Seal licensing system: second review

4. Previous review

The first review was published in September 2015, following the first four years of operation of the seal licensing system. That review considered the various aspects of the system, with five recommendations for further improvements made under the following topics which are described in detail below. Each section outlines the original recommendation and an overview of the action taken. Further details about each element are further discussed under the section headings later in this review. 

SMRU were consulted on the review, on behalf of UKRI, and the resulting comments have been taken into account in the final review.

4.1 Seal licence applications

4.1.1 Recommendation

MS- LOT to continue to seek to improve information collection including through improvements to the application forms and survey process.

4.1.2 Progress

The seal licence application process has undergone considerable improvement since 2015 including the creation of an online management portal for applicants to complete the survey and report seals killed. This has increased the quantity and quality of data provided during the application process and made the processing of applications more comprehensive. The online portal can only be accessed by applicants and MS-LOT staff to maintain data protection and privacy. However, key information is still published regularly on the Scottish Government website.

4.2 Non-lethal measures 

4.2.1 Recommendation

MS-LOT to continue to work closely with the industry and others to improve various existing options in this field and to develop new non-lethal measures.

4.2.2 Progress

Scottish Government is supporting the aquaculture and river fisheries sectors in improving access to and use of non-lethal measures to deter seals. Research has been commissioned which seeks to reduce interactions between river fisheries and seals, including increasing the efficacy of non-lethal measures and improving technology for monitoring and recognising individual seals which travel upriver to predate upon salmon. Further research, led by Scottish Government and funded by Crown Estate Scotland, is reviewing the availability of non-lethal measures in rivers and at fish farms and will make recommendations for future areas of investigation.

The aquaculture industry continues to improve net technology to combat the risk of escapes often due to damage from seals and in utilising other non-lethal measures, although there has been some questions raised about the efficacy of Acoustic Deterrent Devices (ADDs) (Coram et al., 2014) and their potential for impacts on other non-target species, mainly cetaceans (Findlay et al., 2018). This is also the subject of an ongoing research project.

4.3 Seal licence returns 

4.3.1 Recommendation

MS-LOT to consider improvements in the frequency of seal licence returns.

4.3.2 Progress

Licensees are required to report every seal killed within 48 hours, in addition to completion of a quarterly report. This process has also been improved through integration into an online management system providing easy and quick access for all reporting.

Improvements have resulted in automatic alerts being generated when a report of seal shooting is submitted out with the 48 hour review period. This means Marine Scotland have, where appropriate, been able to quickly follow up late reporting through their compliance function. Ultimately, the increase of attention and focus on reporting is having a positive impact on the timing of returns. 

4.4 Carcass recovery 

4.4.1 Recommendation

MS-LOT to consider how to improve the carcass recovery process in discussions with Scottish Marine Animal Stranding Scheme (SMASS), licensees and others.

4.4.2 Progress

It remains a condition of licences that carcasses should be recovered, where it is possible to do so. Furthermore, licensees are reminded through MS-LOT that, in addition to recovery, all carcasses should be reported to SMASS where possible. Despite this, the number of carcasses recovered by licensees is still low. 

4.5 Seal licence fees 

4.5.1 Recommendation

MS-LOT to consider possible future introduction of fees to cover administrative costs of seal licensing system.

4.5.2 Progress

To date, there are no application fees for a seal licence. This remains under review by Marine Scotland.