25 July 2019

Re: THE WALES ROD AND LINE (SALMON AND SEA TROUT) BYELAWS 2017 Inquiry

Dear Minister,

On behalf of the 21 Welsh fishing clubs which I represented at the inquiry and all those who presented on behalf of CPWF I wish to appeal your decision to impose the fisheries byelaws on all Welsh rivers. 

The decision structure used by NRW to justify the byelaws was based upon poor fry and parr counts in 2015 following severe flood events which depressed the recruitment of migratory fish in many UK rivers, not just in Wales.  Since 2015 there has been a marked improvement in migratory fish recruitment however the poor results in 2015 skewed the statistical analysis indicating, via a Bayesian regression line, that most rivers would be ‘at risk’ in 2019/20 whereas runs of salmon and sea trout in 2019 have been above average on many rivers in Wales. 

You base your decision upon the inspector’s opinion that the byelaws are necessary, proportionate and reasonable I have the following comments:

1. Byelaws are necessary

There is no dispute that migratory fish stocks in most UK rivers have declined over the past 40 years but the proposed byelaws will do little or nothing to reverse this decline, this is accepted in the NRW Technical Case and is clearly identified in the inspectors report at 698:

“NRW accept there is a range of factors that contribute to the decline of salmon and sea trout and recognise that anglers are not primarily responsible. However, due to the severity of the depletion of the stocks, the killing of fish is unsustainable and contributes to the problem. It is only reasonable therefore that anglers and netsmen play their part in the solution.”

As stated above the NRW data is based upon the 2015 poor fry and parr counts due to flood events, there is a natural variability of migratory fish recruitment depending on water conditions, 2018 fry and parr counts have been the highest on record for several years demonstrating this natural variability. 

For our part anglers have over the past 20 years or so voluntarily returned an ever increasing proportion of the salmon they catch.  Pan Wales in 2017 this voluntary catch and release resulted in 86% of salmon being returned and is still improving.   The opinion of the inspector is that the need for legislation is essentially to address the 12% of the anglers catching any salmon who killed them during 2017 and emotively the inspector infers that these anglers kill every fish they catch.  The reality is that 75% of the 12% of anglers who killed a salmon only caught one salmon.  The NRW data shows that in Wales during 2017 only eight anglers reported killing more than two salmon – this is hardly excessive and hardly depletes the stock of salmon bearing in mind that anglers, at most, only catch 20% of the salmon which enter a river i.e. there are 80% left to spawn even if every angler caught fish was killed.  As I explained at the inquiry it is the survival from egg to smolts reaching the sea which is the main issue, the inspector makes no reference to this and it is ignored in his report.  The in-river losses are primarily due to pollution events, avian predation and flood/climatic conditions none of which have been adequately addressed or acknowledge in the inspector’s report other than claiming that NRW has proposed a suite of land management measures which may or may not address the issue, if and when they are implemented.

Evidence from byelaws which were introduced on the Wye in 1995 restricting the use of bait, followed in 1998 with a National Byelaw with compulsory Catch & Release for spring salmon up to the 16 June and a total ban on killing salmon from 2012 onwards has seen little or no reversal in the decline of migratory fish, in fact the Wye 2018 catch was less than 50% of the 5 year average and 2019 looks similar.   

The National Spring byelaw was imposed for a period of 10 years, this was extended for a further 10 years until 2018 and has recently been extended for a further period of 10 years until 2028.  The spring byelaws and those on the Wye indicate that method restrictions and catch and release have not worked over the past 20 + years and yet NRW considers method restrictions and catch and release to be appropriate even though it can be shown that this approach is not working. 

The byelaws do not address the root cause of the decline in migratory fish stocks; they are simply a way of diverting attention away for the root cause and the failure over the past 30 + years to address this.  Anglers are just being used as a scapegoat despite the majority of salmon anglers voluntarily returning all of their fish.  The inspector claims that catch and release is just a philosophical issue as the majority are already practicing this and mandatory catch and release is to level the playing field of the minority who kill salmon.  Catch and release is not the major issue it is the imposition of method restrictions which will effectively prevent fishing on small spate rivers in Wales. 

