Transcription of meeting between Andrew Nicholson (Angling Times), John Eardley (CPWF), Peter Gough, David Mee and Ian Davidson (NRW) on 15 February 2018
1. Andrew For the tape and the transcript, could we all please introduce ourselves Nicholson – Peter? (AN)
2. Peter Gough Yes, my name is Peter Gough and I work with Natural Resources Wales (PG)
3. AN Ian?
4. Ian Davidson Yes, I am Ian Davidson and I am a Fisheries Biologist with Natural (ID) Resources Wales
5. David Mee I am David Mee, Senior Advisor with Natural Resources Wales (DM)
6. John Eardley John Eardley, I am with Gwynedd Local Fisheries Advisory Group, (JE) representative for Prince Albert. Not that I have got that hat on today but secretary to The Clwyd, Conwy & Gwynedd Rivers Trust and also now strategy officer for the Campaign for the Protection of Welsh Fisheries.
7. AN Ok thank you. My name is Andrew Nicholson, angling journalist, Angling News, consultant and also representing today Welsh Game Anglers Action Group. First of all gentlemen, we thank you for agreeing to the meeting and also for facilitating the room here in Shrewsbury which is 15 November. The purpose of, our part of the meeting is in relation to the NRW proposals. The Welsh angling community is in total despair, angry and distraught and at a loss as to why these proposals have come about and there are more questions than answers. The following questions are a collective from countless stakeholders, Angling Trust, bodies along with the main copy, list of game anglers throughout Wales, and very many hundreds that visit, holiday and fish in Wales. Many that travel from Europe and other countries. Today John and I are representing those anglers with their questions and statements along with one or two of our own. So I would like to start with the questions if I may gentlemen. The process and the promotion for the consultation is seen by many as seriously flawed. And it is not difficult to state that this was the fact as far as we are concerned of burying bad news. How many, the question is how many Welsh anglers actually read the London Gazette? That is the first question we would like to ask you.
18296037.1 8. PG Ok, you ready?
9. AN Yes, whenever it suits yourselves.
10. PG We have followed the procedure and the process as set down for managing the salmon stocks and for managing public consultations precisely so I take your point that not many people subscribe to the London Gazette but nevertheless that is a requirement placed on us to advertise it in that location and what we seek to do is to bring that to the attention of as many people as possible through existing stakeholder groups, use of our own website and publication in Welsh national newspapers as well.
11. AN Ok thank you for that. You stated that you emailed anglers with regard, the ones that you actually have the emails for, today we have John and I and all the rest of the groups I have spoken to are countless anglers and as yet they haven’t found an angler that received an email from you. How many anglers did you actually email?
12. PG Dave?
13. DM Uh it is around 360 I believe that we have email contacts for and importantly had also ticked the box that said to allow [uhm uhm] us to communicate with them. Ok lots of people obviously have been online, more requiring licences online and we have email addresses for but they had not importantly ticked the box where they are allowed to, and it was only of course anglers in Wales.
14. AN Thank you for that. The question that everybody is asking is that surely to alert all the anglers of the forthcoming proposals, would it not have been easiest because basically you have the address of every single angler to put a slip of paper when they get their licence and you would have told everybody that the proposals were due. Wouldn’t that have been the sensible thing to do and the democratic way forward?
15. PG Well the logistics of doing that at the Post Office including anything out of the ordinary in the mailshot make it impossible to do that. We adopted the other approach which is for the previous two years in discussion with other fisheries groups, other associations and net fishing groups etc. we decided to communicate through that means instead. We treat our local fisheries group members as representatives of a jurisdiction, if you like,
18296037.1 2 a group of anglers and we expect and hope and ask for them to communicate messages in that way.
16. AN Would you not concede though that you could have actually done better in alerting the general populous of the game angling groups to these proposals because there are some anglers today that don’t know anything about it?
17. PG Well there is always more that you could do. The question is how much is necessary to do that and the best use of public money etc. So we believe over a long, long time period using all the dissemination methods we have available to us that we contacted as many people as it was possible to do.
18. AN The major angling press would have run this for nothing but it didn’t appear in a lot of major angling press.
19. PG How something appears in the angling press [talking over each other].
20. AN It has since when it comes to the attention of them but you did not actually alert them.
21. PG Well they were included in all press releases explaining what was happening when we started the consultation so the main angling magazines received those press releases or should have done at least. They were certainly sent to them.
22. AN OK
23. PG So whether or not they publish it is of course a matter for them.
24. AN Right ok well thank you for answering that one. Onto further questions, who exactly did you consult with to arrive at these proposals, which leading fishery scientists and experts along with consultants did you consult with? And where are the findings from your consultations? There has been a threat of catch and release at LFG meetings but this is not classified as consultation. We see these proposals as your own personal beliefs.
25. PG Well there is nothing personal in this. This is a professional relationship between ourselves and Welsh Government and their advisers so it is wrong to personalise this. We are following set procedures for stock
18296037.1 3 assessment which we would like to go through with you shortly and we follow those to the full extent of the operation of guidance and instructions that are set down. So Welsh Government charge us with managing this resource and we do so to the best of our ability. You know we are their public servants who carry out the role on their behalf. We do not accept that it is necessary to consult professionals because we are the professionals in this regard and anyway, the fisheries consultants around the country are all familiar with and indeed many of them were formative in a generation of procedures we follow. When we compile the technical case that you see in front of you there, and we debated this with the Environment Agency but we also submitted it to Welsh Government and they referred this to their technical advisers CEFAS. CEFAS carried out a peer review of that document and were very complimentary about it.
26. AN Ok
27. PG And we can provide you with the words that they provided to us if you wish.
28. AN We would appreciate that but emm
29. PG Dave, can you make a list of summary actions, the first action is to check with CEFAS that they are ok and Welsh Government were ok with that being made available. I see no reason why not but that is not our decision to make.
30. AN Ok we appreciate that but we would be interested to know if there were any outside consultants or fishery scientists that were brought into this that were not part of the organisation? In the Welsh Government
31. PG So the answer to that is that CEFAS are the professional advisers to the Environment Agency and to...sorry not to the Environment Agency, to DEFRA and to Welsh Government and they are also the national representative on international fora for salmon management
32. AN Ok thank you. What impact risk assessment survey has taken place not only on the entire angling community of Wales but the inevitable adverse effect it will have on angling tourism and the economy of Wales all of the social economics involved, we have not seen as yet any vital information on this matter.
18296037.1 4 33. PG We would refer you to the technical case where we deal with social economics having taken the advice of our social economists in compiling that material.
34. AN And this is the same organisation?
35. PG Yes, yes
36. AN So what scientific proof, evidence and research have you that banning worm will have the slightest effect in increasing stocks? Again, we would like some proof on this please. It is totally wrong to assume that anglers who fish the worm kill all the fish, in fact the reverse. The vast majority carefully return the salmon.
37. PG We would refer you to the technical case where that might mention that information.
38. AN Ok thank you, again we, the question that is asked is what scientific proof, evidence and research have you about using a single worm as opposed to a double worm will have the slightest effect on increasing sea trout stocks. Again, it is totally wrong to assume that when a single worm is fished, that salmon will not take a single worm. Why have you not proposed the use of circle hooks that is becoming an angling standard with no possibility of deep-hooked fish?
39. PG Ok there are a number of points there. If you will remind me about them as we go through.
40. AN Yes of course
41. PG The issue of hooked salmon and the worm is one based on risk of salmon by catch. There is no absolute certainty that one or two or three worms would achieve the objectives we set out but it is a risk basis and we believe that small hooks, single worms are less likely to catch salmon whilst enabling sea trout angling to continue. This has been a careful balancing act to ensure that salmon which are seriously threatened can be preserved and have minimum impact on ongoing sea trout fishing. That is that. That is a risk based decision. The use of circle hooks, yes I am very familiar with this and the use of them in North America in particular, I’ve used them myself there, and for some species they do eat, even things like halibut, they do seem to be effective. However, in this country we are also aware of trials with circle hooks which did not
18296037.1 5 yield the, such positive results and because of that and because of our will to be, to achieve our objectives whilst having minimal effect on fishing we decided not, we did consider it, but we decided not to bring this in.
42. AN Ok would, again we would be very interested to see the trials and research with regard to the circle hooks and as yet none of us have seen any of this information. If we can request that that would be very helpful. Thank you very much.
43. PG We will seek that and provide it.
44. AN Ok the prominent and eminent fisheries scientists, official angling bodies i.e. the Angling Trust, Fish Legal, the entire angling press such as Trout and Salmon, Fly Fishing, Fly Tying, local press and a growing number of Assembly Members. Prominent anglers, the vast majority of anglers, clubs, associations along with the game angling community as a whole totally disagree with your proposals calling them and I quote “draconian, divisive and destructive” along with many other negative phrases. Why do you as an organisation totally disagree with their professional thinking? Surely this is not democratic to ignore all of the above and you seem to stand squarely alone on this and the message that is coming across is that all these people are wrong and you are right.
45. PG Well the difference is that we have a statutory obligation set to us by Welsh Government to conserve the natural resource of salmon and sea trout and other things in Wales. So we are the only ones charged with that duty. You say we stand alone, it doesn’t appear the case from the other jurisdictions in the British Isles where similar measures are being proposed; and, indeed, the Environment Agency are scheduled to launch their statutory consultation on similar, not identical, measures later this month.
46. AN Ok, thank you for that. At various meetings you have attended the one single common denominator that came out of the meeting is that you did not listen, won’t listen and have no intention of listening and that you cannot see beyond your own beliefs or the beliefs of what you believe that your organisation is. This appears to be not democratic and it appears not to be a consultation.
47. PG Well I think you know as you say the meetings we have attended, we actually attend these meetings to listen to people. We have how many local fisheries?
18296037.1 6 48. DM Nine
49. PG Nine local fisheries groups around Wales, we also have Net Fishing Groups. One or other of the three of us has attended every one of those for, what? Probably the last five years or more, certainly for the past two years. We do this because we want to maintain a good, close and productive working relationship with anglers. We listen to what we hear. We answer where we can and find out the results of queries and provide those where necessary. We provide all of our annual stock assessment reports to these audiences together with juvenile survey information and we also use the fora to promote messages around fish health investigations, fish licencing, other developments within our, in the way we are structured and the way we operate to the launch of the new legislation in Wales which is fundamentally important to the whole question we are talking about today, the sustainable management of natural resources and the Environment (Wales) Act. So these fora we use for two way flow of information. We provide information and we listen to what we get back. It is not possible for us to provide a satisfactory outcome to every individual member of these fora or indeed the fora themselves. There will always be differences between those charged with statutory regulation which is ourselves and fishermen. There are always going to be differences I am afraid particularly at times such as this when stocks are under stress. So although we want to be everyone’s friend we have duties to perform on behalf of Welsh Government and we have must do that to the best of our ability and that will cause debate. We are well aware of that.
50. AN Ok but in these meetings, if I may harp on this one please, are you actually taking on board and listening to what the clubs and associations are actually saying? Do you actually take on board any of these aspects that they actually bring up in front of you?
51. PG Well I think it would probably by helpful if you posed that question to the Chairs of the LFG’s and we can certainly provide you with contact details for those to see what they believe the relationship between NRW and the stakeholder groups is. We do listen but listening does not mean that we always conclude that we must follow the messages we are given. Wherever we can, within reason, we absolutely do that, but when there are difficult decisions to be taken, such as those put in front of us right now we must follow our governmental advice, our international commitments and agreements and the within jurisdictions procedures that we follow such as salmon management, stock assessment decision structure etc. which we will go through with you later.
18296037.1 7 52. AN Ok, thank you. One of the big questions that so many people asked is why were the hatcheries closed? Especially private ones. What possible harm were they actually doing? Using only brute stock from the river system like the Dyfi which proved it worked. Three to four years after the instigation of the Dyfi hatchery they previously recorded catches of 400 sea trout. Over the years this has, year on year, steadily increased. Now recording this last year catches of over 2,300 sea trout. The proof that hatcheries work is overwhelming, not only in England, such as the King of the Hatchery, ones in Scotland and in Ireland the Delphy Hatchery which is a shining example as are all those ones in Iceland and there is a new hatchery actually being built in Cornwall. It would be interesting for you to actually come clean and confirm why hatcheries are closed, was it an NRW cost cutting measure and to justify closing the state ones that private ones were also forced to close? We believe that the NRW got this one wrong and when I spoke with you Peter, you did mention on the conversations that there was a possibility that hatches may be reinstated.
53. PG Well the purpose of the meeting today is to discuss the matter at hand which is the proposals for byelaws. It is not to revisit hatcheries. So I am not going to do that now. However, you asked a couple of specific questions. In the broad church of management of salmon and sea trout and indeed any other species you care to mention such as the arctic char or pearl mussel or crayfish, there may come a time when we have to balance the risks of local extinction with artificial maintenance of a population. We are not in that position at the moment so we are not proposing to address that right now. You asked also whether this was a cost cutting measure. Patently it’s not because the revenue costs of operating the hatcheries are still invested into fisheries, habitat and river restoration projects at the moment and I can give you some figures on that at some point, not now I suggest, if you wish.
54. AN Yes please but it still doesn’t really answer a privately funded hatchery that was doing no harm and was actually working, nobody can understand why that was actually closed down?
55. PG Well I do not think your statement that no one can understand that is entirely correct. The decision was taken three years, four years ago or so now. It is taken
56. JE 2014
18296037.1 8 57. PG Yeah a date etched on my memory John. The decision is taken. The decision still holds. We have reasons for doing that which we set out at the time and we don’t intend to revisit that today here.
58. AN So really we are not clear on why private hatcheries were forced to close?
59. PG Well you’re not clear but we are.
60. AN Yes but the general public who are asking these questions, and who actually pay their licence fees would like to know why?
61. PG Well perhaps you would like to ask them to pass their questions on to us.
62. AN We will certainly do that yes, no problem at all.
63. JE Can I just come in on that one, just on one point? It was something I picked up on in the advice on the precautionary approach. Where it says ICES or other scientific advisers should be requested, inter alia, to advise in the light of current conditions in the fresh water and marine environment on stock rebuilding programmes including where appropriate habitat improvement obviously and stock enhancement. Does that mean
64. PG Are these words from NASCO
65. JE This is from the NASCO precautionary approach.
66. PG Yeah I think you need to check the date on that
67. JE It’s 2017
68. PG Oh really okay. I wasn’t aware it had been relaunched. Maybe that is when you printed it?
69. JE It is just something I picked up which jumped obviously off the page.
18296037.1 9 70. PG The NASCO precautionary approach was published several years ago and I have in mind it’s nearer 10 years than 5 years.
71. JE I mean if it being an old one, I am very careful what I pick up.
72. PG Well maybe more careful than, although you know we are very familiar with the precautionary approach and stock rebuilding programmes. The stock rebuilding programmes theoretically cover a situation where there are no salmon present at all because of various extinction events in the past - typically industrial revolution – and, as we have said before, we support the use of hatcheries to accelerate recovery of losses in those scenarios. Stock rebuilding might also exist where population is achieving 90% of its capacity. The stock rebuilding programme then would look very different to an extinction scenario.
