Sandeel fishing - proposed closure: consultation analysis

Response to the consultation

A total of 102 respondents gave responses to question 4, 72 of these responses were from individuals and 30 from organisations (see Table 6).

Responses to this question varied in their support of the proposals to close fishing for sandeel in Scottish waters, with a majority of respondents stating they had no additional comments to make in response to this question, a number of respondents highlighting positive potential impacts of the closure on island communities, and others expressing concerns.

Positive impact of increased sandeel stock

One theme that emerged across the supportive responses echoed the content of responses to previous questions: given that sandeel are at the base of many marine food chains, it was noted that any increase in sandeel populations would lead to an increase in larger, predatory fish stocks, as well as increases in populations of seabirds and other wildlife:

"The scientific evidence presented in the SEA report shows that sandeel are a key species for seabirds during breeding seasons. An increase in sandeel abundance would increase the health and the abundance of bird populations breeding on islands…Moreover, it is possible that as sandeel increase in abundance, predatory fish will grow in abundance in turn..." – [Organisation]

It was noted that wildlife tourism and recreational (fishing) tourism would benefit from increased wildlife and seabird populations for example:

“The interest in the natural world is rapidly increasing and nature tourism can be massive to the long standing benefit of our island communities. If we preserve sandeel populations and all the other wildlife that depends on them our islands will be fantastic destinations for ecotourism. To allow the destruction of our natural world does island communities no favours at all” – [Individual]

The less quantifiable benefits of a healthy marine generally were also noted:

“A total ban on this industrial Sandeel fishery can only be beneficial to our island communities…[sandeel fishing] is totally destructive, to all in the sea that is part of a delicate food chain, to our rare sea birds already at risk from climate change, avian flu, pollution, and more. Please take heed and end this Sandeel fishery to help protect the health of our precious Scottish waters, and therefore all the creatures that depend upon it being so. Only good can come from an outright ban on this fishery.”

[Individual]

Several supportive respondents cited the positive benefits that could be realised if the closure of fishing for sandeel in Scottish waters enabled offshore wind deployment:

“It is important to reiterate that our island communities suffer from the highest levels of fuel poverty. Therefore, if sandeel closures can help enable offshore wind deployment, they would benefit from lower energy prices and the wider socio-economic benefits associated with their development.” – [Organisation]

Other supportive respondents noted that UK vessels do not currently catch sandeel, and therefore there would be no negative financial impact on island fishing industries.

“Since, according to the Draft Partial Business and Regulatory Impact Assessment (BRIA), no sandeel quota is currently allocated to UK fishing vessels, islands-based commercial fishing activity as such would not be affected by the proposed sandeel fishery closure” – [Individual]

One respondent offered an alternative view, noting that there would be no concerns for island communities to begin with, as the impacts would be felt elsewhere in Scotland:

“Banning sandeel fishing in Scottish waters is mostly an issue for the Scottish east coast mainland, since historic coastal fisheries off Shetland and the Western Isles have ceased. The re-establishment of such fisheries are unlikely to ever fulfil sustainability criteria, as was demonstrated for the Shetland sandeel fishery” – [Individual]

Some respondents who were supportive of the proposed closure also highlighted the need for further work in some areas, specifically the need for additional quotas to be made available:

“The permanent closure of the sandeel fishery will have no economic impact on vessels operating in the inshore waters around the Outer Hebrides and may result in additional white fish stocks returning to inshore grounds and may be of benefit in the future to inshore vessels providing there is additional quota available to enable vessels to diversify from their high dependence on shellfish stocks.” – [Organisation]

Negative impact on island communities

Some concerns were raised about the impact on island communities of ceasing sandeel fishing, largely relating to financial effects:

“Island populations and economies should be protected, Green proposals to effectively wipe there communities out are reminiscent of previous excesses of state control in other parts of the world.”- [Individual]

One respondent highlighted several concerns relating to the lack of benefit or impact on island communities by proposals to close fishing for sandeel in Scottish waters. They noted that many of the areas proposed in this closure have been closed since 2000 and that the SEA stated that, despite the closed fishery, the biomass levels had not reached levels in 2008-2009 that were similar to those observed in 1997/98 when the fishery was active. They also highlight the Scottish Government’s statement that any closures may take many years to demonstrate any improvement, but that there was limited or no evidence to indicate any improvements since closures near Shetland and the West Coast and note that there is no data to show impacts on ecosystems in those areas.

Those with concerns about the impact on island communities suggested further work was needed to offset this impact.