Inshore Fisheries Management Improvement: call for evidence analysis report

Part 2: Current Inshore Fisheries Management in Scotland

Question 3: What works well with the current national approach to inshore fisheries management in Scotland?

88 respondents provided details of what they think is working well with the current national approach to inshore fisheries management in Scotland. Some respondents stated outright that they believed that the national approach to inshore fisheries management works well within their answers, alongside supplementary information about what specifically works well. Where respondents provided context on what is not working well within this question, this is instead analysed as part of question 2. Fisheries management measures are discussed first, followed by stakeholder engagement mechanisms and then topics focussed on a broader context.

Fisheries management measures

Vessel monitoring technology

A common theme raised by respondents was the introduction of vessel monitoring technology, often referring to remote electronic monitoring (REM) of scallop dredgers. Some respondents felt that scallop REM has resulted in increased compliance and much fewer instances of illegal fishing. One respondent thought that this is helping to improve transparency whilst another commented that data should be used to support stock assessments. A small number of respondents felt that expanding vessel monitoring technology to the pelagic fleet or the under 12m fleet is a positive step to improving sustainability. One respondent felt this should be rolled out further, with another commenting that future roll out is expected.

Sandeel Fishery Ban

Some respondents were positive about the sandeel fishery ban as a measure which has worked well, with some remarking that it is a significant step forward. A small number of respondents reflected than the ban was helping to protect seabirds whilst one respondent felt that it safeguards fisheries and delivers on ecosystem objectives.

Ban on Berried Crab and Lobster Hens

Some respondents thought that the ban on berried crab and lobster hens has worked well. One respondent thought that this was an agile and long overdue measure, with one respondent stating they have noticed an increase in hen size as a result.

Outer Hebrides Creel Limitation Pilot

Some respondents were positive about the Outer Hebrides Creel Limitation Pilot, stating that it worked well and respondents have seen benefits from it. A small number of respondents felt that it resulted in improved catch per effort, financial gains and less gear conflict. A small number of respondents mentioned the tracking device used to monitor the pilot, with a small number of respondents stating that it provides an example of positive co-management. A small number of respondents stated that they wanted the Pilot to be reintroduced permanently. One respondent thought that this approach worked because it was a local approach to an issue. A small number of respondents thought that the scheme should be expanded across the west coast/ Scotland. One respondent summarised the positives of this Pilot:

“The introduction of a pot limitation scheme, again with fishers’ support, is another example of positive co-management of fishery assets. Fishers also worked with St. Andrews University to produce a cheap tracking device which has surpassed all expectations. The reduction in pot numbers also appears to have improved catch per unit effort and enhanced the size and quality of Nephrops caught.”

Minimum Landing Sizes

Some respondents felt that increases in Minimum Landing Sizes is an example of what has worked well with a national approach to inshore fisheries management. A small number of respondents felt they have noticed fish stocks improve and one respondent remarked on noticing an increase in the number of juveniles.

Electrofishing for razor clams scientific trial

A small number of respondents raised the razor clam scientific trial as being a good example of successful fisheries management. A small number of respondents felt that it requires fishers to commit to their legal responsibilities and felt it was positive that there is no scope for breaching of permits. A small number of respondents felt the tracking system used as a good example of work, and a small number felt it was positive that stock assessment work is required of participants. One respondent was supportive of the range of permissions needed to catch and sell razor clams.

Management in the Shetland Islands

A small number of respondents were supportive of the work that has been undertaken in Shetland, through the Shetland Islands Regulating Order and the Shetland Shellfish Management Organisations (SSMO). A small number of respondents thought that the system has had a positive impact and is working well. According to a small number of respondents, scallop, brown crab, lobster and whelk populations are doing well in the area, in some instances in better condition than elsewhere in Scotland. One respondent was supportive of the ability of the SSMO to commission additional data collection, which they felt helps support stock evaluations and certification. One respondent thought that the Shetland system should not be changed.

Stakeholder engagement mechanisms

Stakeholder engagement

Some respondents felt that stakeholder engagement and consultation is working well. A small number of respondents felt that there has recently been more effort to consult with a wide range of stakeholders, including coastal communities. A small number of respondents felt that this Call for Evidence displays an example of good communication and consultation regarding inshore management. One respondent felt that there is success when the fishing industry is engaged, with another highlighting that cross-sectoral discussions are beneficial. One respondent felt that public consultations are working well whilst another welcomed the opportunities presented to them to have face-to-face discussions.

