Nith District Salmon Fishery Board’s response to the revised proposals for the conservation of Atlantic salmon (Kill license)

This response is made on behalf of Nith District Salmon Fishery Board to the Scottish Government’s request for a response to its revised proposals on conservation of Atlantic salmon.

The Board is pleased that Scottish Government has decided to consult on an approach to salmon conservation that will hopefully be more focused on the requirement to preserve and enhance the welfare of the species.

The Board welcomes the opportunity to respond in respect of the proposed conservation measures for salmon. In essence this has for many years been its primary legislative function.

The Board is constituted by a membership that represents angling proprietors, netting proprietors, anglers and tenant netsmen. The Board convened an extraordinary meeting to discuss the latest conservation proposals and so the views expressed were naturally varied. This document attempts to provide a response on the consensus that was reached on what the Board considers to be the most important issues relating to salmon conservation policy in the future.

The Board hopes that this is the first in a series of steps that are urgently required to deal with the fall in numbers of surviving adult salmon returning to natal rivers to breed.

The need for conservation

The Board has been encouraged by the adoption of voluntary catch and release of salmon and sea trout on an increasing trend over the last few years, in line with the Board’s Fishery Management Policy.

There can be no doubt that urgent measures are required to seek to preserve and protect salmon, not only in fresh water but in relation to all aspects of the geography and biology of their life cycle. The salmon has significant importance as an indigenous and iconic species to Scotland and for the economic benefit that its presence provides to Scotland in a number of well known respects.

There is merit in identifying and categorizing water courses that are known to support the presence of salmon in the fresh water phase of their life cycle to determine whether it is necessary to restrict the exploitation of what is a natural resource.

The Board supports completely the need to adopt restraint in respect of such exploitation in order to preserve and enhance the survival of the species, provided that the categorization of these water courses is based on sound science and data collected in a manner and by methods that are wholly relevant to properly establishing that sustainable numbers of wild salmon are returning to natal rivers to breed and juvenile stocks are surviving in an optimal fresh water environment to migrate to sea and grow to maturity.

However to predicate the categorization on the previous five years catch statistics returns and seek to apply such classification to all Scottish Rivers is both flawed and inadequate for a number of reasons, some of which, put briefly are as follows:-

Catch Statistics returns are notoriously inaccurate and it is the view of the Board that the numbers of salmon caught and declared for catch statistic purposes are considerably suppressed.

The number of salmon caught and declared has a direct bearing upon establishing the rateable value of a fishery. The higher the catch returns for a fishery, the higher will be its rateable value and therefore the amount of rates that the owner will pay, resulting in an increase in the rent or permit price paid for use of a beat. A substantial proportion of salmon fisheries in this catchment are rented by tenants on a seasonal basis.

The ability of salmon to run from the sea into a river is dependent upon there being a sufficient flow of water to permit this to happen. It is the opinion of the Board that a large majority of the rivers in Scotland are water flow dependent or Spate Rivers. When there are low river flows the fish will not run. In a particularly dry summer and autumn, which is generally the time that salmon would be expected to run almost all West Coast and Solway Rivers there will be few fish entering the rivers.

The weather patterns over the last few years have led to prolonged dry spells. The consequence of this is that angling effort has been reduced.

The effect of low flows on the restriction of migration of salmon in large East Coast Rivers is significantly less. There is usually always a sufficient volume and flow of water to allow for salmon to migrate into these rivers, even in times of extremely low flows. The consequence of this is that angling effort is much greater throughout most of a salmon fishing season on large East Coast Rivers and flowing from this, the catch statistic returns of salmon for these East Coast Rivers is correspondingly larger.
The use of the immediately preceding five years catch statistic returns is flawed in that it has not taken into account extreme weather events such as, for example, the very cold and prolonged winter of 2010-11. During that winter the Nith catchment experienced a combination of continuous daily sub zero temperatures combined with extreme low flows. Large numbers of adult salmon were prevented from reaching small water course spawning grounds. In some such tributaries spawning beds were frozen and ova were frozen and killed as a consequence. At other times extremely high flows washed out spawning beds.

If catch statistics are to be considered as one method of measuring the presence of returning adult salmon then it is the view of the Board that a much greater period of time should be used to judge the presence/absence of a sustainable population of returning salmon.

In addition such a method of measurement of population should be used in conjunction with other more scientifically relevant methods to establish whether or not there is a viable sustainable population of all life cycle phases of salmon at relevant times of the year in a river system, sufficient to meet the required escapement targets required for that river system.

The use of a three tier (three sizes fit all) classification for all river systems in Scotland  fails to take into account the individual character of these river systems, which may contribute markedly from season to season and (five year) cycle to cycle to a variation in the catch statistic returns for these rivers.

Individual River Classification

It is the view of the Board that in order to put into place a proper effective salmon conservation policy for each river system in Scotland there needs to be a thorough science based investigation into all of the factors that influence the presence and viability of a salmon population arising from that river. To achieve this, the following is a briefly stated (by no means exhaustive) list of the information and data collection that would be required to achieve a sound conservation policy for each river system:-

A full survey of the whole system to establish the presence/absence of all age classifications of salmon in all water courses within the system.

A full survey to establish both quantity and quality of water throughout the whole river system, what may be affecting such quantity and quality and what remedial steps might be taken to enhance quantity and quality of water to maximize available good quality environment for all age classifications of salmon.

A full survey of all taxonomy within all watercourses within a river system to establish quantity and quality of the taxonomy, what may be affecting the taxonomy and what steps might be taken to enhance the quantity and quality of the taxonomy for the better health of the river system as a whole and salmon age classes in particular.

As a consequence of establishing base line measurements for the above three areas of investigation it should be possible to establish what the maximal output of juvenile salmon from each water course within a river system should be, thus determining what should be the juvenile escapement targets for each water course and the river system as a whole.

