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From: Paul Cawthorne <paulcawthorne1966@gmail.com> Dear Ruth, Further to meeting on the Dovey yesterday. Following Alicia’s kind agreement to a meeting, it was good to meet several workers on beaver issues- a researcher, a consultant and a lead implementer if we understood correctly. It is clear the science of barriers to migration, fry to adulthood survival determinants and environmental damage are highly contested as soon as specifics are reached. We were able to identity parameters where more clarity was needed and perhaps achievable. It would be good to have those more fully discussed before any further movement on this issue, especially as there is a distinct whiff of attempted fait accompli about the present juncture, which you are well-placed to bring back into proper relationship. Without the apparent present rush to authorisation, consensus does look achievable by prioritising proper research in an agreed framing between interested parties. Space still exists for that until you authorise beaver release, but clearly will not after the event. In the Dovey valley, anglers are deeply scarred by the severe power imbalance of the departmental inspector’s unsafe report based on an expensive barrister’s non-angling analysis, which prepared the way for draconian restrictions on angling which have led to an exodus of anglers from migratory salmonid angling in Wales recently. This is evidenced by the spread of licences purchased, as the repeatedly refused impact review would display clearly. That is the sad, and wholly avoidable, context we find ourselves in. We are reluctant to speak for Dovey farmers but after speaking with NFU reps and press associates and with one of our alliance being a farmer, initial indications are clear that farmers feel similarly marginalised to anglers. We understand that there was a very strong rejection of the beaver release proposal by valley farmers collective reflection and so the stage seems set for more of the kind of vigilante activity which is happening in Scotland. This of course mirrors the officially blindeyed prior vigilante activity which has already led to unenclosed beaver presence on the Dovey with observable damage to trees. The lack of official activity in response to that vigilantism is glaring and diagnostic of the apparent fait accompli attempted framing. As the Director of the Wild Trout Trust writes: “We have, from the very outset, challenged NE on illegal (what they call unauthorised) releases, but there’s little or no appetite for action…..Of course, it’s emboldened the illegal releasers since they’ve no chance of being pursued or caught…” The official disdain and lack of listening is summed up for us by two reported occurrences: 1. the Dovey enclosure being reportedly built a month before the consultation finished. If true (please confirm for the record), this seems unacceptable behaviour, yet where is the accountability? The Minister deserves better from her arms-length helpers. 2. Richard Evans relates how he walked the banks with members of your team pinpointing barriers to migration and coming up with a consensus plan for their removal, yet now you seem intent on allowing FRESH barriers to be created. Where is the NRW policy coherence? So it really brings us to the point of asking whether you, as NRW policy director, want a regulated situation or a free-for-all, where the remaining vestigial respect for official process and the integrity of officials who determine process evaporates altogether. It is not clear to our alliance what process led to the selection of the Dovey as a setting for this experiment. We were not consulted (were we, please confirm to the Minister) and are now being expected to meekly trust that same officialdom will agree with us on the same riverbank which particular barriers to migration are problematic and then remediate them. In this jaded setting of lost trust among politicians and farming and angling organisations Natural Resources Wales criticised in Senedd over ‘lack of trust’ | The National Wales , that is a big ask, which will become well-nigh impossible if you just plough on with authorising release before a proper debate about illegal releases (rather than a commissioned all-clear from a Beaver Trust young researcher who talks about the Cowx review being “ridiculed”).Without a consensus consultative review of the salmonid migration barriers issues actually happening in a catchment-specific way prior to authorisation, NRW’s lack of clothes will be evident for all to see and you will have burnt your remaining bridges with our alliance. We really do not want to spend the coming decades having to try to find beaver dams within the fortnight to be allowed to remove them or face the same insanely cumbersome paper chase licensing system that currently applies for goosanders. Promising it will be sorted soon simply doesn’t cut the mustard. Once it is sorted, then we can start to trust again. So it was poignant that there was a flock of eleven goosander sat at the tail of the bridge pool as we met and a shoal of smolts obviously too scared to descend and shoaled vulnerably in shallow water above the tail. We noted from America the strange and tiresome new human activity of putting chickenwire round numbers of important trees to