Salmon and sea trout plan of action for Wales 2020: areas for action

1. Evidence

Issue: understanding the status of stocks by delivery, with regular review, of cost-effective salmonid resource monitoring

As an evidence-based organisation, we must make sure our decisions and actions are underpinned by high quality evidence. We need to ensure that our methods of monitoring, analysis and interpretation are robust, whilst keeping up-to-date with the latest research. We work closely with other organisations to collect and analyse data and constantly keep our environmental evidence base under review.

We implement stock assessment methodology designed to support the management of salmon stocks. The methodology for England and Wales was produced by a working group consisting of Cefas, the EA and NRW and the annual outputs are reviewed by DEFRA and Welsh Government prior to international evidence reporting to ICES. We have further designed and now implemented a similar methodology for sea trout stocks.

Current commitments include work to assess stocks based on juvenile monitoring data and other potential fishery independent methods. These may be required in future should catch statistics become less reliable.

A full review of existing stock assessment methodology is a commitment required in the Ministerial Direction that introduced Salmon Action Plans in 1998 and is reiterated in the current NASCO Implementation Plan.

It is an ambition of NRW to further develop the fish counter network in Wales that is currently limited to the rivers Dee, Teifi and Taff. This will provide catch-independent evidence of stock size together with evidence on migration timing and its relationship to environmental conditions.

Current actions

Action Lead and partners Date Priority

1.1 Undertake annual salmon and sea trout stock assessments to determine need for stock protection and scope for relaxing measures

NRW Ongoing High
1.2 Continue the Dee Salmonid Stock Assessment index monitoring programme and the Teifi fish counter to inform assessments of salmon and sea trout stocks across Wales NRW Ongoing High
1.3 Continue to monitor juvenile spatial distribution and temporal change in all major rivers in Wales for multiple users NRW Ongoing High

Future requirements - committed

Action Lead and partners Date Priority
1.4 Consider new whole-catchment census approach to juvenile census NRW 2020 Medium
1.5 Consider future scope for fishery-independent stock assessments NRW, EA, CEFAS 2020 Medium
1.6 Review adult stock assessments - as committed in the NASCO Implementation Plan NRW 2020-2024 High
1.7 Maintain horizon scanning of new and emerging techniques to address evidence gaps and pressures that threaten stocks NRW Ongoing Medium

Future requirements - proposed

Action Lead and partners Date Priority
1.8 Maintain and seek opportunities to expand fish counter network to provide further appropriate index monitoring NRW 2020/21 High
1.9 Work with Welsh Government on a Fisheries Evidence Plan Welsh Government, NRW 2020/2021 Medium

2. Managing exploitation

Issue: Maximise spawning escapement by ensuring exploitation does not damage stock recovery prospects

Exploitation is the term used to refer to the killing of fish by a rod or net fishing method. This is less relevant today as catch-and-release fishing has become firmly established in the rod fishery and is now also required in net fisheries. However, the term continues to be used to describe fish killed where this is permitted, and the residual unintentional mortality of returned fish.

Decision structures supported by the stock assessment methodology for both species are used as evidence to support exploitation management decisions. Although there has been an understandable driver for tightening of exploitation measures, the same methodological approach would be used in future for relaxing controls.

Certain net fishing methods in Wales are regarded as culturally significant. The significance of this and policy in terms of preserving such methods, at times of depleted fish stocks, needs to be considered.

The socio-economic value of recreational rod fishing in Welsh rivers has recently been estimated at £20 million per annum (Gross Value-Added – a measure of household income) and to support more than 700 full-time jobs. This could be higher, and it is important that NRW considers optimising the benefits that could arise from the fisheries.

Current commitments

Action Lead and partners Dates Priority
2.1 Carry out annual reviews of adult stock assessments for salmon and for sea trout to determine need for future management interventions (tightening or relaxation of controls) NRW Ongoing High
2.2 Implement new fishing byelaws (the ‘all Wales’ rod and net fishing byelaws; the cross-border Dee and Wye byelaws; the Welsh Severn emergency byelaws), integrating these into the full suite of fishing byelaws in Wales NRW (EA in the English cross-border catchments) Ongoing High

