Sixty eight percent: According to the Mail on Sunday anglers are facing a salmon ban on 117 of Scotland’s top rivers. However, despite this sensationalist headline, anglers are only banned from keeping the fish, which translated means that they must catch and release if they fish for salmon. This ‘ban’ is being introduced after officials ruled that 68% of Scottish salmon stocks are unsustainable.
The Scottish Government published the proposed river gradings for 2025 on the 7th of August. This is just under four months before the 2024 season ends with the closure of the river Tweed to fishing on the 30th of November. If the proposed gradings are approved, they will be implemented by the 11th of January 2025 when fishing opens on the river Helmsdale. This is more than four months before the catch details of the 2024 fishing season are published in mid-May. This means that if the 2024 fishing season proves to be another year of record low catches, it will still be business as usual on Scotland’s salmon rivers, subject to the minor changes proposed by the conservation gradings.
The reality is that the current method of assessing the conservation grades of Scotland’s salmon rivers is not fit for purpose. It is nothing more than a nod to anglers to allow them to continue their sport without any regard to the future of wild salmon. As I have written previously, the Scottish Government’s wild salmon strategy has more to do with promoting Scotland’s wild salmon fisheries than protecting Scotland’s wild salmon.
This can be seen from the tone of the consultation questions. Four of the eleven questions relate to whether the respondent will be financially impacted by any changes or whether their business will be impacted. It seems that salmon conservation is being driven by the interests of river proprietors rather than those of the salmon. Is it really possible that changes to protect wild salmon will not be implemented if the financial interests of the river proprietor will be harmed?
The other questions include whether the respondent agrees or disagrees with the changes: whether the respondent is interested in a specific river or a district or a region; whether the respondent has concerns about the data used and whether the respondent has any further information that might be useful. I certainly didn’t feel the questions were aimed at protecting the fish but rather that the right to fish should be protected.
The first thing that is apparent about the proposed river gradings is that they are no longer gradings. Gone are the gradings, Grade 1, Grade 2, and Grade 3 and these have been replaced by ratings of Good, Moderate, and Poor. After around ten years, it is unclear why there is a need for change. Perhaps, the Scottish Government has assessed that anglers have no concept of what the numbered gradings really mean, so have adopted wording in plain English. However, it is worth noting that the supporting documents still refer to the three grades.
In addition, rivers that have changed are now either ‘improved’ or ‘declined’ instead of being shown to increase or decrease except for the Laggan which is shown as decrease. Clearly, the proofing of these documents leaves something to be desired as does the whole conservation assessment.
The aim of the assessment is to estimate whether there will be sufficient eggs to sustain the stocks in each area. This is calculated from the number of returning adults which in turn is calculated from the rod catch. The main problem is that the 2025 gradings are calculated from the 2023 rod catch, not the most recent one. Marine Directorate scientists have no idea as to whether the 2024 catch will be better than, worse than, or the same as the 2023 catch as there is no apparent means of continual means of monitoring catches in place. If it is worse, which would be in line with the current trend, then fish exploitation will be based on out-of-date numbers. If fish stocks were healthy, then this wouldn’t matter but because salmon stocks are in such a dire state and even have been classed as endangered, then it seems obvious that the whole process needs a complete rethink. To use wild fish vernacular, the status quo is not an option.
Surely, any change in conservation grading for 2015 must be based on catches from this year, not from 2023. I have written several times that it is a complete mystery why we must wait for May 2025 until the detailed catch data is published. The Marine Directorate did once investigate real time catch data but abandoned their attempt without any explanation. Presumably, there was resistance from river proprietors about providing such information. It is already well known that many river proprietors have resisted providing such information because of concern that if it is publicised that fish are not biting in their part of the river, then anglers might be tempted to cancel and seek fishing in other rivers where the fishing is more rewarding. In 2024, it makes no sense that catches cannot be reported at least weekly. It is only necessary to see the weekly fishing report from the Spey Salmon Fishery Board to see that regular reporting (with a few tweaks) is not impossible. The fishing report for the week commencing 5th of August was posted on the 11th of August.
Against a background of threatened stocks and in the absence of accurate real time catch data, there must be better ways of ensuring the salmon stocks can experience some form of conservation. One option would involve consideration of the various stock components and adjust the fishing accordingly. This graph is taken from the report of the 2023 catch statistics.
