The Wales Net Fis ishing (Salmon and Sea Trout) Byela laws 2017 - - PowerPoint PPT Presentation

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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

CONSENSUS CROSS FERTILISATION OF IDEAS INFORMED DECISIONS C0-PRODUCTION & INTERPRETATION OF EVIDENCE CONCILIATION INFORMED AND ENGAGED COMMUNITY CONSIDERATION OF COMMUNITIES IDEAS, VALUES,PREFERENCES & NEEDS TRANSPARENCY, LIGITIMACY, ACCOUNTABILITY IN DECISION MAKING

NRW’s MYOPIC APPROACH

NRW thrown blind faith at a system of prohibition to create outcomes

PREDETERMINATION PROHIBITION

NRW

COMMUNITIES

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

Marine

• Reported changes in adult salmonid

feeding grounds.

• Over fishing at sea and by-catch of Adult

Salmon (& over exploitation of prey)

• Fish Farms (Sea Lice & Disease affecting

wild stocks)

• Fish Farms (Escapement & Interbreeding)
• Estuarine illegal fishing
• Natural Predation
• Climate Change – Induced ecosystem

response to ocean temperatures River

• Climatic variability – temperature

increase/extreme flows/low flows and rapid flux between flows.

• Altered flow regimes and sediment

transportation due to engineered in channel assets and abstractions

• Water Quality Impacts
• Habitat Loss and degradation
• Excessive natural predation rates
• Man-made and natural barriers to

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 31st

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

NRW Board Members Signatories of two petitions [1069;1720] 83% of respondents to NRWs consultation Assembly Members & the Assembly’s Petitions Committee

OPPOSE THE BYELAWS

NOT BECAUSE THEY OPPOSE THE CONSERVATION OF SALMON, BUT BECAUSE THEY RECOGNISE THE BYELAWS STAND AS A HIGH RISK TO IT AND EMPOWERMENT OF ANGLERS AND PROMOTING THE RESILIENCE OF ANGLING INSTITUTIONS IS A FAR STRONGER MEANS OF CONTRIBUTING TO ACHIEVABLE OUTCOMES

OPPOSING BYELAWS TO DEFEND A SUSTAINABLE APPROACH

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’

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

Red Flag Impacts

CONSEQUENCE EVIDENCE Stock Assessment Decision Management CONSEQUENCE EVIDENCE Stock Assessment Decision Management Well-being Sustainability OUTCOMES SYSTEM UNDERMINED

PEOPLE COMMUNITIES Fish Temporal Context Environment Fishery River Catchment

SYNERGY

• Opportunity
• Connectivity
• Progression
• Proportionality
• Partnerships

PEOPLE Fish Temporal Context Environment Fishery

SYNERGY

• Opportunity
• Connectivity
• Progressive
• Realistic
• Sensible

PROHIBITORY BYELAWS

PEOPLE Fish Temporal Context Environment Fishery

SYNERGY

• Opportunity
• Connectivity
• Progressive
• Proportionality
• Partnerships

PROHIBITORY BYELAWS

PEOPLE Fish Temporal Context Environment Fishery

SYNERGY

• Opportunity
• Connectivity
• Progressive
• Proportionality
• Partnerships

PROHIBITORY BYELAWS

CATCHMENT EXPERIENCE RIVER OGWEN - AFON OGWEN

50.6 21.8 11.9 26.2 50.7 75.7 49.6 99.5 29 137.4 25.2 48.2 64.4 113 55.6 88.8 82.2 94.7 52.4 52 87.5 20 40 60 80 100 120 140 160 1989 1990 1991 1992 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m squared - Afon Ogwen 1989 - 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m

Adapted from Source NRW - Salmonid Juvenile Data – Afon Ogwen Site 4 SH63806270

50.6 21.8 11.9 26.2 50.7 75.7 49.6 99.5 29 137.4 25.2 48.2 64.4 113 55.6 88.8 82.2 94.7 52.4 52 87.5 20 40 60 80 100 120 140 160 1989 1990 1991 1992 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m² Afon Ogwen 1989 - 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m

Adapted from Source NRW - Salmonid Juvenile Data – Afon Ogwen Site 4 SH63806270

Years Exceeding Estimated Salmon Parr Population – 50 fish per 100m² 1989 2000; 2001; 2003 ;2005 ;2008 ;2009 2010; 2012; 2013; 2014; 2015; 2016; 2018

