DRAFT COPY Evid idence to be presented at the Public lic Enquir iry: The Wales Rod and Lin ine (Salmon and Sea Trout) Byela laws 2017 The Wales Net Fis ishing (Salmon and Sea Trout) Byela laws 2017 Reuben Woodford – Riv iver Ogwen/Afon Ogwen Angle lers In In conju junction wit ith The CPWF
To achieve our shared goal for the well-being of fisheries and fishing communities we must formulate a means of delivering outcomes without creating the damaging consequences brought by NRW’s proposals. These Byelaws based upon ‘myopic thinking’ CANNOT achieve the OUTCOMES we All desire. NRWs failure to engage in a reasoned deliberative process has progressively undermined our ability to bring forth the foundations for future adaption.
DELIBERATIVE PROCESS • Failure to stimulate a deliberative process CONCILIATION CONSENSUS INFORMED AND ENGAGED COMMUNITY CROSS FERTILISATION C0-PRODUCTION & CONSIDERATION OF COMMUNITIES IDEAS, OF IDEAS INTERPRETATION OF EVIDENCE VALUES,PREFERENCES & NEEDS INFORMED TRANSPARENCY, LIGITIMACY, DECISIONS ACCOUNTABILITY IN DECISION MAKING
NRW’s MYOPIC APPROACH NRW thrown blind faith at a system of prohibition to create outcomes COMMUNITIES NRW PREDETERMINATION PROHIBITION
STRATEGIC IN INCONSISTENCIES • THE BYELAW APPROACH - DENIES US THE ‘COMMON SENSE’ APPROACH STIPULATED WITHIN NRWs CORPORATE PLAN • POSITIVE BEHAVIOURAL CHANGE WITHIN NRW SEEMS BLOCKED BY A DEFICIT OF INSTITUTIONAL MANOUVERABILITY • NRWs ‘State of Natural Resources Report’ [ SoNaRR] MAKES EVIDENT THE WIDESPREAD ENVIRONMENTAL IMPROVEMENTS NECESSARY • NRW’s PROMISE IN ‘STRATEGIC PLANS’ FAR OUTWEIGHS ACTIONS ON THE GROUND • OUR RIVER CATCHMENTS require urgent action, to improve ecological status and revitaliSe habitats to optimise the productivity of fisheries
• THE BYELAW MEASURES OFFER NO GUARANTEED DELIVERY OF REQUISITE OUTCOMES WHILST CARRYING SIGNIFICANT RISK TO WELL-BEING GOALS AND MANAGEMENT OF FISHERIES • TINKERING WITH ANGLING METHODS WILL MERELY CAUSE ANGUISH FOR ANGLERS AND LITTLE ELSE. • NRW elude to in their corporate plan: • ‘And we will know we are working in the best way we can because our staff and customers will have told us so. We strive for excellence and are continuously improving how we work – this is an integral part of our culture and our behaviours.’ (1)
CAUSATIVE FACTORS OF STOCK DECLINE River Marine • Climatic variability – temperature • Reported changes in adult salmonid increase/extreme flows/low flows and feeding grounds. rapid flux between flows. • Over fishing at sea and by-catch of Adult • Altered flow regimes and sediment Salmon (& over exploitation of prey) transportation due to engineered in • Fish Farms (Sea Lice & Disease affecting wild stocks) channel assets and abstractions • Fish Farms (Escapement & Interbreeding) • Water Quality Impacts • Habitat Loss and degradation • Estuarine illegal fishing • Excessive natural predation rates • Natural Predation • Man-made and natural barriers to • Climate Change – Induced ecosystem response to ocean temperatures juvenile and adult fish migration • In river illegal fishing
NON-ENFORCEMENT OF CURRENT PROHIBITIONS • Prohibition of the Selling of Salmon – Ineffective Law • Prohibitory legislation introduced by the Environment Agency on 31 st January 2007. • Number of prosecutions for selling of rod caught salmon & sea trout in Wales per annum, 2013 - 2018. 0 • 2. Number of prosecutions for selling of illegally caught salmon & sea trout in Wales per annum, 2013 - 2018. 0 [FOI NRW] There is no institutional will to act on the ban.
WHY THE BYELAWS COULD NOT BE ENFORCED • SOCIALLY UNJUST AND DISPROPORTIONATE – Anglers practicing a craft v hardcore poaching • NRW DO NOT HAVE ADEQUATE ENFORCEMENT RESOURCE or WILL • NRW REPUTATIONAL DAMAGE – Widespread Enforcement Action • Individual enforcement actions would be deemed PERSECUTION • Most enforcement officers are anglers. They were not consulted on these plans internally and they recognise the angling community have been ALIENATED by NRW.