RIFGs

Some respondents provided positive comments about RIFGs. A small number of respondents felt that RIFGs are useful for helping to discuss and identify local issues, which can then inform the Marine Directorate of the Scottish Government. A small number of respondents felt that RIFGs help to bring fishers together and leads to greater collaboration. One respondent felt positively about the Marine Directorate’s management of RIFGs with another praising the Shetland RIFG. One respondent felt that RIFGs enable fishers to have a direct point of contact with the Marine Directorate or with other fishers. One respondent felt that RIFGs have good potential.

FMAC & FMAC Inshore Subgroup

Some respondents provided positive comments about the Inshore Fisheries Management And Conservation (IFMAC) Group, now known as the FMAC Inshore Subgroup. A small number of respondents raised the view that it is a positive thing to have a forum such as the FMAC Inshore Subgroup where stakeholders are brought together for focussed co-management, with a small number of respondents highlighting that these forums are good places to discuss challenges and opportunities. One respondent raised the view that FMAC works well when it is based on fisheries topics, whilst another felt that FMAC does a good job of recognising that there are more interests than just those based on fisheries. One respondent positively noted the range of stakeholders involved in FMAC and another felt that FMAC enables engagement.

Broader context

Marine Protected Areas (MPAs)

A common theme raised by participants was comments related to Marine Protected Areas (MPAs), with positive comments made regarding MPAs that have fisheries management measures in place (e.g. restrictions on bottom towed fishing gear). Several respondents felt that there have been signs of recovery in places where MPA management measures are in place, with increased biodiversity and abundance. A small number of respondents felt the benefits that MPA measures give to low impact fishing. Some specific examples of areas where marine protection is successfully occurring were mentioned by a small number of respondents included the South Arran MPA and the Wester Ross MPA. A small number of respondents mentioned economic benefits that can result from MPAs with fisheries management measures in place, like more jobs, increased value of fish landings, supporting ports and providing benefits to the community. One respondent felt that the development of fisheries management measures for offshore MPAs is a positive thing, with one respondent highlighting that the introduction of MPAs is positive as it shows action is being taken to protect the environment.

Licensing

Some respondents were supportive of the use of vessel licensing in inshore fisheries management. A small number of respondents felt that licensing works well, with a small number mentioning that the ability of licenses to be enacted and varied at pace has been effective. One respondent felt that licensing has great potential for managing fisheries.

Future Fisheries Management Strategy

Some respondents identified the Future Fisheries Management Strategy as something that works well in inshore fisheries management. A small number of respondents felt that the Strategy provides a useful framework for fisheries management with others stating that it shows ambition. One respondent outlined support for the stakeholder participation and co-development approach to creating the Strategy, with another supporting the ecosystem-based approach of the plan and its alignment with the Blue Economy Vision.

National approach to enforcement

A small number of respondents thought that approaching inshore fisheries management nationally allows for rules to be kept fair for all fishers. One respondent felt that it is easier to enforce rules when they are the same nationally. One respondent thought that a national approach is better for boats that move between areas.

Scottish Government and Scottish Parliament

Some respondents made positive comments about Scottish Government and Scottish Parliament staff, with a small number of respondents specifically praising Marine Directorate staff (including policy, science and local fishery office staff) for always being willing to meet and praising their effort. A small number of respondents were positive about the Scottish Parliament for running events such as the Our Seas Coalition event in January 2025.

Legislation and frameworks

A small number of respondents recognised that the legislation and frameworks already in place to support inshore fisheries management can enact positive change and lead to a sustainable future. The UK Fisheries Act 2020; Marine and Coastal Access Act (2009); Marine (Scotland) Act 2010 and UK Marine Strategy Regulations were examples given of positive legislation and frameworks by a small number of respondents.

Resources

A small number of respondents reflected that some areas of resourcing for inshore fisheries management are working well. A small number of respondents thought that the amount of resource used for staffing (e.g. policy teams, scientists and local fisheries officers) are benefitting inshore fisheries management. A small number of respondents also thought that the support fishers received during the COVID-19 pandemic was helpful, and that other funding schemes have worked well.