50.6 21.8 11.9 26.2 50.7 75.7 49.6 99.5 29 137.4 25.2 48.2 64.4 113 55.6 88.8 82.2 94.7 52.4 52 87.5 20 40 60 80 100 120 140 160 1989 1990 1991 1992 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m squared - Afon Ogwen 1989 - 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m

Adapted from Source NRW - Salmonid Juvenile Data – Afon Ogwen Site 4 SH63806270

Missing Data

Grade Descriptor Interpretation A Excellent In the top 20% for a fishery of this type B Good In the top 40% for a fishery of this type C Fair In the middle 20% for a fishery of this type D Fair In the bottom 20% for a fishery of this type E Poor In the bottom 20% for a fishery of this type F Fishless No fish of this type present

National Fish Classification Scheme Grades (Densities of Juvenile fish present)

50.6 21.8 11.9 26.2 50.7 75.7 49.6 99.5 29 137.4 25.2 48.2 64.4 113 55.6 88.8 82.2 94.7 52.4 52 87.5 20 40 60 80 100 120 140 160 1989 1990 1991 1992 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m squared - Afon Ogwen 1989 - 2018

Salmon (Juvenile) Parr Population Estimate Fish Per 100m

Adapted from Source NRW - Salmonid Juvenile Data – Afon Ogwen Site 4 SH63806270

Missing Data

Grade Descriptor Interpretation A Excellent In the top 20% for a fishery of this type B Good In the top 40% for a fishery of this type C Fair In the middle 20% for a fishery of this type D Fair In the bottom 20% for a fishery of this type E Poor In the bottom 20% for a fishery of this type F Fishless No fish of this type present

National Fish Classification Scheme Grades (Densities of Juvenile fish present)

NRW’s Parr Population Estimate DOES NOT POINT to a ‘’COLLAPSE IN SALMON STOCK’’

Stock status - Conservation of Salmon: Salmon stock status is assessed using ‘Conservation Limits’ which provide an

• bjective reference point

against which to assess the status of salmon stocks in individual rivers. The conservation limit represents the number of eggs that must be deposited each year within a given catchment in order to conserve salmon stocks in the future.

CONSERVATION LIMIT

NASCO Conservation Limit Met 9 of the Last 10 years.

Year Compliant with Conservation Limit Exceedance (%) 2017

265

2016

101

2015

135

2014 (Not Compliant)

39

2013

112

NRW Data-Set: River Ogwen Conservation Limit

RIVER OGWEN

NASCO Management Target Met. ‘Conservation Limit’ Exceeded 4 of Last 5 Years:

Year Compliant with Conservation Limit Exceedance (%) 2017

265

2016

101

2015

135

2014 (Not Compliant)

39

2013

112

NRW Data-Set: River Ogwen Conservation Limit

RIVER OGWEN

NASCO Management Target Met. ‘Conservation Limit’ Exceeded 4 of Last 5 Years:

Year Compliant with Conservation Limit Exceedance (%) 2017

265

2016

101

2015

135

2014 (Not Compliant)

39

2013

112

NRW Data-Set: River Ogwen Conservation Limit

RIVER OGWEN NRW’s Stock ASSESSMENT DOES NOT POINT to a ‘’COLLAPSE IN SALMON STOCK’’

0% 10% 20% 30% 40% 50% 60% 70% 50 100 150 200 250 300 350 400 450 1994 - 1997 1998 - 2001 2002 - 2005 2006 - 2009 2010 - 2013 2014 - 2017

Salmon Caught/Released 4yr Intervals

Caught (No) Released (No) Released (%)

River Ogwen : Progression of Salmon Catch Release Rates 1994 - 2017

River Ogwen 2017 Performance

• Salmon rod catch – improved in 2017 to slightly above the 10

year average catch.

• The Salmon release rate in 2017 was 65% the highest

recorded for the Ogwen.

NRW Management Target

• MANAGEMENT TARGET set at 80% above the defined Conservation

Limit (River Ogwen) – Arbitrary Figure

DISTORTION

• f

Management Decision Process Distorted Evidence Base Compliance with CL achieved - Debilitated Compliance Capability Management Target [Obscured] – Constricted Attainability

The BYELAW MEASURES pose a significant and likely risk to our collective ability to ‘assess fish stocks’.

