The body of this document consists of the SFCA's response to a report entitled "REVIEW OF POLICIES CONCERNING FRESHWATER FISH IN SCOTLAND", a discussion paper issued by Dr. Peter Maitland of the Fish Conservation Centre in October 1996.

This reply was constructed by the Federations Executive Committee, whose members include respected specialists from the Scottish angling community with wide experience and knowledge in all areas of coarse angling. A number of meetings held over the last 6 months as well as survey and draft documents were presented to the Federations members before this final submission was concluded on their behalf.

Any enquiries in regard to this document should be submitted to:

Stephen Clerkin

Secretary (SFCA)

Response from the Scottish Federation for Coarse Angling

In general, the SFCA supports the conclusions of the Report. We are particularly pleased to see that Dr. Maitland proposes measures to remedy both the fragmented nature of fisheries management policies across Scotland and the existing bias in favour of the perceived interests of game species, especially salmon.

There are a number of items within the report on which we would wish to put forward our own observations to highlight the coarse angling perspective. In doing so we recognise that although coarse fishing undoubtedly provides an additional dimension to the recreational use of Scottish lochs and rivers both for residents and tourists, it is viewed as a minority aspect of the Scottish angling scene. In some respects this masks the true picture, as many Scottish anglers have always spent at least some of their season pursuing coarse species, especially pike and grayling.

Nowadays coarse fishing not only encompasses an increasing number of these occasional practitioners, but is also the main area of interest for a growing proportion of the current generation of Scottish anglers. From the establishment in the late sixties of a single small club comprising largely expatriate Englishmen, coarse fishing in Scotland now has it's own Federation, the SFCA, with affiliated clubs sharing hundreds of members. Scottish match anglers compete at the highest international level, and several of our specialist anglers - particularly in pike fishing - are nationally-respected figures in their field. Many coarse anglers visit Scotland from England and further afield to sample, for instance, the renowned pike fishing of waters like Loch Lomand and Loch Awe. Numerous small hotels and guest houses, particularly in Dumfries & Galloway, prosper through a steady stream of visiting coarse anglers and in some cases control their own small coarse fisheries to cater for this demand.

Scottish coarse fishing is currently at much the same stage of development as sea angling was here in the late sixties: the quality of the sport is becoming recognised and the level of participation has started to grow. The Wild Rivers report therefore comes at an important time for us. When the Hunter report was issued in 1965 coarse fishing was less popular and had no organisational infrastructure, so it is not surprising to find that coarse fishing interests merited no more than a speculative nod from its authors. The position today is very different, and we hope that what emerges from Wild Rivers will acknowledge that and enable coarse fishing interests to have a balanced role in the future development of Scottish angling resources both at a strategic level and in individual waters. We firmly believe that, far from being at odds with the salmon and trout fishing fraternities, we share an interest with every Scottish angler - and indeed with the wider community - in maintaining and improving the management of fish populations of all species in Scotland.

The comments which follow are cross-referenced to particular pages and paras of the October 96 draft of the Wild Rivers report. To avoid duplication, we have commented on items as they appear in the main text rather than where referred to in the executive summary:-

We believe that some species, particularly carp, may in fact have reached Scotland rather earlier than indicated in the second paragraph, although this does not materially affect the point that these are comparatively modern arrivals. We are more concerned, however, by what we infer to be the view that species which were not in Scotland shortly after the last ice age are somehow less legitimate members of the fish community. We comment more fully on this issue against the Section regarding "Alien Species".

We have no wish to threaten any established species by disease, competition or predation. We want to make it very clear that we fully support the management of fish stocks through proper controls over the introduction and movement of fish - of whatever species - throughout Scotland. Only fish from licensed sources supported by appropriate test records should be considered for stocking.

We note and agree that "the total worth of Scotland's freshwater fish resource has never been properly evaluated and is much higher than normally appreciated". However it would be rather short-sighted to try to evaluate that resource purely in terms of the revenue which could be gained from commercial sales of edible species. On this estimation species such as powan would be disregarded, and in the extreme it would point towards a massive expansion of aquaculture at the expense of any semblance of a natural environmental balance. We trust this item should be interpreted as a inviting a broad-based assessment which would take full account of the value of Scotland's fish stocks as a leisure resource.

We agree that the indiscriminate movement of fish (for whatever reason) should be prevented. We would see no problem however with the controlled and considered introduction of new stocks of some species to selected waters, but only where it can be seen that there is no threat to other species.

