Wild Wrasse harvesting - proposed mandatory fishing measures: consultation analysis

General Comments and Observations

The consultation sought views about specific proposals to introduce mandatory control measures and the criteria which must be met to enable access to the wrasse fishery. However a number of respondents also offered a range of views about other concerns they have relating to the wrasse fishery more generally.

Further Research Concerns

Across all respondents 30% felt that further research was required in the wild wrasse fishery. This included the need to have a better understanding of the needs and complexities of wild wrasse populations with regard to spawning season, structure, behaviours, habitat, genetics etc. much of which was not within the scope of the consultation.

Salmon Farm specific concerns

Some respondents made reference to the Scottish finfish aquaculture’s Code of Good Practice stating that cleaner fish should be used no more than once. This document states within Chapter 5, under point 3.74 “Cleaner fish should not be released into the wild at the end of a production cycle, but should be humanely destroyed and disposed of, or may be reused in accordance with the provisions set out in this Code.” Some respondents were keen for salmon farms to reconsider how they look after wrasse, and use them appropriately given their nature and perceived high demand within the industry as cleaner fish.

There were a few respondents who asked whether there would be limits placed on the biomass of wrasse to be harvested and through this a limit to how many cleaner fish farming companies could purchase within a given cycle per farm or farm area.

Additional Control Measures

A small minority (8%) of respondents consisting of environmental groups and members of the public stated their desire for a wrasse total allowable catch (TAC) or quota to be set at the beginning of each season. Requesting that this restriction would take the population dynamics and stock health of wrasse into account and be adjusted accordingly. 5% of respondents, mainly comprising members of the public, called for a complete ban or moratorium on the wrasse fishery.

A few fishermen noted that it would be beneficial if it would be possible to record the number of fish caught on the FISH1 form, instead of weight as is at present. This was due to the perceived difficulties in converting the number of fish to weight, as the catch is alive and excess handling would put too much stress on the fish and thus lessen their overall quality.

Diversification opportunity

The desire for the wild wrasse fishery to be used as a diversification opportunity from other stocks, such as shellfish, was represented by 19% of respondents who mainly comprised salmon farm operators and fishermen.

Closed Areas

Concerns were raised by 20% of respondents, consisting mainly of environmental groups and members of the public, about allowing any fishing in MPAs/SACs designated for rocky reefs, with some strong views that this should not be allowed. Specific areas for this included Special Areas of Conservation (SACs) where rocky reefs are protected or qualifying features and in Nature Conservation Marine Protected Areas (MPAs) in which kelp and seaweed communities are designated Priority Marine Features (PMFs) which 14% of respondents agreed with. A further 6% of respondents had concerns which encompassed looking into specific areas for wrasse fishing to be allowed; creating no take zones or isolating where the nursery grounds are and designate these as closed areas.

Marine Scotland Policy Response

Further Research Concerns

Marine Scotland agrees that it is important to improve the evidence base and the implementation of the proposed mandatory control measures will help to achieve that, helping to inform future changes to the measures if these are required. Marine Scotland will set out in letters of derogation the reporting requirements that must be followed to participate in the fishery. These new requirements are likely to include for each species, details of specific numbers of fish caught, kept, returned and whether those returned to the sea were alive. Over time this new data will be enhanced by scientific observer activity and may include tracker and REM input, depending on the outcome of our Future Fisheries Management project.

Salmon Farm specific concerns

Marine Scotland acknowledges that practices at aquaculture sites as described above are subject to strict Food Safety standards and various codes of practice.  However some interesting points were made relating to existing practices and possible future directions. For example most farm operators may destroy wrasse at the end of a salmon cycle but some re-use the wrasse following strict health protocols. These issues are not strictly within the scope of this consultation but do have the potential to reduce the demand for fresh wrasse and we will therefore discuss with industry the options for re-using wrasse in due course.

Additional Control Measures

Marine Scotland agrees that setting some form of TAC would be a good way forward and it would bring the wrasse fishery into line with many of our other fisheries.  However, at the moment there is no stock assessment of wrasse populations around Scotland which makes setting a TAC extremely difficult. In the absence of detailed population data, we will continue to operate creel limits to control effort while working to improve the evidence base over time. 

The completion of FISH1 forms, showing the weight of catch, is a statutory requirement and as such we do not propose to alter that form. Marine Scotland will however require that fishermen provide details of the numbers of wrasse caught in addition to the statutory requirements. 

Diversification opportunity

Marine Scotland is aware that the wrasse fishery provides a diversification option from crab and lobster fisheries and that those currently involved in the fishery have been able to successfully use this opportunity. Marine Scotland will devise a system for considering new entrants to the fishery which will take into account the impact on the fishery, the requirements of the industry and the benefits of diversification.  

Closed Areas

We are aware that Naturescot has recently completed some research in this area.  The findings are not yet published but we will discuss this with them in due course seeking their advice about the effects of the wrasse fishery on controlled areas.