COLLAPSE of Management Decision Process Objective Evidence Depleted Debilitated Analytics INCAPACITATED MANAGEMENT ANALYSIS TOOL

DISTENDED SENSE OF PREDETERMINATION OF POLICY

River Ogwen Salmon Stock Risk Status Under Current Constrained Assessment

DISTORTION

• f

Management Decision Process Distorted Evidence Base Compliance with CL achieved - Debilitated Compliance Capability Management Target [Obscured] – Constricted Attainability

CURRENT: PROBABLY AT RISK FUTURE PROJECTION [5YR]: PROBABLY AT RISK

Under the Scottish System the River Ogwen would have NO RESTRICTIONS as a result of its current stock status.

WE ARE PAYING THE PRICE OF REGULATORY STAGNATION – RESOURCE DEFICIT AND NRW STAFF DISEMPOWERMENT

VISION ACTION

CATCHMENT EXPERIENCE

AGENDA INSTITUTIONALISED PROTECTIONISM

CRISIS

2010 2012 2014 2016 2018

ANGLER CONTROL MEASURES

RIVER OGWEN CATCHMENT Upper WFD Lower WFD Liverpool Bay Coastal Environment Sustainability Principles Community Centric Catchment Focused Ecosystem Approach

RIVER OGWEN CATCHMENT Upper WFD Lower WFD Liverpool Bay Coastal Environment

• Barrier to Fish

Migration : Redundant fish- pass

• HEP Weir/Affected

Reach & Outfall

• Illegal Fishing
• Natural Predation

Zone

Penrhyn Fishing Club Associate Members Ogwen Valley Angling Association

River Ogwen Primary Spawning Grounds

Conservation Zone – No Angling weir Redundant Fish-pass HEP Weir FISH MIGRATION IMPEDED ACCESS SEVERE RESTRICTION ON MIGRATION

OGWEN BANK

HEP ‘Affected Reach’

Ogwen Bank – Historic Weir & Fish Pass

Fish Migration Potential – Indicative

River Flow 3 Months - Summer Non Operational Fish-pass Operational Fish-pass

Ogwen Bank – Historic Weir & Fish Pass

Fish Migration Potential – Indicative

River Flow 3 Months - Summer

Operational Fish-pass

Salmonid Migration & Access to Primary Spawning Areas

Temporal Window

Ogwen Bank – Historic Weir & Fish Pass

Fish Migration Potential – Indicative

River Flow 3 Months - Summer

Non Operational Fish-pass

Salmonid Migration & Access to Primary Spawning Areas

Temporal Window

Penrhyn Fishing Club Associate Members Ogwen Valley Angling Association Low Angling Intensity Low Angling Intensity (Lessened angling Opportunity) Conservation Rule Season Close 30th Sept

CONSEQUENCE OF BARRIERS TO MIGRATION OGWEN BANK

Fish Holding Areas Increased Vulnerability of stock to Illegal Fishing and natural predation

1 2

Distorted Migration Pattern Catch and data distorted

CONSEQUENCE OF BARRIERS TO GEOMORPHOLOGICAL PROCESSES OGWEN BANK 3

Weir Weir Weir

Penrhyn Slate quarry

Residual Slate Waste RIVER OGWEN Impeded Sediment Transport

FISH-PASS WEIR

HEP WEIR

SLATE WASTE RIVERBED – DOWONSTREAM OF HEP

SLATE WASTE RIVERBED

FAIL ILURE TO REALISE AN IN INTEGRATED SOLUTION TO IM IMPEDED FIS ISH MIG IGRATION AT OGWEN BANK

• Failing fish-pass REPORTED IN 2011 by the community
• Impeded fish migration remains after 8 YEARS
• NRW advised an HEP developer to ERECT A WEIR 100m downstream
• f the existing barrier. The schemes depleted reach coincides with a

locality given protection by byelaw

• Construction of a second weir runs counter to NRWs own guidance to

‘promote natural processes through weir removal’

• CONSEQUENCE: FISH & THEIR HABITAT AT INCREASED RISK

HEP Policy – Leaching Fisheries Progress

• Estimated ‘TOTAL DEPLETED REACH’ imposed upon Snowdonian rivers since 2010
• approximately 50km
• Total energy production equivalent to 1 – 2 (large scale) wind turbines
• HEP’s disrupt natural processes and distort river flows placing environment and

fish at increased risk

• The CATCHMENT WIDE IMPACT is not being assessed
• The ‘polluter pays principle’ is not being applied
• WG Proposal to Scrap planning requirements for some HEP – Sept 2018 [Very

dangerous precedent for river health]

• Inspection of NRWs SoNaRR Report ‘risk register’, illustrates renewable energy is

given exploitative license under a polarised definition of sustainability.

