Promoting Best Practice for Inshore Fisheries: A consultation on measures for hobby/unlicensed fishermen in Scottish inshore waters

Section 3: Consultation Objectives

The working group identified a number of possible actions to reduce the incidence of unlicensed fishermen selling their catch for profit which can be broadly split into two distinct areas; educational and legislative.

The Scottish Government is already considering the 'educational' recommendations and some of these are already being undertaken by Marine Scotland Compliance.

Permits for unlicensed/hobby fishermen

The introduction of a requirement for unlicensed/hobby fishermen to hold a permit has occurred in some other parts of the UK and in conjunction with other measures has been viewed as contributing to the reduction in unlicensed fishermen selling their catch for profit. A permit would state clearly what hobby fishermen were permitted to do and include limits on species, numbers or the amount allowed for personal consumption etc.

Question 1: Should a permit system be introduced for fishermen not fishing from a licensed fishing vessel?

Creel Limits/tagging

There is evidence to suggest that some unlicensed fishermen are laying numerous creels whilst claiming they are fishing for personal consumption. It is difficult to monitor the position as many of the creels are not identifiable and therefore cannot be conclusively attributed to unlicensed fishermen.

A requirement for every fishermen to tag each creel with a specified amount of information would allow identification of the owner of the creel. This would enable enforcement of any fixed upper limits on the number of creels that can be set by unlicensed/hobby fishermen, ultimately allowing for the removal of untagged creels or creels set in excess of numbers allowed for hobby fishermen. Northern Ireland, for example, does not allow hobby or unlicensed fishermen to use more than five pots or to use a stock cage.

Question 2: Should a maximum limit be set for the numbers of creels that can be set by unlicensed/hobby fishermen?

Question 3: If you have answered 'Yes' to Question 2, what should be the maximum number of creels that can be set by a hobby fishermen?

Landing limits for different species

There is evidence that some unlicensed fishermen are landing amounts of fish for 'personal consumption' far in excess of what might be considered a 'reasonable amount', which is a subjective phrase open to wide interpretation and therefore difficult to enforce. Measures could be introduced that establish clear maximum daily catch or landing limits that were more readily enforceable. A ban on the use of keep boxes could also help prevent any minority of unscrupulous fishermen claiming that catches over the daily limit were caught previously and stored.

Question 4: Should daily catch or landing limits be introduced for certain species?

Question 5: If you have answered 'Yes' to question 4 what species should be covered and what do you consider to be an acceptable limit for each species for hobby fishermen to land?

Insert Q6: Should the use of keep boxes by unlicensed / hobby fishermen be banned?

Personal Consumption Definitions.

Current legislation allows for fishing for personal consumption but does not define what this means. There have been reports of unlicensed fishermen setting significant numbers of pots and scallop divers bringing ashore enough scallops to fill several large sacks of scallops yet still claiming they are for personal consumption.

Question 7: Should legislation define what is meant by 'personal consumption'?

Question 8: If you answered 'yes' to Question 7, how should 'personal consumption' be defined - by weight or number, depending on species, or by some other means?