Although it probably doesn’t really matter when the fish enters the river, the Marine Directorate identifies salmon as spring, summer or autumn fish. Whilst until 2010, summer and autumn salmon increased, spring stocks have been in long term decline as illustrated in the Marine Directorate graph.
In 2015, fish caught before the 1st of April were made mandatory catch and release, however, it is clear that this measure has not stopped the decline of these spring fish. This is not surprising since over twenty years of catch and release have not stopped the decline of stocks on the river Dee where catch and release has been in place longer than anywhere else. Given the small number of salmon actually caught before April, which in 2013 was 918 fish, perhaps the time has now come to put an end to all fishing for spring salmon. Not unsurprisingly, the majority of these spring salmon (613) were caught from the big four salmon rivers (Dee, Spey, Tay, Tweed)
The benefit of postponing the start of the fishing season until mid-April is that it would give Marine Directorate scientists the opportunity to analyse the previous year’s catch and determine a more accurate conservation status that reflects the true state of the salmon stock before anglers are allowed to begin to fish.
At the same time, the introduction of real time data (at least on a weekly basis) should be made a priority. In Norway, knowledge of returning salmon meant that the authorities were able to close those rivers that were experiencing few returning fish and prevent unnecessary exploitation.
In terms of changes for 2025, the Marine Directorate first mention that no new rivers have been added to the assessment process (173 in total) but that the river Laxford is no longer assessed along with Gleann Dubh. This would imply that the two are assessed separately but it seems that Gleann Dubh is no longer assessed at all. At the same time, the overall number should have decreased but the Marine Directorate misleadingly often assess closely associated areas together and then class them as one, which is why anyone counting all the separate assessments listed on the Scottish Government website will find there are over 220 altogether.
The Marine Directorate detail the changes for 2025 which includes five stocks that have improved, four of which are no longer subject to mandatory catch and release and twelve stocks that have declined of which none are now mandatory catch and release. It is only when these changes are considered in detail that this approach to conservation is not fit for purpose.
It is worth remembering that when the conservation gradings were first introduced, the assessment was made of the 109 fishery districts but immediately, anglers and river managers complained that the stock in their river was different to the fishery district as a whole. Because the Marine Directorate’s salmon scientists favour anglers, they were happy to allow them to request separate assessments, which meant that the total number of assessed areas rose to the 173 used today. The Marine Directorate treat these as if all are the same, as can be seen from the graph from the ‘Status of Salmon in Scotland’ document published with the latest assessment.
One of these areas is the river Tweed, which covers an area of 16,187,000 m3 and which I will use this as a base line for discussion of other stocks. Another fishery district of interest is the Creed in the Outer Hebrides. From the assessment process, I have determined that the area covered by the Creed is 504,000 m3 or just over 3% of the area of the Tweed.
Despite this small size, the Creed fishery district has been divided by Marine Directorate into ten different assessment areas. Five of these relate to the Eishken Estate, which covers 120,000 m3. All are judged to be of a poor conservation status and thus are all mandatory catch and release.
A further two relate to the Aline Estate of size 48,000 m3 and these are both rated poor.
Two more relate to the Soval Estate of size 165,000 m3and these have been downgraded from moderate to poor and are now mandatory catch and release. They are highlighted in the Marine Directorate summary.
At the same time, one more of the ten areas, the Creed of size 171,000 m3 has been identified as improved with a rating from poor to moderate and can now be exploited by anglers.
This is nonsense, the Creed fishery district is clearly in a poor state and should be rated accordingly across the whole district.
Of course, anglers will blame the presence of salmon farms within 10 km as the reason why the fishery district has such a poor conservation rating, yet despite the presence of two salmon farms, the main river has seen such an improvement in its salmon stock over the last year that the river can now be exploited.
In fact, all five stocks that have shown improvement are all west coast rivers in the heart of the salmon farming zone, with the exception of the river Clyde which borders the zone.
Another area where the conservation status has improved is Hinnisdal to Haultin. These are two rivers in the Snizort fishery district. When the alphabetical list on the website is consulted, there are three entries under Hinnisdal to Haultin all of which have the same improved grading to moderate. These are the rivers Hinnisdal, Haultin, and Romesdal.
The Snizort fishery district also has ten assessment areas covering 594,000 m3. The three rivers that have shown improvement cover just 123,000 m3. The remaining 471,000 m3 covering seven areas of which four are rated poor and the other three are rated as moderate and are unchanged. This means that 450,000 m3 are rated moderate and this is despite the presence of local salmon farms including one of those considered at most high risk for sea lice by SEPA. Clearly, the relationship between farms and wild stocks is not as clear cut as SEPA and the Marine Directorate would have everyone believe.