Future requirements - committed

Action Lead and partners Dates Priority
2.3 Carry out preparatory liaison, followed by statutory consultation, into new rod fishing byelaws on the Severn in Wales NRW 2020 High
2.4 Carry out review of rod fishing byelaws for the Wye and Usk prior to their expiry in December 2021 NRW 2020 High
2.5 Carry out mid-term review of new rod and net fishing byelaws in Wales NRW, LFGs, Rivers Trusts 2025 High
2.6 Adopt risk-based approach to any resumption of catch-and-take fisheries NRW Ongoing High

Future requirements - proposed

Action Lead and partners Dates Priority
2.7 Review cultural significance and socio-economics of net and rod fisheries in Wales and recommend new policy NRW, Welsh Government 2020/2021 Medium

3. Protecting stocks through effective enforcement

Issue: Effective enforcement of all legislation for fisheries

Effective fisheries enforcement today is both ‘intelligence-led’ and risk-based. To best use our resources to deter, prevent and detect offending, we are guided by real-time incident reports to support our own intelligence. We therefore continue to rely partly on timely reports and information by members of the public.

NRW is developing new approaches to increase the reporting of incidents of significance to the fisheries resource, and to demonstrate the effectiveness of responses to incidents.

Current actions

Action Lead and partners Dates Priority

3.1 Respond effectively to prioritised pollution and fisheries incidents

NRW Ongoing High
3.2 Enforcement of all fisheries byelaws NRW Ongoing High

3.3 Implement risk-based enforcement to protect fish in vulnerable locations:

  • estuaries and coasts:
    • develop local work plans
    • engage with WG marine fisheries on joint approaches
  • in-river barriers and spawning sites:
    • review risks associated with locations across Wales
    • prioritise patrols at sensitive times of year and river conditions
NRW and Welsh Government for estuaries and coasts; NRW for in-rivers and spawning sites 2020 High

Future requirements - committed

Action Lead and partners Date Priority
3.4 Review of fisheries enforcement priorities and resources NRW 2020/21 High
3.5 Review risk associated with disturbance to spawning fish caused by recreational access NRW 2020/21 High
3.6 Review potential blocks to supply by the public of timely evidence on fisheries incidents NRW 2020/21 High

3.7 Develop new resources for collection of intelligence on illegal threats to fish stocks:

  • Develop and implement training of all NRW field staff for expansion of intelligence gathering
  • Share intelligence and conduct joint patrols with other enforcement agencies:
    • with the EA on shared cross-border rivers
    • with WG on estuarine and coastal waters
NRW 2020 High

Future requirements - proposed

Action Lead and partners Date Priority
3.8 Refine proposals for River Guardian initiative, identifying partners for catchment-based initiative NRW 2020/21 Medium
3.9 Explore development of a smartphone App for the reporting of fisheries incidents, including pollution incidents NRW 2020/2021 Medium


4. Tackling physical habitat constraints in the freshwater environment

Issue: sub-optimum freshwater habitats

The quality of freshwater habitats determines the performance of the ecosystems they support. The characteristics of water flow and quality, and the physical structure of the rivers in terms of connectivity barriers and riparian zone quality are therefore critical to the wellbeing of fish populations.

Good habitat for salmonid fish consists of:

  • natural hydromorphological condition, with networks of runs, riffles and pools
  • an absence of manmade constraints such as barriers to the free movement of fish and sediments
  • un-modified channels and un-damaged riparian zones
  • water quality and quantity unaffected by any impacts of man-made activities

Many factors, including impounding structures for purposes including water abstraction and stream-crossings that create barriers, and modification of banks and unsympathetic local land-use have cumulatively impacted upon good condition of streams over many years. This has damaged their performance as salmonid spawning and nursery areas. Today there are few rivers that have escaped damage caused by combinations of these factors.

The need for restoration of constraints to salmonid stocks in the freshwater environment has become well understood. Work has been underway in Wales by NRW, its predecessors and by Afonydd Cymru and the family of rivers trusts, for several years to restore good physical condition. Between us, over a hundred fish passes have been built ranging from large civil-engineered structures to smaller less-formal arrangements, and many barriers have been removed completely. This has improved connectivity for migrating fish enabling free movement of adults upstream and smolts downstream. Improved access or, in some cases, new access to upland stream areas provide greater quantities of habitat, sometimes in higher altitude areas where cooler stream water temperatures prevail. Tens of kilometres of river banks have been fenced to exclude trampling livestock and reduce the delivery of soils into rivers.

