North West Angling Trust Fisheries Consultative Council part of the Angling Trust and AT North West Freshwater Forum
9 th February 2020
Heidi Stone, EA Salmon Programme Manager Peter Gough, NRW Principal Fisheries Adviser Cc Dr Alan Walker, Cefas Senior Scientific Officer Lesley Griffiths AM, Cabinet Secretary, Welsh Assembly Government Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPWF Notification of National salmon review timetable & content re England & Wales River assessments and Byelaw Implementation
Dear Heidi & Peter,
I write as representative of the Salmon Anglers Advisory Group, Chairman of NWATFCC and on behalf of CPWF Campaign for Protection of Welsh Fisheries whose member rod fisheries and business interests hold and manage extensive migratory fisheries in England and Wales. There are as you know two national review processes that are now underway that rod fisheries were instrumental in lobbying for and are scheduled as EA, NRW & Cefas commitments. As yet we have received no prior notification regarding their proposed timetable, contents or point at which rod fisheries representatives will be invited to make their contributions. In letters to the Defra and Welsh Cabinet Ministers in April & Sept 2018, NWATFCC & CPWF made strong recommendations that the E & W national Byelaws should be deferred until the necessary improvements to revising stock assessments were agreed and incorporated into Byelaws and that interim conservation measures were introduced to enable those review processes to conclude with agreement by all parties. In the case of the ongoing national Rod Exploitation Rate review, I was informed in April 2019 that invitations would be circulated, but these have not arrived. Those recommendations to Ministers, made through Mark Lloyd of the Angling Trust were to prevent the situation that now confronts us – that revision and activation of necessary rod exploitation rates are being “held” to prevent exposure to historic stock assessments that might be considered unsafe in framing conservation measure justifications in the current national Byelaws. There is the means to overcome the logjam that is blocking urgently required stock revisions and we must not remain blind to this. NWATFCC & CPWF have formally notified the EA, NRW & Cefas that the provisional 2018 assessments released in June 2019 require revision and we could not accept these until the rod exploitation rate review incorporated corrections in “final“ 2018 published reports. We have asked, but received no confirmation of the progress of the final assessments or what the status of individual river stocks are as regards the original provisional stock report. We have also submitted detailed proposals as part of drafting of the NASCO 2019 – 24 IP Improvements to Stock reporting, River Classification and Decision measures. A summary of the subject headings rod fisheries would wish to engage with within the reviews is set out below and supported by reports containing detailed analysis, modelling, alternate methodology and stock reporting proposals; 1. National Rod Exploitation Rate (RER) review EA & NRW proposals to improve capture of angler rod catch & species rod effort EA & NRW proposed methodology for estimating individual river RER`s and elements – rod effort, River flows & salmon runs ( timing re rod season and cyclical frequency) Rod fisheries analysis & modelling – Prof Brian Revell`s research & findings Managing Rivers with inadequate rod catch data Index river validated outputs as linked River reference RER applications Implementation of annual reviews in annual stock assessment procedures 2. NASCO 2019 – 24 IP Improvements Review a) Conservation Limit CL as a single conservation reference point Resetting CL in revising SAP`s b) Annual River assessment of egg depositions to CL Rod catch and under reporting estimates Age/weight proportions determining ISW/MSW – Index River estimates Fecundity values & mortality estimates Use of existing River stock performance as percentile to CL Proposed River Fisheries report KPI`s c) River Classification Fault lines & weakness in current 15 year Linear regression methodology Adoption of alternate & transparent methodology Transparent River stock performance as actual percentile MAT to CL in classification status bands Use of Juvenile data to support stock health assessments System validation Opportunities for improved stock performance reporting Integration and harmonisation of a single UK mainland Conservation strategy d) Decision Process Transparent River measures process based on River Classification status Annual River Status review & application of C & R measures Flexibility to change targets and breakpoints We would welcome a positive response to this communication as part of an inclusive and progressive approach to improving reporting of stocks and applying long term conservation strategies in the national review phase. We very much hope this can be responded to as a joint EA & NRW communication for reasons that both organisations and jurisdictions have shared stock reporting system procedures and commitments in the planned reviews.
