Seal Haul-Out Sites Consultation Analysis

3. Themes and Comments

3a. Predictably there were differing views on the protection of seal haul-out sites between NGO's, some members of the public and different small coastal (tourism) businesses.

• There is universal support for the establishment of designated haul-out sites. 51% of responders wanted more sites and 24% wanted every haul-out site designated to allow complete protection of seals on land.
• Some NGOs and individuals expressed concern about the selection process might limit protection to 50% or less seals. ^[1]
• Some suggested that protection be extended to seals in adjacent waters in order to allow safe access to and from sites.
• The designated site boundaries are not defined as the minimum distance of possible harassment sources and clarification is sought. Comments express concern that harassment, in the form of noise for example, can originate from vessels or machinery a considerable distance from the boundaries and this legislation does not take such circumstances into consideration.

"The harassment of seals at their haul-out sites could not be seen as sustainable and should not be permitted anywhere."

OneKind

"All places where seals are known to give birth, nurse and chaperone pups, moult or rest should be included."

Seal Conservation Society

"The proposal rationale of designating the larger seal haul out sites to encompass 50% of the populations reminds me of the native American Indian tribes being forced into smaller and smaller reservations."

Peter Lamont

3b. Industries operating in the coastal areas

The general response to the consultation from this group is negative.

• There are worries that further legislation will limit current and future marine development, whether in the field of aquaculture, fishing, renewable or oil and gas industries.
• The lack of a clear 'harassment' definition is of importance as many respondents are unclear as to how their industry will be affected by the designation of haul-out sites in close proximity to operations. The SFF and MyGen would also like a clear definition of the management measures that will be taken for the sites.
• The various industries' replies acknowledge their awareness of the potential risk of seal harassment but list examples of the compromises that have already been made in order to reduce that risk. With these evasive measures already taken the two major representatives of the aquaculture industry, Marine Harvest Ltd. and the Scottish Salmon Producers' Organisation consider the status quo more than adequate.
• The fishing and aquaculture industries suggest that the increasing grey seal numbers threaten both wild fish and farm fish populations and further protection of a top predator is potentially damaging to their livelihoods.
• The Shetland council lists twelve sites that are in the vicinity of current commercial ventures and states these sites are active despite the movement and noise around them. In these cases seal populations have habituated to the activity around them and the council worries that these activities would be limited in the future should Marine Scotland consider them harassment.
• Forth Ports PLC is concerned that should entire SACs be considered for haul out designation intertidal areas within them where seals do not haul out would be lost as a resource for future coastal development and activities. ^[2]
• The SFF believes any aggregation of seals in an area is enough to deter fishing activities thus negating any further need of protection of the seals.

"The number of haul-out sites proposed in the consultation will have a significant impact on the Scottish Government's ability to reach its target of 100% electricity generated from renewable sources by 2020."

MyGen Ltd, Renewables Sector

"The grey seal population in particular has increased massively over the last 10 years. Seals prey on wild fish such as juvenile white fish, sea trout and salmon. Designating 50% of the grey seal haul outs is not going to help protect wild salmon, a species also designated as requiring protection under legislation."

Scottish Salmon Producers Organisation, Aquaculture Sector

"A common sense approach would be to give a presumption in favour of any existing activity to continue rather than be denied access on some spurious notion of protecting seals from harassment."

Scottish Fishermen's Federation