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

6. Reasonable alternatives

The 2005 Act requires that the Scottish Government identify, describe and evaluate the likely significant effects on the environment of any reasonable alternatives to the plan or programme, taking into account its objectives and geographical scope.

The reasonable alternatives considered in the draft Environmental Report 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

The potential environmental effects associated with the four reasonable alternatives were identified and set out in detail in the Environment Report. The SEA 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. Several respondents agreed with this assessment in their consultation response.

Consideration of reasonable alternatives in the draft Environmental Report showed that several scenarios could result in some of the benefits of full closure being realised, but that the proposed full closure was the most likely scenario to bring about long-term benefits across the themes of Flora, Fauna and Biodiversity and Water Quality, Resources and Ecological Status. Consideration of alternatives also showed that taking no action poses a risk of adverse environmental effects through the potential for increased fishing effort in Scottish waters as a result of the closure of English waters of the North Sea. Several respondents agreed with this assessment in their consultation response.

Through the consultation process and the responses to the consultation, alternatives were considered as follows:

6.1 Additional alternatives proposed in response to the consultation

Many respondents supporting the proposals did not offer views on alternative or complementary measures, with some suggesting that alternatives were incompatible with the goal of increasing sandeel stock resilience. Those that did, suggested alternative options such as zero-TACs and the Norwegian model (including real-time monitoring and adaptative management) of sandeel stock management. We considered these responses, however since setting a zero-TAC would only be possible subject to agreement in annual negotiations; and since the Norwegian model would only result in partial restrictions of fishing therefore such alternative approaches would not be sufficient in moving towards achieving the envisaged ecosystem benefits that a full closure could bring.

In response to the consultation, one organisation suggested that to ensure the proposed measure effectively attains its objectives, it should be integrated into a holistic approach to forage fish management across all UK waters, via extended cooperation with other devolved administrations. The Scottish Government has engaged with the UK Government on the outcome of their consultation and welcomes the decision to close all of Area 4 in English waters, which will provide complementary benefits to the closure of all Scottish waters for fishing of sandeel.

6.2 Views on how the reasonable alternatives were considered

One respondent provided comments on each of the alternatives proposed. This response disagreed with the rejection of the alternatives 'no action taken' and 'extension of existing closure to all of sandeel management area 4 only' in the Environmental Report due to what they saw as limited benefits of the proposed closure. Our assessment is that the precautionary approach adopted from our scientific evidence base which takes account of the unpredictability in the system is valid, as discussed in Section 5.

This respondent also felt that the Environmental Report did not provide enough detail on what the alternative 'seasonal closure of the sandeel fishery' would entail. Seasonal closures can be an effective means of management in instances when releasing fishing pressure over a defined portion of the year protects an important period ecologically either for the fished species or their wider ecosystem (for example, to protect the breeding season). This was not determined to be an appropriate measure in this instance, as it was assessed that closing the fishery on a seasonal basis could result in moderate detrimental effects should the timing of sandeel availability to the fishery shift to outside the current fishing season, allowing sandeel to still be targeted outside the closure period. Therefore, it was determined that a seasonal closure would not be an optimal solution for the purposes of this closure.

Similarly, this respondent felt that the Environmental Report did not provide enough detail on the option 'voluntary closure of the sandeel fishery'. The voluntary closure proposed as an alternative would involve agreements between parties that jointly manage the sandeel stock in Scottish waters, which could be set as part of the annual international negotiations. It was considered that this could bring about the same benefits as the preferred option, but would require ongoing management costs. In addition, due to the reliance of the continuation of this measure being agreed during annual negotiations, this was not determined to be as strong a guarantee of a long-term closure and this alternative was therefore rejected.