To date there has been little or no action by the various predecessor agencies or NRW to identify and take steps to reverse this decline despite a statutory duty to maintain, improve and develop fisheries.  The lack of positive action has primarily been due to budget cuts to fisheries work over many years.

The claim at the inquiry that a suite of land management measures to improve the environment i.e. proposed agricultural pollution legislation, is in support of the byelaws is not true, it is just a happy coincidence.  The land management reforms came about due to the pressure on the Welsh Government by Afonydd Cymru some three years after the NRW byelaw proposals were published.  The proposed byelaws were, at that time, ‘standalone’ based on the NRW Technical Case using data from poor fry and parr counts following several years of significant flood events which depressed migratory fish recruitment.  Had pressure not been put on the Welsh Government nothing would have been done to address one of the major contributors (agricultural pollution) to the decline in migratory fish stocks.  It is just convenient to claim these agricultural pollution controls are in support of the byelaws it remains to be seen if the proposals will be implemented let alone have any effect. 

• Byelaws are proportionate

In terms of proportionality there are probably only four rivers that are at significant risk due to decline in migratory fish numbers i.e. Tywi, Teifi, Taff and Ely.  In the case of the Tywi and Teifi a significant cause of the decline is agricultural pollution.  The Taff and Ely are in decline due to the effect of the Cardiff Bay barrage. 

It cannot be judged proportionate to apply the same restrictions to at least three rivers which achieved more than 200% of their Conservation Limit (CL) in 2017 to two rivers which achieved less than 10% of their CL during the same year.  We argued at the inquiry that each river should be addressed on an annual basis as happens in Scotland.

The NASCO policy is that all monitored salmon rivers and their conservation action measures are defined by each rivers ‘Risk Classification’ status. This requires rivers declared as ”At Risk” and “Probably at Risk” to request that rod fisheries meet a target for catch and release of 90% by voluntary means  in their first year. Only where these targets are not met should mandatory measures be considered and deployed.   There is clear evidence of many rivers in Wales reaching or exceeding this 90% voluntary catch and release target and many are in the high 80% i.e. heading in the right direction by voluntary means.  There are also indications that the fry and parr counts in several rivers since 2015 have been improving as there have been few flood events to depress recruitment.

The inspector has completely dismissed all the objectors concerns despite the overwhelming evidence that the byelaws will not reverse the decline.  This is what the inspector reported at 695 in his report which demonstrate his dismissive attitude of our genuine concerns:

“The proposed byelaws solution to the decline in fish stocks included mandatory C&R, method restrictions, bait bans/restrictions, slot limit, and seasonal restrictions. There was no convincing arguments that the raft of measures contained within the proposed byelaws were not appropriate, reasonable and proportionate.”

It is disproportionate to apply regulations on anglers and yet positively encourage adventure activity over spawning grounds between November to the end of December.  The continual disturbance of spawning fish by paddlesport causes more damage to recruitment than an angler taking an occasional salmon.  If the fish are driven from their spawning site they cannot spawn and there will be no fish in the river.  The RSPB would not tolerate the continual disturbance of nesting birds even when they are not in decline and yet NRW positively encourages such disturbance through the information they provide on their website.  Whilst the advice may be applicable on some sections on large rivers such as the Wye/Severn/Dee this is not the case on most small spate rivers or over known spawning sites.  There is a closed season for fishing for a good reason i.e. to enable fish to spawn in peace.  If the precautionary principle is to be applied to anglers then the same must also be applied to paddlesport.  This is something I have been trying to get under control on our North Wales rivers for more than 10 years.  Whilst disturbance of spawning fish is an offence under the Salmon and Freshwater Fisheries Act it has to be proved that the disturbance is done ‘knowingly’ i.e. with mental intent.  The advice given to paddlesport enthusiasts on the NRW website ensures that disturbance is not done ‘knowingly’ and therefore it is difficult to prosecute.  There have however been successful prosecutions of paddlesport enthusiast in the past. 

