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Galloway Fisheries Trust

Fisheries House, Station Industrial Estate, Newton Stewart, Dumfries & Galloway, Scotland. DG8 6ND
Telephone: 01671 403011 · Fax: 01671 402248 · Scottish Registered Charity No. SC020751

Looking downstream on the River Cree

Brown Trout

Looking upstream on the River Bladnoch

Felling of commercial forestry in Galloway Forest Park

Looking upstream on the River Luce

North American Signal Crayfish

The sandy beach at Loch Grannoch

Belted Galloway Cattle, or 'Belties'

Fly fishing on the River Cree

Murray's Monument

A small upland burn

A stoneloach

The High Cree, looking towards Cairnsmore of Fleet

A small waterfall on the Buchan Burn

A salmon from the Kirkcudbrightshire Dee

GFT'S response to Marine Scotland regarding the BAN ON KILLING WILD SALMON

05 November 2015

Below is GFT's official response to Marine Scotland regarding the ban on killing wild salmon except under licence consultation.

Fiona Hepburn
Marine Scotland
Salmon and Recreational Fisheries Team
Area 1B North
Victoria Quay
Edinburgh
EH6 6QQ


29/10/15


Dear Ms Hepburn

Re: Ban on the killing of wild salmon except under license consultation

The Galloway Fisheries Trust (GFT) is a registered charity working across most of the freshwaters and fisheries in Dumfries and Galloway Region. We are part of the network of fishery trusts which make up the River and Fishery Trusts of Scotland (RAFTS) network. GFT has worked across Galloway since being established in 1989 and presently covers six main Scottish river catchments in south west Scotland; Water of Luce, River Bladnoch, River Cree, Water of Fleet, Kirkcudbrightshire Dee and River Urr.
The use of Conservation Limits to manage fish populations is wide spread around the world, including in the management of salmon populations in various European countries. The general principle of the technique is simply to calculate the egg requirement to fill the available habitats within a river system to sustain the population. You can then assess whether the adult spawning population is sufficient to be able to provide these egg requirements. Any harvesting (killing) of adult fish should only be allowed if it can be shown that the fish stock is able to meet its egg requirements.

The principle of managing fish populations using Conservation Limits should be endorsed and supported by all of those involved in managing fisheries and is essential for the short and long term sustainability of any fishery. However for conservation limits to work they must be based on accurate data and GFT do not believe this is the case with the calculations used to define the River Categories in the present consultation. Biologists, fishery managers, riparian owners and anglers will not support the consultation if they do not have faith in the accuracy of the egg requirement and present stock assessments used in setting Conservation Limits. It is important not to go against the ethos of the on-going Wild Fisheries Reform which appears to prioritise the need for evidence based management. The calculation of Conservation Limits must be accurate to ensure that future management considerations are correctly identified and undertaken. The lack of data provided so far through the consultation for each Fishery District, apart from which category it falls into, is also particularly unhelpful and limits the comments we are able to provide. More details behind the calculated figures for each of the five years being considered for each district would have allowed us to have provided a more informed response to the consultation.

Having examined the supporting paper titled ‘The application of Conservation Limits for Atlantic salmon in Scotland’ we are concerned that many of the general assumptions and non-local data sets which have been used to calculate the Conservation Limits in the Galloway rivers will not give a true assessment of the stocks in these rivers. Specific comments are provided below:

Regarding egg requirements – it is crucial that the egg requirement is correctly calculated to ensure it is adequate for the long term sustainability of the salmon populations and is attainable. Specific concerns GFT have regarding this are:

• The egg requirements per m2 of habitat for each river will not be the same across Scotland. Even within the Galloway rivers there will be variations due to river productivity, habitats, feeding, etc. This figure needs to be refined to ensure it is representative of the different situations around Scotland.

• Ensuring that there are accurate calculations of wetted area of juvenile habitat for each river system is crucial. The general modelling used may not be accurately calculating the correct quantity of wetted area. In the Galloway rivers there are extensive sections of main river stems which are deep and slow and play no role in juvenile production especially on the Rivers Bladnoch and Cree, and presumably this area should be excluded from the calculations. The Kirkcudbrightshire Dee is heavily modified by the Galloway Hydros Scheme resulting in numerous main channel impoundments creating the reservoirs of Loch Ken, Tongland, Carsfad and Earlstoun, and it is unclear whether these have been removed from potential juvenile production areas. Proper consideration needs to be given to the extensive areas affected by acidification in many Galloway river catchments headwaters and how they should be addressed in the model depending on whether can sustain natural spawning, or not, in their present state.
Regarding stock assessment – again it is crucial that the available spawning stock within each river can be accurately assessed when calculating whether the Conservation Limit is being met or not. Specific concerns GFT have regarding this are:

