SFFF SG 5-3: Report of the Sub Group examining ideas for future management structures for salmon and freshwater fish
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1. Introduction
2. Principles & Objectives
3. Assessment of Options
4. Assumptions
5. Options for Funding
1. Introduction
The Freshwater Fisheries Forum Steering Group, at it's meeting on 7 October 2004, agreed to establish a Sub Group to consider views and generate a single document proposing a new structure of management for freshwater fisheries in Scotland, and for it to report back at the next meeting on 25 November 2004. The membership of the Sub Group is:
- Andrew Wallace - ASFB
- Dr Alastair Stephen - IFM
- Jane Wright - AWCFT
- George Holdsworth - ASSF
- David Howell - SNH
- Ron Woods - SFCA
- SEERAD representative
Whilst not a formal member of the Group, Brian Davidson agreed to draft the Report of the Group.
The Sub Group was not given a formal remit or terms of reference but was simply asked to consider the various models for a future management structure encompassing all species of freshwater fish, including migratory salmonids, and provide some guidance to the Steering Group on the most logical option. It is emphasised that the ideas in this report are simply that: they are not recommendations but are a synthesis of the various ideas discussed, and are intended to provide a focus for the Steering Group, and ultimately the main Fisheries Forum, on the potential way forward. The Sub Group, in its discussions, were mindful of the need to consider all options and to take a dispassionate, objective look at the strengths and weaknesses of these.
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2. Principles & Objectives of Any New Structure
The Sub Group agreed that any system, irrespective of how it is structured, should deliver a set of key aspirations and objectives for Scotland's salmon and freshwater fisheries. It agreed that it should set out a series of assumptions that any future management system should be prepared to work to and that alongside this should be listed some of the core functions of any future management structure. These are listed overleaf in no order of importance.
Principles | Functions |
Sustainability - management bodies must ensure that management is conducted according to principles of sustainability as they apply to management of fish stocks, fisheries and access to fisheries | Regulatory body - management bodies must be effective regulatory bodies with appropriate and enforceable powers, duties and responsibilities |
Accountability - management bodies must be accountable to anglers, proprietors, public sector bodies and the general public | Management planning - management bodies must be responsible for producing, collating and delivering fisheries management plans and ensuring such plans are integrated with other relevant plans eg) WFD |
Transparency - management structures must operate in an open and transparent manner | Funding - management bodies should have powers to collect and disburse funds |
Effectiveness - management bodies must operate efficiently and deliver cost effective benefits to anglers, proprietors, managers and the general public. Any new system must build on and improve on the old system. | Statutory consultee - management bodies must be considered as statutory consultees in all areas of public life that have an impact on the responsibilities of those bodies |
Proportionality - the focus of management must reflect the relative importance of each of the angling sectors in each area | Data gathering - management bodies, with the assistance of the SFCC must be responsible for collecting, collating and storing high quality data appropriate to the responsibilities of those bodies |
Self containment - funds raised locally must as far as possible be spent locally | Training - management bodies must ensure that all staff involved in the management and use of the fishery are trained to high and nationally consistent standards |
Subsidiarity - decisions must be devolved as far as is possible to catchment level, or indeed individual fisheries where appropriate. | Work to common standards - management bodies whilst recognising the different circumstances on the ground should work to consistent common standards |
Universality/Flexibility - a consistent management system should be applied but management bodies must be adaptable to the different circumstances that exist in catchments around Scotland | Representation - management bodies should be representative of the needs and aspirations of anglers, proprietors and managers in their area |
Funding - Sufficient funding must be made available from public and private sector sources to ensure that management bodies can function properly | |
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3. Assessment of Options
The Sub Group reviewed the analyses of the various options for future structures already tabled by some members of the Steering Group. The various models examined by the group were:
- Option 1: Retention of the status quo
- Option 2: Parallel structure
- Option 3: Unitary structure
- Option 4: Centralised control
- Option 5: Stimulated evolution
- Option 6: Expanded Salmon Fisheries Boards
- Option 7: Nationalisation
The following is a SWOT analysis of these 7 options:
Option 1- Retain Status Quo
Various combinations of District Salmon Fisheries Boards, Fisheries Trusts, Liaison Committees, Angling Associations etc interacting in different ways in different localities. Data collection, where it takes place, generally co-ordinated via the Scottish Fisheries Co-ordination Centre.
