BEAULY SYSTEM FISH AND FISHERY ACTION PLAN ... - RAFTS

There is reference to the presence of ‘lamprey’ in the river systems, but nodifferentiation between sea lamprey and the two Lampetra species. It would behelpful to distinguish them where possible.The tabulated fish counter data is of interest, but perhaps would be better presentedas graphs. It is unclear if the Scottish Fisheries Coordination Centre has beeninvolved in training survey staff or for data storage and collation. Compliance withSFCC protocols and the use of their facilities for data handling is to be recommendedand might add value to the current surveys and monitoring efforts.There is recognition of gaps in fish stock data, particularly for lochs and for nonsalmonidspecies. SEPA welcomes the plans’ aim to try and fill such gaps –something that is widely acknowledged as a shortcoming nationally.The Ness plan refers to changing forestry practice and the increased planting ofnative broad-leaved trees. SEPA also favours this policy, which may be relevant tothe cultural oligotrophication referred to elsewhere in the plan, as well as to otherbiodiversity gains.Links to Water Framework Directive and River Basin Management PlanningAt present the plan contains some references to the Water Framework Directive (WFD) andthe North Highland Area Advisory Group. SEPA is keen to work with stakeholders and thiswill underpin much of its work as it implements the WFD and operates under the WaterEnvironment and Water Services (Scotland) Act 2003. We think it would be helpful to have aspecific reference to the draft North Highland Area Management Plan in the fisherymanagement plan, so that readers can easily see the links and synergies between the twoplans.We would also like to suggest that the fisheries management plan could referencethe WFD classification results for the area. We appreciate that the classification datahas only very recently become available, but it would provide the most up to datepicture of the current status of the catchments in WFD terms. It would also enable theactions of the plan to be put into context in terms of their potential contribution toimproving water bodies to good status or preventing deterioration. The classificationresults will be updated each year based on new monitoring data and developments inthe classification process. We may be able to provide you with maps showingpollution, hydrology and morphology impacts.We note your Fisheries Management Plan includes a range of opportunities to workwith, and communicate to others who manage, impact and use the waterenvironment. We welcome this activity as it will hopefully result in behaviouralchanges which will benefit the water environment.RegulationSome of the activities to deliver your projects outlined in the Action Plan could potentiallycome under the Controlled Activities Regulations (CAR). Your local SEPA team in Dingwallwill be able to advise you on any of these authorisation requirements.45