Not a lot happening at present. Some rain forecast for the weekend but still uncertain at present. River really is on its knees.
At least somone is trying to to something to stir up the unfit for purpose NRW and indeed WAG.
8 August 2018
Re: NRW fisheries bylaw proposals
Dear Minister,
Thank you for
your response on 18 July (Your Ref: LG/01334/18) to my letter dated 10 July
2018 in which you say you are unable to meet with stakeholders at this juncture
in the process and that you will keep us advised via NRW.
Unfortunately NRW
has declared in a press release that there will be no further debate and we are
therefore being kept in the dark on progress on this important issue. I have written to the Chief Executive of NRW
requesting a meeting to try and resolve the lack of communication; however I
would draw your attention to what is happening across the border in England .
The Environment Agency, following
improvements in the 2017 rod catches on many rivers, together with uplift to account
for angler under reported catch returns, has updated the 2017 to 2021 river
status classifications into its 2019 Byelaw proposals. As a consequence the number of “At Risk”
Rivers to which mandatory measures will be applied has dropped from 10 to 4.
Together with English anglers we funded an
independent review of the statistical river classification methodology used by
both NRW and EA. This independent review
raised some serious concerns on the interpretation of the data from the model
being used. An email exchange between
CEFAS & NRW in July 2015 stated that: “NRW
note that the current levels of exploitation are not the primary cause of the
current low abundance and that the proposed measures will thus result in
relatively modest increases in spawner numbers….”. In looking at the
comparative NRW & EA 2017 angler declared catch returns that generate
spawning stock estimates we are particularly concerned that the average under
reported catch uplift applied to Welsh
River catches is
16.76% whilst for English Rivers the uplift was 31.5%. This mirrors concerns we
have with NRW rod catch estimates used in comparison to the more realistic rod
fisheries catch totals on a number of managed fisheries.
The 2017 and 2018 juvenile salmon surveys
provide further evidence that the data being used by NRW is flawed as these are higher than the predicted numbers from the river
classification model. A number of North Wales rivers have shown above average numbers of
salmon parr, with some rivers recording their “best ever” results. Despite this, NRW prefers to take the easy option of
imposing blanket restrictions on all rivers in Wales and dismisses a voluntary
solution which will potentially deliver better outcomes for both our stocks and
fisheries. If the proposals are introduced without giving a voluntary solution
a chance it will be a travesty, particularly given that there are clear signs
that a significant number of rivers are now showing a steady improvement.
There is no
evidence that Catch & Release (C&R) is effective based on the National
Salmon Regulations introduced in 1999.
It is therefore unlikely that the proposals put forward by NRW for a
period of 10 years will not have any effect in increasing the numbers of salmon
returning to our rivers. You may be told
that without the 1999 regulations things may have been much worse and that not
to approve the proposals could be seen as negligent; the reality is that this
is little more than speculation and cannot be substantiated. The decline is due to many things but angling
is not one of them. However, high on the list of poor recruitment is
agricultural pollution and predation by fish eating birds.
It has not gone
unnoticed that many of the responses from your office, although signed by you,
were probably drafted by fisheries officers.
A recent request from Lynne Neagle AM about the proposed
bylaws on behalf of one of her constituents to Clare Pillman (CEO of NRW) is yet
another example of the reply not being written by the person who signed
it. The response to Lynne Neagle AM was
designed to demonstrate that the complaint from the constituent was wrong. The response uses inaccurate and emotional
data i.e. claiming that the number of anglers "killing all of
their salmon" is 30% and yet in a recent note from NRW to members
of Local Fisheries Advisory Groups it was said that there were 24% of anglers,
based upon catch returns, who killed all of their salmon, this fails to
recognise that these anglers may have only caught one fish. These figures do not match the declared 80%
of salmon in Wales
which had been released, on some rivers the release rate is more than 90% i.e.
voluntary measures can work.
I note you prefer
not to legislate on agricultural pollution but prefer a co-operative approach
with farmers, an option which is being denied to anglers.
You prefer to
deny anglers an opportunity to meet with you or your Environment Minister in
order to put forward alternatives despite the evidence
that we have presented to you that the data used by NRW is flawed. Anglers are not the root cause of the decline
in fish stocks and yet you are being told by your advisors that the only way
forward is to impose further restrictions on anglers. The greatest fear amongst anglers is that you
will sign off the NRW Bylaw proposals during the summer recess and in so doing
avoid any debate in the Senedd from AM’s who support the anglers in their
constituents. If this is the case we
will insist on an inquiry.
Regards
Chris White
Conservation
Officer: Campaign for the protection of Welsh fisheries
Representing, but
not limited to the following:
Angling Cymru
Betws-y-Coed Fishing Club
Seiont, Gwyrfai and Llyfni Anglers' Society
Penrhyn Fishing Club
Rhyl & District Anglers
Vale of Clwyd Anglers
Corwen & District Angling Club
Llangollen Maelor Angling Club
Dolgellau Angling Association
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Federation of Clwyd Anglers
Wye Salmon Association
Merthyr Tydfil Angling Association
Crickhowell & District Angling Society
Usk Fishery Association
Brecon Angling Society
New Dovey Fishery Association
Prince Albert Angling Society
Wirral Game Fishing Club
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