The Prohibition Paradox • THERE IS A HIGH RISK THE BYELAW MEASURES WOULD LEAD TO CONSEQUENTIAL IMPACTS ON STOCKS THROUGH ILLEGAL EXPLOITATION • BANNING SOMETHING RARELY STOPS THAT THING FROM HAPPENENING – [PARTICULARLY - WHEN SOCIALLY UNJUST] • OVERWHELMING NEED FOR EMPOWERMENT
OPPOSING BYELAWS TO DEFEND A SUSTAINABLE APPROACH NRW Board Members NOT BECAUSE THEY OPPOSE THE CONSERVATION OF SALMON, BUT Signatories of two BECAUSE THEY RECOGNISE THE petitions [1069;1720] OPPOSE THE BYELAWS STAND AS A HIGH RISK TO IT AND EMPOWERMENT OF 83% of respondents to BYELAWS ANGLERS AND PROMOTING THE NRWs consultation RESILIENCE OF ANGLING INSTITUTIONS IS A FAR STRONGER Assembly Members & MEANS OF CONTRIBUTING TO the Assembly’s Petitions ACHIEVABLE OUTCOMES Committee
Direct Impacts of Proposed NRW Byelaws on Angling Behaviour • Remove freedom of choice • Stop anglers taking a trophy fish • Stop anglers taking a salmon for subsistence • Stop angling for salmon using traditional methods • Limiting anglers ability to fish certain water conditions • Limiting anglers ability to fish certain waters • Forcing anglers to make counterintuitive actions • Forcing clubs to make counterintuitive actions • Forcing anglers to buy new equipment • Forcing anglers to pursue their pastime outside of their community environments and country • Forcing anglers to pursue their pastime during unsociable hours • Forcing anglers to follow an alternative fishing regime and fishing methods • Forcing anglers to return dying fish to the water • Destroy the free spirited nature of fishing
Consequences to Angling due to impact on angling behaviour NRW Byelaws • High negative impact upon intrinsic and amenity value of angling • High impact upon the cultural value of angling • High impact upon traditional fishing methods • Loss of subsistence benefit • Unequitable consequences in comparison to recreational sea angling controls • Forced to adopt immoral stance through participation [release dead fish/C&R only/use of light tackle for large fish] • Criminalisation of mundane acts in comparison to current high impact illegal activity • Unequitable impact upon anglers
The consequential risk due to the byelaw measures proposed High risk to the resilience and future of community angling clubs due to; a. Lost participation b. Inability to maintain club managed assets c. Inability to pay tenancy fees d. Consequential loss of local waters to community clubs High risk to objective Catch Return Data sets - Inability to asses stocks - Inability to apply appropriate management controls - Loss of regulatory functions - System failure High risk to community sourced partnership working - Loss of enforcement capability - Loss of habitat restoration - Loss of access maintenance - Loss of environmental crime data - System failure Negative impact upon mental well-being of through: loss of guarded cultural values; loss of traditional angling methods; loss of ability to supplement diet with wild fish; necessity to return dead fish to water; inability to exercise mundane acts under draconian restrictions; loss of life experience; loss of shared experience; loss of existing positive impacts upon mental well-being; over regulated environment.
Red Flag Impacts Community related: i. Dead Fish Carcasses to river ii. Loss of safe access to riverside paths iii.Loss of community centered service/hub iv.Loss of positive local and distal economic impact v. Negative impact on traditional skills and values vi.Anglers forced to seek pursuit in other uk/foreign waters a) Significant cost implications and not a reasonable option b) Negative carbon footprint impact c) Alternative access to pursuit limited accessibility d) Perverse consequence in terms of wider sustainability i. Loss of ‘healthy community spirit’
Red Flag Impacts NRW Related 1. Increase in Illegal fishing and impact on fish stocks 2. Increase in environmental crime and impact on ecosystems 3. High magnitude people science data loss and subsequent failure of evidence based system – Fisheries/WFD 4. Negative impact upon community centered ‘environment’ projects 5. High level of reputational damage 6. Antithesis of required approach leading to ill-being impacts
OUTCOMES EVIDENCE EVIDENCE Well-being Stock Assessment Stock Assessment Sustainability Decision Management CONSEQUENCE Decision Management CONSEQUENCE SYSTEM UNDERMINED
PEOPLE COMMUNITIES • Opportunity • Connectivity • Progression Fishery • Proportionality River Catchment Fish Environment • Partnerships Temporal Context SYNERGY
PEOPLE • Opportunity • Connectivity • Progressive • Realistic Fishery Fish Environment • Sensible PROHIBITORY Temporal Context BYELAWS SYNERGY
PEOPLE • Opportunity • Connectivity • Progressive • Proportionality Fishery Fish Environment • Partnerships PROHIBITORY Temporal Context BYELAWS SYNERGY
PEOPLE • Opportunity • Connectivity • Progressive • Proportionality Fishery Fish Environment • Partnerships PROHIBITORY Temporal Context BYELAWS SYNERGY
CATCHMENT EXPERIENCE RIVER OGWEN - AFON OGWEN
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