With regards
Mike Ashwin Chairman NWATFCC North West Angling Trust Fisheries Consultative Council The Barn, Skirwith, Penrith, Cumbria CA10 1RH Tel 01768 879047 mob 07926 489764
North West Angling Trust Fisheries Consultative Council part of the Angling Trust and AT North West Freshwater Forum
8 th February 2020
To: Lesley Griffiths AM, Cabinet Secretary, Welsh Assembly Government
Correspondence.Lesley.griffiths@gov.wales
Cc Peter Gough, NRW Principal Fisheries Adviser Heidi Stone, EA Salmon Programme Manager Mark Owen, Angling Trust Head of Freshwater Paul Knight, S&TCUK Chief Executive Officer Mark Bilsby, AST Chief Executive Officer Officers of NWATFCC, PAAS & CPWF Approval of Cross border Welsh Dee & Wye byelaws & Implementation of All Wales Byelaws
Dear Lesley,
Thank you for your letter of the 4th February 2020 and with it, comments and clarification of the Cross Border approval decision process. We note your approval of these Byelaws on the 29th January, the day after receiving our request to carefully review this intended action and our strong recommendation to introduce interim arrangements until the two imminent national (NRW, EA & Cefas) stock review processes are concluded. We find it difficult to comprehend this decision in the light of the information we provided and questions we have raised over the Welsh Dee Index river methodology and outputs that determine other Welsh river stocks. The national England & Wales Stock reporting and Assessment system may have been found to be “Fit for Purpose” at the local Inquiry by the Planning Inspector. But I can assure you, it is certainly not fit for purpose, has not undergone validation when introduced in 2004 or subsequently been QA reviewed since that time. The substance and scope of the two national review processes testify to that and we anticipate the system will undergo major overhaul which will make historic assessments unsafe. I refer you to NWATFCC correspondence (attached) with NRW, EA & Cefas that sets out the vision of those improvements that rod fisheries expect to see addressed in the NASCO 2019 – 24 IP and separate national Rod exploitation rate review. 2020 enacted Byelaws carry a penalty that 5 year mid-term review arrangements will lag 3-4 years behind these national review improvement implementations. The enforceability of the All Wales byelaws is a major and unforeseen consideration and Cross Border Rivers, where E & W national measures are not aligned and diametrically opposed pose additional complexity and resource allocation that is not available. This at a time when stocks will be threatened by increased poaching activity through reducing angler presence and supervision. In view of the significant impact the All Wales and Cross Border Byelaws are expected to have on migratory licence sales and rod effort, and here we are anticipating a 25% – 35% reduction in 2020 on top of a 40% – 50% reduction in both over the last 9 years,
NWATFCC , PAAS & CPWF are now taking legal advice over the approval of the Cross Border byelaws.
With kind regards Mike Ashwin Chairman NWATFCC North West Angling Trust Fisheries Consultative Council The Barn, Skirwith, Penrith, Cumbria CA10 1RH. Tel 01768 879047 mob 07926 489764
Ceri,I note that you are a signatory on behalf of NRW on the attached 2018 protocol for the disposal of contaminated water. I have real concerns on the disposal of wash water from poultry farms due to the impact of the disinfectant on the aquatic environment. I expressed my concerns at the last Fisheries Forum about the approval of a planning application and construction of a 150,000 bird poultry farm at Fron Bella Farm, Hafod Denbigh, Conwy with approval for a further 75,000 birds (location slides attached). This farm is at 300 m (984 ft) on the head waters of a major spawning tributary of the upper Conwy and is claimed to produce 7.1 Tonne of manure per year. It is unclear from the permit for this farm how wash water will be disposed. Assuming the use of Virkon S applied at the DEFRA dosing rate for poultry farms of 2.8Kg in 750 ltr (0.33 mg/ltr) to cover 2,300 sq m then for the two sheds (each shed is approx 2,000 sq m) it will take 1,500 ltr each time they are cleaned, this occurs 6 time per year producing at least 1,000 ltr of contaminated water for each wash (allowing for evaporation). At this concentration (0.33 mg/ltr) any run-off into the surrounding fields will be lethal to aquatic invertebrates, the data sheet for Virkon S says 0.22 mg/ltr is lethal to aquatic invertebrates and 0.29 mg/ltr is lethal to terrestrial insects. Should the wash water tank be emptied and then sprayed on the surround fields if will find its way into the Afon Nug and then Afon Merddwr both are spawning streams on the upper Conwy, it has taken 15 years to establish this spawning area. In addition it is likely that this water if sprayed on fields will kill all field insects which will impact on field bird populations.Whilst my concern is for the potential impact from Fron Bella farm on the Conwy I suspect that the same will apply to all poultry farms in river valleys. Can you please advise the policy from NRW/WG with respect to disposal of this contaminated water as it is included within protocol see page 5 item 3 Scope first bullet point.
Regards
Chris White
Conservation officer: Campaign for the Protection of Welsh Fisheries (CPWF)
Ceri,
I note that you are a signatory on behalf of NRW on the attached 2018 protocol for the disposal of contaminated water.
I have real concerns on the disposal of wash water from poultry farms due to the impact of the disinfectant on the aquatic environment.
I expressed my concerns at the last Fisheries Forum about the approval of a planning application and construction of a 150,000 bird poultry farm at Fron Bella Farm, Hafod Denbigh, Conwy with approval for a further 75,000 birds (location slides attached). This farm is at 300 m (984 ft) on the head waters of a major spawning tributary of the upper Conwy and is claimed to produce 7.1 Tonne of manure per year. It is unclear from the permit for this farm how wash water will be disposed. Assuming the use of Virkon S applied at the DEFRA dosing rate for poultry farms of 2.8Kg in 750 ltr (0.33 mg/ltr) to cover 2,300 sq m then for the two sheds (each shed is approx 2,000 sq m) it will take 1,500 ltr each time they are cleaned, this occurs 6 time per year producing at least 1,000 ltr of contaminated water for each wash (allowing for evaporation). At this concentration (0.33 mg/ltr) any run-off into the surrounding fields will be lethal to aquatic invertebrates, the data sheet for Virkon S says 0.22 mg/ltr is lethal to aquatic invertebrates and 0.29 mg/ltr is lethal to terrestrial insects. Should the wash water tank be emptied and then sprayed on the surround fields if will find its way into the Afon Nug and then Afon Merddwr both are spawning streams on the upper Conwy, it has taken 15 years to establish this spawning area. In addition it is likely that this water if sprayed on fields will kill all field insects which will impact on field bird populations.
