Outcome Report: Consultation on setting the total allowable catch for Herring in the Firth of Clyde 2024

2. Overview of responses

In this section we provide an overview of responses and a summary of key themes raised.

2.1 Overview

During the consultation, a total of 16 responses were received, of which 14 were received via Citizen Space and two 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. Nine responses were received from organisations, and seven responses were received from individuals.

2.2 Analysis of responses and key themes

Of the responses received:

• Five responses  supported a rollover approach of setting a TAC of 583 tonnes, all of which were submitted by organisations.
• Five responses suggested that a 0 TAC or bycatch TAC should be applied for 2024 of which four were submitted by an organisation and one by an individual.
• Five responses stated that TAC should be reduced, of which four did not propose a specific number and one suggested a cut of 10% every year. All of which were submitted by individuals.
• One response from an individual did not indicate a position on the TAC recommendation.

The following points were made in responses to the consultation, as reasons to set the TAC at 583 tonnes, which is maintaining the TAC level from 2023 and between 2015 – 2021:

• Some respondents stated that, based on the provided scientific evidence there is no justification to change the TAC.
• Some respondents highlighted the need for additional data and offered to support initiatives which would aid with data collection, including some suggestions of work which could be considered. These included collecting additional scientific information about the Clyde herring stock and the wider ecosystem in the Clyde basin.
• One respondent asked for the licences to be available by 1 August to allow for late summer fishing.
• One respondent suggested more work was needed to assess the effectiveness of the closure in the Ballantrae Bank spawning ground closure on the Clyde herring stock.
• One respondent recommended derogations be added to three of the control measures to aid in the uptake of the stock and provide samples for analysis.
• One respondent requested considerations be made to improve local infrastructure for landing herring in the Clyde.

The following points were made in responses to the consultation, as reasons to reduce the TAC or set at 0:

• Many respondents highlighted a lack of evidence available on the stock as a justification to be precautionary and reduce or set 0 TAC until the time more robust evidence is available. They suggested methods of increasing the data, of which, one suggested a request to ICES and data collected from any landings of herring in the Clyde.
• Many respondents considered that the data shows the population is in a collapsed state with no signs of recovery and that it is dominated by juvenile herrings. They concluded that until evidence of recovery is shown, the TAC should be reduced, or fishing ceased.
• Some respondents suggested that the current management has not been effective in the recovery of the stock so there needs to be a change in the management approach.
• Three respondents suggested that the control measures in place should be increased, notably around increasing the length of closure around Ballantrae Bank.
• Two respondents noted that the low landings in recent years indicated a lack of economic dependency on the fishery.
• One respondent highlighted the population links between the Clyde herring and the wider west coast population therefore giving the rationale for setting a much more precautionary TAC or 0 TAC.
• One respondent noted the lack of discard data.

The individual who did not indicate a TAC position highlighted the need to consider increasing the restrictions on net volumes and the use of sonar, as well as an increase in the minimum landing size.