At 698 in the report the inspector makes the following statement: “…It is only reasonable therefore that anglers and netsmen play their part in the solution.” The UK Government (this includes Wales and Scotland) agreed with NASCO to remove all netting of migratory fish by 2020 and whilst netsmen fish on a commercial basis killing their catch this does not apply to recreational fishermen.  It seems that in order to remove the nets NRW is prepared to penalise anglers simply to demonstrate proportionality.  The removal of the nets on the Clwyd some 20 years ago and the Dee some 10 years ago has seen no improvement in migratory fish stocks and a continuing decline in the conservation limits on both rivers. 

• Byelaws are reasonable

It is not reasonable to impose method restrictions on Mid, South West and North Wales rivers which are traditionally fished with bait as alternative methods are unsuitable due to the nature of the rivers.  Implementation of these byelaws will effectively close many of the fishing clubs in Mid, South West and North Wales as they have for generations been primarily fished with bait and are not generally suitable for other fishing methods. 

There is much talk in the Welsh Government of the rich heritage in Wales and yet you are prepared to preside over closure of local community fishing clubs.  These local fishing clubs provide a way of engaging young and old alike which meets The Well Being of Future Generations (Wales) Act 2015 however due to your decision the opportunity to fish in their local rivers will now be removed from many of these communities. 

It is clear in the inspector’s report that he has simply taken note of NRW’s claims that these communities can take up ‘coarse fishing’ (at Para 245 and 626).  Except for the three major cross border rivers there are no coarse fishing opportunities in the small spate rivers of Mid, South West and North Wales.   It was interesting to note that the inspector refers to the byelaws reducing the mortality of Twaite and [Allis] Shad (at Para 19 iv). These fish are rarely found in any Welsh rivers other than in the Wye. 

During the inquiry I had requested that the inspector visit North and Mid Wales rivers during the recess in order to see the differences in rivers and the way they are fished in order to fully understand our objections, this was refused without explanation.  It would be normal under a planning appeal for the inspector to make a site visit to understand objectors’ concerns.

As mentioned in 2 above there is an urgent need to protect spawning fish from disturbance by paddlesport and other invasive activities.  To impose restrictions on anglers and ignore the damage done by other river users is unreasonable.

General Comments

In your written statement on 16 July you say:

“I will, therefore, be asking NRW to take the lead on working with stakeholders to bring together all the current work being taken forward by all relevant parties in a Salmon and Sea Trout Plan of Action.  The Welsh Government will be contributing to this, as I hope will anglers and supporters of angling”.  

The expectation that stakeholders and anglers will co-operate with NRW in developing a Salmon and Sea Trout Plan of Action is unlikely to gain much support.  This is just adding more insult to injury as for more than 20 years we have been trying to get EA(W) and NRW to take some positive action to reverse the decline.  Anglers on the rivers are well aware of what needs to be done but Government Budget cuts to fisheries over several years have allowed the situation to deteriorate to its present state, your proposals whilst well meaning are too little too late. 

Recent changes to the NRW management structure now mean there is no dedicated fisheries department and much of the work will now be passed to Rivers Trusts (via Afonydd Cymru) to carryout relying in many cases on volunteers who will be disaffected by these byelaw proposals. 

It is disappointing that despite our frequent requests you have refused to meet with us, had you done so we may well have avoided a costly inquiry by working with WG/NRW and stakeholders to provide a solution which will continue to enable local community angling clubs to operate whilst a solution is found to reverse the decline.  As accepted in the inspectors report the byelaw proposals will not achieve this.  

The Inquiry procedure

You will be aware that I had challenged, prior to the commencement of the inquiry, the way the inquiry was to be run i.e. the use of the Planning Inspectorate and the Planning Appeals Procedure and why this was classed as a ‘Local Inquiry’ when it was to be applied to every river in Wales. 

On the appointment of the inspector for the above inquiry I undertook a Google search on Mr Beggan and found a reference in the public domain from Landmark Chambers a London law firm who were publishing their success in defending a planning appeal, representing NRW claiming the inspector, Mr Beggan, had found in favour of NRW based upon the ‘precautionary principle’.  Whilst the link still exists on Google access to the Landmark Chambers servers has since been removed (we have a copy on file).

