Proposed inshore fisheries pilot host sites 2017: consultation analysis

Summary of feedback from the 'consultation on proposed sites to host inshore fisheries pilots 2017', which took place from 30 November 2017 to 22 February 2018.

The report provides Marine Scotland’s response to each pilot p

Proposal 2: Mull Crabbing Box

This proposal involves introducing a prohibition on mobile gear fishing and a limit on creel fishing effort in order to protect a brown crab fishery of local importance to Mull fishermen in the period 1 October to 31 January. The full proposal form can be viewed at and an overview is provided in the consultation document.

The consultation asked three questions in relation to this proposal (Questions 3 to 5).

Question 3: Do you agree that the pilot proposal for the Mull Crabbing Box should be taken forward by Marine Scotland as described?

There were 45 responses to this question, with 40 respondents (89%) expressing support for the proposal and 5 respondents (11%) opposing it.

The proposal received strong support from local organisations. This included the main local fishing association (Mull Fishermen's Association), as well as Mull Community Council, Mull and Iona Community Trust, South West Mull and Iona Development, Tobermory Harbour Authority and Argyll and Bute Council.

The proposal also received support from organisations in the wider fishing industry and environmental sector. Individual respondents in favour of the proposal included fishermen from both the static and mobile sectors with an active interest in the fishery, as well as others with a general interest in inshore fisheries management.

Those opposed to the proposal were all individual respondents, many of whom appeared to be mobile gear fishermen.

Themes from supportive responses

I. Economic Benefit

The main theme in comments, particularly from local organisations and individuals, was the belief that the crabbing box could contribute positively toward the socio-economic growth of the Mull area.

"We strongly believe that the measures proposed will improve the sustainability of both the mobile and static fishing sectors based on Mull. This will strengthen the economy of the Isle of Mull and contribute positively to efforts to reverse population decline." [Mull and Iona Community Trust]

"The local boats are very important to the island economy and they need to be encouraged. To date compromise between sectors has not been successful." [Individual response]

II. Gear conflict

Many cited the potential for the pilot to reduce gear conflict between mobile and static sectors.

"It would allow some local small boats to fish crab without worrying about visiting mobile gear boats towing their gear away." [Individual response]

III. Test ability for locally led management

Several responses from the fishing industry cited the proposal as a good example of locally led management, in particular highlighting the cooperation between the mobile and static sectors in agreeing the details of the crabbing box.

"There is local Island support from both sectors for this crab box which is also an achievement." [Organisation response]

IV. Other positive impacts

A range of other benefits that could accrue from the proposal were identified by respondents, including improving the sustainability of the crab stock / local marine environment.

"I believe the health of the wider marine environment - and, consequently the sustainability of fisheries - is dependent on severely restricting fishing activities in certain areas. Moreover the local fishing community is best placed to monitor those activities." [Individual response]

Themes from opposing responses

Those who did not support the proposal expressed a general opposition to the closing of grounds to mobile vessels, citing safety concerns and that many existing restrictions on mobile fishing were already in place. Their preference for improving management in the area was better communication between the different fishing sectors.

"Scallop dredgers are under severe restrictions now, especially in the winter season, on where they can fish. This is an area that could be managed more realistically with good cooperation instead of closures. Suggest setting up a steering group and points of contact to avoid gear interaction." [Individual response]

"No grounds should be closed to any sector of fishing, a properly managed fishery with good communication allows all sectors to work together, closing grounds creates unsafe fishing practices to be made when sheltered areas are closed. West coast boats tend to be open decked vessels where crewmen are out on a deck in rough weather with no protection." [Individual response]

Question 4: What is you view on the possible impact, both positive and negative, of the introduction of a seasonal restriction on mobile gear activity in the area for the duration of the pilot?

Positive impacts

I. Economic benefit

The potential benefits to the static gear sector and wider fishing communities in the surrounding area were highlighted.

"This is all about the long term sustainability of stocks and for the harbour this will result in more local boats and more local employment. We… hope to invest in new Phase 6 infrastructure for the fishing sector at Tobermory and we welcome long term sustainability." [Individual response]

"[This gives] the static gear sector real security during the period when traditionally the crab are in this box area. This is a real positive during a period when demand / prices are high and crab is traditionally on this ground." [Organisation response]

II. Stock / environmental impact

Potential benefits to both the brown crab and to a lesser extent the scallop fishery were highlighted in responses.

"…will protect both the intended species i.e. brown crab but also other species in the area as well as the habitat as mobile gear can be very destructive." [Individual response]

"Limiting or banning mobile fishing gear in an area will only serve to improve the productivity of that area for sustainable fishing practises (creels, diving for scallops) and allow non-targeted species to survive and flourish." [Individual response]

III. Other positive impacts

Other responses highlighted a reduction of gear conflict, the potential to test local management, and the impact for testing the impact of seasonal gear separation for the duration of the trial.

Negative impacts

I. Loss of fishing opportunity / negative financial impact

The most frequently cited negative impact was the loss of fishing opportunity / economic impact on those mobile vessels that currently fish in the area during the proposed prohibition period. However, many respondents believed any impact would be relatively small, and would be mitigated due to the area being open to mobile fishing for the remainder of the year.