reduce damage and our alliance is not convinced that will happen sufficiently reliably through a volunteer squad. Please ensure protocols are completed in writing before any authorisation or it will lead to an appearance of being ultra vires and this will be fully scrutinised. We are not clear the freelance ecologist understood the crucial technical point that descending smolts taken by FEBs are not a loss compensated from elsewhere in the river system, in the way that some parr losses can arguably be considered. This was disappointing to our technical people. To add more dinner tables by fresh beaver dams closer to the spawning grounds higher up the system intuitively seems foolish at best. It was stated that FEBs won’t learn to fish them, which showed a profound ignorance of the Dovey system where cormorants and goosanders are often encountered up the sidestreams and with a very clear preference for the deeper sections for hunting. We know more than academics at times about our rivers due to the time spent quietly learning along the banks, without fuss or plaudits but with deep expertise. To say that FEBs won’t learn to use fresh dams much was a dangerously self-interested statement. The extra time descending smolts will remain trapped above such dams in times of low flow such as this year’s is obvious to anyone with eyes to see and it is perhaps disingenuous or wishful to say it will average out across an ecosystem or across years. It was good that the lead implementer yesterday recorded his “concern” about descending smolt losses. There will almost certainly be substantial net smolt loss. Your own organisation recognises this issue “migratory fish past the age of smoltification have no such compensatory mechanism and any loss due to predation then is a net loss to the population” Natural Resources Wales / Salmon and sea trout plan of action for Wales 2020: areas for action, so what are you going to do, add to it ? ! Potential support for hatcheries was given by the team, as a trade off to compensate for the anticipated smolt losses. Please would you clarify to them and us at this early juncture whether that would be looked on favourably by NRW. It is a possible area of helpful joint enterprise as long as not kyboshed by NRW, so your early comment will be appreciated. At the meeting, we asked for proposed management protocols to be made open to discussion and finalised by consensus PRIOR to authorisation (particularly agility and light touch guiding of dam removal with autonomy retained, such as short lead-in time to dam removal, a key issue identified by STC). Again, if it doesn’t happen that way round, our scepticism will have been justified. Please reflect on the full implications of these sentences, as they are wide and deep well beyond the specific issue. Please see the attached formal complaint to IEPAW, which probes the legal situation and NRW’s evident conflicting objectives, and requests expert scrutiny of the apparent present mess. We look forward to your involvement in helping the dialogue tentatively begun to flourish rather than fail as your team’s much vaunted “working more effectively with anglers” (P. Gough Jan 2018) in practice so disastrously did. You have the chance to do better this time round and we respectfully urge you to take it. Yours sincerely, Mark Frey, Paul Cawthorne, Karl Humphries, Richard Evans From: CEO <ChiefExecutivesOffice@cyfoethnaturiolcymru.gov.uk> Dear Mr Ashwin, Thank you for your letter in relation to the above dated the 09/05/2022 addressed to Clare Pillman, Chief Executive. I can confirm that my colleagues are liaising on this matter. Your comments are being considered and a detailed reply will be sent to you in due course. If you have any queries regarding this issue in the interim, please do not hesitate to contact us. Many thanks, Lauren Lauren Hughes Cyfoeth Naturiol Cymru / Natural Resources Wales Tŷ Cambria, Heol Casnewydd, Caerdydd, CF24 0TP Tŷ Cambria, Newport Road, Cardiff, CF24 0TP FAO Clare Pillman – CEO Natural Resources Wales, Dear Clare, Please receive a Formal request from PAAS Prince Albert Angling Society, CPWF Campaign for Protection of Welsh Fisheries & SFG Severn Fisheries Group with extensive waters in Wales for an Assessment of the Impact of the 2020 All Wales Byelaws. The attached Report provides the reasons and justification for this request together with recommended criteria and metrics for quantifying the impact. The request is consistent with monitoring outcomes in NRW`s 2020 Salmon & sea trout Plan of Action and NASCO Guidelines for the Management of Salmon Fisheries in England & Wales. If you would kindly respond to myself (advisor and representing PAAS, CPWF & SFG). Further Cc. Welsh Government, DEFRA and Conservation NGO`s – Angling Trust, Fish Legal, Salmon & Trout Conservation UK, Atlantic Salmon Trust, Wild Trout Trust. With regards, Mike Ashwin, The Barn, Skirwith, Penrith, Cumbria, CA10 1RH
Minister for Rural Affairs, North Wales and Trefnydd (via email) Re: Releasing Beavers into the ‘Wild’: Environmental engineer or a waterway menace? Dear Minister,
t is noted in the final report of the River Otter Beaver Trial – ROBT (download link: The River
CC via email: Where does it come from? Check this link. . Too many vested interests but no overview that’s worth serious consideration.
