SFCA Observations on funding for Fisheries
Management
Background
Environmental scientists and fisheries experts generally
agree that a great deal more money needs to be spent on the
management of freshwater fisheries in Scotland to ensure
they are sustainable in the long term. No-one has a
comprehensive picture of what stocks or even what species
most "wild" or "natural" waters contain, far less the
growth and reproduction rates they achieve or how they are
affected by angling pressures or factors such as
acidification or nutrient run-off. Over the last few years,
Fisheries Trusts have been formed in various parts of
Scotland with the aim, among other things, of carrying out
this kind of work. The Trusts nominally cover a large part
of Scotland, but with their present resources they can
service only a fraction of the waters in their
territories.
Much of the Trusts' funding comes from game fishing
interests, especially the Salmon Fishery Boards, and most
of their work is concerned with supporting salmonid
fisheries. But coarse angling can also benefit. In the
past, pike and other species have often been netted out of
waters because club officials or proprietors thought they
were eating all the trout, or some such nonsense. Most of
these people just wanted to improve their fisheries. They
killed coarse fish because their members or customers
demanded action; and stocking or culling were the only
kinds of management they knew. Better-informed fishery
managers are increasingly turning to other strategies like
improving spawning habitats or eliminating sources of
low-level pollution, which can often bring them much
greater benefits and divert them from ill-judged and
pointless barbarities against coarse species.
A lot more money would be needed if comprehensive and
effective information collection and management advice -
whether from the Trusts or any other source - is to be
available for all fisheries and all species of fish
throughout Scotland. Few would deny this would be
desirable, but it can only happen if someone pays for it.
Who should that be? Scotland's fisheries represent a major
part of our natural heritage. They are also a social
amenity and, as the recent Scottish Executive survey has
shown, an economic asset that brings income and employment
to some of the less prosperous areas of the country. It's
therefore reasonable that a substantial proportion of any
investment should come from public funds. But anglers would
benefit from this directly in the long term, so it is
equally reasonable that we should make some
contribution.
There is another more fundamental reason why anglers
should contribute: to buy our place at the decision-making
table. In the unlikely event that the Executive was to come
up with all the money needed, anglers would not be the only
interest group wanting a share. If we were active
contributors with a stake in that funding, we would have an
undeniable claim to a role in dividing up the cake.
The angling and fisheries community will not be
universally attracted to the idea of making a contribution.
There is little or no tradition of anglers paying anything
at all to fish for freshwater species in "wild" or
"natural" fisheries in Scotland. And where people do pay
something by way of permits or club fees they expect it to
fund the kind of management that has a direct and tangible
effect, such as stocking, hatcheries, access, or
anti-poaching measures. Many of the management activities
that might be desirable for the well being of natural
freshwater fisheries have less visible benefits, and some
are unlikely to have an immediate impact on the quality of
sport. In any event, angling clubs that have put time and
money into their own fisheries over many years may reject
outside involvement, seeing it as interference. They may
also take the view that any contribution to the funding of
natural fisheries should come exclusively from those who
own or use them. In addition, any comprehensive system for
collecting money would inevitably have to be channelled
through some form of regional or national agency. This will
create a gap in the minds of anglers between what is paid
and what it is used for, and an almost unavoidable
perception that a substantial proportion of their money is
simply supporting the administrative cost of collecting
it.
Options for raising revenue
Assuming for the moment that more money
does require to be raised for fisheries
management, and that anglers
are to make a contribution, the next question is
how should that contribution be collected. There are five
broad options, not all of which are mutually
exclusive:-
- Voluntary donations;
- Direct levies on the owners of
fishing rights;
- Levies on the sale of fishing
permits;
- Area permits;
- Rod licences.
Fisheries trusts currently get a significant part of
their revenue from
voluntary donations, some of them from anglers or angling clubs.