Other

A variety of other areas that work well were identified by a small number of respondents. These include the emergency measure to protect flapper skate; maximum scallop dredge bar length; management of the wrasse fishery; running of pilot projects; introduction of seasonal closures; use of interim measures; recognising the importance of fishing communities; and fair treatment of fishers.

Question 4: What does not work well with the current national approach to inshore fisheries management in Scotland and needs to be improved?

A total of 97 respondents provided details of what they think is not working well with the national approach to inshore fisheries management in Scotland. Some respondents outlined that they felt nothing works well with current approach. In some cases they, and others, provided more detailed feedback on what they feel doesn't work well. These have been described under some broad headings for ease; wider marine environment, fisheries management measures, stakeholder engagement mechanisms and then topics focussed on a wider context. A number of the themes mirror those outlined in the previous question; sometimes due to opposing views, and sometimes highlighting a slightly different aspect of that theme that respondents felt were not working well.

Wider marine environment

Impacts of trawling and dredging

A common theme mentioned by respondents was that management of trawling and dredging is not working well in the national approach to inshore fisheries management in Scotland. A common theme mentioned by participants was that trawling and dredging is damaging the environment, damaging the seabed, impacting marine biodiversity and harming habitats, with current trawling and dredging activity not within environmental limits. One respondent stated:

“It is alarming that scientific and fisheries monitoring evidence shows that trawl and dredge fishing are not currently operating within environmental limits. This must be urgently addressed to prevent further harm to marine ecosystems.”

Some respondents felt that management of the marine environment is biased towards the benefit of commercial trawling interests, rather than for national, environmental and social interests. One respondent stated:

“Scotland’s inshore is a public asset that should be managed in a way that is transparently in the national interest, which is not the same as the interests of the commercial trawl industry. We critique the ‘current national approach’ on the basis that it appears to be primarily driven by the demands of the commercial trawl sector rather than the national interest.”

Some respondents raised the view that areas should have greater protection from trawling and dredging, including that MPAs should be better protected from trawling activity. A small number of respondents raised their view that there is limited monitoring or regulation of trawl and dredge activity even where it is banned in MPAs. Additionally, some respondents felt that inshore trawling and dredging should be banned, and that the 3 nautical mile limit should be reintroduced. One respondent stated:

“The extent of damage caused by bottom towed gear to seabed habitats means that there is an urgent imperative for the introduction of a ban on the use of all bottom towed gear in all Scottish MPAs (inshore and offshore) and in all waters within 3 nautical miles of the coast where nature and low-impact fishers should take precedent. Bottom trawling and dredging are simply not compatible with effective marine protection.”

A small number of respondents raised specific concerns about bycatch associated with trawl and dredge, highlighting that this can stop populations of marine species from developing, and can lead to the destruction of spawning sites. A small number of respondents raised the view that damage to the seabed releases carbon dioxide into the atmosphere, damaging blue carbon stocks. A small number of respondents raised the view that by allowing trawling and dredging, environmental policy and legal commitments are not being met. A small number of respondents felt that trawling and dredging are leading to economic loss. One respondent raised the view that there has been a failure to distinguish between fishing methods and their impacts, whilst another raised the view that there has been a failure to abolish dredging and other destructive fishing techniques.

Management within Marine Protected Areas

Although support for Scotland’s MPA network was a common theme within the previous question, criticism of the management of Scotland’s MPAs was a common theme within question four. Several respondents raised the view that there have been significant delays to the introduction of fisheries management measures in most MPAs, and felt that these are still not in place in most MPAs. Some respondents raised the view that MPAs are not being adequately protected, with either no protections in place or protections not going far enough and therefore activities that damage the marine area are still being allowed. A small number of respondents also raised the view that MPA management measures are not sufficiently policed, with reported poor compliance and enforcement. One respondent held the view that there are:

“Very poor levels of compliance of commercial fishing vessels in or around MPAs where there are management measures in place… [redacted] members have noted VMS systems being turned off on scallop dredge fishing boats as they approach MPAs where dredging is banned.”

One respondent felt that there are too few MPAs and that they are too small, leading to a patchwork of management. One respondent raised the view that current seasonal controls are not working. Another raised the view that the term ‘Marine Protected Area’ risks losing its meaning, because of the perceived lack of protection being provided to these areas.

