Seal licensing system: third review

5. Recommendations from the 2020 review

The previous review was published in September 2020. That review considered the various aspects of the system, with four recommendations for further improvements described below. Each section outlines the original recommendation and an overview of the action taken.

5.1 Seal licence application forms

5.1.1 2020 Recommendation

A new application form which encompasses all licensable purposes should be developed for any future applications to kill or take under the purposes of S110 of the 2010 Act.

5.1.2 Progress

The seal licence application form and associated guidance was updated in 2021 to reflect the removal of two licensable purposes – protecting the health and welfare of farmed fish (S110(1)(f)) and preventing serious damage to fisheries or fish farms (S110(1)(g)).

The new application form was specifically designed for the purpose of conserving seals or other wild animals (including wild birds) or wild plants (S110(1)(c)), as this is the purpose for which the majority of licence applications are submitted. Queries for any other licensable purpose can be made directly to md.marinelicensing@gov.scot.

The new form requires applicants to specify the river on which it is proposed to kill seals, the river conservation grade, and to provide a detailed description of the section of specified river including identifiable landmarks and Ordnance Survey grid references. A separate seal licence application must be made for each river.

For each application, a detailed description is required of the behaviour of the seal, how the seal is causing damage to the population of another species, predation data and circumstances relevant to the river where killing a seal may be required to conserve another species. The applicant must also describe all other measures that are currently used to enhance conservation of the species and how the killing or taking of seals fits into the wider management of the river.

Applicants must provide a detailed explanation of the non-lethal measures they have undertaken to deter seals from entering the river, including physical barriers, harassment, translocation, and acoustic deterrent devices.

Finally, a method statement must be provided that demonstrates how killing of seals is the last resort in the section of river, with reference to the description of the behaviour of the seal; non-lethal measures that have been attempted for every seal identified; and how these have been shown to be ineffective before a seal is killed. Adherence to this method statement is the condition of a seal licence, if granted.

5.2 Seal carcass recovery

5.2.1 2020 Recommendation

Further work is required to encourage recovery of seals killed and reporting to the Scottish Marine Animal Strandings Scheme (SMASS).

5.2.2 Progress

It remains a condition of licences that carcasses should be recovered where it is possible to do so. Furthermore, it is a condition of seal licences that, in addition to recovery, all carcasses should be reported to SMASS where possible.

While seal licences have been granted for the purpose of conserving wild Atlantic salmon during the period of this review, it should be noted that no seals have been shot under this purpose .

5.3 Seal management Code of Practice

5.3.1 2020 Recommendation

The Code of Practice should be updated to reflect the most up to date science and the changes to the purposes for which licences can be granted.

5.3.2 Progress

Due to the limited number of licences granted during the review period, updates to the Seal Management Code of Practice have not been progressed.

5.4 Non-lethal measures

5.4.1 2020 Recommendation

Work should continue in the aquaculture and river fisheries sectors to improve the efficacy of non-lethal measures in deterring seal predation.

5.4.2 Progress

The Scottish Government continues to support research to improve understanding of seal-salmon interactions and investigate non-lethal measures to manage these interactions in Scottish rivers. This has included research to develop an automated ‘detect and deter’ system using a triggered Acoustic Deterrent Device (ADD), with collaborative trials underway in different river conditions, which will provide an improved understanding of the efficacy of non-lethal measures in different riverine environments. Annual reports for this research can be found on the Marine Mammal Scientific Support programme website. Additional funding and collaboration will be required in the future to allow the system to be tested more widely.

Several District Salmon Fishery Boards (DSFBs) also continue to trial ADDs in rivers.