Trusts have achieved a lot on this basis, but it's commonly
agreed that the money they get does not fund all they want
to do; that a disproportionate amount of their time has to
be spent fund-raising; and that the uncertain flow of
income makes it difficult to plan ahead. It could be
claimed that the voluntary nature of donations has a
positive impact by creating incentives to deliver what the
funders want. However, this can be a mixed benefit - it may
concentrate management on activities that serve the
interests of the largest donors at the expense of those who
have legitimate need of resources but cannot contribute as
much. There is every reason for bodies such as fisheries
trusts to continue to encourage voluntary donations as one
of several sources of support, but it is difficult to see
this as a credible way of funding an all-Scotland
system.
Statutory
levies on proprietors have long been the means of funding Salmon
Fishery Boards. These and other management costs can be
taken into account when setting permit charges, and thus
passed on to anglers. However, migratory fisheries have
certain characteristics that lend themselves to this
approach, while freshwater fisheries do not. Any levy would
require all the relevant proprietors to be identified,
their fisheries evaluated to assess fair contributions, and
machinery put in place to collect the revenue concerned.
The cost of establishing and maintaining these arrangements
would be astronomical. Given that freshwater fishery rights
are closely tied to land ownership, a fisheries levy would
also effectively be a tax on land, which would meet strong
political opposition. For freshwater fisheries, this option
is simply not viable.
There is an initial attraction to
permit levies: the anglers who fish most (and therefore benefit
most) would pay most. And they are potentially transparent
- the money raised from a particular branch of angling or a
specific fishery is readily identifiable. This approach can
work where there is general support for the concept, and
some quite successful examples already exist in Scotland.
For example, almost all the money collected by the Loch Awe
Angling Improvement Association goes to support the Argyll
Fisheries Trust, and on a smaller scale the Tay & Earn
Liaison Committee is funded by a voluntary levy on permits
sold for those waters. However, devising a fair and
workable system for the whole country would pose immense
practical problems. For example, it would need to
accommodate both conventional permits and club membership
fees that give access to fishing but also fund other club
activities that would not be subject to the levy. And as
with levies on fishery proprietors, there would be enormous
costs and problems identifying all the relevant fisheries
and collecting the revenue concerned. There is also a very
high risk of avoidance where the person or body running the
fishery isn't fully on board - particularly because some
proprietors may prefer that their income from fishing
permits isn't known to the authorities in case Inland
Revenue gets to hear of it. In addition, intense political
opposition could be expected from commercial fishery
owners, who would quite reasonably see it as a tax on their
business. This would be all the more unacceptable to them
because it would be used to subsidise "wild" fisheries in
direct competition with their own interests. Again, it is
impossible to see this as a tenable basis for a statutory
scheme.
In Europe (eg France & Spain) and North America,
area permits are commonplace. A modest annual fee gives access
to most of the fisheries in a state or region. Private and
commercial fisheries still exist to a greater or lesser
extent, but they are in the minority. In Scotland we have a
handful of small-scale examples where a single permit
allows fishing on a geographic cluster of fisheries owned
by several proprietors, notably the Assynt hill lochs.
There may be scope to develop similar models elsewhere,
particularly in respect of fisheries owned by public bodies
or the Crown. However, the fact that the great majority of
fisheries are already privately owned and the strength of
the link between riparian land and fishery ownership
militate against area permits becoming the dominant - let
alone universal - mode of raising revenue for fisheries
management in Scotland.
There is no tradition of
rod licences in Scotland, but these are the principal means of
raising funds from anglers in England & Wales. The
system there is universal and attracts substantial levels
of compliance. In 03/04 EA is reported to have spent about
£28m on fisheries management, of which around £18m gross
was raised through rod licence sales. Collection and
compliance costs are understood to have been approximately
£4m. The rod licence provisions currently applicable south
of the border are fundamentally flawed in many ways, and
are not well loved by anglers. But that does not mean the
principle should be rejected out of hand. Adopting
rod licences would not require the wholesale importation of
the E&W model. In particular, it is neither necessary
nor desirable for the money raised by rod licences to be
channelled through a monolithic national agency like the
EA. The concept of rod licences - which could usefully be
re-labelled to avoid emotive connections with the E&W
model - merely implies that anglers have to pay some form
of statutory charge before they can fish lawfully with rod
and line in freshwater. The key factor is that the charge
is separate from, and additional to, any permit fee levied
for consent to fish a particular water, and applies even
where the angler himself or herself is the owner of the
fishing rights.