These escapement targets should be capable of being measured if the resources to establish measurement are made available. Such resources should be primarily (but not exclusively) dedicated to regular electro fishing surveys of relevant water courses together with provision of strategically placed fish traps in the river system to measure the seaward migration of salmon smolts.

Fish counters should be installed and used to accurately measure the numbers of returning adult salmon to each river system. These numbers could be extrapolated forward to determine if in any given year sufficient adult salmon were returning to the river system to allow for adequate regeneration of juvenile salmon.

This information could then be used to determine the systems and levels of fishing effort and others methods of conservation required in an individual river system.

The Board recognizes that the financial resources required to provide the equipment and methodology sufficient to enable the collection of such important information would be considerable. It would also take time to put the systems and equipment in place to allow for the collection of the relevant information.

While re-emphasizing that the Board wholly supports a robust salmon conservation policy, the Board is of the view that it would serve all interests if the categorization river systems was undertaken over a period of time.

Economic Impacts of the proposed Salmon Conservation Policy

It is the Board’s view that the proposed classification (which in the case of the Nith system would mean total catch and release of salmon) will have an adverse economic impact on the river system for the following reasons:-

The Board believes that a considerable number of anglers will forego the purchase of permits to fish if they are not permitted to kill fish and will choose to pay for permits on river systems where catch and kill of salmon is permitted. There has been the view expressed that many local anglers will choose to fish Rivers Tyne and other Northern English rivers where there still remains the right to kill fish.

The Board represents a considerable number of salmon fishery proprietors who own haaf netting fisheries. Haaf netting is a centuries old method of salmon fishing undertaken in the estuary of the river believed to have been introduced in the time of the Vikings. Haaf netting does not impact upon mixed salmon stocks, targeting salmon that are destined to run the River Nith. The Board has one stake net fishery deemed to lie within its jurisdiction. The implementation of total catch and release will effectively eliminate all net fishing within the Board’s jurisdiction. It is thought that as a consequence a traditional method of fishing which has both cultural and heritage value will be irrevocably lost.

As a consequence of the reduction of angling effort and the extinction of netting effort, the proprietors will suffer related direct economic loss. The Board believes that there will be loss of employment directly attributable to the implementation of a total catch and release policy, in respect of jobs relating to the conduct of fishing for salmon by all methods and because of the drop off in revenue that would otherwise make its way into the area (e.g. fishing tackle shops, hotel, bed and breakfast and restaurant businesses).

The total cessation of netting will devalue the fishery upon which it is conducted to nil. This will result in a loss of revenue to the Board, resulting in a financial restriction of its ability to fulfill its statutory functions. This effect will continue on to affect any FMO that is set up to manage the area of which the Nith salmon fisheries will form part.

As a consequence of a downturn in fishing effort by all methods it will be impossible to re-establish if returning numbers of adult salmon have increased, thus perpetuating the classification of the rivers affected, with the resulting continued knock on adverse economic impact on the local economy.

Suggestions

The Board emphasizes that it supports all necessary investigation into all reasons as to for the decline in the number of returning adult salmon to its river system and to others throughout Scotland and wishes to support the Scottish Government in the implementation of a valid effective conservation policy.

The Board has over the last twenty five years developed a rigorous conservation policy for the waters within the Nith system. Heavy poaching has been successfully dealt with. Substantial habitat enhancement projects have been created throughout the system. The Board has worked in conjunction with SEPA and SNH to monitor and improve water quality and awareness on the part of land users within the catchment as to the importance of minimizing damage to the freshwater environment so important to the survival of the salmon fishery under its charge. It deals regularly with forestry, agriculture, open cast coal mining and renewable energy developers among others to enhance awareness and adopt best practice to mitigate against damage to the fishery.

The Board undertakes regular monitoring and electro fishing surveys of water courses to establish and retain data on fish and other taxonomic populations within its river system. As a consequence of the gathering of such data over many years the Board has been able to establish that in large part, the river system is in good condition and able to sustain viable populations of juvenile salmon.

The Board believes that the decline in salmon numbers arises primarily as a consequence of what happens to salmon during the sea going part of their life cycle.

The Board has noted that with very few exceptions almost all of the Solway and West Coast Rivers are classified under the currently proposed system as category 3 rivers. The Board considers that there must be a correlation between this and the presence of a substantial aquaculture industry on the west coast of Scotland, whereas there is no such industry on the east coast of Scotland, where the majority of category 1 and 2 rivers are located.

Juvenile fish migrating from Solway and West Coast Rivers must migrate through waters off the West Coast of Scotland where there is an abundance of sea going salmon cages giving rise to high concentrations of parasitic sea lice. Wild migrating juvenile salmon cannot survive the resulting parasitisation.

The Board suggests that:-

• The Aquaculture industry should be taxed for the benefit of salmon fisheries to help defray the cost of implementing a cohesive salmon conservation policy as outlined at point 2 above
• In addition or as an alternative to the immediately preceding point Scottish Government should contribute funding to enable the analysis required at point 2 above in order to implement a cohesive national policy of salmon conservation.
• There should be more analysis of river systems as detailed at point 2 above before a complete classification of conservation requirements is implemented.
• In the event that Scottish Government is serious about salmon conservation and wishes to implement a full catch and release policy on a large number of salmon fisheries throughout Scotland as quickly as possible then it should be implemented so as to affect all river systems throughout Scotland. In this way it is thought that this would  dilute insofar as possible a shift of anglers away from the Nith System and other river systems similarly affected by a total catch and release policy, for the benefit of salmon conservation on a national basis and in fairness to everyone who uses and derives benefit from salmon fisheries throughout Scotland.

Nith District Salmon Fishery Board

27th October 2015