Strengths - DSFBs are a functional system for managing migratory salmonids - Management at a local level - PO's have some sound principles and in places appear to work well - Substantial investment from private sector - Good voluntary involvement in many locations - Where it works well it can work very well -No new legislation or public funding - well established roles and structures - attracts extensive voluntary effort in many locations - data-collection generally uses consistent methods, where it takes place | Weaknesses - Little management or statutory control of all other fish species - Little political support - Perception of democratic deficit and anachronistic legislation -Lack of engagement by public sector - Inconsistency -Conflict between species management - inconsistencies in roles and practices - gaps in coverage and / or representation - major gaps in data-collection, geographical and by species - no guarantee of expertise / qualifications on management bodies - largely salmo-centric - Where it does not work well it is weak, and there is no obvious mechanism to resolve problems. | Opportunities - Build on evolutionary progress of existing structures - System could be enhanced by strengthening the fisheries trust network to deal with other fish species issues and modernising the PO system to deal with access and management issues without fundamentally altering current system | Threats - Continued lack of engagement by public and political sectors - Lack of public support/buy-in - Reliance on income from fisheries which, with fisheries in decline, results in reduced investment when most needed. |
Option 2 - Creating A Parallel Structure
Establish new catchment-level management bodies which take responsibility for the management of freshwater species, acting in parallel with District Salmon Fisheries Boards
Strengths - Leaves existing DSFB system undisturbed, retaining the strengths of current management structures for migratory fisheries - Allow better focus on specific management issues - In some locations can build on established structures. - Largely retains psychological and legal ownership, and thus should sustain most voluntary effort and private investment. | Weaknesses - Administratively complex - Duplication of effort / lack of co-ordination - Confusing to outside world - Expensive duplication of effort and administrative structures - Would require effective mechanisms to co-ordinate migratory and freshwater management and mediate between competing interests No pre-existing way to fund management of species which generate little or no income | Opportunities/resources required - Not obvious - requires primary legislation to define roles and powers of freshwater management bodies - requires financial pump-priming to establish and maintain management structures which largely do not exist at present - need for the establishment of a rod licence system or other source of funds from anglers? - Might be possible to use a derivative of the liaison committee system to provide this structure (although no current provision in law to create such a committee). | Threats - Fragmentation and poor co-ordination in a sector already suffering from poor co-ordination. - Likely to suffer from inconsistency Conflict between species management - creates duplication of structures between migratory and freshwater fisheries - historical lack of mutual trust between freshwater and migratory interests in some locations - requires effective mechanisms to mediate between migratory and freshwater interests |
Option 3 - Unitary Structure
Abolish District Salmon Fisheries Boards. Create entirely new catchment-based umbrella bodies to take responsibility for the management of all species and all waters in the relevant catchment.
