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Promoting sustainable seafood from Scotland's Seas

The quiet deregulation of Scotland’s fisheries

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.

Back-sliding

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.

Documenting a decade of decline in Scotland’s seas

A new ten-year assessment reaches the stark conclusion that in many respects the health of Scotland’s marine environment is still deteriorating. What actions does our government need to take to actively recover our seas?

As one decade ends and another begins, the Scottish Marine Assessment 2020 has finally been published, and sadly confirms what many now know – that our seas are still in environmental decline. Despite the bold intentions of the Marine Scotland Act in 2010 to “protect and enhance” our seas and kickstart a recovery from spiralling fish populations and vanishing habitats, this much-needed ‘enhancement’ is simply not happening – the Assessment documents many symptoms of environmental deterioration.

The Assessment confirms serious declines in biogenic seabed habitats (previously revealed in a leaked Government report) and makes similar findings for seabed habitats generally throughout Scotland’s inshore seas.  It also confirmed that many of Scotland’s fish populations such as cod, whiting and herring, once mainstay stocks for the Scottish fishing industry, remain in poor or even declining condition. Declines are recorded in ‘species richness’ and  ‘species diversity’ indicators for fish, particularly in offshore areas. [Read more…]

Scotland’s fisheries in numbers

The Scottish Parliament is due to debate a Ministerial statement of the Future of Scotland’s Fisheries, As the end of the Brexit transition period looms and a no-deal still looks like a possible scenario, this is would be a rare opportunity for our MSPs to debate at any real length the future direction of Scotland’s fisheries management.

Scotland’s fisheries are a public resource and for decades now have been mismanaged – both environmentally and economically. Here are some numbers that might help put this important political debate in context and explain why fundamental reform of our fisheries management is urgent and in the public interest… [Read more…]

#FishLocal for Lobster

Lobster – it’s widely regarded as gourmet seafood, and is a delicious treat if you can afford it and it’s ethically prepared. But while lobster is likely a rare culinary occasion for most, it’s one of the staple catches within the Scottish fishing sector. Just like brown crab, lobsters are caught and landed all around our coastline mainly by smaller local boats and therefore help bring in distributed value to communities.

Scottish lobsters are populations of the European lobster (Homarus gammarus), and are dark blue unlike their brown-orange North American cousins. They are caught by creels (baited pots, set on the seabed) which coax lobsters out of their hiding spots, especially around rocky shorelines.

Lobster fishing has been practised for centuries, and fisheries have boomed in recent years. Around 1,200 tonnes, roughly doubling since the 1970s and 1980s. The vast majority of lobster is caught by Scottish boats landing to local ports. These are often sold to higher-end restaurants but there has been a increase in exports, especially since 2010. However, with some inshore fishermen considering localising their markets, there are signs that this special shellfish may be available closer to home.

Remember that lobster fisheries fluctuate and so there is a high degree of seasonal availability often due to variability of environmental conditions.

If you’re buying lobster, please make sure you check and ensure it meets the minimum landing size. Confusingly these sizes are different in different areas and also depends whether it’s a male or a female. Check out the official control guide here. Just as crucially try to make sure it is not ‘berried’. Female lobsters carry their eggs for up to 11 months and responsible fishermen advocate the return of these ‘berried hens’ to sea to allow those eggs to hatch and underpin the viability of local populations.

Unfortunately this is not happening everywhere and there is also concern about overfishing the stock and risk of serious impacts for the industry. Cases of undersized lobster catches are not uncommon. In sustainability and fisheries management terms, there is a lot that needs improved; there are no limits on the overall volume of lobsters that can be caught, stock assessments show that some populations are being overfished and in some areas the data is so inadequate that a realistic stock assessment is not possible. It’s crucial that buyers check the situation locally. Research is showing that area-based measures can help – studies by COAST and University of York of lobster populations in Lamlash Bay show that there is a ‘spillover effect’ with larger lobsters recorded nearer to the No Take Zone.

The MCS Good Fish Guide rates Scottish lobster fisheries as ‘4’ due to the shortage of adequate controls within the fishery.

