TOP

Open Seas

Promoting sustainable seafood from Scotland's Seas

Are Scotland’s fish stocks in good condition?

The Scottish trawl fishing lobby has recently declared that there are “more fish in the sea than ever“. We consider the facts behind the headlines.

“Another component of the threadbare dossier produced by the greens to attack the industry is “over-fishing. This myth really needs to be put to bed, once and for all.”

Elspeth MacDonald, chief executive of Scottish Fishermen’s Federation, The Scotsman, August 2021

In recent months, some of the main trawler lobbyists, the Shetland Fishermen’s Association and its parent organisation, the Scottish Fishermen’s Federation (SFF), have made far-fetched statements that dismiss overfishing as a “myth”, environmental concerns as “misguided” and amazingly ask whether “environmental NGOs are recommending mass starvation?” – this last statement is from organisations who have lobbied for their members to land more than 45% of their catch directly to foreign ports, bypassing our own food system and workers in Scotland entirely.

These comments are apparently aimed to distract from calls for parts of the fishing industry to reduce its carbon footprint and environmental impact. The industry lobbyists instead claim that “North Sea fish stocks are in a tremendously healthy state“, or recovering and indeed that “there are more fish in the sea than ever”. It is vitally important to assess whether these statements are factually correct.

So what is the state of Scotland’s fish populations? Is overfishing a myth?

No. Overfishing is not a myth. And to call it one either negligently ignores the evidence, or is a lie.

Not only is overfishing the backstory to the current state of our seas (Scotland is estimated to have allocated 1.2 million tonnes of fishing quota above scientific advice from 2001-2020), it sadly still continues today for several key stocks, notably cod on the west coast of Scotland.

Overfishing continues

If we consider the Greater North Sea in detail for stock assessments available in 2021, of 30 stocks with suitable data, 17 (57%) were subject to ongoing overfishing and 15 stocks (50%) were outside of safe biological limits. Only six stocks (20%) were sufficiently large (ie where the spawning stock biomass (SSB) exceeded the population size at the point of maximum growth rate (Bmsy) and were exploited sustainably (F <= Fmsy), as required by the Common Fisheries Policy and new UK legislation, applicable in Scotland.

Iconic species such as North Sea cod were badly overfished in the late 1990s and into the 2000s. The size of the adult (spawning) population fell to its lowest levels ever in 2005, something that was predicted six years before by scientists who were warning of overfishing. An emergency plan was put in place to help the population stabilise and grow. It began to recover, but soon overfishing began again and sadly continues to this day.

The Scottish Government’s recent decadal “Scottish Marine Assessment 2020” found that 46% of the stocks it evaluated were overfished.

In the North Sea, a combination of the post-Brexit treaty requiring an agreement between UK governments and the EU, and the fact that the EU has a legal duty to end overfishing by 2020 has meant that, for 2021 at the least, quota levels have been set in line with sustainable limits for most species. However, not all. Notably, total quota levels for North Sea cod, whose population (or Spawning Stock Biomass) is below its sustainable limit and therefore should be in remedial measures, were set beyond sustainable limits.

Beyond the North Sea the situation is much worse, with the lowest adult population of cod in the west of Scotland ever recorded last year and no sign of it bottoming out. Scientific advice for this stock is that no fish be caught at all: this is not very practical advice, but is indicative of the near-collapsed status of the stock. A ‘bycatch quota’ is still allocated for the west coast cod population, due to the bycatch of juvenile fish involved in Nephrops trawling. Consequently the government has set a total catch level of 1,279 tonnes – this is supposedly only for use as a bycatch species but that has plainly been abused.

Other stocks are also being overfished, such as Northeast Atlantic mackerel and blue whiting, something raised as a serious concern by the North Atlantic Pelagic Advocacy Group (NAPA), a collective of retailers and supply-chain businesses.

Unfortunately, we can go on – advice for haddock is that no more than 6,239 tonnes be caught in Rockall, the agreed catch level was 8,375 tonnes… Overfishing is not a ‘myth‘.

Part of the reason for claiming overfishing is a myth may be the fact that some fishermen are finding juvenile and adult cod in places and abundances they have not been in the recent past. This is good news – and everyone welcomes the calls for more research into why this is happening. Is it an early sign that the cuts to quota made over recent years are working? Is it a result of the fact that fishing effort in 2020 was suppressed for a significant part of the year due to the pandemic? Is it in part a result of restrictions on scallop dredging on the Dogger Bank?

Part of the problem untangling these problems, however, is that these catches are not made as part of any robust scientific study and are going unrecorded because these juvenile fish, these budding signs of recovery, will be bycatch that often goes completely unrecorded and thrown back dead into the sea. This prevents any of the information (currently being reported anecdotally) actually feeding into the next scientific catch limits.

The detail behind the headlines

So, how can SFA and SFF claim that all is well, that whitefish stocks in Scotland are “at record levels”?

They do so by considering the situation only in its aggregated form. If you mix overfished stocks in with enough recovering ones you can arrive at a position where everything looks roughly okay and this is what they have done.

