SFCA POLICY ON FISH MOVEMENTS AND INTRODUCTIONS

There is presently little or no regulation of the movement or introduction of fish in Scotland. This lack of control is widely believed by environmental scientists and fishery managers to leave Scotland’s fisheries and fish populations vulnerable to a number of significant risks:-

• the introduction into the wild of prolific and/or destructive species from similar environments elsewhere – whether from another continent or just another catchment - can harm established populations through competition, predation or habitat degradation;

• disease and parasites can be introduced to established populations by poor quality stock fish, or by fish obtained – formally or informally - from sources without health checking;

• the movement of breeding stock between catchments can dilute or eliminate unique and sometimes valuable genetic characteristics of local populations.

In the light of the above, SFCA supports the principle that movements and introductions of all aquatic species should be subject to regulation. In addition, we support the creation of statutory measures to require health certification of fish farms and hatcheries and permit stocking only from demonstrably safe sources. If there are to be such controls, it is self-evident that compliance must be assured through effective monitoring and enforcement measures, and so we also support the establishment of appropriate machinery to achieve these goals.

We will only be able to extend our support to specific regulatory proposals if we are satisfied that they do not have a disproportionate or detrimental effect on coarse fish species or the future development of coarse angling. Coarse fish are a legitimate component of Scotland’s established wildlife and a valuable sporting resource. As well as providing welcome and valuable diversity in angling opportunities they enrich Scotland’s comparatively impoverished native freshwater fish fauna by occupying ecological niches that are largely separate from those taken up by other species. The presence of coarse fish in Scotland is not intrinsically more or less desirable than any other species. Any new Regulations must therefore fulfil certain criteria:-

• They must not purely restrict movements and introductions by anglers or for the purpose of stocking fisheries. They must include effective provisions for control over the two principle sources through which most unplanned movements and introductions presently take place; namely inefficient containment practices in the aquaculture industry and irresponsible discarding of unwanted specimens into open waters by ornamental fishkeepers.

• They must not act as a de facto ban on the stocking or introduction of coarse fish species in Scotland. There must be scope to progress from the status quo by responsible restocking of existing fisheries and the introduction of coarse fish to waters where they will be the only species present, or can reasonably be expected to co-exist with other inhabitants.

• The issue for control must not be whether the species concerned is "native" to Scotland, but what impact its introduction is likely to have on other occupants of the water or catchment concerned. We reject the proposition that some fish species should be regarded as "native" everywhere else in mainland GB but not in Scotland. The border between Scotland and England is a political artefact, not a natural environmental boundary. It is irrational for a fish to be considered "natural" on one side of an administrative border, and yet be regarded as posing a threat to the environment in another stretch of the same river a hundred yards away. The only rational units against which to consider the question of "nativeness" are either the whole landmass or the specific catchment.

• Decisions on whether or not to permit particular movements and introductions must be based on a practical, pragmatic, scientifically-informed risk assessment of the potential impact on the other occupants, if any, of that environment, and must also take account of the amenity value of the introduction concerned.

• Evidence that a species has long been established in the same water, or similar waters nearby, without apparent detriment to the other inhabitants must be taken as a persuasive indication that new introductions to that water on a suitable scale are unlikely to have adverse effects.

• Where the risk to the aquatic environment concerned of any harmful impact from a particular movement or introduction is small - and in some cases it will be astronomically remote - the emphasis must be on identifying effective containment measures rather than prohibition.

• There are no commercial fish farms supplying coarse species in Scotland. The legislation must therefore permit the acquisition of stock fish from appropriate sources in England & Wales, underpinned by adequate provisions for assuring the health status of the fish concerned.

• Fish populations can be threatened by proposals to drain lochs and reservoirs. Regrettably, it is also the case that the law currently allows proprietors to displace established populations of coarse fish to make way for other species. If fish in these circumstances cannot be removed to another suitable location, they will be killed. The new regulations must therefore provide for the possibility of fish being moved from sources other than hatcheries or fish farms, providing appropriate authority is obtained to stock them in the water to which they are relocated, and relevant health checks are undertaken.

It is our view that measures can be devised which meet these criteria while providing reasonable and effective controls to address the legitimate concerns of environmental scientists and fishery managers. We would suggest that the "Section 30" model presently applicable in England & Wales offers a suitable starting point for constructing such regulations.

Scottish Federation for Coarse Angling

July 2004