So it’s a very broad range of scenarios covered with that and a broad range of management responses. You know I would observe at the moment that NRW is involved with captive breeding programmes for arctic char, pearl mussel, white clawed crayfish and some other species which are, less significant for us here today. And those are supported by our biodiversity resilience board and they were intending to do exactly what it says which is to rebuild stocks which are at threat of ongoing loss and local extinction.
73. AN Ok well personally I find that answer inconclusive and I would request respectfully that this could be answered more in full.
74. PG We will consider doing that Andy, but these are decisions that are taken by NRW and its executive and its board. They are not questioned by our supervising bodies in Welsh Government so with respect we will do what we can but we are not going to spend an inordinate amount of time re- justifying decisions previously taken.
75. AN Well these are the questions that the licence fee paying public are asking and I feel duty bound that they should be asked and it is a question that has been on my mind and John’s mind and many other people so you can understand why we are asking it.
Okay I will move on. The next big question we are asked continually is why still issue licences for estuarine netting coracle fishing when clearly your maths and figures show that these are clearly uneconomic for all concerned and if I may quote you some figures please: Net licence income for 2016 was £16,460, total catch of salmon 241, total sea trout catch 1,384. Therefore the maths: each fish cost the netsman £10.13 in just licence fees alone. Without costing in the running costs of boats,
18296037.1 10 fuel and maintenance, time and equipment, this quite clearly does not make any sense. Or simply put, the netsman due to the severe under policing by the NRW or maybe lack of funds that the netsman we can only assume and declare that they are grossly under declaring their catches.
76. PG Well I don’t recall you or anyone making these observations in your representations.
77. AN It was quite possibly, I have got the piece of paper here with us, facts and figures were put before you. In our original proposal from a Welsh game angling action group those figures were there and they have been sitting there since before Christmas on your desk.
78. PG Can you turn that off a second please
79. AN Sorry
80. PG Could you turn that off a second please
81. AN Why
82. PG Because I want to ask my colleague
83. AN I can pause it
[Recording paused.]
84. AN Ok we are resuming now after a private discussion.
85. PG The policy of licensing nets is not set by NRW. The policy for these areas of fisheries are set by Welsh Government so I suggest you put those questions to Welsh Government.
86. AN We have put those questions to Welsh Government but so far we have not had any answers to these.
87. PG They will probably ask us to provide information to support that and you know we are well able to do so. We have to have our mind on our
18296037.1 11 guidance and our management about what is a priority at the moment. But we have nothing to hide about this.
88. AN Okay
89. PG Let me just say we have nothing in principle against net fishing or of course rod fishing. We recognise the roles both have for recreation, rural economies but we are also aware of their roles in the case of some of the net fishers in Wales in the area of culture and heritage. We have asked the questions before about the relative merit and the relative balance of the two fishing forms, net and rod, and we continue to seek guidance on how that should be apportioned. We are well aware of the relative social economic benefit of both sectors but we are not in a position to take action against perceived heritage and culturally valuable fisheries and neither would we want to as a matter of principle.
90. AN Okay, I…
91. PG …May I, can I just answer a couple of questions, a couple of allegations of ..
92. AN It is not allegations, it’s, we were…
[several people talking]
93. DM It’s pure allegations of under-reporting by nets and I just wanted to cover that with the amount of information we have back of nets. Since 2010 then all salmon, sea trout and net fisheries need a carcass tag placed in them. They also have a log book which is inspected by our enforcement staff that they have to return. At the present time that has been 100% return for both tags and unused tags and log books in those fisheries. Those fisheries are checked every year by enforcement staff and some of them on a regular basis, the large ones in particular, specifically the Tywi and the Teifi, there are regular net checks. I don’t have any information to suggest they are vastly … or even under reporting the catches that they have, that is rumour.
94. AN Well the facts and figures, these are your facts and figures that basically for every fish that they are declaring it costs the netsman £10.13…
[All talking over each other.]
18296037.1 12 95. DM …that’s what they are declaring and what they are paying because that is not to say that they are not declaring catches. I do not believe there is any great under declaration from the net issues.
96. AN Okay, well it just does not make sense that basically a £2 sea trout that has cost them £10 to actually catch, it’s a commercial operation this, how can they possibly operate with those costs selling a £2 sea trout for £10.13, it just does not, the facts and figures which are yours don’t actually add up.
97. JE Well you can understand why we are asking you this.
98. PG It depends what criteria you consider, that the numbers of fish being caught in net fisheries in Wales is a tiny proportion of the numbers being caught in net fisheries in England. That immediately tells you something about the relative…
99. AN These are Welsh figures, they are your figures and this is data in Wales
100. PG Andy, I understand that, what I am saying is that although there may be a commercial - a large commercial - fishery currently operating in England, that same term wouldn’t be used for net fisheries in Wales. The numbers of fish being caught is far, far lower which means that some of the people engaged in net fishing are not in it for commercial purposes. There is nothing wrong with a heritage fishery being enjoyed for a recreational activity for example and I think we would all conclude that that is what some of them are.
101. AN Okay, well I am very glad that you mentioned heritage and recreational because we will come on to that with regards anglers later but if I may hold that point for now.
102. PG Well I just repeat for your transcript, here, what I said in closed session just now, that it would have been very helpful if you had given us forewarning of these questions because you would have had a more profitable meeting.
103. AN And if I may repeat what we said before, all these questions, all these statistics and all these figures were put before you and you acknowledged them in our respondent document and you responded saying that you had received them and you answered some questions but you didn’t answer all of the questions.
18296037.1 13 104. PG As I understand it, these are new questions
105. AN No they are not new questions, they are … put before you by several respondents.
106. PG In that case we will already have answered these questions.
107. AN Well this is why we are asking them today, they were not answered.
108. PG So which questions did you answer?
109. AN Well I answered the ones that, basically the ones that I am asking you today but all the… some of the questions, these questions are not on here, is the questions that you have not actually answered that were on documentations by the various representative groups.
110. PG I don’t believe that there are any questions which were not answered in the process of the statutory consultation. So if you are repeating questions now...
111. AN No we are not.
112. PG … so, as they are new questions, as I said, it would have been more profitable if you had shared them with us beforehand.
113. AN The questions were asked but they were not answered.
114. PG You just said they were not.
115. AN No, these questions were not answered hence why I am asking them now.
116. PG Well…
117. AN But they were in the respondent details that we sent to you and you confirmed that you received them.
18296037.1 14 118. PG .. and are you confident that they weren’t answered, have you examined the..
119. AN Yes we have …
120. PG …consultation responses?
121. AN Yes we are confident.
122. PG Well, if we answered them, if you have already asked them then we will have answered them. If you have not already asked them then I agree that we would need to answer them now, or at some time in the future.
123. AN Okay, thank you. Well I mean obviously ones that you cannot answer today then we appreciate that you need a bit of time and that can be answered at a later date.
124. PG Well, if you could indicate which are the new questions, we will consider providing answers to those.
125. AN Ok
126. PG If they’ve already been asked - and as you indicate most of them have been - then there is no point in wasting our time.
127. AN No, there is a point, because they have not been answered, and this is why people want the answers, and this is one of the reasons for the meeting today. We could go round in circles, it would be a lot easier just…
128. PG I think we have demonstrated that we can go around in circles.
129. AN Yeah
130. PG Do you want to carry on?
131. AN Yes please if I may, thank you.
18296037.1 15 132. DM Can I just add one thing to the net rod debate: in that we have tried to take an equitable approach between the two fisheries.
133. AN Ok, thank you for that input. As far as we are concerned the economics and the figures do not add up as per EA and NRW combined figures valuing licence revenue for fish caught and retained in 2016. The total rod caught salmon and sea trout retained is 8,300, the income for those licences is £1,440,332. That brings in a revenue of to your NRW of £172 per fish. The net caught, total fish caught, is £62,110. That is the income from net licences which is actually 100,000 which equates to £1.61 per fish. So to sum up the anglers contribute the vast majority of funds that go into the NRW are not actually from the net and I think that is a point that has got to be worth noting.
134. PG Well I think, you’ve just made a very good point of a list of statistics, it would have been helpful to have seen beforehand but we won’t go round that circle again.
135. AN Okay
136. PG As I said, right at the beginning of this particular part of the debate, the issue of apportionment of catch between rod and net fishery sectors and recognition of heritage and culture value, perceived or real, is a matter for Welsh Government: they set a policy in this area.
137. AN Okay, thank you for that. The Osprey Centre on the Dyfi, I gather that NRW made a donation to the Osprey Centre.
138. PG I wouldn’t be particularly surprised but I am not familiar with that.
139. AN Yes, well if I can say that there was a donation made. The point is that you’ve made a donation to the Osprey Centre, it is a predatory bird and last season they ate 150 sea trout that is actually recorded at the Osprey Centre. Basically you are donating to an organisation for a bird that eats the very species that NRW are trying to protect and the irony is not lost. The main question is you obviously, and it is very laudable and admirable that you made a donation, but in that same financial year, did you make an equivalent donation to an angling organisation on the Dyfi?
140. PG First of all our role covers a broad range of biodiversity in Wales, whether it is aquatic, terrestrial or whatever it is, organisms. I don’t see that there is a particular issue here with trying to restore a very rare part of our
18296037.1 16 biodiversity which is much appreciated by many hundreds of thousands of people in Wales and beyond. In answering your questions about whether we donated, donation is the wrong term actually but that is a minor point, we provide funds for project work for fisheries across Wales. I am not aware of whether any of that specifically went to the River Dyfi in 2017. If you had asked me that question beforehand I would have sought an answer for you.
141. AN Well we could find the answer out. The point I am making is that I feel that angling should be on a level playing field with the laudable work of making a donation to the Osprey Centre which obviously gives a lot of pleasure.
142. PG We invest far more in terms of project, as far as I am aware anyway, in terms of project funds for fisheries development than we do for Osprey rehabilitation or whatever.
143. AN Okay well thank you for answering that. Avian predation I’d like to quote you Dave and these are your own words from the Post: “NRW already issue licences for the control of these birds but before issuing any more it would require evidence of specific harm to fish stocks.” This is what you wrote in an article.
144. DM Did I?
145. AN This is actually…
146. DM I do not remember actually saying those exact words.
147. AN Well it is actually quoted in the paper there. While you’re reading that, this makes the critical vital question, have you actually read the Angling Trust website on these birds, have you seen the website, Cormorant Watch, have you seen the recent programme Countryfile, and plus the overwhelming evidence that year on year cormorants and goosanders are growing significantly in numbers? There appears to be, on this subject, a naivety within your organisation.
148. PG Well the answer to, have we seen, is mostly yes although I don’t recall the Countryfile programme.
149. AN Just recently.
18296037.1 17 150. PG Well, as I said, I don’t recall the Countryfile programme
151. AN Right
152. PG If that was relating to the conference of last year, I think, or the year before, hosted on the Tweed, then we are aware of all that happened in that conference and I am personally aware of the work of Niels Jepsen in Denmark, where the situation of cormorants is indeed someway worse than it is the UK. We are also familiar with the work of the Angling Trust and I speak with Mark Owen and Mark Lloyd quite regularly on this; we are aware of recent correspondence between them and Defra and the outcome of that which you may not be yet. So we follow this with considerable interest not least because it was by some way the most frequently mentioned pressure in our statutory consultation. So what we are doing as a result of this is reviewing all the procedures involved with the potential lethal control of one legally protected species which eats another legally protected species and I think you can see the conundrum that exists there. There are some of Natura 2000 sites which are designated because of their assemblage of cormorants etc. So we cannot enter a debate about lethal control of one species without thorough consideration of this in terms of biodiversity and other statutory objectives and protections.
So we are going through this review at the moment, we introduced - some 15 years before the Angling Trust - integrated catchment control measures on rivers in Wales as a result of Wye Management advisory group. We continued to promote that sort of integrated catchment licensing. Licences to lethally control must only be issued as part of an overall deterrent and scaring strategy. Any licence application must be accompanied by a reliable bird census data and that has been a constraint in some sites in the past. So we are - in fact, on the way here today Dave told me that the internal meeting in which we are going to arrange an external forum based approach to the review of this is now scheduled - we will be engaging with the RSPB, BTO and the Welsh Ornithological Society as part of that group and we will take everything into account including fish census data, matched with bird census data and known statistics about consumption rate and all available evidence on other catchments including the Atlantic Salmon Trust work, but also work probably 20 years ago in Ireland so this is not a new issue. Bird populations as I understand it, although Dave might correct me here, cormorant and goosander populations are not increasing at the moment, this is my understanding Dave, you can correct me.
153. DM Last couple of years have gone down, yeah.
18296037.1 18 154. PG So that is not any means of making…
155. JE .. I think they probably moved..
156. PG What do you think might have moved, John? you are absolutely right…
[Talking over each other]
157. PG You know what, that is indicative of some of the problems we have? You know, it is highly mobile species - you know - being scared from one place to another, doesn’t really achieve a lot.
158. JE One thing that I wasn’t aware of, please correct me if I am wrong on that, was that when I started to look at this, somebody pointed out to me if you get the licence in England to kill it actually gives you double the number of birds that it does in Wales…
159. AN Well I think we need the absolute facts behind that. I know…
160. JE …It was just something that was raised to me so it’s not something…
161. PG As a result of the work - maybe 5 years ago or so - in which the Angling Trust was involved, they - through the minister at the time, Ben Bradshaw - doubled the peak threshold of a number of birds which might be killed so it was a proportion of the extant population. And they increased the proportion of that population which could be lethally controlled on an England wide basis. That did not mean to say “that is normal, that is the new threshold, a new peak”. Everything must be arranged on the basis of local bird census data - and that I am sure is the case in England - but it certainly is in the case of Wales, that bird census data is matched to fish population data and other risks that come up, but the key to this is absolute reliability of input data because we will be scrutinised on this and getting it right. We are at the stage now where we need to make sure that the current procedures are appropriate, defensible and they are going to achieve their objectives without threatening, and I know you won’t like this, without threatening the conservation status of the birds in question and there are concerns from powerful bodies who believe that those populations are themselves under some pressure.
162. AN Okay
18296037.1 19 163. ? John I would have to slightly just...
164. AN …Now we are taking…
165. ? John …one more quick point on that, just to be, nothing for us to do here, but I wonder what the RSPB’s stance on cormorants would be if they were as routine dippers for kingfishers? That does not require an answer.
166. PG Yeah, yeah, I know and I take that point, and um…
167. AN Would it be? would it be?
168. DM We would like to say though that we are trying to take on board what people brought up in the consultation as one big hint and trying to move positively forward with that. We hope that we will have this new forum that comes through for both birds and fisheries to look at ways forward on doing that.
One of the key issues actually is good, reliable bird evidence because if you look at the WeBs count data it looks like the number of goosander is going down for the last couple of years. We have looked at data and we did a contract with the survey on the Dee, a couple of winters ago and we need to look and see how those numbers from a, as it were, professional count that was done on a main river then is matched up with what is coming through from licences from fisheries interest. There are obviously some issues, which I take very advisedly, when some applications come through with miracle numbers on there, small half acre / acre lakes with ridiculous numbers of birds on there and that is what really sometimes brings down. But we are looking and prepared to take a new look and try to engage on a new look with predation and what that means.
