This week an annual seasonal closure to protect spawning cod has come into force in the Clyde. Proposed measures to protect cod have courted controversy and the Scottish Government has u-turned on their plans, apparently to appease commercial trawl fishing interests. We share evidence of cod bycatch within the Nephrops trawl fleet that calls into question the recent decision that allows trawling to continue within a closure designed to protect spawning cod.
The Clyde cod population, which once underpinned a thriving fishery, remains in a state of collapse due in part to severe overfishing in the 1980s and 90s. The spawning stock biomass for cod is estimated to be at its lowest in recorded history.
For the past 20 years the annual seasonal spawning closure, designed to safeguard cod while they spawn, has included a number of exemptions. This has meant that bottom-trawling for Nephrops (prawns or langoustine), the dominant method of fishing in the Clyde, has not been prohibited by the closure. During this time cod stocks have not recovered. In January this year the Scottish Government finally sought to address this management anomaly by banning prawn trawling within the cod box during cod spawning season. However, under pressure from industry, the Government has since u-turned by reducing the size of the closure (removing areas containing muddy sediment from the closure), such that prawn trawling could continue largely as before, whilst banning all fishing within the smaller revised closure area. This has simultaneously restricted low impact creel fishing, whilst failing to properly reduce the impact from bottom-trawling. A recent submission to the Rural Affairs Islands & Natural Environment Committee from the Clyde 2020 Research Advisory Group has stated that there is no evidence creeling impacts spawning cod (“the justification for excluding creels from the cod box is lacking“), and the tenuous memo which the Scottish Government had previously provided and claimed to be that evidence has since been removed from the Government’s blog on the subject.
We think this is a serious problem and exposes a broader dysfunction about the way Scotland’s inshore fisheries are managed. One key issue is the variable quality of evidence upon which fisheries management decisions are made.
The bycatch of cod in the Nephrops bottom trawl fishery is known to be a reason for the poor condition of the Clyde cod stock. However, there is very little recent evidence available on the distribution, timing or rates of this bycatch. That is not to say that there has been very little research, simply that the research that has been done has yet to be made public.
In 2013 and 2014 a programme of bycatch observations was undertaken by the Scottish Fishermen’s Federation (SFF) on the bottom trawl fleet operating in the Clyde seeking to understand the catch rates of fish in the trawlers and the amount of this which was discarded back into the sea. The results from this were used to argue that bycatch rates from this fishery were low and that therefore should be exempted from various regulations, including elements of the impending discard ban, eventually fully implemented in 2019 for the Nephrops fleet.
To our knowledge no such observer trips with such a focus on studying bycatch have been undertaken since. So they are clearly also very relevant to the current debate about protecting spawning cod within the Clyde during the spawning season.
The data have been shared with us by a former employee of one of the commercial groups involved in the study. Given the importance of this information for understanding the environmental footprint of the bottom trawl fishery in the Clyde, its impact on spawning cod, and how it should be managed, as well as the fact that neither Marine Scotland nor SFF themselves appear to be willing to publish it, we have chosen to publish it in part. We summarise some key data here:
- Between July 2013 and August 2014 383 trips were observed across a large number of boats, fishing out from Campbeltown, Troon, Rothesay, Carradale and Tarbert.
- Of these, 31 took place within the Clyde Cod Spawning closure and during the months of February to May, i.e. during the spawning season (and the period for which the closure was in force).
- Cod was caught in all but three of the trawl tows.
- In those 28 tows, cod bycatch ranged from 21 individual cod weighing in total 36kg, and comprising 11% of the total catch, to one small 30g cod comprising less than 0.1% of the catch.
- In all 28 tows in which cod was bycaught, all of the cod was discarded. On average four cod were caught in each tow.
A map of these catches shows very clearly that the distribution of these catches aligns closely with the distribution of the bottom trawl fishery for Nephrops.
But more importantly, it clearly shows that the exemption which the Scottish Government has recently made for bottom trawling within this area clearly holds cod and includes areas where cod have been bycaught during the spawning season.
We believe that Marine Scotland have access to this data and should be transparently using this data to inform its management approach.
The Scottish Parliament’s Rural Affairs Islands & Natural Environment is planning to scrutinise the decision and has called for evidence by 23rd February.
This blog was last updated on 4th March 2022, following a public session of the Scottish Parliament’s Rural Affairs, Islands & Natural Environment Committee.
We will update this blog as more information is released into the public domain.