SFFF SG 5-3: Report of the Sub Group examining
ideas for future management structures for salmon and
freshwater fish
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1. Introduction
2. Principles & Objectives
3. Assessment of Options
4. Assumptions
5. Options for Funding
1. Introduction
The Freshwater Fisheries Forum Steering Group, at it's
meeting on 7 October 2004, agreed to establish a Sub Group
to consider views and generate a single document proposing
a new structure of management for freshwater fisheries in
Scotland, and for it to report back at the next meeting on
25 November 2004. The membership of the Sub Group is:
- Andrew Wallace - ASFB
- Dr Alastair Stephen - IFM
- Jane Wright - AWCFT
- George Holdsworth - ASSF
- David Howell - SNH
- Ron Woods - SFCA
- SEERAD representative
Whilst not a formal member of the Group, Brian Davidson
agreed to draft the Report of the Group.
The Sub Group was not given a formal remit or terms of
reference but was simply asked to consider the various
models for a future management structure encompassing all
species of freshwater fish, including migratory salmonids,
and provide some guidance to the Steering Group on the most
logical option. It is emphasised that the ideas in this
report are simply that: they are not recommendations but
are a synthesis of the various ideas discussed, and are
intended to provide a focus for the Steering Group, and
ultimately the main Fisheries Forum, on the potential way
forward. The Sub Group, in its discussions, were mindful of
the need to consider all options and to take a
dispassionate, objective look at the strengths and
weaknesses of these.
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2. Principles & Objectives of Any New
Structure
The Sub Group agreed that any system, irrespective of
how it is structured, should deliver a set of key
aspirations and objectives for Scotland's salmon and
freshwater fisheries. It agreed that it should set out a
series of assumptions that any future management system
should be prepared to work to and that alongside this
should be listed some of the core functions of any future
management structure. These are listed overleaf in no order
of importance.
Principles | Functions |
Sustainability -
management bodies must ensure that
management is conducted according to
principles of sustainability as they apply
to management of fish stocks, fisheries and
access to fisheries | Regulatory body -
management bodies must be effective
regulatory bodies with appropriate and
enforceable powers, duties and
responsibilities |
Accountability -
management bodies must be accountable to
anglers, proprietors, public sector bodies
and the general public | Management planning -
management bodies must be responsible for
producing, collating and delivering
fisheries management plans and ensuring
such plans are integrated with other
relevant plans eg) WFD |
Transparency - management
structures must operate in an open and
transparent manner | Funding - management
bodies should have powers to collect and
disburse funds |
Effectiveness - management
bodies must operate efficiently and deliver
cost effective benefits to anglers,
proprietors, managers and the general
public. Any new system must build on and
improve on the old system. | Statutory consultee -
management bodies must be considered as
statutory consultees in all areas of public
life that have an impact on the
responsibilities of those bodies |
Proportionality - the
focus of management must reflect the
relative importance of each of the angling
sectors in each area | Data gathering -
management bodies, with the assistance of
the SFCC must be responsible for
collecting, collating and storing high
quality data appropriate to the
responsibilities of those bodies |
Self containment - funds
raised locally must as far as possible be
spent locally | Training - management
bodies must ensure that all staff involved
in the management and use of the fishery
are trained to high and nationally
consistent standards |
Subsidiarity - decisions
must be devolved as far as is possible to
catchment level, or indeed individual
fisheries where appropriate. | Work to common standards -
management bodies whilst recognising the
different circumstances on the ground
should work to consistent common
standards |
Universality/Flexibility -
a consistent management system should be
applied but management bodies must be
adaptable to the different circumstances
that exist in catchments around
Scotland | Representation -
management bodies should be representative
of the needs and aspirations of anglers,
proprietors and managers in their area |
Funding - Sufficient
funding must be made available from public
and private sector sources to ensure that
management bodies can function properly | |
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3. Assessment of Options
The Sub Group reviewed the analyses of the various
options for future structures already tabled by some
members of the Steering Group. The various models examined
by the group were:
- Option 1: Retention of the status quo
- Option 2: Parallel structure
- Option 3: Unitary structure
- Option 4: Centralised control
- Option 5: Stimulated evolution
- Option 6: Expanded Salmon Fisheries Boards
- Option 7: Nationalisation
The following is a SWOT analysis of these 7 options:
Option 1- Retain 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.