"…if the current trend of areas of sea being closed off to dredging continues then it will force people out of this sector of the industry as many of the small individual operators don't have the ability to travel all round the British Isles to fish like large company owned vessels that fish 24hrs a day. These smaller inshore boats depend on areas such as this to work the year viably." [Individual response]

"Mobile fishers are able to work round seasons it is the nature of the job that they keep moving to areas where fishing is good the area proposed is tiny compared to vast areas wide open to them." [Individual response]

II. Displacement of effort

Mobile fishing effort being displaced was also cited in several responses, from different perspectives. Some were concerned about the impact on stocks outside the pilot area, while others were concerned that conflict could increase outside of the crabbing box.

"Could cause overfishing by scallopers surrounding the box through diverted effort." [Individual response]

"The mobile boats will trawl elsewhere, potentially increasing conflict there." [Individual response]

III. Does not go far enough to protect stocks

Conversely, some respondents commented that the prohibition would not offer enough protection to the area due to only being seasonal in nature.

"This proposal does not go far enough in my view in that it still allows the seabed to be seasonally trawled so has limited value in protecting the habitat and fostering regeneration." [Individual response]

Question 5: What is your view on the possible impact, both positive and negative, of whether a seasonal restriction on the number of creels in the relevant area should be put in place for the duration of the pilot?

Positive impacts

The primary benefit would be a control on the level of fishing effort in the proposed pilot area.

"By limiting the number of creels there will be a "control" over the fishing effort. The Mull creel fishermen have all agreed that this is essential so that no one boat can take excessive advantage within this very limited "crab box area". Not having a limitation opens up the scenario of 1 creel boat "flooding" the area with gear, thus not allowing the rest of the fleet access to the crab box." [Organisation response]

Additionally, a number of respondents also believed that a creel limitation could be of benefit to the health and sustainability of the crab stock.

"A reduction on the number of creels will hopefully strengthen stocks and help make the activity more sustainable." [Mull and Iona Community Trust]

Negative impacts

I. Difficulties in enforcement

A number of respondents cited the difficulty of enforcing a creel limitation during the closure period.

"This requirement could be unnecessarily onerous to implement and police and could possibly not be required at all in such a short duration pilot. It may be possible to implement a voluntary arrangement for the duration of the trial." [Scottish Creel Fishermen's Federation]

II. Displacement of effort

Others also suggested that limiting creel numbers within the proposed area could result fishing effort being displaced outside the area.

" WWF Scotland is somewhat concerned about the potential displacement of creeling into surrounding areas, and in particular the adjacent Loch Sunart to the Sound of Jura ncMPA, where creeling is not currently restricted. Given that the economic needs of local creel fishers will still need to be met through the winter months, consideration must be given to potential increase in creel activity in adjacent areas and the impact that may have on Priority Marine Features ( PMFs)." [ WWF Scotland]

Marine Scotland Response

Marine Scotland will introduce the Mull proposal as a pilot.

This was a considered proposal with a number of strengths:

  • It has a clear and specific management objective: to introduce a time limited prohibition on mobile gear fishing activity within a defined area, to protect the locally important brown crab fishery.
  • The proposal has been developed by an RIFG-led working group with a broad range of interests – including representatives of the static and mobile gear sectors, the Local Authority, and government bodies.
  • The proposal has been subject to a lengthy period of discussion to achieve consensus on the management measures, involving a series of RIFG-facilitated stakeholder meetings and workshops.
  • The proposal makes strong arguments for why the crabbing box was necessary, in that it would:
    • Protect the local economy and creel fishermen who benefit from the seasonal brown crab fishery
    • Protect the brown crab stock
    • Reduce gear conflict between static and mobile sectors
    • Improve the management of creel effort during the seasonal fishery
  • There was a clear rationale presented for the individual management measures being proposed, with the possible positive / negative consequences on existing fishing activities in the local area being well considered.

However, from Marine Scotland's perspective there are also weaknesses to the proposal, which include:

  • While consideration was given to who would monitor the pilot – through the established RIFG working group – little detail was provided as to what this monitoring would entail and how it would measure the pilot's effectiveness.
  • While consideration was given to controlling effort in the proposed crabbing box – by limiting creel numbers and vessels permitted to fish in the area – little detail was provided on how this would be implemented.


One of the key aims of the Inshore Fisheries Pilots initiative is to investigate the impact of separating different methods of fishing within a specified area. The Mull Crabbing Box proposal is well placed to assess the benefits of a temporal, spatial management approach, through introducing a prohibition on mobile gear fishing during a seasonally important time for local creel fishermen targeting brown crab.

The proposal was written with a clearly defined management objective, reached by the group through inclusive stakeholder engagement with both fishing sectors prior to consultation. It also achieved a broad level of support at the consultation stage, especially from local community organisations and fishing organisations.

Due to the overall strengths of the proposal and the positive response from consultees, Marine Scotland will proceed to introduce the Mull Crabbing Box as an inshore fisheries pilot. However, Marine Scotland does not intend to make creel limits mandatory for the first year of the pilot, to establish if local, voluntary controls on creel numbers can work effectively.


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