Some have questioned the benefits of stream habitat restoration. However, when there are clear physical constraints to the free migration of fish and to the optimum condition of streams used by salmonids for spawning and for production of parr and smolts, it is difficult to draw any conclusion other than habitat restoration is a relevant and important activity. This also delivers broader benefits for flora and fauna.

All parties agree that much remains to be done if we are to optimise river environments. Together we need to invest, and then maintain features such as fish passes and riparian zones, so that the maximum number of wild smolts may be sustained and migrate safely to sea.

However, repairing a century or more of inappropriate development cannot be achieved overnight.

NRW has commissioned Fisheries Habitat Restoration Plans for all important migratory salmonid rivers in Wales. These reports compile catchment-scale information on physical constraints to fish population status. We will complete these for 33 rivers (principal salmon rivers and further main sea trout rivers) by March 2021. These will then represent an evidence base for a ‘Forward Plan’ document that will explain how we propose to resolve physical habitat constraints in Wales.

We will seek future funding to prioritise and resolve known constraints and deliver solutions. When delivery is complete, then all known physical constraints to achieving Good Ecological Status, and to remove constraints on fish populations, will have been resolved.

Current actions

Action Lead and partners Dates Priority

4.1 Continue work on:

  • 10 catchment-based Fisheries Habitat Restoration Plans
  • 9 Water Framework Directive catchment plans
  • river restoration plan for the Cleddau SAC
NRW with Afonydd Cymru as contractor Ongoing, Fisheries Habitat Restoration Plans to be delivered by summer 2020; other plans ongoing High

4.2 Implement 2020/21 capital programme of work for delivery of work to resolve habitat constraints:

  • Reducing barriers to river connectivity to restore river functioning and fish migration (upstream and downstream):
    • construction of 5 technical fish passes, and design of future schemes
    • programme of 30 fish passage solutions
  • Restore and maintain effective riparian zone management in approximately 100km of stream to:
    • exclude livestock from rivers
    • intercept and reduce soil delivery to rivers
    • provide buffering from solar radiation (Keeping Rivers Cool)
  • Restore delivery of riparian tree carbon supply (leaf and other organic litter) to upland nutrient-poor streams.

NRW with river trusts, partners, Afonydd Cymru

Delivery of 2020/21 capital work programme High

4.3 Deliver prioritised Sustainable Fisheries Programme, following principles agreed with WG


Ongoing High

4.4 Devolve Alternative Mitigation budgets to Afonydd Cymru and rivers trusts to deliver resolution of agreed habitat constraints in the targeted river catchments

NRW and river trusts (North Wales, Dee and SE Wales)

Ongoing High

Future requirements - committed

Action Lead and partners Date Priority

4.5 Commission final Fisheries Habitat Restoration Plans, to complete coverage for Wales, setting out and quantifying:

  • Remaining connectivity challenges to be resolved through combination of fish passes and barrier removal
  • Riparian habitat pressures
NRW (AC as contractor) 2020/21 High
4.6 Compile and prioritise full inventory of habitat constraints in Wales NRW, WFF, LFGs, rivers trusts 2020/21 High
4.7 Continue development of strategic river restoration programme NRW 2020-21 High
4.8 Develop and publish 3-year delivery plan setting out delivery of prioritised solutions to physical habitat constraints in Wales and identifying funding and delivery requirements NRW 2021/22 High

4.9 Seek new Fish Passage Regulations, through collaborative work with DEFRA, to secure appropriate powers to require resolution of fish passage at barriers to migration

Welsh Government, NRW 2020/21 High

4.10 Delivery of £6.8 million LIFE partnership project on the River Dee catchment, delivering significant benefits for migratory fish through:

  • fish passes and barrier removals at 10 major sites
  • improved habitat connectivity
  • restoration of in-river habitats improvements to land management and forestry practices.

NRW, Dŵr Cymru/ Welsh Water, Snowdonia National Park, Environment Agency

2020-2024 High, with funding from NRW, Welsh Government and EU

Future requirements - proposed

Action Lead and partners Date Priority
4.11 Review the relative impact of pressures on river quality and therefore fish populations NRW 2021 Medium

4.12 NRW to be lead partner in a National Lottery Heritage Fund project ‘Back from the Brink’ that, subject to confirmation, would include actions to:

  • improve river habitats including resolution of habitat connectivity
  • inspire people to discover, value and act for Wales’ threatened species
NRW 2020 ongoing Medium

5. Safeguarding water quality and quantity

Issue: Providing optimum conditions of water quality and quantity through achieving the objectives of the Water Framework Directive

Natural conditions of water quality and quantity, together with un-modified physical habitats have the potential to support optimum ecological conditions. These are the conditions in which salmonid and other aquatic fauna developed and, in these conditions, we might expect optimum abundance and range of fish populations. However, the influence of society, including the need for water supplies and the management of land for matters such as agriculture and forestry means that today there are few natural habitats in our rivers.

