Open Seas’ mission is to promote more sustainable fishing in Scotland. It is with some regret that we are now challenging the proposed re-certification of the scallop dredge fishery in Shetland. Unfortunately the possible re-certification of scallop dredging here, under its current management regime, risks green-washing an important certification standard that should represent a benchmark for sustainability.
Scallop dredging is one of the UK’s most damaging forms of fishing. Dredge boats tow heavy rakes with metal teeth several inches long that dig into the seabed, dredging out the scallops. In April of 2017 the severity of damage caused by scallop dredging was revealed when a vessel towed through a well-known flame shell reef in Loch Carron. The killing of species other than scallops and the flattening of seabed habitats, means dredging has and continues to have a profoundly negative impact on the health of our seas. However, it does not have to be this way. Dredging in some places might be sustainable, particularly in areas of seabed that are frequently disturbed by natural wave action and currents and which do not – or could not, either now or in the future – support sensitive seabed species and habitats. Any scallop dredge fishery hoping to be viewed as sustainable must be able to evidence that it operates in this way.
Five years ago, Shetland’s scallop dredge fishery (managed by the Shetland Shellfish Management Organisation; SSMO) was awarded the Marine Stewardship Council (MSC) blue label certification. Whilst the assessors granting this certification noted at the time the fishery still had some way to go to meet its full sustainability credentials, the Shetland scallop dredge fishery has since been praised as an example of a locally and environmentally-sensitive management system. The fishery has since been able to sell their scallops at a premium, and is currently worth about £2.4 million pounds annually.
Now, five years on, the fishery’s certificate is being reassessed. Since the original certification some things have changed: new Marine Protected Areas (MPA) have been designated in Shetland’s seas; and some moves – albeit still inadequate – have been made to improve scallop dredge fisheries around Scotland. We argue the issues outstanding in 2012 still remain and have not been fully addressed. In particular, we have concerns about the fishery’s impact on the seabed, the amount of other species caught and killed, and the fact that the fishery operates within the new and now well-established MPAs. We estimate that hundreds of tonnes of fish and habitat-forming molluscs (such as horse mussels) are raked up by this particular fishery each year.
We’re obviously concerned by these things, and so, soon after we were founded as an organisation, we started looking at the re-certification process, trying to understand the reassessment criteria, the evidence and the management regime.
Day 3 Horse Mussels
Did you know?
A horse mussel bed off the coast of Wick was recently found to be the size of 380 ha – the biggest ever found.
In an area no bigger than a sheet of A3 paper, there can be 270 different species found and in excess of 5,000 individual animals! pic.twitter.com/IgoAxYsze7
— Scotland Big Picture (@ScotlandTBP) December 3, 2017
A private assessment company undertakes the assessment on behalf of MSC and in this case the assessor, Acoura Marine (previously Food Certification International), had been working on this fishery’s MSC certificate since 2012. Given our various concerns we wrote to the assessors back in December 2016 to ask how best to engage and feed them in to the process. Following their advice, we submitted our concerns formally just over a year ago (see here) with the aim of improving the assessment and finding ways that the fishery could be improved to address such concerns. Acoura responded by saying “Anything that you submit now we will consider and come back to you on.”
Between November 2016 and December 2017 Acoura Marine have three times asked for extensions for their reassessment based on “exceptional circumstances”. MSC approved each of these. During this time we received no responses to our comments or concerns. Finally in November 2017, the reassessment report was published (see here).
The reassessment report recommended the fishery be recertified, but had not considered the issues we had raised, nor addressed those concerns. These were not insignificant issues – things like the fact that “parts of” the critically endangered common skate were found in 2 of 57 dredging events undertaken as part of an experiment, and the fact that the assessment overlooks Government advice.
Notwithstanding legitimate concerns about the financial barriers to accessing food certification schemes, a MSC blue label, in our view, should reflect a gold standard for sustainability. However, we simply couldn’t see how the assessor with this reassessment report, or the fishery with its current management regime, could meet the strict MSC criteria. It for this reason that we have decided we must draw wider attention to this issue. It appears that legitimate concerns have not been adequately considered and could be ignored if left unchallenged.
We are aware of the gravity of highlighting these concerns, but we regard the long-term sustainability of our seas to be the most important consideration of all. Consumer confidence in sustainable seafood comes a close second; the MSC standard should not be diluted through inadequate application of its criteria.
We do not consider that the scallop fishery meets MSC criteria in its current management regime. In particular, we contend that evidence shows that the fishery does not meet “pass” criteria for three ‘Performance Indicators’ (vital if the fishery is to achieve certification). We highlight these in turn here:
- Whilst it recognises that dredging has serious and long term seabed impacts, the assessor considers that these are entirely mitigated by the SSMO’s few small voluntary closed areas. These cover only around 20km² of Shetland’s inshore sea and are designed to protect maerl and horse mussels only – other areas are open to dredging. A range of other species and habitats susceptible to impact by dredgers exist outside of these closed areas; and so too do areas of maerl and horse mussels which are considered by the SSMO to be too sparsely distributed to be called a “reef” or “bed”.
- The assessors have overlooked Shetland’s nature conservation Marine Protected Areas entirely, i.e. there is no mention of “ncMPAs” at all in the entire report, let alone any assessment of the fishery’s impact on the kelp beds in the Fetlar to Haroldswick MPA, or sandeels in the Mousa to Boddam MPA. This goes against MSC criteria, and ignores the concern Open Seas raised in December of 2016.
- The assessors say “Impacts of [scallop dredging] on [Shetland marine] SACs is not of concern (SNH, pers. comm. during site visit)“. Whilst it is unclear who at SNH gave this advice, we note that it is not actually the case. Scottish Government hosted a workshop in Shetland on 30th April 2015 to discuss exactly how the impact of scallop dredging on the Shetland marine SACs could be mitigated and this clearly needs to be part of the sustainability assessment.
- Despite admitting finding “parts of” two common skate in the 57 experimental dredge tows, the assessor considers there is no significant impact on this species. Common skate are recognised as Critically Endangered by the IUCN, and in particular are known to have been extirpated from most of their range, with only a few strongholds remaining – one of which is in Shetland. The two skate which came into contact with the gear most likely died on the seabed, and as well as these body parts, two egg cases were also found. We feel strongly that such an impact on such a species cannot be considered sustainable.
- Despite finding that horse mussel (and similarly rare species) made up 6.9% of the catch in those experimental tows, the assessors do not consider there to be any issue with this. Again they have not attempted to do any species level impact study.
- The assessors have not considered any Scottish Priority Marine Features under their assessment of ‘Endangered, Threatened or Protected’ species. This appears to go against any rational interpretation of MSC assessment guidelines and also means that the management in Shetland lags behind the Scottish national policy.
- 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.
We think it is essential that these concerns are acknowledged in the assessment. It would be very strange if the fishery, despite these issues, was certified as sustainable. We have therefore recently provided another comprehensive and robust response to the assessor and hope it will play a role in helping craft a more sustainable future for our scallop fisheries.
There has been discussion elsewhere about the potential for MSC certification of other scallop dredge fisheries in the UK. As one of the first scallop dredge fisheries to be MSC-certified, the SSMO must be an example of best practice regulation, otherwise a worrying precedent will be set. The health of our seas and Scotland’s reputation for high-quality, sustainable seafood is ultimately at stake.