Salmon fishing - proposed river gradings for 2023 season: consultation analysis

3. Consultation analysis

3.1. Respondents and their interests

There were 211 responses submitted to the consultation from individuals (77%) and organisations (23%). A range of organisations submitted responses to the consultation including sixteen district salmon fishery boards, the River Tweed Commission, three river or fisheries trusts, ten angling clubs or associations, six organisations with national membership such as Fisheries Management Scotland, two community councils and five other businesses.

A large majority of respondents (81%) indicated that they had an interest in the river grading assessments for the whole of Scotland, although many were also interested in specific freshwater systems. More than 90 rivers, lochs and geographical regions across Scotland were indicated to be of interest to the respondents of this consultation.

3.2. Views of consultation respondents on the proposed river gradings

Nearly half of respondents (47%) agreed with the proposed gradings for the 2023 salmon fishing season, while a third (33%) objected and a fifth (20%) had no specific view for or against the gradings. A few respondents (7%) indicated that they believed the proposed grade assigned to a specific river was incorrect and should be changed.

A proportion of respondents (13%) raised concerns over the methodology used to calculate the conservation status of rivers. Prominent issues raised included:

• requests for fish counter data to be used in addition to rod catch data in the assessment of river conservation statuses (7%)
• that environmental conditions such as low water levels reduced the number of catches (5%)
• that rod effort on rivers should be considered in the assessment method (4%)
• the effect of the covid-19 pandemic on reduced rod effort and corresponding lower number of catches (4%)
• concerns that the proposed gradings for upper tributaries should not influence the gradings of main stem rivers (3%)

Most respondents indicated that the sources of information provided in support of the proposed river gradings were 'useful' or 'very useful', although on average this majority was greater for organisations (85%) compared to individuals (65%). Individuals were also less likely on average to indicate whether the information provided met their accessibility needs (43%) compared to organisations (70%).

3.3 Views of consultation respondents on the catch and release regime

3.3.1. Catch and release

The practice of catching and releasing Atlantic salmon in recreational angling has substantially increased in the past three decades to support the species. Catch and release in 2021 accounted for 95% of the total rod catch of salmon and 99% of the rod-caught spring salmon (taken before 1 May).

Since the introduction of the Conservation of Salmon (Scotland) Regulations in 2016 river assessment areas that are categorised as grade 3, which indicates that exploitation is unsustainable, require statutory mandatory catch and release of salmon for all fishing methods. Voluntary catch and release actions are strongly promoted in grade 2 areas and most grade 1 areas also encourage anglers to practice catch and release.

3.3.2. Views on enhancing catch and release rates through voluntary or mandatory measures

While a large number of respondents (42%) voiced support for the regime to encourage 100% catch and release across Scotland through voluntary measures, the majority of respondents (48%) opposed this. A small proportion of respondents (10%) did not provide a specific view on the regime for voluntary measures.

A majority of respondents (75%) opposed a regime for mandatory measures to achieve 100% catch and release across Scotland in future and less than a fifth (18%) of respondents supported the prospect. A small proportion of respondents (7%) did not provide a specific view on the prospect of mandatory measures.

A few respondents rejected the use of voluntary measures in favour of mandatory measures to achieve 100% catch and release rates instead, meaning that in total 46% of respondents supported the idea of either voluntary or mandatory measures, or both.

A broad array of reasons were provided in either support or in objection to the catch and release regime. For example, 34% respondents felt that catch and release rates were already high in Scotland and 40% of respondents felt that pursuing a policy of 100% catch and release would not be effective in protecting wild salmon populations. This latter view was largely held for three reasons:

• respondents felt that angling did not constitute a significant pressure on wild salmon populations;
• that as catch and release rates are already high the small increase to 100% would not have a substantial benefit;
• that salmon populations in rivers which are already operating a 100% catch and release policy, such as rivers that have consistently been grade 3 over several years, have not recovered.

The views of some respondents on the use of voluntary or mandatory measures in future to achieve 100% catch and release are included below:

"A very high level of catch and release has been achieved without mandatory measures. Anglers have demonstrated a willingness to apply the measure in places where it is not already compulsory. Therefore, there would be no meaningful change by making it compulsory"

"I think, whilst hugely unfortunate, that this is required. This is not only because the small proportion of adults killed would then contribute to recruitment. This is mostly because I feel other sectors such as aquaculture and forestry are unlikely to take seriously their impacts on salmon stocks when those advocating their conservation only do so, so that they can kill them for sport"

3.3.3. Views expressed on other actions to protect and restore wild Atlantic salmon populations

Over two thirds (67%) of respondents indicated that they would like to see action taken on other pressures impacting wild salmon populations. Respondents were similarly likely to indicate that other pressures needed to be addressed whether they supported or objected to voluntary measures to encourage full catch and release (69% or 61 out of 89 positive responses compared to 65%, or 65 out of 100 objections). However, only 46% of respondents who supported mandatory measures (17 out of 37 responses) indicated that other pressures needed to be addressed compared to 73% of those who objected to them (116 out of 159 responses).