169. PG We will have news on this I suspect… when is this session?
170. DM March, mid March.
171. PG Okay, well surely after that we will be taking advice for our executive and our board on exactly what the external based full review will look like and clearly we need to engage with RSPB etc. who we talked about earlier. We will be coming to fisheries groups as soon as we can with details of how that is going to move forward and we will be looking at appropriate cross, or whatever it is called, representation and interest.
18296037.1 20 172. AN Well from our investigations and from the numbers, there is no doubt that the numbers are actually growing. With the cormorant watch, with talking with keepers on the rivers, anglers who are there all the time, these numbers are actually growing.
173. PG Can I just, you know, Dave’s explained the acceptable bird census data figures to you and although they are not as robust as they are in England, you know we have to be careful, about, I suggest, making statements which are unsupported by evidence? You know, we can only take the professional, currently, survey data that is available to us and that survey data is indicating that populations are not increasing at the moment. We do not take that lightly and we need to explore further to make sure that this evidence and information is fit for purpose.
174. AN Okay, well the muddle is …
175. PG …I just caution against...
176. AN Well there must have been some evidence available because in 2016 on the Dyfi you issued a licence to cull 6 cormorants and 18 goosanders, in 2017…
177. DM …Ok, well can I just?…
178. AN ...well, can I just finish please?...
179. DM …we do not issue licences to cull, you need to be careful about the language that you use. It is very, very important.
180. AN Well, the next licence was dramatically reduced to 3 cormorants and 5 goosanders so therefore there must have been some evidential material that made you issue those licences - under whichever term that you want to catch…
181. PG On the evidence: on which, the latter lethal control licence was issued, would have been based on the applicant’s evidence.
182. AN Right, okay.
18296037.1 21 183. DM And again, if the applicant is late in applying the numbers, reduce
184. AN So, they if it is, if they are late in applying?… does that not seem a bit of a? ….
185. DM No, because it’s over - they are set over _ a set period of time, Andy. Okay, so the season is from September to March or whatever, but if someone comes in in December it is pro rated though the season
186. AN On the Dovey Association, they applied for the licence at exactly the same time every year.
187. DM Well I can’t comment on that because I haven’t seen it.
188. AN Maybe it is something that is worth investigating, please, because I think there is a major problem as far as them eating: we all know the actual statistics of how much a goosander and how much a cormorant eat, and they are actually slaughtering hundreds and thousands of juvenile salmon and sea trout in our rivers year off, year on, and that is a problem that has to be addressed and however which way we couch it that problem has to be addressed. If this problem is addressed we will save thousands and thousands. Would it be right to say that basically you’re walking a very tight line; is it the case that you are so entwined with the RSPB that your hands are tied on this issue?
[laughter]
189. AN Well, would that be the case?
190. PG …strange bunch of metaphors there. We are not entwined with anyone. We have a professional relationship with other bodies, including NGOs such as RSPB: we have a great deal of respect for them and what they have achieved. And so we are not considering their sensitivities when we carry out our licencing procedure.
191. AN Okay, well, thank you for that. We will thank you for answering those. Moving on, if I may. This is a question that everybody is asking, as I hope you can appreciate that. These are questions that have been posed by many, many groups that we are talking with, and that we are representing today. If the three factors that we have just talked about - hatcheries, nets and predation - if those were looked at correctly and dealt with correctly, surely your aims and objectives would actually be
18296037.1 22 reached by preserving and enhancing stocks without making these draconian measures?
192. PG Well as we have said all along, there are a whole range of pressures affecting fish stocks. The number one objective is to conserve your spawning stocks so you have a reserve for future production. We are not stopping at that, and as soon as we are able to, we will move firmly on to all the other pressures: we have indicated what we are doing around fish eating birds; we have indicated the challenge around the licencing process and the fundamental data that supports that; we have explained to you what we are doing with nets - we have nothing in principle against net fishing - but we need the guidance which would come from the Welsh Government on apportioning available stocks.
I have forgot the other point you raised, but all these other issues are crucial to us: the subject of river restoration - which John will have heard about at the board meeting - has been challenging us for a year or so now. Longer really - depending on how you define river restoration - we have been investing in fisheries habitat work, which is a good example of river restoration, for 15 years or more. There is an increasing focus on that right now and I would like to move on to a discussion around that with you John particularly - because I do not know if your geographic interest is the same Andy – but…
193. AN Yes it is.
194. PG …but I would certainly like to move on and have a discussion about that before we run out of time.
195. AN Yes, we most certainly will. So would it be right in saying that with regards to the predation, before we leave this subject, that you are relying on the angling communities to actually apply for these licences but you actually do not do directly anything to protect the juvenile stocks in the river against this predation?
196. PG Well other than funding habitat work which indeed provides refuges from predators - which is not the direct objective I agree - that is correct because the licensing system there is there in response to applicants who have come from interest groups on our rivers.
197. AN So without anglers there would be no licences issued?. It has to be from the angling society/community?
18296037.1 23 198. PG No, it does not have to be from them, it can be from any interest group. It just so happens that I am sure that, without exception, that it is all angling groups.
199. AN Yes okay well I think we have covered that point.
200. PG …but one of the things we will be looking…
201. AN Thank you
202. PG …at is indeed this dilemma which I mentioned earlier about protected species eating another protected species and what the role of a regulatory organisation like NRW must be.
203. AN Okay yeah we will await that with great interest, thank you. One of the very, very big questions is asked by so many anglers. We were at the fishing fair on Saturday, there are, and correct me if I am wrong, there are only 16 enforcement officers for the entire Wales, is that about right?
204. PG Well it is there or thereabouts.
205. AN Ok
206. PG We deal with man days …
207. JE 16.4 I think
208. DM Yeah I think it’s about right, full time equivalents.
209. AN The point four is half the money use to be so we will miss out on them. Would it be right to say that you can’t have any more enforcement officers because of lack of budget or maybe not allocating the budget correctly?
210. PG Migratory salmonid licence enforcement is a grant in aid funded area of our business and Welsh Government, for reasons which I am sure are good but are reasons that they know about, have reduced grant in aid year on year recently so that clearly reduces the staff resource in GIA funded areas of our work…
18296037.1 24 211. AN Okay the point being is that, as an angler myself - and I have fished pretty much along the Dyfi most weeks through the season and I have since retired - I have actually not seen an enforcement officer on the river..
212. PG Can I just help you a second here?
213. AN Yes please.
214. PG Although this is fisheries enforcement, neither of us here is involved in the management of fisheries enforcement and neither are we accountable for it.
215. AN OK
216. PG So we would really need to take your questions and present them to those who are.
217. AN Yeah, well, we would like you to do so.
218. PG What I do not want to do is to give you our interpretation - although I am sure would be right, I am confident we would be right - but it is only correct to address those questions to those responsible for the work.
219. AN Okay, well for the vast majority of anglers they see the enforcement officers - and hope you can appreciate that - coming from NRW, they do not actually know the internal politics behind who is actually responsible for sending those enforcement officers.
220. PG Well there we are then.
221. AN So we have learnt that. Obviously the simple question is that we just don’t see enforcement officers on the river and that is a concern to many, many anglers.
222. PG There are a number of reasons for that, which I have heard from our enforcement colleagues before, and I am not going to paraphrase them here now so you need to provide that question to us…
223. AN Ok
18296037.1 25 224. PG …and we will seek a response to that.
225. JE Okay, well one of the questions that is being posed to me is that basically a lot of the angling clubs like the Dovey Association, the Prince Albert, and the Betws-y-Coed Anglers is that they all have their own bailiffs so they see this that they had had a good thing , ‘OK it is being policed we will not bother going on to those rivers we will go elsewhere’.
226. PG Well, again, I will refer you to our enforcement professionals.
227. AN OK
228. PG I have a very clear view on that, but I am going to leave it to the professionals.
229. AN OK, you are saying that
230. DM This falls within… the enforcement sections of the technical case do deal with those issues.
231. AN Okay, well, I mean, quite simply, you can realise that the actual rivers are not being policed and the point…
232. DM Well I can’t agree with that.
233. AN Why do anglers not see one? We just don’t see...
[Talking over each other]
234. PG Can we just defer this debate on enforcement to those who in NRW in charge of the fisheries enforcement, and that is not us?
235. AN Yes, but the point that everybody is making is that, if angling clubs are forced to close down and those balliffs will therefore not be on the banks, we cannot see that there will be any chance of tackling poaching and pollution in the future if these proposals come forward. That is the point we are actually making …
18296037.1 26 236. PG …Sorry, I refer to my…
[Talking over each other]
237. AN Yes, okay. Right we, Dave, last time we spoke you were in pains to, to tell me - and we touched on it a bit today - about whether the fishery boards doing similar work in other fishery areas in England outside there - but what appears to be happening is that the other fishery boards are actually looking at each individual river rather than actually - and this is the whole point - that they are acting accordingly as each river has its own merits and its own problems, resulting hopefully in the right action, and leaving the clubs to impose their own restrictions - they are consulting with the clubs - now this has been bandied about so many times that this blanket ban across all of Wales is lazy, and bad science, and lazy, and bad methodology, rather than actually looking at each river in Wales, you are doing a blanket ban, and this is where some people just cannot, including ourselves, cannot actually understand, and also that some of the rivers in Wales, quite a lot of them, are actually improving, so we cannot actually see where ….
238. PG Have you read the technical case? Have you read the annexes?
239. AN No, because it has never been presented to me.
240. ID Well it is online, it is in the public domain and has been for several months.
241. PG Well, we will be tempted not to answer your questions now, because all of that information is within the technical case. However what I would say is this, we analyse the performance of stocks on a river by river basis.
242. AN Ok
243. PG Each river, each of the principal salmon rivers, and now each of the main sea trout rivers, we analyse them on a river by river basis. Taking salmon in the first instance - and excluding the cross border rivers - all of those rivers or one or other are either ‘at risk’ or ‘probably at risk’. And of ‘probably at risk’, there is all but one who are in the process of ongoing decline. So what looks like a blanket measure is in fact a reflection of the fact that all stocks are performing at the same level. Okay?
18296037.1 27 244. AN OK
245. PG And I would encourage you to read the technical case. I have some concern that a lot of work went into that - and that is not a problem, you know, but we think that, we are very confident that, this reflects the current situation of our stocks in Wales - and if people have made their representation responses without looking at that or talking to someone who understands it, then that is indeed a shame and a wasted opportunity. As I said, all of the data is presented in there and it tells the story that you need to have considered in making your considered representation.
246. AN It still does not get over the fact that other fishery boards deal with each individual river and this is a blanket ban. This is a blanket ban across all of the rivers in Wales.
247. P G With respect, I do not agree with that for reasons I have just given.
248. AN There are so many examples of actually how rivers have improved with proactive fishery boards and obviously I could mention the river Moy over in County Mayo whereupon they have taken away the fish boxes. I worked intensively with Government in the inter-aid programme there, they took away estuarine netting and the short and tall of it is, they looked at that river, they saw the potential for bringing anglers in, improving association on it, improving tourism and they worked hand in hand with the stakeholders basically that river now generates a huge amount of money as it did not in the ‘60s when they canalised it and anglers are coming in from all over the place, it has increased tourism and economics. This situation over on the Moy does not seem to be happening over here and this is what the frustration of actual people
249. PG Well the Moy is a truly unique river, and you know I spent a long, long time discussing this and the issues around it with Ken Reelan - who you probably know…
250. AN Yes
251. PG … the remarkable thing about the Moy, and I do not know if we have time to go into this, is that when they undertook massive land drainage...
252. AN That was in the ‘60s, yes
18296037.1 28 253. PG They actually improved the salmon habitat by reducing the depth and exposing more grass spawning areas for salmon so I do not know the river intimately enough to go on about that, but that in a nutshell was what was happening and once that had taken effect the annual run of salmon in those rivers over there are in excess of 60,000, 80,000… that is phenomenal.
254. AN The fishery board now, I have been heavily involved in this and the fishery board now has spent so much European money actually fixing all of those mistakes in the ‘60s and..
255. PG …and taking advantage of the mistakes in the 60s...
256. AN …no, no, not at all, quite the reverse.
257. PG People catch on to it.
258. AN No they have been improving habitat, they are actually improving the river for fishing, putting flows in, there’s a hydrologist over there, there is a huge amount of work which may be worth you investigating of how they actually brought it back to being an angling river to bring in tourism and bring in income. Obviously, I am mindful of time and I think now this is what you wanted to do the facts and figures so I am actually going to hand over to Jonathan now if that is OK.
259. PG John, not to steal your thunder here but just to respond a little bit: you know we talk with rivers trusts and fishing associations in Wales, we have invested money in infrastructure and logistics of fishing in Wales as far as we can with the results that are available to us. We have worked with fishing clubs on establishing car park areas, access to banks, fishing platforms, we have done a lot of this according to our ability to resource this. So although it may not be to the same scale as the Moy, where they have massive European Social Fund and Regional Development Fund access, more than Wales I believe, we have been active in this area of work in the past and we have facilitated others to be active. So for example we have responded to various funding opportunities presented by one of the foundations access funds to introduce improvements to fishing infrastructure, we have done the same in still waters around South Wales where, as you will be well aware, most of our angling activity takes place. So it is wrong to suggest that we are ignorant and blind to this, we have invested in it, we will always like to spend more, it is not always possible and we remain open to proposals, in fact we have had difficulty in getting proposals given to us for this sort of work.
18296037.1 29 260. AN OK well that is interesting, thank you for that. John
261. JE Thank you.
262. PG I would just like to ask for an intermission please.
263. AN A pee break, yes. I will pause right now. There we go.
[There is a break in the meeting]
264. JE I’m at a disadvantage here in the presence of three fisheries scientists and me a mere mortal… I do question sometimes over the past few years... how the hell did you think it would come to this when you first picked up a cane and went after perch but there we go, we are where we are…
265. PG Yes indeed
266. JE I mean I will put them as a series of questions or points or whatever, there is nothing in here that I do not think that will cause many surprises and I think you probably answered the first one because my first one would be with, you know, table 7 of the technical document: I have read it by the way.
267. PG Good
268. JE Then I woke up and I read some more.
269. PG Yes well indeed….
270. JE And I found it extremely useful on the night time…not being facetious.
271. PG No, that is alright
272. JE Clearly, otherwise it would not be …
[Talking over each other]
18296037.1 30 273. JE I have looked at it many times but, I presume you know, that there is a confidence amongst fishery staff that that is an accurate reflection of stocks in Welsh rivers at the moment. The one that every river is either ‘at risk’, ‘probably at risk’ and realistically in 5 years forward projection is going to tell us the same thing?