Risks
However desirable it might be to have a new revenue
stream to support fisheries management, we must also
recognise that it there is a serious risk that it would
become a substitute for, rather than a supplement to,
existing sources of funding. At present there is
substantial private expenditure on some fisheries, and
considerable effort and ingenuity has gone into developing
and funding initiatives such as the scientific fisheries
trusts. It can be argued that this investment has emerged
in response to the absence of a satisfactory national
system of funding for fisheries management; but it would be
unfortunate if a national system led to a decline in
private expenditure.
In addition there is already an enormous input of
voluntary manpower on the part of angling clubs and
syndicates to run the fisheries they manage. Any system to
collect and disburse revenue for fisheries management
similarly runs the risk that angling clubs may step back
and seek to have this resource provided by others. This may
be especially true where clubs find themselves expected to
carry out management activities that they do not
necessarily perceive to be in accord with their own
immediate priorities.
The way forward
SFCA believes that there should be substantial
investment in all-Scotland, all-species provision for data
collection and scientific advice to inform fisheries
management, and that anglers should contribute directly to
supporting this facility. Ideally, we would like to see the
present level of voluntary donations, voluntary permit
levies and area permit arrangements maintained or expanded;
but we see no viable alternative to collecting the bulk of
the anglers' contribution via an acceptable form of rod
licence system underpinned by appropriate structures and
safeguards.
Even if anglers can be persuaded that more money should
be invested in fisheries management, a lot of effort will
still be required to convince them that it is necessary to
contribute a share of it. Inducing them to pay up if and
when a scheme is put in place will be even more
challenging. We should not underestimate how difficult it
will be to gain acceptance of the benefits and shift
people's thinking towards a long-term perspective.
A great deal will depend on the structure of the system
put in place. To be acceptable, any rod licence scheme must
possess the following characteristics, which are presented
in alphabetical rather than priority order:-
·
Accountability - anglers must have a pre-eminent place in the
decisions on the disbursement of the funds concerned. This
must not be restricted to arms-length advisory committees
as in the EA arrangements, or rely on representations
submitted in response to decisions already made.
·
Conservation - the system must under no circumstances support
or promote management measures which are beneficial to one
species to the detriment of another, regardless of their
relative sporting or commercial value.
·
Effectiveness - the system must actually yield improvements to
the quality of anglers' sport.
·
Efficiency - the costs of collection, administration and
enforcement must be maintained at the lowest possible
level.
·
Flexibility - the decision-making machinery must be capable
of responding to short-term or localised needs as they
arise, without requiring ponderous and time-consuming
deliberations or weeks or months of preparatory work and
consultation.
·
Proportionality - The contributions raised from each branch of
angling and each broad locality must be reflected to a
reasonable degree in the distribution of expenditure to
benefit them.
·
Self-containment - all the revenue raised from anglers must be
used to benefit fish and fisheries; not to support wider
objectives - however laudable - by way of environmental
protection.
·
Subsidiarity - decisions must as far as possible be taken at
the lowest practicable point in the structure. This must go
down at the very least to catchment level.
·
Transparency - anglers must be able to see what money is
raised and what is being done with it.
·
Universality - the system must provide funds to support
management and data collection for all parts of the country
and for all species, regardless of their sporting or
commercial value.
This paper has been prepared as a basis for discussion
by the Freshwater Fisheries Steering Group as part of the
dialogue leading to the development of new fisheries
legislation and management structures for Scotland. It has
the support of the SFCA Executive Committee and has been
circulated for comment to all member clubs. As yet we have
not been able to gather widespread feedback, but the
contents are consistent with views expressed to us in the
course of face-to-face consultations that have recently
taken place with groups of members in some of our larger
clubs.
