Consultation outcome

Summary of responses

Updated 8 March 2022

1. Foreword

The UK is committed to developing a world-class fisheries management system, supporting sustainable fishing and a diverse, profitable and sustainable fleet which serves the needs of coastal communities and contributes to the UK economy.

Collaboration between UK fisheries administrations, scientists, and industry is vital to ensure we work together to secure sustainability of our stocks, the environment, and a thriving industry. The Department for Environment Food and Rural Affairs (Defra) is, therefore, working with the Scallop Industry Consultation Group, the Shellfish Industry Advisory Group and its species-specific sub-groups to develop a future management programme for non-quota species. It was identified through these discussions that further evidence from wider stakeholders would increase understanding around whether current management of the under 15m scallop fleet is an area of concern. A 6 week call for evidence was launched in July 2021. This document provides a summary of responses to this call for evidence.

Fisheries policy and management is largely devolved, and the result of this call for evidence will be shared with all devolved administrations.

2. Introduction

The purpose of the call for evidence was to seek views on 3 key areas:

• impacts of unrestricted fishing on stock sustainability
• impacts of introducing restrictions on industry
• future management options

The call for evidence ran for 6 weeks from 19 July 2021 to 30 August 2021.

3. Number of responses

In total, the call for evidence received 18 responses. These consisted of:

• 9 fisheries organisations
• 6 individuals
• 2 non-departmental government bodies
• 1 representative of an environmental non-governmental organisation (eNGO)

Four of the above respondents wished for their responses to be kept confidential. We have therefore summarised 14 of the 18 responses.

4. Headline messages

79% of respondents agreed, to varying extents, that increased management measures for the under 15m fleet should be introduced to ensure the sustainability of scallop fisheries across the UK. Those who expressed concerns about introducing more management measures for the under 15m fleet were either worried about their business being adversely affected or that they would be overregulated if further restrictions were applied, given existing measures in inshore areas. 86% of respondents supported the need for improvements to management measures, and better information relating to stock status and the impact of the fleet on scallop fisheries.

There was some consistency in relation to the opinions provided and the type of respondent. Larger fishery organisations viewed regulating the under 15m fleet as a priority. This was mainly due to concerns that the under 15m fleet could be directly impacting stock sustainability where they fish unregulated. Additionally, they stated that depleted stock levels and poorly managed stocks impacts the entire fleet’s profitability and economic sustainability. However, under 15m vessel owners considered further restrictions would be detrimental to the economic viability of the fleet and their business.

It was generally agreed that imposing restrictions on the fleet exclusively in the Western Waters affected areas would be insufficient, as it would cause displacement elsewhere. Additionally, many respondents suggested that there should be a requirement to reform management of the over 15m fleet.

Several respondents stated that they would have preferred the inclusion of Scottish data in the call for evidence to provide a wider UK perspective.

5. Responses by question

5.1 Questions about the current under 15m fleet and management

Question 5 in call for evidence document: Please provide any evidence you have to assist our understanding about the scale and value of the current under 15m fleet (and wider sector).

Respondents provided mixed answers regarding the scale and value of the current under 15m fleet and wider sector. Several references were made to published reports by Seafish, the Marine Management Organisation (MMO) and the North Western Waters Advisory Council (NWWAC) as reliable sources of statistics for the scallop sector’s fleet size and value ^{[footnote 1]}.

Fleet Size

Responses analysing the scale of the fleet tended towards a comparative analysis rather than a quantitative one. For example, several respondents noted that the number of 10m-15m vessels in the scallop sector had grown significantly in recent years. Other respondents referenced a MMO report, which noted that the over 15m fleet accounted for the majority of landings (2017). One respondent stated that the scale of the under 15m fleet is difficult to understand without monitoring devices, for example (inshore) vehicle monitoring system (iVMS/VMS).

Three responses (across questions 5 and 6) from under 15m scallopers and organisations representing the under 15m fleet highlighted that poor weather conditions particularly affect the under 15m fleet as smaller vessels cannot handle adverse weather as effectively as the over 15m fleet.

One organisation noted the impact of coronavirus (COVID-19) and EU Exit, emphasising that some vessel owners were selling their boats or ‘mothballing’ them as a result of declining economic circumstances.

One respondent noted that as technological advances have increased vessel efficiency, the entire scallop fleet is at maximum capacity which is adversely affecting stock sustainability.

Value

Several respondents noted that king scallop fisheries represent one of the most valuable fisheries in the UK. Additionally, many respondents implied that to retain value for the UK scallop industry, additional management measures for the under 15m fleet are required to ensure the long-term sustainability of the stock and the industry.

Two organisations detailed the costs behind running an under 15m vessel. Both discussed the high selling price of under 15m vessels. One of the respondents explained that the under 15m fleet have lower running costs than the over 15m fleet, so they can fish whenever the weather allows to maximise profitability. The other organisation emphasised how increasing business costs disproportionately impact the under 15m fleet, as under 15m vessel owners are more likely to be independent businesses.

One respondent noted the vital importance of the under 15m fleet in supporting local coastal economies.

