Loch Lomond Catchment Management Plan Consultation Report 
- December 2001

The views of the public are being sought by the Loch Lomond Catchment Management Plan (CMP) Steering Group on draft proposals for maintaining and improving the water quality of Loch Lomond and its tributaries. The Loch Lomond catchment sustains agriculture, forestry, recreation and development and is, consequently, subject to a range of pressures that can have an adverse impact on the aquatic environment. The Loch Lomond CMP has brought together representatives of the general public, statutory agencies, research institutions and interest groups to address these pressures and the Consultation Report is the opportunity for all those with a stake or interest in Loch Lomond to comment. The development of the Plan is particularly important as the area will be part of Scotland’s first National Park.

See the Loch Lomond Catchment Management Plan Consultation document at the SEPA website.

Response of The Scottish Federation for Coarse Angling - January 2002

Background

1. The Scottish Federation for Coarse Angling (SFCA) is the governing body for the sport of coarse angling in Scotland. 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. Our 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.

2. Coarse angling has been pursued in Scotland for many generations, but we have only recently developed formal structures which enable us to engage with national and local political and management bodies. SFCA is now consulted via SportScotland on proposals for SSSIs and SACs, and has been actively involved in the First Minister’s Consultative Committee on Protection Orders, the Secretary of State’s 1997/98 Review of Protection Orders, the Access Forum for Inland Waterways, and the Angling for Change (AfC) initiative. Representatives of SFCA or member clubs sit on the Boards of several Scientific Fisheries Trusts, including the Loch Lomond Fisheries Trust.

SFCA Objectives and Priorities

3. It may be helpful to start by giving a brief overview of the matters of general concern to us throughout Scotland. Present legislation and fishery management practices in Scotland do not serve the interests of coarse angling and coarse fish species well. Our long term aim is simply to see a level playing field. 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

4. The goals described above are partly dependent on statutory underpinning, and we have made extensive representations to that effect in the course of recent national consultation exercises conducted by SEERAD and SNH. However, they depend equally - perhaps more so - on sympathetic management and constructive dialogue at the level of individual fisheries and catchments. We therefore welcome the opportunity to contribute to the current consultation, and offer our unreserved support for the general principle of partnership and participation which it seeks to promote. This is most definitely the way forward, both in the Lomond catchment and elsewhere in Scotland.

5. The catchment contains several particularly valuable coarse fisheries. Most important of these is Loch Lomond itself, which is arguably one of the three or four best pike fisheries in the British Isles. Other coarse species are pursued in the Loch, in the lower reaches of the Endrick, in the upper part of the Leven, and in several smaller lochs, ponds and quarries in the vicinity. SFCA clubs and individual members make extensive use of these facilities, and one SFCA club, the Scottish Carp Group, leases and manages a fishery (Culcreuch Castle Loch, Fintry) within the catchment.

6. Coarse fishing is grossly under-exploited in Scotland. Our pike fisheries in particular offer substantial potential for the development of coarse angling tourism. The opportunity to catch hard-fighting wild pike in spectacularly attractive surroundings is a potent attraction for many anglers, and Loch Lomond is already internationally renowned in that capacity. While some of the popular areas of the loch are quite heavily fished at present, there are other productive areas that either get little attention or are subject to access restrictions. There is also much untapped potential in other waters in the catchment, and elsewhere in the Trossachs. The development of pike angling, both for local anglers and as a tourism resource, requires a combination of better access, better publicity, sustainable management, and the freedom to use all legitimate coarse angling methods.

7. We were disappointed to find that the consultation group on fish and fisheries mentioned at 1.4 of the Report was established without inviting SFCA or any of our member clubs to take part. It seems to us incongruous that observations on matters such as the management of coarse fisheries found their way into the Report without any dialogue with those who participate in coarse angling in the catchment. Had someone thought fit to consult coarse angling interests when compiling the relevant items, we could readily have contributed to a more comprehensive picture. As it stands, some aspects of the Report seem to lack an appreciation of issues related to coarse fish and coarse angling. Hopefully the present consultation will provide an opportunity for such omissions to be rectified.

8. Notwithstanding the matters raised in the paragraph above, our perception of the content of the Report is extremely positive. There is nothing in the draft management objectives with which we would take issue in principle. Indeed they contain much which will be beneficial from a coarse angling perspective and we are happy to offer our support for the general direction in which the process is moving, and for the broad thrust of the Plan.

9. In the main, the same can be said for the individual management proposals in Section 3 of the Report. We have comments and concerns with regard to some of these items, and list these in the Appendix. We hope that these can be taken in the constructive spirit in which they are put forward, and that they will serve to inform the development of a more rounded and effective final product. For the future, we would urge that SFCA should be given the chance to participate in, or at least have dialogue with, any group which may play a part in subsequently developing appropriate aspects of the Plan.

10. We would introduce only one downbeat note. There are two vital questions which the otherwise comprehensive Report signally fails to address: what is all this going to cost and, most important, who is going to pay?

Appendix - Comments on Management Proposals

• ISSUE 12 - Management of angling activities

• ISSUE 14 - Legal protection of fish stocks

• ISSUE 15 - Introduction of non-native fish species

• ISSUE 16 - Conservation of lamprey, salmon, powan and other native fish populations