SFCA
August 2004
Fishery management
structures and processes -
assessment template |
Key Element | Indicators | Evidence | Score (circle) | Comments |
1 - Appropriate
Fisheries Management structures are in
place | Decisions are
taken at a local level by those with an
interest in the fisheries and species
concerned | a structure or set
of structures exists for making plans
and decisions on fishery management
issues in the catchment; | 1 2 3 4 5 6
7 8 9 10 | |
| | all interested
parties are represented in the
decision-making structure | 1 2 3 4 5 6
7 8 9 10 | |
| Fishery Management
Structures operate cost-effectively | revenue from
permits and other sources is
supplemented by voluntary effort by
individuals, clubs and other
organisations. | 1 2 3 4 5 6
7 8 9 10 | |
| Those responsible
for fishery management are competent in
appropriate matters. | individuals
involved in all aspects of fishery
management are well-informed; | 1 2 3 4 5 6
7 8 9 10 | |
| | many of those
involved in fishery management have
obtained, or are pursuing, relevant
formal qualifications. | 1 2 3 4 5 6
7 8 9 10 | |
Key Element | Indicators | Evidence | Score (circle) | Comments |
2 - Appropriate written Fisheries
Management plans are in place. | Fisheries Management plans encompass all
waters | plans have been prepared for all
fisheries in the area concerned | 1 2 3 4 5 6 7 8 9 10 | |
| | a catchment-based Fisheries Management
plan has been prepared, either as an
aggregate of individual plans or as an
exercise in itself | 1 2 3 4 5 6 7 8 9 10 | |
| Fisheries Management plans encompass all
species | plans are informed by robust and
comprehensive scientific data on the fish
populations in the area and their
status; | 1 2 3 4 5 6 7 8 9 10 | |
| | plans include management provisions to
benefit both freshwater fish and migratory
salmonids | 1 2 3 4 5 6 7 8 9 10 | |
| Fisheries Management plans address fish
conservation issues | plans state how fish populations will be
monitored; | 1 2 3 4 5 6 7 8 9 10 | |
| | plans include measures which preserve
and enhance established populations on a
water-by-water basis; | 1 2 3 4 5 6 7 8 9 10 | |
| | plans contain specific provisions for
the protection of any rare or endangered
species present; | 1 2 3 4 5 6 7 8 9 10 | |
| Fisheries Management plans link access
for angling to the sustainable management
of fish populations | plans contain detailed information on
the proposed extent of access for angling
in respect of each sporting species
present; | 1 2 3 4 5 6 7 8 9 10 | |
| | plans indicate the likely impact of
proposed management actions; | 1 2 3 4 5 6 7 8 9 10 | |
Fisheries Management is carried out in
an appropriate manner | Accurate up-to-date scientific data on
fish populations and other related issues
is gathered and disseminated | monitoring information is collected in a
co-ordinated manner and consistent form to
agreed standards; | 1 2 3 4 5 6 7 8 9 10 | |
| | monitoring information is passed on to
appropriate bodies; | 1 2 3 4 5 6 7 8 9 10 | |
| Fishery Managers act upon the scientific
information gathered | monitoring information is used to amend
plans and introduce or vary management
measures as and when necessary; | 1 2 3 4 5 6 7 8 9 10 | |
| | monitoring information is used to inform
future fisheries planning in the
catchment. | 1 2 3 4 5 6 7 8 9 10 | |
| Responsible access for angling is
readily available at reasonable cost | levels of permit charge are commensurate
with the quality and type of fishing
available. | 1 2 3 4 5 6 7 8 9 10 | |
| | in "wild" fisheries the bulk of the
money raised from permit fees is recycled
into management measures for the benefit of
the fishery concerned; | 1 2 3 4 5 6 7 8 9 10 | |
| | access is provided for both local and
visiting anglers; | 1 2 3 4 5 6 7 8 9 10 | |
| | arrangements are publicised so that
anglers can readily identify what angling
opportunities are available; | 1 2 3 4 5 6 7 8 9 10 | |
| | permits are obtainable from a range of
convenient outlets such as tackle shops,
local stores, post offices, hotels etc | 1 2 3 4 5 6 7 8 9 10 | |
| Appropriate recognition is given to the
full diversity of sporting species
available | the demand for angling of all types is
met to the maximum degree compatible with
sustainable exploitation of stocks of each
species; | 1 2 3 4 5 6 7 8 9 10 | |
| | restrictions on methods for pursuing
particular species, or on seasons or closed
times, are confined to the minimum
essential for the species they seek to
protect. | 1 2 3 4 5 6 7 8 9 10 | |
| The proprietors and operators of "wild"
