Sandeel fishing - proposed closure: consultation analysis

Introduction

This report provides an analysis of responses to the Scottish Government consultation on “Proposals to Close Fishing for Sandeel in all Scottish waters”. This public consultation ran from 21^st July 2023 to 13^th October 2023.

Policy Context

The Scottish Government would like to see a marine environment that is clean, healthy, safe, productive and biologically diverse and that meets the-long-term needs of nature and people. In July 2023, the Scottish Government initiated a consultation on proposals to close fishing for sandeel in all Scottish waters in alignment with Scotland's Fisheries Management Strategy.^[2]

Sandeel are a key component of the ecosystem of Scotland’s seas due to their role in marine food webs as a prey source for a range of species including seabirds, seals, cetaceans (e.g., whales, dolphins and porpoises), and predatory fish. Declines in sandeel abundance can negatively impact the survival and reproduction of ecologically important species.

Given the importance of sandeel to the wider ecosystem and the subsequent benefit provided by the species in aiding long-term sustainability and resilience of the marine environment, it remains an overarching Scottish Government position, reflected in Scotland’s Fisheries Management Strategy, not to support fishing for sandeel in Scottish waters. This position was emphasised in June 2021 when the Cabinet Secretary for Rural Affairs and Islands committed in Parliament to considering what management measures could be put in place to better manage the North Sea sandeel fisheries in Scottish waters.

There are several measures in place for the protection of sandeel stocks including through the network of MPAs. Furthermore, a sandeel closure in sandeel management area 4 has been in place since 2000, and the UK has not allocated sandeel quota to UK vessels since 2021.

A UK wide call for evidence in 2021 was conducted to gather information to better inform considerations for future management for sandeel and Norway Pout. The Scottish Government is committed to considering how best to manage fishing for sandeel in Scottish waters, with the aim to benefit both sandeel stocks and the wider ecosystem, including sensitive marine species.

Therefore, the Scottish Government has consulted on proposals to close fishing for sandeel in all Scottish waters. The proposal is driven by the importance of sandeel in marine food webs, supporting species like seabirds, seals, cetaceans, and predatory fish. ^[3] It also aligns with international commitments to protect marine biodiversity, and to take necessary measures to protect and conserve the marine ecosystem and the UK/EU trade agreement on sandeel quotas, prioritising sandeel protection, diverse ecosystem benefits, and complementing existing management measures in relation to sandeel (see Section A). ^[4]

This initiative prioritises effective sandeel protection, diverse ecosystem benefits, and complementing existing management measures, contributing to Scotland's Blue Economy and environmental goals.^{[5] [6]}

The consultation

The public consultation sought views and comments on several documents relating to proposals to close fishing for sandeel in all Scottish waters. These documents included:

• the consultation paper,^[7]
• a Review of Scientific Evidence, providing a review of the available scientific evidence on the potential effects of sandeel fisheries management on the marine environment, ^[8]
• a Draft Environmental Report, produced from the strategic environmental assessment on proposals to close fishing for sandeel in all Scottish waters, ^[9]
• a Draft Partial Business and Regulatory Impact Assessment, representing an initial assessment of the potential costs, benefits and risks of the proposals and their potential impact,^[10]
• a Data Protection Impact Assessment, explaining how respondents data will be handled.^[11]

The public consultation was undertaken with the purpose of bringing about wider environmental and ecosystem benefits. These include potential benefits to sandeel, seabirds, marine mammals, and other fish species.

The desired aims of the consultation were as follows:

a) To seek effective protection of sandeel, as a contribution to the wider marine ecosystem,

b) To provide the opportunity for wider ecosystem benefits to a range of species, including commercial fish species, seabirds and marine mammals, that will also improve resilience to changes in the marine environment,

c) To complement, as far as possible, existing sandeel management measures.

The consultation contained six questions – five open, and one closed with the space to provide further comments. The questions covered:

• Support to close fishing for sandeel in all Scottish waters (Question 1-2),
• Benefits or value in closing fishing for sandeel (Question 3),
• Impacts on island communities (Question 4),
• Cost and benefits of the option (Question 5),
• SEA Environmental Report (Question 6).

Appendix 1 contains a complete list of consultation questions.

Aim of this report

This report presents a robust and systematic analysis of the material submitted in response to the consultation. The structure of the report follows the structure of the consultation paper and considers the response to each consultation question in turn.

Approach to the analysis

The analysis seeks to identify the most common themes and issues. It does not report on every single point raised in the consultation responses. All responses, where the respondent has given permission for their comments to be published will be made available on the Citizen Space website.

Equal weighting has been given to all responses. This includes the spectrum of views, from large organisations with an international, national or UK remit or membership, to individuals’ viewpoints.

Tables demonstrating a breakdown of the number of responses to each question are included at the beginning of each section. This analysis report quotes and paraphrases some of the comments received. However, this does not indicate that these comments will be acted upon or given greater credence than others.

In line with qualitative reporting practices, phrases such as ‘many’, ‘several’ or ‘some’ have been used to indicate the volume of responses in relation to the particular points or themes discussed. Here, ‘many’ or ‘most’ can be understood as the majority of respondents, ‘several’ or ‘some’ as a smaller subset of respondents, and ‘a few’ as a minority of respondents. Phrases like ‘one respondent’ or ‘one participant’ are used where a respondent raised pertinent points that summarised, or contrasted, the views of others.

Comment on the transferability of the consultation findings

As with all consultations, the views submitted in this consultation are not necessarily representative of the views of the wider public. Anyone can submit their views to a consultation, and individuals (and organisations) who have a keen interest in a topic – and the capacity to respond – are more likely to participate in a consultation than those who do not. This self-selection means that the views of consultation participants cannot be generalised to the wider population. For this reason, the main focus in analysing consultation responses is not to identify how many people held particular views, but rather to understand the range of views expressed and the reasons for these views.