Loch Lomond Catchment Management Plan Consultation Report 
- December 2001

Response of The Scottish Federation for Coarse Angling - February 2002

ISSUE 15 - Introduction of non-native fish species

MANAGEMENT OBJECTIVE

Discourage further introductions of non-native fish species and research their impacts on native species.

A15.1 We suggest that it is doubtful whether a Protection Order could actually be framed to achieve this objective. The matter of what is and is not a "native" species is also a moot point. We discuss this in more detail with regard to Issue 16 below.

We believe that national legislation should control introductions and movements of all species. Decisions to introduce or move fish should be based on scientifically-informed risk assessment of the potential impact on the other occupants, if any, of that environment. Any controls, either on a national or a local level, must not however prevent responsible stocking and introductions of coarse fish in waters where they are the only species present, or can reasonably be expected to co-exist with other inhabitants. Coarse fish are not intrinsically more or less desirable than any other species, and properly managed coarse fish stocks enhance the range of sporting opportunities in appropriate waters.

In particular, there must be scope to maintain and enhance stocks in enclosed waters in the catchment. For example, Culcreuch House Loch has a long standing population of various coarse species which the Scottish Carp Group replenishes from time to time because of losses through age and predation. This presents no threat to the biodiversity of the catchment and must not be prevented by conservation controls designed to protect the quite different environment of "open" waters.

It is also important to stress that the risk presented by non-natives varies considerably between species. Not all could be expected to spread and multiply. Some- the unfortunate example of ruffe springs to mind - show signs of proliferation. But others such as carp do not reproduce well in Scotland, and few current populations of these are even self-sustaining.

A15.2 We share the desire to accomplish this objective, but under no circumstances can we accept that a ban on the use of live fish as bait is either a reasonable restriction to place on anglers or an effective means to achieve it. We cannot over-emphasise that livebaiting and translocations are two entirely separate issues.

It seems that some species have been introduced to the Lomond catchment over the last thirty or forty years. Discarded livebaits are one probable source of this, although there are others. But regardless of where they came from, these fish are where they are. Some are no doubt established for good, while others may well disappear in time. The task in hand is to prevent further movement or introduction of any species, other than within a framework of scientifically informed fishery management. The most appropriate and effective way to prevent undesirable introductions is by legislation directly regulating fish movements. We support the establishment of such legislation, and understand this is high on SEERAD’s agenda.

Livebaiting is universally recognised by coarse anglers as a legitimate practice for the pursuit of predatory fish, mainly pike. In many circumstances it is almost the only effective way to catch these species. It is permissible not only in England and Wales but virtually everywhere else in the world. Banning this technique would undoubtedly deter some potential visiting anglers at a time when there is a general thrust to promote coarse angling tourism, within which pike angling is undoubtedly Scotland’s greatest attraction, and the Lomond catchment our greatest asset.

The enormous majority of pike anglers are entirely innocent of introducing non-native species, and would understandably see a ban on livebaiting as profoundly unfair. It would punish them for the alleged behaviour of a handful of their fathers’ generation, and thus create resentment among responsible pike fishers and indeed coarse anglers generally. Even if we were to obtain majority support for a voluntary ban on livebaiting, we must face the fact that any rule which is widely perceived as unfair and unreasonable tends to attract low levels of compliance. Some individuals will inevitably be tempted to break it, and some otherwise responsible anglers may be inclined to sit back and watch them doing so. Most important, that sense of resentment could spill over into more general resistance to the positive measures which can emerge from the Catchment Plan.

It would plainly be far better to find a way of achieving what the Report sets out to attain in terms of stopping the uncontrolled spread of locally non-native species; but without alienating a large part of the community it seeks to regulate. We believe that this can be done.

SFCA is currently developing a Code of Conduct which will require the use of livebaits in Scotland to be restricted exclusively to fish taken from the water being fished. We will expect all coarse angling clubs in Scotland to enforce this rigorously in respect of their members. We believe this will be very much more effective than an outright ban on livebaiting in ensuring that unauthorised translocations do not take place in future - not least because it will have support and co-operation from the anglers to whom it applies. We believe this approach provides an acceptable, workable, and above all more effective alternative to this unnecessary proposal. We would welcome the opportunity to discuss this matter further.

R15.1 The matter of introduced fish species is an understandable concern to conservationists, but there is no unequivocal evidence whether any of them have actually caused harm. We would welcome a comprehensive, objective assessment of their impact. In passing, we would suggest that LLFT should be a key player in this and perhaps - if funding can be provided - take lead status.

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

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ISSUE 12 - Management of angling activities

ISSUE 14 - Legal protection of fish stocks

Return to Main SFCA Response