Loch Lomond Catchment Management Plan Consultation Report 
- December 2001

Response of The Scottish Federation for Coarse Angling - February 2002

ISSUE 12 - Management of angling activities

MANAGEMENT OBJECTIVE

Promote the scientific management of fish stocks and angling activities, including the planned restoration of degraded habitats to benefit native fish populations.

A12.1 We fully support this proposal and have for some time been playing an active part in the embryonic Loch Lomond Fisheries Trust. Representatives of coarse angling interests sit on the Board of the Trust.

A12.2 We agree in principle with this proposal, but would offer a note of caution, both as to the benefits which may flow from a Protection Order and the practicality of obtaining one. It must be said that Protection Orders under the 1976 Act have a number of serious flaws, such as:-

• There is no mandatory provision for establishing a Liaison Committee;
• Liaison Committees do not have the power to require comprehensive monitoring or the systematic gathering of data on the operation of the PO;
• There is no adequate mechanism for funding the activities of Liaison Committees;
• The system makes no link between granting an Order and effective fishery management;
• Levels of access are not linked to the capacity of fish populations to sustain exploitation;
• The system contains little or no power of sanction to induce reluctant proprietors to comply with the letter - never mind the spirit - of the legislation..

It would be unduly generous to describe coarse anglers’ experiences of the Protection Order system elsewhere in Scotland as chequered. In many cases POs have quite clearly been used to reduce access to fishing. With the honourable exception of the Loch Awe and Associated Waters Protection Order, none of the current POs takes significant steps to meet the needs of coarse anglers or coarse species. Many of them leave us with almost insuperable restrictions on methods, seasons, or permit availability. Some are also heavily biased against visiting anglers.

Not surprisingly, therefore, it may be difficult to generate enthusiasm among the coarse angling public - and perhaps many game anglers - for the introduction of a Protection Order in the Loch Lomond catchment. It can only win coarse anglers’ support if it embodies and indeed exceeds best current practice in other Protection Order areas. To do that it must be seen to be established and operated according to the most positive interpretation of the spirit of the legislation.

We are already in dialogue with LLAIA on this and related issues. In addition, it is understood that approaches have been made to riparian owners on behalf of the National Park with a view to the Park Authority taking on the freshwater fishing rights and presumably issuing permits for trout and coarse angling accordingly. The position and involvement of the Park Authority in this matter needs to be clarified before any further action to obtain a PO can be contemplated.

Whoever takes the lead, there will be major problems associated with the practicality of gaining and enforcing a PO in the catchment, especially with regard to the Loch itself. Firstly, it will be difficult both to obtain and to demonstrate "additional" access to angling, which would be a prerequisite of the granting of an Order. Secondly, there is the matter of "exclusion zones" where riparian owners opt out of the provisions of the Protection Order and make their own arrangements with those who wish to fish on their land, or launch boats from it. Loch Lomond is fished by boat anglers to a greater extent than any other significant coarse fishery in Scotland, and thanks to the widespread watersport interests on the Loch, also has a plethora of launch facilities. If even one such launch site fell within an "exclusion zone", enforcing the Protection Order in respect of the very substantial number of boat anglers present would be at best laborious, and at worst impossible.

A12.3  This appears to us to be a matter in which the LLFT should also be involved. In our opinion it may be appropriate for the Trust to be offered lead responsibility for this project.

A12.4  As above, this should involve or be conducted by LLFT. Indeed a closely related project is already planned in the Trust’s provisional work plan. The difficulty of obtaining reliable data on catches and angling effort should not be underestimated, particularly in the absence of a current Protection Order. That said, pike anglers in Loch Lomond and Loch Awe have in the past contributed to valuable studies of pike movements and populations through tagging programmes. We would be prepared to consider participating in similar exercises in future if this was appropriate.

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

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