Sandeel fishing consultation: strategic environmental assessment - draft environmental report

Non-Technical Summary

Introduction

The seas around Scotland have a wide variety of marine wildlife and varied habitats that support a diverse abundance of marine organisms. Sandeel form a particularly important component of the North Sea ecosystem and a link between different levels of the marine food chain^[1] from plankton up to commercial fish species, seabirds, and marine mammals. As an island-based society, the sea around Scotland has always had an important role to play, offering a source of food and recreation.

The Scottish Government has national and international commitments to protect marine biodiversity, and to take necessary measures to protect and conserve the marine ecosystem. The Scottish Government is also committed to the sustainable management of fisheries, which includes taking account of the protection of biodiversity and healthy functioning ecosystems.

Taking these commitments into account, the Scottish Government is consulting on proposals to close fishing for sandeel in all Scottish waters. The consultation, which will seek views on these proposals, is being undertaken with the purpose of bringing about wider environmental and ecosystem benefits. These include potential benefits to sandeel, seabirds, marine mammals, and other fish species.

What is a Strategic Environmental Assessment?

This Environmental Report summarises the findings from the Strategic Environmental Assessment (SEA) of the proposals to close fishing for sandeel in all Scottish waters. An SEA of the proposals is required by the Environmental Assessment (Scotland) Act 2005 ('the 2005 Act').

SEA identifies the likely significant environmental impacts of plans and policies, and proposed reasonable alternatives to them. SEA also identifies mitigation measures that are required to avoid or minimise any significant adverse effects and highlights opportunities for enhancements of beneficial effects. Taking place at an early stage in the plan or policy preparation process, it ensures that decision-making is informed by relevant environmental information. SEA provides opportunities for the public to consider this information and use it to inform their views on the draft plan or policy.

A screening and scoping exercise on the proposed sandeel fishery closure was undertaken by the Marine Directorate, in accordance with the requirements of the 2005 Act. In response to the screening, Consultation Authorities^[2] confirmed the need for a SEA due to the potential for significant environmental effects to occur. They also provided comment on the proposed scope and methodology of the assessment and the proposed consultation period for the Environmental Report. Their views are taken into account in this Environmental Report, as per the requirements of the 2005 Act.

What are the proposals?

The Scottish Government has national and international commitments to protect marine biodiversity, and to take necessary measures to protect and conserve the marine ecosystem. The Scottish Government is also committed to the sustainable management of fisheries that takes account for the protection of biodiversity and healthy functioning ecosystems.

Given the importance of sandeel to the wider ecosystem and the subsequent benefit provided by the species in aiding long-term sustainability and resilience of the marine environment, it remains an over-arching and long-held Scottish Government position not to support fishing for sandeel in Scottish waters, which is reflected in Scotland's Future Fisheries Management Strategy.^[3] A sandeel closure in sandeel management area 4 has also been in place since 2000 (Figure 1) and the UK has not allocated sandeel quota to UK vessels since 2021.

Taking these commitments into account alongside the key role that sandeel play in the marine environment, the Scottish Government is consulting on proposals to extend the existing closure in Sandeel Area 4 to all Scottish waters. As part of the process to determine whether this measure should be taken, the Scottish Government is now inviting views on the findings of the SEA.

How was the Strategic Environmental Assessment undertaken?

The SEA provides a high-level and qualitative assessment of the potential environmental effects that are likely to result from the extension of the sandeel closure to all Scottish waters. In addition, the potential effects that may arise from reasonable alternatives are also assessed (see below).

The assessment identifies the effects of the proposed closure extension that are scoped into the assessment, specifically Biodiversity, Flora and Fauna; and Water Quality, Resources, and Ecological Status. The assessment also considers the effects of the proposed closure extension on a series of key statements ('SEA objectives'). These SEA objectives reflect the scope of the assessment as well as the environmental protection objectives from relevant legislation. The assessment also considers the interaction of this proposal with existing and developing projects, plans and strategies that have similar objectives.

Economic impacts, including those on other users of the marine environment, are assessed in a Business and Regulatory Impact Assessment (BRIA).

Which reasonable alternatives have been assessed?

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. The alternatives assessed were:

• Extension of the existing closure to all of Sandeel Area 4 only
• Seasonal closure of the sandeel fishery
• Voluntary closure of the sandeel fishery
• No action taken

It was assessed 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. Extension of the existing closure to sandeel area 4 only risks displacement of fishing effort into novel sandeel fishing grounds in Scottish waters with potential for detrimental environmental effects. Seasonal closure of the sandeel fishery has the risk of being an ineffective measure if the timing of sandeel availability were to change in the future due to changes in environmental or biological drivers. Voluntary closure of the sandeel fishery was assessed as risking a potential shorter fishery closure due to the need for annual agreement to the measure from all fishing nations, and also incurred an increased management cost.

Taking no action was assessed as not providing sufficient benefits to meet the policy objectives. Additionally, potential detrimental effects were also identified due to potential displacement of fishing effort into Scottish waters under the UK Government's preferred option of closure of English Waters within the North Sea.

What is the current state of the marine environment?