Strengths - A "fresh start", allowing stakeholders to move on from historical differences - Co-ordinated approach - Retains management at a local level - Retains local representation - Attractive to potential private / voluntary / public funders Precedent already set on the Tweed (Commissioners/Foundation) - in some locations can build on established structures. - largely retains psychological and legal ownership, and thus should sustain most voluntary effort and private investment. - leaves current management structures and arrangements for migratory fisheries undisturbed - data-collection should become universal and consistent - in many locations can build on sound relationships to reduce discontinuity arising from change - creates potential for cross-subsidisation - minimises change to current management structures and arrangements for migratory fisheries - data-collection should become universal and consistent. - Trusts could be retained alongside unitary Board to assist with fund-raising and provide scientific/management advice - Specific interests eg) non statutory salmon management groups/coarse groups/trout groups could be retained to manage specific fisheries within a Board area | Weaknesses - Achieving flexibility in representation to reflect circumstances on the ground - Creating a management Board small enough to manage and large enough to be representative - Difficulty in defining areas - Difficulty in developing expertise - Funding of management of species which generate little or no income required - substantially alters psychological ownership of freshwater and migratory fisheries management, thus creating a high risk of loss of voluntary effort and investment. - strong historical lack of mutual trust between freshwater and migratory interests in some locations - strong perceived danger of becoming even more salmo-centric Not sure I agree with this The rationale for this comment is that because the bulk of funding will generally be coming from migratory interests, the risk exists that those interests will dominate decision-making. More important, the perception that this will happen may make it difficult to establish trust. So saying, the original wording is a bit harsh. Perhaps substitute "Some perceived risk" for "Strong perceived danger"? - creates potential for cross-subsidisation | Opportunities/resources required - Create a structure which has political and public sector support but which retains local management control - Relationship with Trusts could be much closer - Opportunity to raise funds through area permit system - requires primary legislation to abolish DSFBs - requires primary legislation to establish new management bodies and define their roles, composition, and powers - requires establishment of new mechanisms for funding fisheries management - requires substantial financial pump-priming to establish new structures - need for the establishment of a rod licence system or other source of funds from anglers? - Trusts could be retained alongside unitary management body to assist with fund-raising and provide scientific/management advice - Specific interests eg) non statutory salmon management groups/coarse groups/trout groups could be retained to manage specific salmon fisheries within a catchment | Threats - Conflict between species management - May tend towards quango status - Perceived danger of domination by migratory interests - Management body may tend to become a "talking shop" - Alters psychological ownership of freshwater fisheries management, risking loss of voluntary effort and investment. Will be difficult to completely eradicate historical lack of mutual trust between freshwater and migratory interests in some locations |
Option 4 - Centralised Control - "EA surrogate"
Create a public body to assume fisheries management role inScotlandanalogous to that held by Environment Agency in E&W. (or modify SEPA's role to take on those responsibilities.)
Strengths - Ability to apply more consistent management - data-collection would become universal and consistent. - full coverage of all areas - capacity to switch resources from where they are generated to where they are most needed - capacity to draw in additional public investment according to need | Weaknesses - Absence or dilution of local representation - Very high cost - Bureaucracy - Loss of control at catchment management level - Lack of public support - Dissatisfaction with existing systems in England and Wales (EA) - management decisions influenced by political debate - resourcing affected by political priorities rather than actual need - difficulty establishing roles and relationships with riparian owners - cost of establishing & running new agency (or expanding SEPA) - ongoing cost of replacing some items currently funded by private sector investment - less psychological ownership will reduce voluntary effort / investment | Opportunities/resources required - Potential to take strategic "all-Scotland" view of fisheries management - Ability to apply consistent management practices - Capacity to deploy resources where they are most needed Capacity to draw in additional public investment according to need - Probably attract most buy-in from public sector - primary legislation to create new management body or alter SEPA role and delineate its powers - public funding for running costs of management body (or additional funding for SEPA expansion) - public funding for ongoing investment in fisheries - requirement to establish a rod licence system or other source of funds from anglers. | Threats - disenchantment within fishery owner network - lack of credibility - High proportion of new public investment absorbed in cost of establishing and running new agency (or expanding SEPA) rather than management on the ground - Tainted by general dissatisfaction with existing systems in England and Wales (EA), leading to lack of public / stakeholder support Minimal psychological ownership - would undoubtedly reduce voluntary effort and private investment |
Option 5. Stimulated Evolution
Identify and publicise minimum standards and best practice from current structures. Create incentives (eg, through conditions for granting Protection Orders, access to project funding etc which encourage /oblige fishery owners seeking public funding or statutory protection to adopt appropriate management structures and practice)s.
