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Richard Gustar Our ref: PS67/03 Scottish Executive Environment & Rural Affairs Department Freshwater Fisheries, Aquaculture & Marine Environment Room 408A Pentland House 47 Robb’s Loan EDINBURGH EH14 1TY May 2003 AMENDMENT TO THE SALMON (FISH PASSES AND SCREENS) (SCOTLAND) REGULATIONS 1994 Thank you for inviting SNH to comment on the above consultation paper, on the Executive’s proposed amendment to the Salmon (Fish Passes and Screens) (Scotland) Regulations 1994. As the paper acknowledges, the Regulations in their current form contain no explicit requirement to undertake maintenance of fish passes and screens which have been installed to ensure the safe and uninterrupted passage of Atlantic salmon. SNH has considered the Executive’s proposals in the context of our response to the joint SNH/SE publication ‘Protecting and Promoting Scotland’s Freshwater Fish and Fisheries: A Review’. In our response to that consultation SNH expressed a wish to encourage all water users to accept that, wherever possible, river processes such as water flow, water level change and sediment movement and accumulation, should be allowed to operate in ways which are near-natural, or which mimic natural conditions. However SNH appreciates that many fish passes, dams and lades have been in place for several decades and that these have been used to support a variety of water-based industries, such as textile manufacture as well as recreational fisheries. The recent rise in small scale hydro scheme developments in response to the Government’s renewable energy programme has meant that the requirement to install fish passes and screens in Scottish freshwaters has increased significantly over the last decade. The decline in Scottish Atlantic salmon and sea trout stocks has also meant that fishery managers have re-examined possibilities for improving access for migratory fish to remote areas of river catchments in an attempt to increase natural smolt production. This work invariably involves the construction of fish passes and/or the physical modification of man-made or natural obstacles such as dams and waterfalls. However SNH considers that fishery managers should be discouraged from breaching natural obstructions, such as waterfalls, and is concerned that there is some evidence that this type of intervention continues to occur. Clearly, where fish passes and screens have been put in place, it is desirable that those responsible for their construction should be charged with maintaining the structure, so as to ensure its continued efficacy in facilitating the free passage of Atlantic salmon, sea trout and indeed other migratory Annex II species, such as brook, river and sea lamprey. SNH welcomes the proposed amendment to the Salmon (Fish Passes and Screens) (Scotland) Regulations 1994 and sees this as a positive step in ensuring the continued efficacy of new and existing fish passes for migratory salmonids. Andy Dorin Deputy Head of Secretariat