Impact of water abstraction on water levels in major Scottish Salmon rivers: EIR release
Information request and response under the Environmental Information (Scotland) Regulations 2004.
Information requested
No 1: What studies has Marine Directorate carried out or commissioned to show the impact of water abstraction on water levels in major Scottish Salmon rivers, especially during long drought spells as experienced this summer?
No 2: Why does Marine Scotland allow the restocking of rivers with hatchery-raised and fed Brown Trout but not Salmon and Sea Trout?
No 3: What scientific trials and what published papers does Marine Scotland have that show and explain why restocking rivers with hatchery-reared and fed Salmon and Sea Trout fry/parr is not an acceptable practice?
No 4: Can you supply reports showing the mortality rates for wild ova, Alevins, Fry, Parr, and Smolts of Salmon in Sea Trout in freshwater?
No 5: Can you show any statistics for the survival rate of Salmon and Sea Trout transplanted/stocked eyed ova and unfed fry?
Response
As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.
This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.
Response to your request
The answers to your questions are as follows:
No 1: What studies has Marine Directorate carried out or commissioned to show the impact of water abstraction on water levels in major Scottish Salmon rivers, especially during long drought spells as experienced this summer?
Answer:
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested above. Therefore, we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reason why that exception applies is explained in the Annex to this letter.
Additional information provided out with the EIRs :
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide some additional information that may be of interest.
Scotland’s National Water Scarcity Plan sets out how water resources are managed during periods of prolonged dry weather. As part of that plan, the Scottish Government’s Directorate for Environment and Forestry, SEPA and Scottish Water have established processes to monitor the situation, protect the environment and support those affected.
SEPA uses a combination of river flows, soil moisture, and groundwater data to determine water scarcity levels of Early Warning, Alert and Moderate Scarcity.
To identify the most severe situations, SEPA uses DRAT (Drought Risk Assessment Tool) stations, which monitor river flows closely. If a DRAT station shows that river flow is at Q95 - a recognised low- flow threshold in hydrology - for 30 consecutive days the catchment is classified as experiencing Significant Scarcity.
This science-led approach is used to track environmental conditions and help prevent lasting harm to rivers, lochs and the ecosystems that depend on them.
If conditions do not improve and these areas move to Significant Scarcity, SEPA takes regulatory action. Measures may include limiting or temporarily suspending abstractions where necessary. These decisions will be based on sound science and environmental monitoring, including recognised hydrological low-flow thresholds based on river flow records that span decades. Restrictions will only be in place for the shortest time possible.
No 2: Why does Marine Scotland allow the restocking of rivers with hatchery-raised and fed Brown Trout but not Salmon and Sea Trout?
Answer:
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested above. Therefore, we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reason why that exception applies is explained in the Annex to this letter.
Additional information provided outwith the EIRs :
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide some additional information that may be of interest.
The Scottish Government’s Marine Directorate does permit stocking of rivers with hatchery-raised brown trout, sea trout and salmon in certain circumstances. The relevant policies can be found at the following address:
https://www.gov.scot/publications/introduction-of-freshwater-fish-and-ova/
Under the Salmon and Freshwater Fisheries (Consolidation) (Scotland) Act 2003, District Salmon Fishery Boards (DSFBs) are the consenting authority in the vast majority of cases involving salmon and sea trout with the Scottish Ministers acting as the consenting authority where in Districts where there is no DSFB. The consents issued by the Scottish Government are published at the following link:
List of consents issued by Marine Scotland for the introduction of freshwater fish - gov.scot .
No 3: What scientific trials and what published papers does Marine Scotland have that show and explain why restocking rivers with hatchery-reared and fed Salmon and Sea Trout fry/parr is not an acceptable practice?
Answer:
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained in the Annex to this letter.
As outlined in the answer to question no.2, the Scottish Government’s Marine Directorate does allow stocking of rivers with hatchery-raised brown trout, sea trout and salmon in certain circumstances. The relevant policies can be found at the following address: https://www.gov.scot/publications/introduction- of-freshwater-fish-and-ova/
Some of the information you have requested is available from Science of Salmon Stocking: Scientific Considerations in Stocking Policy Development for River Managers which was published in February 2023 by Marine Directorate and which brings together the science behind the various considerations needed to be taken prior to and following stocking, with a view to aiding design of salmon management strategies that balance risks and benefits within a broad policy framework.
Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format.
No 4: Can you supply reports showing the mortality rates for wild ova, Alevins, Fry, Parr, and Smolts of Salmon in Sea Trout in freshwater?
Answer:
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained in the Annex to this letter.
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide some additional information that may be of interest. Some of the information you have requested is available in:
Soulsby, C, Tetzlaff, D & Malcolm, I 2024, 'Six decades of ecohydrological research connecting landscapes and riverscapes in the Girnock Burn, Scotland : Atlantic salmon population and habitat dynamics in a changing world', Hydrological Processes, vol. 38, no. 3, e15105.
Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format.
No 5: Can you show any statistics for the survival rate of Salmon and Sea Trout transplanted/stocked eyed ova and unfed fry?
Answer:
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained in the Annex to this letter.
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide some additional information that may be of interest. Some of the information you have requested is available in:
Survival and growth of salmon, Salmo salar (L.), planted in a Scottish stream - Egglishaw - 1980 - Journal of Fish Biology - Wiley Online Library
Can Conservation Stocking Enhance Juvenile Emigrant Production in Wild Atlantic Salmon - P. J.
Bacon , I. A. Malcolm , R. J. Fryer , R. S. Glover , C. P. Millar , A. F. Youngson – 2015 - Transactions of the American Fisheries Society, Volume 144, Issue 3, May 2015, Pages 642–654
Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format.
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