To the Environment and Sustainability Committee for its Consultation on Natural Resources Wales 2014/15

These are personal comments.

1. My experience

As a keen naturalist I am a member of several wildlife conservation organisations, and an active volunteer in various capacities. I have no direct involvement with NRW but take a keen interest in the environment and wildlife of Wales, and regularly meet others with similar interests including some NRW staff (whose expertise and commitment I value). On these occasions the formation of NRW and its performance are sometimes discussed. The following comments are my own, but I think that they may reflect the views of other concerned people.

2. The NRW and its remit

The merger has been difficult, diverting effort from the real purposes of the agency, with cuts in budgets and staff. On the NRW website and accompanying documents I find little reference to biodiversity, the ongoing declines of so much of our wildlife (clearly set out in The State of Nature 2013) and the ways in which NRW will attempt to reverse those declines and measure success or failure.

3. The NRW and its partners

As well as reducing its own capacity, NRW will be giving less support to its natural partners among the wildlife conservation charities. These employ dedicated staff and great numbers of loyal volunteers. NRW is making less money available and making access to funding more difficult and competitive. Charities with their strong popular and expert support carry out much of the work which NRW is required to deliver, and the weakening of this partnership threatens to result in real losses of activity.

4. The NRW and payments

NRW, like CCW for years previously, pays invoices and agreements with its partners weeks or months after they are due. These are not occasional lapses but happen so regularly as to appear the result of a deliberate policy. NRW’s performance in this matter does not meet required standards.

5. The NRW and licences

I survey and record birds on the River Usk. I am aware that NRW grants licences for the culling of fish-eating birds – Cormorants and Goosanders. It is my opinion, in line with ornithological bodies which have collected and examined the evidence, that these licences are not justified by good science. The birds do not cause serious damage to fish stocks. I understand that NRW is to commission further surveys. Until this has happened I think that culling should be suspended, and that licences should only be reinstated if there is conclusive proof that they are necessary.

6. NRW’s profile

When controversial developments are proposed, such as the Circuit of Wales and the M4 relief road around Newport, the visible defenders of the environment, wildlife and designated Sites are bodies such as the RSPB and the Wildlife Trusts. I would like to see NRW taking a stronger and more public stand in such matters, and in education about climate change and loss of biodiversity. These are crucial issues which are not sufficiently understood and appreciated by many people in Wales and its government.

Keith Noble