As already mentioned, we feel the division of species currently found in Scottish waters into "native" and "alien" species on the basis of whether they were here when the glaciers retreated is misleading. There has been extensive climatic change since then, and much has altered in the natural environment around the river systems (hydro-electric schemes, de-marshing etc.). As a result the aquatic environment has also changed, and large sections of some rivers (e.g. the lower reaches of the Clyde) or stillwaters (e.g. the Forth & Clyde canal) are far better suited to the needs of more recently introduced species. We feel it is more helpful to speak of "established" species and acknowledge that the hand of man is as much an inevitable feature of the spread of species as it is in the development of the aquatic environment. Trying to register some well established species as "alien" and deal with them as suggested will do nothing to alter the fact that significant parts of the Scottish aquatic environment are simply no longer suited to their original inhabitants.

We agree with the issues raised. However the reference should be with regard to all freshwater fish including coarse species. In particular we can see the success of pike-specific considerations that are already in place at Loch Awe where officials recognise that the law (see comments on the Hunter Report) does not properly recognise legitimate coarse angling practices. However, due to the positive contribution of the pike anglers to the local fishery management body, their needs have been recognised and accommodated.

With regard to the reference to "intensive management", our experience is that such action often also deprives the public of a valid and established coarse fishery, replacing it

with a marginal trout fishery where sport is only available at a cost beyond the means of many of those who would otherwise have benefited. The coarse fish present in a water are all too often assumed to be the culprits when trout or salmon catches decline, whereas in many cases they are equally the victims of other problems such as cormorant predation or pollution from agrochemicals. One major benefit from the proposed new management structures is that they offer the scope to avoid decisions about controlling coarse fish stocks being made without the basis and advantage of sound scientific evidence.

It is worth pointing out that stillwater coarse fisheries also relieve pressure on "native" fish stocks, and indeed adding that as coarse anglers return their catches the cost of maintaining a sporting population of coarse fish in most waters is minimal.

We have already drawn attention to the greatly increased popularity of coarse fishing in Scotland since Hunter was written. Coarse fisheries, albeit in modest numbers, have developed, as to a greater degree have rainbow trout fisheries. The truth is, however, that "ample [brown trout] angling for the public at a reasonable price" is further away now than it was then, certainly for anglers in the central belt, and is unlikely ever to return.

The legal provision restricting methods to "angling by a single rod held in the hand (this to cover coarse fishing also)" needs to be reviewed. In most forms of coarse angling the rod is placed in a rest, not to indulge the laziness of the angler but as a necessary measure to keep the bait static and in some circumstances also to enable bites to be detected. Universally accepted modern day tactics for many species, especially carp and pike, also involve the use of more than one rod at a time. This is not a question of leaving tackle spread out unattended over a wide area of banking until some poor fish expires with a hook in its gut. Quite the reverse. Rods are always closely attended and by using sensitive electronic bite detectors the angler can ensure takes are registered and responded to immediately. Fish conservation and health issues are fully addressed. Accepted practice throughout Europe and most of England is to allow simultaneous use of up to three rods in these circumstances, and we would seek to bring Scotland into line with that.

Such a change would not of course preclude the rights of a fishery owner to make appropriate local restrictions.

Referencing the Area Board powers in this same section - any action would be required to be based on sound scientific evidence.

Sub-section 1 - we have already mentioned our concerns at the way the term "Native Fish" seems to have been used. Whilst we recognise some species of coarse fish are recent arrivals to Scotland, many are now firmly established and in the main occupy legitimate niches in the ecosystem of the waters they inhabit, competing little with their post-glacial cousins. The SFCA would suggest that all established species deserve the "improved conservation protection" envisaged.

Sub-section 2 - coarse fishing organisations could provide a valuable source of the kind of "experience and expertise" mentioned and should be given appropriate opportunities to play a part in fisheries management bodies in those areas where significant coarse fish stocks exist. We would in passing mention a specific example of a valuable coarse fishing water - the Forth & Clyde canal - which crosses the boundary between at least two river catchment areas. No doubt this is something of a one-off anomaly, but it would need to be addressed in the new structure.

Sub-section 4 - we strongly agree with the position stated as regards paying attention to the needs of all species. Further, it is a fact that new stillwater coarse fisheries can also relieve pressure on all species elsewhere, and develop broader opportunities for coarse angling.

Sub-section 6 - we strongly support the concept of scientifically-based fisheries management decisions. We would draw attention to the fact that "put and take" is misleading with reference to coarse fisheries, as coarse fish caught are invariably returned. Management is therefore more concerned with maintaining or optimising stocks after an initial introduction. For some species, such as carp, which rarely breed with success in Scotland, this is akin to the "put and take" approach, but for others it is more like the model described for "wild" fisheries.

Sub-section 1 - Whilst we are generally in support of the structure proposed, we are particularly concerned that the new Boards should be composed and run in a manner which guarantees that they act with broad fishing and fishery management interests in mind, rather than just those of the salmon proprietors as at present. With regard to the reference on "control of stocking and predators", we agree subject to the proviso that any such decision must be subject to proper scrutiny, and only taken after considering sound scientific evidence.

