Kill Licence Briefing – April 15




In the face of diminishing runs and increased netting, it is time we finally had legislation in Scotland to remove from those who are allowed to take salmon the right to take as many as they want regardless of the vulnerability of the salmon run.


Scottish Government is consulting on proposals to introduce a licensing system for killing salmon by both nets and rods, in conjunction with numbered carcass-tagging, from the 2016 season. Full details (including how to respond) are at
All owners of rights to catch salmon (netsmen and riparian owners) will have to be licensed. This will give the right to kill. In conjunction with this will be an offence to move dead fish without that fish being tagged. The number of tags issued to each beat or fishing station will depend on the strength of the runs in that area.
Recently the senior civil servant with responsibility for these matters, said: “If a net fishery cannot demonstrate that there is a harvestable surplus for the fisheries that it impacts on, licensing it might not be possible.”


The principle is in our opinion correct. No-one should have the right to threaten the wellbeing of a vulnerable stock. In some districts of Scotland, netting accounts for 90% of the fish killed; now over Scotland overall, almost twice as many fish are killed in nets as by anglers. Whilst it could be argued that anglers through catch and release are already doing their bit, and it is hard to think of any river where angling alone is threatening the stock, we must accept that it is impossible politically for the Government to introduce legislation which targets only netting.
Much has been written to say that the proposals are unworkable, and whilst the devil will be in the detail, it is the principle we are dealing with here.

S&TA(S) supports the principle of a licensing system as it should, once implemented, help ensure that only salmon stocks that exceed conservation limits are exploited.

The details will be all important, and until the implementation is clarified, it is only the principle which is supportable.
We do though believe that the cost of the scheme (which has to be self-funding) must be borne by those who want to kill fish. It would be ludicrous and very unfair if a small beat or angling club, applying for the right to kill a few fish a year, was obliged to pay the same as a very large beat or netting station which wants to kill many hundreds. The cost must be based on the number of tags issued.


If you have any questions or comments, do feel free to contact Hughie Campbell Adamson on 07860 815828 and, or Andrew Graham-Stewart on 07812 981531 or



(With some suggested bullet point answers)

1) Do you agree with the proposal that Scottish Ministers introduce, for conservation
reasons, a ban on killing wild salmon by all methods except under licence? If you disagree, please provide suggestions for alternative measures which, within the context set out in the consultation paper, would deliver the objective of a more robust regulatory framework to control killing of salmon to enable conservation objectives to be met.

• Agree with the principle of licensing.
• A properly administered licensing system, using the best available science allied with the precautionary principle, should help to ensure that harvesting of returning adult salmon, either by nets or rods, is limited to stocks where there is good evidence of a sustainable surplus.
• Indiscriminate coastal exploitation needs to be curtailed (and in due course eliminated), to protect the most vulnerable populations.

2) Do you agree with the basic outline of how the licensing system would operate?
Please provide suggestions, and rationale, if you consider it should operate in a
fundamentally different way.

• Agree – with the principle of quotas. Where applicable, they should be set by river catchment.
• The cost of licensing should be borne by those owners or lessees who want to kill fish.
• To be equitable, the cost of individual licences must be pro rata to the number of fish allocated to be killed on a particular beat or netting station.
• The application form and process should be as simple as possible – so as not to deter smaller beats and fisheries (including angling associations) from applying.

3) Do you agree that the ban on killing and associated licensing system for Atlantic
Salmon should be accompanied by regulations prohibiting use of certain fishing equipment which is liable to cause greater harm to the fish? What other equipment, other than that set out at paragraph 24, do you consider should be included and for what reason (please provide evidence for your suggestions if possible)?

• The use of treble hooks should cease – even if the intention is to kill, as fish other than the intended quarry (such as unclean/stale fish, kelts, smolts, parr etc) may be hooked and the ease of their safe unhooking must be a consideration.
• The number of hooks on lures should not exceed two.

4) Do you agree that a carcass tagging scheme should be made as an integral part of
the licensing system to aid compliance? If not, please provide suggestions for methods of ensuring compliance with licences and their conditions.

• A numbered carcass-tagging scheme is vital to ensure compliance.
• It should greatly improve the accuracy of declared catches by nets.
• It should reduce the ease with which illegally caught salmon can reach market.

5) What do you consider the main impacts of the package of measures to be? Where
you are commenting on the proposed ban and associated licensing scheme, please identify whether the potential impact is a result of the principle of having a more robust regulatory system in place or is more connected to the potential decisions that might be made by the licensing system. Please provide any evidence that you consider should be included within the Business and Regulatory Impact Assessments that will be completed alongside the legislation required to deliver the package of measures. The BRIA helps us to use available evidence to find proposals that best achieve the policy objectives while minimising costs and burdens. It also ensures that any impact on businesses, particularly small enterprises, is fully considered before regulations are made.

• The status quo of fishery owners being allowed to kill salmon with no regard for the sustainability of stocks is untenable.
• A licensing scheme will enable added statutory protection to be given to the most vulnerable populations.

6) Do you have any other observations about the proposals as conservation measures to help regulate exploitation of Atlantic Salmon? In the context of the legal framework in Scotland, do you have any suggestions or options for how they might operate in practice?

• It is important that commercial pressure from netsmen is resisted and the netting season is not extended beyond the current close dates.

Consultation responses (the deadline is April 30) should go to:
or Jackie McDonald, Area 1-B North, Victoria Quay, Edinburgh, EH6 6QQ.


Responses must to be accompanied by a Respondent Information Form – also available via