Dear Sirs

I am writing as an individual who has worked extensively in nature conservation in Wales for 21 years and who, for the past 16 years, has reported on the status of Welsh wildlife.  As such, I have worked alongside staff members from the Countryside Council for Wales and, for the past two years, Natural Resources Wales. Unfortunately, this consultation has not been widely publicised and has only now come to my attention therefore I have not been able to allocate as much time to it as I would have liked.

1.  Our rivers are currently in a sorry state. Fish stocks have declined rapidly since the 1980s and an industry that formerly attracted thousands of fishermen and millions of pounds to rural Wales is now a shadow of its former self.  Whilst the decline has accelerated over the past two years, NRW has cut the staff that are patrolling and helping to manage our rivers.  Further observations on the declines of our fish stocks are made by many other individuals and organisations on here.

2.  Glastir, the Welsh Assembly Government's agri-environment scheme, has never delivered for wildlife. Whilst its precursor, Tir Gofal, was by no means perfect, there were several examples where it did deliver for key species.  Glastir should be delivering curlew, skylarks, yellowhammer and hay meadows to the wider countryside. It is not.  It is suffering from a lack of funding, a lack of focus, a lack of monitoring, a lack of adequately trained staff and a lack of support.  Glastir has proved disastrous for Wales' wildlife and should be scrapped in order to be replaced by an adequately-funded, biodiversity-led scheme.

3.  Wales' National Nature Reserves (NNRs) are the jewels in the natural history crown and include iconic locations such as Cwm Idwal and Skomer Island.  NRW has seen fit to cut the NNR budgets by up to 60%, resulting in inadequate management and monitoring.  This includes pulling funding for a long-running research project on breeding guillemots on Skomer.  It is hugely disappointing that an English university has had to step in to fill a void left by NRW.

4.  NRW prides itself on being an evidence-based organisation.  Some of its important decisions, however, appears to be based on scant evidence at best.. One prime example is the granting of licences to shoot goosanders and cormorants on Welsh rivers and lakes. The evidence presented by NRW makes no reference to the alleged damage the birds are causing nor the population of birds affected. As such, issuing such licences may well prove to be unlawful.

5.  The Greenland white-fronted goose is a migratory species of waterfowl that breeds in Greenland and winters in the UK and Ireland. Whilst the bulk of the population overwinters in Scotland and Ireland, one flock spends the winter months on and around the Dyfi estuary.  NRW and WAG have repeatedly refused to give full protection to this species making Wales the only country in the whole of the goose's range where it is offered no statutory protection.

6.  The £6 million Nature Fund was launched by WAG in response to the State of Nature in 2013. So many constraints of time and guidelines were put on this funding that it proved inaccessible to many conservation organisations, including several who had put forward projects involving priority habitats and species.  Approximately £1 million of this money was given to NRW for 3 Natural Resource Management Trial areas (Tawe, Rhondda and Dyfi).  The focus of the fund is on Natural Resource Management (whatever that means), not biodiversity, therefore it begs the question of how species and habitats are benefitting from this money and is the work adequately monitored?

7.  Staff morale within NRW is at a critically low level. A recent staff survey found that only 20% agreed with a statement that the organisation was well managed.  This figure was barely above 10% amongst some parts of the organisation, particularly departments dealing with nature conservation and biodiversity. 

8.  Whilst there have been significant budget cuts in the fields of nature conservation and biodiversity, the salaries paid to the Senior Executive Team have increased significantly, as has the number of members on this team.  Every one of the 11 members of the team now earns a minimum salary of £95,000 per year with several reportedly earning well in excess of £100,000.  At a time when significant cuts have been made elsewhere, this is clearly unacceptable. 

9. Of the 11 Senior Executive Team members, not one is a recognised and respected expert in the field of nature conservation. Indeed, since the sad loss of Morgan Parry, the input of biodiversity expertise at a higher management level has been consistently notable by its absence.

In summary, since its formation in April 2013, Natural Resources Wales has proved to nothing short of disastrous for wildlife in Wales.  It is consistently failing to meet its biodiversity targets and its hard-working conservation staff are hampered by a lack of clear and transparent leadership from senior management.  NRW is THE public body that was set up to protect and enhance Wales' wildlife and its landscapes.  Under its guidance, I genuinely fear for the future of our countryside.

Iolo Williams

Conservationist and broadcaster