Bring Back the Fish - Bring Back Scotland's #InshoreLimit
We call on the First Minister and Scottish Government to stop the chronic destruction of our seabed by urgently reinstating a coastal limit on bottom-trawl and dredge fishing...
What is the problem?
Scottish coastal seas have been driven into decline due to decades of mismanagement. Destructive bottom towed fishing gear has had free access to over 95% of our inshore waters since the 1980’s, to the detriment of habitats, biodiversity, fisheries, and communities. The Covid-19 pandemic has put a spotlight on how few of our inshore fisheries could feed our nation if times get tough.
How have we got here? In 1889 a law was passed to protect fish stocks and small boats by banning trawling (except by sail) from within three nautical miles of the shore. Catastrophically the law was removed in 1984 against a backdrop of the industrialization of fishing technology, breaches of the Three Mile Limit, and declining offshore fish stocks. Access to the inshore appeared to improve catches for a short while, but inevitably led to the rapid decline of fish stocks as seabed habitats - vital nurseries and shelter for many species - were destroyed. We are now at the point where many regional fisheries, including herring, cod and haddock, have disappeared - and the majority of inshore fishermen are worryingly reliant on shellfish such as scallops and langoustines to make a living. Scientists have voiced serious concern about this situation, which leaves fishermen vulnerable to market vagaries, and changes in stock health and composition. We are now, literally, scraping the bottom. 'In a very short time generations of fishermen have fished down through the species. My grandfather fished for white fish, my father fished for herring and now I fish for langoustines, which are bottom feeders - beautiful eating - but the end of the food chain' Ali Macleod Creel Fisherman - Applecross 2017. What is happening now? Creeling and diving are low impact, high value fisheries, trawling and dredging are high impact, low value fisheries yet scallop dredgers and large bottom-trawling vessels are allowed to dominate our inshore waters. Trawling and dredging have high levels of bycatch and cause huge environmental damage, by scraping or aggressively sweeping the seafloor. This intensive fishing sector has a strong voice within government and management decisions are made in their favour. Even though the Scottish Government’s own policy objectives in our National Marine Plan and Marine (Scotland) Act 2010 specify that they will favour sustainable methods. The remaining shellfish stocks which most fishermen currently depend on are in poor shape; despite dredging effort going up by 53% between 2008 and 2016, scallop landings have continued to decline. In the Solway Firth queen scallops have fallen by 61%, king scallops by 39% and Nephrops by 84% since 2014. This is not sustainable by anyone's measure. This figure from Ecological Meltdown in the Firth of Clyde, Scotland: Two Centuries of Change in a Coastal Marine Ecosystem shows plummeting cod landings in the Firth of Clyde. Similar graphs for hake, flounder, whiting, plaice and herring can be seen here. Why does it matter? Seabed habitats are vital as fish spawning grounds and nurseries, and they are significant carbon stores rival to any on land. The top 10cm of Scotland’s seabed holds more carbon than all the peatlands, soils and trees Scotland combined. These habitats protect our coasts from storm surges and wave action, and can ameliorate the rising ocean acidification that is being caused by global warming. These carbon stores have no chance to recover as things stand. Coastal marine biodiversity is of significant socioeconomic importance. As well as the provision of food, the marine environment contributes to human well-being. The leisure and recreation industries directly reliant on coastal marine biodiversity contribute over £11 billion to the wider UK economy each year and our contact with marine life has benefited our culture and economy for thousands of years (Beaumont et al 2008, Smale et al 2013). The success of the Scottish Government’s Marine Tourism strategy ‘Giant Strides’(2020) is reliant on the restoration and increase of the natural capital of our seas, which will contribute £0.5billion to the Scottish economy by 2025. (Giant Strides, 2020). Current protection is inadequate and underfunded it covers only scattered remnants of the rich seabed we once had, this piecemeal approach does not allow for real recovery. Marine Protected Areas (MPA’s) supposedly cover 20% of coastal seas, but in reality under 5% are off-limits to scallop dredging and bottom-trawling. Map above shows restrictions Green no dredge/trawl. Blue no dredge. Light green no trawl. These few ‘protected’ areas have proven impossible to police and are illegally dredged with little or no consequences for the perpetrators. Who is responsible for this mismanagement? The blame lies primarily with Scottish Ministers. The Scottish Government has control over the management of our inshore area within 12 nautical miles, and has the power to stop the damage done by scallop dredging and bottom-trawling. This Government is failing to protect our natural heritage by allowing our seabed to be routinely destroyed. Unless ministers take action now, they will be turning their back on not only our marine environment, but the future of our fisheries, fragile rural economies and Scotland as a whole. Marine Scotland, as the executive agency in charge of our fisheries, are obliged to follow policies set out in our National Marine Plan (NMP) and the Marine (Scotland) Act 2010 which require Marine Scotland to place fisheries on a sustainable footing. The Scottish Government’s National Performance Framework commits them to: “by 2020 [to] effectively regulate harvesting and end over-fishing…and unregulated fishing and destructive fishing practices and implement science-based plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce sustainable yield as determined by their biological characteristics”. The same policies require the promotion of local, small-scale and sustainable fisheries, robust measures to protect vulnerable stocks, and “mechanisms for managing conflicts between fishermen” (Policy FISHERIES 1), so as to manage fisheries in the long-term public interest. Marine planners must also identify marine carbon sinks and seek to avoid the ‘Colocaton of damaging activity’ None of these obligations are being met by our Government. We all need to ask Why? The longer Ministers stall, the more habitats we lose and the harder it gets for them and the species that rely on them to recover. We need urgent action to