Sub-section 2 (Page 21) - We believe that the participation of angling organisations' representatives on Regional Fishery Trusts should not be an optional matter involving co-opted members, but a mandatory component of the make-up of the Trust Boards.

Sub-section 3 (Page 21) - we support the extension of Protection Orders, providing they operate genuinely to increase access for bona fide anglers and not, as in some cases at present, simply to enable salmon proprietors to impose unreasonable restrictions on the pursuit of trout and coarse fish.

The SFCA do not see the introduction of a close season for coarse fish as being necessary. Close seasons are virtually unknown throughout Europe, and have recently been abolished in respect of stillwater fisheries in England without ill effect. The main arguments in favour of a close season are either to protect fish during spawning periods or to provide relief from intensive angling pressure. The angling pressure here is still modest, however, and in Scotland several species often spawn later than the English close season, if at all, so this would be of little value. Individual fishery owners could make rules to cater for local requirements, but we vigorously oppose any general close season.

Our views on controlling and managing coarse fish movement have been noted earlier.

Sub-section 6 (Page 22) - We have considerable concern that the report makes little challenge to the assumption that "the emphasis on the Atlantic Salmon....will feature strongly in fisheries management". The report should concentrate on the conservation and preservation of all species and not be swayed by economic issues attracted by one in particular. The fact is that salmon fishing - albeit more by force of economic circumstances than choice - probably has much the same number of regular participants as coarse fishing in those areas of Scotland where coarse fishing is available.

We are somewhat confused by the comment that the salmon fisheries can "raise most money for management". If this means they will generate this by selling more licences, we would doubt it is true. If it is in respect of other ways of raising money, such as through individual permit charges, we have no objection to that money being spent as the fishery owner thinks fit. If, however, it implies that money should be siphoned away to salmon interests because the fishery owners can get a better return from it, we are most certainly opposed. The overriding principle must be to consider the broader angling community and its needs.

Sub-Section 7 (Page 22) - The SFCA does not disagree in principle to the introduction of a national angling licence. We have considerable reservations, however, about some of the practicalities and comment in more detail on this later. We would stress that some of the funds raised under any such scheme should be invested in coarse angling in reasonable proportion to the need for that investment and demand from participants - we would be less than happy to see what might become an effective tax on our sport used purely to further the interests of already-wealthy salmon proprietors.

The distribution of coarse fish and fisheries is such that most coarse anglers would wish to fish in more than one of the proposed regions. The SFCA would therefore suggest a National Rod Licence, rather than individual licences for different regions, would be the most appropriate option.

Sub-section 10 (Page 23) - It is vital to stress that SANA is not - and as far as we are aware does not seek to be - the representative body for all freshwater anglers in Scotland. It legitimately represents the interests of game fishers and their respective angling clubs. The SFCA performs the corresponding function for coarse anglers (indeed we are listed in that capacity in Appendix 2 of the report). We enjoy good relationships with SANA and sit alongside SANA representatives on several existing bodies. We would wish similarly to be acknowledged separately in any national consultation and represented separately on Regional Fishery Trusts along with the SANA and ASSF in those parts of Scotland where there is any significant coarse fish stock. This would probably imply involving us in around ten of the proposed Trusts.

Sub-section 13 (Page 24) - we support this move providing, as with the proposed extension of Protection Orders, it results in a tangible improvement of access to and management of the waters concerned.

Taking the figures given, the sale of 50,000 licences at £ 10 would yield the substantial sum of £ 500,000 gross. However,

in order to police the Rod Licence scheme each of the 25 Regional Boards would presumably have to employ at least one bailiff, or the Central Fisheries Unit would have to employ a troop of peripatetic or outstationed bailiffs. Either way, we appear to be looking at a sizeable overhead (probably more than half of the revenue raised) simply to ensure compliance. Add to that the administration cost of maintaining the necessary records, plus the individually minimal cost of the hat badges, plastic cards, prize draws, booklets and car stickers listed in Appendix 5, not to mention the commission the Post Office would no doubt want for selling the licences, and we may see very little of the revenue raised actually ploughed back into fisheries management.

We may have overstated the cost of bailiffing, but in the absence of more detailed information in the report the sums we have estimated do not appear unreasonable. Of course the licence sales could be much higher, but experience in England and Wales is that a high level of non-compliance can be expected. Given the traditional Scottish perception of a universal right to "free" trout and coarse fishing, and the fact that Rod Licences would be a new development, we tend to think this may even be more of a problem here. Alternatively, the individual cost of licences could be set higher, but this would be likely to exacerbate the rate of non-compliance and it would in any case be difficult to justify a cost above the £ 16 currently paid by English anglers, which would still leave little for investment after dealing with overheads.

While, therefore, we have no philosophical objection to the introduction of a national Rod Licence, we are sceptical about its value in practice and would certainly oppose any scheme which did not result in the great majority of the revenue raised actually being used to improve fishery management.