• The use of rod catch data on the Galloway rivers will not have provided accurate information on the overall population size. These rivers are all spate rivers and rod catches varies greatly between years depending on flow conditions experienced during the angling season. Angling effort also varies greatly depending on river flows and may vary by a substantial factor between years. Angling pressure across the Galloway rivers is generally light and many conservation measures have been put into place in recent years which have further reduced catches such as closing upper beats early, bag limits and delaying the start of the fishing seasons. It is wrong to use a system where by undertaking measures to limit catches – which are good conservation measures – results in the model reducing the estimated population size. It is recognised that within the present consultation paper some rivers will be category 1 and 2 rivers only because they are fished heavily compared to other rivers, which may actually have the same adult fish population, but because it is fished lightly will end up being a category 3 river suggesting that the river is unsustainable – this makes no sense at all. In addition, the suggested model appears to take no account for late running fish which may not enter freshwater until after the angling season has closed. The number of these late running spawners is believed to be significant in some years on some Galloway rivers, especially during some dry years. The accuracy of catch records must also be questioned on some rivers, especially regarding the historical data. Any measures which reduce angling pressure such as mandatory catch and release would be expected to reduce rod catches and, if using the present model, would suggest a lower overall population even though this may not actually be the case.

• There are other data sets such as juvenile electrofishing data which could provide important information on the health and size of the stock and should be incorporated into the model to make it more accurate.

• GFT does not think the suggested ‘grilse error’ used in the model will represent the true situation in the Galloway rivers. The suggestion that 42% of recorded multi-sea winter salmon caught (after June) are in fact grilse seems very high. It appears that if the ‘grilse error’ used is too high then this could result in underestimating the spawning stock present. This needs to be investigated at a local level.

• The exploitation rate used will have a strong influence on the overall stock calculation. Exploitation rates will vary greatly between rivers and between different years for a range of reasons: angling effort, angling methods used and whether the river is a spate river or not. It is important not to use a general figure for all rivers for this calculation.

• Finally it is important to ensure sex ratios are correct as there is some suggestion that these ratios may have started to change in recent years.

In summary:

– GFT supports the principle of using Conservation Limits to manage fish populations, especially Atlantic salmon.

– The proposed Conservation Limits methodology outlined in this consultation needs to be refined using locally derived available data for each river district (catchment).

– Without refining the methodology the model outputs for both egg requirements and present stock levels will not be accurate and thus may result in incorrect management decisions being made. In particular, the weight that rod catches have in the model to estimate stock size appears flawed on many rivers especially on the Galloway rivers.

– Any salmon population in a river is made up of many sub-populations divided by run timings and / or distribution around the catchment – these sub-populations should always be considered separately where possible as some may potentially have a harvestable surplus while others may not.

– If stakeholders, fishery trust biologists, anglers, fishery owners and managers do not feel the methodology and models outputs are accurate then these parties will not support or ‘buy-in’ to this system. Rushing in the current methodology for assessing CLS may prove counterproductive in the longer term.

– It is expected that angling effort will reduce on many rivers if 100% catch and release is imposed especially if the underlying principles justifying the restrictions are not supported. The proposed system as it stands would then suggest a reduced stock in the river even though this may not be the case.
GFT can see no justification in imposing the mandatory catch and release figures now without using the next 12 months to refine the Conservation Limit work undertaken to date by Marine Scotland. It is recognised that ultimately this may not change the categories of individual rivers but it will ensure that stakeholders and others involved in fisheries management understand and have more confidence in the overall system.


It is important that the Conservation Limit modelling for individual river districts is used in the future to consider why many stocks are low and what the pressures are limiting these stocks and which can be addressed. In Galloway, acidification of the headwaters of many rivers continues to limit the spawning and nursery areas which salmon can utilise. Mandatory catch and release will not return salmon to areas where water quality is too low to support them. GFT supports the proposed use of conservation plans to ensure good management of salmon stocks but it must result in practical improvements on the ground and this will need adequate resourcing and support from the various Government agencies.

GFT is keen to assist in any overall process to refine the suggested methodology to ensure it is truly representative and accurate and can be used to improve the overall management of freshwater habitats and the fish they support.

Yours sincerely

Jamie Ribbens
Senior Fisheries Biologist
Galloway Fisheries Trust


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