There were a number of pressures on wild salmon populations identified by respondents, these have been ranked by the percentage of total respondents who mentioned that pressure:

• predation (53%)
• fish farms (41%)
• habitat degradation and river barriers (20%)
• low water quality and pollution (19%)
• pressures in the marine environment (19%)
• low water flows and abstraction (11%)
• climate change (10%)
• estuary netting (9%)

Furthermore, a number of actions were suggested by respondents to help protect and recover wild salmon populations. These are ranked below by the percentage of the total respondents who mentioned these actions:

• stocking (13%)
• preventing illegal fish poaching (7%)
• prohibiting specific fishing methods or tackle (4%)
• close rivers to angling for set periods of time (3%)
• adjust angling season times (2%)

Responses from organisations tended to be more comprehensive than those from individuals. For example, more than half of the responses (52%) from organisations highlighted three or more pressures other than angling that should be addressed to protect and restore wild salmon populations, compared to less than a quarter of individual responses (23%) who did the same^[1].

The views of some respondents on other actions needed to protect and restore wild Atlantic salmon populations have been included below:

"An alternative approach to mandatory catch and release would be to use the river grading system to enforce and increase what funding and management tools are available to local stakeholders (DSFB's, SEPA, SNH [sic], landowners) to protect and enhance salmon stocks to improve river gradings. Management tools should include proportionate licences for predation control (FEB's & In river Seals), stronger diffuse pollution control measures and improved habitat schemes linked to agricultural subsidies, more robust abstraction control and regulation and restorative or mitigation stocking of salmon if proven to be required and appropriate"

"The costs of this legislation could, arguably, be better spent in addressing other factors affecting the fish and the riverine habitat."

"We are also of the view that more can be done to ensure that best practice in catch and release is followed both locally and more widely in Scotland, particularly in relation to air-exposure of fish and fishing in high temperatures. We would be supportive of more guidance being developed and circulated on this"

3.3.4. Concerns regarding the potential impacts of a 100% catch and release policy

A number of potential impacts of a Scotland-wide 100% catch and release policy were identified by respondents. These are ranked below by the percentage of the total respondents who mentioned these impacts:

• deter anglers from the sport and reduce tourism (39%)
• have an economic impact on businesses that benefit from angling and local economies (26%)
• reduce income for businesses directly or indirectly associated with angling (17%)
• reduce the contribution of the angling community (due to reduced angling and associated income) to initiatives that promote the protection of wild salmon populations such as habitat restoration projects or the reporting of pollution incidents (12%)
• result in an increase in fish poaching and other wildlife crimes due to reduced angler presence on rivers (10%)

11% of respondents also expressed views that a 100% catch and release policy either through voluntary or mandatory measures effects their personal freedom to catch and eat wild salmon and 15% commented that anglers value the choice to 'keep one for the pot'. Some 11% respondents also commented that they would be opposed to returning injured fish that were unlikely to survive, or fish that died during handling, back to the river.

Organisations were more likely to highlight the potential impacts of a 100% catch and release policy, including deterring anglers (33% of individuals, 59% of organisations) and reduced income for businesses that benefit from angling (10% of individuals, 38% of organisations).

The majority of comments relating to the impacts of a 100% catch and release policy identified likely negative trade-offs, whereas a few respondents expressed their views on potential benefits. For example, some respondents highlighted that promoting a 100% catch and release policy could promote a more ecologically-focused tourism industry for angling. Others mentioned that a 100% catch and release policy may not have a severe impact on the income of fisheries managers, as numerous fisheries across Scotland have already been operating a 100% catch and release policy for some time.

The views of some respondents on the potential impact of a voluntary or mandatory 100% catch and release policy are included below:

"Efforts to enhance conservation work best when those directly affected have full buy-in to the process. Statutory intervention and prohibition would have the direct opposite effect, leading to disenfranchisement and a drop-off in interest and participation in conservation measures and potentially in angling itself. There is considerable psychological difference between voluntary C&R and a compulsory scheme which carries the threat of prosecution"

"I personally think that a 100% catch and release (including for heavy bleeders) across all grades would be beneficial. At the moment beats (even category 1) which have voluntarily moved to catch and release only and focus on other marketing aspect to maintain/grow their revenues and maintain jobs are somehow penalised by opportunistic fisheries whose key selling point is "you can kill fish within the law""

3.3.5. Views on review period length of a catch and release policy

The majority of respondents (41%) felt that the introduction of a 100% catch and release policy, either through voluntary or mandatory measures, should be reviewed annually in line with the annual assessment of the conservation status of salmon stocks and the proposed gradings for the upcoming salmon fishing season. A smaller proportion of respondents indicated that catch and release policy should be reviewed over longer periods including every three years (15%) or five years (7%) in line with the life cycle of Atlantic salmon.

The views of some respondents on how often a Scotland-wide catch and release policy should be reviewed are included below:

"This [a 1 year review period] could allow fisheries a regular opportunity to assess the impact of mandatory C&R in terms of bookings and income, local angler interests, as well as assessing and taking in to account the annual runs of salmon"

"By adopting a period of 100% catch and release across the country, for at least one lifecycle (5 years), then robust assessment of the wild stocks and the trend will be possible without any skew from anglers harvesting salmon. If this conservation measure works, this should be reflected in monitoring results following a period of mandatory catch and release."