This blog is part of our ‘Fish Local’ series, to help inform how you can buy locally-landed and sustainable seafood.

Mapped data courtesy of MMO and made available under OGL. Catch data – 2018 UK Vessel Landings per ICES rectangle. Landings data – 2018 UK Vessel Landings to Scottish Ports. Available at https://www.gov.uk/government/statistics/uk-sea-fisheries-annual-statistics-report-2018.

Fish images above courtesy of illustrations from The Natural History of British Fishes (1802) by Edward Donovan (1768-1837), digitally enhanced by rawpixel.com and adapted by Open Seas

Brown crab

Populations of brown crab are distributed all around Scotland’s coasts. Night-time foragers, Brown crabs are caught by creels and are one of the big mainstays of our inshore fisheries. Crabs can grow to over six kilos in weight and live to around 25-30 years. About one third of the weight of a crab is edible and the white and brown meat is variously used in soups, pates and delicious simply dressed.

Amazingly the Scottish fleet catches more brown crab by weight than fish species like hake or whiting, averaging around 11,000 tonnes per year. The vast majority is landed to Scotland, with big catches going to harbours such as Brora, Gardenstown, Scrabster and Ullapool. Orkney sustains the country’s biggest Brown crab fishery with sizeable landings at Holm, Stromness and Kirkwall.

One of the good things about the crab fishery, is that unlike much of the rest of our seafood, it is landed all around the mainland and islands and is not concentrated to big ports. Much is caught using passive fishing gear by small-scale fishermen who are integral within their local economy and rural communities. Recently, a large amount of brown crab was exported abroad, with a big market in China, but the impacts of trade restrictions and Covid-19 may yet force the fishery to adapt its approach.

In terms of sustainability, the fishery is currently not optimally managed because there are no overall limits on the amount anyone can catch. There are few effort restrictions and unfortunately stock assessments estimate that brown crab has been overfished in recent years. If you’re picking yourself a crab, make sure it meets Minimum Landing Size restrictions – generally 150mm carapace width. The MCS Good Fish Guide rates them between 2-3 for Scottish fisheries.

This blog is part of our ‘Fish Local’ series, to help inform how you can buy locally-landed and sustainable seafood.

Mapped data courtesy of MMO and made available under OGL. Catch data – 2018 UK Vessel Landings per ICES rectangle. Landings data – 2018 UK Vessel Landings to Scottish Ports. Available at https://www.gov.uk/government/statistics/uk-sea-fisheries-annual-statistics-report-2018.

Fish images above courtesy of illustrations from The Natural History of British Fishes (1802) by Edward Donovan (1768-1837), digitally enhanced by rawpixel.com and adapted by Open Seas

Mackerel

Nearly a third of Scotland’s fish landings (by value) are mackerel. However, there remain massive issues about where this benefit lands, given the majority of mackerel quota is currently controlled by a few individuals, that roughly half of the mackerel caught by Scottish boats is landed directly abroad and that commercial interests have resisted attempts to encourage them to land more in Scotland. Hopefully this will not continue through the COVID-19 crisis.

They are delicious, and whether you eat them fresh, smoked or even as sushi, they are extremely good for you. In fact, Scottish dietary guidelines say you should be aiming for one portion of oily fish (like mackerel or herring) each week.

We haven’t mapped the landings to foreign ports (although you can view the overall Scottish mackerel landings by value from 2015 here) but below you can see that, whilst the main ports dominate the landings – 56,000 tonnes to Peterhead, 14,000 tonnes to Lerwick – each year a couple of tonnes land to Scrabster, Eyemouth, Ullapool, some of the small port towns on the north Aberdeenshire coast like Portsoy and Rosehearty, even to Pittenweem on the Fife coast. This happens especially during the summer when shoals of mackerel head in to the coasts. Much of this has typically been used for baiting creels (shellfish pots) for crabs, lobsters and langoustine.

The Good Fish Guide has it rated green and green/amber throughout our seas – and, though there are some issues to do with overfishing in the big pelagic fishery, hand-lining is all green rated.

