SFCA Response to Scottish Executive Green Paper "Scotland’s Freshwater Fish and Fisheries: Securing their Future"

The SFCA, after consultation with member clubs and individuals, has compiled a comprehensive response to the recently published Green Paper.  Thanks to all of you who contributed.  A full copy of the text is provided below.

To summarise our response -  the SFCA welcomes the acknowledgment of the need for reform, and shares many of the sentiments expressed in the Green Paper.  But despite many positive aspects, the Green Paper does too little to correct the bias against coarse angling which pervades existing legislation and the management activities which are carried out on most waters.  We see nothing concrete in it to address crucial issues affecting coarse angling and the positive measures it does put forward appear neither forceful nor immediate.  Whilst applauding the Paper’s broad intentions, we are therefore forced to conclude that its proposals fall short of what is needed.  

Please take some time to read through the detail of our response which comments on each part of the Green Paper and gives our opinions on what is missing and also what should be included.

The Pike Anglers Alliance for Scotland has also compiled a very professional response which we also recommend you read on the PAAS website.  See also our introduction to the subject of 18 September 2001.

1. The Scottish Federation for Coarse Angling (SFCA) is the governing body for the sport of coarse angling in Scotland. SFCA member clubs cover the full spectrum of coarse angling pursuits, ranging from "single species"groups whose interests focus on pike or carp, through to those who engage exclusively in competitive angling. Several SFCA clubs lease and manage their own fisheries or run them in partnership with, for example, local authorities.

2. SFCA promotes the coaching of young anglers, organises competitive coarse fishing in Scotland, manages the Scottish international match team, and represents coarse angling interests at national level. SFCA is consulted via SportScotland on proposals for SSSIs and SACs, and we have been actively involved in the First Minister’s Consultative Committee on Protection Orders, the Secretary of State’s 1997/98 Review of Protection Orders, and the Access Forum for Inland Waterways. We provided an extensive submission in response to last year’s consultation paper Protecting and Promoting Scotland’s Freshwater Fish and Fisheries.

3. SFCA has been a party to the Angling for Change (AfC) initiative since its inception, and contributed substantially to the comprehensive paper which AfC submitted in connection with Protecting and Promoting. We wish to reiterate our endorsement of that document, and in particular the AfC proposals for management structures and access provisions. We are presently working within AfC to develop a joint response to the current Green Paper.

4. The main text of this submission explains SFCA’s aspirations for new legislation and fishery management practices in Scotland, and offers general comments on the Green Paper. This is followed by two Appendices. Appendix 1 highlights two important issues which the Paper does not appear to address. Appendix 2 is structured around the specific actions and proposals contained in the Green paper, and puts forward our detailed comments on each.

SFCA OBJECTIVES AND PRIORITIES

5. Our prime objective for future legislation and management structures in Scotland is simply to create a level playing field for coarse angling and coarse fish species. In order to achieve this, measures must be put in place which ensure that :-

1. Current stocks of coarse species are protected against arbitrary culling or extermination;

2. Clubs and proprietors are able to stock coarse fish in appropriate waters where there is no reasonable prospect this will cause damage to existing stocks of other species;

3. Coarse anglers are granted responsible access to pursue their sport in waters which contain the species concerned;

4. Coarse anglers are permitted to make responsible use of all legitimate techniques;

5. Coarse angling interests have the opportunity to participate fully in the management of wild fisheries which contain coarse species.
   

GENERAL COMMENTS ON THE GREEN PAPER

6. We welcome the Executive’s acknowledgment of the need for reform, and share wholeheartedly the sentiments expressed in the Paper concerning issues such as:-

1. the need for effective measures to ensure "the appropriate conservation of all (our italics) fish species, regardless of their commercial or sporting interest" (Para 1);

2. the adoption of a scientific approach to fisheries management and the sustainable exploitation of fish as a sporting resource (Para 1);

3. the Executive’s desire to tackle the "question of how different freshwater species and habitats, and the industries and pursuits which depend on them, may effectively co-exist...." (Para 2);

4. the assertion that "threats to the status of salmon and other (our italics) freshwater stocks must be identified and minimised or, ideally, eliminated..." (Para 8);

5. the Executive’s intention to direct more resource in FRS towards "additional support to develop fisheries for potentially underexploited species, including grayling, charr and coarse fish." (Para 33);

6. the need to establish "better mechanisms to provide for the co-existence of salmonid and other freshwater fisheries in a manner which optimises the contribution of both..." (Para 35);

7. the development of a structure which will "recognise the diversity of Scotland’s fisheries; and accommodate the varying needs of both (our italics) users and proprietors in different types of fishery." (Para 35);

8. the long-overdue reform of the failed 1976 Act (para 50); and

9. the proposal to review the archaic legal definition that brigades legitimate coarse angling techniques along with poaching methods such as night lines (para 53).

7. Despite such positive aspirations, however, the Paper is fundamentally salmo-centric in tone. It does too little to correct the bias against coarse angling which pervades existing legislation and the management activities which are carried out on most waters. We see nothing concrete in it to address the crucial issues set out in our para 5 above, and only a few, tentative, steps towards achieving the laudable objectives described in the statements quoted in our para 6 above. The positive measures it does put forward appear neither forceful nor immediate, and there is an all-pervading sense of "jam tomorrow" rather than action now.

8. From SFCA’s perspective it is also disappointing to note that references in the Paper to coarse fish species and coarse fishing methods seem generally to be couched in dismissive or pejorative terms. We are especially concerned that a number of the proposals it contains could be unnecessarily detrimental to the sport of coarse angling. Whilst applauding the Paper’s broad intentions, we are therefore forced to conclude that its proposals fall short of what is needed.

9. We cannot therefore concur with certain specific measures the Paper proposes; but we subscribe wholeheartedly to many of the broad policies that it espouses and offer our active support for the process of translating those underlying principles into reality. We would welcome any opportunity to contribute to that process, both directly and through our continued participation in the Angling for Change initiative, and to have further dialogue on the matters of concern.

NEXT SECTION - APPENDIX 1  - OMMISSIONS

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