In autumn 2009 COAST made these four points to the Scottish Government as we move towards a Marine Bill

1. Has Marine Scotland since its inception in April 2009 changed from being a government department thats sole consideration is the extraction of fish & the production of farmed salmon? To be a department that balances both the environment with the industries that depend on that environment; also balancing the views of all sectors that value the marine environment, not just certain sections of the commercial extractive sector.
In COASTs opinion Marine Scotland (MS) are the same people with the same policies basically the same department as the old SEERAD. That just cannot understand that the foundation of any extractive industry is a healthy environment, they seem unable to make any decisions based upon the precautionary principle. The fishing & aquaculture lobby normally gets the Minister’s ear. You only have to look at the higharachy of MS to see that all departments are about extraction and not with an environment remit.

2. The present Government have proved with the way it has set up the new Inshore Fishery Groups (IFGs) and in its response to the EC Common Fisheries Policy that it does not understand the legality of the public right to fish, That the sea is a common resource. That everyone has a right to have a say in its management. Coastal & Island communities like Arran have over the last 12 years lost confidence in the government’s commitment to govern the seas for all Scotland’s people. The scientific history of the Clyde shows that a very important food resource has been squandered by bad management. COAST feels the Marine Bill is the last chance of any regeneration due to IFGs at present being controlled by the mobile sector of the fishing industry.

3. Enforcement of Marine Protected Areas (MPA) must be straight forward & simple or Scotland will just end up with more paper reserves.  COAST's experience over the past 12 months of the Lamlash No Take Zone is that a prosecution of anyone contravening the NTZ is virtually impossible. COAST feels that if Section 85 clause 2 (i) is included in the Marine Bill that there is absolutely no point in setting up any MPAs in the first place. Can anyone justify why fishermen or anyone should have any exemption from the law? COAST feels that there is a complete lack of political will to make enforcement of MPAs simple and straight forward. Both police and marine enforcement officers should be able to prosecute. Recreational and commercial fishermen should have to prove that they are not fishing if within a MPA rather than at the moment fishery protection officers trying to prove fish or shell fish was caught within the area. With the public, a fine and possible imprisonment imposed; With the commercial sector having their licence temporary withdrawn on first offence. On a second offence; permanent withdrawal of licence as well as fines and possible imprisonment must be imposed.This is what happens in other countries and has proved very effective.

4. Coastal Communities must feel that they are involved and have a feeling of ownership of their piece of sea. This is why COAST was delighted with the coastal communities’ designation on page 63 of the Sustainable Seas for All document. Unfortunately this now seems to have been dropped or made too difficult to obtain due to lobbying from sections of the fishing industry.  Without local involvement most MPAs will not succeed. COAST learned from the mistakes made in the early 1990s when the Government decided Loch Sween would be Scotland’s first Marine Reserve without consulting the local community at the start. The Government & SNH put in a huge amount of effort & finance into making Loch Sween a marine reserve. It was all wasted due to the initiative being only top down without the community stakeholders being involved from the start.