Strengths - DSFBs are a functional
system for managing migratory salmonids - Management at a local level - PO's have some sound
principles and in places appear to work
well - Substantial investment
from private sector - Good voluntary involvement in many
locations - Where it works well it
can work very well -No new legislation or
public funding - well established roles and
structures - attracts extensive voluntary effort in
many locations - data-collection generally uses
consistent methods, where it takes
place | Weaknesses - Little management or
statutory control of all other fish
species - Little political support - Perception of democratic
deficit and anachronistic legislation -Lack of engagement by
public sector - Inconsistency -Conflict between species
management - inconsistencies in roles and
practices - 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 - Where it does not work well it is
weak, and there is no obvious mechanism to
resolve problems. | Opportunities - Build on evolutionary
progress of existing structures - System could be enhanced by
strengthening the fisheries trust network
to deal with other fish species issues and
modernising the PO system to deal with
access and management issues without
fundamentally altering current system | Threats - Continued lack of
engagement by public and political
sectors - Lack of public support/buy-in - Reliance on income from
fisheries which, with fisheries in decline,
results in reduced investment when most
needed. |
Option 2 - Creating A Parallel
Structure
Establish new catchment-level management bodies
which take responsibility for the management of
freshwater species, acting in parallel with District
Salmon Fisheries Boards
Strengths - Leaves existing DSFB system
undisturbed, retaining the strengths of
current management structures for migratory
fisheries - Allow better focus on specific
management issues - In some locations can build on
established structures. - Largely retains psychological and
legal ownership, and thus should sustain
most voluntary effort and private
investment. | Weaknesses - Administratively
complex - Duplication of effort / lack of
co-ordination - Confusing to outside
world - Expensive duplication of effort and
administrative structures - Would require effective mechanisms to
co-ordinate migratory and freshwater
management and mediate between competing
interests No pre-existing way to fund management
of species which generate little or no
income | Opportunities/resources
required - Not obvious - 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? - Might be possible to use a derivative
of the liaison committee system to provide
this structure (although no current
provision in law to create such a
committee). | Threats - Fragmentation and poor
co-ordination in a sector already suffering
from poor co-ordination. - Likely to suffer from
inconsistency Conflict between species management - 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 3 - Unitary Structure
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.
Strengths - A "fresh start", allowing stakeholders
to move on from historical differences - Co-ordinated approach - Retains management at a local
level - Retains local
representation - Attractive to potential
private / voluntary / public funders Precedent already set on the Tweed
(Commissioners/Foundation) - 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 - 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. - Trusts could be retained
alongside unitary Board to assist with
fund-raising and provide
scientific/management advice - Specific interests eg) non statutory
salmon management groups/coarse
groups/trout groups could be retained to
manage specific fisheries within a Board
area | Weaknesses - Achieving flexibility in
representation to reflect circumstances on
the ground - Creating a management Board small
enough to manage and large enough to be
representative - Difficulty in defining
areas - Difficulty in developing
expertise - Funding of management of
species which generate little or no income
required - 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 Not sure I agree
with this The rationale for this comment is
that because the bulk of funding will
generally be coming from migratory
interests, the risk exists that those
interests will dominate
decision-making. More important, the
perception that this will happen may
make it difficult to establish trust.
So saying, the original wording is a
bit harsh. Perhaps substitute "Some
perceived risk" for "Strong perceived
danger"? - creates potential for
cross-subsidisation | Opportunities/resources
required - Create a structure which
has political and public sector support but
which retains local management control - Relationship with Trusts could be much
closer - Opportunity to raise
funds through area permit system - 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? - Trusts could be retained alongside
unitary management body to assist with
fund-raising and provide
scientific/management advice - Specific interests eg) non statutory
salmon management groups/coarse
groups/trout groups could be retained to
manage specific salmon fisheries within a
catchment | Threats - Conflict between species
management - May tend towards quango status - Perceived danger of domination by
migratory interests - Management body may tend to become a
"talking shop" - Alters psychological ownership of
freshwater fisheries management, risking
loss of voluntary effort and
investment. Will be difficult to completely
eradicate historical lack of mutual trust
between freshwater and migratory interests
in some locations |
Option 4 - Centralised Control - "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.)