The list goes on and on and on NRW, has dedicated and hard-working staff, but is grossly underfunded and massively understaffed and are failing. Remember the old saying? : “You can please some of the people all of the time, you can please all of the people some of the time, but you can’t please all of the people all of the time”. It seems to me that they are succeeding in very limited areas and pleasing very few. It is not good enough that they respond only to political directives. If it was not for the River Wye and wild swimmers pointing out the high levels of sewage pollution and the publicity that has subsequently ensued then little would have been planned to address the issue. This is no way to manage our rivers: they are too important. Otters: I have nothing against otters, in fact, one of my fishing seasons was “made”, and I will never forget that time an otter stepped on my boot and its reaction when I said “Hello beautiful, what are you doing here?” The otter looked up at me, obviously surprised, before tuning and disappearing, I wished him well and thanked him for the encounter, Why do some anglers anglers curse these charming creatures? Is it because of the lack of fish in the rivers because of the water quality? Anglers feel that otters are feeding on a very limited supply of fish. There should be enough fish in our river to satisfy us both. Beavers: It may be that beavers once roamed the thickly wooded banks of our then crystal clear rivers, and helped thin out our woodlands, However our rivers are no longer crystal clear, and our woods are now all but diapered. They may be furry, beautiful and fascinating, but our countryside has changed massively since the days when beavers roamed free, the country is no longer massively wooded. it is intensively farmed, and we need land for housing. The current re-wilding initiatives fall far short of providing suitable habitat for a growing population of beavers, their numbers would have to be seriously controlled and how would beaver culling be regarded. Pollution: It is difficult to justify pouring untreated sewage into our rivers, except in a carefully monitored way and only in exceptional and exceeding limited and controlled circumstances. Why then is there no planning requirement for developers to pay for the expansion required to water treatment plants as a consequence of the increased load imposed on the system. This pollution will include concentrations of the chemicals we ingest as medication and then discharge into the drainage system, which is, for the greater part, unable to separate such pollutants from the waste water Why are farmers allowed to submit planning application for a 4,000 chicken production unit, that is required to comply with few regulation, when another family member submits a similar application for a unit on the same piece of land, thus avoiding the need to comply with the legal obligations imposed on the larger 80,000 bird unit. The waste products from these great numbers of birds are often spread over the land in unmonitored quantities and much ends up in the watercourses and thence to the river The Welsh Government, is responsible for the quality of the water in our rivers. It must address the problem and discharge its obligations. It has been reported that the Welsh Government want Wales to become second only to Switzerland as the outdoor pursuit centre of Europe, perhaps we should act, regardless of damage to the environment Pollution: It is difficult to justify pouring untreated sewage into our rivers, except in a carefully monitored way and only in exceptional and exceeding limited and controlled circumstances. Why then is there no planning requirement for developers to pay for the expansion required to water treatment plants because of the increased load imposed on the system. This pollution will include concentrations of the chemicals we ingest as medication and then discharge into the drainage system, which is, for the greater part, unable to separate such pollutants from the waste water Why are farmers allowed to submit planning application for a 4,000 chicken production unit, that is required to comply with few regulation, when another family member submits a similar application for a unit on the same piece of land, thus avoiding the need to comply with the legal obligations imposed on the larger 80,000 bird unit. The waste products from these great numbers of birds are often spread over the land in unmonitored quantities and much ends up in the watercourses and thence to the river The Welsh Government, is responsible for the quality of the water in our rivers. It must address the problem and discharge its obligations. It has been reported that the Welsh Government want Wales to become second only to Switzerland as the outdoor pursuit centre