This blog is part of our ‘Fish Local’ series, to help inform how you can buy locally-landed and sustainable seafood.

Mapped data courtesy of MMO and made available under OGL. Catch data – 2018 UK Vessel Landings per ICES rectangle. Landings data – 2018 UK Vessel Landings to Scottish Ports. Available at https://www.gov.uk/government/statistics/uk-sea-fisheries-annual-statistics-report-2018.

Fish images above courtesy of illustrations from The Natural History of British Fishes (1802) by Edward Donovan (1768-1837), digitally enhanced by rawpixel.com and adapted by Open Seas

 

Saithe (Coley)

Saithe, otherwise known as Coley, is one of our favourites. Saithe is a gadoid, in the same family as cod, but it’s generally smaller, less meaty and a bit bonier. Because of this it’s never been as popular but don’t let that put you off; it’s great, especially when fresh.

Most saithe/coley is caught by the demersal trawl fleet, often the same boats catching your cod or haddock. We’re just coming out of the breeding time so aim for bigger fish – minimum size is 35cm, but anything above 60cm is mature so had chance to spawn.

Despite there being some concerns about trawling causing damage to the seafloor and other species being accidentally bycaught and discarded in this fishery, all the coley fisheries around Scotland are rated green or green/amber by the MCS Good Fish Guide

Here’s where they’re caught and where they are landed. There is a concentration of landings to the big ports of Peterhead, Lerwick and Kinlochbervie but Scrabster, Ullapool and Mallaig all have several tonnes worth of fish landing there each year. The fishing grounds are concentrated in the north North Sea and along the ‘Hebridean Shelf’, a steep underwater cliff edge to the North of Lewis.

This blog is part of our ‘Fish Local’ series, to help inform how you can buy locally-landed and sustainable seafood.

Mapped data courtesy of MMO and made available under OGL. Catch data – 2018 UK Vessel Landings per ICES rectangle. Landings data – 2018 UK Vessel Landings to Scottish Ports. Available at https://www.gov.uk/government/statistics/uk-sea-fisheries-annual-statistics-report-2018.

Fish images above courtesy of illustrations from The Natural History of British Fishes (1802) by Edward Donovan (1768-1837), digitally enhanced by rawpixel.com and adapted by Open Seas

Report highlights illegal discarding in scampi industry

We have published a ‘Discard Dossier’ in collaboration with Our Fish providing evidence that illegal discarding continues in the Scottish prawn (scampi) fishery and is threatening the recovery of our already collapsed fish stocks.

Here’s the executive summary:

In 2013 the ‘discard ban’ or Landing Obligation was agreed to reduce and record the amount of fish killed as ‘unwanted catches’ in our fisheries, specifically to end seafood waste at-sea and reduce the amount of unintended fish mortality caused to populations of fish caught as bycatch.

On the West Coast of Scotland, these populations include cod, whiting and haddock, all of which are at depleted levels in this area. Cod stocks have essentially collapsed.

The discard ban was phased in between 2015 and 2019 to allow fisheries and businesses time to adapt. However, a 2018 House of Lords investigation found “no evidence that fishers have been complying with it”, and further that “little attempt appears to have been made to enforce the landing obligation’s requirements thus far”.

Due to the depletion of fish stocks and consolidation of quota, the west coast fisheries now [Read more…]

Transparency is a fundamental tool for deterring illegal fishing

Earlier this week, the Herald ran a front page story ‘Justice in secret for skippers that flout laws at sea’. 

The news article focussed on concerns raised after the Scottish Government declined to disclose the identity of vessels given fines for suspected illegal trawling inside Loch Gairloch, an area of inshore seabed known to hold vital habitat for spring spawning herring. 

