Herring in the Firth of Clyde 2022 - setting the total allowable catch: consultation analysis

2. Overview of responses

In this section we provide an overview of responses and a summary of key themes raised. In section 3, we set out the Scottish Government's proposed next steps.

2.1 Overview

• During the consultation, a total of 16 responses were received, of which 15 were unique, and one was a duplicate response that had been submitted twice by the same individual. 13 responses were received via Citizen Space and 3 responses were submitted directly to clydeherring@gov.scot.
• Respondents to the consultation were asked whether they were replying as an individual or on behalf of an organisation. 9 responses were received from organisations, and 6 unique responses (7 in total) were received from individuals.

2.2 Analysis of responses and key themes

Of the responses received:

• 4 responses supported an approach of a rollover of the 2021 TAC at 583 tonnes, of which 3 were submitted by organisations and 1 by an individual.
• 2 responses supported a 20% reduction on the 2021 TAC, both of which were submitted by individuals.
• 8 responses suggested that a 0 or de minimis TAC should be applied for 2022, 6 of which were submitted by organisations and 2 by individuals.
• 1 response (submitted twice by the same individual) suggested that the TAC should be increased to 648 tonnes.

The following key points were made in responses to the consultation, as reasons to reduce the TAC:

• Uncertainty in the current knowledge of the stock was cited by many respondents as a reason to reduce or cease fishing, until more robust scientific data is obtained.
• Many respondents raised concerns with the state of the Clyde herring stock, noting in particular the predominance of fish below minimum landing size, and the lack of evidence of stock recovery despite low landings in recent years. These respondents therefore focused on the importance of allowing time for the stock to recover to a better state.
• Two respondents noted that the low landings in recent years indicated a lack of dependency on the fishery.
• Some respondents suggested increased sampling and/or monitoring of vessels participating in the fishery, to improve knowledge of the stock. One response suggested that a request should be made to ICES for a full stock evaluation.
• Some respondents suggested that there should be a greater focus on developing an ecosystem-based approach to management of herring in the Clyde and the wider west coast.

The following key points were made in responses to the consultation, as reasons to rollover or increase the TAC:

• Some respondents stated that the TAC should be based on the best available scientific information, and that the information currently available gave no scientific justification to reduce the TAC.
• Some respondents raised concerns over a perceived 'use it or lose it' policy.
• Some respondents suggested that a reduction in the TAC this year would set a precedent for year-on-year decreases.
• One respondent suggested that, due to the reduction in the TAC in recent years, the stock should be in a better state, and therefore the TAC should be increased.