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| PAC response to 'Scotland's freshwater fish and fisheries: Securing their future'. |
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October 25th 2001 Graeme
Waugh Dear
Sir, I am privileged to represent the Pike Anglers Club of Gt. Britain in responding to the Scottish Executive's Green Paper, specifically on the points which directly affect our members. The Pike Anglers Club of Gt. Britain (PAC) was formed in 1977. It is the representative body for pike anglers throughout Great Britain, and has a membership in excess of 2,000. A significant number of these are resident in Scotland, and many others are regular visitors. Since its inception PAC has been involved with many waters in Scotland, both from a fisheries management point of view, and also in the promotion of greater opportunities for pike angling. Our Mission Statement reads:
Historically, pike were regarded as little more than vermin, to be killed and removed at all costs, although thankfully attitudes are changing and it is now widely accepted that pike deserve to be protected and preserved like any other species. With this in mind it is disappointing to note that the Green Paper does not contain any proposals geared specifically towards the conservation of pike, when other species are singled out as being particularly desirable from a fisheries development point of view. This potentially serves to reinforce the archaic view that pike are somehow less desirable, and this is not at all helpful. Over the years Scotland's game fisheries have blossomed at the expense of coarse fishing interests, and arguably pike have suffered a far greater degree of persecution than any other species. PAC would like to see measures adopted which would end the wholesale slaughter of pike, in favour of other species, on Scottish waters. The Green Paper raises a number of other issues which are of direct concern to pike anglers. I would like to offer the following comments in response to paragraph 53 on page 14 which deals with Legitimacy of coarse angling methods: The concept of 'set lines' in conjunction with modern coarse angling methods does require to be examined. It is now common practice for specialist coarse anglers (including pike anglers) to utilise a number of rods at any one time, these usually being set in rod rests or on a purpose designed rod pod. Given that 'catch and release' is practised almost without exception within coarse angling circles, the use of multiple rod set-ups is only made possible by the adoption of adequate (audible and visual) means of bite indication, and by virtue of the angler being in close attendance at all times. Issues such as this may be dealt with via a 'Code of Conduct', such as that issued by the Specialist Anglers Conservation Group in 1997. This code is currently under review and will be re-published in due course under the organisation's new title, the Specialist Anglers Alliance. This code has been supported by all the relevant single species groups within coarse angling, including PAC, and has been endorsed by a wide range of individuals and organisations from outside the world of angling. A copy is enclosed for your reference (please see page 4). In drafting new legislation, consideration should be given to the number of rods an angler might use at any particular time, in England and Wales the maximum is four. 'Set lines' which are unattended serve only to capture fish which are invariably gut hooked and killed as a result. There are means by which set lines can be used to take fish alive, but these are only adopted for the covert purpose of taking fish illegally (carp in particular can command a high commercial value) and have no place within angling. Unattended ' set lines' should therefore remain illegal in Scotland. Moving on to the detailed proposals for new legislation affecting the Introduction and transfers of non indigenous species (page 7, paragraph 19); the Green Paper is not clear about exactly what is meant by the terms 'non indigenous' and 'exotic'. I would point out that some species which may well fall into these categories actually provide a valuable angling resource. Rainbow trout, carp and barbel, all of which are already established in Scotland, are perhaps the most obvious examples. 'Banning the introduction, keeping or release of such species', as the Green Paper proposes, suggests that the Scottish Executive might support a policy of culling those fish already present - which I find difficult to believe. Surely it would be more practical to examine ways in which the existence of these fish could be properly recognised for the benefits they provide to anglers ? Some measure of control is most certainly needed in Scotland in order to prevent the indiscriminate introduction of species to waters where their presence may have an adverse effect on the existing population. PAC has always supported the Environment Agency by strongly discouraging the movement of fish between waters in England and Wales, unless written consent has first been obtained in accordance with Sec. 30 Salmon & Freshwater Fisheries Act 1975. The criteria on which the Environment Agency judges applications for the introduction of fish to waters are strict, but entirely reasonable. PAC has made it clear to members that any breach of this particular legislation will result in their expulsion from the Club. A draft copy of an SAA information sheet dealing with this issue, and fully supported by PAC, is attached. I would respectfully suggest that there are difficulties in enforcing legislation which affects the activities of anglers, particularly in remote areas. In accordance with the request for views on how carefully targeted advice might assist in reducing unwanted introductions in the future (page 7, paragraph 21), PAC is well placed to deliver such advice to pike anglers throughout Great Britain - not just to those who reside in Scotland. I am deeply concerned by the next proposal (page 7, paragraph 22): "Anglers' use of live bait has led to infestation by non indigenous species, or transfers of species to catchments where they were not previously found. When a suitable legislative opportunity presents, we propose to take the necessary powers to enable a total ban to be put on the use of live fish as bait". With respect, it has to be said that the premise on which this proposal is based is fundamentally flawed. Whilst it is undoubtedly true that certain species have, over the years, found their way into waters where they were not previously found, I would challenge the assumption that anglers' use of live bait is wholly responsible for this. The example which has been quoted in the past relates to the presence of ruffe in Loch Lomond. However, to the best of my knowledge it has never been scientifically proved that their presence is the result of anglers' use of that species for livebait. Indeed, I am not aware of any pike angler who would seriously consider the use of this species for bait when other species (perch for example) are readily available in the loch itself. It cannot be disputed that some Scottish waters have become populated with 'non indigenous' species. The escape of large numbers of rainbow trout from hatcheries and fish farms is a prime example of such an occurrence - and has nothing to do with livebaiting. It is worth noting that , in Great Britain, there are no proven cases of the escape or transfer of live bait into non-donor fisheries assisting in the spread of disease or parasites. The use of live fish as bait is an established, legal angling method for capturing piscivorous and some omnivorous fish. Livebaiting is highly effective for pike, perch, eels, and for trout. In the sea live fish are used as bait largely for members of the shark family and for bass. It is vital to appreciate the fact that using live fish for bait is not dependant upon the introduction of fish from elsewhere and that there appear to be no documented instances of freshwater fisheries where the capture and removal of fish for bait has caused significant depletion of the fish populations. There
is therefore no reason why anglers should be denied the opportunity to use live
baits caught from the water being fished. The proposal to ban livebaiting in Scotland is quite unnecessary and is strongly opposed by the anglers who would be affected. This is evidenced by the enclosed petition which carries the names of almost 600 anglers who support PAC in making representation for the retention of livebaiting as a legal method in Scotland. In addition, a poll conducted on PAC's web site has demonstrated that 96% of respondents supported the Club on this issue, even though 63% were not members. In conclusion, I would urge the Scottish Executive to consider the points raised in this submission with a view to re-evaluating some of the proposals currently on the table. In this regard it is hoped that PAC's contribution to the consultation process will be viewed as a positive one, and will prove to be of assistance. Yours sincerely, Mark Leathwood General
Secretary |