Annex B - Example Reply from Marine Conservation Society
According to the Scottish Government's own Marine Atlas, the health of virtually every broadscale habitat type is a matter of concern and/or decline throughout Scotland's waters, and fishing is identified as one of the two widespread drivers for this. With metal teeth ploughing up to 10cm into the seabed, in the wrong place scallop dredging is amongst the most damaging of fishing activities, particularly to living reefs, maerl beds, fish and shellfish nursery grounds and other stable, ecologically complex habitats. It is therefore deeply disappointing that following the 2012 scallop dredging review and subsequent 2013 Poseidon report 'A Review of the Scottish Scallop Fishery', the Scottish Government has singularly failed to take this opportunity to consult on a strategic management plan for scallop fisheries in Scottish waters, including spatial measures, to ensure the fishery plays its full role in halting and reversing the declining trend. The scope of the consultation and measures proposed within it fall far short of what is required.
The Scottish MPA process identified sites for designation based on the presence of priority marine features ( PMFs), including maerl beds, horsemussel reefs, flameshell reefs, fan coral communities and kelp habitats on sediment. Whilst we recognise the parallel consultation on fisheries management measures for at-risk inshore Special Areas of Conservation ( SACs) and nature conservation MPAs ( ncMPAs) to deliver their nature conservation objectives, even the most ambitious protection plans will not nearly be enough to help secure a sustainable Scottish scallop fishery. Both within and outside of designated sites, priority marine features, nursery grounds and other complex, biodiverse habitat remain exposed to damage from scallop dredging and other heavy bottom-towed fishing gear. Evidence is growing that closing areas to dredging and trawling increases the extent of complex seabed, encourages settlement of scallop spat, significantly increases the age, size and biomass of adults and contributes positively to sustainable fisheries.
Just as in 2012, the proposals in this consultation remain woefully inadequate for developing a management framework for sustainable scallop fisheries and will not contribute to Scotland meeting its many obligations to conserve and recover marine species and habitats. An important opportunity is being missed to fully consider the measures urgently required to address the wider environmental impacts of the king and queen scallop fisheries to support a truly sustainable industry. To contribute to delivering a three-pillar approach to marine nature conservation, the legal requirement to protect and enhance the health of our seas, the objective of securing a sustainable king scallop fishery and the need to address the queen scallop fishery, I ask the Scottish Government as a matter of urgency to:
1. Deliver strategic management - map king and queen scallop dredge and dive effort in Scottish waters and develop a strategic management plan to include spatial and effort measures.
2. Introduce a low impact zone from shore to 3 nautical miles to include fully protected areas, areas just for static gear fisheries and scallop divers and areas for other low impact uses such as recreation. Shetland, Wales and the Isle of Man provide approaches to be learnt from;
3. Introduce closed areas, additional to those needed within SACs and ncMPAs, to protect living reefs, priority marine features and other sensitive, complex seabed habitats from scallop dredging wherever they are found
4. Introduce spatial reserves, or scallop regeneration areas, permanently closed to all types of fishing to protect important scallop and nursery grounds
5. Increase the minimum landing size of king scallops to 110mm
6. As a minimum cap current effort, remove latent capacity and freeze the footprint to prevent fishery expansion and apply further effort management as required
7. Introduce an inshore curfew to prohibit scallop fishing within 6 nautical miles of shore during agreed hours at night