Whilst my concern is for the potential impact from Fron Bella farm on the Conwy I suspect that the same will apply to all poultry farms in river valleys. Can you please advise the policy from NRW/WG with respect to disposal of this contaminated water as it is included within protocol see page 5 item 3 Scope first bullet point.
Regards
Chris White
Conservation officer: Campaign for the Protection of Welsh Fisheries (CPWF)
The link to the Newsletter, which gives details of NRW’s fishery related works, is located under the Newsletter Tab
Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig
Minister for Environment, Energy and Rural Affairs
Eich cyf/Your ref
Ein cyf/Our ref LG/7611/19 Chris White
Llywodraeth Cymru Welsh Government
chriswhite.cohite@gmail.com
Ni h January 2020
Thank you for your letters of 10 and 13 December,
regarding your ongoing concerns about my decision to approve the All Wales
byelaws (AWB) and my recent decision to delay the proposed introduction of
regulatory measures to address agricultural pollution pending further
consideration.
Whilst I understand you
are not happy with the recommendations of the Local Inquiry and my resulting
decision to confirm the AWB, I am content these byelaws were carefully
scrutinised as part of the impartial Local Inquiry process and all parties were
given the chance to put forward their views. The inspector’s recommendation
report confirmed the Natural Resources Wales’ byelaw proposals were necessary,
proportionate and reasonable in view of the decline of salmon and sea trout
stocks throughout Wales and alternative voluntary measures would not be
suitable.
I’ve taken the decision to
delay the proposed introduction of regulatory measures to address agricultural
pollution, to enable me to consider all the evidence provided by the Farming
Unions and wider stakeholders before I take a final decision. However, this is
not a valid reason to defer the AWB coming into force, as all additional fish
returned alive under the new compulsory regulations, will help contribute to
the recovery of salmon and sea trout stocks. The AWB for salmon and sea trout
will come into force on 1 January 2020.
As you know, I have also
asked NRW to put together a Plan of Action (PoA) for salmon and sea trout. The
PoA aims to set out all the current work being carried out by various parties
to combat the issues impacting upon our fish stocks, as well as identify any
gaps and new actions. Reversing
the decline of salmon and sea trout stocks will be a challenge and the PoA will only be
successful if everyone with an interest in salmon and sea trout contributes.
Therefore, I am glad you are working closely with NRW as part of the Wales
Fisheries Forum, to try and help reverse the decline in stocks.
I am aware
Fish Eating Birds, ‘in river’ loss of smolts and Enforcement were all issues
raised in the inquiry and therefore anticipate these issues will be addressed
in the plan. With
Bae Caerdydd • Cardiff Bay
Caerdydd • Cardiff
CF99 1NA
Canolfan
Cyswllt Cyntaf / First Point
of Contact Cent re :
0300 0604400
Gohebiaeth.Lesley .
Griffi
ths@ll yw.cymru Corresp ondence.Lesley .Gri ff it hs@gov. wales
Rydym yn croesawu derbyn gohebiaeth yn
Gymraeg . Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg
ac ni fydd gohebu yn Gymraeg
yn arwain at oedi.
We welcome receiving correspondence in Welsh. Any correspondence
received in Welsh will be answered in
Welsh and corresponding in Welsh
will not lead to a
delay in responding.
regard to Enforcement I
will discuss the meeting which took place in Bala with Ms Pillman and consider
any points which were raised.
In the meantime, I
understand there has been further exchanges with NRW about the methodology used
for assessing stock levels and I can confirm they will be responding on this
matter in due course.
I have recently been in
contact with your associate Mr Eardley and offered him the opportunity to meet
my officials to discuss any further concerns about restoring salmon and sea trout
stocks. I would like to extend this invitation to you and ask if you would like
to accompany Mr Eardley to meet with my officials to discuss your concerns
about both agricultural regulations and salmonid fish. If you would like to
take up this offer please contact:
Julian Bray, Head of
Domestic Fisheries Policy and Management 03000 625605 I Julian.Bray2@gov.wales
From: Mike Ashwin
Sent: 02 January 2020 15:07
To: Stone, Heidi <heidi.stone@environment-agency.gov.uk>; Talks, Lawrence <lawrence.talks@environment-agency.gov.uk>; simon toms <simon.toms@environment-agency.gov.uk>; brian shields <brian.shields@environment-agency.gov.uk>; Bainger, Chris <chris.bainger@environment-agency.gov.uk>; Gough, Peter <Peter.Gough@cyfoethnaturiolcymru.gov.uk>; Mee, David <David.Mee@cyfoethnaturiolcymru.gov.uk>; Davidson, Ian <Ian.Davidson@cyfoethnaturiolcymru.gov.uk>
Cc:alan.walker@cefas.co.uk <alan.walker@cefas.co.uk>
Dear colleagues,
This communication is circulated to lead EA & NRW managers/advisers and will be forwarded to EFG & WFF representatives involved in ongoing Byelaw/Stock management dialogue, authors of key elements of River stock reporting methodology and rod fisheries groups. It expresses the direction of engagement and collaboration rod fisheries have been seeking in shared areas of improved salmon stock management, and our ongoing actions to secure this. It is sent for reasons that usual channels of communication have become truncated and locked during Byelaw and system review process.