Strengths can develop in tune with local situations and priorities. - Retains, builds on and strengthens the best of existing structures - retains "psychological ownership", which should sustain voluntary effort and private investment. - data-collection will become more widespread, comprehensive and consistent in methods | Weaknesses - pace of development uncertain - potential that the flaws identified in respect of Option 1 will remain if the incentives built into legislation and funding practices do not prove sufficiently strong - potential for "tokenism" or possibly even deception to subvert the purpose of incentive measures - cost of resources to police compliance | Opportunities/resources required - Structures can develop in tune with local situations and priorities. - needs careful shaping of new legislation and funding practices to create incentives. - may stimulate greater demand for project funding. - would benefit from financial pump-priming to establish / maintain management structures were none (or only rudimentary structures) exist at present System could be enhanced by strengthening the fisheries trust network to deal with other fish species issues and modernising the PO system to deal with access and management issues without fundamentally altering current system | Threats - Continued lack of engagement by public and political sectors - Lack of public support/buy-in Reliance on income from fisheries which, with fisheries in decline, results in reduced investment when most needed. |
Option 6. Expanded Salmon Fisheries Boards
Extend the remit of District Salmon Fisheries Boards to encompass the management of all species and all waters in the relevant catchment.
Strengths - Minimises change to the existing DSFB system, largely retaining strengths of current migratory fisheries management structures - Retains management at a local level - Retains local representation - Co-ordinated approach - Data-collection should become universal and consistent. - Creates potential for cross-subsidisation | Weaknesses - DSFBs do not exist in a number of important catchments - alters psychological ownership of freshwater fisheries management, and thus risks loss of voluntary effort and investment. - strong historical lack of mutual trust between freshwater and migratory interests in some locations - strong perceived danger of becoming even more salmo-centric - creates potential for cross-subsidisation (Migratory) - Difficult to achieve flexibility in representation to reflect circumstances on the ground - Difficult to expand Boards sufficiently to be representative while keeping them small enough to manage - Difficulty in developing expertise - No pre-existing way to fund management of species which generate little or no income | Opportunities/resources required - requires primary legislation to redefine roles, composition, and powers of DSFBs - requires establishment of separate mechanisms for funding freshwater fisheries management - requires financial pump-priming to establish expanded structures - need for the establishment of a rod licence system or other source of funds from anglers? - Improve level of political and public sector support for management structure while retaining local management control - Relationship with Trusts could become much closer - May be able to raise funds through area permit system - In many locations could build on sound current relationships to reduce discontinuity arising from change. | Threats - Likely to suffer from conflict between species management - Perceived danger of domination by migratory interests - Board may tend to become a "talking shop" - Alters psychological ownership of freshwater fisheries management, and thus risks loss of voluntary effort and investment. |
Option 7. Nationalisation
Take all fisheries, freshwater and migratory, into direct state control.
Strengths - potential for high degree of consistency in management practices - data-collection would become universal and consistent. - full coverage of all areas - capacity to switch resources from where they are generated to where they are most needed - capacity to draw in additional public investment according to need - Perceived scope to increase and guarantee access | Weaknesses - politically controversial change - management decisions subject to political debate - resourcing dictated by political priorities rather than actual need - difficulty establishing roles and relationships with riparian owners - cost of compensating riparian owners - cost of establishing and staffing new management body - ongoing cost of replacing all current private sector investment - absence of psychological ownership will eliminate voluntary effort and investment - Loss of control at catchment management level - Absence of stakeholder support / participation Possibly subject to legal challenge | Opportunities/resources required - Potential to take strategic "all-Scotland" view of fisheries management - Ability to apply consistent management practices - Capacity to deploy resources where they are most needed Capacity to draw in additional public investment according to need - primary legislation to create compulsory purchase power, establish state-run management body and delineate its powers - public funding for compensation to current owners - public funding for running costs of management body - public funding for ongoing investment in fisheries - requirement to establish a rod licence system or other source of funds from anglers. - primary legislation to create compulsory purchase power, establish state-run management body and delineate its powers - public funding for compensation to current owners - public funding for running costs of management body - public funding to replace all current voluntary and private sector investment in fisheries - Need to establish a funding stream from freshwater anglers | Threats - absence of psychological ownership would eliminate voluntary effort and investment High proportion of new public investment absorbed by administrative overheads and compensation to riparian owners rather than management on the ground - Politically hugely controversial and would destroy much recent progress within and between angling sectors |
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4. Assumptions
An assessment of the strengths, weaknesses and opportunities of each model are listed above. A number of assumptions were made when considering which of options 1 - 7 may best lend itself to achieving the objectives alluded to in 2. above. These assumptions are:
- that the current system of management of Scottish freshwater fisheries can be improved on.
