 Campaign For The Protection Of Welsh Fisheries
To: Chair and members of the NRW Board Re: January NRW Board meeting 18 January 2018 – Fisheries presentation At the Board meeting on Thursday 18 January the NRW Board will be asked to approve the recommendations from NRW Fisheries Officers to impose draconian bylaws which are supposed to protect and stop the decline in salmon and some sea trout stocks in Welsh rivers. Whilst nobody disputes that there has been a serious decline in salmon stocks this is not unique to Welsh rivers with all of the UK rivers (with some exceptions) experiencing a similar decline. You will be told that there is a need to increase the number of fish spawning but the real problem is the survival of egg to smolts reaching the sea (smolts are young salmon ready to migrate). Whilst the NRW acknowledge that anglers are not the main cause of the decline in fish stocks they are being targeted as if they were. There are many causes for this decline some of which is due to the conditions in the North Atlantic, the following are the key issues which we believe should be addressed before legislation is used as a blunt instrument:
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 the proposals are accepted it will be almost impossible for NRW to enforce them, 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 C&R and method restrictions managed by local angling clubs. This option has been dismissed in the proposals.
Regards Chris White Conservation Officer: Campaign For The Protection Of Welsh Fisheries Press release from The Angling Trust, for which we are most grateful. It would seem that NRW continue to treat anglers with contempt! AT press release follows
Unfortunately the system will not let me add the Angling Trust Logo Angling Trust Eastwood House 6 Rainbow Street Leominster Herefordshire HR6 8DQ 17th May 2018 By email to: Correspondence.Lesley.Griffiths@gov.wales Dear Ms Griffiths, As you know, the Angling Trust is the representative body for all disciplines of angling with thousands of individual members and members of affiliated clubs in Wales. It is united in a collaborative relationship with Fish Legal, a separate membership association that uses the law to protect fish stocks and the rights of its members throughout the UK. Freshwater angling is one of the Wales’s most popular pastimes and also makes an important contribution to the economy, generating at least £150 million in revenue, attracting visitors from throughout the world and supporting countless jobs either directly or indirectly. Angling also has numerous social benefits for individuals and communities and for many local anglers it is their only leisure activity. A large proportion of this angling is for game fish: salmon, sea trout, trout and grayling. The Angling Trust responded, along with hundreds of anglers, to the recent consultation by Natural Resources Wales regarding the exploitation of salmon and sea trout in Wales. The overwhelming majority (83%) of responses were opposed to the imposition of mandatory catch and release on the angling community. We also attended the NRW board meeting where this was discussed on the 18th of January. We were very disappointed that the board decided to recommend to Welsh Government that the views of the anglers who pay their wages should be ignored and that they should go ahead with banning the taking of fish by anglers, which is something they have been doing for centuries. Anglers have greatly increased the rates of catch and release in recent decades and they also invest countless volunteer hours and substantial funds into the restoration and protection of our nation’s rivers. Anglers are often the first to report pollution incidents, poaching and other illegal activity. The NRW board was rightly concerned from the responses to the consultation that anglers had lost confidence in NRW as an organisation and in Welsh government’s recognition of the importance of angling. In addition to this consultation, anglers have been faced with your government’s recent consultation which proposed opening up all rivers to navigation, which would destroy our members’ property rights, and a complete failure by NRW and Visit Wales to promote what is left of Welsh freshwater fishing to visitors. A decade ago, the Fishing Wales initiative generated a massive return on investment, but since it was axed there has been an apparently deliberate attempt to hide the opportunities to fish on Welsh rivers from potential visitors. It is understandable that many now believe that Welsh Government is deliberately trying to destroy angling. The NRW board also recognised that anglers are not the cause of declining fish stocks and that the reasons are mismanagement of the natural environment and that urgent action was now required to correct that failure. Whilst climate change is a factor affecting all salmon stocks, some rivers are still managing to maintain or even increase their populations by successfully managing the other human pressures on the water environment. However these are very much the exception in Wales. I have written to you several times about the endemic levels of slurry pollution from the intensive dairy farming areas of Wales, but you have declined to meet with me to discuss this on several occasions and have failed to take the necessary urgent and comprehensive action required to tackle this dire situation, which is getting worse. In the last decade I have also witnessed in Wales a huge expansion of the area of maize, stubble turnips and over-grazing of pasture that are causing an increase in flood risk and heaping costs on the rest of society. Your government’s response has been for a voluntary approach to regulation of agriculture, the country’s biggest polluting sector, which kills far more salmon and sea trout than anglers could ever dream of catching, let alone taking home to feed their families. Two major pollution incidents on the Teifi two years ago killed more salmon and sea trout than the entire annual catch by anglers, but Natural Resources Wales has still not prosecuted either of the perpetrators. Countless other prosecutions for agricultural pollution are pending. In this context, the imposition of 100% mandatory catch and release regulations, making it a criminal offence for thousands of anglers to take fish home to feed their family very occasionally looks entirely disproportionate, asymmetric and staggeringly unfair. I urge you to adopt a voluntary approach to implementing catch and release which would be compatible with the approach that we have negotiated with the Environment Agency in England. As I wrote to you in a letter in May of 2017, it is now more urgent than ever that your government sets out a clear strategy to tackle the ever-growing problem of agricultural pollution and the impacts it is having on fish stocks, and the wider environment. Finally, we would like to see a comprehensive programme introduced to manage predation from cormorants and goosanders to reduce the impact that they have on salmon and trout stocks, and coarse fisheries, throughout Wales. I would like to meet with you and your officials to take this agenda forward. In England, we meet regularly with the Water and Fisheries Ministers and the Secretary of State for Environment, Food and Rural Affairs and I see no reason why you should not meet with the representative body for one of your largest stakeholder groups in the context I have set out above. Yours sincerely,
