Proof of Evidence Document Reuben Woodford Afon Ogwen Anglers (Petitioners) {In collaboration with CPWF} Personal Background My Name is Reuben Woodford, I am the Gwynedd Local Fisheries Advisory Group representative for ‘Anglers of the Afon Ogwen’ – Anglers are served by and contribute to, two community clubs on these waters 1) Ogwen Valley Angling Association [Approx 80 members] & 2) Penrhyn Fishing Club [approx 30 members]. I represent the committees and anglers of the afore-mentioned community clubs and as originator of a petition presented to the Welsh Assembly ‘Give Welsh Fishing Clubs & Salmon & Sea- trout a chance’, on behalf of 1719 signatories (calling for a revised approach to improving habitats, managing fisheries and collaborative initiatives, underpinned by a new era of improved relationships and communication, conducive to progressive and productive, catchment and community focused approaches. We recognise that there are uncertainties in terms of risks to salmon at sea and within coastal margins and we call for greater action to identify and help manage these impacts.) I stand alongside members of the CPWF in providing evidence to the Public Inquiry. I have worked within the environmental field for the last 25 years for NRW; EAW & CCW, primarily within Flood and Coastal Risk Management and produced the Catchment Flood Management Plans for North Wales, establishing the strategic approach for FCRM in line with climate change predictions. I have worked for Local Authorities as a flood risk engineer and as a private sector environmental consultant managing ecological and human health risk from contaminated land; habitat restoration. I have an MSc in Water Resource Management and hold a BSc in Applied Geography/Geology and am a qualified personal trainer and sports therapist (Dip PT & Dip ST) with an interest in sports science. I have a lifetime of participation in sport and following pursuits in the outdoors, angling being the one that draws all these interests together and upon which I have a multi-disciplinary view. Forward Summary Section 1 Our Current Position Prohibition and Stock Recovery Exploitation Controls in the Context of Catchment Limitations to Stock Recovery Causative Factors of Stock Decline and Recovery The Selling of Salmon – Ineffective Law Social Backlash – Enforcement Information The Consequence of Applying Bylaws with Social, Cultural and Economic Impacts The Prohibition Paradox To Lose Cultural Values The Consequential Risk Due to the Byelaw Measures Red Flag Impacts Section 2 The River Ogwen – In the Context of the NRW Byelaw Proposals Catchment Characteristics Habitat Impacts Catchment Pressures Salmon & Sea-Trout River Restoration Work Water Framework Directive Key Problems Ogwen Bank Weir Fish-Pass Small Scale Run of the River HEP Denuded River Channels Achieving Actions Salmon and Sea-trout Action Plans Water Framework Directive Future of River Channel Restoration Salmon Stock Status Afon Ogwen Fishing Clubs Conservation Measures Section 3 Well-being Considerations – NRW Byelaw Impacts The Well-being Goals The Five Ways of Working A Failure to instigate Sustainable Development Well-being – Pitfalls and a lack of Opportunity Byelaw Impacts - Objectives Section 4 Consideration of Proof of Evidence NRW/1 Consideration of Proof of Evidence NRW/1A Table 1 Direct Impacts of proposed NRW Byelaws on Angling Behaviour Table 2 Consequences to Angling due to Impact on Angling Behaviour from NRW Byelaws Table 3 Conservation Limit Afon Ogwen Table 4 Fish Predation Rates Figure 1 Fish Exploited by Natural Predators, Poachers and Anglers River Ogwen Proof of Evidence Document Reuben Woodford Afon Ogwen Anglers (Petitioners) Foreword The fact we have been drawn into this stage of a process that was to be about collaborative partnerships and a shared way of working is of great disappointment to I and the angling community I represent. This level of discord between NRW and communities cannot be perpetuated as there is far greater challenge to come and we must find common ground upon which to build a future. NRW’s Byelaw measures cannot provide what we collectively seek, as prohibition of elements of angling will neither improve fish-stocks or our shared well-being, now or in the future. Summary The primary frustration for the angling community, is that we and NRW share a common goal for the present and future for salmonid fish stocks. Our current predicament places partnership working between NRW and communities in jeopardy. This is a non- productive situation to be in and a waste of resource for all concerned, unless; we learn by this painful scenario and build measures that allow us to progress building resilience and positive adaption. It is however, NRW, who have placed us in this position; we have provided the scrutiny and evidence that they have refused to apply and pursue, to bring us all to a point of enablement. We can only participate in a meaningful way if we are allowed to participate; and we have not been. Having considered well-being goals in a seemingly myopic way, NRW have failed to identify