Fisheries management measures within Scottish Offshore Marine Protected Areas (MPAs): consultation analysis

Draft Fisheries Assessments for each site

Respondents were also invited to comment on the Draft Fisheries Assessments, including the methodology, which have been undertaken for each site.

While respondents were asked specifically on the Draft Fisheries Assessments in this question, some chose to express their views on the consultation more generally.

Positive commentary on the approach taken to the Draft Fisheries Assessments

There was some positive commentary on the approach taken to conduct the fisheries assessments, including how the evidence was used, how it was collected and the definitions and methods used. Indeed, one respondent remarked that the document had been “well researched” and contained “useful background and informative explanations of the terms used, and the processes followed” [Individual]. Another said they appreciated the detailed methodology used, particularly the focus on minimising habitat disruption.

Some highlighted the importance of site specific fisheries assessments in gaining an understanding of the real impact of the individual components of the fishing industry on the marine environment, including habitat degradation due to demersal fishing gear:

“Many of these activities will likely be degrading the impact of the individual MPAs, in effect negating and possibly reversing the planned outcome in the designation of each MPA. It seems that these effects have been previously ignored in favour of continued fishing activity and at the expense of the designation of the MPA for marine wildlife” – [Organisation].

There was recognition that impacts will vary significantly depending on the constituents and make up of the habitats present, which may vary from region to region. Respondents also noted that these impacts will vary significantly between different trawl gear specifications, such as single or twin rig, rockhopper gear or grass rope gear.

However, respondents largely shared additional thoughts on what else the Draft Fisheries Assessments could have considered, as well as potential flaws in the methodology and/or data used.

Expressions of support for zonal measures (Option 1)

As discussed in response to later questions on the individual sites, some respondents believed that zonal measures (Option 1) would be better than full site measures (Option 2). They wrote that the draft Fisheries Assessments judge Options 1 and 2 to be in support the environmental outcomes of the National Performance Framework by restricting activities to a level that support the achievement of the various sites’ conservation objectives.

Some felt that Option 1 would allow the continuation of fishing activities which have been identified as not requiring management to continue in the sites, as they would not compromise achieving the sites’ conservation goals. Others raised that the Option 1 was reached through a lengthy process of finding consensus amongst stakeholders, including eNGOs, and felt this should be respected.

Expressions of support for full site measures (Option 2)

On the other hand, several respondents expressed their support for Option 2 where they considered Option 1 as insufficient to meet conservation objectives in several key locations, providing examples:

“The assessment of impacts of fishing pressures at current activity levels on offshore deep-sea muds and Ocean quahog aggregations features of East of Gannet and Montrose Fields NCMPA has indicated that demersal trawling activities would or might hinder the achievement of the conservation objectives of the site through impacts to offshore deep-sea muds” - [Organisation].

Concerns around the negative effects of vessel displacement

Some expressed concerns around the negative effects that the vessel displacement could have on the incomes of fishing businesses, and in potentially further compounding the ‘spatial squeeze’ caused by renewables developments and restricted quotas:

“Although overall environmental impacts from displacement may not be significant. In individual cases and for specific species the need for the businesses being displaced to make up their lost incomes elsewhere will result in additional effort and further compound spatial squeeze. This squeezing has to be considered in light of all the other factors also impacting the fleet. Factors such as renewables developments also squeezing the fleet and restricted quota availability may compound to increase the overall footprint of the demersal gear sector and or increase the intensity of effort within the existing footprint. This will add to benthic impacts which are already a substantial factor in our failing to achieve good environmental status” – [Organisation].

Concerns around the required fishing and financial contributions

A couple of respondents were pessimistic that the aims and measures outlined in the consultation – including the Draft Fisheries Assessments – would come to fruition in reality, and were concerned that the required fishing and financial contributions were underestimated:

“Having taken part in several surveys over the years we have always found that what the survey says bears little resemblance to reality, always vastly underestimates the amount of fishing and financial contribution due to proposed sites” – [Organisation].

Calls to ban bottom trawling in all MPAs

A few respondents repeated calls to prohibit bottom trawling in all MPAs as a minimum, in order to make them completely secure and protect them from damage. They therefore saw full site measures as the easiest way to achieve such a ban and monitor the relevant restrictions:

“'Full site fisheries management measures' in place that banned bottom trawling for all the MPAs would be the best way forward; much simpler to maintain and enforce” [Individual].

Calls for the further incorporation of the welfare impact of different fishing methods

One respondent suggested that the Draft Fisheries Assessments should further incorporate the welfare impact of different fishing methods on aquatic species, providing specific examples:

“This includes evaluating how certain practices, like the use of non-selective nets, affect not only target species but also bycatch, which can lead to high levels of stress and mortality among non-targeted aquatic animals. We advocate for greater emphasis on monitoring welfare conditions during fishing activities through technologies like Remote Electronic Monitoring (REM), ensuring that management measures minimise animal suffering” – [Organisation].

Discussion around the stakeholder engagement process

A few respondents expressed their disappointment that, “following the EU’s exit, [they] were no longer invited to the discussions with the previous parties in 2022, even though they are directly impacted” [Organisation]. Relatedly, others commented on a lengthy negotiated process on behalf of demersal mobile gear over many years to develop the protective advice in Option 1; they also wrote that “static gears were never included in the original proposals and therefore no talks ever took place until very late in the process” [Organisation].

Comments on the relevance of the data used

A couple of respondents suggested that the assessments be replicated using more recent data, particularly given that Scottish Government Equality Impact Assessments (EIAs) and other applications are required to use data of less than 5 years old. They pointed to the limitations of the data used – which has potential to grossly over or underestimate the level of fishing activity – and felt that more recent data is available and should have been drawn on. They also highlighted potential data gaps, where there is no reference to ground truthing the data through consultation or through comparison with other datasets.

An organisational respondent felt that the Option 2 presented in the Draft Fisheries Assessment which has been developed is “non-evidence based at times”, particularly for Firth of Forth Banks MPA which they have particular interest in.

Summary

In summary, feedback on the Draft Fisheries Assessments was mixed, with both positive and critical commentary. Supporters praised the methodology, highlighting the thorough research and the detailed approach to assessing the impacts of fishing activities on marine environments. Many emphasised the importance of site-specific assessments to understand the effects of various fishing techniques, particularly demersal gear.

However, some respondents felt that the assessments lacked sufficient consideration of the broader impacts of vessel displacement, the financial contributions required, and the welfare effects of fishing methods on marine species. Additionally, there was a division between those who supported Option 1 (zonal measures) for its balance between conservation and fishing activity, and those who advocated for Option 2 (full site measures), arguing that full protection was necessary to meet conservation goals. Concerns were also raised about the timeliness of the data used in the assessments and the need for more recent and comprehensive information to ensure accurate conclusions.