Driving Catchment Im Improvement

RIVER OGWEN CATCHMENT DISTAL CONTROLS ON FISH STOCKS Community Upper WFD Lower WFD WQ WQ Invertebrates – Fish - Phosphates

THE GAP BETWEEN PROMISE & ASPIRATION

Action

• Denuded River Channels
• Depleted Spawning Gravels
• Compromised Natural Process
• Compromised Riparian Habitat
• Diffuse Pollutants
• Excessive Natural Predation
• Sewage Discharge
• Illegal Fishing
• Barriers to migration
• Contradictory Actions
• Resource Deficit

THE GAP BETWEEN PROMISE & OUTCOME

Action

• RIVER RESTORATION
• IMPROVED GRAVEL SUBSTRATE
• SUSTAINED NATURAL PROCESS
• ENHANCED RIPARIAN HABITAT
• OPTIMAL WATER QUALITY
• MANAGEMENT OF PREDATORS
• WATER POLLUTERS PAY
• ENHANCED ENFORCEMENT

CAPABILITY

• REMOVAL OF IN-CHANNEL

BARRIERS

• IMPROVED DELIBERATION OVER

CONFLICTING ACTIONS

• OPTIMISED COLLABORATION

AND INTEGRATION OF ACTIONS

COLLABORATION

A STRUGGLING SYSTEM AT CATCHMENT LEVEL

WFD & RBMP REDUNDANT SALMON ACTION PLANS NO FISHERY SURGERIES DEPLETED NRW RESOURCE LEACHED ASPIRATION POLITICAL PRESSURE DISEMPOWERED ANGLING COMMUNITY UNRESOLVED CATCHMENT PROBLEMS Local Fishery Group Progressive Depletion BYELAW - RISKS ANGLING CLUBS STRUGGLING TO SUSTAIN MEMBERSHIPS HEP POWER INACTION INACTION INACTION INACTION ANTAGONISM INACTION STAGNATION ANTAGONISM RESTRICTED INFLUENCE CYCLING OF PROBLEMS ANTITHESIS PARADOX DISCORDANT PRIORITIES

85 2086 153 81

Fish Exploited by weight kg (2017/18 data)

ANGLERS - (SEASON) OTTERS - (ANNUAL) GOOSANDERS - (ANNUAL) POACHING - (2 INCIDENTS)

Anglers in 2017

The Proportionality of Fish Exploitation Rates

15 Goosander 8 Otter

18% 18% 17% 39% 94% 1977 - 78 1984 - 85 1991 2002 2009-10

Glaslyn & Llyn (inc Gwynedd)

[Ref: 2009-10 Otter survey of wales NRW & Snowdonia Mammal Group] Prevalence of Otter at designated survey sites Sudden decline in Otter numbers late 1950’s – Organochlorine Pesticides

The Otter Paradox

• Historically Otter numbers managed for the health of fisheries
• Conservation of Habitats and Species Regulations (2010); Wildlife &

Countryside Act 1981 – ‘Protected’

• There are no main predators of otter
• Most of the otter’s diet is fish ‘75-95%’
• Juvenile eels (elvers) returning to Welsh rivers have declined by 70%

since 1980 ‘Primary constituent of Otter diet’

• Otters are opportunistic feeders – ‘where salmonid species prevail

they target these species’

Approx 60cm

River Ogwen Remnant Otter Prey – Salmonid Sept 2018 Estimate 5lb Salmonid

The Otter Paradox

OTTER – Increasing Population Density

Fish consumption rate [1.5kg total prey day per adult otter: in captivity] Unquantified Impact

