The S.F.C.A. is the national governing body of the sport of coarse angling in Scotland and as such is recognised and funded by the Scottish Sports Council. The S.F.C.A. represents a large majority of the coarse angling clubs of Scotland

The Federation welcomes the Scottish Office review of the operation of Protection Orders and has prepared this paper to formally document the opinions and requirements of the coarse anglers of Scotland.

Opinion has been canvassed from key, experienced, individuals in Scottish coarse angling, this subject has been discussed at a specially arranged development sub-committee and this document has been syndicated around S.F.C.A. member clubs.

The S.F.C.A. is happy for the Scottish Office to make this statement publicly available.

Coarse Angling can be defined as freshwater fishing for all species not classified as 'game' fish (game fish including salmon, trout and sea-trout). Common coarse species include Perch, Pike, Roach and Eels.

The growth of coarse angling is Scotland is a relatively new phenomenon but coarse fish have been in existence throughout Scotland for much longer. Though coarse angling is viewed as a minority aspect of Scottish freshwater angling it is still significant and undoubtedly provides an additional dimension to the recreational use of Scottish rivers and lochs, both for residents and tourists.

Many Scottish anglers have always spent at least some of their year pursuing species such as pike, grayling and perch. Nowadays coarse fishing encompasses not only an increasing number of these practitioners, but is also the sole or main area of interest for a growing proportion of the current generation of Scottish anglers.

At the time of the creation of the 1976 Act and previous legislation, coarse angling was less popular than today and had no organisational infrastructure, so it is not surprising that coarse angling issues were not taken into account.

The position today is very different and the S.F.C.A. aims to ensure that coarse angling interests are acknowledged and take a balanced place in the development and management of Scottish angling resources.

All freshwater fish and fishing should be 'protected' under the wording of the act. Freshwater fish being defined in Sect 24 of the 1951 Act as 'any fish living in fresh water, including trout, and eels and the fry of eels, but exclusive of salmon and of any kind of fish which migrate between the open sea and tidal waters'.

As a point of principle the view of the S.F.C.A. is that the opportunity to fish for coarse fish must not be excluded by protection orders.

A key aspect of coarse angling is that the fish caught are returned and not killed. Coarse angling relies on a naturally sustaining population so regarding fishery management we would wish to emphasise the 'protection of the fish' objectives of the legislation. Coarse fish present in waters covered by protection orders should not be persecuted in any way without sound scientific reasoning and evidence.

The comments below follow the structure of the Scottish Office letter of 17 October 1997 (received later by S.F.C.A.) inviting comments.

A key statement made in this section of the letter was - 'In making an order, the Secretary of State must be satisfied that there will be a significant increase in the availability of angling opportunities for freshwater fish in the area concerned.'

In many areas covered by protection orders, coarse fish are a significant part of the freshwater fish population. Our wish is to see that the principles of the act are applied correctly such that the chance is taken to enable the people of Scotland to fish for them. At present the ability to fish for coarse fish is prevented in many cases by fishery rules that disregard coarse fish.

It is important here to correct and clarify the situation quoted in paragraph 4.

The S.F.C.A. respects the position of the Scottish Anglers National Association (S.A.N.A.) as an important angling body that is recognised as the governing body for the sport of game angling in Scotland. It must be pointed out that S.A.N.A. is not, and I'm sure does not wish to be seen as, the sole 'governing body of angling in Scotland'.

The S.F.C.A., in a comparable way to S.A.N.A., is a recognised governing body for a branch of angling. We appreciate the invitation to sit on the Secretary of State's Consultative Committee alongside representatives of S.A.N.A. and other bodies.

We concur with the views expressed by S.A.N.A. in their 'REVIEW OF THE SALMON AND FRESHWATER FISHERIES (SCOTLAND) ACT 1976' document (Malcolm Steen, May 1996). This document reflects very well the concerns of the anglers of Scotland and coarse anglers would agree with the thrust of the paper. However the review does not make mention of coarse angling at all so it is vital that the Scottish Office take on board the specific feedback of coarse anglers as expressed in this document.

Coarse anglers with some experience of protection orders share the suspicions of many game anglers. They feel that some applicants have the aim of gaining control to impose restrictions later, such that areas will become 'exclusion zones' denying the opportunity to fish.

The S.F.C.A. does not at present have suggestions for new mechanisms to replace the existing Protection Order system.

The new committee, that has S.F.C.A. representation, is perceived to be an improvement on the past. It is more representative and from our dealings with the committee we can vouch that the members take their responsibilities seriously and work hard to ensure that the principles of the act are observed and not abused.

The application and review process needs to be changed to properly take coarse angling into account.

The current application form includes a section (No.8) that asks the question 'Is there grayling or coarse fishing available?' This is inadequate and misleading. It is too easy for applicants to dismiss the interests of grayling and coarse anglers simply by entering 'No' when grayling or coarse fish are present.

The grayling is a fish that has a suffered in Scotland from debate over it's status as a 'game' fish and the fact that it is treated more like a coarse fish. It is unwise and impractical to deal with grayling and coarse fish in exactly the same way. The Grayling Society in Scotland will be tabling a specific response to the Scottish Office and the S.F.C.A. respects their separate opinion.

There are three questions associated with coarse angling that should be satisfactorily answered by applicants -

i) Are coarse fish present?

ii) If so, please list the species -

iii) What arrangements will be made for those who wish to fish for these fish?

The extent of arrangements to allow coarse angling would of course need to be appropriate to the nature of the fisheries covered by the order. The consultative committee should be satisfied that sufficient access is given to coarse angling as and when appropriate.

Where in doubt, the existence of coarse fish should be checked.

Where coarse fish exist there should be appropriate coarse anglers representation on liaison committees. This may vary from full and active participation to the circulation list of minutes, again depending on the significance of the coarse fish population. The level of participation should be agreed by the consultative committee and recommended to the applicant by the Secretary of State.

The Loch Awe Improvement Association is a successful example of co-operation with coarse anglers in a liaison committee. After much input from pike anglers a specific pike fishing permit has been established, a reflection the importance and renown of the Loch Awe pike population.

No specific comments.

The main experience of S.F.C.A. members is with the Loch Awe order and monitoring arrangements are not seen an issue where there is effective management.

The Loch Awe order is effectively 'managed' by the Loch Awe Improvement Association, not by the Liaison Committee . The Liaison Committee is mainly independent and acts in some ways as the complaints department with access to the Secretary of State. This ensures that any complaint is not dealt with by the managing committee or person who may well have made the offending decision. This is perceived to be a good system, superior to the Liaison Committee only situation. It is perceived as counteracting or slowing up the insidious granting of 'exclusion zones'.

Though we cannot quote specific cases, some members do suspect that some liaison committees are not so effective. It is not clear at present how operational problems, from the anglers point of view, can be effectively raised and resolved.

The Secretary of State's Consultative Committee could have a useful role, even informally, in reviewing and overseeing the operation of protection orders with the aim of assisting liaison committees. The wider view and experience of the committee could perhaps help avoid the kind of problems observed and would provide better feedback on operational issues to the Secretary of State. This is currently outside it's terms of reference.

No specific points.

END