non-migratory fisheries collaborate to
generate revenue for fishery management | permits are available which give common
access to linked fisheries (for example,
adjacent stretches of a river or parts of a
system of rivers and lochs) or groups of
fisheries (for example, a cluster of hill
lochs); | 1 2 3 4 5 6 7 8 9 10 | |
| | a single area permit covers
all wild non-migratory fisheries
in the catchment, or a large part
thereof. | 1 2 3 4 5 6 7 8 9 10 | |
Fisheries Management Structure
Models |
Option | Title | Description | Legislative requirements and
resource implications | Benefits | Risks and drawbacks |
1 | Status Quo | Various combinations of District
Salmon Fisheries Boards, Fisheries
Trusts, Liaison Committees, Angling
Associations etc interacting in
different ways in different localities.
Data collection, where it takes place,
generally co-ordinated via the Scottish
Fisheries Co-ordination Centre. | No new legislation or public funding | - has evolved to reflect local
situations and priorities. - well established roles and
structures - attracts extensive voluntary effort in
many locations - attracts substantial private sector
investment in many locations - data-collection generally uses
consistent methods, where it takes
place | - inconsistencies in roles and
practices - significant gaps in coverage and / or
representation - major gaps in data-collection,
geographical and by species - no guarantee of expertise /
qualifications on management bodies - largely salmo-centric |
2 | Stimulated Evolution | Identify and publicise minimum
standards and best practice from
current structures. Create incentives (eg, through
conditions for granting Protection
Orders, access to project funding etc
which encourage /oblige fishery owners
seeking public funding or statutory
protection to adopt appropriate
management structures and
practices. | - needs careful shaping of new
legislation and funding practices to create
incentives. - may stimulate greater demand for
project funding. - would benefit from financial
pump-priming to establish / maintain
management structures were none (or only
rudimentary structures) exist at
present | - can develop in tune with local
situations and priorities. - builds on and strengthens the best of
existing structures - retains "psychological ownership",
which should sustain voluntary effort and
private investment. - data-collection will become more
widespread, comprehensive and consistent in
methods. | - pace of development uncertain - potential that the flaws identified in
respect of Option 1 will remain if the
incentives built into legislation and
funding practices do not prove sufficiently
strong - potential for "tokenism" or possibly
even deception to subvert the purpose of
incentive measures - cost of resources to police
compliance |
3 | Freshwater Boards | Establish new catchment-level
management bodies which take
responsibility for the management of
freshwater species, acting in parallel
with District Salmon Fisheries
Boards. | - requires primary legislation to define
roles and powers of freshwater management
bodies - requires financial pump-priming to
establish and maintain management
structures which largely do not exist at
present - need for the establishment of a rod
licence system or other source of funds
from anglers? | - in some locations can build on
established structures. - largely retains psychological and
legal ownership, and thus should sustain
most voluntary effort and private
investment. - leaves current management structures
and arrangements for migratory fisheries
undisturbed - data-collection should become
universal and consistent. | - creates duplication of structures
between migratory and freshwater
fisheries - historical lack of mutual trust
between freshwater and migratory interests
in some locations - requires effective mechanisms to
mediate between migratory and freshwater
interests |
Option | Title | Description | Legislative requirements and
resource implications | Benefits | Risks and drawbacks |
4 | Expanded Salmon Fisheries
Boards | Extend the remit of District Salmon
Fisheries Boards to encompass the
management of all species and all
waters in the relevant catchment. | - requires primary legislation to
redefine roles, composition, and powers of
DSFBs - requires establishment of separate
mechanisms for funding freshwater fisheries
management - requires financial pump-priming to
establish expanded structures - need for the establishment of a rod
licence system or other source of funds