The current condition of our watercourses and our ambitions for the future are set out in the package of work under the EU Water Framework Directive.

Natural Resources Wales is the Competent Authority for implementation of the Water Framework Directive (WFD) in Wales. We have responsibility for leading on and publishing the River Basin Management Plans (RBMPs) for the Western Wales and Dee River Basin Districts (RBDs) - working in partnership with a wide range of public, private and voluntary organisations (including water companies, local authorities, eNGOs, business & industry). The Environment Agency lead on publishing the Severn RBMP. We work closely with the Environment Agency and partners on the cross-border aspects of the Severn and the Dee River Basin Districts.

In each RBD, we have a Liaison Panel made up representatives of key sectors. This provides an open forum for co-deliverers to discuss and influence the development of the RBMPs and assist with implementation. RMBPs are produced and updated every six years. The updated plans are now published.

RBMPs are strategic plans which gives everyone concerned with the RBD a measure of certainty about the future of water management in that district. It includes objectives for each water body and a summary of the programme of measures necessary to reach those objectives.

Read the RBMPs for 2015-2021

Read the Severn RBMP on GOV.UK

The overall ambition of the WFD is to restore all surface waters, including transitional waters (estuaries) and groundwater to ‘Good Ecological Status’ (GES). This is the WFD default objective for all water bodies and is defined as representing only a slight variation from undisturbed conditions. The elements that make up ecological status include:

  • biological elements (consisting of measures for fish, macro-invertebrates, macrophytes and diatoms)
  • supporting elements (made up of hydromorphology, ammonia, pH, phosphates, dissolved oxygen and 18 pollutants including some heavy metals and pesticides)

Each of these elements contributes to the overall ecological status. The lowest common denominator rule (‘one-out, all-out) is applied to the elements, so the lowest scoring element denotes the overall status of the water body. For example, if a biological quality element was at moderate and other quality elements were at good, it would be concluded that the water body as a whole is at moderate status.

NRW and the EA design and implement investigations programmes to explore why any water body fails to achieve GES and to contribute to plans to address this.

Water quality

NRW and predecessor bodies have monitored, and continue to monitor, the quality of our rivers and carries out a range of consenting and permitting activities to ensure that ongoing and new activities should not harm the aquatic environment.

In addition to the range of water utility and industrial discharges, NRW regulates the agricultural sector. In each case it does so through consenting, permitting and licencing regimes developed to accommodate all requirements to protect water quality in all surface water, groundwater and transitional waters.

Agriculture and pollution incidents arising from some activities is currently a very high profile matter in many parts of Wales. This and matters related to forestry are considered in Action Table 5.

Across Wales, abandoned mines present significant sources of land contamination and water pollution and are the main reason why Welsh water bodies are unable to achieve 'GES' under the WFD. NRW has awarded a contract to the Coal Authority as part of our work to clean up metal-polluted rivers across Wales. Feasibility studies to address problems at priority metal mine sites are being undertaken in addition to other mine-related assessments. The contract also includes developing a long-term metal mine remediation programme for Wales.

Water quantity

The quantity of water in our streams and rivers and the maintenance of near-natural hydrological conditions is a key factor determining the wellbeing of our fish stocks and fisheries. This is balanced against societal requirements for supply of wholesome water for domestic and industrial consumption and the disposal of waste materials. Effective regulation of these regimes is important if natural resources are to be protected and sustained.

The routine 5-yearly water company price review process enables NRW to influence their investment plans and priorities. These can bring critical benefits to the water environment across Wales (‘Note on stakeholder engagement: identifying the pressures on stocks’, available from NRW).