FISH STOCKS

CONSERVATION (Otter) POLICY

Angling Community –

Fisheries Management PROHIBITION OF OTTER CONTROL MEASURES

Photo: Salmonid Carcass – Otter Prey – River Ogwen August 2018

A Question of f Stewardship

Otter Paradox

OTTER – Increasing Population Density

Fish consumption rate [1.5kg total prey day per adult otter: in captivity] Unquantified Impact

FISH STOCKS

CONSERVATION (Otter) POLICY

Angling Community –

Fisheries Management PROHIBITION OF OTTER CONTROL MEASURES

The Impact of Otter population recovery on Salmonid fish stocks – A retracted debate

Ogwen River Fishing Clubs – Byelaw Impacts

• Contradict current conservation measures
• Both clubs have already seen a drop in membership
• Predominantly a river fished with worm and shrimp on low water
• Early close season on upper catchment would have to be removed
• On basis of angler views and current trend both clubs would be

put at imminent risk by imposition of the byelaws

WELL-BEING CONSIDERATIONS

THE CONTINUUM OF WELL-BEING

The well-being of Future Generations (Wales) Act 2015, states what we as a nation are aiming for in terms of well-being:

The Well-being Goals “A” Wales of cohesive Communities More equal Wales Healthier Wales Resilient Wales Wales of vibrant culture and thriving Welsh Language Globally responsible Wales Prosperous Wales

The ‘The Well-being of Future Generations (Wales) Act 2015 (WFG Act) instructs all public bodies including NRW to follow the

Sustainable Development Principle’:

Long Term Integration Involvement

SHORT LONG CONTINUUM RISK ASSESS ADAPT OPTIMISE INCORPORATE GAIN DIVERSIFY WELCOME PARTNERSHIP SUSTAIN LISTEN EMBED EMPOWER

Prevention Collaboration

‘The leadership challenge for’ those within

• rganisations referred to in the WFG Act,

irrespective of their position within that

• rganisation is ‘to work in a way that improves

economic, social, environmental and cultural well- being to help us create a Wales that we want to live in now and in the future. It is a way of thinking and behaving – developing a shared future where we can all work together with a shared purpose. ’ (7)

NRW’S BYELAW APPROACH ‘Places Environmental & Societal Well-Being in Jeopardy’

ECOSYSTEM SERVICES FISH STOCKS SOCIETAL WELL-BEING BYELAW MEASURES

FUTURE

NO RISK ASSESSMENT ECONOMIC PROSPERITY NO RISK ASSESSMENT SOCIO-CULTURAL VALUES NO RISK ASSESSMENT HEALTH & PARTICIPATION NO RISK ASSESSMENT EVIDENCE & ANALYTICS NO RISK ASSESSMENT FUTURE PARTNERSHIPS WELL-BEING IMPACTS CONSEQUENTIAL ILL-BEING

DISTORTED STOCK INTERPRETATION & RISK

UNREALISED OUTCOMES INAPPROPRIATE MANAGEMENT DECISIONS ACCUMULATIVE IMPACTS ON WELL-BEING

PRESENT

ECOSYSTEM SERVICES FISH STOCKS SOCIETAL WELL-BEING BYELAW MEASURES

FUTURE

NO RISK ASSESSMENT ECONOMIC PROSPERITY NO RISK ASSESSMENT SOCIO-CULTURAL VALUES NO RISK ASSESSMENT HEALTH & PARTICIPATION NO RISK ASSESSMENT EVIDENCE & ANALYTICS NO RISK ASSESSMENT FUTURE PARTNERSHIPS WELL-BEING IMPACTS

DISTORTED STOCK INTERPRETATION & RISK

INAPPROPRIATE MANAGEMENT DECISIONS ACCUMULATIVE IMPACTS ON WELL-BEING

PRESENT

CONSEQUENTIAL ILL-BEING

UNREALISED OUTCOMES

We must formulate a REVISED means of delivering WELL-BEING OUTCOMES to Environment & Society. NRW’s BYELAWS impose current and progressive ill-being impacts.