Strengths - Ability to apply more
consistent management - 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 | Weaknesses - Absence or dilution of local
representation - Very high cost - Bureaucracy - Loss of control at
catchment management level - Lack of public
support - Dissatisfaction with
existing systems in England and Wales
(EA) - 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 | Opportunities/resources
required - Potential to take strategic
"all-Scotland" view of fisheries
management - Ability to apply consistent management
practices - Capacity to deploy resources where
they are most needed Capacity to draw in additional public
investment according to need - Probably attract most
buy-in from public sector - 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. | Threats - disenchantment within
fishery owner network - lack of credibility - High proportion of new public
investment absorbed in cost of establishing
and running new agency (or expanding SEPA)
rather than management on the ground - Tainted by general dissatisfaction
with existing systems in England and Wales
(EA), leading to lack of public /
stakeholder support Minimal psychological ownership - would
undoubtedly reduce voluntary effort and
private investment |
Option 5. 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 practice)s.
Strengths can develop in tune with local
situations and priorities. - Retains, 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 | Weaknesses - 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 | Opportunities/resources
required - Structures can develop in tune with
local situations and priorities. - 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 System could be enhanced by
strengthening the fisheries trust network
to deal with other fish species issues and
modernising the PO system to deal with
access and management issues without
fundamentally altering current system | Threats - Continued lack of engagement by public
and political sectors - Lack of public support/buy-in Reliance on income from fisheries which,
with fisheries in decline, results in
reduced investment when most needed. |
Option 6. 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.
Strengths - Minimises change to the existing DSFB
system, largely retaining strengths of
current migratory fisheries management
structures - Retains management at a local
level - Retains local representation - Co-ordinated approach - Data-collection should become
universal and consistent. - Creates potential for
cross-subsidisation | Weaknesses - 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 - creates potential for
cross-subsidisation (Migratory) - Difficult to achieve flexibility in
representation to reflect circumstances on
the ground - Difficult to expand Boards
sufficiently to be representative while
keeping them small enough to manage - Difficulty in developing expertise - No pre-existing way to fund management
of species which generate little or no
income | Opportunities/resources
required - 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? - Improve level of political and public
sector support for management structure
while retaining local management
control - Relationship with Trusts could become
much closer - May be able to raise funds through
area permit system - In many locations could build on sound
current relationships to reduce
discontinuity arising from change. | Threats - Likely to suffer from conflict between
species management - Perceived danger of domination by
migratory interests - Board may tend to become a "talking
shop" - Alters psychological ownership of
freshwater fisheries management, and thus
risks loss of voluntary effort and
investment. |
Option 7. Nationalisation
Take all fisheries, freshwater and migratory, into
direct state control.
Strengths - 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 - Perceived scope to increase and
guarantee access | Weaknesses - 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 - Loss of control at catchment
management level - Absence of stakeholder support /
participation Possibly subject to legal challenge | Opportunities/resources
required - Potential to take
strategic "all-Scotland" view of fisheries
management - Ability to apply consistent management
practices - Capacity to deploy resources where
they are most needed Capacity to draw in additional public
investment according to need - 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. - 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 to replace
all current voluntary and private
sector investment in fisheries - Need to establish a funding stream
from freshwater anglers | Threats - absence of psychological ownership
would eliminate voluntary effort and
investment High proportion of new public investment
absorbed by administrative overheads and
compensation to riparian owners rather than
management on the ground - Politically hugely controversial and
would destroy much recent progress within
and between angling sectors |
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4. Assumptions
An assessment of the strengths, weaknesses and
opportunities of each model are listed above. A number of
assumptions were made when considering which of options 1 -
7 may best lend itself to achieving the objectives alluded
to in 2. above. These assumptions are:
- that the current system of management of Scottish
freshwater fisheries can be improved on.