Current actions

Action Lead and partners Dates Priority

5.1 Continue to implement work programmes delivering action on the Water Framework Directive

NRW Ongoing High

5.2 Reduce risks to water quality through effective permitting and regulation of all relevant discharges to land and water

NRW Ongoing High
5.3 Address impact of relict metal mines by implementing the Metal Mines Strategy for Wales to deliver remediation of prioritised legacy metal mines NRW, Welsh Government Ongoing High

5.4 Development and delivery of 2020 capital work programme for remediation

NRW, Welsh Government Ongoing High

Future requirements - committed

Action Lead and partners Date Priority

5.5 Development of 15-year programme of works, to include development of proposals for:

  • Dylife - the main source of metals in the Dyfi catchment, impacting over 35km of watercourse
  • Remediation at Frongoch-Wemyss to improve 32 km of watercourse
  • Mine water from the Cwmystwyth mine complex, impacting 33km of the Afon Ystwyth
  • Cwm Rheidol min, located in the Rheidol Valley with impacts of the mine water extending to the coast at Aberystwyth
  • Parys Mountain, one of the most polluting metal mines in the UK.
NRW, Welsh Government Development of project plan High
5.6 Continue to implement the Restoring Sustainable Abstraction Programme NRW Ongoing High
5.7 Implement review of time-limited abstraction licences NRW Ongoing High
5.8 Introduce regulation of previously exempt abstractions NRW Ongoing High
5.9 Secure environmental improvements through the water company price review process NRW, water utilities Ongoing High
5.10 Continue effective engagement with water utilities on water resource and NRW Ongoing High
5.11 Ensure permitting of hydropower schemes (including marine tidal energy) does not harm fish populations NRW Ongoing High
5.12 Work with water utilities to ensure delivery of future Asset Management Plans NRW, water utilities 2020-2025 High

6. Addressing land management, and associated risks to water quality

ISSUE: Sub-optimum freshwater habitats: poor land use results in damage to rivers

Catchment land use is a predominant factor influencing the quality of freshwaters. Poor and inappropriate land-use can result in the run-off and delivery of eroding soils into rivers together with surplus nutrients and chemicals that may have been applied to the land.

Increased agricultural intensification and the spreading of agricultural slurries has caused many pollution incidents and resulted in the mortality of large numbers of fish.

Past forestry management did not achieve the higher standards now specified in forestry standards and in the Forest Water Guidelines and has resulted in damage to the environment through rapid drainage and erosion. The guidelines include specification of tree species mixes, drainage and the protection of stream quality. Afforestation provides opportunity to retain water in the uplands for multiple benefits downstream including buffering of river temperatures and contributing to flood resilience.

Restoring and protecting upland peatlands offers the chance to store water preventing rapid run-off, with associated risk of stream erosion, and providing some resilience to increasing water temperature.

NRW delivers against all statutory requirements of the Environment Permitting Regulations – specifically as they affect land management issues of agriculture and forestry. Strong environmental protection is critical if river quality is to be restored and preserved.

Current actions

Action Lead and partners Dates Priority

6.1 Develop and implement improved agricultural regulation regime

Welsh Government, NRW Ongoing High
6.2 Work with farmers, their representatives and all other relevant partners to protect river environments, including the prevention of soil loss to rivers NRW, farmers & unions, Afonydd Cymru Ongoing High

6.3 Maintain contribution to Wales Land Management Forum and sub-group to influence land-use matters to significance to fish populations

NRW and Forum members Ongoing  

6.4 Continue existing programme of dairy farm inspections to improve routine management in order to eliminate risk to surface water quality

NRW, Welsh Government Ongoing  

6.5 Application of best-practice approach to forest management, as set out in the Glastir Woodland Restoration programme and adhering in full to the current Forest Water Guidelines

NRW, Welsh Government, private forestry Ongoing  

6.6 Contribute to WG Woodlands For Wales Strategy, including opportunity to create new woodlands

NRW, Welsh Government Ongoing  

6.7 Contribute to peatland protection and restoration

NRW Ongoing  

6.8 Progress the LIFE Welsh Raised Bog Project, restoring 4 square miles of raised bog (peatlands) within Special Areas of Conservation

NRW, Welsh Government, Snowdonia National Park 2019-2024 with funding from NRW, Welsh Government and EU High

7. Addressing predation on salmonids: fish-eating birds and seals

Issue: unsustainable depredation of depleted and vulnerable salmonid stocks by predatory birds

Predation on fish is a natural phenomenon that does not normally threaten stock sustainability. Population feedback mechanisms often compensate for losses through density-dependent regulation in which the remaining fish survive at higher rates. However migratory fish past the age of smoltification have no such compensatory mechanism and any loss due to predation then is a net loss to the population.