With this in mind we were most concerned to discover that the planning Inspector appointed by Welsh Ministers had apparently sat as adjudicator in a planning appeal action brought by NRW in a case which we believe to a large extent turned as in the instant upon the doctrine known as The Precautionary Principle. In that case the Inspector apparently sided with NRW.  Our concern is not that there has been bias but that this inquiry has manifestly demonstrated the appearance of bias in favour of NRW as we shall address below.

You will be aware that the byelaw proposals by NRW which will restrict catch methods have been robustly opposed by the angling community in Wales.  Indeed, the level of opposition required you to hold an inquiry to determine whether they should be accepted by your Government.

As you are aware, we have previously expressed our concern that you chose to utilise an appeal procedure conducted by a planning inspector under planning legislation rather than an independent Public Inquiry conducted by an independent and impartial adjudicator.  The procedure under the planning legislation is designed to address a local issue not a pan Wales issue affecting your electorate across Wales.

Notwithstanding our concerns you proceeded to pursue your inquiry using the Planning Inspectorate, a department which you have responsibility for.  Utilising a planning appeal procedure and appointing an inspector who had previously supported an NRW appeal based upon environmental concerns.

Our concern is that Welsh Ministers have proceeded to utilise the planning appeals procedure as a device to try and procure a favourable outcome for its Agency NRW rather than a truly independent inquiry.  Instead an Inspector who has apparently previously found in favour of NRW advancing the Precautionary Principle and with no known expertise in fisheries or their management was appointed.

The subsequent process has adopted an adversarial instead of an inquisitorial approach the manner of which has attracted previous complaint and of which you have dismissed out of hand.

Given the highly contentious nature of this inquiry we are surprised that this association i.e. the inspector previously supporting NRW would have been concealed from CPWF and the general public by both NRW and yourself had we not made diligent enquiries.  We would perhaps have expected in the interests of fairness and transparency to have been consulted as to whether we objected or consented to the appointment of the inspector.  We were not and instead our concerns to you about how the inquiry was to be conducted have been dismissed.

Be that as it may we submit that, given the fact that the Inspector has supported NRW in the past on such a narrow point, that there was a real risk of bias or at least the appearance of bias in these proceedings should these facts be known to a member of the public observing proceedings.  The dismissive nature of the inspector’s report with respect to our objections tends to reinforce our concerns of bias.  Given the inequality of arms of the State and its agents facing unrepresented members of the public this omission is we submit indefensible.

Finally, it is painfully apparent that those representing NRW had been accommodated by the inspector throughout this inquiry to ensure the most favourable conditions in which to present its case.

We remind you that we are not the Appellants bringing an appeal, this was an inquiry into proposals the recommendations upon which you have relyed upon to make your final decision. This process has throughout been unfair and demonstrated the appearance of bias in favour of NRW.

Regards

Chris White

Conservation Officer: Campaign for the Protection of Welsh Fisheries

Marine and Fisheries Division

Environment, Energy and Rural Affairs 

16 July 2019

Dear Mr Eardley,

I would like to update you on the outcome of the Local Inquiry relating to Natural Resources Wales’ (NRW) proposed Byelaws for Salmon and Sea Trout.  The Planning Inspectorate concluded the Inquiry and provided the Minister for Environment, Energy and Rural Affairs with a final report on 3 June, which has today been published along with a Ministerial Written Statement outlining the Minister’s final decision.  The statement and a copy of the Inspector’s Recommendation Report can be found at the following link:

https://gov.wales/written-statement-outcome-local-inquiry-natural-resources-wales-proposed-all-wales-salmon-and-sea?_ga=2.35170979.380425072.1563178964-1735457580.1537351409

It is clear to see, from the Report, the depth of feeling and passion on both sides. It is also clear to see there is common ground, between all sides, that Salmon and Sea Trout stocks in Wales have been suffering an ongoing decline.  It is therefore generally agreed there is a problem.  There is also an acceptance, as a matter of principle that its important stock levels do not fall to unsafe levels, and declines need to be reversed.

Having reflected on all the evidence and arguments put forward, the Minister agrees with the Inspectorate; the Byelaws are necessary, proportionate and reasonable in view of the decline of Salmon and Sea Trout stocks throughout Wales.  She has therefore decided to confirm the Byelaws, and for them to come into force on 1 January 2020.

