The Kill Licence proposal- consultation

The notice under paragraph 11 of schedule 1 to the Salmon and Freshwater Fisheries (Consolidation) (Scotland) Act 2003 (“the 2003 Act”)

Ministers are required under paragraph 11 of schedule 1 to the 2003 Act to advertise the general effect of the kill licence proposal and the prohibition on killing salmon outside estuary limits.  Representations or objections may be made within 28 days from 23 July.  We hope that engaging with the interactive discussion will help to inform any response you wish to make to this consultation.  

More detail on the application process and the way the applications will be assessed can be found in the  “Application” idea box.                   


Why the contribution is important

Scottish Government wants to be confident

·      that everyone who would be affected by the proposals or who would be interested was aware of the consultation and felt sufficiently informed to be able to put in a response.

·      that the consultation process was as straightforward as possible.


by LockhartL on July 22, 2015 at 05:28PM

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  • Posted by par2164 July 23, 2015 at 14:06

    Is it really a consultation if the Scottish Government have already decided that this will go ahead in some form or another?
  • Posted by par2164 July 23, 2015 at 14:07

    When will the review of aquaculture and it's effect on fisheries take place?
  • Posted by galloway_fisher July 23, 2015 at 14:48

    Why did Andrew Thin during the Wild Fishery review refuse to look at factors at sea (including salmon farms) which can cause problems for migrating salmon. ?
  • Posted by kgm July 23, 2015 at 15:40

    Why did Andrew Thin ignore all the advice provided by the salmon anglers and association members he spoke with ? Lets just call a spade a spade, this has absolutely nothing to do with protecting Wild salmon, it's only a facade introduce further rural taxation in a none too stealth like manner.

    The proposals as they stand will drive anglers away from the rivers and destroy association waters. True anglers are the only people that can and do police the rivers effectively and by driving them away you leave rivers wide open to poachers and the further demise of wild salmon and rural tourism in Scotland.
  • Posted by galloway_fisher July 23, 2015 at 15:46

    There were view few riparian owners on the rural affairs committee and those who were chosen to speak in front of the rural affairs committee were cherry picked.
  • Posted by charlesjeffrey July 23, 2015 at 16:00

    By issuing kill tags, more salmon, not less would be killed.
    Current river boards are doing a great job, particularly here on the Tweed. No one here wants any centralisation and interference from folk who don't know about particular river conditions. Ghillies and regular anglers like myself who have had many years of experience are the folk that should be deciding what is best for their own river.
    Salmon farms, which for some sinister reason is not up for discussion, are a disgrace and the surrounding area of these farms is so contaminated that no wild fish will come near, when the Government has a remit to allow safe passage of migratory fish to their spawning grounds. When is this going to be up for discussion? Predators is another serious issue and no one seems willing to bite the bullet and cull seals which have increased in number dramatically over the past three years.
  • Posted by marinescotland3 July 23, 2015 at 17:20

    This is very much part of the consultative process. Any comments in relation to the wider review will be collated and passed to colleagues working in that area to consider as appropriate. It would be helpful to understand the basis for the view that anglers will be disinclined to fish rivers in Scotland. We would welcome more detail. Do others agree?
  • Posted by ms July 23, 2015 at 18:07

    I attended a local discussion with Thin and associates and engaged him on the thrust of his Mission. It seemed quite clear to me that he had been given the broad conclusion for the Review he was conducting. His parameters seemed to be a very narrow vision of migratory fishery management and that owners, ghillies and fishers' comments were to be noted, nothing was permitted to impinge on the hallowed salmon farming industry. Totally excluded from the discussion were the effects of open cage salmon farms and the identification of the main predators. We need to take these aspects into account as they have possibly the highest impact on our salmon & sea trout numbers.
  • Posted by galloway_fisher July 23, 2015 at 19:38

    In an area such as Dumfries and Galloway, local people can buy tickets relatively cheaply for annual fishing from local fishing associations and river boards have grown and encourage around 80% catch and release with all spring fish returned until 1st of June and coloured back end fish returned. Leaving a naturally small window of opportunity for anglers to keep a fish for themselves.