Bycatch and entanglement

Some respondents raised concerns about the management of bycatch and entanglement. A small number of respondents felt that the Scottish Government is not effectively addressing bycatch and entanglement, including in MPAs. A small number of respondents felt that this is negatively affecting seabirds, marine mammals and non-target fish. A small number of respondents felt that Scotland is not meeting or making progress towards the bycatch regulations under the UK Fisheries Act 2020. One respondent felt that the Scottish Government needs to be more proactive in managing bycatch and entanglement.

Ecosystem approach

A small number of respondents raised the view that there has been a lack of ecosystem approach to managing inshore fisheries, with fisheries considered in isolation without consideration of other marine sectors or the environment. One respondent thought that the focus should be on protecting ecosystems rather than priority marine features as is the case at the moment.

Fisheries management measures

Vessel monitoring technology

Although support for the introduction of vessel monitoring technology was a common theme within question three, some respondents critiqued the rollout of vessel monitoring systems in response to question four, with the rollout of REM considered by some respondents to be inadequate and delayed. A small number of respondents felt that REM does not cover the whole fishing fleet, isn’t used efficiently and doesn’t go far enough. A small number of respondents felt that more needs to be done to maximise the use of REM to support enforcement and improve compliance.

A small number of respondents critiqued the data collected by tracking systems, with one respondent remarking that the resolution of VMS data is not good enough and one stating that there is overall a lack of spatial data. One respondent thought that all dredgers should have tracking on them and another thought that more should be done to use data to inform fisheries management. One respondent believed there has been an over-focus on using REM to support enforcement activities.

Creel numbers

Some respondents raised concerns about the number of creels being worked in the inshore area, with respondents highlighting that the quantity of creels used by individual fishers is increasing. Concerns raised by a small number of respondents include this negatively impacting the creel fleet and being “out of control”, with one respondent raising that this is leading to a lot of buoys in the sea and potential overfishing. One respondent also raised the view that the number of pots being discussed for pot limit schemes are too high.

Ban on Berried Crab and Lobster Hens

Despite some respondents stating that the ban on berried crab and lobster hens is working well in response to question three, other respondents have criticised it when responding to question four. A small number of respondents raised concerns about engagement and changing of rules, perceived to be without evidence, particularly related to the sudden exemption of the Solway Firth from the ban. Other concerns raised by singular respondents include: impacts of the ban on smaller vessels; unintended impacts on stock assessments; questions over what happens to female hens that berry in storage; different rules in different areas being unfair; and a perception that a national approach is not appropriate when stocks vary regionally.

Stakeholder engagement mechanisms

Engagement

Although some respondents felt that stakeholder engagement and consultation is working well in response to question three, a common theme raised by respondents in response to question four was that approaches to engagement are not going well in the current national approach to inshore fisheries management. Several respondents raised the view that a wider range of interests should be involved in discussions about inshore fisheries management, with several respondents raising that local communities (along with environmental interests, tourism and recreation) do not get a seat at the table, with too much of a weight on commercial fishers views. Some respondents thought that fishers themselves are not listened to, with some respondents raising that it is only the large-scale commercial sector who has a seat at the table. Some respondents feel that the large-scale mobile sector have their interests prioritised. A small number of respondents thought that voices representing fisheries interests should be given priority as they felt it was more important that fishers views are considered in fisheries management decisions over the views of others.

Some respondents felt that although there has been some effort to bring disparate voices of stakeholders together, such as through FMAC, that this has led to a lack of consensus and increased entrenchment of views. They felt this has led to delays and lack of progress.

A small number of respondents perceived consultations to be a waste of time and not an accurate reflection of stakeholders’ views. They felt that they are either not acted on or led by pre-conceived ideas. A small number of respondents commented that consultations are often promised and then do not occur, or are not published (e.g. inshore MPAs). A small number of respondents thought that there are not enough face-to-face discussions with stakeholders. One respondent commented that a national approach to fisheries management makes engaging locally challenging. One respondent thought that there is a lack of feedback loop once views are considered. One respondent felt that stakeholder feedback is not acted upon, with another commenting on poor stakeholder communication within the current model.