- that protecting the status quo is neither desirable
nor defendable.
- that some form of change is likely to be demanded
by the Executive, the public and Parliament. I think we
might be over-egging it here. The public at large is
probably blissfully unaware of the current situation,
and I've certainly never heard the slightest suggestion
that they are "demanding" change. Even the angling
public is not exactly baying for new structures. Like
it or not, most of them probably just want more stock
fish.
- that we wish to retain the strengths of
catchment-based fisheries management in Scotland and
that some form of integration of management of all
freshwater fisheries/fish stocks is desirable. I
appreciate that we are trying to preserve catchment
level management of migratory species, of course, but
for freshwater fish we are not talking about
"retaining" catchment management so much as introducing
it. Surely that's actually part of what we are seeking
to achieve?
- that to develop a parallel structure for managing
fisheries other than salmon and sea-trout would lead to
considerable confusion and that a centralised
Environment Agency approach, such as is present in
England and Wales, is unlikely to satisfy the
principles listed above I don't think these should be
portrayed as "assumptions". They suggest we have
pre-judged the analysis. In truth, they are
"conclusions". I don't entirely diagree with them, but
this should emerge from the SWOT rather than being
portrayed as a priori principles of it. I think this
bullet point is covered adequately in the section which
follows, ansd suggest it should be removed.
- that any new system should retain all the strengths
of the existing system of migratory salmonid management
and ideally improve on it as well as ensuring the
sustainable management and use of all fish stocks and
fisheries in Scotland
- that income from migratory salmonid management
should not cross-subsidise other species management any
more than it is doing so at present.
- that the above assumptions are based on the
requirement that adequate funding can be sourced from
both the public and private sector to pay for these
management systems on a long term and sustainable
basis
Based on the above assumptions, and taking into account
the aspirations and objectives of the sector, the Sub Group
agreed that:
Option 1 - Retention of the status quo,
would fail to deliver what the stakeholders - the anglers,
managers, public agencies and politicians - want. There is
at present little political support for continuation of the
current system. There is a fundamental vacuum in management
for freshwater species and there is a ministerial
commitment to address access (we acknowledge that access is
being addressed separately but for the purposes of this
process we strongly believe it must be tied together with
management in view of the need for access to depend on
sustainable fisheries).
Option 2 - A parallel structure, would
create yet another organisation. This would result in
duplication of effort where resources are already thin on
the ground. This would be untenable and support for an
additional tier of management would be extremely hard to
source. Furthermore, co-ordination between the
organisations would add a further burden to already
stretched resources and would further compromise the
ability of both bodies to achieve the objectives in 2.
Option 3 - A unitary structure, is the
option which the Group felt could deliver most effectively
the objectives above, as well as commanding the most
support from the stakeholders. Our rationale is provided at
the end of this section.
Option 4 - Centralised control, is very
much how fisheries managed in England and Wales through the
national Environment Agency. This type of structure would
not lend itself easily to the existing legal framework in
Scotland, and the Sub Group identified a number of issues
associated with this approach, such as very high cost and
level of bureaucracy, loss of control at catchment
management level and high prospect of little public
support. One element of the English system which does merit
further discussion is the revenue raising power conferred
by rod licensing and this is addressed in section 4.,
funding.
Option 5 - Stimulated evolution, is an
interesting concept and one which we would not wish to
discount out of hand. It is a concept which could
complement the development of a unitary structure, using
the best of existing structures and aiding development,
through incentives and examples of best practice, and
including all stakeholders. Such a concept would allow
developments to take place in tune with local circumstances
and priorities through positive means, with a legislative
backstop where necessary.
Option 6 - Expanded Salmon Fisheries
Boards, whilst appealing to some interests, would not
provide a politically acceptable solution. There is a
strong perception (and likely reality) that an expanded
Board would retain a prime interest in salmon fisheries. It
would be difficult to arrive at a compromise whereby all
interests were happy in terms of representation and voice
on the Board, revenue generation for each fishery component
and disbursement of funds in a fair way. The' psychological
ownership' of freshwater fisheries management would be
altered, and thus risks loss of voluntary effort and
investment. The Sub Group also recognised the strong
historical lack of mutual trust between freshwater and
migratory interests in some locations.