Question 6 in call for evidence document: Please provide any evidence you have on the impact of the under 15m scallop fleet on scallop stocks

Responses analysing the quality of scallop stocks either stated that they were being fished unsustainably or there was not enough data to understand current stock levels. Several respondents concluded that while there are difficulties behind understanding current stock levels, greater regulation is still required to protect the stock, as an unregulated sector becomes a risk to sustainability. One respondent mentioned that they were previously able to fish all year round but now, due to significantly lower stock levels, they are limited to shorter periods throughout the year.

Several respondents emphasised that the entire scallop sector requires improved management to ensure sustainable, effective management of stocks, and this is imperative given the increasing concerns of fishery sustainability around the UK.

An independent respondent stated fishing pressure on scallops in waters surrounding Northern Ireland has increased since scallop fishing has been prohibited in the Irish Sea between June to October. This has limited many of the local, smaller boats to within Northern Irish inshore areas.

Question 7 in call for evidence document: Please provide any evidence of the impact of the lack of restrictions on the under 15m scallop fleet in the wider fleet context

Responses to this question were mixed.

There was a narrative that a lack of restrictions on the under 15m scallop fleet could potentially undermine management measures to develop sustainable fisheries. For example, 5 respondents referenced that the 10mto 15m scallop fleet has been the fastest growing part of the sector, and that this growth is likely to have an impact on the sustainability of the stock. Two other respondents suggested that the under 10m/12m fleet requires greater regulation, particularly in inshore areas. Two respondents stated that whilst under 15m scallop fishing activity is monitored, it has not been managed to the 1998 to2002 baseline required by the Western Waters effort regime. They noted that this is partially due to the lack of fishing activity data available for the under 10m sector during this period.

Some responses questioned the link between lack of restrictions on the under 15m fleet and stock sustainability. One respondent stated that it was difficult to prove that the stock is being disproportionately impacted by the under 15m fleet. Another respondent pointed out that while smaller vessels will have some impact on stock sustainability, larger vessels will have a higher impact and are more likely to be fishing consistently due to the rotation of crews. Additionally, they added that fishing practices have changed significantly since the Western Waters effort regime was introduced, with more modern and efficient vessels of all sizes impacting the sustainability of the stock.

Two respondents noted that the under 15m fleet is already managed and does not face a lack of restrictions, as they are governed by various regional regulations.

Questions about the impact of different management measures for under 15m scallopers

Question 8 in call for evidence document: Please explain whether you consider the proposed area scope, for example the Western Waters area, appropriate. Please provide any additional evidence you may have to support your view

Responses to this answer generally considered the proposed geographic scope of Western Waters to be too limited and suggested that if management measures were to be introduced, then they should be UK wide. Some respondents also suggested that the scope of management measures should be extended to all vessel sizes. Almost all respondents believed that some level of displacement would occur if restrictions were only applied to the Western Waters area.

Scope

Eight responses stated that to ensure sustainability and limit displacement, all areas surrounding the UK should have management measures introduced for the under 15m fleet, not exclusively the Western Waters area.

Some respondents suggested that a ‘one size fits all’ approach would not be productive. For example, one respondent referenced issues that could arise from differing regulations between inshore and offshore areas. They specifically noted how stock conservation efforts that have taken place in the Isle of Man Territorial Sea have resulted in increased effort in areas that have less restrictions.

Displacement

Many respondents stated that if restrictions were introduced to the Western Waters area only, this could cause displacement to other areas, for example the North Sea. Some respondents, however, noted that the under 15m fleet is less nomadic than the over 15m fleet, so only a portion of the under 15m sector would be able to seek out fishing opportunities elsewhere.

Question 9 in call for evidence document: Please explain what type of management measures (if any) could be introduced. Please provide any additional evidence you may have to support your view

There was a wide variety of recommendations provided in response to this question. They have been summarised as follows:

• closed seasons

Many respondents suggested the introduction of closed seasons to allow stock and ground recovery. Some respondents emphasised that this would have to be done cautiously to prevent mass migration of the scallop fleet from one site to another, and it would be imperative to coordinate a rotational closure system to lower the risk of this occurring.

• total allowable catch (TAC)

While this suggestion was popular, four organisations emphasised that they would only support this management measure if limits were scientifically based. They also recognised that it would take time to introduce this approach. One respondent aligned their support for a TAC approach with the introduction of landing limitations, as introduced under the UK-EU Trade and Cooperation Agreement (TCA), noting that the UK could use this as a driver to develop a catch limit-based management system.

• permits for under 10m vessels fishing for king scallops and all vessels fishing for queen scallops

Respondents recommended the introduction of permits for under 10m vessels fishing for king scallops. Additionally, some respondents recommended that permits should be introduced for all vessels fishing for queen scallops.

• capping unused scallop entitlements

A reference was made to the NWWAC report ^{[footnote 2]} that concluded that if unused licences were taken up, then it would result in substantial pressure on scallop fisheries. No evidence/ views were provided on the likelihood of latent licences becoming active.

• combination of a number of technical measures; including mandatory iVMS/VMS

Technical measures were recommended more than once across responses, as well as a range of other management measures, including geographically specific effort regimes, banning weekend fishing and decreasing the number of dredges worked.

