River still a bit Iffy.  Possible upriver - but no go on downstream beats.   Could be a fish today perhaps.

LATEST   Nothing reported so far. still holding its level but colour fining off

See below for a read of a letter from NRW in reply to some objections.  Full of platitudes, brush off,  mealy mouthed aspirations and indeed a lot of bulls==t

REPRESENTATIONS MADE TO STATUTORY CONSULTATION: The Natural Resources Body for Wales salmon and sea trout cross border rivers byelaws.

Thank you for your response and observations to the NRW statutory consultation on proposed new cross border fishing byelaws for the rivers Dee and Wye. We have liaised with many fisheries stakeholder groups on these difficult matters over the past 2 years prior to this consultation and we highly value the advice and comments we have received. These helped us to formulate the proposals that have been the subject of the recent consultation.
Our fishing controls proposals were published 13th November 2017, supported by a comprehensive technical case with full background evidence -
https://naturalresources.wales/media/684367/technical-case-structure-final.pdf
NRW is of the clear view that there is a compelling case for further urgent conservation action to help arrest the decline in the status of salmon stocks, and some sea trout stocks, and that this is essential to help restore stocks to healthier and more sustainable levels. On the Wye, where statutory catch-and-release fishing is already in place, we believe that further measures to maximise the success of C&R fishing are required.
The proposed measures, are both proportionate and reasonable, in view of the present risks to vulnerable and declining stocks throughout Wales.
Continuing to kill fish whilst stocks are far below their target levels is not sustainable. Furthermore, we maintain that released fish should have a good chance of survival and therefore propose byelaws commensurate with ‘good practice’.
Ein cyf/Our ref: CBR_014
Eich cyf/Your ref:
Natural Resources Wales
Maes Newydd, Britannic Way West
Llandarcy
Neath Port Talbot
SA10 6JQ

