CAMPAIGN FOR THE PROTECTION OF WELSH FISHERIES

10 July 2018

Re: NRW fisheries bylaw proposals – Update

Dear Minister,

We note in recent correspondence to both ourselves and various AM’s who are supporting Welsh Anglers that you continually say “I am unable to comment on the proposals at this time” as you are awaiting a response from you officials on the bylaw proposals.

You will undoubtedly be told by NRW that there are only six complainants about the proposed bylaws. The reality is that those six represent all anglers in Wales – we are the Anglers Shop Stewards fighting for the rights of our members.

We commissioned an independent Evaluation Report on the methodology used by both the NRW and EA, the findings in this independent report show that the present river classification system is statistically incorrect, has not been validated since its introduction in 2003 and is deeply flawed.

Our collective view is that the proposed measures and justification set out by the NRW in the Bylaw Consultation conservation case will not reverse the decline in stocks and potentially places salmon and sea trout stocks under greater threat.

Prior to your final decision on the bylaw proposals presented to you by NRW we wish for an opportunity to present our case to you or your Environment Minister for a shared management approach reflecting the important role anglers play in conserving, protecting and enhancing salmon and sea trout stocks. This request is being made as it has become apparent that in making their bylaw recommendations NRW reached the conclusion that none of the reasoned objections to mandatory measures or alternate conservation proposals submitted by anglers in the public consultation were considered as being of sufficient merit to change or amend their original drafted bylaws (The NRW preferred option).  One small consideration has been adopted. However this is more to do with avoidance of disability discrimination, although there still remains a question mark on whether the concessions actually achieve that.

The uncertainties of the introduction of the proposed bylaws are already having an impact on the management and viability of fisheries (reductions in membership and visitor income) and we wish to present our own evidence on the following grounds: –

• The Consultation Conservation case states that 10-year statutory catch and release measures for salmon are necessary to reverse the current threat to stocks at a time when, according to NRW anglers in Wales already voluntarily return 86% of the salmon they catch.  The implication in the NRW case is that anglers are the cause of the decline; this is patently not the truth.
• Anglers, Riparian interests and Rivers Trusts undertake a range of important voluntary fish protection and enhancement programmes. The loss of these critical voluntary programmes is imminent as anglers give up fishing or fish elsewhere. Unviable Clubs, fisheries and Riparian owners will be forced to scale down their activities or close altogether. The NRW are not able to back fill these voluntary programmes and the vacuum left will result in greater loss of juvenile and spawning stock due to increased poaching activity, predation and other river related incidents – pollution etc.
• Anglers have taken a responsible conservation approach, introducing voluntary codes and tagging schemes to meet agreed target catch & release rates in the lead up to the Bylaw review. The C & R rates are at a historic high (appox 90%) and in line with national guidelines.
• The conservation case is based on questionable stock data assumptions and should not be used to implement statutory measures.
• Elements of the proposed Bylaws are not enforceable and would rely heavily on angler’s support.  Recent reorganisation within NRW has further weakened fisheries enforcement who will now only be active from 8am to 5pm, poachers operate at night.
• Little economic or social impact assessment was undertaken with NRW publicly stating there would be a reduction in angling activity.

I would draw your attention to the press statement issued by NRW (Messrs Gough & Mee) following the deferment of proposals in which they say, “there will be no further debate” and that “they were prepared to make themselves unpopular”.  It is clear from these statements that the response from Inland Fisheries/NRW will be for you to support the proposals as published.  The approach in England by the EA is not as draconian as those by NRW with no blanket ban as proposed in Wales i.e. it is easier to blame Welsh anglers than deal with the root cause.  It was agreed at a recent EA meeting (with NRW present) that the way forward for England and the EA was for co-operation with anglers, unlike NRW who prefers to ignore stakeholders.

Our preference is for stakeholder involvement and meaningful discussion, as is happening in England, instead of imposing on Wales the most severe conservation legislation in the whole of the United Kingdom and Ireland.

As Minister we do not expect you to have an in depth knowledge of the issues.  The NRW Fisheries Team has freely acknowledged that anglers know their own rivers better than they do and that alone provides sound basis for our concerns to be heard independently (as recognised at the recent Petitions Committee meeting on 3 July). Your options are therefore to either support your agency and approve their proposals or support anglers, your electorate. To that end we would again request a meeting with either yourself, or your Environment Minister, in order to present our case for a voluntary solution and as a result avoid the need for statutory legislation as a first response.

Regards

Chris White

Conservation Officer: Campaign for the protection of Welsh fisheries