This is an issue we have been following for some time. Reports of illegal fishing in protected areas of Scotland’s seas are sadly all-too-frequent and despite increasing awareness of the problem, it’s still happening. This is in part due to the under-resourcing of fisheries enforcement in Scotland, but also because the legislative regime itself does not effectively deal with – and deter – illegal fishing. Sustainable fishermen, and our environment, are now paying the price:  illegal dredging or trawling can entail huge collateral damage to marine wildlife and also compromise the sea’s productivity for other fisheries. Back in 2018, we collaborated with local divers to investigate the seabed after reports of illegal trawling in Loch Gairloch. In July this year, the Scottish Government confirmed that two vessels were issued ‘Fixed Penalty Notices’, each for £2,000 for illegally fishing inside the Gairloch closed area. [Read more…]

A lesson from Loch Carron

What happened in Loch Carron is a window into the bright future that could exist along our coastline and a lifeboat moment for sustainable fishing in Scotland. It shows what can be achieved with popular will, local support and political leadership – that the guardianship of our seabed for future generations is possible, and is a good thing for coastal communities.

On Friday 17th May, a diverse group including local fishermen, divers, marine scientists, school children, campaigners, and a local politician, gathered in Plockton to celebrate Loch Carron becoming a permanent Marine Protected Area. Some literally gathered in Loch Carron itself, snorkelling and diving to see first-hand what lies below the waves.

Inverness Sub-Aqua Club, Ullapool Sea Savers, Maree Todd MSP, fishing businesses, community groups and environmental campaigners gathered in Plockton

Back in April 2017 a scallop dredger had been witnessed towing its heavy and damaging dredges through the sea loch known by locals to be [Read more…]

Dredging in the dark

The success of Scotland’s seafood sector relies upon a reputation of high-quality, sustainable and traceable fish, and yet the Scottish Government is continuing to sit on its hands in the wake of repeated instances of illegal scallop dredging. We document a recent incident of suspicious fishing activity in the Sound of Mull, and explain how inaction by the Scottish Government is undermining the recovery of our marine environment – and why vessel tracking could help solve the problem.

Ram-raiding MPAs

In recent weeks, community organisations, fishermen and environmental groups have spoken with one voice to highlight the systemic failure by Marine Scotland to effectively manage Scotland’s inshore fisheries and protect and enforce fishing rules in Marine Protected Areas (MPAs). A series of incidents of both damaging and illegal scallop dredging prompted 42 organisations – including our own – to sign a joint letter to First Minister Nicola Sturgeon calling for the Scottish Government to enforce fishing laws in MPAs and rethink the lack of management, which currently leaves 95% of Scotland’s inshore waters open to scallop dredging.

Our view is that without improved management, the productive potential of our seabed will continue to be eroded by poorly regulated dredging. This means coastal communities, businesses and our broader inshore fishing sector are being disadvantaged by a degraded marine environment. [Read more…]

Open Seas statement on illegal and damaging dredging in Gairloch

Scallop dredging pulverises our seabed, and yet it is permitted through about 95% of our coastal seas. What we have seen in Gairloch are the actions of a few greedy fishermen, for whom 95% of it is not enough. These scallopers have decided to decimate one of the few small areas protected from this damaging form of fishing.

We need to get this fishery out of our sensitive and vulnerable coastal sea, unless in areas where the fishery can itself prove it is sustainable for it to be there. We also need to establish a proper means of tracking the boats so that illegal fishing like this is stamped out for good.

The blame in this instance lands firmly with Scottish Ministers. The current regulation of scallop dredging is pitifully inadequate. This Government is failing to protect our natural heritage by allowing one of the only places where herring are still spawning to be destroyed in this way. Unless they take action soon, they will be turning their back on not only our marine environment, but the future of our fisheries and the rural economy in places like Wester Ross. Real stewardship of our seabed would be to the long-term benefit of Scotland.

In just four years, scallop landings in Scotland have declined by roughly 30% (2013-2017). There is an underlying problem that needs to be addressed urgently.

For more information and background to this issue, read ‘Probe into alleged scallop dredging in protected area‘.

We will continue to update our own news page with more detail.

Members of:

Scottish Rewilding Alliance
Our Seas coalition
Slow Food Scotland
Scottish Food Coalition
UKELA Scotland
Stop Climate Chaos Scotland