Well here we go again. Another couple of days lost with the river up and dirty again. May not yet have reached the Ross area yet so there may be a chance there -but not for long.
Seems after this episode we have the long dry warm spell the met Office are predicting so who knows even the bottom river might get some action eventually thought not for a week and possibly longer.
LATEST Colour is grim and rising this morning in the Hereford area. Peaked on the upstream beats and falling slowly.
-----------------------------------------------------------------------------------------------------------------------------
Interesting letter below. The reply from the Minister Lesley Griffiths to Chris Whites letter (below) suggests she has had no further information from NRW since 20th February so none of the results of the consultations etc have even been submitted to her. Looks 100% certain to me that there will be NO new bylaws this season at least.
10 April 2018
Re: NRW fisheries bylaw proposals – request for an Inquiry
Dear Minister,
We note in your
recent correspondence that you say you will be following the requirements of
the Water Resources Act 1991. We draw
your attention to Schedules 2 and 26 of this Act and formally request an
inquiry as the objections from the majority of the respondents to the
consultation have not been withdrawn.
To date our
correspondence with your office has been put on hold with no indicative time
scale for you to make your decision. In
Schedule 2 of the Act it clearly states that you can only confirm or reject the
proposals once all of the objections have been dealt with. To this end all that has been received from
your agency (NRW) is a request that objectors withdraw their objections based
upon their technical case which is flawed. NRW have simply dismissed our objections claiming
that we have not presented any evidence; In March CPWF together with the North West
Angling Trust Fisheries Consultative Committee (NWATFCC) jointly commissioned
an Independent Evaluation of the rivers Classification methodology which has
been used to justify the proposals (see attached report).
The findings and
conclusions of this Evaluation by Consultant Statisticians are of such concern
that we have requested that the Angling Trust write to NRW, EA, Cefas and NASCO
requesting that the proposed 2018 measures are suspended based upon the
contents of the evaluation. In our
correspondence with your office we have provided draft proposals on alternate
and interim measures which will achieve better results than the proposed bylaws. It was clear from the outset that there has
been pre-determination by NRW in the outcome of the consultation; a similar
situation exists in England .
Nothing in the NRW
proposals will reverse the decline in salmon stocks in the short or medium or
even long term as the proposals do not address the root cause of the decline,
they simply disadvantage the stakeholders. The evidence from 20 years of compulsory catch
and release for spring salmon demonstrates the futility of the recommendations
in achieving the desired outcome.
We would refer you
to the comments made by Cefas on this issue who advised you that the proposals will
have little impact but may be worth doing as there may be some improvement in
the long term i.e. it is accepted by NRW that these proposals will do little or
nothing to reverse the decline.
We would draw
your attention that in August 2017 a public notice was placed in the London
Gazette by the Welsh Government under its seal based upon the original bylaw
proposals which have been subsequently amended.
We have taken legal advice concerning the publishing and formal
notification in the London Gazette asking for objections whilst at the same time
running a consultation i.e. were we objecting to bylaws which you had already
approved or were we consulting on other options. I would refer you to Schedule 26 and the
requirement for formal notification following a consultation for a period of 28
days for objections to be lodged, this has not been complied with, there has
been no opportunity to object to the amended proposals and you are not
therefore in a position to approve the proposals.
The present
fisheries bylaws are river specific and are to be replaced with a bylaw which
covers all rivers i.e. a national Welsh fisheries regulation and not a bylaw. I would again refer you to Schedule 26 and
the need to revoke the existing bylaws before the new bylaws are enacted, I am
not aware of any notice of revocation.
It is our
preference to hold meaningful discussions on how salmon stocks can be conserved
after all as stakeholders we know our own rivers best and are their guardians,
it is not in our best interest to destroy our fish stocks as implied in the
proposed NRW bylaws.
The draft interim
proposals and pausing of the proposed Consultation Bylaw measures gives all
parties the opportunity to engage and frame a constructive partnership approach
that will conserve and benefit fish stocks, fisheries and communities for the
long term.
Regards
Chris White
Conservation
Officer: Campaign for the protection of Welsh fisheries
No comments:
Post a Comment
Note: only a member of this blog may post a comment.