In this case they have considered the hammered cod stocks alongside hake, a species experiencing a boom in the North Sea as waters warm and become better for their growth. Similarly, the statistics include plaice and sole, two species which suffered so badly from overfishing that they were also put into recovery plans banning overfishing and ultimately meaning that they have seen a rapid increase in numbers between 2009 and 2020 – albeit exclusively of small fish with few larger adults returning.

An important point to take from this “record numbers” claim, however, is the fact that the recoveries which are resulting in these “record numbers” are a direct result of scientists and fishermen acknowledging the declines and taking action. These plans would not have succeeded in recovering these fisheries had managers and the people fishing them considered overfishing a ‘myth’. Being up-front and honest about overfishing and taking action, is what has allowed them to recover. Good management works, and we should welcome and celebrate those fish populations which are now recovering like haddock and plaice, not just as ‘stocks’ that provide food, as important as that is, but also as biodiversity: species that are our natural heritage and vital components of our marine ecosystem. In the meantime, it is misleading to suggest that fish stocks are generally in good condition, just because some populations are recovering (as heartening as that is).

Any signs of recovery need to be put in historical context – cod catches in the North Sea used to be routinely upwards of 150,000 tonnes per year. Many scientists now warn of repeating mistakes made in other fisheries where collapsed North Atlantic cod fisheries have never effectively recovered due to taking out more fish than is sustainable, failing to let fish spawn before capture, providing too few refuges and not acting early on the warning signs. Scientific advice West of Scotland herring remains ‘zero catch’, so there is still a lot of work to do to recover these populations.

 

Understanding the statistics

The aggregation approach is also something done by the Scottish Government’s National Performance Framework (NPF) which finds 33% of stocks are not fished sustainably. However, it arrives at this position by removing from the analysis any stocks which are collapsed (such as West of Scotland cod) or not properly studied (e.g. shellfish). This means the NPF’s figure of 33% is a percentage of the 11 most valuable (landings) ICES stock-assessed stocks which overlap Scottish seas and only includes stocks that have quantitative assessments (that give estimates of F and SSB, and have agreed MSY reference points). If you only look at the part of the glass with water in it you can conclude that it’s half full.

Many stocks are simply not included in the assessment, such as wrasse, crabs, lobster, ling, many of which are commercially significant. Some of these (eg crab and lobster) have intermittent stock assessments which show that their health is a concern at regional levels. Some fish such as wrasse and ling have no stock assessments at all, which is a big worry in itself. The NPF also does not consider other stocks which are no longer caught in commercial quantities from our seas, a symptom of the shifting baseline syndrome that besets fisheries management globally.

Continued illegal discarding

Another issue that the trawl lobby seems keen to gloss over is that these catch figures involve alarming levels of food waste. In the last four years alone, ICES estimates that over 20,000 tonnes of North Sea cod and 48% of all the plaice caught in the North Sea has been discarded. This is an unsustainable situation and no doubt those involved in these fisheries are not happy with that kind of waste. SFF are right to be concerned about food security, but what’s the best way to make sure we have fish? The fundamental place to start is to recover historically overfished stocks, regenerate the environment they depend on, and end the wasteful practice of discarding. Discarding was made illegal in 2019 (with only certain exemptions), but tragically is continuing to this day as a commonplace practice within the industry. Our report highlighted illegal discarding in the Nephrops (prawn trawl) fishery and a recent EU report (“Synthesis of Landing Obligation measures and discard rates”) acknowledges that “significant undocumented discarding of catches occur”.

A new reality?

Unfortunately, rather than address these clear problems, some of the bigger trawl fishing trade associations are instead pushing for a new ‘independent’ panel to provide Scottish-specific fisheries advice, rather than relying on that of the International Council for the Exploration of the Sea (ICES), a scientific forum that has been in place since 1902. We have expressed concerns about this and question the real motivation behind such a new panel. We acknowledge that ICES is not without its flaws (discarding is likely being under-estimated, and therefore total fish catches from Scottish waters), but its advice is transparent and peer-reviewed.

These concerns seem to be shared by some fisheries scientists who diplomatically note that “robust peer review is an essential part of the scientific approach and, in the context of ICES advice, could be strengthened. However, replicating the entire ICES stock assessment process within Scotland does not seem to me to be either desirable or feasible.” How the Scottish Government responds to these calls for a new panel remains to be seen, but the rationale needs to be based on facts, not misinformation.

The misleading statements about fish stocks now being put out by the Scottish Fishermen’s Federation are worrying, because it makes harder a mature public policy debate about how to manage and safeguard our fisheries for future generations and address the clear problems faced by parts of the industry. Although we state our concerns about the environmental impacts of fishing, Open Seas is also campaigning to support well managed fisheries and are passionate about sustainable seafood in Scotland, produced and eaten as locally as possible. However, next time you come across a statement which suggests all of Scotland’s fish stocks are in buoyant health, we entreat you to take it with more than a pinch of sea-salt and check the underlying facts.

Members of:

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