New controls in queen scallop fishery: summary of consultation responses

Analysis Of Consultation Responses, Part 1: Management Measures Advocated By The Working Group

This section summarises responses to the first part of the consultation, which sought views on management measures that the queen scallop working group had agreed should be introduced into the fishery as soon as possible.

Proposal 1: Increasing the Minimum Conservation Reference Size ( MCRS) of Queen Scallops

Views were sought on whether the MCRS of queen scallops should be increased, in order to give queen scallops an additional opportunity to grow and reproduce before being landed. An EU-set minimum size of 40 mm currently applies in UK waters, while a 55 mm size is in force in Isle of Man territorial waters.

1. Do you support increasing the MCRS of queen scallops in ICES divisions VIa and VIIa?
Option	# of responses	% of responses
a) Yes	32	94%
b) No	2	6%

Nearly all respondents supported this proposal, with only two not being in favour. Most respondents cited the stock conservation benefits as being their main reason for supporting increasing the MCRS:

"Increasing the MLS would enable stock recovery and It would also help minimise impact on grounds. By having more larger animals present there would also be an overall increase in fecundity of the population." [Individual respondent]

Only one of the respondents opposed to the proposal chose to comment, expressing concern that increasing the MCRS would have a financial impact on their business:

"It would be very costly to my operation unless grant aid was available." [Individual respondent]

2. If Yes, what size should the MCRS be increased to?
Option	# of responses	% of responses
a) 50 mm	13	43%
b) 55 mm	9	30%
c) 60 mm	8	27%

Increasing the MCRS to 50 mm was the most popular option chosen by supportive respondents, which included POs, processors and fishing associations. Several commented that vessels were already landing at this size, while others said they were open to further size increases in the future:

"Some boats have already applied a 50 mm limit and the quality is far better for processing and worth more to the fishermen." [Isle of Man Seafood Products Ltd]

"If stock recovers sufficiently the minimum size could be increased again to 55 mm." [AM Seafoods Ltd]

A majority of supportive respondents favoured increasing the MCRS to a size greater than 50 mm, sharing the opinion that a larger size would be more beneficial for stock conservation. However, views were split between 55 mm (chosen by a number of individual respondents) or 60 mm (preferred by conservation groups):

"I believe the smaller queenies should be left to grow and spawn a few times, as well as increase in yield when eventually caught and processed." [Individual respondent - for 55 mm increase]

"In terms of protecting the species, we would look to having as a large an MCRS as is practicably feasible." [National Trust for Scotland - for 60 mm increase]

3. What impacts would increasing the MCRS of queen scallops have on your business? What would the likely costs be?

Views were also sought on the potential costs for businesses as a result of increasing the MCRS. Most respondents commented that, while it may cause a short term reduction in catches, it would have a positive impact on the stock in the longer term and increase the consistency and quality of product landed:

"Initially there may be some smaller catches, but the long-term effect on the fishery should be positive." [Scottish Fishermen's Federation]

"It would improve the fishery and make it more sustainable and far better for the sales of the goods with a consistent and higher MCRS." [Isle of Man Seafood Products Ltd]

"Most queen scallops are of more than 50 mm, but there may be economic incentive for fishermen to keep them when below 50 mm, despite the fact that the processors don't want them and the price is lower. At and above 50 mm the processors will get the product they want and a better price should be reflected." [South Western Fish Producer Organisation Ltd]

A few respondents highlighted particular negative impacts for their business, including a potential decrease in profitability from a reduction in catches, and the expense of re-gearing to target larger queen scallops:

"First few years catch decrease and less profit if any out of job." [Individual respondent]

"The increase in size would require new gear for fishing as ring size would need to increase and new shakers and riddles aboard vessel." [Individual respondent]

Proposal 2: Introduction of a Closed Season for Queen Scallops

Views were sought on whether there should be a seasonal closure for fishing for queen scallops, in order to protect them during their main spawning season. Queen scallops can currently be fished throughout the year in UK waters, while a statutory seasonal closure from 1 April to 31 May is in force in Isle of Man territorial waters.