stop further destruction and improve the resilience of our seas. Our marine environment and fish stocks are not managed democratically or with any public accountability. To restore public confidence, Ministers must be guided by science and policy, and not the demands of one commercial interest group at great cost to our environment and communities. The remits and mandates of our politicians are repeatedly broken as environmental targets are missed; The Scottish Government has failed to meet 11 of their own 15 indicators used to measure Good Environmental Status, allowing our marine environment to decline. The unsustainable practice of bottom towed fishing methods has continued, regardless of the social, environmental, and economic impact on coastal communities. Our seas are a public asset and potential resource; they must be managed for the many and not the few, in a way that restores lost marine life and degraded fish stocks, and recovers the marine environment so that it can provide for us into the future. What can be done to preserve what’s left and allow recovery? If we protect the seabed it will recover, the degradation can still be reversed. This European Environment Agency report, specifies that ''Solutions for halting the loss of marine biodiversity and starting to restore ecosystem resilience, while allowing for the sustainable use of Europe's seas, are obvious and available. They just need to be implemented'.'. Report after report has presented evidence that if we take action, environmental and economic benefits will flow. We call on First Minister Nicola Sturgeon and the Scottish Government to implement their own policies and stop the chronic destruction of our seabed by urgently reinstating a coastal limit on bottom-trawl and dredge fishing. Case study 1 The Scottish Creel Fishermen’s Federation (SCFF) Judicially Reviews the Scottish Government’s decision to refuse the Inner Sound of Skye fisheries Pilot. Read the full briefing. 74% of Scotland’s inshore fleet are creel fishermen. Creeling employs more people, has a lower carbon footprint, and has less by-catch and less collateral damage to the seabed than trawling. Despite this, creeling as a sector has long been overlooked and underrepresented at a policy-making level. The North West Responsible Fishermen’s Association (NWRFA) - a regional creeling organisation and a member of the SCFF - put forward a proposal for a Pilot in the Inner Sound of Skye designed to create separate zones for trawlers and creelers in order to study the respective economic and environmental performances of these two forms of fishing for Nephrops, as well as trialling local management. This would provide important and potentially unique evidence with national implications for the management of our Nephrops fishery. The proposal was rejected by Marine Scotland on 26 February 2020 against the recommendations of their own economics unit and Scottish Natural Heritage. The reason given for the rejection was given in the Outcome Report: “The responses to the consultation make it clear that there is continuing opposition to the proposers inshore fisheries pilot in the Inner Sound of Skye. The majority of the proposed measures set out in the consultation were strongly opposed by respondents”. The SCFF is therefore taking legal action and requesting a judicial review of the decision, where Marine Scotland refused the application based on the results of a consultation rather than by applying Scottish Government’s own criteria. Negative consultation responses were dominated by members of the trawl industry, because this sector of the fleet objects to restrictions on their presumed ‘freedom to trawl’. If Marine Scotland give the commercial trawl lobby an effective right to veto any changes to inshore fisheries management it will be impossible for our inshore fisheries to recover. The SCFF has a wider concern that this case follows a pattern that suggests that the mobile sector wields too much influence with Marine Scotland and thus that the management of our fisheries appears more aligned with the interests of the mobile sector than with the public interest or fisheries policy. Case study 2: Loch Carron - Legal damage to flame shell reef. In 2017 a scallop dredger tore through a flame shell reef in Loch Carron, this was not illegal as the reef was not protected. Damage to the seabed is routine, but events like this often go unreported as there are few witnesses to the damage done to marine life out of sight, underwater. In this case the destruction of the reef was recorded by a group of divers and given exposure by the media, prompting a public outcry. This resulted in Marine Scotland designating an emergency MPA in Loch Carron to stop further damage, and by initiating a much broader review of the impact of fishing (specifically bottom-trawling and dredging) on other areas of Scotland’s seabed, stating that they needed to; “Identify where else fisheries management is needed to ensure there is no significant impact on Priority Marine Features”. Yet damage is still taking place, and three years on Scottish ministers continue to kick the PMF Review into the long grass. Case study 3: Persistent damage to herring spawning grounds in Gairloch When the 3 mile limit was removed in 1984 Loch Gairloch was considered so important as a herring spawning ground that it retained legal protection. The loch contains maerl beds that provide the perfect environment for herring to lay their eggs, but these maerl beds are fragile and easily damaged by dredging. Bottom-trawl and scallop dredge vessels are therefore not allowed beyond a line that runs across the mouth of the loch. In March 2018, divers found an area of herring spawning ground beyond the protection of Loch Gairloch. The find was reported and surveys have since demonstrated the presence of maerl. However, two years later there is still no protection for this area. Scallop dredger skippers have proposed a temporary and voluntary closure for just three months of a year - but this means that the maerl beds will be at risk of dredging for the rest of the year. The International Council for the Exploration of the Sea (ICES) advice is clear: “Activities that have a negative impact on the spawning habitat of herring should not occur, unless the effects of these activities have been assessed and shown not to be detrimental (ICES, 2003, 2015b).” Why are we still allowing destruction of maerl beds in the 21st century? If you want to hold the Scottish Government to account and insist on action to resolve the issues described please get involved in the ourseas campaign to ‘Bring Back the Fish - Bring Back Scotland's #InshoreLimit’
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