However, she was also struck by the arguments put forward by many of those who attended the Inquiry and acknowledges angling is only one of many interventions which affect the survival of Salmon and Sea Trout. 

The impact of agricultural pollution was raised as a major concern during the Inquiry.  In November 2018 the Minister issued a Written Statement which will introduce regulations to tackle agricultural pollution.  The proposed regulations are expected to come into force in January 2020 and will provide greater protection for water quality from excessive nutrients.

Other concerns raised include obstructions to migration, water abstraction and robust enforcement activity.  The Inquiry showed NRW and others are already carrying out a great deal of work on these areas, however, the detail of these actions is not always shared with the public and not readily accessible.  For this reason the Minister has asked NRW to take the lead on a Welsh specific plan of action for the protection of Salmon and Sea Trout, working with stakeholders, including anglers.  It will pull together all the current work being taken forward by all relevant parties, as well as identify gaps and actions to address these.  Welsh Government officials will work with NRW to contribute to this, as I hope will anglers and supporters of angling.

We expect the plan of action to be made public and shared with anglers, and other interested parties, before the Byelaws come into force on 1 January 2020.

Calling for a Local Inquiry was not a decision the Minister took lightly, however, it was necessary and many lessons have been learnt.  Going forward, we will work with NRW to improve effective, meaningful and collaborative engagement with interested parties from the onset.

I hope you will take the opportunity to engage in this work to achieve our shared goal of addressing the decline in Salmon and Sea Trout stocks in our waters.

Yours sincerely

Gareth Bevington

Deputy Director

Marine and Fisheries Division / Is-adran Môr a Physgodfeydd

Deputy Minister for Housing and Local Government

Ein cyf/Our ref DC/HB/05335/19

Mr W G Davies Chairman

Merthyr Tydfil Angling Association w.gary.davies@sky.com

12 June 2019

Dear Gary,

Thank you for your letter received on 3 June, on behalf of Merthyr Tydfil Angling Association, regarding an invitation to meet.

Access to inland water has long been a contentious issue with both user communities passionately believing that they are in the right, both legally and morally. These highly polarised views have hindered efforts to reduce the conflict between users to date. I believe that access to water now needs to be considered as part of a wider approach, not in isolation. We need to broaden the debate and ask what Wales wants from its inland waters, and the role that access rights have in delivering this.

To try to resolve this stalemate, I have asked the National Access Forum to give particular priority to laying the ground work for greater dialogue on inland waters issues that is needed. I am also seeking specialist advice from Natural Resources Wales, who are the Government’s advisers on access matters which will include possible non-legislative approaches. However, I recognise that options may be limited given that we have tried to promote VAAs (Voluntary Access Agreements) before, with little take-up.

I strongly feel that the long term answer needs to come from stakeholders and have encouraged them, through my Written Statement, to find a practical joint solution. I hope that by focussing on what we share, rather than our differences, may help to find solutions and reach some form of consensus.

Should I not be satisfied of reasonable progress within 18 months, I plan to consider future legislation on access to water. However, at this stage I do not have a set view of what any such legislation would look like.

Bae Caerdydd • Cardiff Bay

Caerdydd • Cardiff

CF99 1NA

Canolfan Cyswllt Cyntaf / First Point of Contact Centre:

0300 0604400

Gohebiaeth.Hannah.Blythyn@llyw.cymru Correspondence.Hannah.Blythyn@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.

Yours sincerely,

Hannah Blythyn AC/AM

Y Dirprwy Weinidog Tai a Llywodraeth Leol

Deputy Minister for Housing and Local Government

Joel Rees Jones, of NRW, has been good enough to share the various reports relating to the smolt tagging experiment currently in its final year on the head of the River Dee click here for link.

As I am away next week following discussions with the key CPWF objectors I have sent the attached letter to the Minister this evening (and received acknowledgement of its receipt). 