4. Do you support an annual spawning closure for queen scallops in ICES divisions VIa and VIIa?
Option	# of responses	% of responses
a) Yes	33	100%
b) No	0	0%

Respondents were unanimous in their support for this proposal. Those who commented highlighted the benefits of a closure from a conservation perspective (protecting stocks at key spawning times) and an economic perspective (low yields reducing earnings):

"Macduff Shellfish believe an annual spawning closure would provide real benefits to this important fishery, not only would it allow the queen scallops to spawn but also allow the seabed time to recover." [Macduff Shellfish]

"The poorest meat yields from the queenie are obviously during spawning times, so rather than fishing them harder, better to let them recover and continue to provide spawn." [Scottish Fishermen's Federation]

5. If Yes, which of the following closure options is preferred?
Option	# of responses	% of responses
a) One annual closure between 1st April and 31st May (i.e. same as statutory Isle of Man Closure)	7	21%
b) One annual closure between 1st April and 30th June	13	39%
c) One annual flexible closure between March and June, with specific timing determined by the fisheries management agencies, in consultation with industry representatives, and with reference to biological and commercial considerations.	13	39%

Respondents were split on how a seasonal closure should be implemented, with none of the options being favoured by a particular sector. The views of respondents in support of each option can be summarised as follows:

• Option A: would match the Isle of Man, and have a smaller financial impact.

"It makes sense to make all the areas have the same closed season and a 2 month closure would have less of an impact on the economics than a longer one." [Isle of Man Seafood Products Ltd]

• Option B: would offer more protection by covering the entire spawning season.

"Queen scallops typically spawn in spring between March to May. By having the longest close season of May to June you are ensuring the maximum possible chance for the scallops to complete spawning." [Individual respondent]

• Option C: would be more responsive to annual variations in spawning times.

"As queen scallop recruitment can be erratic and subject to fluctuations, closed seasons needs to be adaptive and based on the state of stock." [Individual respondent]

6. Should fishery closures be implemented on a voluntary or compulsory basis (statute or licence condition)?
Option	# of responses	% of responses
a) Voluntary	4	12%
b) Compulsory	29	88%

A majority of respondents also felt that any closures should be implemented on a compulsory basis. The shared view was that people would not comply with a voluntary closure over the long term, and that a compulsory approach would be easier to enforce:

"Any closure is likely to be most effective if it is respected by all relevant vessels, and the best way to enforce this is through a compulsory basis (for example as a licence condition)." [ClientEarth]

"It is an unfortunate reality that voluntary closures (or any other voluntary measures) will not work in the long-term." [Individual respondent]

Even among those who preferred a voluntary approach one commented that, if fishermen were not complying, closures would need to be made compulsory:

"If this doesn't work out then compulsory is the only option. With a strict enforcement and loss of fishing entitlement if not observed." [Individual respondent]

Proposal 3: Entry Restrictions for the Queen Scallop Fishery

Views were sought on whether the number of vessels that can take part in the queen scallop fishery should be limited (i.e. restricting entry), and whether greater data collection should be a condition of receiving a queen scallop entitlement. The fishery is currently 'open access' in UK waters, meaning that it is open to any vessel with a commercial fishing licence.

7. Do you support the introduction of entry restrictions to the UK queen scallop fishery?
Option	# of responses	% of responses
a) Yes	29	85%
b) No	5	15%

A majority of respondents supported this proposal, with several commenting that restricting entry was necessary for other management measures to be effective. Others remarked that continuing open access arrangements, along with modern processing capacity, would have a further impact on stocks if the number of active vessels increased:

"The number of vessels needs to be controlled so that management plans can be put in place. Without limitation of numbers any management plans can be affected at any time and there would therefore need to be more micro management and administrations do not have the resources to continually alter plans." [Manx Fish Producers Organisation]

"Any more expansion of the fleet can only have a detrimental effect on the queen scallop stock. In the past when queen scallops were all cut out by hand there was only a limited demand but now that processing machinery has been introduced the stock could be severely damaged as result of increased effort." [AM Seafoods Ltd]

Those opposed to entry restrictions gave different reasons for doing so. These included that they could prevent new entrants from joining the fishery, or include areas that are not part of the current fishery:

"I do not welcome Entry restrictions. Main reason as we need to keep an opening for youth coming along and new entrants into fishery." [Individual respondent]

"I can quite clearly see the need to restrict access in a fishery that has virtually no management but I cannot see the reason to bring the same rules into sea areas that are not heavily exploited but could be exploited in the future." [Individual respondent]

8. Do you support the introduction of additional data collection as a condition of receiving a queen scallop entitlement?
Option	# of responses	% of responses
a) Yes	30	94%
b) No	2	6%

Nearly all respondents supported this proposal, with only two not being in favour. The shared view was that accurate data was essential to managing the fishery effectively, and that collecting additional data could only improve knowledge of the stock. Several felt it was reasonable for fishermen to contribute data, with it being noted that a similar practice was already in effect in Isle of Man waters:

"There needs to be more data collection and the boats are out there in all weathers and so are the obvious way to collect data." [Isle of Man Seafood Products Ltd]

"It is a relatively simple thing to do and is standard in Manx waters that when requested to do so data is collected by the fishermen. Also the best way to get sufficient data in a short time period." [Individual respondent]

The respondents opposed to the proposal did not consent to having their comments published.