Scotland's marine environment supports a diverse complex of different habitats, which in turn support a wide range of marine plants and animals. Sandeel are a key component of the ecosystem of Scotland's seas due to their role in marine foodwebs as a prey source for a range of species including seabirds, seals, cetaceans (whales, dolphins and porpoises), and predatory fish. Progress towards Good Environmental Status (GES) for elements including biodiversity and commercial fish is monitored and measured under commitments in the UK Marine Strategy.^[4]

Sandeel stocks are influenced by environmental factors such as temperature, and biological factors including the availability of their zooplankton prey, mortality from predation, and mortality due to fishing. The sandeel stock experienced a decline between 1992 and the early 2000s and has remained relatively stable since although fluctuations occur between years (Figure 2).

Scotland holds internationally important numbers of breeding seabirds, many of which include sandeel in their diet during the breeding season. Species that include sandeel in their diet include black-legged kittiwake, Atlantic puffin, Razorbill, European shag, Black and Common guillemot, Artic and Sandwich tern, and Northern gannet. The conservation status of the majority of these species has been assessed as unfavourable with only Northern gannet carrying a favourable conservation status in the UK. Scottish seabirds were heavily affected by the 2021-22 Highly Pathogenic Avian Influenza outbreak^[5] and it has not yet been possible to fully assess the effects of this outbreak on population status. The conservation status of these seabird species may therefore have changed since last assessed.

Scotland has two native species of seal; grey seals and harbour seals; that are found in Scottish waters year-round. Both of these include sandeel in their diet. Grey seals occur around the entire Scottish coastline where their distribution is driven by proximity to suitable haulout sites. Harbour seals are also distributed around Scotland's coastline with highest densities occurring throughout the Inner Hebrides, Orkney, Shetland, and the Inner Moray Firth. The grey seal population is showing overall growth, which is mainly limited to the North Sea colonies along the east coast of Scotland and England, with slight declines occurring in the Inner and Outer Hebrides and Orkney.^[6] Harbour seal populations also show regional trends with significant population declines occurring in some regions.^[6] GES has been achieved for grey seals but has not been achieved for harbour seals.

Eleven species of cetacean are regularly sighted around Scottish seas. Of these, harbour porpoise, minke whale, and white-beaked dolphin include sandeel in their diet. The long-term population trends of these species are classed either as 'unknown' or 'uncertain' as not enough survey data is available to establish a trend. Estimates of harbour porpoise and minke whale in the North Sea suggest that their numbers are stable.

Several species of commercially important fish species include sandeel in their diet, including Atlantic cod Gadus morhua, haddock Melanogrammus aeglefinus and whiting Merlangius merlangus. Atlantic cod biomass declined between 1980 and 2005 followed by a slight increase in biomass since 2005. Biomass of haddock in Scottish waters showed an initial decrease in the mid-80's followed by relatively low biomass levels except for a peak between 2000 and 2003. Biomass has shown recent increases since 2020. Biomass of whiting has been relatively stable since the mid-80's. As mentioned above, GES has been achieved for some species of commercially important fish.^[7]

What are the likely significant environmental effects of the proposed sandeel fishery closure?

The proposed sandeel fishery closure are 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. This is due to evidenced linkages between predator success and prey abundance as has been observed particularly for black-legged kittiwake, harbour seals, and harbour porpoise.

However, there is also evidence that other drivers may play a greater role in population dynamics of marine species that include sandeel in their diet. These are varied and include disease outbreaks, climate change, mismatch between prey availability and key life stages, as well as various anthropogenic stressors. Benefits may be difficult to evidence due to the challenge of identifying the influence of individual factors. However, having access to ample prey resources can help marine species cope with other stressors, for example good body condition may incur greater resilience to thermal stress and disease.

It is expected therefore that increasing the abundance and availability of sandeel in the marine environment may bring wide environmental benefits through increased population resilience to the range of pressures faced by marine species.

What are the cumulative effects of the proposals to close fishing for sandeel in all Scottish waters?

As the proposal is for a single measure, there is no scope for cumulative effects of this proposal. The cumulative effects of this measure were considered in combination with other existing or developing plans, programmes and/or strategies that have similar objectives, but that fall outside the scope of this proposal.

It is assessed that the proposed extension of the sandeel closure to all Scottish waters will potentially support the outcomes of existing measures to protect seabirds, and marine mammals including Special Areas of Conservation (SACs), Special Protected Areas (SPAs) and Marine Protected Areas (MPAs) in which seabirds and marine mammals are a protected feature. It is also assessed that the proposed extension will potentially support Scotland's Highly Pathogenic Avian Influenza in wild birds response plan, Scotland's Future Fisheries Management Strategy, Scotland's National Marine Plan, and the developing Scottish Seabird Conservation and UK Dolphin and Porpoise Strategies. Complimentary benefits to these plans, programmes and strategies will likely arise through increasing the resilience of sandeel and the species they support to the range of other pressures that they face.

How do I respond to the consultation?

The consultation on the SEA Environmental Report is now open. Views and opinions on this are now invited and should be provided by 13 October 2023.

Please respond to the consultation online.

If you have any enquiries please contact: sandeelconsultation@gov.scot

Or send your inquiry by post to:

What happens next?

Following the consultation period, the responses received will be analysed, and a Post-Adoption Statement will be prepared. The Post-Adoption Statement will explain how issues raised in the SEA, and associated views in response to the consultation, have been addressed.