Option 7 - Nationalisation, would be a
very radical move. Ideology aside, such a concept would be
enormously expensive to the State in acquiring ownership of
all fishings. Such a system would mean management decisions
would be subject to political debate, resourcing dictated
by political priorities rather than actual need and there
would be a widespread lack of credibility between owners
and the state management. Nevertheless, we acknowledge that
there are some proponents of nationalisation but we believe
that this is unlikely to command widespread support.
Conclusion:
It is being assumed therefore that a unitary system of
management is the preferred option, taking into account the
merits of stimulated evolution in developing such a
system.
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5. Options for Funding
As suggested above no new management system can be
expected to operate without sufficient long term
core-funding. Unless such funding can be sourced the
sub-group believes that there is little point in further
discussion of the ideas listed above.
Sufficient funding is available from two principle
sources:
The public sector - through block grant,
project finance etc. from SEERAD, SNH and SEPA
The private sector - through some form of
enforced contribution from anglers
The sub-group recognises that the current system of
raising funds for the management of migratory fisheries
through the system of statutory levies on proprietors based
on rateable value, whilst having certain flaws, is a system
that has proved robust, workable and proportionate. The
sub-group therefore has concluded that this system should
be retained and incorporated into any new management
structure.
However, the additional responsibilities of a new
management structure as proposed above will require further
and substantial funding. This could be made available in a
number of ways. The sub-group has considered the following
options:
Option 1- Status Quo
Angling clubs and proprietors, acting
individually or in groups, employ a disparate
mix of approaches to raise money. The levels of
funding for management varies from nothing at
all through to fully commercial operations
where management costs are an integral part of
business overheads. Public funding, where it
takes place, tends either to be in the form of
small-scale support for publicly owned amenity
fisheries or grant aid for specific projects,
largely conservation-based.
Strengths investment made in response to perceived
needs and/or commercial demand financial input supplemented by
voluntary manpower from angling clubs and
syndicates substantial private expenditure on some
fisheries support for initiatives such as
scientific fisheries trusts in some
areas growth of fisheries trust network has
enabled and encouraged many clubs and
proprietors to manage more effectively /
cost effectively | Weaknesses major gaps and inconsistencies management and/or data collection
largely disregards species of little or no
interest to anglers clubs and proprietors tend only to fund
management activities perceived to serve
their own priorities where revenue does not fund sound
scientific advice, management activities
can be inefficient or ineffective some of the "management" of freshwater
species takes the form of control measures
aimed at improving migratory fisheries | Opportunities Improved PO system could create scope
for more revenue to be raised from
freshwater fisheries and thus make it more
attractive for clubs and proprietors to
invest in longer term management
activities the level of investment might be
improved by educating and informing clubs
and proprietors in the benefits of
appropriate management and encouraging them
to invest accordingly | Threats declining revenue to clubs &
proprietors may reduce management at the
very time it is most needed perceived decline in sport can prompt
inappropriate short term management
measures pressure to keep down the cost of
permits or club subscriptions leads to
under-investment in appropriate management,
and to short-term rather than long-term
measures |
Actions to develop as a national system of
funding: No apparent possibility of developing in
a way which would ensure adequate, consistent and universal
coverage
Option 2 - Voluntary Donations
Funds raised from private or corporate
donors.
