Herring in the Firth of Clyde - recommending the total allowable catch 2025: consultation analysis

2. Overview of responses

During the consultation, a total of 18 responses were received via Citizen Space. Respondents to the consultation were asked whether they were replying as an individual or on behalf of an organisation. Eleven responses were received from organisations, and seven responses were received from individuals.

2.1 Analysis of responses and key themes

In total 18 responses were received, which comprised the following:

• Eight responses supported a rollover approach of setting a TAC of 583 tonnes, seven of which were submitted by organisations, and one submitted by an individual.
• Four responses suggested that a 0 TAC should be applied for 2025, of which one was submitted by an organisation and three by individuals.
• Two responses, submitted by organisations, stated that the TAC should be reduced. One of those respondents suggested a more precautionary TAC of 466 tonnes, in line with the 2022 TAC level. The other respondent did not propose a specific number.
• One response, submitted by an individual, stated that there should not be an increase but did not state whether the TAC should rollover or decrease.
• One response, submitted by an individual, stated that there should be an increase in TAC for 2025 but did not propose a specific number.
• Two responses from individuals did not indicate a position on the TAC recommendation.

The following points were made in response to the consultation, as reasons to set the TAC at 583 tonnes, which is maintaining the TAC level from 2024 and 2023 and between 2015 – 2021:

• Some respondents stated that, based on the provided scientific evidence there is no justification to change the TAC.
• Some respondents highlighted the need for additional data and offered to support initiatives which would aid with data collection, including some suggestions of work which could be considered. These included collecting additional scientific information about the Clyde herring stock and the wider ecosystem in the Clyde basin.
• Four respondents asked for the licences to be available by early August to allow for late summer fishing.
• One respondent suggested that a proportion of the TAC should be set aside to allow licenses to be available earlier in the year.
• One respondent suggested more work was needed to assess the effectiveness of the closure in the Ballantrae Bank spawning ground closure on the Clyde herring stock.
• Two respondents requested considerations be made to improve local infrastructure for landing herring in the Clyde.

The following points were made in response to the consultation, as reasons to reduce the TAC or set at 0:

• Many respondents highlighted a lack of evidence available on the stock as a justification to be precautionary and reduce or set 0 TAC until the time more robust evidence is available. They suggested methods of increasing the data, of which, one suggested a request to ICES and data collected from any landings of herring in the Clyde.
• Some respondents considered that the data shows the population is in a collapsed state with no signs of recovery and that it is dominated by juvenile herrings. They concluded that until evidence of recovery is shown, the TAC should be reduced, or fishing ceased.
• Some respondents suggested that the current management has not been effective in the recovery of the stock so there needs to be a change in the management approach.
• One respondent noted that there is no commercial reliance on this stock and that the state of the stock does not allow it to be commercially viable.
• Three respondents noted the low landings in previous years yet still little sign of recovery of the stock.
• Two respondents highlighted the population links between the Clyde herring and the wider west coast population therefore giving the rationale for setting a much more precautionary TAC or 0 TAC.
• Some respondents noted the lack of discard data.
• Two respondents stated that no fish zones should be put in place to preserve the stock and wider marine and biodiversity needs.

The one respondent who supported an increase in TAC suggested that doing so would allow for a sentinel fishery to take place and use that fishery to give an indication as to the state of the stock.

One of the respondents who did not indicate a TAC position made comments outside the scope of the consultation.