Deputy Minister for Rural Affairs
John Home Robertson MP MSP
To: Interested Parties
Dear Sir/Madam
Scotland's natural environment attracts international acclaim. The range of flora and fauna inhabiting a landscape largely unspoilt by the action of mankind serves as a magnet for people from all over the world. It provides those of us fortunate enough to live here with a unique asset to enjoy, but it also places an obligation on us to look after that asset for the enjoyment of future generations.
In Scotland we have 139 candidate and proposed Special Areas of Conservation (cSACs and pSACs) and 116 classified and 23 proposed Special Protection Areas (cSPAs and pSPAs). Some 1450 sites have been declared as Sites of Special Scientific Interest (SSSIs).
The designation of further sites is currently under consideration. In addition the Scottish Executive is now preparing legislation to designate the first National Park in Loch Lomond.
Whilst much attention tends to focus on our magnificent tracts of land, mountains and great lochs, less interest tends to be shown in another great asset which makes an important contribution to our environment and the life that it supports. I am referring to our system of rivers.
Nobody in Scotland is ever very far from a river, stream, loch or pond. Scotland has over 50,000 kilometres of rivers and more than 30,000 lochs and ponds. Amongst these are some 400 rivers that are home to Scotland's world famous Atlantic salmon and sea trout. Many other lesser known, but also important, fish species share these waters and, of course, rivers provide a source of great enjoyment to many people, particularly anglers.
It is little wonder, therefore, that there have been growing concerns about our freshwater fish stocks, about the management of our rivers, and about general access to the rivers for recreation and other uses.
It was against that background that I instructed my officials in the Scottish Executive to work with Scottish Natural Heritage to produce a Review setting out the facts about our fish and fisheries and highlighting the issues which currently affect them. The attached Review "Protecting and promoting Scotland's freshwater fish and fisheries" is the outcome. It can also be found on the Scottish Executive Internet site at www.scotland.gov.uk.
I would welcome views on the Review from groups and individuals with an interest in what it covers. Individual chapters of the Review conclude with a short summary of the issues involved, but in offering comments you should not feel constrained by these summaries. However I would particularly welcome comments on the following specific matters:
Conservation
Crucial to opening up angling opportunities is the availability and sustainability of the fish resource. Conservation is central and raises issues about management, about improving knowledge about fish resources, about the prevention of over-exploitation and the proper exercise of best practice, such as catch and release. The question therefore has to be how the appropriate balance between management for conservation and exploitation is to be struck, and which stakeholders it should involve?
Whether fish are fished for or not, Scottish Ministers have biodiversity obligations which involve protecting the fish, their habitats and their native predators.
In what ways might we be able to improve upon existing protection mechanisms for important sites and species?
Increasing Angling Opportunities
Feedback on the adequacy of angling opportunities is mixed. Some claim that opportunities are plentiful but are simply not well enough publicised. Others are more sceptical.
We have already announced our broad plans for increasing access to the countryside. Can we go further with angling? If so, how should this be funded?
If adequate angling is available, is the issue really one about better information? Is there more of a role here for angling clubs or the Scottish Anglers National Association? If there is scope for more use of the Internet to reach some potential anglers, what are the alternative means for reaching others who do not currently have access to the Internet?
And is there potential to develop existing or establish new fisheries? If so, where should this happen, and what are the main issues to be addressed before embarking on such a strategy?
Management of Fishery Resources
Much of Scottish freshwater fishing legislation is dominated by salmon. The only management structures in place (other than for Protection Orders) are the District Salmon Fishery Boards (DSFBs) - and their coverage of Scotland is incomplete. The consequence of this is that management of other fish species is left to riparian owners or angling associations. Too often it goes by default. The 'Angling for Change' partnership highlighted this as a concern.
This prompts the question about who should be responsible for other fish? Should the responsibilities of DSFBs be extended, as was mooted in the Scottish Salmon Strategy Task Force Report, or should a new body be created, or should SNH or local authorities have a role? Should we seek to achieve more broadly-based fishery management bodies, and if so how?
A point to bear in mind is that in England and Wales management is exercised by the Environment Agency alongside their other responsibilities. This requires Grant-in-Aid and there is a system of national rod licences. How would the funds for a changed regime in Scotland be generated?
Introductions and transfers of non-indigenous species
Concern has been expressed about the spread of fish species that are not indigenous to Scotland. But the reality is that these were probably introduced by anglers in the first place, albeit innocently.
More strict legislation to prevent this is one possibility, but how enforceable would it be? Failing that, what additional means are available to protect rare or endangered species?
Protection Orders
There are currently 13 Orders in operation. Reaction to them is mixed: some see them as providing protection to the various fish species while offering enhanced angling opportunities; others see them as divisive and serving only to exclude anglers.
A Task Force report published in 1999 suggested that, by and large, the system was working reasonably well and that fishing opportunities were available but, as touched on above, were simply not being taken up.
The granting of Protection Order status is conditional upon the owners of fishing rights increasing angling opportunities. What should be done if access to anglers is not provided as expected?
If you wish to offer views on the Review and/or on the foregoing questions, please write by 4 August 2000 to Ms Fiona Currie, Scottish Executive Rural Affairs Department, Room 408A, Pentland House, 47 Robb's Loan, EDINBURGH EH14 1TY or send your response by email to: fiona.currie@scotland.gov.uk.
As is normal practice with consultations, a copy of your response will be made available to Parliament, and to the public on request, unless you specify that you wish all or part of it to remain confidential. All responses will, however, be counted for the purposes of the published total of responses.
I look forward to receiving your comments in due course.
Yours faithfully
John Home Robertson signature
JOHN HOME ROBERTSON
A cursory glance at a map of Scotland reveals that nobody can ever be very far from a river, stream, loch or pond. Scotland has over 50,000 km of rivers and more than 30,000 lochs and ponds. Many of these waters support populations of fish which, in turn, support world-renowned fisheries. Most of the water is of very high quality but the freshwater environment and the fauna it supports can be affected by a number of factors, many of them associated with Man's activities, be they work or play.
Fishery management must co-exist with farming, forestry and other land and water uses, with each evolving in different ways. In recent years, demand has increased for angling opportunities, as it has for other outdoor leisure pursuits. At the same time there has been a growing awareness of the importance of protecting fish as part of the aquatic flora and fauna. Fish and fisheries therefore face new pressures. Not least of these is the decline in populations of several important species, most notably salmon, where the immediate challenge is one of striking a better balance between exploitation and conservation. All of these factors underscore the need for sustainable fisheries management that is able to reconcile sometimes conflicting pressures. After all, there can be no fishery without fish.
A number of interests, ranging from central Government to private individuals, are charged with different aspects of the management of Scottish fresh waters and the fish they support. Given this broad community of interest, any consideration of appropriate management structures and priority issues to be addressed requires close consultation with all those who will be affected.
Against this background, John Home Robertson MP MSP, Deputy Minister for Rural Affairs, commissioned the Scottish Executive Rural Affairs Department (SERAD) and Scottish Natural Heritage (SNH) to work jointly on the production of this paper. Intended as an overview of the factors that affect freshwater fish and fisheries, its purpose is to provide the starting-point for an assessment of how best to plan for the future.
April 2000