the risks associated with their prohibitory measures, and thus continue to throw blind faith into their byelaws. The measures have been developed without the deliberative process called for within NRW’s SoNaRR Report (3) and the ‘common sense’ approaches spoken of in NRWs corporate plan (1). Collectively, we within the angling community, who come from varied backgrounds, but share a common purpose, present in our evidence, reasoned argument why the byelaws would bring detriment to the fisheries we share. NRW’s Corporate plan (1), promises much and seeks change in the behaviours of its Institution, that make sense to us all, and yet our collective experience indicates that change remains blocked by an organisation with very little maneuverability, choked of the ability to accommodate adaption and admit mishap in approach. Whilst providing us with a dearth of promise within corporate ‘delivery plans’, we know all our river catchments require attention, to improve ecological status and habitats and to optimise the productivity of fisheries. The SoNaRR report (3) makes very clear the improvements that are required in our environment and acknowledges our collective shortfalls. Little ‘on the ground’ action has taken place recently because regulatory aspiration and resource is in a downward spiral. We understand the constraints, but we offer a solution in partnership to alleviate some of the pressures. A rebuff such as the byelaws, is a self- destructive management tool in such a scenario. Excluded and disempowered from an inclusive, collaborative and integrated development approach, contrary to the guidance and vision expressed in a host of strategic documents, to which NRW are tied to by law and best practice principles - the angling community face prohibition from traditional angling methods. For over a decade, anglers have been progressively returning more of the fish they catch and engaging in environment projects which help sustain the eco-system services of our rivers and riparian corridors. We have all engaged more, learnt more and developed greater synergy with the requirement to adapt to environments and fish stocks under variable degrees of pressure. Criminalisation of people with whom NRW work in partnership, in particular when NRWs own enforcement teams doubt the wisdom of the approach or their ability to police such a system, or ethicacy to do so – sends a strong warning sign to those who believe in the unquestionable ability of prohibition to stop practices guarded by tradition. Tinkering with angling methods will achieve nothing. The consequential impacts of the byelaws have been ignored – it is imperative they are not. The Environment Agency in England recognises the danger of criminalising acts that represent very low impact to fish survival whilst cultural worth to its people. This is a pursuit that brings well-being to communities in many ways. NRWs ‘byelaw’ choice is its own and it risks making Wales an exporter of angling tourism, when the natural predation rates and poaching activities upon Welsh Waters are likely to make up most of the exploitation of adult and juvenlie fish in Welsh rivers. Lacking robust scrutinisation, NRW have provided measures, not fit for purpose, which were they to be applied to Wales rivers would leave the regulatory environment blind and weak with depleted data and enforcement supplementation. The sociological connections and synergies formed through the existence of angling as a pursuit in Wales stimulate well-being; social, economic and cultural. Angling communities have found themselves in a contrary position; defending principles of sustainable development and well-being because NRW are not adhering to them. The divergence in stance between communities and the NRW, is not one related to ‘aim’, but of the most appropriate means of ‘achieving’ a shared goal; a goal both of fish and of people and their relationship with environment. The alternative approach presented by CPWF(6) supported by the angling community, seeks a collaborative and integrated approach to formulate a robust and useful mechanism to take our shared initiatives forwards. There can be nobody by now who relishes the lack of consensus between NRW and stakeholders. The angling community, have developed their evidence further since the NRW Board meeting of January 2018, illustrating objectively the weaknesses in NRWs stock assessments; management tools and well-being considerations. Diane McCrea made a decision upon the bye-laws, knowing there was not only a serious gap between the views of the fishery team and stakeholders, but a serious lack of collaborative working to derive the measures. This is simply not sustainable principles in motion – it is time NRW considered why there is such a gap between their aspirational rhetoric and the working reality. ‘An important success factor for sustainable development is to obtain greater consensus and strengthen community involvement in both deciding on priorities, and on delivery. ‘ (7) The Prohibition ‘Byelaws’ would undermine our progress and have wide ranging consequences: 1.