Scottish Sea Fisheries National Discussion Paper

In paragraph one of the introduction it is said that " we need to look afresh at how we manage our fisheries to ensure the remain productive and sustainable for future generations". While the sentiment is laudable the assumption is incorrect. Scottish seas are not as productive as they have been or are capable of being and the fisheries in the main currently being carried out are not sustainable. So the consultation is starting off with an incorrect premise, it must first be accepted that |Scottish Seas are in a very poor state, they are unhealthy with key stock having collapsed or being on the point of collapse and immediate strong and targeted measures are required to get stocks back to where they have been in the past in order to manage fisheries in a sustainable way moving forward for future generations. Until it is accepted that the base line should not be where we are today but how rich the seas were historically we will continue to fish to the bottom and no management measures will bring our seas and fisheries back to where they used to be. The aim of conservation and management measures should be to return the seas to the healthy state the were once in, this would ensure the health of the seas for all future generations not just fishermen.

The Scottish Government must urgently introduce measure to protect and recover fish habitats, these are often inshore and particularly vulnerable to mobile bottom trawling and dredging. The precautionary principle should be applied to all damaging fishing activities including trawling, dredging and electro fishing unless they can prove that they do no damage to the seabed and the surrounding areas.
Trawling and dredging should be banned inshore, these are large offshore vessels and have caused untold damage to habitats that the small fish rely on inshore. The recovery within the Firth of Lorn Special Area of Conservation demonstrates how the seabed and fish stocks can recover inshore when these damaging activities are stopped.
Urgent action needs to be taken to recover lost stocks not to maintain the seabeds in their present damaged state.

The majority of plastic waste I see around the shores actually comes from fisheries activities including offshore and inshore fisheries and aquaculture. The public are unaware of much of the pollution which goes on in our seas from aquaculture and fishing but in this instance the plastic blights our beaches and much will also be within the water column.
It is essential that the Scottish Government keeps all the current EU protections after Brexit. Some are not being upheld at present but their existence gives some protection to our seas and the Environment Secretary has assured the public that the government will not roll back on our hard won EU protections"
The MPA network must be completed and afforded comprehensive protections and not just be "paperparks" such protections would include a ban on all damaging fishing activities within the MPAs. This would give the vital inshore habitats an opportunity to recover from their current poor state.

All groups interested and invested in the sea (which is the whole population of these islands) need to have a say in fisheries management. In England there is the Inshore Fisheries and Conservation authorities which allow more voices than just commercial interests to be heard.
Vessel tracking should be fitted to all vessels in the fishing fleet. This was a decision made by the Scottish parliament so should be implemented as soon as possible. There have been several instances of illegal fishing in SACs which have not been prosecuted as Marine Scotland have insufficient evidence to prosecute as the current tracking system is not fit for purpose or it is not fitted to all vessels.
The government must engage with the fishing industry but there are many more stakeholders in Scottish Seas, the seas are a public resource belonging to all and one industry cannot dominate decisions made about this common resource.
Tourism for example has been ignored as a hugely important stakeholder in the seas and a huge contributor to local economies in fragile communities quite possible now a higher contributor than the fishing industry. Marine tourism relies on the wildlife that is sustained by healthy seas. Where wildlife is abundant tourism is successful and brings sustainable jobs to these coastal communities.
Coastal communities are now finding a voice through the Coastal communities network and these voices are asking for our seas to be restored to what they once were, abundant and healthy. This is not a utopia but was a reality in Scottish Seas. Returning our seas to that state is a responsibility of all stakeholders and government.
While it is important to empower local interests this should not be limited to local fishing interest but to all stakeholders.

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Article 61 of UNCLOS states "such measures shall also be designed to maintain or restore" this is important as restoration is what is required not maintaining the current poor state of Scottish Seas.

Until the seas are restored there cannot be future sustainability.

The current system of quotas allows for the selling of quotas and this has led to huge quotas being held by very few large family businesses. This is unhealthy for bringing new fishermen into the industry.

Quota's could be leased to fishermen rather than allocated and there should be clear restrictions on selling on quota.

New entrant licenses could be made available and allocated without charge, there should be no monetary "sell on" value.

The Scottish Government and the fishing industry must acknowledge now that Scottish Seas are in a bad state. This is self evident from the many fewer fishing boats than there used to be and the decline in fishing communities because of this. The ongoing pretence that Scottish Seas are in a pristine state must cease. Only once this happens can all stakeholders come together to try to manage recovery. It is estimated that there is now only 5% of the fish that were in our seas 200 years ago and the rate of decline has accelerated as technology has advanced. If we genuinely want fishing to continue for future generations we must act hard and fast to bring out about recovery.
The seabed and ecosystem has been degraded by scallop dredging and trawling, conservation measures should be viewed as part of an inshore fish and shellfish stock recovery.
A new coastal limit should be set up (suggest 3nm from shore) within which any fishing activity must be sustainable and damaging fishing banned.
There must be robust legislation to improve compliance and enforcement within inshore fisheries. there have been too many instances of illegal fishing within MPAs which Marine Scotland have not felt able to prosecute.
More weight must be given to views, knowledge and requirements of other stakeholders in our seas including scientists, coastal communities, marine tourism and also those dependent on tourism in general. The fishing industry at times does not recognise that there are other interested and invested parties in the health of out seas, these out of date views must be broken down so that stakeholders can work together.

Scotland's sea fisheries have been subsidised by the public tax payer for many years. The contribtion to the rural economy is not as great as it used to be due to the decrease in the size of the fleet. Public Money should be used to encourage environmental measures management and monitoring to aid recovery of our seas

There should be incentives for new entrants to the industry through licencing arrangement along with subsidised training and education of fishing and the environment.

The industry should contribute to the costs associated with science, research and development, however these contributions should be to central fund as any scientific work must be completely independent from the industry.
there is also a lot of pollution at sea caused by fisheries including aquaculture, there should be a fund set up funded by fisheries and aquaculture to develop measures to remove this pollution from our waters.

To ensure long term sustainability the seas must first recover from the devastation that has happened through mismanaged fisheries especially over the last 50 years. Reading "Environmental history of Hebridean Seas" by Catrin Norris , University of York 2019 it becomes clear that the fishing industry in some cases unwittingly but also through mismanagement has devastated fish stocks and seriously damaged ecosystems. We are at a cliff edge where all stakeholders need to come together to recognise that we are in a bad state and action must be taken to ensure that ecosystems and fish stocks recover. this will not happen unless hard and sometimes painful decisions are taken and adhered to by compliance and enforcement.

Government must recognise that the seas are a common resource and must be managed for the benefit of all not just one small sector. For example marine tourism has grown and now contributes more to the economy of coastal communities than fisheries. However, coastal communities depend on all sectors but one must not be allowed to damage the other and for there to be healthy marine tourism the wildlife must be healthy and numerous. This cannot happen unless the ecosystem of the seas and fish stocks are also in a healthy state. we have seen recovery of the ecosystem within the Firth of Lorn SAC; closing areas to damaging fishing activities does bring recovery. This closure has seen an increase in marine wildlife tourism, scallop dredging and sustainable creel fishing.

The fishing industry are very sensitive to conservation measures being proposed, it is however ironic that these measures are the only ones that can bring about recovery and ultimately make their industry sustainable for future generations.