The remaining river to show an improvement is the river Clyde, one of Scotland’s major rivers. This river was previously a Grade 2 river but slipped in 2023 and 2024 to Grade 3 – Poor. For 2025, the river has returned to its former moderate status. The two other key assessment areas in the Clyde fishery district are the river Leven and Endrick Water (SAC). These have both been Grade 2 (moderate) areas for some years but have both fallen to become of poor status.
The change in the status of Endrick Water will probably be the most contentious of the changes. Firstly, the Marine Directorate have stated that the Leven is actually of good status but because it is linked to Endrick Water which has declined, the two areas will be given the same poor status.
According to the Loch Lomond Angling Improvement Association, the river Leven is central Scotland’s premier salmon and sea trout fishery so the Association will clearly be unhappy with the latest change. The Association have been in the past very vocal about salmon farming especially about escapes and no doubt salmon farming will be on the list of those to blame for the decline. Yet, the decline is only in the river that feeds into Loch Lomond’s east bank. The river leaving Loch Lomond is rated as good but loses this rating due to its connection to changes in Endrick Water’s status. Fish entering the Leven must pass the same distant farms as those reaching the Endrick. Fish heading for the Clyde into which the Leven runs, also must pass the same distant farms and the Clyde is rated by The Marine Directorate as improved.
Finally, I want to return to the Mail on Sunday article which relates how officials have ruled that 68% of the salmon stocks in Scottish rivers are unsustainable. I apologise to readers that I am having to repeat the following every year and which Marine Directorate scientists continue to ignore.
According to the Marine Directorate 30 out of 173 stocks are assessed as good. A further 26 stocks are assed as moderate with the remaining 177 being poor.
This equates to the following percentage:
Good – 17.3%, Moderate – 15.0%, Poor – 67.7%
However, as I keep pointing out these 173 areas are rather arbitrary with sizes ranging from 4,000 m3, to the Tweed as stated earlier of over 16 million square metres. If the assessment is based on size of area, then the percentage change significantly
Good – 52.2%, Moderate – 17.2%, Poor – 30.6%
Thus, according to the Marine Directorate’s assessment, the actual state of Scottish salmon stocks is much better then suggested.
If the same calculations are made for the west coast Aquaculture Zone, then based on the number of stocks only the assessment would be
Good – 9.5%, Moderate – 16.0%, Poor – 74.5%
When based on area, this changes to:
Good – 5.1%, Moderate -24.4%, Poor -70.0%
Before critics of salmon farming start to shout that this is proof that salmon farming is having an impact, it is worth considering that the west coast Aquaculture Zone only accounts for 12% of the area covered by Scottish rivers. Together all the west coast rivers are just slightly larger than the Tweed catchment on its own.
It is worth considering catchment size of the 173 assessment areas.
53 are less than 100,000 m3 in size, the smallest being just 4,000 m3
88 are between 100,000 and 1,000,000 m3
29 are between 1 million and 10 million m3
3 are larger than 10 million m3
If just the west coast Aquaculture Zone assessments areas are considered, then.
43 are less than 100,000 m3 in size
49 are between 100,000 and 1,000,000 m3
2 are between 1 million and 10 million m3
0 are larger than 10 million m3
It is easy to see that most of the small catchments are located within the west coast Aquaculture Zone. It has to be questioned why the Marine Directorate are bothering to assess such small areas on their own.
In fact, if the Marine Directorate were to revert to assessing the conservation status by established fishery district, then only 18 have multiple gradings i.e. areas of Grade 2 and Grade 3 in the same fishery district. Most of these are so widely different that it is relatively simple to decide which grading should prevail. For example, Leven fishery district has 121,000 m3 of Grade 3 – poor fishing and just 24,000 m3 that is adjudged to be Grade 1 – Good. In the interests of this threatened species, surely this district should be all graded poor. Finally, just one fishery district has representatives from all three grades. This is Loch Roag which is within the Aquaculture Zone.
Is it not time that Scotland reassesses its relationship with wild salmon so that it can decide whether it is the fish itself or the fisheries that need to be protected. The current conservation gradings appear to do nothing to ensure the future of wild salmon but ensure business as usual when it comes to angling.