A small group of rod fisheries individuals has been engaged in developing and communicating these improvements:
1. In the first instance, forming and making recommendations to Defra & Welsh Cabinet Ministers in letters of 9th April & 17th Sept 2018 presented by Mark Lloyd of the AT on behalf of NWATFCC & CPWF. Those recommendations being part of E & W National Byelaw “processes” and set out specific rod fisheries requests that :
- a national rod exploitation rate review take place to report on seasonal factors influencing rod catch and river spawning estimates and incorporate as annual revising river estimates for assessment purposes.
- for improvements to angler rod catch reporting systems & River stock reporting procedures.
- for validation and periodic QA review of the of the River Classification system
- steps are taken to “re-introduce” a harmonised E & W stock reporting, classification, decision structure process.
- that interim (three year) E & W voluntary rod C & R measures are agreed and introduced to enable these review/improvement processes to be concluded and steer delivery of common Byelaw proposals. In hindsight adoption of this would have forestalled the contested positions we now find ourselves defending.
2. In communicating the reasons for improvements and recommendations by NWATFCC & CPWF to current system procedures as part of submissions to the drafting of the NASCO 2019 – 24 Implementation Plan. If EFG & WFF representatives are not aware of these, then I recommend those are made available.The recommendations set out fundamental change to outdated SAP and CL annual estimates, calculation of annual estimates to incorporate seasonal factors in rod catch, current River status methodology and decision processes. And a much longer term vision to harmonising and creating a common UK mainland conservation policy (England, Wales & Scotland). These involve extracting elements of our reporting and assessment procedures that were introduced in 2004 without validation or periodic QA review. And adoption of a Scottish style annual assessment review and river status/rod exploitation measure approach based on five year average or mean attainment to CL target.
3. New analytical and modelling techniques have been explored and developed for determining rod catch and run size estimates and the influence of principal factors that are presently contributing to inaccurate and uncertain River status “predictions or forecasts”. Emeritus Professor Brian Revell has lead that work and NW & Welsh rod fisheries have received papers on regional and individual River analysis of rod catch and simulations of changes to rod effort, river flows & cyclical patterns of 1SW/MSW. Brian`s work history is listed on page 3. The study explores two rivers, the Severn & Welsh Dee that are the subject of separate dialogue taking place with the EA & NRW that I am directing on behalf of PAAS & CPWF. The study provides a refreshing examination and in depth reasoned academic interpretation of factors effecting changing rod catch and ultimately run estimates. Something that has been missing in recent Byelaw consultation exchanges. The same analytical and modelling principles (given data source) could be applied to historic and predicted catch and run size estimates from threats and pressures that appear to fall below the radar as far as actually assessing stock impact.These might include rising ocean temperature, food source depletion, pelagic trawler impact, damage from aquaculture expansion and ingress from predation populations.
4. A new proposed format of accessible on-line River reporting data. This is currently being circulated to rod fisheries groups for consideration and comment. We would like to bring this forward as part of improvements to provide transparent and informed stock assessment data which will enable fisheries managers and national advisers to better track changes to applied estimates and rod catch/spawning assessments and trends.
A considerable amount of time has been spent in the last 12 -18 months in non productive exchanges as rod fisheries representatives sought acknowledgement of the need for improvement to systems and accuracy of historic assessments.
We would welcome a more progressive period of engagement and collaboration on systems and policy development, where our recommendations and research can and should be complimenting proposed review process and within communicated timetables. I have recommended to the Angling Trust that a small rod fisheries group is formed to present and review proposals.
This communication is for information purposes, unless further clarification or confirmation of progress is appropriate.
With best regards, Mike Ashwin
Chairman NWATFCC North West Angling Trust Fisheries Consultative Council
- NOTE from the editor. If you would like a copy of the report please email 1highplains@gmail.com and I will send you a .pdf
President
Allan Cuthbert Email: 1highplains@gmail.com
Strategy Officer
John Eardley Email: johneardley@btinternet.com
Conservation
Officer
Chris White
57 Normanby Drive
Connahs Quay Flintshire
CH5 4JX
Email:chriswhite.cohite@gmail.com
Re: Written Statement:
Agricultural Pollution Regulations
Dear Minister,
12 December 2019
I wrote to you on 10 December concerning the effect of the proposed
fisheries byelaws on rural communities. I was alarmed to see that on 11
December you issued a written statement
with respect to Agricultural Pollution Regulations in which you say that in
working with NFU Cymru to develop a water framework that this work “…has highlighted it may be possible to
offer a more flexible approach based on earned autonomy to deliver the same
outcomes compared to regulation”. I take it
that ‘earned autonomy’ means self regulation. This approach is contrary to that taken with respect to the proposed fisheries
byelaws where alternative solutions offered during consultation were dismissed
with NRW insisting that only legislation would achieve the desired result – it won’t.
It should also be noted that at the inquiry, under oath, we were
promised Agricultural Pollution Regulations which would prevent the frequent
pollution events we see on Welsh rivers and fish kills which far exceed any
damage to fish stocks caused by angling. The inspector for the inquiry referred
to this promise in his findings.
In line with your concession on agricultural pollution we would
therefore request a deferment of the proposed byelaws to enable those few Welsh
rivers which are not compliant with the NASCO recommendation of a voluntary 90%
C&R to achieve this target i.e. “…earned autonomy to deliver the same
outcome…”. Overall Welsh anglers achieve 86% C&R with many rivers meeting
or exceeding the NASCO 90% release rate through voluntary measures. We have
continually drawn your attention to the major reason for the decline in
migratory fish stocks and this is not due to angling. Perhaps you can extend
the courtesy of meeting with us so you may fully understand our concerns
something which you seem to have done with NFU
Cymru.
