Wednesday, September 13, 2006

Scottish Fisheries Bill - the PAC's response


From the Pike Anglers Club of Great Britain

1/ General

We fully support and endorse the responses already tabled by the Pike Anglers Alliance or Scotland and Scottish Federation for Coarse Angling.

Part 2 GYRODACTYLUS SALARIS: Containment and Treatment

We are extremely concerned at provisions which allow the eradication of all species in rivers or catchments where an infestation of GS is detected.

While selectively culling an infected species may be necessary in the event of an infection, there can be no justification for eradicating fish which are not susceptible to or capable of carrying GS.

We endorse the Scottish Federation for Coarse Angling's view that eradication should not be the "default approach".

To do so effectively creates the power to poison whole river catchments.
We view this as a shoot first, ask questions later approach, with unknown environmental consequences and damage to the genetics of fish strains which have evolved in a catchment.

Fish eating birds obviously depend on fish, as do otters. Wiping out stocks in a catchment obviously deprives both of their main food source, again with unforseen consequences.

It should also be noted that so far, GS has not occurred anywhere in the British Isles and has so far been confined to Scandinavian salmon populations.


Para 20: Use of gaff, tailer or landing net

We welcome the measures proposed.

Para 21: Rod and line

We welcome the definition and measures proposed. Using rod rests to support multiple rods is legal just about everywhere else in the world and an integral part of prompt bite indication, which is essential if damage to pike stocks is to be minimised.

Para 22: Prohibition against using pike gags and certain keepnets

We welcome the measures proposed. Pike gags are unnecessary and both ourselves and the Pike Anglers Alliance for Scotland devote considerable energies to promoting safe fish-handling techniques and the use of unhooking mats and the correct tools.

Para 25: Freshwater fish conservation regulations

We strongly disagree with the statement in Para 50 of the Policy Memorandum that suggests Ministers should be allowed to specify particular baits and lures that may be used for freshwater fishing in the same way as they can for salmon under Section 33 of the 2003 Act.
We believe any bans should be the province of individual fishery owners and controlling clubs, in consultation with interested and informed bodies such as the Scottish Federation for Coarse Angling, the Pike Anglers Alliance for Scotland and ourselves.

We welcome the provision of added protection for freshwater fish species against removal or activities that adversely affect their environment.
We are aqware that indiscriminate culling of coarse fish, generally by the use of nets, takes place on many waters in Scotland, yet at present the law exercises little control over the removal of freshwater fish by means other than rod and line.

Section 2 of the 2003 Act should be repealed and replaced by appropriate regulations controlling all removals other than via rod and line.

We fully endorse the Scottish Federation for Coarse Angling's comments on measures such as lowering water levels or the installation of gabions.

We reject the claim that anglers translocating livebaits have been responsible for the wholesale introduction of species such as roach to waters where they were not previously indiginous.
More likely sources are deliberate stockings made by clubs, proprietors or individual anglers, and escapes or discards from fish farms and even garden ponds.

We believe that the appropriate way to prevent inappropriate introductions and transfers is by legislation directly regulating fish movements, such as exists in England under Section 30 of the Salmon and Freshwater Fisheries Act.

In view of the remote nature of many Scottish fisheries, we would argue a livebaiting ban would in any case be unenforceable in some areas.


These are our comments in reply to the ERDC's request for responses from interested groups.

We would be happy to provide a representative to appear before the committee to be examined or provide further supporting information should this be required.

The Pike Anglers Club of Great Britain, September 11, 2006