- that protecting the status quo is neither desirable nor defendable.
- that some form of change is likely to be demanded by the Executive, the public and Parliament. I think we might be over-egging it here. The public at large is probably blissfully unaware of the current situation, and I've certainly never heard the slightest suggestion that they are "demanding" change. Even the angling public is not exactly baying for new structures. Like it or not, most of them probably just want more stock fish.
- that we wish to retain the strengths of catchment-based fisheries management in Scotland and that some form of integration of management of all freshwater fisheries/fish stocks is desirable. I appreciate that we are trying to preserve catchment level management of migratory species, of course, but for freshwater fish we are not talking about "retaining" catchment management so much as introducing it. Surely that's actually part of what we are seeking to achieve?
- that to develop a parallel structure for managing fisheries other than salmon and sea-trout would lead to considerable confusion and that a centralised Environment Agency approach, such as is present in England and Wales, is unlikely to satisfy the principles listed above I don't think these should be portrayed as "assumptions". They suggest we have pre-judged the analysis. In truth, they are "conclusions". I don't entirely diagree with them, but this should emerge from the SWOT rather than being portrayed as a priori principles of it. I think this bullet point is covered adequately in the section which follows, ansd suggest it should be removed.
- that any new system should retain all the strengths of the existing system of migratory salmonid management and ideally improve on it as well as ensuring the sustainable management and use of all fish stocks and fisheries in Scotland
- that income from migratory salmonid management should not cross-subsidise other species management any more than it is doing so at present.
- that the above assumptions are based on the requirement that adequate funding can be sourced from both the public and private sector to pay for these management systems on a long term and sustainable basis
Based on the above assumptions, and taking into account the aspirations and objectives of the sector, the Sub Group agreed that:
Option 1 - Retention of the status quo, would fail to deliver what the stakeholders - the anglers, managers, public agencies and politicians - want. There is at present little political support for continuation of the current system. There is a fundamental vacuum in management for freshwater species and there is a ministerial commitment to address access (we acknowledge that access is being addressed separately but for the purposes of this process we strongly believe it must be tied together with management in view of the need for access to depend on sustainable fisheries).
Option 2 - A parallel structure, would create yet another organisation. This would result in duplication of effort where resources are already thin on the ground. This would be untenable and support for an additional tier of management would be extremely hard to source. Furthermore, co-ordination between the organisations would add a further burden to already stretched resources and would further compromise the ability of both bodies to achieve the objectives in 2.
Option 3 - A unitary structure, is the option which the Group felt could deliver most effectively the objectives above, as well as commanding the most support from the stakeholders. Our rationale is provided at the end of this section.
Option 4 - Centralised control, is very much how fisheries managed in England and Wales through the national Environment Agency. This type of structure would not lend itself easily to the existing legal framework in Scotland, and the Sub Group identified a number of issues associated with this approach, such as very high cost and level of bureaucracy, loss of control at catchment management level and high prospect of little public support. One element of the English system which does merit further discussion is the revenue raising power conferred by rod licensing and this is addressed in section 4., funding.
Option 5 - Stimulated evolution, is an interesting concept and one which we would not wish to discount out of hand. It is a concept which could complement the development of a unitary structure, using the best of existing structures and aiding development, through incentives and examples of best practice, and including all stakeholders. Such a concept would allow developments to take place in tune with local circumstances and priorities through positive means, with a legislative backstop where necessary.