    Some local businesses who cater specifically for fishing holidays offer free fishing for guests fishing, allow guests in feb and march to fish for free, and charge between £100 per week for a rod up to £140 per rod for a week this is incredible value for money, many visiting anglers come from south of the border and already pay for a rod license, they are generally happy to return spring fish and back end fish but anglers in July and August who catch a fresh small salmon / grilse on occasion like to keep a fish for the table, it's part of their enjoyment. There are some regular anglers who come from South of the border and elsewhere who have intimated they will fish else where the tyne, is a good river and Wales offer some very good fishing. Area like Galloway rely on tourism trade and fishing does generate a large income for many b&bs, cottages, bars, hotels, tackle shops, restaurants.
  • Posted by galloway_fisher July 23, 2015 at 19:43

    It is quite ironic that visit Scotland have a tourist brochure for this year states that 'Scotland is the fishing capital of the world'

    To quote the world class fishing article 'many fishing places live on a reputation gained years ago in time however in Scotland however local and visiting anglers will till you that fishing is now actually better (and far more accessible) to anglers both by cost and availability????!!!

    What the Scottish government is proposing will dissuade fishermen and probably force proprietors to sell up of close down.
  • Posted by galloway_fisher July 23, 2015 at 19:47

    Many of the river boards and trusts work using local volunteers, I do not see volunteers willing to give up their time to help out a political quango if they do not feel their concerns are being listened to.

    I cannot believe that Asfb have realised a statement backing kill licenses when it is obvious looking on line At many websites and forums for the likes of the Tay and tweed boards do not agree with many of the wild fishery review sections.
  • Posted by tweedfisher July 24, 2015 at 09:13

    It is felt by many anglers that the kill license is just a round about way of introducing 100% catch and release on all rivers. Andrew Thin admitted that the ultimate objective was to eventually have 100% C&R. The fact that it will be costly to implement and the whole cost has to be recovered from those applying for a licence, is just a deliberate ploy to price anglers out of killing fish.

    Some organisations have welcomed the proposals and certain individuals who derive their income from it, have even called for 100% catch and release despite the evidence to show that anglers are not responsible for the problems some rivers are facing. The Dee is a prime example of catch and release not working. Some might wonder, whether the prospect of a lucrative position in some new department or organisation might be the true driving force for certain individuals??
  • Posted by par2164 July 24, 2015 at 10:01

    marinescotland3 - if the government cannot see how this will drive potential anglers away from the sport then god help us.
    Forget the fact that you are complicating the sport with rules and regulations (coupled with the threat of the law), there will be a cost associated with the kill licence, a cost that will be passed on to the anglers. Couple the increase in cost with dwindling salmon numbers (something that will continue as we are not addressing the real issues) then of course the number of anglers will go down! Some will leave because they cannot afford to fish. Some will leave because they don't agree with the policies forced upon them, many will leave due to the continuing decline and the feeling that no one wants to deal with the problems.
    If the government is truly focused on conserving salmon and understands the benefit that fishing brings to the economy, then absorb the cost of the licence system. If the SG believes that a kill licence will improve stock levels, then the economic benefit to Scotland will far outweigh the cost of administering the scheme. Put your money where your mouth is!
  • Posted by scaredforsalmon July 24, 2015 at 11:05

    I know for a fact that having a blanket 100% catch and release policy will certainly drive anglers away, as my job is teaching fly fishing for salmon, seatrout and trout I know that if a responsible fisherman is told that he has to have a tag to kill a fish and even though he would rather put fish back he would not want to return a fish that he catches if it diseased or damaged. Many fish caught have damage from seals, cormorants, boat propellers, etc etc. If he has to return these fish he will not be happy to do it, however if he does the "right" thing and dispatches the fish he is liable to prosecution and a criminal record. Surely when sea lice populations are out of control in the fish farms and ever higher doses of poison are required to treat them, and is still not working, it is more than hypocrytical to accuse honest everyday rod and line fishermen of breaking the law.
  • Posted by scaredforsalmon July 24, 2015 at 11:11

    I have already had to change my focus of advertising my fishing tourism business, gone through an expensive process of qualification so that I can still offer a service as an instructor but do not actively offer guiding for salmon & seatrout.

