The wrong activity, in the wrong place, can cause serious damage to the health of our seas. In Loch Carron, we saw this starkly when the world’s largest flame shell reef was damaged by a scallop dredger. (If you’re not familiar with what happened in Loch Carron, we suggest you read this before continuing here).
The Scottish Government set up a “National Marine Plan” in 2015 to manage these impacts and guide the way the sea is used by industries. Unfortunately, the events in Loch Carron made clear that Ministers are failing to comply with it, specifically by failing to ensure that use of the marine environment does not impact on the national status of “Priority Marine Features”.
As a result, the Government are now undertaking a “review” to understand what impacts of bottom-towed fishing are taking place and to assess the cost of meeting their own legal requirements… It looks like this is going to result in very little actual action and so we’re calling for a more effective and evidence-based approach to protect our underwater heritage, the future of our fisheries and the health of our seas – read on to find out more.
A brief history
Scotland’s seas are a central part of our culture. Since the first people arrived to settle here after the last ice age, our seas have provided the foundations of society – literally so in some places; archaeologists have found homes made from oyster shell middens, and more recently towns such as Plockton were planned and built to harvest fish. The habitats carpeting the seabed, are the foundation of our seas. They give life to our fish, they filter our water, they store carbon and underpin the functioning of the interconnected web of life in the sea. Unfortunately they are in a historically bad condition.
In the 1800s fishing with trawl gear that ran along the seabed (otter and beam trawl) was seen as new technology. Many were concerned about its impact on the seafloor, fish and the ability of certain species to spawn on the seabed. Towards the end of the century there was so much concern that, in 1863, the House of Commons set up a Royal Commission to investigate the issue.
“In three weeks time we had that spot of ground raked and torn up and in such a condition that we had every fish of it. I believe it was as bare as the council chamber. I believe there was nothing escaped.”
Evidence given the The Royal Commission on Sea Fisheries in Edinburgh regarding trawling in the Forth.
Henry Fenwick MP, who led calls for the Commission stated there was “almost a universal cry that our fisheries were falling off year by year”. The Commission was lobbied both ways, and there was a lot of debate, however, the result was to pass a series of pieces of law which culminated in the Herring Fishery (Scotland) Act 1889. This banned trawling (the only dredging that existed at this time was done by rowers so it was not included) from 3 nautical miles around our coast (and Firths and Sounds) with a few exceptions, for example, trawling by sail was permitted. It was also followed by laws which were set up to properly enforce this limit. The Illegal Trawling (Scotland) Act, 1934 established potentially serious punishment if this rule was broken, including prison time.
These laws lasted for some time but by the 1950s the fishing fleets around our coast had changed significantly and they were beginning to be challenged. This was the era of the Klondykers, when big factory ships from Baltic states visited our coastlines and hammered the herring and mackerel stocks. Our own domestic fleet had also up-tooled following the war and was also now using bigger, faster, more powerful boats and having serious impacts on fish stocks.
The extent of the 1889 trawl ban, compared to trawl restrictions at the beginning on 2017
The 1889 trawl ban was beginning to be challenged. Some vessels started to enter the 3 mile limit illegally, others complained that it made no sense to deny trawlers access when the offshore stocks were now dwindling. Eventually, by 1984 the protection offered to our coastal seas was removed in the Inshore Fishing (Scotland) Act 1984 – the floodgates opened. Older fishermen now talk of this as the end of the time of plenty. Inshore stocks, especially on the west coast, were fished so hard that they returned to their “falling off, year by year”.
New fishing gear technologies (bobbins and later ‘rockhoppers’) enabled trawlers to also move from their historic muddy and sandy seabed grounds, onto harder, rockier ground and sometimes reefs. These ‘craggy’ seabeds were some of the most important and untouched, but they too were now vulnerable to being damaged.
The seabed in Loch Carron after dredge damage
Loch Carron may have been the most memorable and well-documented damage in past years, but during the late 1980s similar incidents were happening all around our coasts, out of sight and largely unacknowledged. Evidence from the Clyde shows the late 1980s saw significant and long term changes in the species and habitats found on the seafloor; anecdotal reports tell of big cod and haddock catches made by trawlers working behind the dredgers to collect up the fish drawn in by the rubblised seabed.
