Sandeel fishing - closure proposals: strategic environmental assessment - post adoption statement

5. How the opinions expressed on the Environmental Report were taken into account

The Environmental Report was published for consultation alongside the consultation paper, the Review of Scientific Evidence, the partial Business and Regulatory Impact Assessment, and the Data Protection Impact Assessment. Views were invited on the following questions:

• Question 1: Do you support the preferred option to close fishing for sandeel in all Scottish waters?
• Question 2: If your answer is no to question 1, do you have any views on alternative or complementary measures that could be considered in the longer-term for the protection of sandeel in Scottish waters?
• Question 3: Is there any further evidence that should be considered in terms of the potential benefits or value of the preferred option that could be considered?
• Question 4: Is there any further evidence that should be considered to demonstrate any impact on island communities?
• Question 5: Do you have any comments on the assumptions made in the partial Business and Regulatory Impact Assessment (BRIA) concerning the costs and benefits of the option?
• Question 6: Do you have any comments on the SEA Environmental Report?

A total of 494 responses were received, with 90% submitted by individuals. In addition, 9,815 campaign emails associated with the RSPB were received in response to the consultation. An Analysis of Consultation Responses has been published^[5], along with the Scottish Government's response to the consultation analysis^[6].

This section details how these opinions were taken into account when coming to the decision to close fishing for sandeel in all Scottish waters.

5.1 Support for closing fishing for sandeel in Scottish waters over the alternatives identified

While there was overwhelming support for the preferred option to close fishing for sandeel in Scottish waters, of those that responded to the question on the Environmental Report, several agreed with the assessment that none of the identified reasonable alternatives were likely to result in additional benefits compared to the preferred option. This was acknowledged in the analysis of responses, and formed a part of wider considerations in coming to the decision to proceed with the preferred option to close sandeel fishing in all Scottish waters.

5.2 Interpretation of evidence in the report regarding the potential benefits of the proposals presented

Several respondents had views about how the environmental report interpreted the unpredictability of the available evidence regarding the potential benefits that could arise as a result of the proposed closure. Some respondents felt that the language was not stated strongly enough and that greater benefits would be provided than the environment report suggested.

In contrast, a small number of respondents commented that the proposals, as well as any alternative or complementary measures, had the potential for limited benefits. These respondents highlighted the uncertainty around the evidence base and that the current management practices in place are already sufficient to protect the ecosystem and that any additional benefits were unlikely.

We acknowledged that the evidence base demonstrating the effect of the sandeel fishery on sandeel abundance is not definitive and that the subsequent benefits to the marine environment, or specific components of the marine environment are uncertain. It should be acknowledged, however, that this uncertainty is not due to a lack of information or data but is due to the degree of variability in the system, compounded by multiple interacting large scale environmental processes (e.g., climate change) affecting the various components of the foodweb. This complexity and variability means that predictions of the benefits of closing fishing for sandeel on the wider marine environment will have a high degree of uncertainty (e.g., uncertainty in the effect of fisheries management on sandeel abundance and uncertainty of the effect of sandeel abundance on availability to top predators). However, our assessment is therefore that the precautionary approach adopted from our scientific evidence base which takes account of this unpredictability remains valid and therefore updates to the Environmental Report are not required. This aligns with the views of consultation respondents who also expressed their support for the preferred option.

One respondent highlighted the importance of sandeel to cetacean species and argued that the closure would benefit various cetaceans in addition to supporting population recovery. We note the references provided by this respondent. We intend to publish a second draft of the Evidence Paper in due course, which will incorporate these references.

5.3 The need for a fisheries management approach that recognises the connection between ecological considerations and the financial viability of the fishing resource

Two distinct responses 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. 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.

Regarding the concerns on a potential shift in fishing efforts to other species, it should be acknowledged that for the majority of stocks Total Allowable Catches (TAC) are set during annual international negotiations and any fishing should not exceed these pre-agreed levels.

Acknowledging that sandeel forms a significant component of the diet of several species of commercially important fish including Atlantic cod, haddock, whiting and saithe (for more details see the Environmental Report^[12]), it is expected that any increase in sandeel stocks as a result of the closure could bring benefits to wider fish stocks.