Option 6 - Expanded Salmon Fisheries Boards, whilst appealing to some interests, would not provide a politically acceptable solution. There is a strong perception (and likely reality) that an expanded Board would retain a prime interest in salmon fisheries. It would be difficult to arrive at a compromise whereby all interests were happy in terms of representation and voice on the Board, revenue generation for each fishery component and disbursement of funds in a fair way. The' psychological ownership' of freshwater fisheries management would be altered, and thus risks loss of voluntary effort and investment. The Sub Group also recognised the strong historical lack of mutual trust between freshwater and migratory interests in some locations.
Option 7 - Nationalisation, would be a very radical move. Ideology aside, such a concept would be enormously expensive to the State in acquiring ownership of all fishings. Such a system would mean management decisions would be subject to political debate, resourcing dictated by political priorities rather than actual need and there would be a widespread lack of credibility between owners and the state management. Nevertheless, we acknowledge that there are some proponents of nationalisation but we believe that this is unlikely to command widespread support.
Conclusion:
It is being assumed therefore that a unitary system of management is the preferred option, taking into account the merits of stimulated evolution in developing such a system.
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5. Options for Funding
As suggested above no new management system can be expected to operate without sufficient long term core-funding. Unless such funding can be sourced the sub-group believes that there is little point in further discussion of the ideas listed above.
Sufficient funding is available from two principle sources:
The public sector - through block grant, project finance etc. from SEERAD, SNH and SEPA
The private sector - through some form of enforced contribution from anglers
The sub-group recognises that the current system of raising funds for the management of migratory fisheries through the system of statutory levies on proprietors based on rateable value, whilst having certain flaws, is a system that has proved robust, workable and proportionate. The sub-group therefore has concluded that this system should be retained and incorporated into any new management structure.
However, the additional responsibilities of a new management structure as proposed above will require further and substantial funding. This could be made available in a number of ways. The sub-group has considered the following options:
Option 1- Status Quo
Angling clubs and proprietors, acting individually or in groups, employ a disparate mix of approaches to raise money. The levels of funding for management varies from nothing at all through to fully commercial operations where management costs are an integral part of business overheads. Public funding, where it takes place, tends either to be in the form of small-scale support for publicly owned amenity fisheries or grant aid for specific projects, largely conservation-based.
Strengths investment made in response to perceived needs and/or commercial demand financial input supplemented by voluntary manpower from angling clubs and syndicates substantial private expenditure on some fisheries support for initiatives such as scientific fisheries trusts in some areas growth of fisheries trust network has enabled and encouraged many clubs and proprietors to manage more effectively / cost effectively | Weaknesses major gaps and inconsistencies management and/or data collection largely disregards species of little or no interest to anglers clubs and proprietors tend only to fund management activities perceived to serve their own priorities where revenue does not fund sound scientific advice, management activities can be inefficient or ineffective some of the "management" of freshwater species takes the form of control measures aimed at improving migratory fisheries | Opportunities Improved PO system could create scope for more revenue to be raised from freshwater fisheries and thus make it more attractive for clubs and proprietors to invest in longer term management activities the level of investment might be improved by educating and informing clubs and proprietors in the benefits of appropriate management and encouraging them to invest accordingly | Threats declining revenue to clubs & proprietors may reduce management at the very time it is most needed perceived decline in sport can prompt inappropriate short term management measures pressure to keep down the cost of permits or club subscriptions leads to under-investment in appropriate management, and to short-term rather than long-term measures |
Actions to develop as a national system of funding: No apparent possibility of developing in a way which would ensure adequate, consistent and universal coverage
Option 2 - Voluntary Donations
Funds raised from private or corporate donors.