Strengths Established as a significant source of
revenue for fisheries trusts Can offer access to tax benefits
associated with charitable donations,
landfill credit etc Voluntary nature of donations creates
accountability to deliver what the funders
want | Weaknesses no guarantee that amount of money raised
will meet the cost of appropriate
management activities disproportionate amount of time, effort
and resources absorbed in fund-raising uncertain flow of income makes it
difficult to plan ahead. major gaps and inconsistencies | Opportunities clubs, proprietors and fisheries trusts
can continue to encourage voluntary
donations as one of several sources of
support level of investment might be improved by
providing clubs and proprietors better
information about potential sources of
voluntary donations and enhancing their
fund-raising skills | Threats May concentrate management on activities
that best serve the interests of the
largest donors rather than activities that
benefit the fishery as a whole. Level of funding vulnerable to changes
in wider economic conditions and / or
fiscal incentives Pool of potential donors may be limited
- any attempt to exploit further may simply
spread contributions more thinly |
Actions to develop as a national system of
funding: No apparent possibility of developing in
a way which would ensure adequate, consistent and universal
coverage
Option 3 - Area Permits
A single permit allowing the purchaser
access to a group of fisheries owned by several
proprietors. The "area" concerned may be
anything from a fairly small locality to an
entire catchment or a geographical region.
Funds raised from permit charges, after
expenses, are aggregated and reinvested in the
management of the fisheries in the
area.
Strengths Well-established as the norm in Europe
and North America, and appears to work in
those countries A few successful small-scale examples
already operating in Scotland Provides economies of scale in
administration and enforcement Creates scope for more strategic and
co-ordinated approach to management Can improve sustainability by
encouraging anglers to use all the
fisheries in the area rather than
concentrate on particular "hot spots" | Weaknesses the great majority of fisheries are
already privately owned and run, and there
is little evidence of a widespread desire
for a collective approach the strength of the link between
riparian land and fishery ownership tends
to promote individual approaches Individual clubs or proprietors can
block the creation of viable groupings of
fisheries or fragment them by pulling out
of established arrangements Many clubs & proprietors resist
pooling of revenue and loss of personal
control from joint decision making | Opportunities Improved PO system, if structured
accordingly, could stimulate development of
area permit arrangements in additional
localities in Scotland | Threats May create perverse incentive for some
clubs or proprietors to "go it alone" by
offering more favourable terms or less
restrictive regulations |
Actions to develop as a national system of
funding: It is difficult to envisage any way to
ensure consistent and universal coverage short of taking
all freshwater fisheries into public ownership or making
the establishment of area permits mandatory.
Option 4 - Rod Licences
A statutory charge which anglers have
to pay before they can fish lawfully with rod
and line in any freshwater. The charge is
separate from, and additional to, any permit
fee to fish a particular water, and applies
even where the angler himself or herself is the
owner of the fishing rights.
Strengths Well-established means of raising funds
(around £18 M pa gross) from anglers in
England & Wales Equity in level of anglers'
contribution system is universal and consistent clear, simple and readily understood can attract substantial levels of
compliance would be readily accepted by visiting
anglers - most of whom expect to have to
pay for this kind of licence Creates scope for a strategic and
co-ordinated approach to management | Weaknesses no tradition of rod licencing in
Scotland current provisions in E&W are
fundamentally flawed in many ways, and are
not well loved by anglers clubs or proprietors who believe they
already raise sufficient for the management
of waters they control tend to perceive
this as all cost and no benefit for their
clients / members anglers who purely use commercial or
well-funded club fisheries would be funding
the management of fisheries in which they
have no interest | Opportunities Adopting the concept of 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. | Threats Collection and enforcement costs can be
substantial (understood to be between 20%
and 25% in E&W) Risk that money raised centrally would
become a substitute for, rather than a
supplement to, existing sources of funding
and voluntary effort |
Actions to develop as a national system of
funding: Primary legislation would be required to
establish a statutory rod licence. Machinery would have to
be put in place to collect and disburse the revenue
concerned, and to enforce compliance.
Option 5 - Levy on proprietors
A statutory "rate" on the notional value of
each fishery. The value may be calculated with
reference to variables such as catch levels. Funds
raised from the "rate", after expenses, are
aggregated and reinvested in fisheries management
at catchment, regional or national level.