The extension in range of goosander southwards and the frequent movement inland by cormorants to feed both represent relatively recent increased pressures on fish populations, including those of migratory salmonids. This has led to growing concern. Wild birds are protected by law however there are systems in place for the licencing of control measures, including lethal controls, where certain criteria are met, including damage to fisheries. Both bird species are known to prey on a range of fish species, including salmonids, however there is some evidence that goosanders demonstrate a preference for salmonids.

Salmon and some other species (bullhead, lampreys) are species designated under annex 2 of the EU Habitats Directive. In their current poor status, there is concern that salmon cannot sustain ongoing predation by birds. Fish-eating birds feeding in our rivers on relatively abundant non-salmonids may encounter and predate some of the failing stocks of salmonids. Resolution of the growing conflict between legally protected birds predating legally protected fish species which are in a depleted state requires new policy. It is important that the current imbalance is addressed so that predation is within sustainable limits.

NRW commissioned an external expert group to consider matters relating to fish eating birds and the resulting paper and recommendations were approved by the NRW Board before submission to Welsh Government. This Group will be re-commissioned now to implement the recommendations for a full Policy review:

Scope of Review

To help deliver the policy framework as outlined above the scope of the WFEB Policy Group will develop 8 themes:

  1. Appraise the effectiveness, where practically possible, of non-lethal and lethal control of fish-eating birds in preventing serious damage to natural and stocked fisheries.
  2. Determine population estimates and trends for wintering cormorant and goosander at national and/or Area Statement scale and/or Important Salmonid Catchments.
  3. Determine how to interpret population estimates for salmon and sea trout and fish-eating birds at national and/or Area Statement scale.
  4. Determine whether a cormorant population-based model, similar to models adopted in England and Scotland, is required for Wales.
  5. Assess the need for a goosander population-based model for Wales.
  6. Assess the need for a regional (i.e. NRW Statement Areas) and/or catchment-based licensing approach in Wales.
  7. Develop a fit-for purpose NRW licensing policy.
  8. Develop a communication strategy (including practical advice and guidance) for fisheries and fishery managers, conservation organisations and general public.

A phased approach

A five-phase approach is recommended.

  1. Establish a Wales Fish Eating Birds Policy Group with the mandate to lead an evidence-led review to help develop new policy in relation to controlling the impact of predation (including the threat of serious damage to designated wild fish stocks) on all inland fisheries from cormorant and goosander.
  2. Evidence and data gathering.
  3. Analysis and assessment (including advice to NRW Board and Welsh Minister for Environment as whether evidence indicates public consultation is appropriate).
  4. Public consultation (if required based on outputs of Phase 3).
  5. Final reporting and policy recommendation to NRW Board and the Welsh Minister for Environment.


An indicative timetable for the work plan is provided below. Though, this is dependent on:

  • the date when the Wales Fish Eating Birds Policy Group is established and their agreed approach
  • the time taken to gather the evidence (i.e. survey data and population estimates
  • whether a public consultation is required

March 2020 (Phase 1)

  • Convene the 1st meeting of Wales Fish Eating Birds Policy Group (May 2020)
  • Agree Wales Fish Eating Birds Policy Group work programme (using work streams outlined in the NRW Fish Eating Birds Advisory Group Report to NRW Board) and Terms of Reference

April 2020 (Phase 2)

Convene the 2nd meeting of Wales Fish-eating Birds Policy Group (June 2020).

Draft contracts specifications and invitation to quote for the following contracts:

  • Appraisal of the effectiveness of lethal control and non-lethal measures
  • Winter surveys of goosander and cormorant on Important Salmonid Catchments in Wales
  • National population modelling and population estimates of goosander and cormorant
  • Appraisal of catchment approach to licensing
  • Appraisal of the current licensing process as administered by NRW

Development of a communication strategy to fisheries and others.

April 2021 (Phase 3)

  • Analysis and Assessment (including advice to NRW Board and Welsh Government as to whether evidence indicates public consultation is appropriate)

June 2021 (Phase 4)

  • 12-week Public Consultation (if necessary)

October 2021 (Phase 5)

  • Policy developed and reported to NRW Board and Welsh Government (November 2021)
  • Following agreement by NRW and Welsh Government an announcement of the outcome of the review will be anticipated December 2021


  • A report to NRW Board and Welsh Government will be produced by the Wales Fish Eating Birds Policy Group detailing draft Policy
  • Regular updates of the work of the Wales Fish Eating Birds Policy Group will be provided on a dedicated area of the NRW website, including links to papers, information etc. NRW will also give update reports to NRW Board, the Wales Fisheries Forum, Local Fisheries Groups etc.

