We recently voiced our concerns about a seafood eco-labelling process for a scallop dredge fishery and have been publicly criticised for doing so. Polarised debate is clearly not in anyone’s interests, but we take accusations about our use of evidence and accuracy very seriously, and so here lay out our evidence and the reasons why our concerns remain accurate and valid.
We have not raised our concerns to cause angst and anger from anyone, but we have legitimate concerns about an eco-labelling certification process. Should a fishery not meet the eco-label criteria, for example, by continuing damaging fishing inside MPAs or through damage to rare, non-target species, we think it is surely right to raise these concerns. We hope that the concerns can be addressed, the fishery improved and a sustainable product remain on the table. However, we believe that if a fishery is certified with the concerns we’ve raised unresolved, the consumer will be left completely confused – and that is in no-one’s interest. We engaged in good faith with an open certification process and stand by the evidence that we have presented in our submissions to that process.
Late yesterday afternoon, a PR agency put out a statement, on behalf of the Shetland Shellfish Management Organisation (SSMO) and the North Atlantic Fisheries College (NAFC) accusing us of “getting our facts wrong” to “meet a political agenda”. We reject this. We respond to each issue outlined by the agency below.
However, before getting into that detail we note that this PR statement rebuts our comments as if they are made about the fishery more widely and SSMO’s management. Our comments are about Acoura UK Ltd’s assessment of the scallop dredge fishery against Marine Stewardship Council (MSC) criteria. This is the issue at hand and the one which we feel needs wider public attention. In that regard, we want to make clear that we have attempted from the start to improve understanding and take a pro-active approach to engage with the certification process and we contacted Acoura back in November 2016 (as was recommended to us as the most appropriate pro-active approach). However, over the following 11 months and three certification extensions granted by MSC, the concerns we raised have not been responded to. We also made both Acoura and MSC aware we were planning to raise public awareness of the issue on 5th December. We set this out in an article on our website here.
We respond here to each of the bullet points in the press release issued by the PR agency on behalf of SSMO and NAFC:
- Open Seas claim: The stock of scallops has almost halved since 2012. SSMO & NAFC counterclaim: Stock assessments for the SSMO area show the biomass has remained stable and this is reflected in very stable catch, effort and landings per unit effort data. All of the indicators used in managing this fishery indicate that it is being managed in a sustainable way. The number of vessels with access to the fishery is limited via licencing, while the amount of effort is limited via dredge limits and a night time curfew.
The claim made on our website is “Recently published scallop stock assessments undertaken by the Scottish Government indicate that the status of Shetland’s scallop stock has been in decline since the fishery was first awarded the certificate. The data presented there suggests the stock has nearly halved in that time.” (the report is here) This data is presented below in graph format.
The Government’s data suggest Spawning Stock Biomass was around 8,000 tonnes in 2012, and was around 5,000 tonnes in 2016 – nearly half. We therefore stand firm on what we have said.
Whilst we acknowledge that NAFC undertake their own assessments and that (according to the MSC assessment) these show that the biomass has remained stable, Acoura also state that “the stock assessments were published annually up to 2010 but are no longer published formally” hence we have not seen those data in detail and have no way to clarify this assertion. Regardless, the Scottish Government statistics do deserve some attention, and the reason for each assessment’s contradiction ought to be better understood. Fisheries are a public resource and it is reasonable to expect that any publicly-funded fisheries assessments are considered.
- Open Seas claim: Closed areas of the seabed are voluntary and small, amounting to just 20 sq km. SSMO & NAFC counterclaim: Closed areas are statutory at the behest of fishermen who wanted vulnerable seabed habitats protected and represent 10.73 per cent of the area fished for scallops.
This is important, especially given there is no public access to information about the exact size or footprint of the scallop dredge fishery. However, i) this doesn’t really show that we were wrong and ii) the point we are making here is that the many seabed habitats exist outside these small areas – i.e. those areas not known to hold maerl beds, horse mussel reefs or seagrass and closed at the behest of the fishermen – remain vulnerable to dredge damage. Many of these other areas are important seabed habitats in their own right. Arguably areas of maerl, such as the one to the east of Mousa found in a Heriot-Watt University survey also remain open to dredging.