Strengths Established as a significant source of revenue for fisheries trusts Can offer access to tax benefits associated with charitable donations, landfill credit etc Voluntary nature of donations creates accountability to deliver what the funders want | Weaknesses no guarantee that amount of money raised will meet the cost of appropriate management activities disproportionate amount of time, effort and resources absorbed in fund-raising uncertain flow of income makes it difficult to plan ahead. major gaps and inconsistencies | Opportunities clubs, proprietors and fisheries trusts can continue to encourage voluntary donations as one of several sources of support level of investment might be improved by providing clubs and proprietors better information about potential sources of voluntary donations and enhancing their fund-raising skills | Threats May concentrate management on activities that best serve the interests of the largest donors rather than activities that benefit the fishery as a whole. Level of funding vulnerable to changes in wider economic conditions and / or fiscal incentives Pool of potential donors may be limited - any attempt to exploit further may simply spread contributions more thinly |
Actions to develop as a national system of funding: No apparent possibility of developing in a way which would ensure adequate, consistent and universal coverage
Option 3 - Area Permits
A single permit allowing the purchaser access to a group of fisheries owned by several proprietors. The "area" concerned may be anything from a fairly small locality to an entire catchment or a geographical region. Funds raised from permit charges, after expenses, are aggregated and reinvested in the management of the fisheries in the area.
Strengths Well-established as the norm in Europe and North America, and appears to work in those countries A few successful small-scale examples already operating in Scotland Provides economies of scale in administration and enforcement Creates scope for more strategic and co-ordinated approach to management Can improve sustainability by encouraging anglers to use all the fisheries in the area rather than concentrate on particular "hot spots" | Weaknesses the great majority of fisheries are already privately owned and run, and there is little evidence of a widespread desire for a collective approach the strength of the link between riparian land and fishery ownership tends to promote individual approaches Individual clubs or proprietors can block the creation of viable groupings of fisheries or fragment them by pulling out of established arrangements Many clubs & proprietors resist pooling of revenue and loss of personal control from joint decision making | Opportunities Improved PO system, if structured accordingly, could stimulate development of area permit arrangements in additional localities in Scotland | Threats May create perverse incentive for some clubs or proprietors to "go it alone" by offering more favourable terms or less restrictive regulations |
Actions to develop as a national system of funding: It is difficult to envisage any way to ensure consistent and universal coverage short of taking all freshwater fisheries into public ownership or making the establishment of area permits mandatory.
Option 4 - Rod Licences
A statutory charge which anglers have to pay before they can fish lawfully with rod and line in any freshwater. The charge is separate from, and additional to, any permit fee to fish a particular water, and applies even where the angler himself or herself is the owner of the fishing rights.
Strengths Well-established means of raising funds (around £18 M pa gross) from anglers in England & Wales Equity in level of anglers' contribution system is universal and consistent clear, simple and readily understood can attract substantial levels of compliance would be readily accepted by visiting anglers - most of whom expect to have to pay for this kind of licence Creates scope for a strategic and co-ordinated approach to management | Weaknesses no tradition of rod licencing in Scotland current provisions in E&W are fundamentally flawed in many ways, and are not well loved by anglers clubs or proprietors who believe they already raise sufficient for the management of waters they control tend to perceive this as all cost and no benefit for their clients / members anglers who purely use commercial or well-funded club fisheries would be funding the management of fisheries in which they have no interest | Opportunities Adopting the concept of rod licences would not require the wholesale importation of the E&W model. In particular, it is neither necessary nor desirable for the money raised by rod licences to be channelled through a monolithic national agency like the EA. | Threats Collection and enforcement costs can be substantial (understood to be between 20% and 25% in E&W) Risk that money raised centrally would become a substitute for, rather than a supplement to, existing sources of funding and voluntary effort |
Actions to develop as a national system of funding: Primary legislation would be required to establish a statutory rod licence. Machinery would have to be put in place to collect and disburse the revenue concerned, and to enforce compliance.
Option 5 - Levy on proprietors
A statutory "rate" on the notional value of each fishery. The value may be calculated with reference to variables such as catch levels. Funds raised from the "rate", after expenses, are aggregated and reinvested in fisheries management at catchment, regional or national level.