of Europe, perhaps we should act, regardless of damage to the environment. Paddlers who want unrestricted access to our rivers. No, I do not believe anglers should have sole access to our rivers, but paddlers should be required to have appropriate permission and pay, just as others have to. They have little awareness of their legal responsibilities about the disturbance of breeding salmonids, a fact that is ignored, for the most part, as enforcement of the requirements is non-existent. The answer lies in the quality of our waters. Water is a necessity for the development of all life on earth, without it we could not exist, the same goes for the smallest of the invertebrates that inhabit our rivers, and they are the the foundation of all life in our rivers: no invertebrates, no fish, no life that relies on fish for it’s sustenance. We should be putting all our efforts into stopping pollution, all pollution from whatever source. Millions have been spent on the River Wye and still the salmon stocks are only a fraction of those in days past. Why? because the river suffers from pollution from any number of sources. We need to stop squabbling and spend all our available funds on anti pollution measures. Minister for Rural Affairs, North Wales and Trefnydd (via email) 15 February 2022 Re: Releasing Beavers into the ‘Wild’: Environmental engineer or a waterway menace? Dear Minister, On behalf of CPWF on the 8 February one of our members (John Eardley) took part in the Welsh Beaver Project: Consultation Workshop at which Alicia Leow-Dyke (Welsh Beaver Project Officer with Wildlife Trusts Wales) outlined the benefits of releasing 10 pairs of Beavers into the Dyfi Valley saying that beavers had been absent since at least the 16th century. Of course, over the intervening 400 years population density in the valley has increased, and changes in agricultural practices have seen rivers and streams managed. Whilst beavers may bring some benefits to the overall ecology of rivers this should not be at the expense of migratory fish stocks particularly as in Wales these stocks are declared as either ‘At Risk’ or Probably at Risk’ Alicia’s presentation focused only on the positives including stating that beavers “only build dams on smaller tributary streams when the water is not deep enough for them to swim”, the wonderful benefits they bring to the hydrological cycle and the biodiversity of the catchment. This statement ignores the fact that these smaller streams are the spawning and nursery grounds for migratory fish. It should be noted that the NRW Executive and Board were told that the ‘All Wales Bylaws’, restricting angling methods, were necessary “in order that stocks can recover in the shortest possible time”. Introducing beavers on a river deemed to be ‘at risk’ for salmon or sea trout would be 100% counterproductive and fly in the face of the oft-quoted Precautionary Principle. This would also make a mockery of the work at present being undertaken by Rivers Trusts on river restoration projects funded via the Salmon Action Fund or the Dee LIFE fund where barriers to migration are being removed. There are claims by supporters of beaver re-introduction with respect to fisheries that: “A wide range of evidence from Scandinavia and North America suggests that most beaver dams are passable to salmonids most of the time and that there is no clear evidence of a negative relationship between beaver activity and salmonids at a catchment level”. And: “Without appropriate management there could be negative effects on salmonid migration during dry autumns on smaller side streams with active beaver dams though this effect is likely to be highly site-specific based upon Scandinavian and North American”. It should be noted that this is only a ‘suggestion’ there is no harm i.e. this is opinion and not based upon any evidence and in addition this opinion is based upon a catchment basis. You cannot compare North American or Scandinavian River catchments with the much smaller Welsh river catchments where the negative impacts will be significant. It is noted in the final report of the River Otter Beaver Trial – ROBT (download link: The River Otter Beaver Trial | Devon Wildlife Trust) that the effect of beaver dams on migratory fish was given scant regard. In the title of this letter, I have used the heading Environmental engineer or a waterway menace? from a paper by Dylan Roberts of the Game and Wildlife Conservation Trust (www.gwct.org.uk ) which expresses caution on the release of beavers into the wild. Within the ROBT report the evidence from electrofishing above and below beaver dams clearly shows the marked decline in salmonid juveniles above beaver dams whilst claiming fish populations had increased, these were mainly minnows, brook lamprey etc. Photographs