274. ID Yes, that’s broadly right.
275. PG That is the most recent assessment…2016
276. JE Yes. Obviously 2017 ain’t out there yet
277. PG It is in the pipeline.
278. JE One thing that has puzzled me, and much of this is probably part of my education such as anything else but what I read was, when I started to dig into parts of this, that quoting from NASCO it said that ‘compliance against the management objective, i.e. that a river must meet its conservation every 4 years out of 5 is assessed annually for each principal river together with a forecast of that assessment in 5 years’ time, which then leads to the decision structure.’ Is that correct?
279. ID Yep, sounds about right.
280. JE The one thing that puzzles me when I start to look at that table and there must be presumably a reason for it is that the assessment seems to have been made against the management target rather than the conservation limit.
281. ID Yes because that has always been the case, the conservation limit is the limit... it is not…
282. JE Yeah, yeah, but the thing, you will have to excuse me fella but I’m a bit of an amateur here but to me, what I read about the management target was that it was this was Ivor Llewelyn and this is not an official document but I am presuming he knows what he is talking about, said that the management target was set to enable managers to ensure that rivers met their conservation limit. But it is set higher if you like, you set the bar higher to ensure that you get there, otherwise you would not have had that statement that says, to meet its conservation limit 4 years out of 5, it would have said, to meet its management target for 4 years out of 5. I cannot find anywhere amongst the nest of stuff where, unless I have
18296037.1 31 missed it, the management target is an applied measure in the formal compliance for assessing stocks.
283. ID No, the compliance statistic is a trend based procedure that encompasses our management objectives. They have a conservation limit which you have just described but the management objective is to meet or exceed that conservation limit 4 years out of 5, 80% of the time in the long term…
284. JE Sure, yeah
[Talking over each other]
285. ID The management target is an expression of that, so for a river to be formally passing its conversation limit would, on average it would be at or above the management target. So…
286. JE It does not say that Ian, though, does it? It actually says that a river must meet its conservation limit for 4 years out of 5, not that it must meet its management target.
[All talking over each other]
287. JE Ivor Llewelyn then says that the management target is, I quote from it, that it is a tool designed to enable managers to ensure that a river meets its conservation limit, so, and it is typically set at about 35% above the conservation limit. Well on that basis when you look, I mean the issue we are looking to raise there but excuse me .. [footsteps]
288. JE Second bit of paper, highly technical. I am familiar with a few of those of your points but if you have the conservation limit for the Mawddach is 1.37, the management target is 2.02, so that is, it is about 40 odd percent, so the 5 year geographic mean eggs (millions) is 1.49 and the Mawddach, sorry it has produced 1.49 against 1.37 over a 5 year period. So it is therefore exceeding its conservation limit.
289. ID Yes, but we are talking about the management target, aren’t we?
290. JE Well no, because of course - this is where I completely screwed up on this - because the formal compliance says that it must meet its conservation limit not that it must meet its management target.
18296037.1 32 291. ID Yes but the compliance procedure, it is not just face value passing the conservation limits, it is…
292. JE No I know because it then says if you want to take a ….go on…
293. ID …it is a statistical assessment isn’t it? That we exceed the conservation limit 4 years out of 5 on average in the long term. The long term. So that statistical assessment is built into our compliance procedure and the management target is just an expression of where a river should be if it is meeting and it’s conforming, passing its conservation limit.
294. JE Well that…
295. ID …I know they are confusing, but they are not …
[Talking over each other]
296. JE …because I can’t find any evidence that management target is an applied measure but that what it is being…
297. ID It is enshrined in the compliance statistic, that trend based procedure, and we are just expressing it in numbers here because it is easier to work with like that. It is often easier to explain like that. There isn’t anything new in that approach: that approach has been around since we started using the conservation limit in the ‘90s, so it is actually nothing new and that process has been…
298. JE Well... you could understand why a mere amateur like me would be completely thrown by that because clearly it says “must meet its …, the management objective that a river must meet its conservation limit 4 years out of 5 is assessed annually, which it is, together with a forecast of that assessment in 5 years’ time, a decision structure is then applied and a process of whether or what changes in regulation are appropriate”. Well, when I look at that, it is clear that you know the management target is there, the conservation limit is there. What it has reached over the last 5 years, in fact they are all another ball game in my opinion but there we go, it does not stack up.
[All talking over each other.]
18296037.1 33 299. JE To be honest, those words for me, I am not getting at you Ian, you know as I say a mere amateur sitting here with just a set of figures that does not make sense because there are on there half a dozen rivers that have actually met their conservation levels.
300. ID Yes, but all that table is trying to say, it is expressing two things isn’t it, it is expressing you know the trend based compliance, so that is the ‘at risk’, ‘probably at risk’ classification, okay; and that enshrines this objective that meeting a conservation limit 4 years out of 5 in the long term alright.
301. JE So they have met the conservation limit in 4 years out of 5 in the long term. Why are the assessments ‘probably at risk’?
[Talking over each other.]
302. ID …No, most of those rivers are ‘at risk’ or ‘probably at risk’ and with the downward trend…
303. JE …But they have met the conservation limits…
304. PG …but not the management target…
305. JE … but not the management target but where is it? If somebody can point out anywhere where management targets is a formal compliance, an applied measure and a formal compliance for assessing stocks, I am baffled.
306. ID Yes, but the formal approach of view is this trend based procedure, isn’t it? And that, as I say, that works, statistical procedure encapsulates the… [talks over] objective to meet the conservation in 4 years out of 5. We put the management target in here as a different way of expressing that, that is all it is and it is useful to us because it is kind of an expression we can refer to in fish numbers or egg numbers. So it gives us a feel for how far short we are in fish numbers from the conservation limit. Can you see that that is a more useful in many ways, statistic to help?…
307. JE Well I can, but, I can…
18296037.1 34 308. PG .We are going to do our very best to steer you through this… so that we have a shared understanding.
309. JE Can I just pick up something else? It might have been helpful for me in completing my response had I understood more of this earlier but I mean I will pick three rivers out…because I say it was Ivor Llewelyn work with the Atlantic salmon trusts said it is typically set about 35% above the actual compliance. Now I am just pointing out... 1.37…management target 2.02 makes it about 40 odd percent above.
310. ID Yeah
311. JE Ogwen 0.87… management target 1.67, that is 82% above, Conwy 1.17... 1.89, sorry I am looking at the wrong one there, 1.17, 1.89, they’re signif… they’re not 35% above, it means that the rivers got …
[All talk over each other]
312. ID The difference between the two is an expression of how variable these stocks are.
313. JE Can you see why I might not really have much confidence in that?
314. PG Well can you just clarify that you have read annex 4, I am sure you have?
315. JE I have, yeah.
316. PG Yeah, I am sure you know quite a lot of it by heart by now, but...
317. JE …but what I do not see there, I would agree with you there are rivers in Wales that are in dire need of action, what I don’t see is across the board, I see some rivers that are clearly, for whatever reasons, in better health than others. I am sure most other people in my position probably feel that same way.
318. ID Well the thing that we would focus on, normally when we are producing these statistics is the coloured boxes on the right hand side…
319. JE Yeah but I mean …
18296037.1 35 320. ID …those are the classic terminology most people are familiar with.
321. JE Okay, but I mean you can colour those boxes in whatever colour you like if things are adjusted, what I do not see there, and you know believe me I have done…my wife is not a happy bunny but there we go. OK let me move on…
322. PG We need to do some work to help you out with this… [talking over] Just to repeat something I said earlier on, these are the agreed management regimes and procedures that we follow, signed up to by Welsh Government and DEFRA and peer reviewed by CEFAS, so, and presented internationally and scrutinised by ICES... in my view and I will always stand to be corrected in anything in life, but in my view it is almost unthinkable that there is anything fundamentally wrong with this as you are suggesting and so the challenge here is for us to explain ourselves adequately to satisfy you. So we will try and rise to that standard and help you a bit.
323. DM And that is one of the things that conference did…
324. JE I mean, what I said …
325. PG Which one, sorry?
326. DM When this was reviewed in England, this was one of the things that came out of that was...
327. PG Indeed. Yeah, we met with the EA and Cefas in November, or something or other, and one of the things you heard us say at the board meeting, is the stated intent of both us and the Environment Agency and others, is to move this forward to take account of a wider range of data. So nothing can’t – no, that is too many negatives - any procedure can be improved. We think, we think this one does what it needs to do, but any procedure can be improved - you know, a fish counter on every river - it will be improved.
328. JE Yeah, from the bits and pieces I have read, you know, there was a fisheries manager conference in Telford
329. PG There was and Ivor was there and Ted Potter was there. There were two of the architects of this or at least one of them.
18296037.1 36 330. JE Okay so obviously the second bit that comes into that is the five year forward projection.
331. ID Yes.
332. JE Of where things are. Then obviously, you know, one of the things that was presented to the board was unless we do something now, what is going to happen in 2021? Do you have confidence in those five year forward projections?
333. ID Yeah, well, we, I think it does two things really. I mean we acknowledge that most fish stocks are not really declining or increasing in a straight line. What the trend procedure does do is gives you a sort of precautionary warning of the direction of travel, whether stocks are going up and down over that 10 year period. So we wouldn’t see it as a, it’s not really a forecast, we are not forecasting how many fish are going to come back but it is giving, well [talking over each other] precaution to this assessment.
334. JE Do you know how accurate they are?
335. ID Well, you know AST have looked at this? In some years they are not particularly accurate, in fact, I think that the information that Ivor was referring to in his correspondence with us on our technical case and proposals was that, well actually it indicated that these projections were not precautionary enough.
336. DM And that, actually, when we forecasted we were say - we looked at 2016 forecast when we did - things are significantly worse - not better - worse than what we predicted.
[People talking simultaneously]
337. PG The system appears to be under-precautionary.
338. JE In some of it it was, and in some of it it wasn’t, it went the other way.
339. ID It is not a forecast model, it is not some sophisticated model..
18296037.1 37 340. JE But it is an indicator, if you like, that if we are confident that a river is getting better, I mean, looking at the figures, you know, 2014 where we ended up was only 41% accurate or 59% wrong depending whether you are a half full or half empty sort of person. 2015, the prediction from 2010 was 27% accurate.
341. PG Yes it wouldn’t have been flawless as well.
342. JE 18% it is not exactly sort of as you say, some are worse, some are better.
343. ID John, if you could just look at that table, I mean we have had this debate amongst ourselves and we know that these compliance assessments, are difficult to explain. They are difficult for us to often explain, and we know that there are many simpler ways of presenting this information, that is something we are going to be working on. You know, even if you were to look at 2016 on this table which, there is no real projection there 5 years on, you would still be drawing the same conclusions about the status of stocks on these rivers. Wouldn’t you?
344. JE I mean, well, yes we know, I mean one thing I don’t and I was led to believe that there are a lot of people who don’t actually, or find it difficult to understand, professionals about some of the variables that are built into a statistical model like this. You change one thing and you find you’ve lost something else. You know, I’m no fool when it comes to that but I mean one thing you could try and explain to me that - this is far too long for the time we have got left and I have got a few other things - one thing that struck me was that if the amateur was to look at what the actual recorded totals were, or estimates of egg deposition they would draw a best fit line, a trend line through the centre. But they all show a 20% regression.
345. ID And that 20 percentile regression is reflecting this management objective that we exceed the conversation limit 80% of the time so it is just a statistical expression in that trend line of that management objective. That is why it is offset the way it is.
346. JE I mean, you know, apologies for me being a bit thick but is that…
347. PG Stop saying that, you are clearly not.
348. JE …it is that word that keeps coming up, conservation limit.
18296037.1 38 349. PG Yes.
350. JE Conservation limit, you know. I don’t hear management target, I hear conservation limit.
351. ID When NASCO introduced this concept… and ICES it is about managing Salmon stock and it is… conservation limits are applied across the North Atlantic, we are not doing anything novel here. There are two targets: there is the conservation limit which is a limit reference point, it’s the lower limit beyond which we don’t want to go; and the management target reference point, and we use that to ensure that a high probability that the stocks going to be above conservation limit. And that has been the principle in our application and the application of numerous jurisdictions since the start. So nothing is new here.
352. JE No, I think…
353. DM I going to just change the debate, have you got the actual stock recruitment draft? Could you stick it up? Because the one thing we want to say as well is that the conservation limit is actually not as precautionary as it could be because we use maximum sustainable or maximum yield or maximum gain against - actually what would be more precautionary would be - a maximum smolt output. So you know the conservation limit for this, it helps keep things in context, one is the conservational limit and monitoring targets, actually if we went for maximum smolts, we would have much bigger targets. And because we are managing on that slope, things can particularly be in the way, and much quicker as well. It would be more precautionary and many argue, that that would be better
354. PG I always have to look at Maximum smolt as optimum performance.
355. JE I’ll take your word for it, but if you look at it in terms of just simple, what’s been deposited. Whilst the trend line zooms down there and it is below, if you actually just take the actual figures, you end up with something that to the layperson shows from 2014 that actually, most of those rivers that are exceeding the conservation limit. And I have only done a few notes [people talking over each other] is showing upwards and okay, we can’t use 2017 data clearly, because it is not available. But, for example, one of the things that has been raised on, certainly rivers with which I am familiar, is that 2017 is likely to show a big upturn.
18296037.1 39 356. PG Well I certainly hope that is the case.
357. JE Right well, for example I have got the returns, obviously, I can’t use Prince Albert’s because until everybody has renewed, we haven’t got the figures to compile them. The Dovey are available: that is 3.4 times the total in 2015. For some. The Dee: their returns are all on. So, I can’t say for every river but what I am saying is that to me it wasn’t quite the doom and gloom picture.
358. DM Well there is a couple of things that, you know, be mindful of, there has been virtually no grilse for the last three years.
359. JE Plus point of that is if you don’t get the grilse, you get multi-sea: you do get more eggs.
360. PG Yes you do.
[Talking over each other]
361. PG One of the things that goes to my mind when I am awake at night is you know, it is only about four or five years ago, maybe longer, where we had real low numbers of multi-sea winter salmon and our stocks were being supported by grilse. Now it has flip flopped.
362. JE Why is that?
363. PG I wish we knew. The nightmare scenario is if things flip in the ocean and they are against both one sea winter and two sea winter sea fish then we have a real problem on our hands.
364. DM And when you say you don’t see anything, my view of salmon stocks through Wales is they are all getting very, very, very few grilse, and I accept when you look at that, that some of the tables we put in there – 17, where we ranked them - the lines at the top: multi-sea winter, and if you look back, look down, it is the grilse rivers that are all off towards the block. So we are having huge reductions in grilse which has knock-on effects on spawning. We have got really, very poor juveniles in 2016. From the ‘15 spawning for part of last year, for smolts this year, for next year grilse, the year after new multi-sea winter. So, you know, I have to disagree, things are looking not good for salmon throughout Wales. I am
18296037.1 40 blissfully unaware that anywhere is looking great for the salmon. I am blissfully unaware.
365. ID Through your own correspondence [talking over each other]
366. JE Dave, I suggest you get ready to rod on the Tywi and up the Conwy where I have got friends who are catching. It’s a bit out of my league.
