Commercial fishery for razor clams using electric current gear consultation: partial BRIA

13. Summary and Recommendation

No option is being recommended in advance of consultation. Following analysis and consideration of consultation responses, a recommendation will be made to Ministers. A Full BRIA will be published at this time making this clear.

13.1 Option 1 (Do Nothing)

13.1.1 Total benefit per annum: economic, environmental, social.

This is the ‘Do Nothing’ option so has no additional benefits.

13.1.2 Total cost per annum: economic, environmental, social.

The loss of a low-impact and sustainable fishery will impact up to 90 jobs, though as fishing businesses have licences to target other species, we do not understand the reduction in employment we may expect, in absolute terms.

Although this is the ‘Do nothing’ option it would have regulatory and enforcement costs which were between £1.5-2 million pre-trial and we would expect increased enforcement resource demands with this option.

13.2 Option 2 (Commercial Fishery)

13.2.1 Total benefit per annum: economic, environmental, social.

Aligns with Scottish Government policy to link economic activity with the local area. The arising benefit would be limited to a small number of vessels targeting razor clams using the electrofishing method. The policy aligns with the national benefit objective in the Fisheries Act 2020 (to support coastal communities and maintain the role of the seafood sector in employment and food supply). Another benefit of this option is that it keeps any fishing activity in regulated oversight which maintains the environmental benefits of sustainable fishing activity. In 2024, active trial vessels landed 546 tonnes of razor clams, at a value of £4.5 million. 22 vessels had derogations allowing them to participate and 81 people were employed throughout 2024. Depending on the scale of the limited fishery, this may remain similar in scale or vary. We consider it is possible for the scale of fishing to increase slightly in some areas. Our fisheries assessment has found that currently authorised activity can continue with some changes to ensure potential risks to protected species are reduced.

13.2.2 Total cost per annum: economic, environmental, social.

Vessels could potentially incur costs related to REM and data management for compliance reasons in a future razor clam fishery. Different regulatory options to be explored which may involve cost to businesses in demonstrating suitability to be authorised to fish. Regulators may also face costs if requests for shellfish classification increase dramatically. Prices are sensitive to demand, and an influx of new fishers may undermine the viability of fishing for razor clams in some cases, requiring careful control on the size of the fishery.

13.3 Option 3 (New Scientific Trial)

13.3.1 Total benefit per annum: economic, environmental, social.

Aligns with Scottish Government policy to link economic activity with the local area. Balances continued activity with other uses of marine space. The arising benefit would be a more robust scientific evidence base for stock management or understanding impacts on non-target species. We note these could be progressed in a commercial fishery setting.

13.3.2 Total cost per annum: economic, environmental, social.

Some administrative and policy costs to determine the correct mix of approaches. Vessels could potentially incur costs related to REM and data management for compliance reasons in an alternative razor clam scientific trial. This option may also be more complex to regulate, if there were two tiers of regulation on razor fishing (scientific/commercial) to oversee.