RIFGs

Whilst some respondents provided positive comments about RIFGs in question three, several respondents raised criticisms of RIFGs in response to question four. Some respondents outlined their perceived weaknesses of RIFGs, including poor chairing, a lack of balance and range of stakeholders, bias towards commercial mobile fishing, and a lack of transparency. One respondent felt that RIFGs lack knowledge whilst another thought they were a waste of time and money. Some respondents raised the view that RIFGs lack power or authority, and are seen to have no impact on national policy. Some felt they are not an example of successful co-management. A small number of respondents felt that RIFGs have failed to deliver regional management plans. A small number of respondents raised the view that RIFGs lack resourcing. One respondent raised concerns that the work of RIFGs often overlaps with that of associations, and another respondent felt that they thought the RIFG areas are too large.

Wider context

Environmental damage and decline

A common theme raised as something that is not working well with our current national approach shifting environmental baselines and decline in the condition of the environment and in the fishing industry. Several respondents raised the view that the health of marine ecosystems is in decline. Several respondents felt that biodiversity is declining (in the sea, and in seabirds), the health of the seabed and therefore carbon stocks is declining and that habitats (including benthic habitats) are damaged.

Some respondents raised the view that fish stocks are in decline, with many different species mentioned by participants, including Atlantic salmon, herring and commercial fish species in general. Some respondents explained the associated declines these are causing in the fishing industry. One respondent raised:

“One creel fisherman recalled how he would barely get past Ulva lighthouse from Mull when he would need to turn back due to a full catch, whereas now productive creeling is difficult due to the sparse population.”

Another felt:

“The commercial fishery in the Clyde has seen an unprecedented collapse, with fishing boat numbers plummeting by approximately 80% in most harbours—and in some cases, by 100%. For example, in 2006, Girvan was home to 16+ local boats, the majority of them trawlers. By 2024, that number has dropped to zero.”

Furthermore, some respondents felt the negative impact these declines are having on coastal communities and towns:

“All assessments highlight the losses and impacts occurring in the inshore marine environment. Aside from the losses to the commercial fishing industry, these impacts have affected many other people reliant on the health and productivity of the marine environment for business and recreation, e.g. loss of the once widespread and economically important recreational fishing activity in the Clyde marine region.”

A small number of respondents felt that declines have led to shifting baselines, where people are no longer aware what a healthy marine ecosystem should look like, with a consequent need to look further back than 10-20 years ago to see what damage has been caused.

Delays to implementation

A common theme raised by respondents as something that is not working well in the management of inshore fisheries in Scotland is a lack of action as well as delays to policy implementation. Several respondents felt that various Acts, laws, policies and frameworks (e.g. Fisheries Act 2020; National Marine Plan; Marine (Scotland) Act 2010; Future Fisheries Management Strategy) are already in place and could aid inshore fisheries management in Scotland, but have failed to be implemented, are not being followed, or require clearer implementation plans and governance. One respondent felt:

“Our inshore fisheries are not managed consistent with law and policy be that the Marine Strategy, the Sustainable Development Goals, the Marine Scotland Act.”

Some respondents raised the view that policy goalposts are created but are often not fulfilled, or are delayed or postponed. One respondent felt:

“Constantly disappointed by failed commitments - Ministers continually say they will do one thing, and then when the deadline comes, push it back two or even five years”

Some respondents listed commitments which they claim have yet to be achieved or implemented. These included Good Environmental Status; MPA management measures; reviving the Clyde; implementation of the National Marine Plan; widespread REM; regional marine planning; and assessment of wrasse populations. A small number of respondents felt that too much time is spent talking, and that change is not enacted urgently. Individual respondents felt that: there have been missed opportunities; research has not been acted upon; vessel license conditions have not been enacted with speed; decision-making conflicts with existing commitments; and that it appears the Scottish Government waits for a judicial review before action is taken.

Compliance and enforcement

Several respondents raised the view that compliance and enforcement of illegal fishing activity in inshore fisheries is not working well in Scotland. Some respondents raised the view that the penalties used are not a deterrent to illegal activity, that the prosecution system is long-winded with loopholes, and that enforcement is not done effectively, potentially due to a lack of resourcing. Some respondents raised the view that there is inadequate monitoring and enforcement of fishing activities on sea and land, and that illegal fishing activities are not being caught or stopped, with monitoring (by staff on shore or at sea) often predictable and outdated. One respondent felt:

“the fisheries patrol vessels are easy to identify and the trawler fishermen’s network very quickly spreads the word about where the vessel e.g. the Minna usually is.”