Resource and roles

Appointment of an Independent Chair.

It is suggested representatives from the following organisations, and/or subject experts, would form the Wales Fish Eating Birds Policy Group:

  • NRW (likely to include: Senior Ornithologist; Principal Fisheries Advisor and Permitting Manager)
  • Welsh Government
  • Natural England (for cross-border rivers)
  • RSPB
  • BTO
  • Angling Trust
  • Salmon and Trout Conservation Cymru
  • Afonydd Cymru
  • Independent advisors on fish and fish-eating bird population dynamics
  • Social scientist communications expert
  • Game and Wildlife Conservation Trust

There are also concerns, largely geographically limited, of predation on adult salmonids by seals in some river estuaries (Cleddau, Dee, Teifi, Tywi and Wye) and at some barriers to river entry by adult salmonids (Tawe and Taff barrages).

Current actions

Action Lead and partners Dates Priority

7.1 Review position on predation on salmonids by fish-eating birds (FEBs) by:

  • Implementing in full the recommendations of the NRW external advisory group on FEBs leading to development of new policy on FEBs. This will concentrate on addressing the balance of conservation designations and legal protections
  • Review and improve current system of licencing for control of FEBs taking account of expert group recommendations
  • Review and confirm a ‘fit-for-purpose’ bird census methodology, and implement in prioritised rivers
  • Implement agreed initiatives to map sensitive locations where predation (FEBs and seals) occurs
NRW and a range of partners

2020-21 for policy and system of licencing.

2020 for bird census and mapping sensitive locations.


Future requirements - committed

Action Lead and partners Date Priority

7.2 Exchange best practice with public bodies in England and Scotland to benefit from emerging learning and practices regarding FEBs

NRW, EA, Marine Scotland 2020/21 Medium
7.3 Where there is evidence of unsustainable harm, deliver reduction in damaging impact of predation on depleted stocks of salmonids NRW, Rivers Trusts Subject to outcomes of 7.2 High

8. Understanding marine pressures

Issue: major reduction in marine survival of salmon

The marine life of salmon and sea trout begins when smolts leave the river to enter estuaries and, from there, coastal waters and the high seas.

During the 1960s and 1970s the locations of salmon marine feeding areas became well known and this led to high catches. Through national and international partnerships these came under increasing scrutiny and have now ended as NASCO negotiated, set and administered catch quotas. These are currently set at zero in the Faroe Islands and Greenland (the latter has a limited subsistence quota only).

Over the past few decades there has been a marked increase in the mortality of salmon at sea. This has been demonstrated at index monitoring rivers across Europe and beyond. Today, the rate of mortality is at the highest yet recorded. It is reasonable to assume that similar pressures, albeit presumably less severe, are impacting on Welsh sea trout.

However marine survival continues to fall. There have been suggestions that salmonids may feature as inadvertent bycatch in commercial marine fishing operations, however the evidence for or against this is currently almost non-existent. There have also been concerns about possible illegal catch, probably by-catch, of returning adult salmonids in coastal waters but again the evidence for this is weak.

Pronounced climate changes have occurred in the North Atlantic since the 1970s, and these are demonstrated by rapid loss of Arctic sea ice, large-scale ocean warming and also to changes in ocean acidity and salinity. The principle drivers for this appears to be marked changes in the North Atlantic Oscillation and the outcome for the marine environment is postulated to be changes in the distribution of productivity of the oceans. This appears to have led to changes in the distribution and abundance of some marine fish species, and the widely reported declines in successful seabird breeding. This is also postulated to be driving the changes in marine survival of salmonids and, potentially, the differential effect on grilse and multi-sea-winter salmon runs.

Climate change is expected to impact salmon in the Atlantic Ocean, although the precise mechanisms, scale and details remain poorly understood. There is no such evidence for sea trout, however it may be that marine survival of this species will also be impacted.