Regards
On
behalf of: Campaign for the Protection of Welsh Fisheries cc Mark Drakeford –
First Minister
CPWF has the
support of freshwater and sea anglers in Wales.
Visit our website
at www.cpwf.co.uk
President
Allan Cuthbert Email: 1highplains@gmail.coo.uk
Strategy Officer
John
Eardley
c/o
Vanner Farm & Caravan Site
Llanelltyd
Dolgellau
Gwynedd LL40 2HE
Email:
johneardley@btinternet.com
Conservation Officer
Chris White Email:chriswhite.cohite@gmail.com
9th December 2019
Dafydd
Elis-Thomas AM National Assembly for Wales Cardiff Bay
Cardiff CF99 1NA
By
email to: Dafydd.Elis-Thomas@assembly.wales
Copies to:
Charlie Abbott – Riparian Owner, Garreg Arw, Afon
Mawddach
Hywel Bromley Davenport – Riparian Owner,
Bryncemlyn & Gelligemlyn, Afon Mawddach
Meirion Hughes – Riparian Owner, Felin Newydd, Afon Wnion
Gavin Jones – Secretary, Dolgellau Angling Association
Andy Strickland – Secretary, Prince Albert Angling Society
Dear Dafydd,
I was proud to represent the majority of the angling interests on
the Afon Mawddach & Afon Wnion
at the All Wales Fishing Byelaws Inquiry held in January and March of this year
and am writing to you on behalf of
those same angling stakeholders today.
Key
evidence presented by the Objectors at the Inquiry was ignored by the Inspector
and this led to his report finding in favour of Natural Resources Wales and as
a result the Minister for Environment, Energy and Rural Affairs made a decision
to confirm the Byelaws which are due to come into force on 1st January
2020.
Last week I
attended a joint meeting of the Dee & Gwynedd Local Fisheries Advisory
Groups at Yr Hwb, Bala at which Clare Pillman, CEO of Natural Resources Wales,
was also present.
The meeting
brought into sharp focus the reality of the situation that we are now facing.
The enforcement officer responsible for North West Wales reported that the
current situation is a disaster with most of his team gone. Goodwill has been
lost and experienced staff who have left have taken their expert knowledge with
them. He stated that he had never known anything like this with 45% of the
reported incidents in Wales since July being from North West Wales and only 2
staff available to cover the whole area. He made a desperate plea to those
present for help. Unfortunately attendance at these meetings has been dwindling
for some time with many representatives feeling disenfranchised when their
legitimate concerns
CPWF
has the support of freshwater and sea anglers in Wales.
Visit
our website at www.cpwf.co.uk
are dismissed by
senior fisheries staff. As a result there was nobody present from nearby rivers
including the Dyfi, Dwyfawr and Glaslyn to hear his plea whilst many of those
who were present have become so disaffected that they will not go out of their
way to help.
The chair of the
Dee Fisheries Association reported that poachers are netting the Dee estuary
with impunity now that NRW are unable to carry out boat patrols. We have the
utmost respect for NRW’s hardworking Enforcement Officers but they simply
cannot cope in the current climate.
Given that NRW’s
figures demonstrate that a maximum of 2 salmon in every hundred in Wales (10
out of 500 in the case of the Mawddach & Wnion) is the somewhat paltry
number that will be saved by the All Wales Byelaws we are now facing a disaster
since fewer anglers means less of a deterrent, less intelligence for
enforcement officers, increased poaching and the loss of considerably more
spawning salmon than is currently the case. In short the Byelaws are
counterproductive. Today NRW are in receipt of documents which pose a serious
challenge to the salmon stock assessments used to inform the All Wales, Cross
Border Dee & Wye and Severn Emergency Byelaws and which indicate that
stocks are being considerably underestimated by the current methodology.
It was also
reported at the meeting that the Wales Fisheries Forum and its associated Plan
of Action for salmon and sea trout will do nothing to restore our stocks of
migratory fish. Those of us who are in opposition to the byelaws are working as
conservationists looking to protect our fisheries, and assist in restoring the
stocks of salmon and sea trout in our rivers.
NRW has previously informed us that those anglers who release
all of the fish they catch “will
note little difference under the new regime”. 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
“under the new regime” are denied access. The
very future of smaller community based angling clubs, together with the angling
tourism that they support, is very much under
threat.
We are at crisis
point and failure to take a step back and assess fully the current situation
will see Welsh Government preside over an unmitigated disaster for our stocks
of migratory fish and the fisheries which they support. We seek your support in
achieving that aim.
Should you
require further supportive evidence, or wish to discuss the matter further,
please do not hesitate to get in touch by either email or telephone.
