The Scottish Government’s new ‘Fisheries Management Strategy’. has been long in the making. Has it been worth the wait? Unfortunately it signals a quietly regressive approach which risks deregulating our fishing industry, back-sliding on EU rules, and opens the door to overfishing.
This new ‘Fisheries Management Strategy’ represents the biggest change in fisheries management in a generation, as Scotland leaves the European Union’s Common Fisheries Policy and follows this new Strategy.
Despite the gravity of this change, there has been no parliamentary opportunity to scrutinise the Strategy, or the detail of fisheries management more generally. A Ministerial statement in the Scottish Parliament scheduled for Tuesday 15th December was cancelled and MSPs have since had no opportunity to debate it.
On the surface, the Strategy appears to be a pioneering and innovative in its aim to make Scotland a ‘world-leading fishing nation,’ but what stands out is its failure to even mention the declining health of our marine environment and the poor condition of many fish populations, let alone set out a plan for their recovery. Scotland’s west coast cod populations have declined dramatically and remain in poor condition. ICES now advises “there should be zero catch in each of the years 2021 and 2022”. So while industry and government have spent time haggling about the share of fish stocks in the EU-UK Trade and Cooperation Agreement, a more foundational concern is the health of the fish populations themselves.
The Strategy makes impressive sounding assertions, but the fine detail reveals it is more about quietly deregulating some key EU rules to allow for backsliding on fisheries rules, rather than restoring our fish populations for the long-term. The Strategy contains welcome high level commitments such as “to protect and restore the natural marine environment” but these are set against targets to “maximise opportunity and long term sustainable economic growth.”
Notably the strategy aims to “align with the delivery of fishing at Maximum Sustainable Yield (MSY)” [p.8] rather than meet MSY by 2020 (the current EU regulation), and “Reduce unnecessary discards” [p.24] rather than ending discarding altogether (also required by EU regulation). Continued discarding remains a big problem for parts of our fleet.
The Strategy includes a welcome 12 point action plan, including “securing the resilience of the fishing industry”, “supporting transparent and responsive management” and “full use of existing tools and new available technology including REM and vessel tracking solutions.” However, it contains relatively little detail about how management will deliver the protection and restoration of the marine environment, something which is needed under commitments made in 2010.
The Strategy declares that embraces ecosystem-based management, but under this approach the Strategy only considers fisheries restrictions inside MPAs and Priority Marine Features – two issues that are 2 – 5 years behind schedule and would fall far short of the FAO definition of ecosystem based management.
There has been much talk about how fishing quota has been consolidated in the hands of a few families or businesses. The strategy does not propose any real change to the way that existing quota is handed out, and suggests the Government will only consider changes to how “additional quota” might be allocated at regional level.
More regional management is important for devolving decision-making to local level for the best stewardship of our fisheries. However, Scottish Government has signalled its preference for “co-management” and “formal and informal consultation” with Regional Inshore Fishery Groups and there is a big question mark about how regional and inclusive these decision-making structures are in practice. The Scottish Parliament’s Environment Committee (today) published a report calling for “stronger leadership” from Government and recommended that Regional Inshore Fishery Groups are made into statutory bodies. In the meantime, “informal consultation” hinders transparency and broader ‘social license’ for our fishing industry.
Transparency is a big part of this. Back in 2018, the Scottish Government announced a National Discussion on the ‘Future of Fisheries Management’. It is notable that many respondents to Scottish Government’s eventual 2019 consultation on fisheries gave strong support for spatial management to limit the impact of bottom-trawling and scallop dredging inshore, but this appears to have been ignored in this latest Strategy. Responses to the public consultation which informed the production of the Strategy have still not been published, although we understand this is now subject to a Freedom of Information Request.
A practical strategy in a climate emergency needs sustainable limits and incentives for nature-friendly low-carbon fishing. It should tackle over-consolidation within the fleet, traceability systems to assist the wider seafood sector and present a clear plan to reverse the chronic declines in fish populations.