ECOSYSTEM SERVICES FISH STOCKS SOCIETAL WELL-BEING

MEASURES TO OPTIMISE MULTIPLE OUTCOMES

RISK ASSESSMENT ECONOMIC PROSPERITY RISK ASSESSMENT SOCIO-CULTURAL VALUES RISK ASSESSMENT HEALTH & PARTICIPATION RISK ASSESSMENT EVIDENCE & ANALYTICS RISK ASSESSMENT FUTURE PARTNERSHIPS

OPPORTUNISTIC APPROACH OPTIMISE GAINS ACROSS DIVERSITY OF WELL-BEING GOALS OPTIMISED STOCK ASSESSMENT REALISED OUTCOMES CONSIDERATION OF MANAGEMENT OPTIONS FOR MULTIPLE GAINS ACCUMULATIVE & PROGRESSIVE POSITIVE IMPACTS ON WELL-BEING GOALS

PRESENT TO FUTURE CONTINUUM INTEGRATED PROGRESSIVE BETTERMENT

ECOSYSTEM SERVICES FISH STOCKS SOCIETAL WELL-BEING

MEASURES TO OPTIMISE MULTIPLE OUTCOMES

RISK ASSESSMENT ECONOMIC PROSPERITY RISK ASSESSMENT SOCIO-CULTURAL VALUES RISK ASSESSMENT HEALTH & PARTICIPATION RISK ASSESSMENT EVIDENCE & ANALYTICS RISK ASSESSMENT FUTURE PARTNERSHIPS

OPPORTUNISTIC APPROACH OPTIMISE GAINS ACROSS DIVERSITY OF WELL-BEING GOALS OPTIMISED STOCK ASSESSMENT CONSIDERATION OF MANAGEMENT OPTIONS FOR MULTIPLE GAINS

ACCUMULATIVE & PROGRESSIVE POSITIVE IMPACTS ON WELL-BEING GOALS

PRESENT TO FUTURE CONTINUUM INTEGRATED PROGRESSIVE BETTERMENT

REALISED OUTCOMES

HIGH RISK STRATEGY – SOCIALLY UNACCEPTABLE

• ANTITHESIS OF AN ASPIRED WELL-BEING APPROACH
• PLACES FISH STOCKS AT AN UNQUANTIFIED LEVEL OF RISK
• PLACES THE STOCK ASSESSMENT DATA AT IMMINENT RISK
• PLACES SOCIETAL WELL-BEING AT RISK

Under ‘The Act’, Sustainable Development has been re-defined to aid its function interpretation and delivery.

“sustainable development, means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals.’’ (7)

The NRW have entered into this process with PRE-CONCEIVED PLANS & PREFERENCIAL DELIVERY MECHANISMS and have competed to defend these rather than shape measures through the sustainable development principle.

The WFG Act interprets ‘Sustainable Development as the process of improving well-being.’ This is our joint aim and The NRW’s responsibility under the ‘WFG Act’. As The NRW have developed measures that illicit ill- being, then this is not ‘sustainable development’ and those measures through necessity should be deemed inappropriate.

PEOPLE

ENVIRONMENT Environmental Economic OUTCOMES Social Cultural ‘Environmental sociology is a tool we can use to understand the complexity of the problems and find solutions, thus making sustainable development a reality and not just a dream’ (5) BYELAW MEASURES Consequence

 SILO WORKING  FISH V PEOPLE  DOMINANCE OF FUTURE FOCUS  NO OBJECTIVE RISK ASSESMENT ON WELL-BEING  OUSTING PEOPLE [Section 5 WFG Act] – LIMITING COLLABORATION AND CONSENSUS BUILDING

 Involving people (Section 5 of the WFG Act) No collaboration

‘Effective involvement of people and communities is at the heart of improving well-being currently and in the future. It recognises the importance of involving people in decisions that affect them. This builds on the Citizen-Centred Governance Principles, National Principles for Public engagement and the National Participation Standards for Children and Young People.’ ‘An important success factor for sustainable development is to obtain greater consensus and strengthen community involvement in both deciding on priorities, and on delivery.