Mark Lloyd Chief Executive, Angling Trust & Fish Legal We wish you all a very happy new year, good health and many tight lines. From the recent activity on this site, you could be forgiven for thinking that wed have ceased activities: not so. We are actively contacting NRW management, M.P.’s and A.M’s with regard to the proposed changes in salmon and sea trout bye laws. We continue to challenge the validity of the decision to close all Welsh hatcheries. We work closely with the CLA and Angling Trust to fight for anglers rights, to protect our waters from unfettered access by canoeists and champion the cause of voluntary agreements with paddlers. Many of these communications are and will remain sensitive, but as soon as we can we will publish them on this site. I see that there are petitions about seeking support for various angling/bye law changes. We are greatly concerned that a little over 1,000 signatures have been added to the latest and best supported. There petty numbers create the impression that we anglers are bot concerned or are compliant with teh current NEW onslaught on our support. Please sign teh petition but for goodness sake please do not start another. Watch this space. Please click on the link below to view the newsletters
Click this link to see the BBC item on this subject. For the record, NRW enforcement staff are generally hard working and dedicated, there are just far too few and the few working really hard feel they are overworked, under resourced and desperate to be able to do the job properly. CLICK HERE Thanks to Wynne Griffiths for the link. This is the link to the consultation documents and response form NRW advise us that you may respond by letter/email but they would prefer you to use the form. We urge you to follow this link and respond: Thank you. CLICKHERE When you get to the page, scroll down to the bottom where there is a list of documents, the response form is the second one down on the left: the only word document on the selection. Sorry we are so late posting this link, I though I did it some time ago. I thought you may like to look at the two links below, both of which relate to otter predation on fisheries href=”https://www.predation.co.uk/mission-statement“>Click here href=”href=”https://www.predation.co.uk/predator-press”>Click here”>Click here Andrew Flitcorft, the editor of Trout and Salmon Magazine has kindly allowed us to publish his Editors Letter as included in the September issue. Thank you Andrew and Trout and Salmon Magazine His view: “Anglers are once again being used as political pawns by authorities To read the full letter click on this link Editors letter NRW have replied to the FOI request by saying they did not make any such comment. 4/10/17This a a quote taken directly from a letter produced by Angling Trust and Afonydd Cymru and sent to Lesley Griffiths A.M. Cabinet Secretary. We are awaiting a response to a freedom of information request for a copy of the document proffering this advice to the Welsh Government. We will keep you posted.“Our recent meeting with your officials revealed nothing of substance nor any future plans or direction, save to learn that NRW had advised that climate change would bring a premature end to our migratory fisheries, thus making them not worthy of further attention”Chris, thought you would be interested to see this video on you tube. NRW have been advised that this happens and have been asked to reconsider their fish pass designs on hydro schemes. We await a response. The Welsh Government is consulting on Taking forward Wales’ sustainable management of natural resourcesThis consultation includesPage 38. Proposal 11To amend or revoke the following list of restrictions on access, provided in Schedule 2(1) of the CRoW Act 2000: (b) uses a vessel or sailboard on any non-tidal water; (c) has with him any animal other than a dog; (i) bathes in any non-tidal water; and (s) engages in any organised games, or in camping , hang-gliding or para-gliding. ONCE AGAIN THERE IS YET ANOTHER ATTEMPT TO FACILITATE THE FREE ACCESS OF CANOEISTS TO OUR RIVERS. It is important that as many of you as possible respond to this consultation, even if only to this issue. No need to fill in the whole document, just the question relation to free access to waterways, which includes rivers. Link to consultation page at Welsh Government website click here Here you can download the documentation Consultation document from this site. If you wiah to read the document and respond on line, then this is the link click here
Wednesday June 7th 2017
PROTECT OUR FISHERIES
Following the publication of a report highlighting a “serious decline in fishing in Wales”, North Wales Assembly Member Mark Isherwood has called for a Welsh Government Statement on the protection of fisheries in Wales.
Speaking in this week’s Business Statement, Mr Isherwood said issues regarding the failure to protect fisheries in Wales, in consequence of Welsh Government policy, were covered in the national angling paper ‘The Angler’s Mail’.
He said:
“This highlighted a serious decline in fishing in Wales. It said that the Welsh equivalent of the Environment Agency, Natural Resources Wales, had been branded no longer fit for purpose by fishing and environmental groups, and that of the 6,886 reports of water pollution that Natural Resources Wales received between 2013 and 2016, only 60 per cent were investigated, and there were just 41 prosecutions and 10 civil sanctions, amounting to less than 1 per cent of incidents reported.
“It said ‘There has been a steep decline in fish numbers in recent years in Wales.The regulator needs to take a much tougher stance but…The organisation is unwieldy, too bureaucratic and they don’t seem to have a strategy’.
“They did say that they were meeting with officials in the Welsh Assembly, by which I presume they mean the Welsh Government, to demand action, concluding that there’s been a national failure of Welsh Government to tackle the problem. Given particularly their reference to Welsh Government in the article, and their reference to a meeting with officials, could we have a statement to bring us up to date not only on what was concluded, but what actions, if any, have resulted?”
The Leader of the House, Jane Hutt, told Mr Isherwood “it would be helpful if you wrote to the Cabinet Secretary on this matter as her officials are already engaged in that discussion,” |