Sandeel fishing - proposed closure: consultation analysis

Section F: Strategic Environmental Assessment (Q6)

Context

The environmental impacts of fisheries displacement as a result of closing fishing for sandeel in Scottish waters were considered in the SEA.

The scoping exercise identified some alternative management strategies that could be taken that might achieve the same outcomes, as well as the alternative of taking no action. These alternatives included extension of the existing closure, seasonal closure of the sandeel fishery, voluntary closure and no action being taken. ^[19]

It was assessed that none of the identified reasonable alternatives were likely to result in additional benefits compared to the proposals to close fishing for sandeel in all Scottish waters, and that each carries additional risk when compared to the proposed closure.

Response to the consultation

A total of 76 respondents gave a response to this question in the consultation, these comprised 45 individual responses and 31 organisational responses (See Table 8).

The vast majority of respondents to this question did not have any comments on the SEA, had not read it, or were unsure. Where respondents did have comments on the SEA, there was variation across their responses. A small number of responses to this question contained general statements about the value of conservation efforts, rather than comments on the SEA specifically.

Support for the report’s contents

Respondents who voiced support for the SEA commented on the report’s evidence base or the fairness of the report in their responses:

“Taken with the associated conclusions regarding the potential benefits to marine mammals and to predatory fish, these documents thus make a strong case in favour of the preferred option of full closure of the sandeel fishery in Scottish waters.” – [Individual]

Several respondents in support of the report’s content commented on the rejection of the four alternative management strategies in particular as a positive aspect of the report:

“[organisation name] strongly agrees with the rejection of the four alternative management strategies and support the Scottish Government’s justifications for this. The statement in the SEA on alternative management strategies that ‘none of the identified reasonable alternatives were likely to result in additional benefits compared to the proposed closure of all Scottish waters, and each carries additional risk when compared to the proposed closure’ illustrates that a full closure is therefore the only option.” – [Organisation]

Some respondents highlighted how the No Action option, in particular, would be risky, particularly given the need for synchronous and complementary closure of both English and Scottish waters to eliminate the risk of any cross-border displacement of sandeel fishing effort:

“I strongly agree that the 'No action' option would carry the risk of potential detrimental effects from potential displacement of fishing effort into Scottish waters under the UK Government's preferred option of closure of English waters within the North Sea. The uncertainty of timing of the latter makes it all the more important and precautionary to initiate the sandeel fisheries closure of Scottish waters not later than the start of the 2024 sandeel fishing season.” – [Individual]

Criticism of the report

Other respondents were more critical of the report. A number of respondents highlighted how the impacts of the proposed closure were largely hypothetical:

“The SEA Environmental Report combines matter-of-fact, known food web linkages with extremely vague predictions of what might or might not occur with the closure of the sandeel fishery. Thus we have clear language about what eats what and a host of qualifiers around what the closure of the fishery might mean, with 'could', 'may', 'possibly' taking the place of more convincing language. Without labouring the point, we would point to sections such as the following: "the proposed sandeel fishery closure are (sic) expected to provide potential environmental benefits for a range of marine species that eat sandeel, including seabirds, seals, cetaceans, and predatory fish, as well as the direct benefits to sandeel stocks". Expecting a potential? This is a disappointingly feeble basis on which to take policy action.” – [Organisation]

Two distinct responses raised several issues with the proposal in their identical responses to this question. They recommended that the Scottish Government thoroughly assess the potential adverse effects on the ecosystem resulting from the proposal to close fishing for sandeel in Scottish waters and highlighted several interconnected themes in their responses.

Firstly, they expressed ecological concerns regarding the proposed closure of fishing for sandeel in Scottish waters. They warned of potential shifts in fishing efforts to other species, emphasising the delicate balance within the ecosystem and the resulting biodiversity loss, particularly affecting 0-group sandeel and seabird populations. The organisations stressed the necessity for a holistic fisheries management approach, considering the complex interactions in the marine ecosystem and ensuring the long-term sustainability of sandeel populations and dependent species.

