Special Areas Conservation (SACs)

Atlantic salmon is protected under the Habitats Directive and there are 17 SACs in Scotland where Atlantic salmon is either the primary reason for designation of the site or is a qualifying feature of the site. Applications from within SACs will be assessed using the precautionary approach. In practice this will mean that even if there is a harvestable surplus, any licence will not be for more than the previous 5 year average  of salmon killed in the SAC – so the licence would be for whichever is the lower - the harvestable surplus or the 5 year average.

Is it clear to you why Scottish Government is taking this approach towards SACs?

Why the contribution is important

Scottish Government wants to be reassured that users understand why we are taking this approach towards SACs.

by LockhartL on July 22, 2015 at 05:00PM

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  • Posted by Greenheart July 23, 2015 at 13:33

    In view of the perilous state of salmon stocks surely the precautionary approach should be applied to all fisheries, not just SACs?
  • Posted by reidy July 23, 2015 at 13:53

    The River Dee has a 98% return rate and is an SAC. Do you propose a kill rate based on rod catch undermining 20 years of conservation effort or do you propose a kill license based on numbers killed there in the last 5 years ?
  • Posted by devronmac July 23, 2015 at 14:01

    Perhaps this proposal is designed to prevent or seriously discourage applications for kill licences in SAC rivers?
    It might just be a better move for these rivers to adopt 100% catch and release and save a lot of administrative hassle and argument.
  • Posted by marinescotland3 July 23, 2015 at 17:27

    The precautionary approach is being applied Scotland wide with particular emphasis on SACs. The rational explained in the introduction makes plain that the measures for SACs will be sympathetic to local efforts around conservation.
  • Posted by tweedfisher July 25, 2015 at 15:33

    The river Tweed is a SAC but is generally acknowledged to be the best managed and most prolific river in Europe. It also produces a significant and scientifically provable harvestable surplus. Does the Government feel it is better informed and qualified than the RTC to determine what that should be?
  • Posted by Fishpond July 26, 2015 at 21:02

    Haven't noticed the Dee improving after twenty years of c&r either so I'm not expecting these changes to change the catch returns there. We've been being responsible in returning fish for a decade or more voluntarily in many cases so not sure legislation is actually going to benefit the fish stocks noticeably - stopping all commercial netting and holding fish farms to account for their environmental impact on wild stocks would seem two logical actions which would have an immediate affect.
  • Posted by Piscator July 26, 2015 at 23:48

    Marine Scotland,

    It says above

     "In practice this will mean that even if there is a harvestable surplus, any licence will not be for more than the previous 5 year average of salmon killed in the SAC – so the licence would be for whichever is the lower - the harvestable surplus or the 5 year average."

    My reading of this is that even if salmon abundance increases the effect will be that the number of salmon that can be killed will progressively reduce over time. Correct?

    If your licence is never higher than the previous 5 year average then that average can never rise even if fish numbers rise markedly. Every time there is one or two bad years and the average falls the licence will then fall, never to rise again. Will the end result then be no effective licence?
  • Posted by Renna July 27, 2015 at 07:40

    To answer the question posed by LochartL the answer is no, it is not clear why the SG are taking this approach.

    If the SG were interested at all in what was happening in the SACs they should invest in fish counters which would prove beyond any level of doubt as to the status of the salmonoid populations in these waters. The civil servants have used the term 'harvestable surplus' throughout this discussion document but have not defined how they will actual measure this. They have according to their own timetable 2 months to measure this across Scotland.

    The rush to legislate and get in place licensing arrangements for season 2016 is breath taking, ill conceived and totally without consistent scientific basis. As to suggest we will measure the SAC licensing arrangements on the 5 year average then this puts the tin lid on it in terms of credibility as there are so many variables when it comes to catching fish that to base future exploitation rates on such an average is crazy.

    If SG are at all interested in SACs they should do the science first then come back and tell us what is appropriate for all 17 systems.

