THE SCOTTISH WILD SALMON STRATEGY
The Scottish Government has now published the first stage of its long awaited Scottish Wild Salmon Strategy. The Board welcomes its publication but recognises some interpretation may be appreciated.
The strategy has been produced through recognition that the Atlantic salmon is in real difficulty and hopes to guide collective action. Scottish Government appear to appreciate the urgency of the situation, stating that the strategy needs to be delivered “extensively” and “at pace”.
The document sets out the background to the salmon decline, recognises the economic, social and environmental value of salmon and lists pressures acting on them.
The key section for the Board is chapter 5, Priority themes for action, particularly the first section Improving the condition of rivers and giving salmon free access to cold, clean water.
Seven specific types of action are listed. All are directly relevant to our own River Management Plan published last year.
For example, our plan identifies a number of issues where our action is to “lobby” SEPA to prioritise certain works which fall under their remit. Some of these issues have been identified for action by SEPA by 2027 under the 3rd Water Framework Directive (WFD) River Basin Management Plan, although some have actually been delayed from earlier planning rounds. Therefore, we welcome Scottish Government’s commitment for
“Meeting or exceeding all WFD targets/actions on water quality, quantity, in-river habitat and barrier easement. This requirement will include SEPA carrying out a review of existing CAR licences to improve fish passage at a range of active operations including distilleries, public water supply and hydropower; scheduled programme of barrier removal at historic/redundant sites to be completed by 2027.”
We have supplied evidence to SEPA on the necessity for action to be taken during low flows, particularly on the Ericht and the Lochay, both of which are in our plan. Thus, we welcome the commitment to “following a consultation in 2021, SEPA will take a new approach to addressing water scarcity, with greater management of water abstraction which will address or minimise impacts of drought conditions on salmon.”
We have also identified significant issues which are not considered in SEPA’s river ecology classification schemes and not currently subject to any regulatory framework. A good example is the slow growth of juvenile salmon in the River Lyon resulting we suspect from flow regulation. As the River Lyon only needs to meet certain criteria on amount of flow (which it well exceeds) it is considered to be at “Good Ecological Potential” and therefore there is no driver for any action. Thus, again, we see an opportunity in the strategy to:-
“Undertaking assessments and assemble case studies to determine possible gaps where achievement of RBMP targets may not provide adequate protection for salmon at local and/or national scale.”
We will do everything in our power to have the Lyon included as one of these case studies, hopefully leading to real action.
In our forthcoming 3 year plan we will also identify areas where at least some of the following is relevant:-
“Improving climate resilience of rivers, for example through supporting targeted riparian tree planting and natural regeneration and peatland restoration.
Incentivising habitat improvement projects, such as sustainable riverbank protection, installation of large woody structures and re-connecting natural flood plains.”
Our plan also seeks further funding to extend and expand the highly successful Scottish Invasives Species Initiative. This is covered too by:-
“Preventing and mitigating the introduction, establishment and spread of invasive non-native species.”
And, finally, our wish for more effective deterrence of fish eating birds is supported by:-
“Undertaking a review of fish-eating bird policy with a view to ensuring balanced consideration of the conservation status of predator and prey species and informing the proposed wider review of the species licensing system.”
We are also supportive of the 2nd, 3rd and 4th Priority themes, particularly that on exploitation which has the most direct relevance to us.
Regarding the 5th priority theme, Developing a modernised and fit for purpose policy framework, we draw your attention to Scottish Government’s seeming desire to enhance the links between central government and local management. While we welcome broad principles suggested and the possibility of new funding sources, the detail may require careful consideration.
To sum up, the Strategy document sets out Scottish Government’s aspirations for works to be done. It is encouraging therefore that many of the priorities listed align closely with our own. However, the most crucial stage in the process will be an Implementation Plan which will contain the detail and is to be published within one year.
Whilst there is much to welcome, we are concerned about waiting 12 months for the Implementation Plan when actions are required now. We are also concerned about SEPA’s ability to deliver of the roles allocated to them in the Strategy.
We will work tirelessly on your behalf to ensure that the priorities of the Tay River Systems are appreciated and understood, and accepted as part of the Implementation Plan, moved up the Agenda, and delivered.