SFFF SG 6-3a: Section 30 - Equivalent Regulations
Possible options - in addition to existing fish health
provisions:
1. Those persons, including angling clubs or
associations, who wish to introduce fish into an inland
water from another water should obtain the prior written
consent of the appropriate management body, who should
require that a risk assessment be undertaken by the
proposer.
Agreed
2. Suppliers of fish should be registered and provide
appropriate certification with respect to the provenance
and health status of any fish sold for stocking.
Agreed with the following suggestion
In addition, the legislation should also make
provision - subject to appropriate ad hoc health
checking and the suitability of the recipient location
- for the movement of fish from sources other than
commercial suppliers. Otherwise it would prevent the
rescue and relocation of stocks where waters are being
drained or turned over to commercial fisheries.
3. Detailed movement records should be maintained by
suppliers and the management authority, and these should be
available for inspection.
Agreed
4. The offence should attract appropriate penalties
(fine up to Level 4 on the standard scale (up to
£2500)?).
Agreed - would be useful to have more
knowledge of scale applicable to comparable
offences.
5. In the case of established put-and-take fisheries, a
general licence may be issued to reduce the administrative
burden on such businesses.
Agreed Qualified agreement.
Should not be limited to "put-and-take" or
commercial fisheries - apply also to established
fisheries (eg angling club waters) with approved
stocking practices and appropriate containment measures
in place. Also, certified copies of the paperwork in
relation to health status should still accompany the
load/stock
6. In the case of ornamental fish traders, and
aquarists, a general licence may be issued to reduce the
administrative burden on such businesses.
Comments -
Appreciate the commercial issues involved, but have
some concerns. The release of "ornamentals" has been a
significant vector for introductions in the past, and
indeed may be the true source of some introductions blamed
on anglers. Would need to be supported by rigorous controls
and monitoring
Agreed with some afore mentioned
condition with some afore mentioned conditionwith some afore mentioned condition
Guidelines should be established so
that:
1. Stocking should be permitted where there is no
significant risk of ecological detriment to the donor
waters or receiving waters and where there is demonstrable
environmental, economic or recreational advantage.
Agreed
2. Stocking should not normally be permitted in waters
with established fish populations where it is not currently
practised and has not been in recent years - except where
this is needed to restore depleted populations or mitigate
the effects of e.g. loss of spawning habitat.
SFCA -Not necessary - consideration in Item 1
above provides sufficient protection.
SANA -Agreed
3. Where recreational pressures argue for stocking to
sustain populations or to create new fisheries, decisions
on whether to allow movements and introductions should take
account of the existing populations, carrying capacity and
the current and proposed management regime.
SFCA -
Not necessary, except perhaps as an amplification of
how to go about assessing some aspects of the risk of
"ecological detriment" as referred to in Item 1
above.
SANA -Agreed
4. Fish should not normally be introduced into waters
outwith the natural range of the species or into new
catchments within their existing range.
SFCA -
Not necessary - consideration in Item 1 above provides
sufficient protection.
SANA - Agreed, we do not want game fisheries
stocked with coarse stock where there was no history of
such stock
5. Reintroduction of fish which are no longer present in
a catchment should be permitted only after an assessment of
the likely environmental effect of the reintroduction.
SFCA -Not necessary - consideration in Item 1 above
provides
sufficient protection.
SANA -Agreed
6. Where fish are to be introduced to holding
facilities, such as a fish farm or transit station,
adequate safeguards to minimise the risk of any escape of
fish should be in place before fish may be introduced.
Agreed- but there were some concerns. Escapes from
aquaculture facilities are presently the single largest
source of unplanned introductions, and are far more
numerous and damaging than introductions made by
anglers. Would need to be supported by extremely
rigorous controls and close monitoring.
It was also commented that this should also apply
especially to "Salmon Frming" smolt rearing operations
in freshwater lochs and also to salmon cages in coastal
waters.