Salmon fishing - proposed river gradings 2024: consultation analysis

3. Consultation analysis

3.1 Respondents and their interests

There were 37 responses submitted to the consultation which consisted of those from individuals (46%) and organisations (54%). A range of organisations submitted responses to the consultation including six District Salmon Fishery Boards, the River Tweed Commission, five river or fisheries trusts, three angling clubs or associations, three organisations with national membership such as Angling Scotland and Fisheries Management Scotland and two other businesses.

A majority of respondents (57%) indicated that they had an interest in the river grading assessments for the whole of Scotland, although 68% of respondents expressed an interest in specific freshwater systems. More than 26 rivers, lochs and geographical regions across Scotland were indicated to be of interest to the respondents of this consultation.

3.2 Views of consultation respondents on the proposed river gradings

A small proportion of respondents (14%) agreed with the proposed gradings for the 2024 salmon fishing season, 41% objected and the remainder did not express a specific view for or against the gradings.

A number of respondents (35%) indicated that they believed the proposed grade assigned to a specific river was incorrect and should be changed. These were broadly split into those who felt one or more river grade should be decreased (19%); and those who felt one or more river grade should be increased (16%). In this context a decrease in grade would have been a call for a grade 1 to be reassessed as a grade 2 or for a grade 2 to be reassessed as grade 3. For a requested increase in grade this could have been a request for a grade 3 to be reassessed as grade 2 or a grade 2 to be reassessed as grade 1.

A quarter of respondents (27%) made a plea for a mandatory catch and release regime to cover all of Scotland, 30% of those that suggested this had also asked for a decrease in one or more river gradings. A third of respondents (32%) raised concerns over the methodology used to calculate the conservation status of rivers.

Prominent issues raised included:

• requests for fish counter data to be used in addition to rod catch data in the assessment of river conservation statuses (27%)
• concern that the gradings do not accurately reflect the status of spring fish (24%)
• that rod effort on rivers should be considered in the assessment method (22%)
• concerns of missing catch data due to lower catch rates and/or individuals not submitting their catch return forms on time or at all (22%)
• additional data such as those from the National Electrofishing Programme for Scotland (NEPS) should be included in the assessment model (14%)
• environmental conditions such as low water levels reduced the number of catches or that flow data should be used within the assessment model (11%)

Only one response provided additional substantive evidence that requires further review.

3.3 Views expressed on impacts of the proposed gradings on respondents

Over a third (38%) of respondents expressed concerns that they or their business would be financially or otherwise impacted due to the proposed river gradings. This was equally expressed by those that identified themselves as organisations and individuals. The impacts raised were broadly defined under two main themes, income related concerns and angler related concerns.

Prominent issues raised across these themes included that the proposed gradings would:

• have a wider economic impact on rural communities (46%)
• result in reduced income for businesses directly or indirectly associated with angling (41%)
• deter anglers from the sport and reduce tourism, which respondents were also concerned would lead to decreased angler presence on rivers (41%)
• result in areas being seen as not attractive to anglers as there is a perceived poor chance of catching salmon (30%)

3.4 Views expressed on other actions to protect and restore wild salmon populations

A majority of respondents expressed views demanding urgent actions taken on other pressures that they felt needed to be taken now in order to better protect salmon populations.

There were a number of pressures on wild salmon populations identified by respondents, these have been ranked by the percentage of total respondents who mentioned that pressure:

• predation (41%)
• habitat degradation including issues associated with river barriers (27%)
• aquaculture activities (24%)
• low water quality and pollution (24%)
• pressures in the marine environment (22%)
• low water flows and abstraction (19%)
• climate change (16%)

Furthermore, a number of actions were suggested by respondents to help protect and recover wild salmon populations. These are ranked by the percentage of the total respondents who mentioned these actions:

• taking an ecosystem wide approach to protect and preserve the wider environment (57%)
• stocking (30%)
• preventing illegal fish poaching (11%)
• close rivers to angling for set periods of time through adjusting angling season times (11%)

Finally, respondents were asked what further information they would have liked us to provide so that they could make an informed response to the proposed river grading consultation. This highlighted that 43% of respondents wanted a specific plan to address the decline of wild salmon, and/or had indicated that knowing how the proposed river grading consultation connects with other Scottish Government policies would be useful.