A small number of respondents raised the view that they believed compliance with fishing regulations is not good, numbers of fish can be falsified and gave examples of where they perceived illegal fishing to be occurring. Specifically referring to MPAs, a small number of respondents raised inadequate policing as a concern and thought there is poor compliance. A small number of respondents raised concerns about a lack of data and monitoring surrounding compliance. A small number of respondents raised issues with the regulations themselves, highlighting where some are unenforceable. A small number of respondents raised the view that enforcement is not occurring sufficiently to stop businesses (such as hotels and restaurants) buying illegally caught fish.

Lack of regional/local approach

Several respondents felt that the current national model does not work and in turn felt that a more regional approach is needed. Some respondents raised the view that the national approach is not working as fisheries are not suited to a ‘one size fits all approach’ and that regulations do not suit every area due to regional variations in the environment, fish species and fishing methods. A small number of respondents raised the view that national concerns are listened to over local or regional issues, leading to them being ignored. A small number of respondents raised the view that decisions are made by people who are distanced from the sea, and not aware of what is happening locally. A small number of respondents thought that there needs to be a greater devolution of power to local interests. One respondent thought that having a national approach stops local measures from being developed. One respondent felt that a national approach is not conducive to the objectives of recreational sea angling.

Data

Several respondents raised concerns that data and science are not working well to inform inshore fisheries management in Scotland. Several respondents felt there was a lack of data available to support decision-making and fisheries management, including data not being collected often enough, gaps in understanding, poor stock assessments, assessments occurring at the wrong time, lack of information about fishing activity, inadequate resourcing and delays in publication of findings. Some respondents were of the view that there is an overall lack of confidence in the data collected, with concerns about accuracy and neutrality reducing accountability. Some respondents raised the view that there should be better connections between fishers and data collection, with greater cooperation and use of fisher resource to improve the data available. A small number of respondents raised concerns that decisions are not being informed by data, and that data is being collected and not used.

A small number of respondents raised the view that there is lack of transparency regarding data, and often a lack of access available to it. One respondent felt that there has been a lack of work into emerging fisheries and fish stocks, whilst another perceived that academics and universities are not used enough to support data collection and use.

Marine Spatial Planning

Several respondents raised the view that they do not believe marine spatial planning is working well in Scotland. Several respondents raised concerns about fishing being dealt with in isolation and without alignment to other sectors (and the wider ecosystem) that use the marine space, with particular concerns raised about the apparent exclusion of fisheries management from the National Marine Plan 2. Some respondents raised concerns about spatial management of fishing being avoided generally, with it felt by some respondents that there is an unwillingness to put in place an inshore limit. A small number of respondents raised concerns about the lack of progress towards regional marine plans. One respondent felt that overall we have not succeeded to spatially manage the seas.

Central management

Although some respondents had made positive remarks about the Scottish Government within their response to question three, some respondents outlined areas where they felt the Scottish Government would benefit from improvements in their responses to question four. Some respondents felt that leadership could be improved within the Marine Directorate. A small number of respondents felt that the Marine Directorate would benefit from increased resources, with one respondent feeling that allocation of resources could be improved. A small number of respondents felt that the Marine Directorate must improve on delivery of policy commitments and seek to remove any legislative loopholes. One respondent outlined multiple perceived issues affecting the Marine Directorate including the current decision making processes and how this incorporates stakeholder feedback and best available evidence. One respondent felt the Marine Directorate would benefit from improving stakeholder communication.

Licensing and quota system

Whilst some respondents had outlined their support for the use of vessel licensing in inshore fisheries management in response to question three, some respondents outlined issues with our existing vessel licensing and quota system in their responses to question four. A small number flagged concerns about non-licensed vessels operating commercially, and/or felt that the lack of control on unlicensed “hobby” fishers undermines efforts of the licensed fishing fleet. One respondent felt that a reform of the current vessel licensing system is needed, as they felt that monetisation of them has been detrimental to the inshore fleet and makes it difficult for new entrants to access industry. Another felt that the allocation of quota and other management measures, such as licence conditions, should be underpinned by environmental good practice and efforts to improve sustainability and incentivise behaviour. On a similar theme, one respondent felt that a move to smaller boats with smaller and equal quotas would bring environmental benefits, placing more of the responsibility of protection on fishers from coastal communities. Finally, it was the view of one respondent that quotas are mismanaged across Scotland, with some fishers declaring landings across more vessels than are used to fish in a day.