I am not sure if this will make any difference and expect to receive the standard ‘I can’t comment until I receive the Inspectors report’ reply from the Minister.  However by sending this now it raises concerns about the way in which this sham of an inquiry has been handled.  We cannot of course know what the Inspector will recommend and the fact that he has requested extra time tends to signify he is struggling due to his lack of understanding of fisheries issues.  The risk here is that he will use the precautionary principle to justify his recommendations whilst recognising our valid arguments but we will have to wait until his report is sent to the Minister, hopefully we will get a copy before any decision is made, it is up to the Minister to agree to release the report to us as soon as she receives it.

In terms of the decision process as this is new legislation, the proposals cannot be considered as a byelaw as this is not a local issue i.e. it is an All Wales Fisheries Regulation and therefore has to follow the same route as any other legislation.  In addition it will be necessary to repeal the existing local fisheries byelaws – all 10 of them.  Having looked at the WG process for introducing new legislation my understanding is the Minister has to present her recommendations for new legislation to the Assembly and these are scrutinised by one of two legislative committees before being passed back to the Assembly for approval, the Assembly website says this can take up to 40 days.  Once approved by the Assembly the legislation has to be sent for Royal Assent.  As the inspectors report is now not due until 3 June it is unlikely that the byelaws if approved would be in place before August bearing in mind there is also a summer recess of the Assembly.  My previous request for the Minister to delay any fisheries legislation until 2020 has so far been rejected. 

I have attached an email from the Rev Paul Cawthorn which you should read as it covers most of our concerns.  It seems that in his meeting with NRW (Gough and Mee) in Dolgellau Paul was told that if the decision goes against NRW they will apply for emergency measures but they did not quantify where these would apply, there are still issues we will have to fight whatever happens.

Feel free to circulate this to your members and AM’s

Chris

Attendees

Agenda Items

1. Welcome and Introductions (Ruth Jenkins)

Ruth welcomed everyone to the second meeting of the forum and reviewed the action items from the previous (inaugural) meeting.  The draft minutes will be available on the NRW website once approved.

The reorganisation within NRW will be completed by July.  The new structure will move from 10 areas down to 6.  There will be more people working on the freshwater environment although there will be no increase in fisheries staff.  There is difficulty in recruiting fisheries staff and there is a lack of experienced fisheries officers in NRW it was suggested that fisheries officers could train other members of their team in fisheries issues. 

Mark Lloyd updated how the Virtual Bailiff scheme is working in England, there are 500 volunteers carrying out patrols (7/8 are ex police officers) but Mark emphasised that this was a ‘hands off’ operation feeding intelligence to the EA and Police.  Mark considers this has worked well and it is feasible to extend this to Wales.

The head of Inland Fisheries (Jeremy Frost) for WG either resigned or retired at the end of April, this seems to have been unexpected and Luke Davies is now covering this role for WG until a successor is found. 

Membership of the Forum was discussed and to keep the numbers to a manageable size it was suggested that existing members liaise with their local LFG’s and represent them at future meetings.  This is already happening in North and South Wales but it was recognised that West Wales did not have any contacts on the forum.  It was suggested that a member from the Carmarthenshire Fisheries Federation be invited to join the group.  It was also suggested that Welsh Water become a member.

• Area Statements

John Clark presented an overview of the area statements which are an EU requirement and has now replaced the River Basin management plans.  The plan is to have the area statements completed by March 2020.  The area statements are The State of Natural Resources Report (SoNaRR 2) which is the Assessment of the Sustainable Management of Natural Resources within Wales this includes requirements under the Water Framework Directive.  Mark Lloyd questioned if this was just ‘re-packaging’ of the existing system to make it look as if there is progress being made.  John Clark said there would be local workshops held as happened with the river basin management plans and that SoNaRR 2 would be web based along the lines used in an Australian portal on the Sustainable Management of Natural Resources (SMNR).

• Fisheries Local Inquiry – feedback and commitments made

Peter Gough went through the costs of the inquiry (£350K plus!) and explained that the inspector had set a deadline of issuing his report on or before the 17 May.  The report will be issued to the Minister and it is unclear if those objecting will receive a copy prior to the Minister making a decision.

