Firth of Clyde cod spawning closure for 2024/25

Feedback updated 11 Jan 2024

Results updated 20 Mar 2024

There have been 47 responses to the consultation (46 via Citizen Space plus 1 via email which has been manually added into CS). We also received a further 2 submissions via email which did not follow the consultation question format but supporting the closure.

1 response was removed as it was a duplicate.

Question Number	Question	Total Responses
1	Do you agree with the Scottish Government’s view that it is appropriate to renew the seasonal closure in the Clyde, as in 2022 and 2023, to protect spawning cod, for 2024/25?	46
2	Please give reasons for your answer to question 1	43
3	Do you agree with the continued removal of previous exemptions?	47
4	If no, which exemptions should continue?	29
5	Please give reasons for your answer to question 4	36
6	Do you have any views on alternative or complementary measures that could be considered for the protection of cod spawning in the Firth of Clyde for 2024 and beyond?	46
7	If yes, please give details.	35

36 responses were received from individuals and 11 responses were received from organisations.

Responses from organisations are listed below:

• Galloway Static Gear Fishermen’s Association  
• WSFPO Ltd
• Fish Legal
• Blue Marine Foundation
• Scottish Fishermen’s Organisation
• Sustainable Inshore Fisheries Trust (SIFT)
• Clyde Porpoise CIC
• Scottish Creel Fishermen’s Federation
• Community of Arran Seabed Trust (COAST)
• Our Seas
• Clyde Fishermen’s Association

In addition a submission was received from Marine Concern and Nature Scot.

Question One and Two – Continuation of the closure

On the initial questions about continuation of the closure:

• 26 (55.32%) responses agreed with the continuation of the closure.
• 20 (42.55%) responses disagreed with the continuation of the closure.
• 1 did not answer.

There were a wide range of views both for and against the continuation of the closure. Whilst there was an overall slight majority in favour of the continuation of the closure, those organisations representing the fishing industry all disagreed with its continuation.

For those against the closure, concerns over lack of scientific evidence was a major theme along with the closure having had no positive impact on the cod stock to date. One response claimed that there are more spawning cod in other areas than in the closure area. Other responses focused on other issues causing impacts on cod, including seal predation, and other types of vessels operating in the Clyde (tankers, Navy, cruise ships). It was also flagged that the closure measures were not sufficient and the renewal could only be supported where there were further measures implemented to protect cod stocks. Concerns were also raised over the procedural approach to the closure, a hijacking of the closure by Environmental Non Government Organisations and an unsatisfying experience of co-management.   

Some key themes supporting the closure were that protected areas are critical, and giving cod chance to recover will benefit both the ecosystem and fishing. Several views focussed on preventing seabed disturbance. Numerous responses made reference to the impact of bottom contact gear and that these should be prevented and one comment suggested that the closure in its current form has not yet been in place long enough and should be extended. Some responses suggested that this is the minimum that should be done and that additional measures are needed.   

Question Three, Four and Five - Exemptions

On exemptions, 18 (38.30%) agree with having no exemptions in place, whilst 29 responses (61.70%) disagree and think there should be exemptions in place.

The table below shows the number of responses supporting exemptions for each gear type.

There were 2 responses which seemed contradictory in selecting exemptions but also commenting in a way that suggested they did not support exemptions.

Exemption	Total	Percentage
Creels	27	57.45%
Scallop Dredging	13	27.66%
Nephrops Trawling	15	31.91%
Other Exemption	12	25.53%
Not answered	18	38.30%

“Other Exemptions” that were suggested included “all fishing methods”, and “scallop diving”

For those that support having no exemptions the comments that were provided focused around avoiding disturbance, allowing the ecosystem time to recover, providing maximum protection, and lack of science in support of exemptions.

For those supporting reinstating the exemptions there were wide ranging comments.

As is clear from the table above there was most support for the reintroduction of an exemption for creeling given the lower impact of this method. Marine Directorate was criticised for its failure to differentiate between low impact and high impact fishing gears. One comment stated exemptions for trawling and dredging were ridiculous and should not be reinstated whilst it was suggested that creel and dive fisheries are not responsible for the collapse of the demersal fish populations in the Clyde or the reason that the Clyde ecosystem is unable to recover. Trawls and dredges were noted to inflict a much higher degree of disturbance than passive and lower impact fisheries on spawning. Although other comments also suggested that nephrops trawling has little impact on spawning cod as they are not catching fish. It was suggested that dredging should be restricted or banned. However, one industry comment suggested that to reintroduce some gears but not others would cause further tension between mobile and static gear fisheries.

Another clear theme was on lack of evidence to suggest the exemptions would have an impact on cod recovery, and particularly with regards to the impacts of creels, with one comment stating that exemptions should be allowed for those sectors where no Clyde-specific research exists to support such prohibitions. suggesting that fishing is not the problem. Other comments suggest that they do not think fishing is the problem. Whilst a number of comments supported the precautionary approach, they suggested that the restrictions have clear costs but no benefits and taking away economic benefits with zero evidence of an ecological/stock benefit isn't justified.

Some comments also related to the socio-economic impacts that not been properly considered within the Impact Assessment. One creeler highlights spatial conflict as an issue for relocation, noting that he tried to move his creels and lost 136 creels to trawlers.

Further comments relate to the process, claiming that the consultation process which took place in autumn 2021 was flawed. the closure has been hijacked by eNGOs or is being politically driven to align to the objectives of the Bute House Agreement.

Question Six – Alternative or Complementary Measures

A range of answers were given to this question including suggestions to control the seal population or start a hatchery. There was a focus on carrying out more science to gather improved evidence, particularly surveys specific to the Clyde region. There were also suggestions to carry out studies on temperature. Respondents also suggested more engagement is needed with the local fishing industry.

Some responses suggested wider restrictions and spatial management, including that all suitable spawning habitat should be protected or for a transition away from destructive fishing methods in inshore waters and several references to an inshore limit. One comment suggested returning the closed area to it’s original co-ordinates, whilst another suggested putting in place an effective management plan for the Clyde Sea Sill MPA.

Published responses

View submitted responses where consent has been given to publish the response.