- Open Seas claim: Marine Protected Areas (MPAs) have not been taken into consideration in the assessment process. SSMO & NAFC counterclaim: SSMO and NAFC Marine Centre have worked closely with Marine Scotland on proposed MPA management. MPAs are not closed to fishing, but very often concerns over impact have already been mitigated by existing statutory closures.
The nature conservation MPAs were designated in 2014. At that time additional restrictions were recommended by Scottish Natural Heritage (SNH), the Scottish Government’s nature conservation advisors, to mitigate impact of dredging (see here and here). In addition to these suggested restrictions, improved conservation measures were recommended in the three marine Special Areas of Conservation that exist in Shetland waters.
A workshop was held in April 2015 where government advice was to establish further approaches to mitigate impact of dredging in these sites. Regrettably, and regardless of closeness of working, no progress has yet been made to to enact any further protection. We attach a minute of that meeting obtained via Freedom of Information Request (FOI). Of particular note are statements such as “[Marine Scotland] propos[e] to prohibit mobile gear throughout whole site” at Papa Stour SAC, “Scallop boats do come in close to shore where the kelp beds are” in Fetlar to Haroldswick MPA; “Request [by SSMO] for the Southern area of MPA/SAC to remain open. Environmental groups would be in agreement with this proposal as long as the closure at the north eastern end was in place but ultimately would like to see the boundary of the MPA closed.”
The MPAs have not been considered at all in Acoura’s report. The SACs have been quickly dismissed. This is a concern, and we stand by that statement.
For clarity, here is a map showing the distribution of MPAs, SACs in comparison to the SSMO’s closures.
- Open Seas claim: Horse mussels are rare, yet form a significant by-catch. SSMO & NAFC counterclaim: horse mussels are ubiquitous around Shetland. It is horse mussel beds, which are protected by the SSMO, that are rare.
Horse mussels (as lone individuals) are not common throughout the UK (SNH report here) . Part of the reason why horse mussel beds (i.e. aggregations of horse mussels) are rare is that clumps of few individuals may be disturbed and are therefore not able then to grow and reproduce and form horse mussel beds.
As noted by the Joint Nature Conservancy Council, “Scottish waters support 85% of all horse mussel beds in the British Isles which themselves represent most of the habitat within Europe. They are sensitive to physical disturbance and mobile fishing gears may damage and/or remove beds. The extent and quality of habitat has declined since the 1950s with formerly extensive beds in Strangford Lough (N. Ireland) lost as recently as 2007 due to scallop trawling and dredging.” (see here)
Surely the impact of horse mussel bycatch should be a consideration in a sustainability assessment?
- Open Seas claim: Because Scottish priority marine features have not been considered in the assessment process, policy in Shetland lags behind national policy. SSMO & NAFC counterclaim: many of these features are not present in the area managed by SSMO, nor are they suitable scallop habitat and therefore are not subject to scallop dredging. SSMO’s active management under a locally-specific Regulating Order to protect priority marine features demonstrates that Shetland is very much in harmony with national policy.
It’s encouraging to hear that SSMO’s active management takes account of priority marine features, but this active management is not accessible via a public document so this is news to us. The only public document outlining management, the regulations document (here), makes no mention of priority marine features. Given that there has been no progress to protect sandeels, kelp and seaweed habitat, coarse sand and bivalve habitat, and sand and coarse sediment habitats – all priority marine features – in the MPAs (as discussed above) we consider this concern remains.
A NAFC study shows the distribution of some of these priority marine species in Shetland which, when compared with other maps showing distribution of dredging, appears to show overlap (report here).
The statement issued on behalf of NAFC and SSMO suggests our statements are “devoid” of evidence. We take this very seriously and hope the above has indicated they are not. We can make our 33-page evidence-based submission to Acoura during the MSC process available if necessary.
If anyone would like to discuss this in any further detail, we’re contactable via crew ‘@’ openseas.org.uk.