• THE OPPORTUNITY TO OPTIMISE HOW PEOPLE ARE INVOLVED IN THIS PROCESS HAS BEEN DENIED

BYELAWS – IN CONTRAVENTION TO NRW’s ‘WELL-BEING OBJECTIVES’

[NRW Well-being Statement 2017/2018] NRW Objective1 – ‘Champion the Welsh environment and the sustainable management of Wales’ natural resources’ [Illustration of the risks and impacts due to the proposed byelaws] A Prosperous Wales Risk to opportunities for employment Risk to the future of angling for game fish in Wales Risk to retail outlets (and sole traders) selling fishing equipment and bait Risk to employment from angling orientated roles; guiding, instruction. Risk to angling tourism and possibility of becoming net exporter of salmon tourism Risk to commercial fisheries and land ownership Risk to employment supported by economic benefits from angling Research, Education & Learning Risk to river/fisheries based research and community sourced data Risk to the future of fisheries management development and progression Risk to life-experience of young (all) Risk to formal educational programmes linked to angling Disempowerment of anglers and angling institutions Perverse impact upon well-being goals setting a destructive precedent

A Resilient Wales

• Contradictory approach to elements of the principle of sustainability
• Non adherence to critical ‘ways of working’ within byelaw development

process

• NRWs dangerous conviction without due consideration for consequences

linked to byelaw prohibitions

• Undermining the critical partnerships between regulator and community
• Placing all that ‘NRW do’ under greater pressure by losing voluntary sector

‘good will’

• Failure by NRW to meet the requirements of the current fisheries challenge

and establish a realistic mechanism for adaptive change and progression for fisheries.

• Failure to recognise the existing socio-economic; socio-political and socio-

cultural vulnerabilities of today’s communities and the need to consider all well-being goals as part of the ‘measures’ development process

• Reputational damage – inability to in-still requisite values to assist

communities manage climate change induced impacts

A Healthier Wales

• Loss of public access to riverine environments
• Loss of safe passage through diverse and remote environments
• Inability of community to connect with nature and make positive

lifestyle choices

• Loss of physical benefits associated with angling (method restrictions)
• Loss of physical benefits associated with angling (risk to community

clubs)

• Loss of positive benefits to mental well-being
• Negative physical health impacts due to loss of access to pursuit
• Negative mental health impacts due to loss of access to cultural values

and pursuit

• NRW consideration of value of game angling unsupportive – barrier to

promotion

• Negative health impacts due to relationship between socio-economic

impact of byelaw proposals

• Compound health impact upon communities of alienation from

‘measure’ development process – disempowerment of communities and associated repercussions

• Risk to ‘home waters’ from distal angling syndicates – loss of access to

local environments.

• A More Equal Wales
• Loss of access to local environments through loss of lease
• Loss of access to pursuit due to distorted values of amenity
• Loss of accessibility to community angling club
• Perverse paradox in that Wales is at risk of becoming equal

in its loss

• Impact upon participation driving cost of angling up
• Danger of angling becoming inaccessible – financial

constraint

• Wales at disadvantage to other UK countries
• A Wales of Cohesive communities
• Resilience and quality of natural environment inhibited by

system failures above.

• Disempowerment of community resource
• Establishment of a destructive precedent for continued

community based initiatives to maintain and enhance the environment for their own well-being

NRWs JUSTIFICATION OF BYELAW DELIVERY MECHANISM

WE COULD HAVE BEEN ‘THIS DRACONIAN’ BUT WE ARE BEING ‘LESS DRACONIAN’ THUS OUR APPROACH HAS BEEN ADAPTED AND IMPROVES WELL-BEING THE APPROACH ILLICITS ILL-BEING. MULTIPLE GAINS AND WELL-BEING GOALS MUST BE ACHIEVED THROUGH DUE DILLIGENCE THE EVIDENCE DOES NOT JUSTIFY THIS ACTION AN OPTIMAL DELIVERY MECHANISM HAS NOT BEEN EXPLORED ‘Where we have been lead’ ‘Where we should be’

NRW

WEAKENED STOCK ASSESSMENT PROCESS Draconian Management Response Adoption of high risk precautionary principle Failure to apply well-being considerations

FAILURE TO DELIVER OUTCOME FOCUSSED DELIVERY MECHANISM FOR FISHERIES/WELL-BEING IMPROVEMENT

Deprioritised Well-being Considerations

HOW WELL- BEING CONSIDERATIONS HAVE BEEN DEPRIORITISED

UNDERLYING FAILURE TO EMBED WELL-BEING CONSIDERATIONS IN THE PROCESS

We must find ‘win win’ scenarios for well-being as promoted by the principles of the Well-being of Future Generations (Wales) Act 2015. The Environment Agency in England are not applying mandatory rules acknowledging the need to in still positive behaviours through empowerment.

END OF DRAFT PRESENTATION DOC