    Just to show how bonkers it all is I will provide details from the SAC I currently have an interest in - the River Endrick.

    Last year for the Loch lomond Angling Improvement Association AGM report I (fortunately) complied rolling 5 year catch data for our own waters going back to 1990. In the last 15 years the 5 year catch average for the Endrick has risen from 70 in 2000 - 2004 to 100 in 2008 - 2009to 112 in 2010 - 2014. Whoopee! In the same period our club membership has reduced by about one third and far fewer people are now fishing the Endrick but those that are catching more fish for their trouble, even better. In the spirit of conservation we stopped the killing of all salmon in the month of October in 2012 as well as introduced a tag limit. The impact of these rules has seen catch and release rates rise so that we are now returning well over 90% of all salmon caught on this river in 2012 - 2014, compared anecdotaly with about 50% in 2000.

    The impact on the legislation is that we will receive a handful of tags as a direct consequence of doing our bit for conservation in this SAC. If we had allowed wholesale harvesting we would potentially have got far more licences. As Piscator rightly points out the number of tags we can apply for will dwindle to nothing over the next few 5 year cycles despite according to our own 5 year average figures we are moving in the right direction re stocks.

    Perhaps someone from Marine Scotland would like to comment on the points above?
  • Posted by RichardBrodie July 27, 2015 at 15:51

    I think the notion that ending net fishing will suddenly improve river stocks is not borne out by experience. There used to be dozens of netting stations on the Solway but i think only three survive. Instead of river catches going up the effect was actually inversely proportional.

    The truth is that 90% of the salmon leaving the Solway rivers never return to the Firth. If scientists can reverse that trend, then there will be plenty of fish for both the anglers and the traditional net fishings.
  • Posted by garavogue July 27, 2015 at 20:36

    I agree with Piscator.

    If there has been a preliminary 5 year average established then it is mathematically impossible for this average to ever to up !

    If the average is recalculated every year and there has been a couple of Bad years. Or even Good years in fact, but the responsible Ghillie/ Proprietor has said, well we have a lot of fish, but this year we have a late run and because they are coloured all Salmon will have have to go back.

    This will of course lower the average.

    It is IMPOSSIBLE for it ever to go back up again..
    The amount of kill tags can only ever go down.Perhaps this is the intended consequence of this Carcass tag policy ?

    There is a lot of uncertainty about this review - but this is of course an absolute !!
  • Posted by Speyfisher July 28, 2015 at 07:39

    Well done for pointng that out garavogue. Not sure that it can't go back up slightly depending on numbers killed in recent seasons but the number of fish permitted to be killed will in effect become fixed under this proposal. This is not evidence based management, nor does it reflect salmon biology. Evidence led management would use the best available knowledge to establish the harvestable surplus with reviews on a periodic basis.
    One unintended consequence of this proposal is that the number of fish killed this season could increase as fisheries realise the implications. Now in reality this is unlikely to occur due to the widespread adoption of a positive attitude to conservation, something that has been delivered by local management organisations through "hearts and minds" rather than legislation. The government would do well to recognise the good work delivered under the current system.
  • Posted by Speyfisher July 28, 2015 at 08:25

    An additional point. Last year 364 salmon and grilse were killed on the Spey, significantly below the five year average of 1410. The number killed in 2014 was a reflection of the rod catch and stock availablity in what was a particularly poor year. Based on current understanding there is no prospect that the government advisors would have had the foresight to predict such a poor year and to set such a low kill quota in advance. This is a prime example of how the government should leave areas where good practice is implemented to manage effectively and use what should be reserve powers to intervene where effective local management is not working.
  • Posted by tweedfisher July 28, 2015 at 13:29

    A very good point Speyfisher. I just hope, that those that will ultimately make these important decisions, can understand the logic, of this being decided at a local level, to actually achieve maximum benefit to anglers and fish alike.
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