Yours sincerely
John Eardley
Gwynedd Local
Fisheries Advisory Group Representative, Prince Albert Angling Society Strategy
Officer, Campaign for the Protection of Welsh Fisheries
President
Allan Cuthbert Email: 1highplains@gmail.com
Strategy Officer
John Eardley: Email: johneardley@btinternet.com
Conservation
Officer
Chris White Email:chriswhite.cohite@gmail.com
10 December 2019
Re: THE WALES ROD AND LINE
(SALMON AND SEA TROUT) BYELAWS 2017 Inquiry
Dear Minister,
At the recent joint (Dee/Gwynedd) Local Fisheries Advisory Group
meeting held in Bala the Chief Executive of NRW (Ms Pillman) attended to answer
questions on how NRW can carryout their statutory duties with respect to
fisheries and how the impending byelaws will reverse the decline in migratory
fish stocks. The first agenda item for the meeting was an update on enforcement
activity. The enforcement officer responsible for North West Wales reported
that the current situation with respect to enforcement is a disaster with most
of his team gone. With 45% of the reported fisheries incidents in Wales since
July being from North West Wales and only 2 staff available to cover the whole
area, he made a desperate plea to those present for help, sadly co-operation from
anglers is unlikely to occur due to the byelaws effectively stopping fishing on
many North Wales rivers.
I note in the
Labour manifesto that should they be elected in England Labour intends to: “Introduce a ‘rural proofing’ process so
that all our laws, policies and programmes consider their impact on rural
communities” and yet the Labour Government in Wales has ignored the impact
that the fisheries byelaws will have on rural communities and intend to
implement legislation which is effectively un-enforceable and will do nothing
to reverse the decline in migratory fish stocks.
In my previous correspondence I referred to the inquiry which
accused objectors of not presenting any evidence. The problem was the inspector
failed to understand the evidence we presented i.e. there are enough salmon and
sea trout spawning it is the in-river losses due to pollution and predation
which are the main issues (50% of smolts never get to sea). With respect to the
challenge on the statistical methodology
used by EA/CEFAS/NRW to determine conservation limits the inspector, at the
insistence of the NRW barrister, refused to admit this as evidence and
completely ignored this in his findings.
Over the past few months the North West Angling Trust Fisheries
Consultative Council with the assistance of Prof Brian Revel has been carrying
out further analysis of the methodology used by the EA/CEFAS/NRW in assessing
the river stock levels and the findings have now been presented to NRW and the
other agencies to demonstrate the flaws in their statistical analysis and how
the data has been skewed
CPWF has the
support of freshwater and sea anglers in Wales.
Visit our website
at www.cpwf.co.uk
by ignoring certain variables i.e. drought/flood, reduction in the
number of anglers fishing etc. We can provide copies of the relevant documents
should you so wish.
Since the salmon season closed anglers have been reporting salmon
ascending the Dee/Conwy in large numbers, there is no exploitation of these
fish and they are therefore not included in the calculation of conservation
limits. Photographs of these fish ascending barriers are available if required.
It is unclear how your instruction to NRW to produce a ‘Plan of
Action for salmon and sea trout’ will help in reversing the decline in
migratory fish stocks. We have had various ‘Salmon Action Plans’ over the past
20 years none of which has reversed the decline. The key feature from most LFG
workshops for input into the Plan of Action identified fish eating birds
(FEB’s-mainly goosander) as a major contributor to the decline in fish stocks
on Welsh rivers. To put this into perspective according to the NRW FEB forum
there are 305 pairs of nesting goosanders in Wales (610 goosanders). Each of
these birds consumes 400gm of fish per day and assuming they are resident all
year these birds will consume circa 90 Tonne of fish per year. In addition
there are an estimated 5,394 overwintering goosanders in Wales all consuming
fish. It should not come as surprise therefore that fish numbers in Wales are
in decline – goosanders used to be rare but have now established themselves in
the UK, they are not a native bird but since the 1950’s have become
‘naturalised’. It is interesting to note
that according to the Wetland Bird survey goosanders are in decline probably as
they have eaten all the available fish!
I would yet again request a meeting with you to discuss this issue,
I accept that this is low on your agenda and you have to take advice from your
advisors but your electorate deserve a chance of putting their case to you, at
least Ms Pillman faced her stakeholders and listened to our concerns. We are
all working to reverse the decline in migratory fish stocks, this is about
conservation and not more fish for anglers to catch; the byelaws will simply
drive a wedge between anglers and NRW and is unlikely to reverse the decline.
After 25 years of restrictions on the Wye and millions of pounds spent on
restoration/barrier removal there has been no noticeable improvement in
migratory fish stocks, the 2019 salmon catches on the Wye are the lowest in
recorded history with only 344 reported salmon caught by anglers.
As Prof Lynda Warren said at the 2015 NRW Board meeting held at
Clawdd-Newydd extending restrictions which have been demonstrated not to work
is futile and yet this is the route being taken by NRW. Anglers are not the
problem; we are just being used as a scapegoat to detract from the failure of
agencies to address the root causes.
Regards
Chris White
Conservation Officer: Campaign for the Protection of Welsh Fisheries
cc Mark Drakeford – First Minister
Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for Environment, Energy and Rural Affairs
Ein cyf/Our ref LG/07443/19
Llywodraeth Cymru Welsh Government
John Eardley johneardley@btinternet.com
%r Hrfiudl c)o
November2019
Thank
you for your letter of 13 November, garding
my previous response to you under LG/07251/19.
I apologise the attachrne.i:it{cited was not provided.
It is now attached for you
to consider alongside my answers to your original questions.
I note you have raised a
further question in your most recent letter on my previous decision to decline
invitations to meet and discuss the All Wales byelaws. During the course of the
Inquiry I declined all meeting requests on this matter to ensure no bias was
provided to any particular individual or group ahead of the final report.
