Thursday 14 October 2021

 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.


And then they say this;  NRW have concluded, in light of the status and spawning deficits of Usk and Wye salmonand 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.

This paragraph in particular is plainly ridiculous and shows utter incompetence.
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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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