Ebost/Email: Fisheries.Wales@cyfoethnaturiolcymru.gov.uk
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Our case recognises that both species are facing a wide range of environmental pressures which are constraining stocks and fisheries (and it describes ongoing actions to address these).
For salmon, ongoing issues associated with poor survival at sea are a key concern in all salmon-producing nations. This highlights the importance of ensuring that conditions in freshwater are optimum for maximum production of young fish to go to sea.
Maximising the numbers of fish that survive to spawn is crucial, whilst other important work is ongoing to restore river habitats. This includes all actions that place the quality of our rivers and streams at risk.
NRWs clear view is that in taking no action, fisheries will continue to decline and that these economic interests would face a very uncertain future if strong action is not taken to protect them. NRW views the current proposals as an investment I the future wellbeing of these natural resources.
If you wish to respond to this letter, please do so as soon as possible, and by 6th April 2018.
We invite you to withdraw your objection on the basis of the further information in this letter, however if we do not hear from you by the above date we will assume that you wish your objection to remain in place.
The proposals for the cross border river byelaws in Wales were published, together with associated documents, on 13th November 2017 and ran until February 5th 2018, a period of 12 weeks. At the same time the Environment Agency ran a concomitant consultation for complementary measures on these two cross border rivers in England.
We received 35 representations to our Welsh cross border proposals, the Environment Agency received 13 to the English cross border proposals.
 A total of 48 response have been received,
 Three responders have submitted replies to both sets of Welsh and English cross border byelaw proposals.
 11 separate responders requested that responses to the earlier ‘All Wales’ consultation also be included in the cross border consultation
We are now in the process of reviewing and responding to all those who provided contact details.
This letter now provides our response to your representation and seeks to cover the points that you have made.
We believe you have raised points relating to:
 Hook sizes and shrimp fishing
 Predation
 Water quality
 Enforcement
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If we have inadvertently omitted any matter you might have raised within your representation, please let us know (contact details are provided at the end of this letter) or alternatively refer to our website where you will be able to find responses to the full range of issues raised. http://naturalresources.wales/media/684347/180112-generic-theme-response.pdf
Hook sizes and shrimp fishing
We note the points you make on hook and gape sizes. Please note that the proposal for a 7mm gape on trebles would not ban larger gape sizes in doubles and that majority of flies would still be within the 7mm gape.
We note a very recent scientific review on the subject of hook patterns and C&R survival (Lennox et al, 2017), quoted in the Technical Case (where the full reference is provided): ‘Physical injury caused by hooking is the most important predictor of post-release fisheries mortality’.
The use of fewer hooks, or single hooks generally, reduces the potential injury and unhooking times. Treble hooks, and particularly when more than one set of hooks is used on lures, are likely to represent the greatest risk of injury in deeply hooked fish. To reduce both the risk of injury and delay in release in order to reduce post release mortality we maintain that prohibition on the use of trebles will substantially improve C&R survival and embed accepted good practice.
It is also not our intention to change already existing byelaws so that shrimp/prawn fishing would be allowed on the Wye. In the all Wales byelaws we have proposed that shrimp/prawn fishing will be allowed after the 1st September where these methods are already permitted.
PREDATION
We note that you raise the issue of predation in your representation. I would refer you to the technical case supporting our proposals (https://naturalresources.wales/media/682258/technical-case-structure-final.pdf), in which, on page 77, we cover this issue together with other environmental issues that might be constraining fish stocks.
Predation on our fish is of course a natural phenomenon. For example predation at sea by dolphins and sharks is known to occur and the quantitative impact of this is included within our marine survival estimates from the index River Dee in North Wales. Predation also occurs in our rivers, for example by otters, however it is generally the emotive issue of predation on young salmonids by cormorants and goosanders that concerns fishermen.
As we note in our technical case:-
We recognise that there is considerable concern by many anglers and fisheries interests that both cormorants and goosanders are damaging our fish stocks through direct and un-sustainable predation.
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We have a duty under section 6(6) of the Environment Act 1995 to maintain, improve and develop fisheries for salmon, trout, eels, lampreys, smelt and freshwater fish and, in particular:-
 to ensure the conservation and maintain the diversity of freshwater and migratory fish, and to conserve their aquatic environment
 to enhance the contribution migratory and freshwater fisheries make to the economy, particularly in remote rural areas and in areas with low levels of income
 to enhance the social value of fishing as a widely available and healthy form of recreation
We are also the species licensing authority in Wales, and therefore we determine applications received from fisheries interests for licences to shoot birds which damage fisheries. The legal background to this is found in the Wildlife and Countryside Act 1981 (Section 16 (1) (k)). #
As NRW is an evidence based organisation, we seek to ensure that our strategies, decisions, operations and advice are underpinned by sound and quality-assured evidence. We recognise that it is critically important to have a good understanding of our changing environment.
Our procedures for dealing with licence applications is set out on our website:- (https://naturalresources.wales/permits-and-permissions/protected-species-licensing/uk-protected-species-licensing/bird-licensing/?lang=en)
where all appropriate documentation may be found. The application form requires evidence from the applicant on the number of birds present and the non-lethal deterrent methods currently in use together with an estimate of the economic impact on the fishery in question (e.g. fish losses, lost income from permit sales, etc.).
Our position is that licences to shoot piscivorous birds are granted as an aid to scaring in order to ensure that birds are deterred from feeding at the fishery in question. We have encouraged applications to be made on a large geographic scale, such as whole river catchments, to maximise the effect of deterrent measures at a broader scale. Our fisheries officers work with fisheries interests to help advise on how to conduct surveys to collect evidence of bird numbers, how to help protect fish from predation by habitat manipulation, the range of methods available for deterring birds, and the application process itself.
We are well aware of the contentious nature of this subject. Informed by published evidence on the potential scale of avian predation in some locations, NRW has initiated a review of the subject and of its roles and responsibilities. This will include consideration of the statutory protection and designations of both birds and fish, and the action we must consider to discharge our duties.
WATER QUALITY POLLUTION FROM AGRICULTURE
You raise the issue of water pollution from agriculture in your representation. I would refer you to the technical case supporting our proposals (https://naturalresources.wales/media/682258/technical-case-structure-final.pdf), in which, on page 70, we cover this issue together with other related environmental issues that might be constraining fish stocks.
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NRW takes the recent examples of water pollution arising from agriculture very seriously, and indeed has always done so. Recent incidents, primarily arising from slurry management, have featured prominently in the media and this has raised the profile of the Wales Land Management Forum sub-group. The group consists of farming unions and other representatives, Welsh Government and NRW and is chaired by a NRW Board member (Zoe Henderson). It represents a multi-stakeholder co-production approach (including representation from fisheries interests) to address a range of agricultural pollution problems. The forum is focussing on key areas including better advice, better regulation and promotion of innovative approaches to key areas of agriculture.