The Fish Eating Birds (FEB’s) Advisory group has prepared a paper and the NRW Executive Team has approved this with some amendments (we did not have copies of this paper).  It seems that there is a concern that there is no evidence base on the damage done by FEB’s so it seems unlikely that there will be any immediate action on controlling FEB’s while a formal study is carried out, as FEB’s only eat fish how much more evidence do they need!  The paper will be present to WG once it has been approved by the NRW Board at the May Board meeting.

There have been 16 rivers surveyed and plans produced as part of the River Restoration project which is being carried out by Rivers trusts in Wales via Afonydd Cymru.  The survey reports and work program will be made public via the NRW website.  Reports are mainly pictorial i.e. photographs showing the areas needing attention.  I had been asked by the Dee LFG to raise the issue of the lack of visibility about the River Restoration project and that more needs to be done to engage stakeholders.  As rivers Trusts are undertaking this work on behalf of NRW it is for the Trusts to communicate with stakeholders.

Items for discussion

• Fisheries Strategy

Members were asked for their feedback on the strategy paper.  The most significant comments were there is now no longer a dedicated fisheries department within NRW.  It was also noted that this was a ‘fisheries strategy’ document which did not make reference to fishing and it was more of a vital nature diversity strategy.  It was also noted that the strategy only dealt with ‘wild fish’ and there was nothing about stocked fisheries or sea fishing.  I asked if WG were committed to promoting fishing in Wales and pointed out that the perception is that WG are only interested in promoting adventure activity on our rivers and consider anglers as blocking the WG wish for open access.  A sub group will be formed to progress the strategy.

• Stock assessment 2018

The two papers on sea trout and salmon stocks were discussed.  The picture remains much the same primarily due to the way NRW applies statistical analysis it should be noted that in the majority of cases the status is declared as ‘uncertain’ i.e. it is just a best guess.  PG explained that NRW had engaged with CEFAS to review the present statistical model due to the uncertainty of the results they produce, this review may be due to the challenge we made at the inquiry about the methodology. 

• Wales land management Forum

The strategy on future land management will be presented to the NRW Board at the May Board meeting.  It remains to be seen if the promised reforms will be implemented and even if they are this will be some time in the future – too little too late!

• Angling promotion update

Mark Lloyd updated the group and explained that AT had received a grant of £100K from Visit Wales and £30K from NRW to promote fishing in Wales.  This will be via a web based system which will list all of the available fishing within Wales this will include Coarse/Sea/Game fishing with contact details for clubs etc.  There will also be a Social media link so that anglers can post their experience of fishing in Wales (good or bad) but Mark said that the posts would be subject moderation.  In 2020 it is apparently the ‘Year of the Outdoors’ and this will be a good platform to promote fishing in Wales with a link to the WUF Fishing passport scheme, clubs in Wales should be encouraged to sign up to the passport scheme or at least ensure that their information is included in the AT database.

• Items for information

There was a short discussion on invasive species and angling Pathway Action Plans (PAP’s) this is directed at recreational anglers to prevent the transfer of disease and invasive species and it is hoped that anglers will sign up to check/clean/dry their equipment.  I pointed out that this must also apply to paddlesport.

There was a quick update on the proposed Tidal Lagoons with NRW remodelling the environmental impact using new parameters.  The general impression was that at this time Tidal lagoons are too costly to proceed.

A hydro power briefing note was handed out I have attached a copy of this.

It seems that Thames Water wants to take surplus water from Lake Vyrnwy using the Vyrnwy and Severn as conduits for most of the distance before diverting the water into the head waters of the Thames.  Apparently this idea has been ongoing for several years but seems to be gaining momentum.

• Any Other Business

Mark Lloyd and Rachel Evans raised the access issue following the statement by Hannah Bythyn AM that if there are no improvements in voluntary access agreements in the next 18 months WG will legislate for open access.  This is a direct threat to fishing activity in Wales and I pointed out that it will have significant environmental consequences as adventure activity is only interested in profit and will contribute nothing to the management of the environment.

Rachel is prepared to deal with this issue on behalf of anglers and riparian owners but needs as much information on VAA’s offered and rejected as possible to counter the belief that anglers and riparian owners are blocking VAA’s.

The next meeting will be in November and will probably be held in Carmarthen.