Secondly, they raised economic reservations, criticising the proposed management approach, deviating from established guidelines, and highlighted potential negative impacts on the fishing industry. The divergence in opinions hinted at differing expectations regarding the commercial benefits arising from the proposed closure, with them urging a more careful evaluation of economic consequences.

“The proposed changes by the Scottish Government regarding the sandeel fishery, which deviate from the established management approach aligned with ICES escapement advice for short-lived species, would also have a detrimental impact on international earnings derived from this commercially significant resource. These “proposed measures overlook the crucial importance of maintaining sustainable practices and optimizing economic benefits associated with the sandeel fishery”. It is essential to recognize the interconnectedness between ecological considerations and the financial viability of this resource, thus avoiding any actions that may jeopardize international earnings generated by the sandeel industry.” – [Organisation]

Additionally, they underscored the contribution of sandeel to feed production for healthy food products, particularly in Scottish salmon production. The organisations advocated for the sustainability of marine resources as a precautionary alternative to land-based production, stressing the need to avoid shifting the burden onto less environmentally friendly alternatives.

Both concluded their comments by noting that they would be open to further discussion with the Scottish Government about their aforementioned concerns.

Additional suggestions or comments for the report

One respondent extensively criticised the SEA, pointing out various flaws in their view. They highlighted issues with the report's treatment of ICES advice, emphasising instances of overfishing in 2018 and 2021. Additionally, the respondent argued that the report failed to distinguish between Scottish inshore and offshore fisheries, especially those involving other European nations. They contested the relevance of fisheries displacement in the proposals to close fishing for sandeel in Scottish waters and disputed the designation of sandeel as a protected feature in MPAs. The respondent also pointed out what they deemed to be inaccuracies in the report, including an incorrect characterisation of adult sandeel and discrepancies in historical information.

Several respondents expressed concerns about what they saw as the report's inadequacy in demonstrating the benefits of the proposed closure. One response highlighted the importance of sandeel to cetacean species and argued that the closure would benefit various cetaceans in addition to supporting population recovery. Another response contested the report's conclusion regarding evidence linking fishing pressure to seabird demography. They referenced the Ossian project and regional compensation measures.

“The importance of sandeel to the distribution, abundance, and health of the three cetacean species included in the SEA Environmental Report are clearly evidenced. However, various other species which are recorded with increasing regularity in Scottish waters such as humpback and fin whales and common dolphin are not included in the documents to support the consultation [even though they will also benefit from access to increased sandeel stock on which to feed]…The proposal to close fishing for sandeel in all Scottish waters will therefore benefit a wide range of cetacean species and support the recovery of cetacean populations.” – [Organisation]

“The review of the scientific evidence provided with the consultation makes clear the benefits to the marine environment that can be expected from a closure of sandeel fisheries in Scottish Waters. However the review concludes that the evidence to support the link between fishing pressure and seabird demography is lacking. From the work COP has been involved with in relation to the Ossian project and regional compensation measures, we would suggest that the evidence is not lacking. Rather than list this evidence here, a comprehensive list of evidence is included in the publicly available Berwick Bank Derogation Case.” – [Organisation]

In the case of the link between fishing pressure and seabird demography, some responses provided a comprehensive list of additional evidence to contradict the SEA's conclusion that the evidence to support this link is lacking while acknowledging that the review of the scientific evidence provided with the consultation makes clear the benefits to the marine environment that can be expected from a closure of sandeel fisheries in Scottish Waters. The responses addressed eight key areas, presenting evidence to demonstrate the link between sandeel fisheries and seabird demographics. They challenged the report's conclusions on breeding seasons, the displacement of fishing in SA4, recovery time, the reason for fisheries closure, the impact of fishing mortality, climate change effects, and the quantification of benefits to seabirds. The response emphasised the need to consider adult survival, immediate benefits from the cessation of fishing pressure, and the quantifiable impact on seabird populations through ecosystem models and correlative relationships.