I could write to the Minister in charge of the Landscapes, Nature and Forestry of the Welsh Government now to complain about the wrecking of an agreement that has worked faultlessly for 8 years with no complaints from either party to the other, but I'd expect to be asked to wait for NRW to make a concrete response (not a PDCMG-style one I hope). So I think we should give NRW a bit of time to present their ideas now the notice period for the previous agreement is over and their solicitor has set them up to deliver alternative ideas.
As to "licences", this is fairly normal practice to allow something to be done on someone else's private land. We are not talking about licences in the sense of individual cavers being licensed to cave like they are to drive a car. The PDCMG has a licence to cover Ogof Draenen access over Pwll Du Conservation Ltd's private land. What I had negotiated in 2014-15 for mine explorer access was in the form of a Property Deed which is much more serious legal instrument for land access over which NRW and WG perhaps later had remorse about signing.
The problem I have is when the sites we are interested in are on publicly accessible land where members of the public have access rights for recreation. I know the Forestry Byelaws prevent unpermitted mine access so that underground explorers are not treated as equals with walkers, runners , cyclists and equestrians (unless they take their horse down a mine) but that is a fault in this day and age with those byelaws and those should be reformed rather than circumvented using Deeds or licences or whatever legal instrument.
Folks, we have the same problem with caving on CROW Access Land too: walkers can do things we can't, allegedly, and we had the opportunity last year to put WG/NRW into the High Court to argue their case in front of a judge, i.e. that caving isn't an open air recreation and so it should be treated differently in law from similar non-competitive outdoors pursuits. Whatever the chance of us having a success then, we had some chance of success, and you-know-who just gave up after spending a load of money and allowed the other side to walk out instead of having to win their case in open court. This has served to embolden NRW and to make things more difficult for us. If NRW thinks bat groups are more likely to start a judicial review case and remain more resolute than cavers have been, then no prizes for guessing whose music NRW will dance to.
