**UPDATE: Response from Natural Resources Wales**
Open letter from Paul Knight demands explanations and undertakings
Professor Peter Matthews Ph.D., FRSC, FCIWEM, FIWO
Natural Resources Wales
29 Newport Road
Cardiff CF24 0TP
February 11th 2015
I am writing this as an open letter on behalf of our Welsh organisation, S&TA (Cymru), who have expressed deep concern over the recent work carried out in-stream at Llanrwst, Conwy, as part of a flood alleviation scheme.
During this work, the streambed was dug up for footings and then covered in pre-cast concrete sections, totally destroying important salmonid spawning habitat, particularly for sea trout, for whom these small streams are absolutely vital as spawning and juvenile areas. We also understand that the work was carried out during the spawning season and that sea trout redds had already been identified in the gravels that were subsequently taken out, despite inadequate attempts to build a temporary downstream barrier to migrating fish.
Whilst we appreciate that flood defence is a priority, there are surely more environmentally friendly ways in which to protect local properties without such wholesale destruction of fisheries habitat.
S&TA (Cymru) supported NRW’s decision to close down its hatcheries, but only on the understanding that habitat restoration would be a major priority in protecting salmonid fish stocks. The type of work carried out at Llanrwst flies in the face of NRW’s promise to take fisheries habitat restoration seriously, and is seen by our Welsh membership as something of ‘a kick in the teeth’.
We are not impressed either by claims that other habitat will be created in mitigation. If NRW is indeed serious about fisheries issues then the ‘mitigation habitat’ should be created anyway, regardless of whether this sort of destructive activity has taken place, otherwise the freshwater ecosystems necessary for salmonids and other aquatic species to thrive will never improve significantly. This stream is short in length and any loss of habitat is highly significant, especially to spawning sea trout.
Particularly concerning is that a former NRW Fisheries officer, Pierino Algieri, informs me that he refused permission for this work to be carried out, but that senior staff members within NRW ignored his advice, as did Conwy Council. We agree with Mr Algieri that undertaking this sort of destructive work may well be in breach of relevant fisheries legislation and are therefore in the process of consulting with our legal advisors over that issue.
Perhaps the most galling of all is that the excuse given for undertaking the work in the spawning season was that funding was only available within a tight timeframe, otherwise it would have been lost from the budget. We find this a staggering example of unacceptable bureaucracy, particularly as it involved such an environmentally damaging process. Surely in these days of limited resources, there has to be some way of committing funds to projects and holding them until such time as a proper plan is devised that coordinates flood defence with environmental protection? Work could then be scheduled for a time when fish have hatched and can, if necessary, be moved elsewhere until works are completed.
S&TA (Cymru), on behalf of all fisheries and environmental interests in Wales, would ask NRW:
- To let us know upon what basis Mr Algieri’s advice was over-ruled and what legal advice NRW took prior to undertaking the work at Llanwrst?
- To give written assurance that this type of activity is never allowed again and that proper planning and funding, within acceptable timeframes, will always be employed with all future in-stream works;
- To confirm that NRW takes fisheries protection and restoration of salmonid stocks seriously as our members in Wales see the destruction at Llanwrst as evidence of NRW’s lack of commitment to fisheries;
- To confirm that NRW will abide by its obligations to spend the funds saved from closing its hatcheries on habitat restoration projects targeted at improving salmonid fish populations in Welsh rivers and that a transparent audit of such spending will be made publicly available.
- To confirm that NRW will continue with a dedicated Fisheries Department with officers deployed on the ground. This issue has confirmed conclusively why such a department is necessary to protect fisheries from further degradation and to aid their restoration.
I look forward to your early response.
On behalf of: Richard Garner-Williams, Chairman S&TA (Cymru)