Some respondents also highlighted concerns about existing management measures. Several respondents stated that the Western Waters effort regime was ‘unfair’, ‘performed poorly’ and that it should be replaced.

Question 10 in call for evidence document: Please provide evidence you may have to show the possible impact of greater management measures on the under 15m fleet on business

Responses to this question were mixed.

Four respondents stated that they would expect to see positive benefits to business as soon as catches and/or effort is limited effectively in both the EU and UK Exclusive Economic Zones (EEZ) as a result of stock recovery. However, they accepted that benefits would only be realised after the initial economic shock caused by the introduction of any restrictions.

Introducing measures to ensure that business is not adversely impacted was a prevalent theme in the responses to this question. Four respondents expressed concern at the possibility of displacement into the under 15m sector from less restricted parts of the scallop fleet and other fishing sectors if the under 15m fleet were not sufficiently regulated.

Others made a link with the economic hardship that the scallop sector is currently facing (one respondent noted the number of dredgers currently for sale) and highlighted that restrictions could potentially make this worse.

One respondent indicated that further restrictions would make their business unviable.

Questions about other fishery management measures

Question 11 in call for evidence document: Please provide any evidence you may have to support the view that introducing greater management measures to the under 15m fleet should be addressed as a priority. Which ones should be prioritised?

Eleven respondents agreed to some extent that greater management measures should be introduced for the under 15m fleet. Most respondents did not recommend specific measures to prioritise but instead focused on why they considered the under 15m fleet a priority to manage or not.

Prioritisation

Several respondents stated that introducing measures to the under 15m scallop fleet should be a priority as their exclusion from the current Western Waters Effort Regime is not effectively managing stock levels. One respondent emphasised that the current active fleet is already over capacity and that unregulated fishing is undermining a number of the objectives set out in the Fisheries Act (2020) including on sustainability, ecosystem protection, available scientific evidence and climate change.

Several respondents emphasised that introducing more effective measures for the over 15m fleet was just as important as for the under 15m fleet, given that this size vessel contributes the largest proportion of scallop landings.

One respondent emphasised that there should be a dialogue between the Fisheries Administrations and Crown Dependencies to draft geographically specific measures, as a ‘one size fits all approach’ may fall more heavily on some parts of the under 15m fleet than others.

Measures to Prioritise

Measures suggested for prioritisation included:

• fitting iVMS/VMS/Automatic Identification Systems (AIS) to all vessels
• capping all vessel size catch to a level no higher than the present catch limits
• rotational closures

Further Evidence

Question 12 in call for evidence document: Please provide any other relevant evidence you would like to include in relation to scallop fleet management measures in the UK

The intention of this question was to capture any other evidence that had not been provided in the previous questions. This question had the least but most varied responses. Many respondents summarised the points they had made in previous questions.

One respondent outlined how measures are already being introduced to improve the sustainability of stocks within the Western Waters areas.

A few respondents highlighted their full support for the management proposals put forward by the Scallop Industry Consultation Group in 2019. These proposals include better regulation of the under 15m scallop sector, including permits for the under 10m scallop fleet, consideration of the risks posed by inactive licences (latent capacity), introduction of a TAC, harmonisation of UK management regimes, for example dredge number limits, expansion of the Western Waters effort regime to include all vessels, and closed areas/seasonal closures.

Another respondent highlighted that they would be content with the continuation of a days-at-sea effort regime.

One respondent emphasised that stock management needs to be informed by thorough stock assessments. The same respondent stressed that the scallop fishing industry is struggling and that further controls would impact it further.

One respondent highlighted that sustainable management instils confidence, creates jobs, and benefits coastal communities, and that there is an absolute requirement to address current environment issues in the scallop sector.

6. List of organisations that responded

• Cornish Fish Producers Organisation
• Macduff Shellfish
• Manx Fish Producers Organisation
• Natural England
• Open Seas
• Scallop Industry Consultation Group
• Scottish White Fish Producers Association
• South Western Fish Producer Organisation Ltd
• Southern Inshore Fisheries and Conversation Authority (IFCA)
• Western Fish Producers’ Organisation Ltd

7. Next steps

Defra continues to place the utmost importance on the protection and sustainable management of scallops, shellfish and other non-quota species.

The responses to this call for evidence highlighted concerns about the sustainability of scallop fisheries across the UK and significant support for the introduction of increased management measures for the under 15m scallop fleet. On the basis of the sustainability concerns highlighted, we will seek to develop a reformed regime, in collaboration with industry, that will apply to all scallop fishers. Given the differing opinions and perspectives regarding the preferred management approaches to adopt, we intend to work with industry through development of Fisheries Management Plans (FMPs) to explore and then consult on wider reform and specific management measures.

1. Motova, A., Curtis, H., Quintana, M. and Metz, S. (2016) Seafish Economic Analysis: UK 15m and over scallop fishing fleet in ICES Area VII. ↩

2. Cappell, R., Huntington, T., Nimmo, F., and MacNab, S. (2018) UK scallop fishery: current trends, future management options and recommendations. ↩