The Grayling Society is a UK body with supporters in over twenty

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The Grayling Society is a UK body with supporters in over twenty Powered By Docstoc
					             The Grayling Society

             43 Blinkbonny Road, Falkirk, FK1 5BY, Scotland
         Tel: 01324 623920 e-mail:

Thekla Garland
Wildlife & Natural Environment Bill Team Leader
Victoria Quay
                                                                          Date 24th August 2009

Wildlife and Natural Environment Bill – Consultation

The Grayling Society is a UK body with supporters in over twenty countries in the Northern
Hemisphere where grayling are found. We are pleased to make a response limited to Section
4 of this consultation. We have no wish to see further invasive non-native species being
introduced to Scotland, and deplore the way that several which are already here are
spreading and threatening some of our natural wildlife. We regret that there are people who
are ignorant about, or have no qualms about introducing new species, and agree that current
legislation needs tightening up. This is particularly so regarding aquatic species, with the
American Signal Crayfish being potentially one of the worst.

We are very conscious of course that the grayling is not native to Scotland. However, it has
been here for over 150 years, proving a valuable introduction to several rivers in central and
southern Scotland, and providing enjoyable fishing for anglers in the winter when its cousins,
trout and salmon are spawning. It has found its own niche in those rivers, and has integrated
well with other species with no readily apparent retrograde impact on any of them. It also
enjoys some protection under Annex V of the EC Habitats Directive.

The Grayling Society does not support the introduction of grayling to further rivers, unless this
has sound scientific and Governmental backing, but one of our core aims is its conservation
where it does occur and also its reintroduction if populations die out due to pollution or other
damaging incidents.

Our grayling related replies to some of your questions are as follows:-

Qs 42 – it seems extraordinary that immediately a species that has escaped into the 'wild' in
one location it can be termed "ordinarily resident", so we support the proposal.

Q43, 44 A&B, and Q46 – These questions are inter-related. As stated above we do not
support introducing grayling to new rivers without sound reason, but we do recognise that
events may conspire to consider doing so in future. For instance, it may be unthinkable, but
not impossible for the parasite Gyrodactylus salaris to arrive in Scotland and devastate its
salmon populations; if it did the introduction of grayling to some rivers could provide an
alternative if slightly less iconic species for people to fish for.
An exception would have to be made to allow the release under licence of this non-native but
well established species in such a case, and also to allow its reintroduction to waters in which
it already occurs in the event say of a catastrophic pollution.

Q45A – We agree with the approach, but point out the difficulty in policing it.
Q46 - This question may concern just plants and fungi, but if it applied to the grayling we
consider it would be useful if the fish was placed in a category listing non-native species that
are well established in Scotland and beneficial or benign to its natural environment; the
antithesis of Japanese knotweed and Himalayan balsam, which are proving a blight and
currently getting out of hand.

Q47A & Q48 – These proposals seem sensible with the proviso that the grayling is exempt.

Q53 – We agree with this proposal, on the understanding that an exception is provided as
stated above under Q44B for the grayling.

We are happy for this response to be made public and for you to contact us as and when

We also look forward to seeing and commenting on the revised list of species proposed for an
order under section 14A of the 1981 Wildlife and Countryside Act.

Yours faithfully

Alan Ayre