COAST response to RAINE Committee call for views on Clyde Cod Closure – February 2022

The Clyde Cod Box – well known amongst fishers and conservationists as a seasonal closure in the southern waters of the Clyde marine region – has long been subject to systemic failure within Marine Scotland and its preceding bodies. This year, it appears, is no different with the latest debacle playing out what can only be described as a real-life episode of “Yes Minister”.

For 20 years, a specific area in the Firth of Clyde has been closed to fishing to ‘protect’ spawning cod in response to the devastated stocks of a once thriving fishery. The greatest failing in the legislation to date was the exemption to allow destructive and highly impactful bottom-trawling and scallop dredging to continue thus negating any benefit from the ‘protection’.

To the delight of conservationists, Ministers recently announced the removal of these exemptions for the closure in 2022 and 2023. This was viewed as a positive step, showing substantial progress by the Scottish Government to take whitefish and cod recovery seriously. This said, there was a key issue in the new measures; creel-fishing and hand-diving were also to be excluded from the area in a move neither proportionate nor properly targeted, as low-impact fisheries such as these should not be dealt with in the same way as the mobile fishing sector, namely dredgers and trawlers.

In a series of strange moves by Marine Scotland in the weeks following the announcement, last minute changes to the closure Order have now been laid by Government which unduly favour the mobile fishing sector and reduce the size of the closure by 28% compared to previous years. Victim to the same failings as many other proposals for marine management, this proposal has not been subject to a transparent, publicly accessible consultation process and, alarmingly, there is a lack of robust scientific justification provided for the revised Order. The new closure area not only fails to include important cod spawning grounds (the one thing this order is in place to do) further north along the mainland Ayrshire coast, but a comparison of the closure with fishing vessel activity indicates the revisions better favour the mobile fishing sector while continuing to exclude the low-impact sectors.

The current focus of Marine Scotland’s fisheries management in the Clyde is not helping to recover the Clyde marine ecosystem. Our experiences over many years lead us to conclude that current fisheries management favours the mobile trawl and dredge fisheries with little or no consideration of the views of other stakeholders about the management of a public resource; the recent action around the Clyde Cod Box is yet another example of this.

This current approach of fisheries management by Civil Servants hampers progress towards the Scottish Government’s overarching aspirations for a healthy and productive marine environment that is resilient and can support the needs of Scotland’s people into the future. The Clyde seasonal cod spawning closure will ban creel fishing and hand-diving without any scientific evidence; introducing blanket bans in this manner not only leads to financial hardship on fragile communities, but to diminished support from static fisheries for other restoration, conservation and management measures. Clearly there is an urgent need for progressive fisheries management in Scotland’s inshore waters that supports ecosystem recovery, is based on sound science, and enables more sustainable fisheries to thrive.

Read COAST’s full submission to the RAINE Committee call for views here.