SFCA OBSERVATIONS ON FUNDING FOR FISHERIES MANAGEMENT

Environmental scientists and fisheries experts generally agree that a great deal more money needs to be spent on the management of freshwater fisheries in Scotland to ensure they are sustainable in the long term. No-one has a comprehensive picture of what stocks or even what species most "wild" or "natural" waters contain, far less the growth and reproduction rates they achieve or how they are affected by angling pressures or factors such as acidification or nutrient run-off. Over the last few years, Fisheries Trusts have been formed in various parts of Scotland with the aim, among other things, of carrying out this kind of work. The Trusts nominally cover a large part of Scotland, but with their present resources they can service only a fraction of the waters in their territories.

Much of the Trusts’ funding comes from game fishing interests, especially the Salmon Fishery Boards, and most of their work is concerned with supporting salmonid fisheries. But coarse angling can also benefit. In the past, pike and other species have often been netted out of waters because club officials or proprietors thought they were eating all the trout, or some such nonsense. Most of these people just wanted to improve their fisheries. They killed coarse fish because their members or customers demanded action; and stocking or culling were the only kinds of management they knew. Better-informed fishery managers are increasingly turning to other strategies like improving spawning habitats or eliminating sources of low-level pollution, which can often bring them much greater benefits and divert them from ill-judged and pointless barbarities against coarse species.

A lot more money would be needed if comprehensive and effective information collection and management advice – whether from the Trusts or any other source – is to be available for all fisheries and all species of fish throughout Scotland. Few would deny this would be desirable, but it can only happen if someone pays for it. Who should that be? Scotland’s fisheries represent a major part of our natural heritage. They are also a social amenity and, as the recent Scottish Executive survey has shown, an economic asset that brings income and employment to some of the less prosperous areas of the country. It’s therefore reasonable that a substantial proportion of any investment should come from public funds. But anglers would benefit from this directly in the long term, so it is equally reasonable that we should make some contribution.

There is another more fundamental reason why anglers should contribute: to buy our place at the decision-making table. In the unlikely event that the Executive was to come up with all the money needed, anglers would not be the only interest group wanting a share. If we were active contributors with a stake in that funding, we would have an undeniable claim to a role in dividing up the cake.

The angling and fisheries community will not be universally attracted to the idea of making a contribution. There is little or no tradition of anglers paying anything at all to fish for freshwater species in "wild" or "natural" fisheries in Scotland. And where people do pay something by way of permits or club fees they expect it to fund the kind of management that has a direct and tangible effect, such as stocking, hatcheries, access, or anti-poaching measures. Many of the management activities that might be desirable for the well being of natural freshwater fisheries have less visible benefits, and some are unlikely to have an immediate impact on the quality of sport. In any event, angling clubs that have put time and money into their own fisheries over many years may reject outside involvement, seeing it as interference. They may also take the view that any contribution to the funding of natural fisheries should come exclusively from those who own or use them. In addition, any comprehensive system for collecting money would inevitably have to be channelled through some form of regional or national agency. This will create a gap in the minds of anglers between what is paid and what it is used for, and an almost unavoidable perception that a substantial proportion of their money is simply supporting the administrative cost of collecting it.

Assuming for the moment that more money does require to be raised for fisheries management, and that anglers are to make a contribution, the next question is how should that contribution be collected. There are five broad options, not all of which are mutually exclusive:-

• Voluntary donations;
• Direct levies on the owners of fishing rights;
• Levies on the sale of fishing permits;
• Area permits;
• Rod licences.

Fisheries trusts currently get a significant part of their revenue from voluntary donations, some of them from anglers or angling clubs. Trusts have achieved a lot on this basis, but it’s commonly agreed that the money they get does not fund all they want to do; that a disproportionate amount of their time has to be spent fund-raising; and that the uncertain flow of income makes it difficult to plan ahead. It could be claimed that the voluntary nature of donations has a positive impact by creating incentives to deliver what the funders want. However, this can be a mixed benefit – it may concentrate management on activities that serve the interests of the largest donors at the expense of those who have legitimate need of resources but cannot contribute as much. There is every reason for bodies such as fisheries trusts to continue to encourage voluntary donations as one of several sources of support, but it is difficult to see this as a credible way of funding an all-Scotland system.

Statutory levies on proprietors have long been the means of funding Salmon Fishery Boards. These and other management costs can be taken into account when setting permit charges, and thus passed on to anglers. However, migratory fisheries have certain characteristics that lend themselves to this approach, while freshwater fisheries do not. Any levy would require all the relevant proprietors to be identified, their fisheries evaluated to assess fair contributions, and machinery put in place to collect the revenue concerned. The cost of establishing and maintaining these arrangements would be astronomical. Given that freshwater fishery rights are closely tied to land ownership, a fisheries levy would also effectively be a tax on land, which would meet strong political opposition. For freshwater fisheries, this option is simply not viable.