Entry Restriction Options - Qualifying Period

Views were then sought on the management options available for implementing entry restrictions. The first of these was the preferred reference period for determining eligibility through a track record of fishing activity.

9. What is the preferred 3-year reference period for determining eligibility for the fishery in future?
Option	# of responses	% of responses
a) 2013-2015 - would tend to maintain current vessel numbers	10	43%
b) 2012-2014 - would tend to maintain current vessel numbers	0	0%
c) 2011-2013 - would tend to maintain current vessel numbers	0	0%
d) 2010-2012 - would tend to reduce current vessel numbers	13	57%

Respondents were split between the 2013-15 and 2010-12 reference periods, with a small majority favouring the latter option. These were mostly individual respondents, who felt that a reduction in vessel numbers was necessary for stock conservation:

"Catch rates are falling the fleet is too large for the resource." [Individual respondent]

"There were less vessels and less pressure on the stocks at this time." [Individual respondent]

The 2013-15 option was preferred by POs, processors and fishing associations, as well as some individuals. Their main view was that this option would avoid impacting on vessels that had been active in the fishery in recent years:

"This would maintain current levels but would avoid most of the pipeline cases and also reflects current practices. Effort control can be brought in through other means. Also this would enable those that have invested recently to be able to fish." [Isle of Man Seafood Products Ltd]

Options for Entry Requirements

Specific activity criteria were also identified that could be used, in combination with the three-year reference period, to determine eligibility for entry. Views were sought on a preferred reference point (i.e. threshold) among the following options for differentiating between eligible and non-eligible fishing vessels:

• Option 1: Reported landings quantity, i.e. vessels would need to meet a certain tonnage of queen scallops landed.
• Option 2: Landings frequency, i.e. vessels would need to meet a certain number of recorded landings of queen scallops.
• Option 3: The number of days at sea of targeted fishing activity, i.e. vessels would need to meet a certain number of days spent fishing for queen scallops.

None of the above options had a clear preference over others; while nine respondents (39%) had selected just one option, 11 respondents (47%) selected from two or even all three options. There was however a common thread in respondents' comments for why they chose a particular reference point:

• Those selecting a broader reference point did so as it would allow most vessels who had fished for queen scallops to retain access to the fishery.

"Give vessels with small track record a chance to join fishery under conditions." [Individual respondent - for Option 3(a) (Q12)]

• Those selecting a narrower reference point instead preferred that only vessels that could be proven to be reliant on the fishery should qualify for access.

"This would mean that only serious queenie fishermen were included and would cut the latent effort." [Individual respondent - for Option 2(e), (Q11)]

Only a few commented on possible negative aspects of the three options, highlighting how each could be biased toward or against a particular size class of vessel:

"Basing this on weight might exclude smaller artisanal fishers from the market and favour larger vessels." [Individual respondent - against Option 1 (Q10)]

"Option 2 favours smaller vessels who have to land more often." [Individual respondent - against Option 2 (Q11)]

"Option 3 favours larger vessels who can operate under a wider range of sea conditions." [Individual respondent - against Option 3 (Q12)]

The number of responses received for each option and preferred reference point were as follows:

10. What is the preferred reference point for 'reported landings quantity' during the 3-year reference period?
Option	# of responses	% of responses
a) Up to one tonne landed during the 3 years would qualify.	2	10%
b) Minimum of one tonne landed during the 3 years would qualify.	2	10%
c) Minimum of 5 tonnes landed during the 3 years would qualify.	3	14%
d) Minimum of 10 tonnes landed during the 3 years would qualify.	4	19%
e) NONE - prefer use of Option 2 or 3.	10	48%

 

11. What is the preferred reference point for 'landing frequency' during the 3-year reference period?
Option	# of responses	% of responses
a) Any recorded landing during the 3 years would qualify.	4	20%
b) Between 10 and 20 landings over the 3-year period would qualify.	0	0%
c) Between 20 and 30 landings over the 3-year period would qualify.	5	25%
d) Between 30 and 50 landings over the 3-year period would qualify.	0	0%
e) More than 50 landings over the 3-year period required to qualify.	6	30%
f) NONE - prefer use of Option 1 or 3.	5	25%

 

12. What is the preferred reference point for 'number of days at sea' of targeted fishing activity during the 3-year reference?
Option	# of responses	% of responses
a) Any recorded days at sea during the 3 years would qualify.	4	20%
b) Between 10 and 20 days at sea during the 3 years would qualify.	0	0%
c) Between 20 and 30 days at sea during the 3 years would qualify.	5	25%
d) Between 30 and 50 days at sea during the 3 years would qualify.	0	0%
e) More than 50 days at sea during the 3 years would qualify.	6	30%
f) NONE - prefer use of Option 1 or 2.	5	25%