from anglers? | - in many locations can build on sound
relationships to reduce discontinuity
arising from change. - creates potential for
cross-subsidisation - minimises change to current management
structures and arrangements for migratory
fisheries - data-collection should become
universal and consistent. | - DSFBs do not exist in a number of
important catchments - alters psychological ownership of
freshwater fisheries management, and thus
risks loss of voluntary effort and
investment. - strong historical lack of mutual trust
between freshwater and migratory interests
in some locations - strong perceived danger of becoming
even more salmo-centric |
5 | Joint Boards | Abolish District Salmon Fisheries
Boards. Create entirely new catchment-based
umbrella bodies to take responsibility
for the management of all species and
all waters in the relevant
catchment. | - requires primary legislation to
abolish DSFBs - requires primary legislation to
establish new management bodies and define
their roles, composition, and powers - requires establishment of new
mechanisms for funding fisheries
management - requires substantial financial
pump-priming to establish new
structures - need for the establishment of a rod
licence system or other source of funds
from anglers? | - in many locations can build on sound
relationships to reduce discontinuity
arising from change - creates potential for
cross-subsidisation - minimises change to current management
structures and arrangements for migratory
fisheries - data-collection should become
universal and consistent. | - substantially alters psychological
ownership of freshwater and migratory
fisheries management, thus creating a high
risk of loss of voluntary effort and
investment. - strong historical lack of mutual trust
between freshwater and migratory interests
in some locations - strong perceived danger of becoming
even more salmo-centric |
6 | EA Surrogate | Create a public body to assume
fisheries management role inScotlandanalogous to that held by Environment
Agency in E&W. (or modify SEPA's role
to take on those
responsibilities.) | - primary legislation to create new
management body or alter SEPA role and
delineate its powers - public funding for running costs of
management body (or additional funding for
SEPA expansion) - public funding for ongoing investment
in fisheries - requirement to establish a rod licence
system or other source of funds from
anglers. | - potential for high degree of
consistency in management practices - data-collection would become universal
and consistent. - full coverage of all areas - capacity to switch resources from
where they are generated to where they are
most needed - capacity to draw in additional public
investment according to need | - management decisions influenced by
political debate - resourcing affected by political
priorities rather than actual need - difficulty establishing roles and
relationships with riparian owners - cost of establishing & running new
agency (or expanding SEPA) - ongoing cost of replacing some items
currently funded by private sector
investment - less psychological ownership will
reduce voluntary effort / investment |
Option | Title | Description | Legislative requirements and
resource implications | Benefits | Risks and drawbacks |
7 | Nationalisation | Take all fisheries, freshwater and
migratory, into direct state
control. | - primary legislation to create
compulsory purchase power, establish
state-run management body and delineate its
powers - public funding for compensation to
current owners - public funding for running costs of
management body - public funding for ongoing investment
in fisheries - requirement to establish a rod licence
system or other source of funds from
anglers. | - potential for high degree of
consistency in management practices - data-collection would become universal
and consistent. - full coverage of all areas - capacity to switch resources from
where they are generated to where they are
most needed - capacity to draw in additional public
investment according to need | - politically controversial change - management decisions subject to
political debate - resourcing dictated by political
priorities rather than actual need - difficulty establishing roles and
relationships with riparian owners - cost of compensating riparian
owners - cost of establishing and staffing new
management body - ongoing cost of replacing
all current private sector
investment - absence of psychological ownership
will eliminate voluntary effort and
investment |