367. PG I’ve heard about…
368. JE …we are talking of multiple seven/eight salmon in a day.
369. PG News to me. Usk in 2017 was reasonably good but we already knew that the Usk wasn’t doing too bad.
370. DM Just kind of wavering along.
371. PG Yeah, yeah.
372. DM But there are some serious issues with the Usk juveniles in terms of distribution and [talking over each other]
373. AN I mean on the Dyfi this last year I have the figures, there was 124 salmon taken and the year before was 87, the year before that was 57, the year before that was 36. So there is an increase. This is just pure fact. That is the Dovey Association, that does not include all the other stakeholders. But now it is increasing every year.
374. PG Andy, we take solace in
[talking over each other]
375. PG …any good news, from anywhere, we welcome.
376. AN But that is just pure fact, it has increased from 36 over the last 4-5 years to 124. It is as simple as that: that is fact.
18296037.1 41 377. PG When the facts come in we analyse them, present them. We look for good news wherever it exists and we celebrate that. We wring our hands when it is the opposite. John, where would you like to take us?
378. JE Yeah, that point about, you know, grilse are sort of mostly multi sea winter fish… there is some pause in that for me, I mean obviously these are all estimates aren’t they? But there we go.
379. PG I don’t know why…
380. JE So there is an estimate, what is based on the figures is the average weight of an 8lb fish. The number of eggs… if you go back to… expressed as an 8lb fish equivalent where average fecundity equals three thousand eggs per fish…
381. ID That was just for illustration in the table. That was just to translate egg numbers into roughly how many fish that equates to.
382. DM It is just illustrative, when they are actually doing the compliance we use the actual weight of the actual fish from the distribution that comes back from the…
383. ID So we use the fisherman’s declared fish weight as an indicator of weight composition of the stock
[Talking over each other]
384. DM That is for illustrative purposes only. It is not what we use in compliance...
385. JE …Because otherwise it would be…
386. DM …No, every fish is not 8 lb.
387. JE No.
388. PG So just to be clear we use actual weights?
389. JE I mean what all of this evidence is if it is based on an 8 lb fish producing 3000 eggs, 3000 eggs, according to the Atlantic Salmon Trust a female
18296037.1 42 salmon in most areas produces 450-750 eggs per pound of body weight, although there was a case in Iceland apparently where they got to 900.
390. PG That’s all over the place.
391. JE Well, shouldn’t that then lead to a total for the number of eggs produced to be higher than 3000?
392. ID Well not all fish are females.
393. JE That’s true.
394. ID It is the average eggs carried per fish.
395. JE We would be well and truly stuffed if they were.
396. ID That’s why it probably looks lower than…
397. PG That’s one biological fact that we can agree on then.
398. JE Yeah
399. PG Where catchment specific data exists for sex ratios that we use that, we don’t just generate it from the AST figures or elsewhere.
400. JE I mean just another one on that obviously. It’s as much for my education as anything else in some ways, but the accessible wetted area, how is that determined per river?
401. PG That was determined, well, do you want to do that because you are closer to it, but I can help if necessary?
402. ID When we started this process in the 90s that’s all behind the setting obviously of conservation limits… So at the time, the NWRC did some work for us and they devised the model to generate conservation limits for each river in Wales or England and the wetted areas is based on the GIS initially. So there is a computer mapping system, it looked at each system separately at a 1-250,000 scale drainage and measured all that drainage and apportioned it up into altitude and stream areas and various sections. Because altitudes and stream areas were used to
18296037.1 43 predict how many juveniles they expect in different streams but anyway - that’s a long winded response - but we then had those maps with the drainage network and the Mawddach and the Conwy, and we took it to the individuals that knew about those rivers on the ground and said ‘is that map covering all the stream areas you understand to be accessible to salmon?’ And there were some reaches which were inaccessible, occasionally there might be tributaries that were missed off the map, so they were then manually corrected so those accessible reaches are based on that computer map plus the input from individuals, and also input about how wide these streams were so we could estimate the wetted area so it is a…
403. PG And the effect of barriers.
404. JE I mean because one thing that strikes me from a geography background, is that, for example, has there any correction ever been made to that since it was originally set out?
405. PG Correction for what, John?
406. JE Well for example, if I take somewhere I am very familiar with, massive gravel washouts caused by the 2001 flood on the Mawddach where there used to be spawning gravels but there are…
407. PG There is a good reason why, which Ian will explain, which is the underlying assumption of pristine.
408. ID Well yeah that was the only… so these…
409. PG …which is important because if we assume pristine then that determines the conservation limit and if we fall below achieving that, then that’s an indicator on management intervention requirements to restore to pristine if you see what I mean. There’s no point - at some points - there’s no point setting a target because you can achieve it, we’ve got to set a realistic catchment target and measure performance against that.
410. JE I mean, these things sort of change, don’t they? And I know you can sort of say, what I mean by that is, for example, the issue with agricultural practices have changed, you’ve got a substation in…
411. PG But that’s an important one. If we remove a barrier and it was a complete barrier, for example. Or we fit a fish pass, or whatever, then the area upstream becomes accessible so we transform, we change the target at
18296037.1 44 an appropriate time while taking consideration of recolonization time at some point that newly accessible habitat come in to question. However, if habitat is damaged by - I’ll use the example of agricultural issues - then we don’t change the target for that, because we need to retain the ambition to achieve the target by addressing the constraining factor, sorry that doesn’t sound very clear to me and I said it.
412. JE No, no, that actually does make some element of sense, if you like, that if you impact on it…
413. ID Yeah, that’s good, the difficulty is, it’s trying to understand what the impacts are. In the case of the Mawddach you seem to have a clear idea that the wash out has had a kind of lasting impact on the carrying capacity of that catchment.
414. JE I’ve got a lot of issues on the Mawddach.
415. PG Oh well, that’s what we want to talk about and we need to reserve 20 minutes or so...
416. JE I mean one other thing that came into that is, one of the issues to me is that I think the Dyfi has actually only met its conservation limit once for salmon, once in the last 10 years. Now, that strikes me as a bit of an issue when you suddenly think, oh what else could you do in terms of habitat improvements? Just to make sure I’ve checked it...
417. PG Yeah, I am just looking to make sure.
418. JE …but what it has, is an extremely large wetted area, accessible wetted area, because it is not only got numerous decent spawning streams it has got it has got some significant tributaries Dulas North Dulas South, Twymyn, Cleifion [talking over each other] what my issue would be to try and explain that is that, you know, we got quite a few walkers on a number of those streams, no but take one, the Cleifion, in particular.
419. PG Okay that doesn’t mean anything to me.
420. JE If you came down from Welshpool towards Dolgellau you come down into the Brigand’s Inn roundabout, walk towards The Street, you don’t see, you know, there at the bottom, small stream, narrow deep gauges, tree shape etc. it’s never been a salmon river if that makes any sense.
18296037.1 45 421. PG Well it does.
422. JE If you fish the Cleifion, not - historically, I am not talking about now.
423. PG Do you mean a juvenile salmon recruitment river or an angling river?
424. JE Well, if you wanted to catch a salmon or you wanted to catch salmon parr, you wouldn’t head to the Cleifion. And neither would you particularly head to the North Dulas… If you go and fish for pot on the South Dulas, people catch sea trout, big sea trout and numbers of sea trout. It is a bit of a talking point if somebody gets a salmon so what I’m saying realistically at that point, is that you may have an accessible wetted area but it isn’t an honest picture for some.
425. ID Well I think that where we would rely on the local input so I am not sure… Rob Evans would be more familiar from a juvenile…
426. DM I think it would be a long time before Rob’s time that this was done.
[Talking over each other]
427. JE And the one other one, you know, one of the things that clearly is going to have a massive impact on the actual numbers of salmon that return to or return... right... not the numbers of salmon that return, the numbers of salmon that are caught and therefore in turn inform this model. Is there any adjustment that’s actually factored in there for river flows?
428. PG Into the compliance?
429. JE No, into the statistic. Right. At the stream border is there is something, you know, part of the model that has an adjustment through wet summer, a drought…
430. ID No, now that is something that we have been working on. That’s a fair, fine, we can talk about that…
431. JE I mean, quite obviously, last summer, was a wet summer, significant numbers of… except after a while the fishing isn’t that good anyway because we’ve all seen it all before wherever we go, so it might appear ideal but it isn’t always but, I mean, I’ve spent, wasted, depends how you
18296037.1 46 look at it, many hours on the Winion in particular, when I can actually see the fish - and that’s much much harder to see the fish on the Mawddach which is peat stained, difficult to see - where you can actually see them. There is so many, you think you know it all, there’s two words that don’t exist in the worlds of salmon and as far as I am concerned, always and never. Because you’re going to get surprised. The timings of those runs, the times have come beyond the end of the annual season, so the catch return is going to be very much depressed on that basis.
432. ID Yes but the estimates of exploitation or proportion of fish caught by anglers are based on the whole year, so they are based on our counters so there you have got to count of the return fish for the whole year, in season and out of season. And, you know, it is the proportion of that whole return that’s caught that fisherman would use, so in a sense you are taking account of the out of season run.
433. JE So presumably the Dee would have to be the Chester trap?
434. ID And others, there is about nine or ten… well, Chester trap in terms of the Dee cos Chester’s… but in terms of in other systems in England... yes there are others, we’ve used all those rivers and they appear every year there are statistics on how many fish are coming back and the exploitation rates they appear in that ICES report that…
435. JE I’ve had a good look but I mean one thing that strikes me about that, there is information on the Dee but as we have just said, whether any fish, have there been any fish in the Chester trap? No, but we’ve had high river flows so we never know what’s really gone on…
436. ID But we don’t base our return estimates just on the trap capture, it’s based on mark-recapture [talking over each other]….so that allows us effectively to estimate trap efficiency.
[Talking over each other]
437. DM I just want to just add about the evidence of out of season run at the moment... There is very little evidence available of significant out of season run now in Wales. Where we’ve got traps where we’ve run them on the Taff, the Tawe - we’ve got counters on the Teifi - there does not appear to be a significant out of season run. Look, there’s probably fish in the rivers every day, there is not the number. Predominantly those fish in the past were grilse and as said before grilse have become very rare especially in the last few years, you know.
18296037.1 47 438. JE [ ] in the last year. But, you know, I wasn’t actually specifically returning to - or referring to I should say, not returning to - out of season runs. You can have a situation, I had this one I actually videoed it, go and fish the upper Wnion in the last week of October and you won’t catch many sea trout.
439. PG And you won’t, did you say?
440. JE You won’t catch many sea trout because they’ve been up there for a long time.
441. DM Yeah… their minds are on other things…
442. JE Exactly. Two seasons ago, there were sea trout running everywhere because we’d had low water. As far as I am aware I’m the only person up there because it’s worm fishing territory, worm fishing had finished. I went up, I actually fished the odd fly in a spot or two, and I witnessed large numbers of fish but what I’m saying is, they were never going to feature on anyone’s catch returns.
443. PG No, they never were.
444. JE And in the same way… if you’re not doing that, [talking over each other] trying to catch hatching brood stock fish. I’ve witnessed runs of fish coming on the Mawddach literally right in the back end, ‘where the hell have these been because they are as black as coal’.
445. PG Yeah, well some of these are.
446. JE I’m conscious of time. I mean, I don’t mean to sort of, one thing, one place that did have a measure, its Conwy falls fish count. Now obviously there’s a slight error or caution that there will be a few sea trout not that many, it’s predominantly salmon.
447. PG That is total count is it?
448. JE That is the count that’s going 2004-2016.
449. PG And it is total?
18296037.1 48 450. JE Yeah, total fish through the pass, doesn’t show a picture of a river in decline.
451. PG No it doesn’t, not from that…
452. JE I mean there’s no other way to go past the Conwy but what goes up the fish pass, goes up the fish pass.
453. PG Yes… I didn’t want to put…
454. JE No, it was just, you know, there’s no cause for optimism but the trend line is clear now. The graphs are not...
455. PG Indeed, we spent many many years, we spent many years fighting to get that fish pass built and we spent many years adapting it so it works as efficiently as possible and we continued to operate the fish counter so we look at this data and although we would expect a recolonization effect, in other words, an increase in abundance, generally 10-12 years after a barrier is opened we now actually see that at least some evidence for it as a gradual increase, so that’s what we would expect and of course the fish going up the Conwy Falls fish pass are fish that would not have done so if there was not a fish pass there, so they would contribute to spawning etc. so you, know, it’s not always black and white for these things but interestingly we wouldn’t build that fish pass now.
456. JE Yeah, I know. I only wish you’d built it up the Mawddach.
457. PG Well, we’ll come on to that in a minute.
458. JE But… one thing that strikes me, you know, on much of this, and I will shut up in a minute if you want.
459. PG No John, this is interesting.
460. JE This is not aimed personally, but just as a picture, I mean in the case of the Mawddach… I know you’ve spent a day there with me Peter …
461. PG And I still remember the awful sights at the top.
18296037.1 49 462. JE I think its a bit off Dave’s patch isn’t it, to spend any time up the Mawddach and Winon?
463. DM I spent 3 or 4 years in Aberystwyth.
464. JE On the Mawddach and Wnion?
465. DM No as a student, fishing right on the Rheidol and Ystwyth.
466. ID I’m not really familiar with it.
467. JE Right. To be honest the way fisheries… we’re aware of the cuts and how many staff went under reorganisation …I’ve got Tommy Hughes, Kat Marshal I can rely on. There’s not many people on the ground, just, I’m not going round the enforcement debate, but we’ve got Peter Willis who is covering Barmouth, Aberystwyth, inland to Newtown, Oswestry, Its about 1200 square miles on that, I reckon. It’s a simple question, really. .. who knows that river best?
468. PG Well you do
469. DM Probably. You do.
470. PG You do, there’s no doubt about that.
471. DM Thanks.
472. JE Which almost brings me round to the point
473. PG What I am saying, because I don’t want to be misquoted on this. What I mean by that is geographically and the nature of the fishery I’m sure you know better than most people.
474. JE You see, when I look, and there may be, is there something factored into that model for how much data is missing?
475. ID What do you mean?
18296037.1 50 476. JE Well missing… catch returns
477. PG Yes.
478. JE To what degree?
479. ID Yeah, the general correction mostly has been that we understand nationally around 90% fish are reported now these are national corrections, that’s the only way we are able to do it, but in more recent years since the introduction of the online systems, so the last couple of years where there’s been some evidence that, you know, that system beds in the reporting rate’s fallen, so we’ve put that correction in.
[talking over each other]
480. DM And the reminder system.
481. ID And the reminder system.
482. JE What puzzles me on that and I can see why it might fill the court rooms of the fact that we’ve got 37% the same last year where we got that 45- 47%.
483. ID You are referring to the data that’s there before...
484. JE Yeah, so there’s missing data, the way that seems to come back was as you are aware, Peter, one other thing of when I wasn’t really around, at the time the letter I wrote, it was about 12 months ago was that I compared the stats from the Dyfi.
