These are the questions that were formally posed by the Association of Salmon Fishery Boards (ASFB) to the Scottish Wildlife Trust in December 2007 and to which no response was made.
1. Can you please confirm what evidence has been procured to demonstrate that there will be negligible impact on migratory salmonids due to the creation of dams in relation to the trial site, as well as other habitats within Scotland? Passage for fish is equally important for downstream migration of juvenile salmon and sea trout at smolt stage in the spring as well as upstream migration of adult salmon and sea trout in late summer and autumn.
2. Are you able to clarify whether smolts, when on downstream migrations, are likely to get through the dam structure at ordinary water flows or would they have to wait for a spate to overflow the dam so they could get past?
3. Can adult fish, particularly salmonids, ascend dams at ordinary flows or would high flows be required to allow passage? There is evidence from Estonia that fish passage problems are exacerbated in dry autumns – have the project team considered the impacts of the range of conditions likely to be expected in Scotland? Rainfall is much higher on the West coast than on the East, so the conditions for fish passage encountered at Knapdale would not be replicated on the other coast.
4. Is there any data to suggest that the dams will modify fish habitat sufficiently to change the population/species dynamic in a watercourse? Specifically, the deep water created is likely to allow large, predatory trout to live in spawning burns where they cannot now do so. Such deep water would also allow Pike (which are non native species) washed out of lochs to live in spawning burns, which would definitely have an adverse effect on smolt migration downstream, especially if these were held up at beaver dams by the need for spates to get them over or around the structures. Such extra predation would put further pressure on the populations of spawning burns and small rivers which could be critical in streams which already have a low biomass of juvenile salmon and sea-trout.
5. Should the trial be licensed, what monitoring is proposed to assess the above impacts within the trial site? For example, it would be imperative to establish some form of baseline electro-fishing monitoring to assess juvenile salmonid numbers for a number of years before any beaver dams were created and then upstream and downstream of these dams for a number of years after. The aim should be to cover a variety of conditions and situations, for example and including:
a) After a wet autumn (easy access for spawning adults) and after a dry (difficult access)
b) From wide streams (over 5m width) and narrow (down to 1m wide)
c) From above and below single dams and a series of dams.
6. In view of the above scenarios, can you please provide further information on mechanisms which will be available to resolve fish passage problems caused by dams? The District Salmon Fishery Boards (DSFBs) have legal powers to require free passage of migratory salmonids and the project team did confirm that this would be provided for in the trial framework. Would this be responsive and fully involve the local DSFB and fishery trust? How exactly would this be framed in any licensing arrangement or legal authorization granted?
7. The project team confirmed that tight bio-security measures would be in place to ensure that the animals released into the trial area would be strictly monitored and prevented from escaping from the trial site. Can you please confirm how this will be achieved and what measures will be in place to prevent animals getting out-with the trial site? What strategies will be available for alternative control of the animals should recapture not be possible?
8. Can you please confirm the terms of the proposed exit strategy and on what basis it would be implemented? We understand that a major flaw in the exit strategy for the last proposal was a key factor in the Scottish Executive turning the proposal down (culling of beavers would be illegal in E.U. law). (N.B. an exit strategy was provided in the licence application).
9. At the seminar (Lochgilphead on 19 October 2007) it was apparent that no wider risk assessment or environmental impact assessment has been prepared to inform the project and satisfy stakeholders. We would expect that this assessment would go well beyond fisheries interests, and a number of other stakeholders, (for example British Waterways Board) expressed concern at the lack of this. Are you able to clarify why this has not been prepared?