I hope moving forward
the joint work to develop
the Plan of Action will contribute to restoring
the relationship between
Natural Resources Wales and stakeholders. My officials will also be contributing to these efforts and will
keep me informed on future developments.
lour0 0 Lf\ Gl 1-LLLj
Lesley Gri iths AC/AM
Gweinidog Amgylchedd, Ynni a Materidq g,wledig Minister for En· errt, Energy
and Rural Affairs
Bae Caerdydd • Cardiff Bay
Caerdydd • Cardiff
CF99 1NA
Canolfan Cyswllt Cyntaf / First Point of Contact Centre:
0300 0604400
Gohebiaeth. Lesley.Griffi ths @ll yw.
cymru Correspondence.Lesley.Griffi ths @gov.wales
Rydym yn croesawu derbyn gohebiaeth yn
Gymraeg. Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg ac ni
fydd gohebu yn Gymraeg yn arwain at oedi.
We welcome receiving correspondence in
Welsh. Any correspondence received in
Welsh will beanswered in Welsh and
corresponding in Welsh will not lead to a delay in responding.
13th November 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/07251/19 dated 28th October. Whilst further dialogue seems
somewhat futile there are nevertheless certain points which require a response.
“NASCO
guidance states (document also attached):
‘The decision as to whether, and if so where and
when, catch and release is appropriate, should be made by those managing the
specific fishery concerned in the light of all the known factors about that particular stock.
The publication of these guidelines and their adoption
by NASCO does not imply
that NASCO endorses catch and release in any
particular circumstances.’”
Since there was no document attached
to your letter we remain in the dark regarding the source of this
statement, particularly as it is conspicuous by its absence
within the key document CNL(14)71 NASCO Implementation Plan for the period
2013-18 EU – UK (England and Wales).
- For those rivers in Wales with a
mean catch of less than 20 salmon it is difficult to see how you can be “content (that)
the All Wales
Byelaws are consistent with the principles and guidance developed by NASCO” when, as we have previously pointed out, NASCO
states that voluntary and not mandatory measures should be promoted on
those rivers.
- In your response to our request for deferment of the
All Wales Byelaws for a year, in order to allow for the promotion of voluntary
measures you make reference to your “discussions
with many officials and stakeholders” and yet
every reasonable request that has been made by angling stakeholders for
a face to face meeting with yourself in order to fully explain
our concerns has been met with point blank
refusal.
- Your statement “Most
local angling clubs are already operating with a high rate of voluntary catch and release measures.
Therefore, only a small percentage of anglers might be deterred from visiting
and participating in angling, when the new Byelaws come into force” fails
to recognise the different response by anglers to voluntary and mandatory
measures. We reiterate our original statement: “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”
- With reference to the Dee and Conwy it is again difficult to see how you can be “content (that) the All
Wales Byelaws are consistent with the principles and guidance developed by NASCO” when
both
rivers are fully
compliant with NASCO Policy in meeting their voluntary targets and yet you seek
to impose mandatory measures and in so doing further alienate angling
stakeholders.
- You also make reference to the fact
that “NRW have adequately recognised the
benefits of voluntary catch and release
measures and they have engaged
appropriately with stakeholders in promoting these over the past 5 years, as an
attempt to bring in a voluntary solution” and yet at the NRW Board Meeting on 18th January 2018 there was clear
recognition by both the board and executive that they had “failed to engage properly with stakeholders” in developing the All
Wales Byelaws.
Since July 2015 there has been a constant
refusal by NRW to even begin to discuss the options for a voluntary solution and we are now met with further
intransigence from Welsh Government. The leader of the UK Labour
Party spoke last week of a “government
that’s on your side “and “real
politics is about ‘bringing people together to stand up for their community’”.
In the context of the All Wales Byelaws those words have a very hollow ring to
most of us in the angling community.
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
Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for
Environment, Energy and Rural Affairs
Ein cyf/Our ref LG/07251/19
Llywodraeth Cymru Welsh Government
John Eardley, Dr Robin Parry, Mervyn Williams
johneardley@btinternet.com
28 October 2019
Thank you for your letter of 18 October,
regarding my response
to you under LG/06996/19, to
your concerns about my decision to approve Natural Resources Wales’ (NRW) ‘All
Wales’ Rod and Line (salmon
and sea trout)
byelaws. I will address the points raised
in your letter in the same
numbered order.
- NASCO guidance states (document also attached):
‘The
decision as to whether, and if so where and when, catch and release is
appropriate, should be made by those managing
the specific fishery
concerned in the light of all the known factors about
that particular stock.
The publication of these guidelines and their adoption
by NASCO does not imply that
NASCO endorses catch and release in any particular circumstances.’
The
lines above confirm NASCO do not endorse catch and release measures in
particular circumstances but the decision on whether to introduce such measures
resides with those specifically managing the
fishery. The authority with the power
to make this decision in Wales,
is NRW. On this basis, I am content NRW as the manager of the specific
fisheries for Wales, are therefore not breaching or
contravening NASCO policy.
As previously explained, NRW have
promoted voluntary catch and release measures since 2014 and 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. I have therefore confirmed the All Wales byelaw proposals put forward by NRW to make it a mandatory measure to practice
catch and release and these byelaws will come into
force from 1 January 2020.