We must maintain our engagement to better understand all elements contributing to mortality at sea. Estimates from index rivers, including the Dee in North Wales, include all losses occurring between the release of tagged smolts close to the head-of-tide and the recapture of marked adults in subsequent years. As such, calculated mortality rates include factors such as predation in estuaries to pelagic fishery bycatch, from damage to feeding areas arising from climate warming and intensive fishing for prey species. It is important that we are able to understand the relative impacts of these so that we may prioritise actions, influencing appropriate bodies where we can in order to ameliorate them.

Current actions

Action Lead and partners Dates Priority

8.1 Maintain engagement with NASCO to:

  • ensure no resumption in marine harvest of salmon
  • commit to engage on future research initiatives eg climate effects, location of marine feeding areas and migration routes, bycatch of salmonids in commercial fisheries
  • commit to deliver all obligations in the 5-year Implementation Plan.

NRW and where applicable:

CEFAS, EA, Welsh Government, DEFRA

Ongoing High

8.2 Protect salmonid survival in estuaries and coastal waters to the 6-mile limit:

  • effective and precautionary permitting of developments, including ports, power stations and tidal energy proposals
NRW, Welsh Government Ongoing High

Future requirements - committed

Action Lead and partners Date Priority
8.3 Review potential marine exploitation of salmonids NRW, Welsh Government Ongoing Medium
8.4 Assess scope for by-catch and illegal fishing of salmonids at sea NRW, Welsh Government Ongoing Medium

8.5 Maintain role on Marine Climate Change Impacts Partnership, assessing the scope for environmental change to influence salmonids at sea.

NRW among multiple partners Ongoing Medium

Future requirements - proposed

Action Lead and partners Date Priority

8.6 Develop proposals to research salmonid behaviours in key coastal locations to facilitate permitting;

NRW, Welsh Government (other potential partners include EA, DEFRA) Ongoing High

8.7 Review outcomes of Cefas summary of marine stressors affecting salmonids, specifically including those within the 6 mile coastal zone, to assess significance for Wales

NRW Ongoing Medium

8.8 Develop proposals to assess potential impact of climate effects on estuarine migrations.

NRW 2020/21 Medium

9. Understanding new and emerging potential pressures

Issue: Need for vigilance to identify new pressures

It is important that NRW continues to consider new information on matters that may act in future to damage our fish populations. This is a difficult area to define and quantify, however the ‘horizon-scanning’ approach is recognised as vital if new pressures are to be considered, understood and, where necessary, acted upon.

By their nature it is not easy to define pressures and quantify what needs to be done. However, recent examples include the recognition of pyrethroid sheep dips and their damaging effect on stream ecology, oestrogenic mimics, and the potential impacts of other agricultural and forestry pesticides, herbicides and pharmaceutical products.

The best-known example of a future threat to stream ecology and to fish populations is that of climate change in the salmonid environment. Salmon and sea trout are vulnerable to the implications of climate change in both the freshwater and marine environments, and in the transitions between the two. This is because a warming climate has the potential to damage habitats for salmonids in freshwaters and at sea and to interfere with their reproductive biology. Modified flows may lead to difficulties in downstream seaward migration of smolts and in the re-entry to rivers of adult fish.

NRW has evidence of harm, implicating warm winter conditions, arising from the spawning season 2015/16 and this acts as a clear warning of future potential harm. We therefore need to understand the mechanisms that may harm salmonids, and measures that might be used to ameliorate these.

Current actions

Action Lead and partners Dates Priority

9.1 Continue research into potential adaptations to threats of climate change:

  • Ongoing support to existing PhD research on climate effects on salmonids in freshwaters
  • Mapping of future safe thermal habitats across Wales
Cardiff University, NRW 2018-2021 High, with funding from NRW and university studentship

9.2 Review and consider emerging factors that may damage salmonid populations, including impact of agricultural biocides and pharmaceuticals and their possible synergistic effects, and microplastics

NRW Ongoing Medium

9.3 Review and consider emerging threats from fish diseases and parasites, including review of studies on Gyrodactylus salaris and Saprolegnia and the NRW and WG contingency plans:

  • Commission trial of G.salaris survey.
NRW, Welsh Government 2020 Medium

9.4 Continue horizon-scanning work to identify new pressures and understand their potential significance

NRW Ongoing Medium

Future requirements - proposed

Action Lead and partners Date Priority

9.5 Review range of habitat adaptations to buffer streams from warming climate in summer and winter

NRW, Cardiff University 2021/22 High
9.6 Prioritise, design and implement appropriate riparian improvements and upland water retention initiatives in targeted water bodies NRW 2021/22 High


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