Strengths Long-established and largely effective
means of funding Salmon Fishery Boards. Best suited to situations where
management actions in one proprietor's area
of the fishery have a substantial impact on
others can be taken into account when setting
permit charges, and thus passed on to
anglers. | Weaknesses Most freshwater fisheries do not possess
the characteristics that lend themselves to
this approach in respect of migratory
fisheries An extra tax on commercial fishery
owners' business, many of which are
marginal and already face decline in
revenue As freshwater fishery rights are closely
tied to land ownership, would also
effectively be a tax on land would raise funds from commercial
fishery owners' businesses to subsidise
other providers in direct competition with
them - ECHR implications? | Opportunities Voluntary levies (Option 2) may allow stakeholders in
particular localities a way to raise money
for projects or activities that cannot
otherwise be funded | Threats cost of establishing and maintaining
database of fishery ownership and valuation
arrangements cost of collection and enforcement |
Actions to develop as a national system of
funding: Primary legislation (probably outwith the
scope of fisheries legislation) would be required to
establish a levy and a system of valuation. All riparian
proprietors would have to be identified, their fisheries
evaluated to assess fair contributions, and machinery put
in place to collect and disburse the revenue concerned.
Option 6 - Permit levy
A proportion of the cost of all fishing permits
sold. Funds raised from permit levies, after expenses,
are aggregated and reinvested in reinvested in
fisheries management at catchment, regional or national
level.
Strengths some quite successful small-scale
examples already exist in Scotland can work in certain circumstances, as
long as there is general support for the
concept superficially fair for anglers - those
who fish most (and therefore benefit most)
would pay most. potentially transparent - the money
raised from a particular branch of angling
or a specific fishery can readily be
identified | Weaknesses problems assessing appropriate
contribution where club subscriptions give
access to fishing but also fund other
activities, or where hotel accommodation
charges include provision of fishing for
guests would function as a de facto tax on
commercial fishery owners' and hotel
owners' businesses would raise funds from commercial
fishery owners' businesses to subsidise
other providers in direct competition with
them - ECHR implications? anglers who purely use commercial or
well-funded club fisheries would be funding
the management of fisheries in which they
have no interest | Opportunities Improved PO system, if structured
accordingly, could stimulate development of
localised permit levies as a means of
supplementing core funding in some
catchments or groups of fisheries | Threats very high risk of avoidance where the
person or body running the fishery isn't
fully on board cost of establishing and maintaining
database of fisheries cost of collection and enforcement |
Actions to develop as a national system of
funding: Primary legislation would be required to
establish a statutory levy and a graduated system of
contributions. All riparian proprietors would have to be
identified and machinery put in place to collect and
disburse the revenue concerned.
Option 7 - Levy on sales of fishing tackle
A proportion of the cost of all fishing
tackle sold in Scotland. Funds raised from the
tackle levy, after expenses, are aggregated and
reinvested in reinvested in fisheries management at
catchment, regional or national level.
Strengths superficially fair for anglers - those
who fish most (and therefore buy most
tackle) would pay most. Tackle trade currently benefits - albeit
indirectly - from investment in fisheries
management, but contributes little or
nothing to support it. | Weaknesses An extra tax on fishing tackle dealers'
business, many of which are marginal and
facing a decline in revenue already considerable problems assessing
contribution where goods sold in tackle
outlets have uses outwith angling, or where
"general" retailers sell a few items of
tackle much of the expenditure by Scottish
anglers on fishing tackle is through mail
order / Web-based suppliers, many of which
are based elsewhere in the UK or further
afield levy would create business disadvantage
for several major Scottish tackle dealers
who have mail order / Web-based businesses
which sell throughout the UK or further
afield - ECHR implications? | Opportunities More scope may exist to encourage
voluntary contributions from the
fishing tackle trade (Option 2) to raise
money for projects or activities that
cannot otherwise be funded | Threats very high risk of avoidance would tend to divert spending on fishing
tackle to suppliers outside Scotland cost of establishing and maintaining
database of fishing tackle outlets cost of collection and enforcement |
Actions to develop as a national system of
funding: Primary legislation (probably outwith the
scope of fisheries legislation) would be required to
establish a statutory levy. All fishing tackle outlets
would have to be identified and machinery put in place to
collect and disburse the revenue concerned, and to enforce
compliance.
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