More Wye woe in the Hereford Times. Better late then never I suppose. Conversely a full page on how people are rushing to work for Avara foods, the chicken shed supremo's/ !!
As for this below from Sophie Gott. NRW you just might as well throw it in the bin.
No shortening of the season on the upermost river, no shortening of the Wye or Usk season themselves so no back end protection for the fish they say they are trying to save to ensure enough spawners. NUMPTIES.
REPRESENTATIONS MADE TO STATUTORY CONSULTATION:
Proposed new salmon and sea trout rod fishing byelaws for the River
Usk and River Wye in Wales 2021.
We would like to thank you for the time and effort you have put into providing your
response and to clarifying your points and observations. This is not an easy subject, and
we are aware that it is an emotive one for many. We hope that this letter addresses the
points you raised and that you have found the content helpful.
If you wish to respond to this letter, please do so as soon as possible, and by 29th
October 2021, by emailing Fisheries.Wales@cyfoethnaturiolcymru.gov.uk.
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.
This letter refers to your representation on rod fishing byelaw proposals for the River Usk
and the River Wye in Wales: The River Wye Rod And Line (Salmon And Sea Trout)
(Wales) Byelaws 2021; The River Usk Rod And Line (Salmon And Sea Trout) Byelaws
2021.
The proposals for the River Usk and the River Wye were published, together with
associated documents, on 19th July 2021 and the consultation lasted for 12 weeks before
closing on 11th October. We received 27 representations to our proposals, containing a
total of 11 objections and 83 approvals to the 5 individual byelaws proposed; we are now
in the process of reviewing and responding to these representations.
This letter now provides our response to your representation and seeks to cover the points
that you have made.
We believe that you have objected to:
• The removal of the additional weeks’ salmon fishing in the upper Wye and
tributaries
You have also raised points relating to:
• Shortening the salmon fishing on the Usk to end 15th September
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).
We would also like to note your support of our proposals for C&R for salmon and sea trout
on the Usk and Wye, and we thank you for that support.
Response to objections and proposals to end the season on the 15th
September
We note your objection to our proposal to end the salmon fishing season on the 17th
October for the whole of the River Wye and tributaries. It is not clear from your response
whether you are suggesting that the season ends earlier than our proposed date of the
17th October; however since you recommend ending the Usk fishing season on the 15th
September, we are taking it that you are also proposing that for the Wye.
We note your request that there be a 5-year review period. These byelaws if enacted, will
not run for the full 10 years that we would usually request, but will end in 2029 to coincide
with the end of the ‘All Wales’ and ‘Cross Border’ byelaws. We have decided not to include
a mid-term review as the timescale is shorter than usual, however, the ‘All Wales’ and
‘Cross Border’ byelaws will be subject to a mid-term review and any broader improvements
in our approach to stock regulation will be applied across all Welsh rivers including the Usk
and Wye.
Regarding your proposal for the salmon season on the Usk and Wye to close on the 15th
September. We have assessed this proposal and have calculated that it would save
approximately 24 salmon on the Usk, and 64 on the Wye.
Whilst we acknowledge the potential to save more fish under your proposals, we also have
a duty to consider the socioeconomic value of the fishery. We believe that the proposals
made here for 100% C&R, are proportionate. These measures sit alongside the additional
method controls (restricting hook size and type and the use of barbless hooks to expedite
release) introduced in the ‘All Wales’ byelaws will help to improve handling of fish to be
released and reduce potential mortality after release. By manging the fishing as C&R and
having introduced the method restrictions, we believe that we can maintain the
socioeconomic value of the fishery whilst protecting the stock. Furthermore, closing the
salmon fishing season on the Usk and Wye on the 15th September would have a
disproportionate impact on those anglers fishing the upper beats, where fish tend to arrive
later in the season. On average 26% of the Usk and 32% of the Wye rod catch is caught in
that last month, and there would be a socioeconomic cost to the proposal to end the
season earlier.
We do not believe at this time that altering the fishing seasons on the Usk and Wye is
proportionate.
We invite you to withdraw your objection to the removal of the additional weeks’
salmon fishing in the upper Wye and tributaries on the basis of the information
given above. However, if we do not hear from you by 29th October 2021, we will
assume that you wish your objection to remain in place.
Next Steps
I am sure that you will agree that the health and sustainability of our important stocks of
salmon and sea trout must be the focus of our efforts. Although our consultation has
concentrated on the protection of adult fish during their migration to spawn and repopulate
rivers with their progeny, it is the environmental conditions in the river that must be the
focus of our efforts going forwards.
NRW’s approach is a broad range of proposed measures to address the numerous,
complex causes of this problem, and to ensure that land and water are managed
sustainably (read details of these measures in Natural Resources Wales / Salmon and sea
trout plan of action 2020). The proposed byelaws are an integral component of this suite of
measures as they would preserve vital breeding resources whilst other threats to relevant
habitats are addressed. Our position is that stocks may be exploited when they are
sustainable, but that until they are, we must ensure that pressures are moderated or
excluded to achieve this goal.
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 protect these iconic
species for the benefit of future generations.
We recognise the need for a fully integrated approach for the border catchment of the Wye
and are working together with the EA to ensure that this happens in a practical and
sensible way.
NRW have concluded, in light of the status and spawning deficits of Usk and Wye salmon
and sea trout stocks which consequently are deemed unsustainable with risks of ongoing
decline to unsafe stock levels, that the proposals are necessary, proportionate and
reasonable.
We are in the process of responding to all those who objected to the byelaws. 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 seek the advice of the
NRW Board to support approval 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.
Once we have a decision, we will publicise this as soon as practicably possible.
Yours sincerely
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