There is an initial attraction to permit levies: the anglers who fish most (and therefore benefit most) would pay most. And they are potentially transparent – the money raised from a particular branch of angling or a specific fishery is readily identifiable. This approach can work where there is general support for the concept, and some quite successful examples already exist in Scotland. For example, almost all the money collected by the Loch Awe Angling Improvement Association goes to support the Argyll Fisheries Trust, and on a smaller scale the Tay & Earn Liaison Committee is funded by a voluntary levy on permits sold for those waters. However, devising a fair and workable system for the whole country would pose immense practical problems. For example, it would need to accommodate both conventional permits and club membership fees that give access to fishing but also fund other club activities that would not be subject to the levy. And as with levies on fishery proprietors, there would be enormous costs and problems identifying all the relevant fisheries and collecting the revenue concerned. There is also a very high risk of avoidance where the person or body running the fishery isn’t fully on board – particularly because some proprietors may prefer that their income from fishing permits isn’t known to the authorities in case Inland Revenue gets to hear of it. In addition, intense political opposition could be expected from commercial fishery owners, who would quite reasonably see it as a tax on their business. This would be all the more unacceptable to them because it would be used to subsidise "wild" fisheries in direct competition with their own interests. Again, it is impossible to see this as a tenable basis for a statutory scheme.

In Europe (eg France & Spain) and North America, area permits are commonplace. A modest annual fee gives access to most of the fisheries in a state or region. Private and commercial fisheries still exist to a greater or lesser extent, but they are in the minority. In Scotland we have a handful of small-scale examples where a single permit allows fishing on a geographic cluster of fisheries owned by several proprietors, notably the Assynt hill lochs. There may be scope to develop similar models elsewhere, particularly in respect of fisheries owned by public bodies or the Crown. However, the fact that the great majority of fisheries are already privately owned and the strength of the link between riparian land and fishery ownership militate against area permits becoming the dominant – let alone universal – mode of raising revenue for fisheries management in Scotland.

There is no tradition of rod licences in Scotland, but these are the principal means of raising funds from anglers in England & Wales. The system there is universal and attracts substantial levels of compliance. In 03/04 EA is reported to have spent about £28m on fisheries management, of which around £18m gross was raised through rod licence sales. Collection and compliance costs are understood to have been approximately £4m. The rod licence provisions currently applicable south of the border are fundamentally flawed in many ways, and are not well loved by anglers. But that does not mean the principle should be rejected out of hand. Adopting rod licences would not require the wholesale importation of the E&W model. In particular, it is neither necessary nor desirable for the money raised by rod licences to be channelled through a monolithic national agency like the EA. The concept of rod licences – which could usefully be re-labelled to avoid emotive connections with the E&W model – merely implies that anglers have to pay some form of statutory charge before they can fish lawfully with rod and line in freshwater. The key factor is that the charge is separate from, and additional to, any permit fee levied for consent to fish a particular water, and applies even where the angler himself or herself is the owner of the fishing rights.

However desirable it might be to have a new revenue stream to support fisheries management, we must also recognise that it there is a serious risk that it would become a substitute for, rather than a supplement to, existing sources of funding. At present there is substantial private expenditure on some fisheries, and considerable effort and ingenuity has gone into developing and funding initiatives such as the scientific fisheries trusts. It can be argued that this investment has emerged in response to the absence of a satisfactory national system of funding for fisheries management; but it would be unfortunate if a national system led to a decline in private expenditure.

In addition there is already an enormous input of voluntary manpower on the part of angling clubs and syndicates to run the fisheries they manage. Any system to collect and disburse revenue for fisheries management similarly runs the risk that angling clubs may step back and seek to have this resource provided by others. This may be especially true where clubs find themselves expected to carry out management activities that they do not necessarily perceive to be in accord with their own immediate priorities.

SFCA believes that there should be substantial investment in all-Scotland, all-species provision for data collection and scientific advice to inform fisheries management, and that anglers should contribute directly to supporting this facility. Ideally, we would like to see the present level of voluntary donations, voluntary permit levies and area permit arrangements maintained or expanded; but we see no viable alternative to collecting the bulk of the anglers’ contribution via an acceptable form of rod licence system underpinned by appropriate structures and safeguards.

Even if anglers can be persuaded that more money should be invested in fisheries management, a lot of effort will still be required to convince them that it is necessary to contribute a share of it. Inducing them to pay up if and when a scheme is put in place will be even more challenging. We should not underestimate how difficult it will be to gain acceptance of the benefits and shift people’s thinking towards a long-term perspective.

A great deal will depend on the structure of the system put in place. To be acceptable, any rod licence scheme must possess the following characteristics, which are presented in alphabetical rather than priority order:-

• Accountability – anglers must have a pre-eminent place in the decisions on the disbursement of the funds concerned. This must not be restricted to arms-length advisory committees as in the EA arrangements, or rely on representations submitted in response to decisions already made.

• Conservation – the system must under no circumstances support or promote management measures which are beneficial to one species to the detriment of another, regardless of their relative sporting or commercial value.

• Effectiveness – the system must actually yield improvements to the quality of anglers’ sport.

• Efficiency – the costs of collection, administration and enforcement must be maintained at the lowest possible level.

• Flexibility – the decision-making machinery must be capable of responding to short-term or localised needs as they arise, without requiring ponderous and time-consuming deliberations or weeks or months of preparatory work and consultation.

• Proportionality – The contributions raised from each branch of angling and each broad locality must be reflected to a reasonable degree in the distribution of expenditure to benefit them.

• Self-containment – all the revenue raised from anglers must be used to benefit fish and fisheries; not to support wider objectives – however laudable – by way of environmental protection.

• Subsidiarity – decisions must as far as possible be taken at the lowest practicable point in the structure. This must go down at the very least to catchment level.

• Transparency – anglers must be able to see what money is raised and what is being done with it.

• Universality – the system must provide funds to support management and data collection for all parts of the country and for all species, regardless of their sporting or commercial value.

SFCA [August 2004]