Members of the sub-group have successfully bid for additional resources to be allocated under the Welsh Government’s Farming Connect programme. The immediate intention is to focus on preventing agricultural pollution in 25 catchments deemed to be at greatest risk. Evidence from both NRW and Welsh Water is being used to develop and deliver bespoke frameworks of information provision and support for farmers, including workshops, farm visits, one-to-one advice clinics and signposting to the relevant investment measures. At the same time, a new national campaign will encourage all farmers to think about how they plan and invest to prevent pollution from happening. The initial Farming Connect bid is now being worked up by Welsh Government’s contractors (‘Menter-a-Busnes’) with a view to starting work on the Delivery Plan as soon as possible.
The work of the sub-group is set to continue into 2019 and probably beyond as further work on the new Farming Connect delivery plan progresses together with investigation of the role of Farm Assurance schemes, and exploration of new regulatory approaches such as that now being pioneered by the Food Standards Agency.
NRW believes this is a substantive expansion of the focus on risk associated with agricultural activities, with a clear intention to improve the environmental quality of our rivers. Although the current focus is especially relevant to south-west Wales, newly-developed principles will apply across Wales.
Sewage pollution
The periodic review of water industry prices is determined every 5 years by OFWAT. This determines prices charged by water utilities to finance service delivery and compliance with national legislation and European Directives. In the past this process has seen significant improvements to water quality. The current round will facilitate new ways of working as set out by Welsh Ministers on the well-being of Future |Generations Act 2015, and the Environment (Wales) Act 2016. This will include attention to water industry assets that cause water quality problems in our rivers, and utility assets that might represent barriers to fish migration (of most relevance in South Wales valley rivers).
ENFORCEMENT
Many people have raised the issues of enforcement, mainly referring to the resources available to NRW to undertake this work.
The term illegal fishing is broad, covering many activities ranging from organised illegal netting to unlicensed rod and line fishing by a single angler. We take a risk based approach to our enforcement work, focussing on the activities which present the biggest threat to our wild fish stocks. In recent years, we have successfully taken several prosecutions for
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netting and the use of illegal instruments which have the capability to take large numbers fish.
The present conservation status of salmon and sea trout means that any illegal fishing with the capacity to catch several fish represents a substantial threat for those species. Intelligence, incident reports and past and recent cases show that there is a level of illegal activity taking place across Wales. However, we contend that the level of this activity is significantly less than in the 1980s and 1990s.
Our team of Fisheries Enforcement Officers are passionate, proactive and committed to tackling the problems which remain, but are heavily reliant on information from the public in alerting them to the various forms of illegal activity taking place. Unfortunately, it is still the case that many suspicious activities are still not reported to our hotline, and we would remind everyone of the importance of doing so.
Enforcement resources
In 2017, the staff resources available to us was the equivalent of 16.4 full-time officers delivering fisheries enforcement across Wales. This compares to approximately 60 such officers in the early 1990s, although their work then was more diverse and included other fisheries work.
NRW, along with the wider public sector, has been subject to significant financial pressures which have impacted on the delivery of all services funded by Government Grant-in-Aid. This includes fisheries enforcement. We realise that our stakeholders would like to see more bailiffs patrolling the coastline and rivers of Wales. The reality is we are unlikely to return to the numbers of decades’ past. However, the way we target our effort is evolving, and we are making the best use of the resources available. We identify and review the key risks to our fish stocks regularly and adapt our work to address them applying a consistent response across Wales.
In early 2018 we will be providing training to warrant a further four staff under SAFFA. These officers will not be solely focussed on fisheries matters, but will provide resilience and contribute to succession planning of for this area of work.
We have, and will continue to explore ways of disrupting illegal activity and working better with partners such as the Police and Welsh Government. Upon apprehending those committing fisheries crimes, we will use our powers to prevent and deter further offending.
Inability to enforce new regulations
NRW wants to create a fair environment for legitimate anglers and net licence holders. We invest resource in checking rod licences and compliance with byelaws. We recognise that some anglers without licences are likely to be ignorant of the byelaws designed to protect, preserve and improve fish stocks, therefore presenting an increased risk to the survival of our vulnerable species.
Ensuring those active in our net and rod fisheries comply with byelaws is one of our key fisheries enforcement priorities. Reports of illegal activity relating to the proposed new exploitation control measures have already been identified as constituting a ‘high’ level incident meaning that wherever possible we will respond to these occurrences. We will take a robust approach where byelaws have been contravened resulting in the loss of, or likely loss of migratory fish. In addition, we will ensure that we utilise our communication
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tools to promote our work as we recognise that this can provide a significant deterrent to anyone considering illegal activity.
Next Steps
We are in the process of responding to all those responders for whom we have contact details. We have analysed the issues and points raised and have taken account of all proposals for refinement and change to the proposed measures.
Once we have a final proposal for new byelaws, which may either be those advertised or an amended version as a result of representations received, we will at the next opportunity seek the approval of the NRW Board to apply to the Welsh Government Cabinet Secretary for confirmation. The Cabinet Secretary may, after due consideration, approve our application or may decide to approve with amendments required by Welsh Government, or may decide not to approve the proposals. A similar process will be followed by the Environment Agency for those parts of the Dee and Wye catchments in England. Our clear intent is for integrated measures for each catchment.
Once we have a decision we will publicise this as soon as practicably possible, together with catchment summaries of the implications of the new measures.
I am sure that you will agree that the health and sustainability of our important stocks of salmon and sea trout must be the important focus of our efforts. This is a good example of our statutory roles as set out by Welsh Government in their Natural Resources Policy :-
(http://gov.wales/topics/environmentcountryside/consmanagement/natural-resources-management/natural-resources-policy/?lang=en)
Although our consultation has focussed on the protection of adult fish during their migration to spawn and re-populate rivers with their progeny, it is the environmental conditions in the river that must be the focus of our efforts going forwards. Saving fish so that they may spawn only makes sense if the conditions in the river are of sufficient quality for survival of their progeny. Our ambition must be for each river to be optimised for smolt production (thereby securing benefit and the wellbeing of all fish species and other river fauna). NRW takes this extremely seriously and has been greatly dismayed by the well-publicised pollution incidents that have damaged populations of young fish. I hope you will see in our response to the concerns expressed in the consultation process, and in our future action, that NRW is actively addressing these matters using the resources available to us. Anglers will be key partners among those who scrutinise what we do.
The measures we are proposing are a key part of the strategy which is to safeguard and maximise the numbers of fish that survive to spawn. This action will safeguard these iconic species for the benefit of future generations.
Yours sincerely,
ww




Another super springer.  This time from the North Esk.  Will it be the Wye's turn soon. Must be surely.