Strengths Long-established and largely effective means of funding Salmon Fishery Boards. Best suited to situations where management actions in one proprietor's area of the fishery have a substantial impact on others can be taken into account when setting permit charges, and thus passed on to anglers. | Weaknesses Most freshwater fisheries do not possess the characteristics that lend themselves to this approach in respect of migratory fisheries An extra tax on commercial fishery owners' business, many of which are marginal and already face decline in revenue As freshwater fishery rights are closely tied to land ownership, would also effectively be a tax on land would raise funds from commercial fishery owners' businesses to subsidise other providers in direct competition with them - ECHR implications? | Opportunities Voluntary levies (Option 2) may allow stakeholders in particular localities a way to raise money for projects or activities that cannot otherwise be funded | Threats cost of establishing and maintaining database of fishery ownership and valuation arrangements cost of collection and enforcement |
Actions to develop as a national system of funding: Primary legislation (probably outwith the scope of fisheries legislation) would be required to establish a levy and a system of valuation. All riparian proprietors would have to be identified, their fisheries evaluated to assess fair contributions, and machinery put in place to collect and disburse the revenue concerned.
Option 6 - Permit levy
A proportion of the cost of all fishing permits sold. Funds raised from permit levies, after expenses, are aggregated and reinvested in reinvested in fisheries management at catchment, regional or national level.
Strengths some quite successful small-scale examples already exist in Scotland can work in certain circumstances, as long as there is general support for the concept superficially fair for anglers - those who fish most (and therefore benefit most) would pay most. potentially transparent - the money raised from a particular branch of angling or a specific fishery can readily be identified | Weaknesses problems assessing appropriate contribution where club subscriptions give access to fishing but also fund other activities, or where hotel accommodation charges include provision of fishing for guests would function as a de facto tax on commercial fishery owners' and hotel owners' businesses would raise funds from commercial fishery owners' businesses to subsidise other providers in direct competition with them - ECHR implications? anglers who purely use commercial or well-funded club fisheries would be funding the management of fisheries in which they have no interest | Opportunities Improved PO system, if structured accordingly, could stimulate development of localised permit levies as a means of supplementing core funding in some catchments or groups of fisheries | Threats very high risk of avoidance where the person or body running the fishery isn't fully on board cost of establishing and maintaining database of fisheries cost of collection and enforcement |
Actions to develop as a national system of funding: Primary legislation would be required to establish a statutory levy and a graduated system of contributions. All riparian proprietors would have to be identified and machinery put in place to collect and disburse the revenue concerned.
Option 7 - Levy on sales of fishing tackle
A proportion of the cost of all fishing tackle sold in Scotland. Funds raised from the tackle levy, after expenses, are aggregated and reinvested in reinvested in fisheries management at catchment, regional or national level.
Strengths superficially fair for anglers - those who fish most (and therefore buy most tackle) would pay most. Tackle trade currently benefits - albeit indirectly - from investment in fisheries management, but contributes little or nothing to support it. | Weaknesses An extra tax on fishing tackle dealers' business, many of which are marginal and facing a decline in revenue already considerable problems assessing contribution where goods sold in tackle outlets have uses outwith angling, or where "general" retailers sell a few items of tackle much of the expenditure by Scottish anglers on fishing tackle is through mail order / Web-based suppliers, many of which are based elsewhere in the UK or further afield levy would create business disadvantage for several major Scottish tackle dealers who have mail order / Web-based businesses which sell throughout the UK or further afield - ECHR implications? | Opportunities More scope may exist to encourage voluntary contributions from the fishing tackle trade (Option 2) to raise money for projects or activities that cannot otherwise be funded | Threats very high risk of avoidance would tend to divert spending on fishing tackle to suppliers outside Scotland cost of establishing and maintaining database of fishing tackle outlets cost of collection and enforcement |
Actions to develop as a national system of funding: Primary legislation (probably outwith the scope of fisheries legislation) would be required to establish a statutory levy. All fishing tackle outlets would have to be identified and machinery put in place to collect and disburse the revenue concerned, and to enforce compliance.
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