A commercial fishery for razor clams using electric current gear in Scottish waters

Here we seek views on the establishment of a commercial fishery, where this should be permitted and what management measures should be in place. In general, our view is that if a commercial fishery is established it should have these characteristics:

• The geographic scope of the fishery is limited, to ensure individual grounds are not overexploited.
• The number of vessels able to participate is capped, to ensure the razor clam population as a whole is not at risk of overexploitation, and vessels can be effectively regulated.
• Permission to participate is granted following an application process where applicants demonstrate how they meet required criteria, to ensure effective regulation.
• Permission to participate in the fishery is granted through a time limited authorisation, to allow adaptive management of fishing effort.
• In addition to general controls on fishing activity, the fishery is controlled via bespoke technical measures including the use of REM, to ensure razor clams are not at risk of overexploitation, and risk to protected species and habitats is adequately controlled.

Establishing a fishery

We consider that the scientific and socio-economic evidence supports the establishment of a commercial fishery utilising electric fishing gear, recognising that there are uncertainties that remain, as there are in all fisheries. As set out below, we propose that this fishery be authorised only for electric current gear, be geographically limited, as well as with a mechanism to review and control the number of eligible vessels actively fishing for razor clams. If following consideration of responses in this consultation, we determine that there should be a commercial fishery, we would periodically review the scale, as new data and information became available to guide our decision making.

Vessel controls and technical measures

Razor clams are a non-quota species, meaning there is no overall total allowable catch in Scottish waters. We manage fishing for non-quota species through the use of technical measures appropriate to the particular species. In this section we set out the controls we consider necessary for a commercial fishery. These are intended to manage where vessels can fish, the level of fishing effort, and other technical measures.

During the trial, participants have received a derogation to participate that restricts their activity to a set of areas within one of the trial zones. These have been useful, for example in comparing fished and unfished population structure, however if we were to move to a commercial fishery, there would no longer be a clear rationale for keeping fishing confined to these specific areas. In some cases, concerns have been raised that the duration of the trial has concentrated fishing of the same grounds, creating a potential risk of overexploitation. In a commercial setting, fishers would seek to rotate grounds more freely than they currently can within the constraints of the trial. In concluding the trial, we would stop using the geographical limits of the trial areas to manage any commercial fishery, while maintaining spatial controls through the classification of Shellfish Harvesting Areas.

We also seek your view on the technical measures in place during the trial, and whether these would be appropriate for a commercial fishery, or if you consider different levels or different measures to be necessary. The trial currently operates with the following technical measures in place:

• A days at sea limit of 110 days within the trial year (February-January)
• A daily catch limit of 450kg
• A minimum conservation reference size of 100mm
• A seasonal closure of one month in the spring
• Area-specific closures to reduce risk of harm to protected species and priority marine features
• Fishing gear specifications, set by the Marine Directorate

Our view is the days at sea limit could be changed to run according to calendar years (January to December), the 450kg daily catch limit appears to be sustainable and could continue in a commercial fishery, the minimum conservation reference size could be raised to improve protections for Ensis siliqua while still allowing economically viable fishing to happen, the seasonal closure could continue as practised in the trial, and area-specific closed fishing areas in line with conservation and management advice in relation to the MPA network as the appropriate way to integrate conservation objectives into the management of this fishery. This would mean a commercial fishery would be subject to fisheries assessments including Marine Protected Area assessments, Habitats Regulations Appraisals and Priority Marine Feature assessments where necessary. A commercial fishery would also be subject to any further management measures in relation to fishing activity in the inshore zone more generally.