Livebaiting has been staunchly defended by the Scottish Federation for Coarse Angling, in its response to the country's proposed new fisheries laws.
The draft Aqualculture and Fisheries Bill will shortly be considered by the Scottish Environment and Rural Development Committee, before MPs get the final vote.
There is a limited consultation period, and writtein evidence must be submitted by September 15.
The PAC is currently formulating its response, in support of the SFCA and all predator anglers north or the border.
While much of the Bill concerns the regulation of shellfish farms and game fisheries, it also proposes a ban on livebaiting to prevent unauthorised fish transfers.
The SFCA has come out strongly against the move. In its response, it says: "We totally oppose such a ban. It would be both superfluous and disproportionate to the risks it purports to address.
"It is claimed by some that discarded or escaped livebaits have been responsible for the introduction of certain species to a number of waters in Scotland.
"There is no hard evidence for this, but even if it is true it could only account for a tiny fraction of the spread of locally non-native species and the dilution of genetic identity among established species in Scotland.
"There are several far more significant sources for inappropriate introductions. Most important among these are deliberate stocking by clubs, proprietors or individual anglers, and escapes or discards from aquaculture facilities and garden ponds.
"There is no necessary connection or causal link between the use of live fish as bait and the movement of fish between waters. These are two entirely separate issues."
The SFCA says tighter controls on fish transfers are the answer. It goes on: "The appropriate way to prevent inappropriate introductions and transfers is by legislation directly regulating fish movements.
"Such legislation is proposed Part 4 of the Bill, and has the support of SFCA. No additional Regulation is required.
"If the Executive believes it is essential to strengthen this by regulating the use of live fish as bait, the appropriate step would be to bring in provisions analogous to those in Denmark which directly restrict the use of livebaits to fish caught on the same day from the same water where they are being used.
"This is workable and would reinforce the message the Executive seeks to convey without alienating the angling community it aims to regulate. SFCA would be happy to work with the Executive and other stakeholders to formulate the details of a Regulation along those lines, and to promote compliance."
There are also concerns at proposals to allow all fish to be eradicated from river catchments infected with Gyrodactylus salaris - a salmon parasite found in Norway and the Baltic.
While it has not yet been found in Scottish rivers, officials are seeking powers to cull all fish in river systems where an outbreak occurs, despite the fact the disease affects only salmon and trout.
In its response, the SFCA said: "We appreciate that the power to apply selective eradication of affected species may have to exist as a last resort.
"However, that power should not extend to the eradication of stocks of species that are neither affected by nor capable of hosting Gyrodactylus salaris.
"Nor should it apply to waters within a catchment that are not connected to the river in which the affected salmonid population lives.
Stakeholders – including coarse angling interests – must be fully consulted when deciding the measures to be applied in the event of a particular outbreak, and such decisions must start from a presumption that eradication will not be the default approach."
It adds containment measures are preferable and damage to unaffected species should be kept to an absolute minimum.
The draft Aqualculture and Fisheries Bill will shortly be considered by the Scottish Environment and Rural Development Committee, before MPs get the final vote.
There is a limited consultation period, and writtein evidence must be submitted by September 15.
The PAC is currently formulating its response, in support of the SFCA and all predator anglers north or the border.
While much of the Bill concerns the regulation of shellfish farms and game fisheries, it also proposes a ban on livebaiting to prevent unauthorised fish transfers.
The SFCA has come out strongly against the move. In its response, it says: "We totally oppose such a ban. It would be both superfluous and disproportionate to the risks it purports to address.
"It is claimed by some that discarded or escaped livebaits have been responsible for the introduction of certain species to a number of waters in Scotland.
"There is no hard evidence for this, but even if it is true it could only account for a tiny fraction of the spread of locally non-native species and the dilution of genetic identity among established species in Scotland.
"There are several far more significant sources for inappropriate introductions. Most important among these are deliberate stocking by clubs, proprietors or individual anglers, and escapes or discards from aquaculture facilities and garden ponds.
"There is no necessary connection or causal link between the use of live fish as bait and the movement of fish between waters. These are two entirely separate issues."
The SFCA says tighter controls on fish transfers are the answer. It goes on: "The appropriate way to prevent inappropriate introductions and transfers is by legislation directly regulating fish movements.
"Such legislation is proposed Part 4 of the Bill, and has the support of SFCA. No additional Regulation is required.
"If the Executive believes it is essential to strengthen this by regulating the use of live fish as bait, the appropriate step would be to bring in provisions analogous to those in Denmark which directly restrict the use of livebaits to fish caught on the same day from the same water where they are being used.
"This is workable and would reinforce the message the Executive seeks to convey without alienating the angling community it aims to regulate. SFCA would be happy to work with the Executive and other stakeholders to formulate the details of a Regulation along those lines, and to promote compliance."
There are also concerns at proposals to allow all fish to be eradicated from river catchments infected with Gyrodactylus salaris - a salmon parasite found in Norway and the Baltic.
While it has not yet been found in Scottish rivers, officials are seeking powers to cull all fish in river systems where an outbreak occurs, despite the fact the disease affects only salmon and trout.
In its response, the SFCA said: "We appreciate that the power to apply selective eradication of affected species may have to exist as a last resort.
"However, that power should not extend to the eradication of stocks of species that are neither affected by nor capable of hosting Gyrodactylus salaris.
"Nor should it apply to waters within a catchment that are not connected to the river in which the affected salmonid population lives.
Stakeholders – including coarse angling interests – must be fully consulted when deciding the measures to be applied in the event of a particular outbreak, and such decisions must start from a presumption that eradication will not be the default approach."
It adds containment measures are preferable and damage to unaffected species should be kept to an absolute minimum.
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There is a limited consultation period, during which interested parties can make representations about the proposed new fisheries laws.
Written evidence should be submitted no later than September 15, by either e-mail or post to:
ERDC@scottish.parliament.uk
or:
Jenny Goldsmith, Assistant Clerk, Environment and Rural Development Committee, Room T1.01, The Scottish Parliament, Edinburgh EH99 1SP.
More details of the proposed bill here
