Commercial fishery for razor clams using electric current gear - consultation: strategic environmental assessment report

5. Evolution of the Environment Without Implementation of the Plan

A consultation outcome may be that the trial concludes and no form of fishing is permitted following that date. For the purpose of this report we consider this to be the evolution of the environment without implementation of the plan.

Prior to the trial, there was widespread illegal fishing for razor clams in the inshore zone around Scotland. Razor clams are a high value product and demand would not disappear. We make the assumption that this activity would resume to some extent.

Illegal, unreported and unregulated (IUU) fishing is a higher risk activity than fishing with regulatory oversight. We could expect there to be undesirable outcomes with relation to effects on biodiversity, flora and fauna, population and human health and material assets. These are summarised below and are likely in some aspects to be assessed qualitatively.

5.1 Biodiversity, Flora and Fauna

In a scenario with IUU fishing that we know from experience prior to the establishment of the trial is challenging to effectively police, we may expect fishing activity to proceed with no regard for the conservation and management objectives of the MPA network, or the national status of PMFs. This may result in:

• Disturbance to protected species, barriers to movement, preventing access to optimal habitat, adversely affecting prey availability through damage to prey-supporting habitat;
• Removal of razor clams with effects on biodiversity and ecosystem function;
• Harm to target and non-target species from unregulated high current devices;
• Dumping of catches overboard with unknown effects on the composition of seabed communities and predators

5.2 Population and Human Health

We may expect some level of clandestine fishing and sales of razor clams with no regard to food safety. Regulatory oversight has ensured where necessary that clams be depurated to avoid shellfish poisoning incidents. Regulators would no longer be sighted of these matters, increasing the risk to consumers of this product.

5.3 Material Assets

We know from previous experience prior to the trial that some illegal fishers would simply discard electric current gear overboard if they were expecting to be boarded by a Fishery Patrol Vessel or the police. This may not occur in a future prohibition scenario to the same extent, as the legality of fishing for razor clams at that time was tied to the method used, however there is currently no reason to have electric current fishing gear on board other than to fish for razor clams, as studies have found limited evidence of effect on other bivalve species.

Businesses that opt not to engage in IUU fishing may dispose of vessels, equipment and premises, all of which comes with a risk of materials entering the environment if not disposed of appropriately.

We may expect IUU fishing to lead to overexploitation, depriving future generations of the benefit of a fishing resource. This may take the form of simple overfishing of areas, or fishing clams during sensitive period such as the spawning window in spring.