Ongoing and Future Fisheries Management
13. The 2019 SSI make provision which achieves the particular requirements of the closure. These provisions provide a degree of legal protection to spawning cod at the correct time and place, whilst allowing for some fishing activities to continue. Furthermore the closure complements other similar closures in the region, including the Irish Sea closure which, since 2001, has taken place at the same time of year as the Clyde closure.
14. In January 2020 the Convenor of the Rural Environment and Connectivity Committee, acting upon representations from The Community of Arran Seabed Trust (COAST), requested that the exemptions granted to Nephrops trawlers, creel and scallop dredgers were removed from the 2019 and any subsequent SSI providing for the Clyde Cod closure. In response to that request the then Cabinet Secretary committed "…to use the period before the next iteration of the Order (due in force in 2022) to consider the case for the exemptions more closely. Through further consultation with stakeholders, this will consider current science, cod bycatch levels, achieving consistency with conservation measures currently being introduced for cod in the North Sea, and other factors related to Clyde fisheries." EU Exit and the Covid-19 pandemic limited the team's ability to consider and respond to the Convenor's request in 2020; we had intended to consult on this matter in autumn 2021 in respect of the forthcoming SSI.
15. However, on 20 August 2021, the Scottish Government and the Scottish Green Party (SGP) published a shared draft policy programme, setting out areas of collaboration over the current parliamentary term. This document sets out a number of policy objectives which will affect inshore fisheries in Scotland including the Clyde, such as:
- Enhanced fisheries management measures for existing Marine Protected Areas (MPAs) and other key coastal biodiversity sites;
- Designating a suite of Highly Protected Marine Areas (HPMAs) covering at least 10% of Scotland's seas; and
- Additional specific evidence-based measures to protect the inshore seabed.
16. The Scottish Government and the SGP plan to consult as soon as practicable on these policy objectives. It is likely that such consultations will cover the area of the Clyde covered by the forthcoming Clyde cod closure SSI. In order not to forestall and to minimise any overlap with these wide-ranging consultations, this consultation only seeks views on the continuation of the Clyde cod closure measures already provided for, including the exemptions. It is important that there is no gap in these closures to ensure that spawning cod remain protected to prevent further decline to the stock. In the event that the planned Scottish Government and SGP consultations do not cover this area, we will act on the Convenor's request as part of the next biennial consultations.
17. In terms of other ongoing management initiatives, Scottish Ministers committed to a programme of research and practical measures called 'Clyde 2020' to contribute to restoration of the Clyde marine ecosystem. Following the recommendation by Clyde 2020, there are a number of ongoing research projects in the Clyde. As such the Clyde Marine Planning Partnership have been developing The Clyde Regional Marine Plan to ensure sustainable and co-ordinated management of the region. We understand that the regional Inshore Fisheries Group and CFA will input into the CMPP in respect of fishing interests. Further details can be found at the following link: https://www.clydemarineplan.scot/
18. Our Future Fisheries Management Strategy makes a commitment to work with our stakeholders to deliver an ecosystem based approach to fisheries management, including considering additional protections for spawning and juvenile aggregation areas in Scottish waters.