Evidence Needed

I very much support the Wild Fisheries Review in its call for evidence-based management of salmon in Scotland, but have not seen any evidence produced to support the idea of a kill licence. The basic evidences required are:-

1) That there is a national shortage of spawning salmon & therefore a need to reduce killing

and

2) That anglers kill a significant number of the total Scottish salmon stock. If a (conservative) 20% catch rate is used to estimate the total numbers of fish from the rod catch total (after May), then the proportion of non-Spring salmon killed by  anglers was less than  than 5% in 2013. Additionally, most of those killed by anglers are male.

If there is no shortage of spawners, and anglers only kill an insignificant number of fish anyway, then what is the evidence for this elaborate system of kill licences being necessary? What estimates have been made of the number of females that would be "saved" by such a system? If the number "saved" would not be significant, then this system of licences would be "disproportionate regulation", which is against government policy.

The context has also to be worked out - what estimate is there of the number of adult salmon killed by the 164,000 Gray Seals now in Scottish waters (2009 Scottish government figures) and what would such an estimate be relative to the c. 12,000 salmon killed by anglers in 2013? If seals kill more than anglers, then what is the point of reducing the angler kill? There are also 280,000 Porpoises in North-west Europe, which also eat salmon. 

It would be more practical instead to have an effective, national, monitoring system (as required by Article 11 of the Habitats Directive) and take action when (if) this showed that there was an issue (as required by Article 14). If there is no issue, there is no need for action.

Why the contribution is important

The Wild Fisheries Review calls for evidence-based management, yet this proposed kill licence policy has had no evidence produced to show that it is either necessary nor could be effective, and so contradicts the whole concept of evidence-based management. 

by Alabalik on July 24, 2015 at 05:41PM

Current Rating

4.9
Average score : 4.9
Based on : 10 votes

Comments

  • Posted by bradan July 25, 2015 at 07:43

    A very good and well reasoned arguement. Unfortuately it sems that the the SG is not inteested in science and simply uses the requirement as a fig leaf to cover the paucity of their rationale.
  • Posted by Balmahablogger July 25, 2015 at 13:16

    Well put Alabalik - I don't think your comments will be taken on board though!!
  • Posted by tweedfisher July 27, 2015 at 09:00

    If the Scottish Government and Marine Scotland choose to ignore these facts, it will certainly prove that this whole consultation process is just a sham and the final decisions have already been made regardless of facts, science or logic.
  • Posted by tweedfisher July 27, 2015 at 09:01

    If the Scottish Government and Marine Scotland choose to ignore these facts, it will certainly prove that this whole consultation process is just a sham and the final decisions have already been made regardless of facts, science or logic.
  • Posted by marinescotland1 July 27, 2015 at 17:28

    The basis for this proposal was outlined in the consultation document. Part of this week long dialogue is to gather further evidence about some of the detail. Evidence that we have already listened has been demonstrated with regard to current views about accompanying baits and lures regulations. Please be assured that we are taking your comments into consideration alongside the many others views that are being expressed.
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