485. PG Yes
486. JE And the official stats, and the official stats show shortage of 28.14%. I mean that’s not including the private stretch you mentioned [unclear] simply taken from and no other catch returns was near as damn it accurate. I know the Dovey Association are at an over private stretch so it’s 28.13% of the salmon that were actually caught weren’t reported in the official stats that were crunched by NRW. That was over a 5 year period and then this time when I was looking through stuff, I took what was reported by the River Wye Gillies Association that we suspect with
18296037.1 51 river keepers on the rivers on a daily basis and so on, might have a reasonable record of what is caught on their waters and we compared that with the official stats for the Wye. Right. It’s quite intriguing, bearing in mind 28.3% is for disparity for the Dyfi. The disparity for the Wye was…
487. PG Are much higher and there is very good…
488. JE 28.13%.
489. PG Well…
490. JE We’re almost…
491. PG We understand Wye, well I understand the Wye possibly better than I understand the Mawddach and there’s very good reasons for the disparity on the Wye and that is the Wye is one of only two rivers, I think, in England and Wales where owners can capture returns have always been historically since the early 20th century, actually, have always been used. And that’s because of the nature of the river which is very much a private ownership next to the river, each river, each fishery, rather, tightly managed and gillied etc. so the data that came from that was considered to be reliable.
492. JE I mean, but, what strikes me is that if you don’t have the right information fed into - no matter how good your statistical model - you’re not going to get the results.
493. I D Why aren’t the anglers returning monthly or proper returns?
494. JE Right. One, because I fish there for all I like, there’s one.
495. PG Are all fishermen liars? Or do all liars fish?
[talking over each other]
496. JE But let’s stick to the point. I think there’s been a historical reason for some anglers not wanting to know what other people have caught and they are a bloody secretive bunch for the want of a better word.
18296037.1 52 497. DM But rod licences are anonymous effectively as the return….
498. JE Well, they still don’t like anybody to know. They don’t like the fact that rents might go up etc. but, I mean, it’s a far from accurate picture. Now last point, that’s it I will shut up, but when I look now, I mean, I know you quoted Ian an exploitation rate of about 15% of the stock of a river, perhaps.
499. ID That is a kind of national average based on counted rivers. I mean, in Wales it’s lower than that, probably more like 10%.
500. JE I mean, to be honest, I am alarmed at the lack of anglers, not just… I went to the Dee towards the back end of the waters, there is nobody there. Now take it to its full conclusion if nobody fishes the catch is zero, it is not quite that bad yet. I did a straw poll of missing anglers - some of my colleagues - the returns I got, 75% of the people felt that the loss of anglers in the last 5 years was between 50-75%. There is nobody on the river, it is deserted. Now there is obvious conclusions, now…
501. PG Can I just add to that evidence? I can’t imagine we are seeing a larger reduction in terms of course fisherman on rivers.
502. JE Our stretch of the Wye…
503. PG People are just choosing or have in the past chosen to move to other easier, dare I say, fisheries.
504. JE We had to…
505. PG I detect a slight rebound on that.
506. JE One that I was staggered by, Peter, was that Prince Albert actually had to take on more car porters with the introduction of the Spring Salmon Rules and that was because anglers instead of jumping in the car and driving off to the Severn or Dee or whatever started going to carp fisheries on their doorstep until June 16th. That was one I had never foreseen but it’s going back to this point...
507. PG Of course we don’t know if they were the same anglers.
18296037.1 53 508. JE …of if.. I would suggest the exploitation rate is way, way lower than perhaps where we put it at. Then when you factor into that the percentage of fish that are returned, more on some rivers than others, more on some clubs than others and I have to say I do not accept that voluntary release rates have gone as far not by a long way but there we go. That’s my opinion. What I don’t see is any increase in spawning salmon from the current proposal.
509. PG Right. Ok.
510. JE And the reasons to that I think are, one, we’ve talked about, I shouldn’t use the word culling licences should I?
511. DM What licenses?
512. JE Culling licenses.
513. DM Licence to shoot as an aide to scaring. Just, if you start using culling...
514. JE Yeah I know.
515. JE Let’s be honest.
516. DM Be careful, that is all I am saying.
517. JE Let’s be honest. Not many canoeists take out licenses to scare birds, it is angling clubs that take them out, I would have thought almost exclusively.
518. PG They may find doing it from canoes is constructive.
519. JE I mean maybe if you introduced a canoe culling licence... no, sorry, wouldn’t suggest that…
520. DM No.
521. JE No, don’t. But seriously, so that end is weakened it is anglers that do that. Secondly, you mentioned enforcement and I know I’m speaking to the wrong people here today, but it is alarming what we get from
18296037.1 54 enforcement and the LFAG. Things not followed up and I have the utmost respect for those people on the ground, I don’t know how they can cover the area. One thing we are repeatedly told is that they rely heavily on intelligence, on reports from us. Now the antagonism that’s around at the moment is very much putting to me that that intelligence is going to lessen.
522. PG Is going to?
523. JE It’s going to decrease. People are not going to, assuming you’re there, there’s the other big worry about that to me which is what I’ve just said that decline in angler presence. I’ve shifted numerous people off the Mawddach who are not members of Prince Albert who have no reason to be there. I spoke to Andy in the car coming down here, I went down the canal boat, on a friend’s canal boat down the River Nene towards Peterborough. ‘Nenn’ or ‘Neen’ depending which end of the river you are. To my friends who own the boat, there were fishermen on the river, to me they were poachers.
524. PG Right.
525. JE If Joe Public walks on the Mawddach trail from Dolgellau and he sees a guy in jeans and trainers, and a t-shirt with a 10 pound spinning rod and a big shiny toby and a treble hook, ‘oh, we saw a fisherman on the river’. We don’t. Yeah, we know the difference. There’s not going to come much intelligence other than from anglers, but more to the point a lack of angler presence is providing far more opportunities for the ‘n’eer do wellers’ to actually appear on our waters.
526. PG Yeah, you’ve made that point several, before…
527. JE I’ve made this point repeatedly and I still stand by it and thirdly, in practice, or probably fourthly I think as if I’m losing count. We’re talking about river restoration…
528. DM I’ve got five here.
529. JE …we’re talking about river restoration.
530. PG Yes.
18296037.1 55 531. JE When I stated to Ceri at the end of the board meeting, I said that I had to seriously consider my position about whether it was worth going to any more meetings of any description because, what’s the point? However, I’ve taken a step back from that which I’ve done actually spoken some length to Ceri last week which you may be aware of.
532. PG Yes.
533. JE The end situation from all that struck me as bizarre. You couldn’t really make it up and were it not so serious, Ceri asked me if we as anglers, would be provide, prepared to support, Welsh Government in putting pressure on Welsh Government to, you know, tackle the variations of agriculture that we’re all so concerned about. What we actually have is a shared goal isn’t it.
534. PG We do.
535. JE So I thought about that and I thought, fishermen want Welsh Government to hit NRW with a big stick, NRW want Welsh Government to beat anglers with as big stick and NRW want anglers to beat the Welsh Government with a big stick. And there is a huge, you know what I mean, it’s like Benny Hill running round in a circle, if you’re not careful. The clear thing to me is that unless we work together all of this is not going to achieve what you want it to. And in fact, what we all it to, which is to see the restoration of fish stocks. And one thing that actually struck me in the last week or so, I never thought I’d say this, was that actually, I’m almost hoping that stocks don’t increase too much because there would be absolute bloody chaos for the want of a better word. I can remember times when there was a head bailiff, two full time bailiffs, yeah? All on one river and they couldn’t catch the poachers then. If we don’t work together we’re all doomed.
536. PG Okay well, just to respond briefly to that. Yeah, I also have had a long discussion with Ceri so I know in outline what the grounds you covered. Secondly - you’d better count my points now - I always said over the last two years, three years and longer for those who had to put up with me, that we all want the same outcomes. We all have the same interests and we all need to work together to achieve it and although, at times, each of us might not agree with some things the other person has to do, these other things, only happens because of the respective obligations placed on us by the Welsh Government and the obligations placed on you by your membership because you, I know, you represent a large membership, John. So we do have the same objectives, the underlying goal must be to optimise the performance of our rivers. We have to have a breeding resource to take advantage in that, and that’s the current
18296037.1 56 initiatives but looking forward from now our attention’s got to move very, very quickly towards addressing the other pressures that we’ve talked about: fish eating birds and although we’ve talked around agriculture, and there is a lot to be said about that, and there are lots of new initiatives and our new chairman who you’ve hopefully had a chance to talk to and our imminent new chief executive. The first meeting, as far as I’m aware that our new chief exec has accepted is with me to look at agricultural issues as they affect our rivers and in doing that, our board member who leads the Wales Land Management Forum subgroup which you might have heard quite a bit about, will be there as well.
537. PG So that’s a second example, the third example, is a commitment given, although it was already active for river restoration plans and, John, I was speaking with Afonydd Cymru yesterday and Alan Winstone specifically is more powerful anyway. And we talked about, you know, in session about it where we’re going with the river restoration plans, you know, for those who shrug and tut and say ‘God there’s another plan on the shelf’, well, you know, and apologies for that, but it is an important process if we are all to have a shared view in what we must do in each of our catchments to optimise their performance and although NRW have a lot of information, rivers trust have some, owners have some, fishing clubs and associations have some, forestry even... There’s a disparate source of information so when the Welsh government tap me on the shoulder and say, what do we need to do on the Teifi, for example, to restore it, you know, we would say well these people know something and they know something, so we’ve cutting through all that and we want a single discrete text, minimal text, maximum evidence, statement of what we need to do on river Teifi, right now and what it would cost the society to sort it out. So Welsh Government will have that information and they will use that to explore funding opportunities. Both opportunistic, such as metal mines stuff which I think I have spoken to you before about this, where they found between either two or three million, I can’t remember, to deal with redundant abandoned metal mines and the problems arising from those, more good news from river quality. But also NRW offers, and is just concluding its position, on funding opportunities for stakeholder groups, NGO’s whoever it is. So pretty soon, I think, they will be an outcome of competitive effectively bids, for a £3 million pot of money and what I want to do is in 12 months’ time, be in a position where we have tabled river restoration plans for Rivers Trust and others to pick up and commend back to us to say this is what we want to do for you. It’s quite a lot of effort actually. So we are talking about the next priorities for this although Teifi and Tywi and Clwyd are almost certainly embedded as the first three, what I want to do is increase the rate at which we’re doing this, because we have to get thirty of these things done, we don’t want to mess around doing one or two at a time, so we want to talk to you specifically, John, about what we can do to commission all of this work for the Mawddach to bring it into one place, pick up all these awful things and example you showed me at the top of the catchment which you
18296037.1 57 showed me and I have not forgotten. Which has left a lasting mark on me, that did.
538. DM Are you talking about on the way back from the board meeting?
539. PG Yeah I mean we’ve got to be really, really careful that damaged rivers do not become accepted as the norm. You know, we’ve got to be careful about that and I have been around for quite a long time and when people tell me “Look at the Wye, its doing fantastically”, it’s running at about a quarter of the rod catch that it should be running in so you know, so we are not there on the Wye - and sure there are bits that’s promising - we’re not there. But you must judge by performance potential of the rivers, not just recent 10 years’ rod catch stats or whatever. So we want to optimise rivers for the sole production and we’re looking at, were looking at fishes and what’s going on ground again, and, we want to commission the river restoration plans, we want to put those in place where funding opportunities are realised to do work.
And sort out the Upper Mawddach so we’re, we are going to be coming via Afondydd Cymru who have, who, who we managed to install as our framework contractor in competitive process to the Clwyd, Conwy & Gwynedd Rivers Trust. Talking with you hopefully about commissioning that work. And it’s not a big desk-heavy operation, it’s a compiling evidence, seeking new evidence, getting us a comprehensive statement about what we need to do to sort out the Mawddach and then feeding it to the right funding opportunity and in that way I would hope within a few years we could start to address these catchment issues.
540. AN Thank you very much for that, if I may step in here I’m very mindful of time and I am also mindful of, there are one or two more points I’d like to raise but I’m also mindful that, to give you gentlemen the floor to say whatever you want to say and whatever information you want to impart with us. One of the points I’m looking at is this huge great big book here, and I’m sort of coming at you from a slightly different angle from John that I’m representing your normal general angler who would not read that book and an awful lot of what’s been said today would completely go over his head but he has still some salient questions with regard to the passion that he’s absolutely involved in so, I hope you can understand that, I’m actually asking those questions that, questions of the general angler has been asked towards me. Now, from what has come about, you talk very admirably about working together but at the moment the fact of the matter is, you are completely alienating anglers, stakeholders, the press, angling bodies, other scientists. This is the fact of the matter right now. You’re actually alienating people and this is the great problem we see. So in the future if these proposals are, do actually go through, how then when you’ve actually have alienated the anglers, the angling bodies and clubs how then you feel that you can actually work alongside
18296037.1 58 them when you’ve actually alienated then and you are doing so right now?
541. PG Well, we don’t want, and don’t really see that, this large scale alienation is going to happen and I know, I’m not dismissing what you say, and in saying I’m not going to repeat it I’m repeating it: we have statutory obligations set on us that we must address. We are in this for the medium to long term and if short term pain or what perceived to be pain, is necessary in order to assure future stock sustainability, then that’s what must happen. We have experienced statutory catch and release across of the whole country up to the 16 June and I know people will say there’s no fishermen on our banks prior to 16 June, these are the same fishermen who practise, in some cases, high rates of capture and release, so and it also coincides with a lack of abundance of fish in the early parts of the season, this is a rambling piece of background. We have managed on the Wye and less so on the Taff, but never-the-less also on the Taff, to work with fishery owners and anglers and stakeholders in a background of statutory catch and release to maintain good relationships, constructive working relationships, good outcomes in terms of shared project work, and well I think we have.
542. AN Well, I have to say, the mood that where, actually right on the ground, I run a website with 100,000 users per week, I, we speak to hundreds of thousands of anglers, that is not the mood in the camp. We always like to think that there could be a solution, I mean, one of the things that anglers tend to do and it’s historic, is that they tend to vote with their feet. They’re going to disappear off to Scotland, they’re going to go over to Ireland. It means actually less licenses sold, you’re going to get less revenue because of these measures.
543. PG We know that.
544. AN That shows how counterproductive…
545. PG We are aware of that risk.
546. AN Counterproductive sort of, the fact that it’s actually going to happen. What, you’ve touched on before that, and it… John’s reinstated a few things that have actually happened. I grew up fishing the river Irt in West Cumbria, it was fantastic, it went into the decline. A few years ago through the West Cumberland Rivers Foundation has set up a trust, a trust was set up for the River Irt. We had, funding was found, a project manager for that one river was found. Now what’s actually happened is, since that a lot of funding for a myriad of different places, utility companies, British Nuclear Fuels, Parish Councils, District Councils,
18296037.1 59 County Councils, all this funding has come in, and what’s actually happening now is that the entire community of that valley, and interested parties, angling clubs, the EA, the National Trust, the Guides, the Scouts, all the communities actually come together now, even the schools, to renovate and regenerate that river. What is actually happening is that it’s actually increasing interest in the river, angling clubs are benefitting from it. Runs are definitely increasing on the river Irt. The community is actually getting educated with their children coming in to that situation, it’s a win-win situation for everybody, that could come about without an integrated, fully integrated partnership of all these people coming together. Now, that, for me, is a model of how actually it could be taking place. There was no alienation to the start, there was no pain to start with, it actually, the whole thing came together through one man. There is even a scientific project now, you mention, on mussels there is the very rare, black pearl mussel, freshwater mussel. There’s an ark that’s been set up, the children now are reintroducing that, the children are getting involved, the children are joining the angling clubs. Surely this is how it should be actually all come together. But at the moment, what I have seen is total alienation. Anglers leaving the banks, clubs closing down. We do not see this as a way forward, we see, we’re looking of the broader and the bigger picture and that we feel that you have your own obviously, modus operandum of how you feel you operate, but we feel that there is a different way forward. There’s a better way forward from this mandatory draconian proposals that everybody… We’d like you to look at those and work with us.