    In an area of Scotland that has suffered more than most with a lack of salmon it is not only difficult to earn a living it is nigh on impossible. With B&B businesses closing all around and the very thing that brought the visitors here back in the 70's in short supply and more accessible and prolific fishing in other parts of the world we are on a very slippery slope. In the past month I have taught on 4 different rivers and have not seen a single salmon. When I was fishing in the 70's and 80's there was not a day on the river when you couldn't see dozens of fish. Where were the salmon farms then?
  • Posted by allisterwallace July 24, 2015 at 21:10

    Principal threats and opportunities:

    Predatory birds that have been allowed to migrate and breed within our river systems from the coastal areas without adequate control measures in place.

    Seal populations that harvest returning stocks on a daily basis.

    Long term effects of coastal netting on migratory stocks.

    North sea abstraction of stocks by foreign vessels.

    Changes in food supply chain at sea.

    A realisation that the general angling fraternity has the perpetuation of the salmon as their prime focus of recreational activity.

    That current models of practice within salmon fishery boards, (which are underpinned by scientific knowledge and best practice), are an exemplification of how it is possible to take forward the vision of sustainability (an obvious example is the TDSFB).

    Only with good future working relationships across the parameters of scientific, political and recreational interests, may the plight of our iconic salmon have a long term future.

  • Posted by Renna July 25, 2015 at 13:41

    The question I have relates to the period set aside for public discussion on this matter. Why has this been restricted to one week when the Government have allowed for a 28 day window for responses? Moreover why has this one week window been commenced in mid July which is peak holiday time when many people are out of the country on vacation?

    Surely to maximise the opportunities for debate this national discussion should be extended to mitigate against the above.
  • Posted by Salmon_Fisher July 25, 2015 at 23:56

    It is very difficult to escape the feeling that the kill license proposals are a fait acompli and that this 'consultation' will make little or no difference.

    I would be very surprised if more than a small fraction of the 600 who responded to the consultation said that this would be a good idea and yet here we are, a consultation about a consultation.

    The timing and the nature of this particular consultation would appear to be informed purely by the legislative timetable and the need to get the kill license proposals through Parliament in time for next season.

  • Posted by Pharma July 26, 2015 at 11:43

    To MarineScotland3 on question of driving anglers away from Scottish rivers
    Yes I agree - Visitors who fish to keep what they catch will go to countries where this is possible. In addition, low cost fishing may no longer be available to local anglers. I help run a community fishery that is run by volunteers and is struggling to survive (both financially and in finding volunteers to help). The extra costs and administration will certainly cause our fishery to close if we have to apply for a kill licence. We cannot continue as a C&R fishery as we know we will lose around 20% of income from those anglers who fish to keep what they catch. Either way the outlook is bleak. I'm sure there are many other fisheries that provide low cost angling who will be in a similar situation.

  • Posted by abhainn July 26, 2015 at 14:26

    Where is the evidence that this will drive anglers away from the sport?
    I remember back in the 1990's when catch and release began to take hold. I lost count of the fishermen who said 'its a waste of time as they will all die' etc etc. Guess what I they didn't.
    This proposal wont either.
  • Posted by galloway_fisher July 27, 2015 at 16:38

    We were speaking to a long standing guest would would like the chance to take a fresh fish over the summer of he was lucky enough to catch one, his response to the carcass tagging and being told that we might not even be allocated any tags was that it would shut out fishery down. Guests have previously been returning 80% of their fish caught but would like to be able to use their own judgement to take a fish in summer months, many do not support fish farming and actually like to have a fish for the table
  • Posted by braemish July 28, 2015 at 11:55

