Peter
Gough
Senior
Fisheries Specialist
Natural
Resources Wales,
Monmouth Office
Hadnock Road,
Monmouth.
NP25 3NQ
Re: NRW decision on closure of hatcheries &
cessation of stocking
We the undersigned organisations representing clubs
and some 33,742 anglers fishing the rivers of Wales write to register in the
strongest terms, our opposition to NRW’s decision with regard to banning
properly regulated stocking initiatives on Welsh rivers.
We consider NRW’s decision particularly
irresponsible given the recently published 2014 season assessment of salmon
stocks indicating that in all 23 principal salmon rivers stocks are classified
as either ‘at risk’ or ‘probably at risk’ of remaining so in 2019 with the
trend in all classified as ‘uncertain’. Similarly the assessment of sea trout
stocks indicating in the 28 principle sea trout rivers, 12 are classified as
either ‘at risk’ or ‘probably at risk’ and 7 ‘probably not at risk’, meaning
two thirds of sea trout stock levels in principle river are uncertain.
The scientific advice based on 214 papers
produced by your team in November 2014 to support the decision to close
hatcheries is without merit. The majority of the papers cited do not concern
themselves with the environmental impact of hatcheries on rivers. Where they
do, there is no clear evidence of their threat to natural river environments.
We therefore contend this advice was based not on scientific analysis of
threats, but on a simple requirement to find in favour of closing hatcheries. We
will not speculate on what drove this decision making process.
We also find
no evidence of harm in the papers offering ‘additional evidence’ as supplied by
Peter Gough to us recently. In fact one paper challenges the results of most of
the previous research ‘due to a lack of consistent methodology and small sample
size without consideration of environmental effects’, the other two papers are
more concerned with hatchery practices to improve the outcome, neither supports
the fact that stocking is harmful.
We note there are three basic conditions under
which hatchery operations can play a role in river conservation, these being
(i) recovery (ii) mitigation (iii) enhancement. Given the “at risk” status of 23
significant Welsh rivers, please would you write to confirm why the use of
hatcheries to assist “recovery” from at risk status has now been rescinded.
Would you further provide to us, clear written confirmation in the form of NRW
working papers, indicating you have considered and then
discounted the need for hatcheries to assist in the recovery of “at risk”
rivers (as opposed to assisting mitigation strategies).
NRW’s actions in relation to the banning of
hatcheries, lack scientific evidence and popular support amongst anglers and
those directly involved in fishing on Welsh rivers. In this respect, the
decision is undemocratic, unscientific and indicative of government involvement
in contributing to the decline of Wales’ once great fishing assets.
We ask you to reconsider this ill-conceived and
politically motivated decision.
We further ask that you pass copies of this
letter to your Chairman & CEO’s for their comment.
Yours faithfully
Stuart Smith
On behalf of
Wye Salmon Association [WSA]
Campaign for Protection of Welsh
Fisheries [CPWF]
Welsh Salmon & Trout Association
[WSTA]
River Wye Gillies Association [RWGA]
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