547. PG So, in the last ten years, we’ve seen, I think from memory, a 15% reduction in licence sales. So licence sales are ongoing and that matches, we conclude, this is migratory salmon, an ongoing reduction in stock availability. If we do nothing and we rely on past encouragement from 100% voluntary catch and release, in 2016 anglers declared they killed 570 salmon and about five times of that number of sea trout. That’s in the background, in the context of loud alarm bells and us urging maximum restraint, and anglers still did that unfortunately and largely these are the…
548. AN These are the nets. The nets are killing fish.
549. PG Both nets and rods are licensed to fish and in certain times of the year they are able to kill fish, okay? What we are seeking to do is to manage that regime so we protect an important and a vital spawning resource. We have to do that otherwise we a) have concern of ongoing stock decline, b) we have the existing reduction in anglers continuing and as I mentioned before, you know, our obligation is set in our statutory duties and we must conserve and manage sustainably our natural resources, salmon and sea trout being amongst those. We have, all of the things, the excellent things you were talking about, about catchment groups
18296037.1 60 about iconic local leaders, about Scouts and Guides, we’ve done all of this in the past, we initiated all of this on the river Taff, where statutory catch and release is in place, we’ve run ‘Salmon in the Classroom’ programs, we’ve run ‘Eels in the Classroom’, we have done all of these things, Andy, and although we are severely constrained in what we can do in terms of resources but we would continue to do that, you know, myself and my colleagues voluntarily give up time to operate any of these systems, so it’s a little bit galling to be told that other people are doing it and we’re not because…
550. AN I didn’t say you should do that, I was giving an example of it.
551. PG It’s a good example and I have really taken it on board, and I hope… I’m also a parish councillor and the notion of getting my fellow parish councillors doing things like this, it is a long shot I have to tell you unfortunately.
552. AN You were at pains to mention the heritage of the nets, you know, keeping that going but what about this…
553. PG No, I wasn’t at pains of keeping it going, I’m at pains to express the dilemma we have where there is no policy direction on whether they should be kept going. You know, people will have their own personal views on this but what we need is a policy view from a heritage context about whether some unique fishing methods are culturally significant and therefore must be maintained in some way.
554. AN I think that is a very good point. That point applies exactly to the rod angler as well. You can’t discriminate.
555. PG Well some people have told me there is culture behind rod fishing and…
556. AN Which goes back to the trustees, way before nets ever came about.
557. PG Well that may be the case…
558. AN It is.
559. PG That may be the case but I am not aware of any published work demonstrating cultural significance Andy, but I do not dismiss it in any way I am a fisherman with you, we are all…are you a fisherman?
18296037.1 61 560. ID I am, yeah.
561. PG We are all fisherman here and we all love it and we all want to see it better and prospering in future and if we do not take any action it is not going to be.
562. AN We’re saying we feel that there is a better way forward.
563. DM One thing I want to stress though, as well, Andy, is that this is not cessating angling. This is just making people put salmon back. There are simply not enough salmon currently spawning to sustain stocks as they currently are.
564. JE It’s not just that, its restricting methods also.
565. DM Well it’s restricting methods so that those fish that are released have the best possible chance of survival.
566. AN Well the fish that was caught in the net in an estuarine situation has no chance of survival because…
567. PG That’s incorrect.
568. AN I find evidence of that on the Dyfi and many other rivers, with the net marks and it has clearly been killed by a net.
569. PG Andy, we could argue this point for the tape
570. PG We will respond on that point because it’s an important point. If fish are damaged in nets then and they likely to die. In the past in the Dee and the Tywi and Wye and Taff we have run programmes, telemetric programmes to look at fish migration and behaviour etc. and we take fish from estuary nets and they survive. So if they are handled properly and we have increasing interest in the way that the Teifi coracle netsman released all their salmon last year?
571. DM Yes, they did yeah.
18296037.1 62 572. PG We are working with them, we are using our experience of hundreds and hundreds of salmon which have been taken from nets and fitted the tags and survived and demonstrated positive migratory behaviour throughout the rest of the season. So in the right circumstances survival can be good. In the wrong circumstances, I agree, fish will be injured and die.
573. AN Okay.
574. DM And, you know one of the proposals for the nets was to remove August from the nets because they predominantly caught salmon then, and they were catching very few sea trout so we had taken August from the nets, all those net fisheries that were open we have now closed at the end of July.
575. AN September?
576. DM There’s nothing open in September, everything ends at the end of August.
577. PG Can I just… this is what we are proposing.
578. AN Right, okay.
579. PG So there will be no net fishing in August or later.
580. AN Okay, thank you for that. One of the things that…
581. DM There was a couple of other things there…
582. AN Certainly, carry on.
583. DM …that make me think, is that they do not fish with gill nets and I know that some of the correspondence you have got is that the nets that we license do not fish with gill nets. Okay.
584. AN Okay.
585. PG There is a big difference between those.
18296037.1 63 586. AN Just keeping on that theme of the nets, and this has been mentioned to us many, many times by an awful lot of great people. When nets are closed normally, they are normally compensated by the clubs that actually buy them out.
587. PG There are examples of that but there are also examples of alternatives.
588. AN No obviously this is a sort of a compensation sort of area that we are looking at. Have you considered that through your actions businesses will close down, clubs will close down, associations will close down and jobs will actually be lost?
589. PG Yes, we have.
590. AN Have you actually, delved into the fact that there could be claims against you?
591. PG Yes we have.
592. AN Have you actually set a fighting fund out for that.
593. PG Yes, we have considered that, and, no, we have not established a fighting fund. We have a clear legal position which I believe is in our technical case.
594. AN Okay. We wanted to know that…
595. PG We are also reviewing a decision from the Supreme Court two days ago on this very subject.
596. AN The other aspect that I would to do, show you, is the human issue of the morality of the whole situation. I would like to show you, this came out a couple of days ago it is the Wrexham Leader, there’s been many papers that run stories that are against your proposals. There is an old mate of mine there. This chap’s 83, he has got a stick, he is disabled, his partner has just died, and he is physically unable to cast a fly, to work a spinner, to work the shrimp. He can’t wait for June 16th to come around, to go sit underneath his favourite tree on his favourite river and dangle his worms for a salmon. He basically can’t really sort of envisage anything else other than that. With these proposals, he is going to be heartbroken. You are denying this man his happiness. When the restrictions
18296037.1 64 supposedly if it does happen to come off, he is going to be dead. Are you going to tell that man there that look you cannot do what you have been doing for years, the only way that he can fish, are you going to tell him that or should I tell him that?
597. PG Well that is a very…
598. AN I mean it is a human issue is this.
599. PG …it is a very emotive point and we take it very seriously. Worm fishing will still be permitted for sea trout.
600. AN He does not want to fish for sea trout he wants to fish for salmon. He actually wants to fish with a worm for salmon like he has done for years and years and years. He has not got many years left and that is what he wants to do and there are so many men like him across Wales that actually that is what they have been brought up doing. You are going to take that away from people. You are going to deny them their happiness.
601. PG Yeah, and in seeking to ensure a future and sustainability and opportunity for people in future. You know, I have said it and Dave has, and our technical case makes it clear, our salmon stock cannot sustain ongoing exploitation and cannot, we cannot, afford for potentially spawning fish to be killed. That means we are prohibiting worm fishing because that is not conducive to catch and release of salmon.
602. AN Which we disagree with you on, I am sorry to butt in.
603. PG …well that is…
604. AN We do disagree with you.
605. PG …well that is fine. But with the advice we have and the evidence we have, is that worming should generally results, you know what I am going to say, generally result in deeply hooked fish with poor prospects for survival.
606. AN Again we have to disagree.
18296037.1 65 607. PG We recognise that elderly and disabled anglers may only be able to fish statically with worm or with shrimp and they can still do that in future. Worm for sea trout and fishing of shrimp for salmon.
608. AN He cannot do that. He does not want to break the law. He does not want to say I am fishing for sea trout when he is actually fishing for salmon.
609. PG Well.
610. AN So his days are over now.
611. PG The controls we are, that is very emotive.
612. AN It may be emotive but it is actually true and it is true. There is an awful lot of Roys out there.
613. PG Well there is an awful lot of people who in future want the opportunity to enjoy…
614. AN And so therefore there is always a compromise, and therefore there is always a balance that can be reached and we believe there is a better way of resolving this problem for the greater for the better good.
615. PG Well let me repeat what I was going to say. We recognise all of this. We recognise that there is going to be a problem for certain anglers in certain locations but we do require all salmon to be returned alive to contribute to spawning reserves for the future. That is for everyone and for every elderly angler I am sure that the youngster who wants a future where there is a sustainable salmon stock to fish for, one that exists and one which hopefully can support killing of fish. We are not in that position right now. We recognise that elderly and disabled anglers want to continue to fish and there are scenarios in which they can fish in future for sea trout with worm which if this gentleman’s preferred method and we would ask him and we would hope that we see local partners assisting him and changing his fishing locations perhaps. And we are also aware that people are able to fish with shrimp but not other more active methods.
616. AN Can you appreciate that a lot of angling clubs, like the Dovey Association, banned the use of shrimp many, many years ago?
18296037.1 66 617. PG Yeah I know what the current byelaw conditions are and I know what the…
618. AN These are clubs’ choices, these are clubs’ choices.
619. PG And we know what anglers’ representations were on shrimp fishing, there was a lot of response on shrimp fishing and we took that into account particularly on the evidence on hooking and safety and the potential catch, and safe catch and release and we took that into account and we amended our proposals. We did that because we were persuaded that the method was safe but we are also persuaded that this would, through an equality assessment, we were also persuaded that this would give people, elderly and disabled people an opportunity to fish into the future that would not otherwise exist.
620. AN Okay.
621. PG So we have tried to do this. We have tried to balance what we believe is an urgent need for zero kill of salmon, and with that comes the catch and release methods that we believe support that, and we have tried to balance that with ongoing fishing opportunities for as many people as possible. I am deeply sorry that this might affect some people like this elderly gentleman, I really am. And I would hope that locally some people would help him to fish in alternative locations or with alternative methods. I know that sounds trite and all that, and perhaps overambitious but it is a contribution which we all need to make.
622. AN Okay
623. JE I could point out actually, that if comes down to the Mawddach, where he used to fish. He can still come and fish with a big bunch of worms.
624. PG For brown trout?
625. JE No that is for salmon.
[Talking over each other]
626. AN Anyway, just to move on. I have only got one or two left. And I think it is quite an important point that has actually been raised to us and there is an investigation going on with regard to it. There is a possible
18296037.1 67 infringement of the Equality Act 2010 under indirect discrimination along with age discrimination and disability discrimination. We have had contact with Angling Heroes, a part of Help For Heroes. There is a possibility that there is a human rights issue here. If the proposals go through there is no doubt in my mind now, from what I have heard and people I have met, that a test case will be brought against you. Are you ready for this?
627. PG Absolutely. We have consulted our legal colleagues and we are aware of risks around this and we have made our proposals.
628. AN You have. Okay.
629. PG That would be very unfortunate for everyone concerned. But you know, we are in a position where we have taken the decisions based on what we believe is comprehensive and good evidence and we must take action to preserve these natural resources.
630. AN Okay. I know what you said.
631. PG And we also speak to our colleagues in the Environment Agency about these sorts of things we discuss risk…
632. AN Okay, just a general question. On reflection and now considering all the mountain of objections that you have received, what mistakes do you feel you have made and what would you do differently.
633. PG What I would like to do differently is avoid spending in excess of two years on a fairly laborious process to bring about change. I want us to be more flexible. I want us to be more responsive to the status of stocks and I want to work with all with an interest in this resource to bring in a better system in future to protect our stocks. First and foremost is stock sustainability. It begins and ends there.
634. AN Okay, it’s a request. There is an awful lot of ground that we can cover and there is an awful lot of mutual ground that we want to work towards. I don’t think it is actually too late for the proposals to be deferred until there has been analysis, more consultation with stakeholders and angling bodies, correct statistics brought up to date as we have seen today, partnerships selected, laws verified. I think this is the right, democratic and sensible way forward. I think before these proposals are put to Welsh Government there is a lot more to be discussed and there
18296037.1 68 is a lot more to look at as far as with the angling clubs and associations. Would you consider that?
635. PG No.
636. AN You wouldn’t. Why?
637. PG Because we have been through a procedure which took in excess of two years. We have done all the things you have talked about. We have spoken to a very wide range of stakeholders, we have run a three month statutory consultation in which these points could have been raised and discussed and our decision is taken, our decision has been put to our executive and our board and the decision has been taken. Okay.
638. AN It only just went through the board, though, it was touch and go.
639. PG Erm, well I think only when the minutes are confirmed at the next board meeting you will see their decision set out.
640. AN And the Middleton board member, he wanted this to be deferred? We heard that at the meeting. He actually wanted, he was asking exactly what I am asking, he is the board member and he wanted this deferring.
641. PG The board is a single entity which takes a decision and the decision…
642. AN He was actually a board member.
643. PG I know but they act as a board not as a group of individuals.
644. AN I mean just to sort of have a little think. Between John and myself we have got over 100 years of knowledge, expertise and experience. Can you imagine, rather than alienating, can you imagine what you can harvest from all the anglers of Wales and all the anglers that fish in Wales for the greater good by bringing people together for the better, for the tourism, for the anglers, for the community, for income, all working towards a single goal. Rather than, there is alienation out there, I have to get this through to you, you are alienating so many groups, so many clubs, so many associations. Would it not be better to bring them all on board, harness all that information all that expertise that is actually out there. Would that not be a better way forward?
18296037.1 69 645. PG Well I think we have covered all the ingredients of that in the discussion so far.
646. AN Okay, well we will move on then. I presume you’re now aware that there were exchanges between Neil Hamilton and Lesley Griffiths in the Senedd yesterday?
647. PG Yeah.
648. AN And I…
649. PG Was it yesterday or was it the day before?
650. AN It was yesterday. So, you have actually got quite a lot of AM members that are actually against your proposals.
651. PG Well you are party to information I do not have.
652. AN Well, okay. Well I read you Neil Hamilton’s press release that has gone out to the press today. ‘UKIP Wales leader Neil Hamilton stands up for Anglers in Wales. Today in the National Assembly for Wales UKIP Wales leader Neil Hamilton stood up for anglers in the face of draconian proposals by Natural Resources Wales (NRW). Fisherman throughout Wales face a ten year ban on catching’ etc. etc. etc.