Legislation

Whilst a small number of respondents recognised the positive change enacted by our existing legislation and frameworks within their responses to question three, a small number of participants cited issues with legislation when responding to question four. A small number of respondents felt issues relating to effort, partially that existing legislation does not provide effort control for creels. A small number of respondents felt that there are loopholes in legislation which makes it less effective for managing fisheries. Another felt that existing legislation to regulate effort by unlicensed “hobby” fishers is not being enforced. Finally one believed there is no legislation to require a minimum landing size for prawns. More widely on the theme of legislation, one respondent listed a number of legislative commitments that they do not feel are currently being met under the existing national model. Another felt that much more could be achieved using existing laws and policies, which they felt are currently underutilised.

Environmental organisations

A small number of respondents felt that the current nationwide model didn’t work due to input from environmentalists. A small number felt that they have slowed progress on fisheries management issues due to their high volume of Freedom of Information/Environmental Information Requests, and court challenges. One respondent felt that existing fisheries management in MPAs was brought in place to appease the “green lobby”. They felt that they were not justified by existing evidence and technology, and caused fishers to lose faith in the MPA engagement process. Another felt that their lobbying had resulted in a number of impractical proposals from the Scottish Government. One respondent felt that environmentalists use unsubstantiated anti-fishing industry information without validated scientific evidence to support their claims. Finally one respondent felt that inclusion of certain stakeholders within wider fisheries management prevents frank and honest conversations.

Resources

A small number of respondents mentioned resourcing issues in their answer. A small number raised concerns around Scottish Government resourcing and achievement of policy objectives. A small number felt that the Scottish Government don’t currently make good use of non-financial resources such as research support from industry, and that improved collaboration going forward could make better use of resourcing opportunities. One respondent felt that that resource for science is currently weighted towards the offshore area, resulting in more kneejerk reactions to inshore issues, slower science and a weaker basis for making management decisions. Another felt that a lack of resource is the biggest challenge facing the inshore sector, feeling that there is insufficient resource to adequately monitor, assess and manage the regional complexities of Scotland’s inshore fisheries. One respondent stressed that increased resource is necessary for good science, monitoring and compliance. A similar theme was noted by another respondent who felt that additional resource is needed to support an effective scientific framework to better understand of non-quota stocks.

Issues with large vessels

A small number of respondents felt that boats with a bigger tonnage cause disproportionate damage to fishing grounds due to the size and weight of their gear as well as high frequency of fishing activity. It was the view of one respondent that there is not enough incentivisation of smaller, more sustainable fisheries. Another felt the move to larger vessels had resulted in fewer individuals benefiting from our commercial inshore fisheries.

Recreation

A small number of respondents felt that the current format fails to consider recreational fishers. Within these, a small number felt that recreational sea angling has not been represented within inshore marine management, feeling that fisheries management has prioritised damaging fishing methods over protection of marine ecosystem including recreational finfish fisheries. One respondent felt that Scotland no longer has a thriving sea angling industry due to poor catches, and another felt that the current lack of controls on unlicensed “hobby” fishers undermines efforts of the licensed fishing fleet.

Balance of interests

A small number of respondents felt that the current national structure failed to balance different stakeholder interests. A small number felt that the current model focuses too much on addressing the demands of commercial fishing industry and not enough on wider stakeholder interests. One respondent felt that the current model has allowed inshore fisheries to become dominated by bottom contact fisheries. Finally another felt that the current model enables some policies or consultations to become overtly politicised by some organisations.

Competition in the shared marine space

A small number of respondents outlined issues with high levels of competition within the shared marine space, whereby they felt fishing grounds are being reduced to accommodate other marine industries. One flagged that this is most significant in the inshore area where fishers are less able to fish elsewhere, with another stating that this is increasing incidences of gear entanglement. One respondent felt that the impacts of spatial squeeze on fishing grounds must be assessed, with another feeling that the impacts of the squeeze on the fishing industry needs to be mitigated in light of other expanding marine industries.

Other

A selection of other topics where things are not working well were identified by a small number of respondents. These include: impacts on blue carbon; aquaculture impacts; impacts on the Clyde; gear conflict; the electrofishing for razor clams scientific trial; lack of three mile limit; lack of co-management; FMAC Inshore Subgroup and FMAC; Highly Protected Marine Areas (HPMAs); levels of uncertainty; difficulties in diversification; and pollution.