Bae
Caerdydd • Cardiff Bay
Caerdydd • Cardiff
CF99 1NA
Canolfan Cyswllt Cyntaf I First Point of Contact Centre:
0300 0604400
Gohebiaeth .Lesle
y.Grif fit hs@ll yw.cymru Correspondence.Lesley.Griffiths@gov.wales
Rydym yn croesawu derbyn gohebiaeth yn
Gymraeg. Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg ac ni fydd
gohebu yn Gymraeg yn arwain at oedi.
We welcome receiving correspondence in Welsh.
Any correspondence received in Welsh will be answered in Welsh and corresponding
in Welsh will notlead to a delay in responding.
- I acknowledge your request for all rivers in Wales with a
mean catch of less than 20 salmon, to be excluded from the All Wales Byelaws.
However, I am content the All Wales Byelaws are consistent with the principles
and guidance developed by NASCO and voluntary catch and release
efforts have already
been promoted across rivers within Wales (as per my
response under point 1). These rivers shall therefore remain under the All
Wales Byelaw regulations.
- My position on a deferment
of the All Wales Byelaws for a year, in order to allow for the promotion of voluntary measures,
remains the same. I have reviewed both the Inspector’s recommendation report
following the inquiry and the recently published stock assessments and from
discussions with many officials and stakeholders, I believe such these measures
are necessary in response to a wide scale decline in fish stocks for both
salmon and sea trout.
Most local
angling clubs are already operating
with a high rate of voluntary
catch and release measures.
Therefore, only a small percentage of anglers might be deterred from visiting
and participating in angling, when the new Byelaws come into force.
NRW’s byelaw
proposals sit outside
the requirements to provide compensation under section 212 of the Water Resources Act 1991 and this was
addressed within their evidence submitted to the inquiry, under document APP49.
If owners or occupiers believe they are injuriously affected by the Byelaws once they’ve come into force, then under the
Water Resources Act 1991, compensation may be
sought.
With
regards to your last bullet
under point 3 relating to the rivers
Dee and Conwy, I am of the same opinion for those rivers,
as my answer provided in point 2 above.
Finally, I believe NRW have
adequately recognised the benefits of voluntary catch and release measures and
they have engaged appropriately with stakeholders in promoting these over the
past 5 years, as an attempt to bring in a voluntary solution. Unfortunately, at
present, voluntary measures
alone are not enough to reverse the decline in salmon and sea
trout.
I hope you and all anglers
will take the opportunity to contribute to the Salmon
and Sea Trout Plan of Action, ahead of the byelaws coming into force
on 1 January 2020. The purpose of the Plan of Action is to set out all the current
work being taken forward to restore salmon
and sea trout stocks
and, in addition, to identify
any new issues or gaps and the actions needed to address them.
U1
Lesley
Griffiths AC/AM
Gweinid g
yr Amgylcheqd’ , Ynni a Mat rion Minister fM nvironmerfl, Energy and Rbi:avn
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
Lesley Griffiths AC/AM
Gweinidog yr Amgylchedd, Ynni a Materion Gwledig Minister for
Environment, Energy and Rural Affairs
Ein cyf/Our ref
LG/06996/19 John Eardley johneardley@btinternet.com
Llywodraeth Cymru Welsh Government
t5 October 2019
Thank
you for your letter of 27 Septem r, regarding North Wales angling
representative’s concerns about my decision to approve Natural
Resources Wales’ (NRW) ‘All Wales’
Rod and Line (salmon and sea trout) byelaws.
In common
with other parts of the UK and Europe, salmon and sea trout stocks
are declining in Wales. To avoid stocks falling to unsafe levels,
which may lead to stock collapse, we must take action now.
The majority
of anglers in Wales (86%) already voluntarily return the salmon
they catch and this number is increasing which is
very encouraging . This demonstrates the care and
respect anglers show for salmon and their wish to protect them for the future. 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.
I understand some anglers
were disappointed by my decision to approve the byelaws, but please be assured it was not taken lightly.
I would encourage
you and all anglers to take the opportunity to contribute to the
Salmon and Sea Trout Plan of Action which I have tasked NRW to produce together
with stakeholders ahead of the byelaws coming into force on 1 January 2020.
I note your request for
the introduction of the byelaws to be deferred by a year. 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. As a
result, a deferment is not an option I am willing to consider.
Bae
Caerdydd • Cardiff Bay
Caerdydd • Cardiff
CF99 1NA
Canolfan Cyswllt Cyntaf I First Point of
Contact Centre:
0300 0604400
Gohebiaeth .Lesley. Griffi ths @ll yw.cymru Corresp ondence.Lesley. Gri ffi ths @gov.wales
Rydym yn croesawu derbyn gohebiaeth yn
Gymraeg. Byddwn yn ateb gohebiaeth a dderbynnir yn Gymraeg yn Gymraeg ac ni
fydd gohebu yn Gymraeg yn arwain at oedi.
We welcome receiving correspondence in Welsh. Any correspondence
received in Welsh will be answered in
Welsh and corresponding in Welsh will not lead to a delay in responding.
I am content these byelaws are consistent with the principles and
guidance developed by the North Atlantic Salmon Conservation Organisation (NASCO) and follow
a precautionary approach in
response to the poor status of stocks in Wales. At a time when every fish is
important, the byelaws will provide
clear, enforceable measures
to protect salmon
and sea trout whilst at the
same time allowing angling continue.
Lesley Griffiths
AC/AM
Gweinidog yr Amgylchedd, Ynni a
Materion Gwledig Minister for Environment, Energy and Rural Affairs
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