653. PG Well that’s incorrect isn’t it?
654. AN Well I am sorry, but this, I am actually quoting from his press release.
655. PG If that’s what he has said then he is wrong isn’t he, because we are not banning people fishing.
656. AN No but I am… with regards to the proposals…
657. PG Yeah, I would need to look at the words, but let’s hope he has been corrected and made an accurate statement.
658. AN Okay can I, you have to appreciate, the pressure is mounting. The publicity and the media is mounting against you. Assembly members
18296037.1 70 actually disagree with what you are doing and they are obviously, there’s no doubt about it…
659. PG Can you tell me, do you want to tell me, who?
660. AN Yes of course of can.
661. PG You used a plural there….
662. AN Okay, well there is Neil Hamilton, RT Davis, fish. Go on you can name some more, I have got them all in the top of my head.
663. PG Well it is not a challenge to you to do that, it’s not a challenge at all.
664. AN Okay. What I am saying is…
665. PG This is a robust debate and there will be people who come down on both sides. But fundamentally in having that debate they need to be party to the evidence and the statutory objectives that we are faced with…
666. AN We have said..
667. PG …and if they are not advised on that then they need to be.
668. AN Well we have. All Assembly Members, and boards have all had basically all the information, all the objections. We have been, like yourself, we have sent it out to absolutely everyone.
669. PG Yeah we have correspondence…
670. AN Absolutely everyone, including with the press.
671. PG We have corresponded with all…
672. AN My final comments. If Welsh Government actually reject these proposals I have to say there is an ever-growing possibility that they will be rejected, not only will there be further total alienation against the angling
18296037.1 71 community, does this not put you and your fisheries team in an untenable situation?
673. PG Well no. The Welsh Government will take the decision they need to take based on the evidence presented to them. If they were to decide not to approve these byelaws then we would continue to work with them and with stakeholders on alternatives. But we strongly advise them to adopt what our amended proposals look like.
674. AN As we are strongly recommending them not to…
675. PG And that is fine.
676. AN And this is the sad bit. At the moment we are agreeing to differ. With more consultation and with more meetings and more information we could actually, I am sure, find a solution together, work together to the solution that we all want. Now that is the point everybody is making. We do not feel that this has been thoroughly explored and we feel that there is a broader picture here where we can work towards one end with you, not against you, not being alienated either way, and that we can actually get to the end goal.
677. PG Well what I would say is we have been…
678. AN Now I think that, there is nothing wrong with that, surely.
679. PG …well what I would say is we have been through the process you have described. A lengthy process that we liaison, advisory discussions, leading to a set of proposals on which we consulted. So we have been through this process. We listened to the representations made and we have amended our proposals based on much of the advice we have received. In doing all of this we are not unlike other jurisdictions in the British Isles. We have all analysed the situation and come to broadly similar conclusions. We are not out of step with others. Our advice is to Welsh Government to support and confirm the amended proposals that we have put to them and we will see what happens. So the extensive period of liaison, consultation, discussion has happened, it has happened.
680. AN Well in our opinion there are still anglers out there that do not know anything about it. We feel that you have buried this and kept it at the
18296037.1 72 London Gazette and as you have actually quite rightly said, no Welsh anglers read that.
681. ID Clearly there has been a lot of communication
[Talking over each other]
682. DM They don’t read the Daily Post, the Western Mail? There were 3,000 hits on the website page
683. PG Ian wanted to mention…
684. ID Well clearly there has been far more communication than the London Gazette. Hasn’t there?
685. PG I think you are not sighted on it and I have no understanding why that is the case, when we have had at least 4 meetings I would say of each of the 9 LFGs, each of which had 15 or 20 people in attendance, this conversation has been going on for a long, long time and although I don’t, Dave looks at some of the forums and can advise us that this has been a subject of discussion for a long time on there. My conclusion, Andy, is that discussions/liaison/knowledge/correspondence has been going on for a long, long time. There will always be some people who are unreached by this, if that is a word. Anyway, and it is difficult to know how we can address that. We considered this during the statutory consultation on the Wye Byelaws where people said that they did not know anything about it therefore it was not fair. Unfortunately we conclude that if people are genuinely unsighted on this then there is little more we can do. We cannot guarantee to bring this to the attention of everyone.
686. AN A small slip of paper when they get their licence and…
687. PG I’ve explained why we couldn’t do that, and…
688. AN …I am sure that could be overcome.
689. PG I am not.
690. AN Okay.
18296037.1 73 691. PG Because of the Post Office contract and the complexities of managing that.
692. AN What? A piece of paper in an envelope? It’s not going to weigh any more or anything like that.
693. PG It is not a question of the cost it is the complexity of doing it.
694. AN Well I have to say I have no understanding of that but there you go…maybe this is where I agree with John.
695. PG I have less understanding of it than I would like but we know that doing it through that route is not tenable.
696. AN Basically what I would like to say now gentlemen is I really appreciate that you have made such an effort to come up and speak to us and you have answered some of the questions, not all of the questions, but some may be answered in the future.
697. PG A good majority I think.
698. AN And so we have asked all the questions that we wanted answered and... what time is left to give you the floor and for you to say whatever you want to say gentlemen.
699. PG Well I am not going to repeat the advice I gave you earlier but I would suggest you consider that. Dave you set out these bullet points on the agenda, is there anything you feel that we need to raise or Ian, if you have any contribution that you want to make on any of those points?
700. PG Perhaps we could reiterate the timescales for the annual reporting which might help.
701. AN There is one thing, sorry but, it is just a bit confusing to me. When we spoke you were hoping to get the package off to Lesley within a week or so, when we listened to the transcript Lesley Griffiths said that she is expecting it within a couple of months.
18296037.1 74 702. PG Yes, she also said she was not aware of any problems of fish eating birds so…
703. AN Precisely.
704. PG I am sure about the latter...
705. AN Okay.
706. PG …And therefore I wonder about other things.
707. AN Okay, well, what’s your…
708. AN It is incorrect.
709. PG It is incorrect. The intention expressed at the board was to get the application to the Welsh Government by the end of the first week in February and as a back stop by mid-February.
710. AN Okay.
711. PG So the…
712. AN ..[ ] the intention..[ ]...
713. PG …several boxes were delivered to, have been delivered to the Welsh Government already. We have a translation issue to address, technical translation which is currently going to be resolved tomorrow, we think.
714. AN Okay.
715. PG So the final component of that, the final 2% of paper, 1% of papers probably, should be with them, depending on the performance of our translators, by the end of tomorrow.
716. AN You did mention...
18296037.1 75 717. JE Sorry, by the end of tomorrow?
718. AN …you did mention that you will be hand delivering it to Lesley Griffiths?
719. PG No, I do not think she would have the time to meet us. To her technical advisors, that is correct.
720. AN I think it is yourself that said it was going to be hand delivered, when we…
721. DM Yes, not to Lesley Griffiths.
722. AN No?
723. DM I’ve never met her.
724. AN Oh right, but you…
725. PG I think she has better things to do than meet up with Dave…
[All speaking over each other]
726. AN Well when we spoke on the phone you said it was going to be hand delivered.
727. DM Yes.
728. AN And I said, okay, well that is another journey for you, if I remember rightly.
729. DM Correct.
730. PG Absolutely, but we did not say the Cabinet Secretary would pop down to pick boxes up…
731. AN Oh okay, so is it just going to be delivered by what the post or..?
18296037.1 76 732. PG Well if you want to discuss this that I am fine to do that.
733. AN No, no, not at all, I mean…
734. PG They expressed a view, reasserted by others who we have to listen to, that hard copy material would be delivered to a Welsh Government office.
735. AN Okay.
736. PG And that has happened. The addressee for this is Graham Rees.
737. AN Yes.
738. PG Who is the Head of Department for Marine and Fisheries. And one of his staff carried the boxes. That is exactly what happened.
739. AN Okay, thank you.
740. PG So the rest of it, the 1% that remains, once the translators have finished, will be also, will that be posted or hand delivered, Dave?
741. DM We will probably post it.
742. PG I mean to me, there is nothing wrong with pressing ‘send’ on an email.
743. AN Well there you go. So anything else that you would like to bring up gentlemen?
744. PG Well I will revert to what we were taking about just a second ago, the timescale for annual reporting now Ian…just to help us... me if I’m honest.
745. IG The draft ICES report will be a month from now, something like that, so the catch statistics for 2017, a good provisional version are actually going to be sealed tomorrow, at least that is the plan and then it is on the basis of those provisional catch data that we run our assessments. So then there is a month running time until the report is completed and then
18296037.1 77 colleagues in Cefas take that to the International Working Group ICES, that deal with salmon stocks across the North Atlantic...
746. PG Are there any elections either in Wales or England this year? Because in previous years purdah has caught us and we’ve been unable to publish these prior to elections…
[All speaking over each other]
747. ID We are publishing now
748. JE That won’t be bothering many people.
749. PG So what we tend to do once the annual report which is called the ICES report although it is co-authored by ICES, the EA and NRW once that is available then we generally, you will probably have seen it through this route I hope, notify all the other LFGs and give them a link to the documents. Thereafter or thereabouts the same time the EA and NRW ourselves publish a brief report which you have seen as well which is a salmon stock performance 2017 and sea trout performance 2017 so that will come out via LFGs but we will also put that on our website and email it to anyone else who has expressed an interest in seeing it. A lot of people do not want to see it but there we are. Is there anything else from here? I think that is everything from our agenda so I do not have anything else to add.
750. AN Okay. John, anything more to add?
751. JE No I mean...
752. ID Just to say you know if you have any questions outside this meeting casually.. then I’m always on the end of a telephone…
753. PG Yes absolutely. And I hope that has been clear.
754. JE I still struggle with the conservation limit / management target.
755. PG Well possibly you and Ian need to have a discussion further about that to help you.
18296037.1 78 756. JE Yeah I’ll have a trawl through tonight.
757. PG John, you are not the only one.
758. AN But surely that does affect how you put these proposals forward looking at figures that may be wrong?
759. PG Well we do not believe they are wrong, we strongly support our evidence base.
760. ID There is a difference between being wrong and concepts being difficult to understand and we are not, you know you mentioned Ivor Llewelyn we’ve been having these sorts of discussions, the sort of discussions that you and I have had, that we have had today with the Atlantic Salmon Trust and other representatives like that. These are not easy concepts to understand, we struggle with them at times, people outside struggle with them at times. It does not mean there are problems with it.
761. AN There could be.
762. JE I mean it just seems to me there as the angler on the riverbank who has eyes and ears open that I still do not see the gains that will be made from this will exceed the losses.
763. PG Okay.
764. JE You know, you cannot produce any evidence for that, no more than I can produce the concept that that will be. I have people reporting to me that huge numbers of fish went up the Mawddach last year. Really, I have not got a clue. One of those was actually an NRW enforcement officer. But that is it, you have got pools that are dark and peaty nobody knows what is up there. We, you know, we know the rivers better than anybody I think has been accepted. What worries me greatly about this is, and I can only speak personally from the heart, and I am clinging on by my fingernails in terms of [……] on what side of the fence or the other. Clearly we are different, we approach it in a professional way throughout. As I said to Ceri, we would love to work with you, we want to work with you, you know what my track record is Peter from…
765. PG I do, I do.
18296037.1 79 766. JE …I feel I have been edged out a bit.
767. PG That is not...
768. JE …that is from my personal perspective. I have lost count of the numbers of hours that I have spent spraying invasives, that I have spent trying to work with staff on the ground. I am not going to embarrass myself by repeating Kat Marshall’s words regarding that, but basically if you do not come we meet on our own.
769. PG It makes it much more difficult…
770. JE All that has been put at risk for something that I cannot for the life of me, I think I am reasonably intelligent, is going to make any substantial gain. I know it is very easy to say, well we cannot allow fish to be killed.
771. DM Because there aren’t enough fish spawning...
772. JE Sorry?
773. DM The spawning numbers are going down.
774. JE Yeah, it is very easy to say, ‘right, it stops fish being killed by anglers’, but actually when that is not the significant total that it could be i.e. 500. I still believe there are huge steps... if I take my own club for example, we use tags we have done for some time. And I have to say there is an element of doubt here that the starting point for all of this Peter, for me, there was not this big hard debate at LFGs, ‘look this is where we are’, so had this stock assessment been put to us in a form which I could have understood then and had a chance to go into it. I would step back. We presented with the ‘know your river’ documents... and you look at that graph in the middle and then you close it etc. etc. So, I am not going to go over old ground before we close but when people like myself feel, ‘what is the point? It is a five hour round trip for next week’s LFAG.’ I do not have to go but I want to go. I want to see…
775. DM I know and I reiterate we want you there as well.
776. JE But can you see where I am coming from?
18296037.1 80 777. DM Yeah...
778. JE That we could work together and actually achieved similar if not better results. You have clearly seen that picture differently than we do. The rules or the byelaws as they stand we see as unenforceable in many ways. I mean I know people from 40 years ago who went on... well they made it easy actually to go and catch a salmon or two, because they went out night fishing for sea trout with fast sinking lines. Two flies on a 30 pound leader… I have seen, you know, 8 by 4 sheets I saw... party to a photograph that someone has shown me. You could not see it... for salmon and sea trout.
[All talking over each other]
779. DM Is there many enforcement issues with the spring salmon bylaws in catch and release? Don’t you think anglers will not just…
780. JE Well I could quote you examples, but I will not because I won’t incriminate…
[All talking over each other]
781. DM I fish three times a week, I just do not see it.
[All talking over each other]
782. AN The point you are trying to make is that the anglers, the clubs and the associations are the lifeblood of the river. They are the custodians, they are the guardians, you are the regulators which we have got to work with. You take the guardians and custodians and the lifeblood away from the rivers, all these problems that John is talking about are going to return. Anglers leave the river, poaching comes back, pollution is not reported. This is what I do not think you are grasping. You are alienating the anglers and you are driving them away from the rivers like the rights of Roy Platt and many many more. You take that away, we…
783. PG We are not stopping people fishing.
784. AN No but you are stopping people fishing in the way that their heritage, the way…
18296037.1 81 785. PG No, sorry…
786. DM No we are stopping people killing the fish.
787. AN But you are banning fly fishing for salmon fishing
788. DM Well, so that they survive once they go back in.
789. DM Surely, that is a laudable...
790. AN It is a laudible thing but use a circle hook and then that gets that…
[All talking over each other.]
791. PG We are showing all the signs of revisiting territory we have already covered.
792. AN We are, yes, and I appreciate that.
793. PG So let us stop doing that and agree that…
794. AN We will have to disagree on a lot of things.
795. PG …we do disagree on a lot of things. I hope you understand why we have taken the decision even if you do not agree with it. We understand you are anglers so thank you. And what we 100% want to do is…
796. AN Listen, thank you very much indeed. We really, really appreciate it. Thank you very much.
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