Whilst access to these new grounds appeared to improve fish catches for a short while, it eventually further compounded the decline of our inshore seas. Landings from these seas are down to a very low level; there is now a ‘no catch’ limit on cod on the west coast for example, with no notable fish catches made from the inshore. The fisheries that do remain inshore are nearly all shellfish fisheries – crabs, lobsters, scampi, scallops and langoustine. We have literally started to scrape the bottom – and seabed habitats which underpin a wider array of fish species, have no chance to recover as things stand.
Demersal fish (cod, haddock, flatfish, etc) from ICES area 7a (West of Scotland) over the past 40 years
What is happening now?
Shortly after the damage done in Loch Carron we wrote about how the incident was not just the result of a problem in this one remote sea loch, it showcased a problem that exists throughout our inshore seas – Loch Carron wasn’t the only reef that is being left wide open to damage by dredging and trawling.
Scottish Government took action, not only by designating an emergency MPA in Loch Carron, to stop further damage, but also by initiating a much broader review of the impact of fishing (specifically bottom-trawling and dredging) on other areas of Scotland’s seabed.
“We take our duty to protect Scotland’s rich marine environment extremely seriously and recognise the importance of safeguarding vulnerable habitats like flame shell beds.
“While we recognise there are concerns around scallop dredging in coastal waters, we must balance environmental concerns with the need for legitimate and sustainable fishing.
“The Scottish Government will now begin work immediately to identify if there are other areas which should be protected.”
Roseanna Cunningham, Minister for Environment and Land Reform, 19/05/17 (here)
Although this was arguably something the Government have been committed to doing since the passing of the Marine Act, and definitely since it set itself commitments within its National Marine Plan to not permit use of the marine environment which has a significant impact on the national status of Priority Marine Features and to protect and enhance the health of the marine area, we nevertheless welcomed the Minister’s announcement.
Loch Carron showed the impact and lasting damage that can be caused by even a single reckless or unregulated action, especially when using fishing gear as damaging as scallop dredges. We have documented and evidenced the damaging impacts of dredging and trawling here.
Amazingly, scallop dredging and scampi trawling is permitted to take place across the vast majority of our inshore waters unless specified otherwise. The same is simply not true of other industries. To extract peat, for example, even if you owned the land (and remember, no-one owns the seabed, it’s a public resource) you would have to go through an extensive process of license and planning applications, including environmental assessments and assessments of the CO₂ implications of the activity.
Horse mussel beds provide habitat not only for themselves, but also an array of other species
In their response to Loch Carron, Scottish Government appeared to acknowledge this, and further committed themselves to “identify where else fisheries management is needed to ensure there is no significant impact on Priority Marine Features”
“Most industries have to undertake environmental impact assessments which enable the regulator to determine whether the project will have a significant impact. There is no such mechanism for fisheries. Therefore we intend to identify where else fisheries management is needed to ensure there is no significant impact on Priority Marine Features”
Scottish Government Release, May 2017 (here)
Since the 1984 repeal of the “3 mile limit”, these fisheries have only been restricted in a handful of areas, and more recently in 26 of our inshore MPAs (& SACs). However, these are small areas compared to the amount of healthy habitats that have been lost.
The result is that trawling and dredging inshore is widely considered unsustainable because of impact on the inshore seas. Even Seafish, the Government-funded body responsible for marketing seafood, considers both of scallop dredging and scampi trawling as high risk fisheries.
Healthy maerl beds once carpeted much of our inshore seas; today they remain in only a few places
This seabed review is a major opportunity to undertake a proper environmental impact assessment (as is required of all other industries), improve management and start delivering truly sustainable seafood from our seas.
Why are you telling me?
We think the Scottish Government’s seabed review is a once-in-a-generation opportunity to put our inshore fisheries on a sustainable footing and to kick start the recovery of our seas. However, as it stands it is looking more like carry-on-as-usual, than a strategic vision for the future – here is a map of what they are currently considering.
The Scottish Government’s current plan considers just 11 seabed species and habitats in Scotland, aims to find the few remnant places where they remain, and then do a cost/benefit analysis to assess the impact of restricting dredging and trawling from some of these already small areas.
Young cod on Scottish kelp beds
If this seems completely cart before horse, it’s because it is. If this seems like it’s going to achieve very little, then it’s also because… it is. Why decide on the cheapest approach, and then evaluate how much it may cost? By doing so we are missing the vital chance to understand the actual impacts (both positive and negative) of managing our seas in a more environmentally sensitive or sustainable way – or even just by doing it the way we used to (between 1889 and 1984).
