Landings of wrasse by Scottish vessels: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004.


Information requested

1. In a written answer, the Cabinet Secretary set out certain information about landings of wrasse by Scottish vessels (S6W-03060 in 2021). Please provide available updated data in a similar format for each year it is available, but subject to an alteration giving disaggregation of ‘All other districts’ figures. The latter category appears particularly important for a proper understanding of this fishery, given that average weights per landing appear significantly higher than in the three named districts.

2. Please add to above the numbers of fish caught. (Written Answer S6W-03059 indicates that this data is available).

3. In the Answer referred to in 1. above, it is stated “Information is recorded on live fish movements to aquaculture facilities and this will include information on source and number but not individual wrasse species.” Please provide all such recorded data on wrasse and on lumpsuckers.

Following a request for clarification, it was agreed that data from 2021 to the date of your request (17 August 2024) for parts 1 and 2 of request, and from 1 January 2023 to the date of your request for part 3 would be sufficient.

You also confirmed that with respect to part 3 of the request the details required included the name of receiving facility; date; species; number, and source, and you commented that the source information would indicate whether caught or bred.

Response

I enclose a copy of most of the information you requested in two excel spreadsheets.

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. Therefore we are refusing part of your request under the exceptions at regulation 10(4)(a) of the EIRs and regulation 10(4)(d) of the EIRs. The reasons why these exceptions apply are explained in the Annex to this letter.

Part one of this request is taken from the sea fisheries database up to and including 17 August 2024. However the information for 2023 and 2024 is provisional and will be subject to change. The information on kg and number of landings have been grouped to provide the maximum amount of information. Information by district and month based on less than 3 vessels has been grouped or stared out. This is a similar process to that carried out for the written answer S6W-03060 you referenced.

Part two of this request, is based on information provided by the wrasse fishers. As part of the wrasse derogation, fishers have to submit a record of the number of wrasse caught. The number of wrasse per species caught on the pots and traps is accounted for. This data is later submitted to quality checks before it gets used for further analysis. Information is provided up until the end of 2023. 2024 data is not available and 2023 data is provisional and might be subject to change. The number of wrasse is an actual count and is not based on an weight based estimate.

Part three of this request is extracted information from movement records collected through the Marine Directorate’s aquatic animal health surveillance programme. Please note that this is not a comprehensive record of movement data as the information held only relates to aquaculture sites visited within the time period of your request and only goes up to the date of the last inspection (provided within the spreadsheet for each site included). It is not always possible to tell from these records the exact source of cleaner fish, or indeed whether these relate to wild or farmed animals. In some situations we have annotated the spreadsheet to include instances of suspected wild caught fish.

Additional information provided out with the EIRs
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to advise you that the wrasse season runs from May until November in each year. The sea fisheries data recorded a small number of landings in March and December 2021 and 2022. These have a small weight and have been merged with the May and November data.

ANNEX

REASONS FOR NOT PROVIDING INFORMATION

Exceptions apply

The Scottish Government does not have the information

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have some of the information you have requested because:

  • For part one the sea fisheries database information we hold for 2024 is incomplete, as there is sometimes a delay in receiving fisheries data and not all fishing activity for 2024 will have taken place yet.
  • For part three the information held is not a comprehensive record, in addition it does contain some anomalies where data has not been recorded fully and the information held can not necessarily distinguish for certain between farmed and wild cleaner fish stocks.

This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about both landings of wrasse by Scottish vessels and numbers of fish caught in 2024, clearly we cannot provide information which we do not hold.

The information is incomplete and in the process of being collected

An exception under regulation 10(4)(d) of the EIRs (unfinished or incomplete information) applies to some of the information you have requested because it is still in the course of collection, is incomplete and has not been compiled. This relates to the information on the number of wrasse caught in 2024 and is because the season is only part way through and there is a delay in receiving information.

This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is some public interest in release as part of open, transparent and accountable government, and this will be met when the collection and compilation of this data is complete in May 2025. However, this is outweighed by the public interest in ensuring that unfinished or incomplete information which is still in being worked on is not disclosed when it might give a misleading impression of the matter to which the information relates.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.

EIR 202400427045 - Information Released - Document 1
EIR 202400427045 - Information Released - Document 2

Contact

Please quote the FOI reference
Central Correspondence Unit
Email: contactus@gov.scot

Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road
Edinburgh
EH1 3DG

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