    Much is made in Government's proposals that decisions must be evidence led. Apart from the Tweed Foundation’s sound scientific evidence, from fish counters and electro-fishing data, that ‘There’s a surplus of Summer and Autumn Salmon in the Tweed’ and ‘There’s no biological conservation reason for introducing quotas’, has anybody detected any evidence in any Governments document that shows that, on conservation grounds, the tagging of rod caught Salmon is necessary?
  • Posted by Tweeddale July 28, 2015 at 13:37

    I'm not sure I agree with all the statements here - mixed stock fisheries have been a long running sore for many, many years, and angling bodies have long argued for their regulation. Here we now have a proposal that will not regulate - but PROHIBIT - all forms of salmon exploitation on the coast - i'm actually astonished that Government have decided to take this forward. I'm also astonished that people can't see this for what it is - a groundbreaking conservation move which will undoubtedly benefit Scottish salmon stocks. Now, if they can get the licensing system set up in such a way that it doesn't unduly interfere with our ability to go angling - and take the odd salmon where sustainable - then I think that will be pretty good work.
  • Posted by MacRob July 28, 2015 at 17:07

    It seems clear that the Scottish Government is going to carry on with all of this whatever the comments say. Like most Politicians they thrive on adding to bureaucracy - more rules, more regulations, more civil servants, more offices and more expense landed on the taxpayers.
    Most of the regulation is unnecessary, unwanted and unpopular - certainly in our part of Scotland.
  • Posted by LateRoman July 28, 2015 at 17:42

    Fully support allisterwallace in his list of threats to the Salmon. The list summarises the extraordinary threats that face the Salmon between its first moments of life on the spawning bed and its return to its native river. He might also have added predation by larger fish (e.g. trout) in passage downriver. The BTO published a report stating that a single goosander requires 30kg of small fish to bring it to adulthood. I think I am right in saying that that's the equivalent of 2000 smolts, though of course it'd be doubtful if the young bird's diet were entirely salmon parr/smolts. The Licence is proposed for conservation reasons. As stated in another post, I cannot find the "sound science" and "evidence-based process" for this proposal. Please can someone point me towards it?
  • Posted by Renna July 28, 2015 at 20:09

    If left unchanged these proposals may result in the collapse of many angling associations who provide cheap and at times quality fishing to people who might otherwise not be able to afford more exclusive salmon fishing. It is ironic that the Wild Fisheries Review says it wishes to encourage people into fishing, these proposals will do the exact opposite if not altered.

    This rush to legislate has also led the authors of the proposals to ignore basic equality considerations as can be seen as follows:

    The current age profile of the Loch Lomond Angling Improvement Association equates to:
    Total full members - 477, full members aged 65 or above – 163 (34% of full members). In comparison only 18% of the Scottish population according to the 2011 census was aged 65 years of age over. In addition there are 26 members of the Association who claim a disability preference and have submitted confirmation of disability.

    In total 189 (~40%) of Association full members can be categorised as having protected characteristics under equalities legislation.

    Given that in the past disabled and elderly people have been highlighted as suffering from higher levels of poverty than the average they could therefore suffer disproportionately from these proposals given that the likely outcome will be to undermine the financial viability of many angling associations who offer reasonably priced salmon fishing. It is therefore disappointing to note note that a suitable equality impact assessment has not been undertaken with respect to these recommendations. The rush to legislate would appeared to have blinded the authors to the need to apply appropriate safe guards to protect some of the most vulnerable groups in the angling community.

    I would therefore urge Ministers acting in line with their public sector equality duty to immediately instruct that a wide ranging equality impact assessment is undertaken, with particular emphasis on the impact that these proposals will have on angling association members.
  • Posted by scaredforsalmon July 29, 2015 at 10:29

    Looking at my local angling association I would say that the figures provided by Renna, are a pretty accurate assessment of membership here too, I rarely see members fishing who are not of the "senior" variety and in an area of known low incomes can only assume that they too are of limited means. Yes some of our guests and my clients are relatively well off and they come here to learn how to fish they are the ones who subsidise the club by purchasing high value day tickets so that the locals can have a realisticly affordable annual membership. Take those guests out of the equation and add all the extra costs these proposals bring and we will have an elderly population deprived of their physical activity and social interaction when their associations close.
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