In practice it also means situations similar to Loch Carron will continue and that Ministers will continue to fail their obligations. In practice it means that damaging fisheries will still operate on fragile habitats and impact upon species that are vulnerable to these methods of fishing. But perhaps most significantly, it also means we will continue to overlook entirely the places where we’ve lost species and habitats and where there is still potential for them to recover. As has been seen in Lamlash Bay, the seas have a remarkable ability to recover when damaging fishing is removed, with the recovery in the seabed we see more numerous fish and more spawning shellfish, but this requires proper protection and time.
The distribution of the species and habitats being considered by Scottish Government (all data from NMPi) layers can be switched on and off.
What can I do about it?
The Scottish Government are looking for views on all of this. There is a consultation live now and until 31 August, it can be found here, so let them know what you think.
If you’re interested in our views, read on… we have four key concerns.
As is unfortunately typical, this process has become very technical and no longer really resembles the fishing “environmental impact assessment” which was first promised. Why is no such impact assessment being undertaken? It seems this has been pushed aside, but without any clear indication as to why…
Secondly, by taking this technical approach, the Government have selected only 11 species and habitats from the 65,000+ in Scotland’s seas. Looking at only 11 habitats and species in our sea is missing quite a lot of the rest! Imagine if we protected our land by selecting only 11 species, we would have small sanctuaries around Scottish primrose, tiger worms and a few others, leaving nothing protected anywhere in between.
Whilst the 11 are some of the most amazing and interesting – we’ve been blogging about horse mussels, flame shells and native oysters, with more to come – they are not the only things that keep our seas working or that are highly vulnerable to damage. Scottish Government’s own scientific advice shows that a range of others are also vulnerable – including habitats such as tidal sands with burrowing bivalves, the critically endangered Common skate and species like the Northern feather star. Why are these being overlooked?
SNH footage of Northern feather stars in Scotland’s seas
Thirdly, by looking at the places where 11 species exist now, after a few decades of damage, we are also missing a whole chapter of our history and natural heritage. Imagine if we only protect what we currently have on land, and never sought to recover anything. For a start, the reforestation of Glen Affric would never have begun, the Glasgow School of Art rebuild would not have been considered worthwhile and we would not be able to visit Stenness or the Blackhouses on Lewis. As we have discussed above, we have lost lots of what used to exist in our seas, and much of what we’ve lost is worth getting back – who doesn’t want healthy cod stocks on the west coast or to see the return of the winter herrin’ run? Recovery requires us to change our whole approach to thinking about environmental baselines. The best and brightest minds in Scotland are thinking much bigger and more ambitiously already; a study by Heriot Watt University and the Marine Alliance for Science and Technology Scotland (MASTS) involving a range of expert authors, has boldly assessed the opportunity to recover our native oyster beds.
Historic distribution of Horse Mussel records, from NBN, versus those being used by SNH and Scottish Government
Finally, we are also completely overlooking the unknowns. Until recreational divers reported the damage in Loch Carron and propelled the remote corner of our seas to national prominence, the flame shell bed there was not thought to be significant. Following the press coverage, Scottish Government undertook a survey and realised it was actually the largest flame shell bed in the world. If the world’s largest flame shell bed can go unnoticed, imagine what else is down there. We are undertaking habitat modelling work to identify the places which are being overlooked and this approach is highlighting several areas that are currently considered unimportant by the Government.
Early results of Open Seas Habitat Modelling work, modelled only for the West Coast, compared to Scottish Government locations
We are therefore calling on Government to do two things,
- Consider more appropriate options in its cost/benefit analysis, not just the few corners of our seas currently being considered. This should include a 3 nautical mile limit, but we would also like it to include a “sustainable six”, only sustainable fisheries permitted within the 6 miles around our coast.
- Use all the evidence available: a range of habitats and species are threatened and we must consider these; There is also a wealth of information about their historic distribution, it is vital we consider that too.
If you agree, then you can let the Scottish Government know by either emailing them directly here – email@example.com – or by filling out their online form here – https://consult.gov.scot/marine-scotland/priority-marine-features/
There is a rare opportunity here to really improve the health of our seas and the sustainability of our inshore fisheries. However, there is also a chance neither opportunity is grasped and the Scottish Government rubber stamps them in their currently damaged state. We’d prefer to see them improved! And we owe it to future generations to do so.
Cover image by Howard Wood (C)