12 April 2015 News/Editorial
Those who know me might say many things, but that I am naturally angry is, I hope, not one of them.
Yet I find myself, of late, permanently angry with what is happening in the Scottish salmon fishing world, and the new (yes yet another) consultation referred to in the paper from Nick Yonge/ the RTC below (please read it and respond as advised, if you can face it).... is a perfect demonstration of why.
If you go to page 91 of the SEA (Strategic Environmental Assessment) on the proposals for licensing to kill and carcass tagging of salmon, and the first 2 paragraphs under “Will the proposed conservation measures safeguard…..”, the assessment concludes that licensing and carcass tagging will safeguard spring fish which are caught later in the season after 100% catch and release ends.
What this is saying is that, on the Tweed where 100% catch and release applies up to 30th June, springers caught after 1st July will be protected by bringing in licensing to kill and carcass tagging.
But how?
Let us assume that I am fishing here in August, that I have both a Lees beat “licence to kill” and a quota and carcass tags (heaven forbid, but for this assumed scenario only) and I catch a salmon which is clearly an old springer (for those who do not know, they go a combination of black, red and yellowy green in colour and cannot really be mistaken for anything else but an old springer).
Now, if I am an environmental vandal (I am not), with a licence and quota/carcass tags (which I would have), what do these do to stop me killing it? If I kill it and attach a tag, it is perfectly legal…..so the existence of licensing and carcass tagging does exactly nothing to protect it!
What does protect it, now and in the future, are three things; first, it is most unlikely to be caught because old springers become increasingly reluctant to take a fly or other lure (especially with the banning of worming and prawning); secondly, it is illegal to kill “unclean and unseasonable” fish and an old springer in late summer and autumn is clearly that, so it is an offence already to kill it; and, thirdly, anglers now are incredibly aware of the need to return salmon, so why would anyone kill an old and inedible salmon (it is illegal to sell it) in August in the first place?
Indeed, I would go further that by putting a tag on a (killed) old springer, which would otherwise be illegally killed as being “unclean and unseasonable”, the tag gives it a certain legitimacy which at present, without any tagging system, it will never have.
The conclusion of the SEA on protecting vulnerable stocks, like springers, is therefore incorrrect, both because it comes to the sort of lazy conclusion you come to if you do not really think through the full implications, and because it is easier for the consultants carrying out the SAE to agree with the proposition rather than take the brave decision and disagree with it, because it is fundamentally flawed.
Some might question if it is really a fully independent review, or if it is carried out in the knowledge of the way the political wind is blowing……….you might say that, I could not possibly comment.
Please read the Tweed Foundation response below; thank heavens for RTC and Tweed Foundation common sense and sound science, but will anyone listen?
We can only hope so.
Please give any help you can give in responding to either or both of these consultations, as the full RTC/TF message, from Nick Yonge below, indicates.
It is hugely appreciated.
Thank you.
TO: All River Tweed Commissioners and Tweed Foundation Trustees/
Copy to Tweed proprietors/Fishing Agents
FROM: N Yonge
Since my last email to you, the Scottish Government has now issued a second consultation on licensing, so there are two consultations.
1. Kill Licence Consultation – (sent previously)
This is a public consultation on statutory measures to introduce a licensing system for killing wild Salmon with associated carcass tagging, baits and lures regulations and a provision for charging. It asks six questions and the email I sent gave the RTC position on each question.
2. Strategic Environmental Assessment Report – second (NEW) consultation
This report sets out the results of the possible environmental effects of the proposed licensing system. This is a new consultation. It is very long and is mostly a briefing paper on Salmon knowledge. It has only one question which asks for comments on the report. However it is important, especially section 8 starting on page 53. Our observations are on the following sections:
5.1.23 We disagree that catch and release inflates the reported rod catch data.
Marine Scotland’s modelling is: purely theoretical, uses assumptions we do not believe are valid and is contrary to Tweed’s own research which uses actual data. Tweed’s data from tagged fish shows that the catchability of Salmon declines rapidly once they are in fresh water so few are caught after more than two months in the river which limits the chances of recapture, especially when added to the “shock” of capture, which must also delay any recapture.
8.1.1 We disagree that only protecting spring stocks, as we already do, should be discounted as it would not act to protect other stocks or spring salmon later in the year.
Again, Tweed data shows:
1. less than 5% of fish are killed by rod and line, in most years significantly less
2. that catchability of fish declines rapidly once they are in fresh water, so that few are caught after more than two months in the river
3. the nature of the fish caught by rods changes markedly after June - Grilse and Summer Salmon take over from Spring Salmon as the source of the catches. Spring Salmon are therefore unlikely to be caught after the period of C & R to protect them ends but even if they are:-
a. they could still be killed under the proposed licencing system although,
b. the existing legal ban on the killing of “unclean and unseasonable” fish would still protect them, as it always has.
8.1.3 We disagree that a licence system would reduce the risk of rivers failing to reach their conservation limits
There is no recognised method of calculating Conservation Limits for Scottish rivers. In England and Wales, Conservation Limits are used only to provide threshold targets for management purposes, not for determining the number of Salmon that can be killed because their accuracy is not good enough for this. Conservation Limits are based on retrospective data so they cannot give any protection if there is an unanticipated poor run ( “Past performance is no guarantee of future results.”)
8.1.4 We disagree that the proposed measures around gear (rod and line tackle) would increase the survival rate of Salmon caught using catch and release strategies over those that already exist in the Tweed; there is no evidence for this.
8.3.1 We disagree that licencing the rod fisheries would give benefits to, and improve the sustainability of, Scottish Salmon.
Too small a proportion of the fish coming in to Scottish rivers is killed by anglers for the reduction in such killing to have any effect. In Autumn, too, most fish killed are males, females being protected by angling custom. There is no evidence that the present rate of killing is having any effect on the numbers of juvenile Salmon being produced in Scottish rivers. On the contrary, the work being done by Fishery Boards and Trusts throughout the country has increased juvenile production, mainly through the removal of barriers to spawning fish increasing the area of spawning ground.
8.3.2 We do not agree that the iconic status of the salmon would also be more likely to be secured by a licensing system; indeed it may well be damaged though a negative impact on the angling sector.
Both consultations can be found on the Government’s website HERE; this has now been made more straightforward to understand. Some people have found difficulty in filling out the forms. You can only respond in this way if you have a copy of Word or an equivalent program installed on your computer or device. Printing out the form doesn’t work because the boxes are too small, so if you don’t have a suitable computer program the only other way of responding is to answer the questions in plain text, either in a letter or in an email.
I met with the Scottish Government yesterday and they say they are receiving responses, which is good. However, they are also receiving letters which do not answer the specific questions which they have posed. It is very important that responses address the specific questions (six in one consultation and one is the other): simply agreeing with the RTC position or giving a tirade will not be given credence.
In addition to the RTC’s draft response which I sent to you in my last email, the Tweed Foundation has also published a paper addressing the conservation case on the proposed ban on rod fisheries. This is an objective position aimed to assist the understanding of the proposal. It can be read HERE. Separate from the case for controlling the exploitation of mixed stock fisheries, it concludes that restricting the numbers of adults killed by anglers under the proposed licence system could not have any conservation value. Please pass this on to anyone who may be interested.
RESPONSES TO BOTH CONSULTATIONS ARE REQUIRED BY APRIL 30TH. Please respond if you have views on this proposed ban on killing Salmon.
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