in the ROBT report to demonstrate that beaver dams do not obstruct upstream migration (in high flows) show sea trout leaping the dam which is then claimed that beaver dams are not a barrier to upstream migration. Whilst adult migratory fish may be capable of negotiating beaver dams, juveniles cannot pass these on their downstream migration to the sea as there is no clear flow for them to follow i.e. water percolates through beaver dams. It has been claimed in several papers that beavers improve fisheries as trout above beaver dams are larger (in one report it claims these are the fish anglers want to catch!), trout are predators so any juveniles dropping back into the impoundment caused by a beaver dam are rapidly eaten, which is why the trout are larger, this is short lived as there are no longer suitable spawning areas for these larger trout! It was interesting in the ROBT report that they identified the lack of/reduction in bullheads above beaver dams stating that this is due to bullheads requiring clean gravel and rifles to spawn, this also applies to migratory fish who need clean gravels. There is a reference in the ROBT report to the requirement for further studies on the effect of beavers on fisheries. The ROBT project was only funded for 5 years which ended in 2020. It should also be noted the need for ongoing maintenance due to beavers blocking culverts on drainage ditches resulting in unintentional flooding of fields, roads, and properties. During the ROBT project this maintenance work was carried out by volunteers. The ongoing burden of damage caused by beavers will fall on riparian owners and local councils. In Scotland the spread of beavers due to population growth is now causing issues and beavers are being trapped and relocated, I believe the 10 pairs proposed for the Dyfi valley will be from Scotland. There is a time and a place for the re-introduction of beavers but not at the expense of migratory fish, who at this present time are declared by NRW to be at severe risk. The Precautionary Principle must be applied until the long-term effects on migratory fish stocks caused by beavers is fully understood. There must be a moratorium on the release of beavers into the wild on Welsh Rivers until such time as there is clear evidence that our stocks of salmon and sea trout are well on the road to recovery. Regards Chris White Conservation Officer: Campaign for the protection of Welsh fisheries CC via email: Clare Pillman: CEO Natural Resources Wales David Henshaw: Chairman – NRW Board Ben Wilson: Principal fisheries officer NRW Firstly I must apologise for the apparent lack of activity on this site for some time, work has been progressing on the Campaign generally, it’s this website that must appear to have been neglected. Sorry but we are now back! 
Report: The state of the river Usk – A dying river? FAO Sir David Henshaw, Chair, NRW Board Dr. Guy Mawle By email only: chair.office@cyfoethnaturiolcymru.gov.uk guy.mawle@gmail.com
Cc: With report THE REPORT  The Welsh Dee Trust have commissioned a map of the salmon pools of the Dee. This has been compiled by Nigel Houldsworth who has completed maps of many other rivers. Beautifully illustrated and printed on quality paper each is signed by Nigel. They cost £31 and are available from the Welsh Dee Trust shop https://www.welshdeetrust.com/shop/ All proceeds go towards restoration works on the river. The purpose of this advice note is to ensure:1. That all fishery stakeholders, including fishery managers, anglers and netsmen, are alert to the possibility of the return of pink salmon to Welsh rivers during 2021. 2. To ensure that fishery managers, anglers and netsmen know what to do should pink salmon be observed or captured in Wales. Advice for anglers and netsmenWe are concerned about the state of our native Atlantic salmon stocks: this is why all Atlantic salmon caught in Welsh waters must be returned alive and well. Pacific pink salmon are usually easily distinguished from Atlantic salmon, particularly when mature and in spawning condition. · If you are confident that you have caught a Pacific pink salmon, the fish should be humanely dispatched. Please report the capture as soon as possible to NRW on 0300 065 3000 (24 hours day) as this will enable the fish to be formally logged. · If you are not confident that you have caught a pink salmon, the fish should be released back to the river alive where it was captured, preferably having been photographed and later reported to NRW. This is to ensure that no Atlantic salmon are retained in error. · If you have found a fresh, dead pink salmon, please retain the fish is possible and report this to the Incident Hotline 0300 065 3000 (24 hours day) Please consider distributing the briefing to your own fisheries contacts in Wales |
