NW Coast Report on Consultation re Proposals to Manage the Crab and Lobster Fishery

Report on Consultation into Proposals to Introduce Measures to Manage the Crab and Lobster Fishery in the NW of Scotland.

Introduction

In late January 2024 the Marine Directorate requested the NW Regional Inshore Fishing Group to consult with members of the industry and report back their views in time for the forthcoming Fisheries Management and Conservation Inshore Sub-Group meeting which, at that time, was being scheduled for late February.

This report provides a written record of actions taken and views expressed during this process.

Actions Taken:

Four evening meetings of the industry and their representatives were arranged to be held. One meeting each in of Broadford, Mallaig, Ullapool and Lochinver. Online access was arranged for the Broadford meeting and an ad-hoc online link was established for the Mallaig meeting to accommodate fishers from the Small Isles, who could not easily travel.

The meetings were attended as follows:

Location

No Attending

No Attending Online

Broadford

25

6

Mallaig

18

2

Ullapool

9

0

Lochinver

7

0

Total

59

8

Views Expressed at Meetings

All meetings were very constructive and insightful. No party was disinterested, as evidenced by the turnouts and all contributed in respectful manner.

To open each meeting AH summarised the Marine Directorate’s proposals to introduce measures to protect crab and lobster stock in line with briefing material provided.

Only at the more northerly meetings (Ullapool and Lochinver) did anybody speak out in favour of the proposals. Otherwise skippers resisted the need for intervention, pointing to the reduction in effort that has occurred organically in recent years.

The main reasons for the reduction in effort given were:

1. Boats being unable to get crew:
2. The sale of four super-crabbers which now operate in foreign fisheries:
3. The movement away from crab fishing as the Far East market quietened:
4. Boats not fishing due to lack certainty in the economic viability (due the surge in inflation) and continued uncertainty in the legislative backdrop.

The industry feels that it requires support and promotion from government, not restrictions and would be vulnerable to the financial implications restrictions would bring.

The contraction in activity, both at sea and in shore-side support services in recent years is thought to be significant. Physical evidence of this is most visible in Mallaig, due to its historic dependence on the industry.

Resistance to Invervention Measures

Where the measures did not have support, it is for the following reasons:

1. The proposals are not based on a sound assessment of the stock. The vast bulk of the coastal area covered by the NW RIFG are classified in the report as sea areas Mallaig (MA) or Ullapool (UL). The data on which the Stock Assessment report provided shows the following summarised sampling data over the 4-year period:

Species

MA Samples

UL Samples

Total NW Samples

Total National Samples

% of Samples from NW

Brown Crab

26

1146

1172

216073

0.5%

Velvet Crab

0

0

0

114104

Div by 0

Lobster

1

58

59

44589

0.13%

Despite the NW Coast including in excess of 25% of Scotland’s mainland coastline, no species contributed more that 0.5% of the national samples in any species.

Most of the scientific data used in the report appears to have been drawn from Orkney- and therefore does not reflect local conditions.

The meetings felt that it is far too narrow and remote an evidential basis on which to found actions. [source: tables 3-5 MD Stock Assessment Report].

1. The report is based on data which is considerably out of date and does not reflect the current local conditions in a dynamic ecosystem- see below.
2. It is felt that stock depletion is a regional issue that varies widely around the coast. If measures had to be brought in, there would be considerable benefit in bringing in fishery management, monitoring and conservation measures on a regional basis.
3. The industry feels that the measures, as proposed, would be hollow without a commitment to compliance and there is no detail on where the resources would come from to achieve that. There is an expressed desire that, if enhanced management of the fishery is introduced on a regional basis then compliance is delegated with the same boundaries.

Contrary to the picture produced in the MD stock assessment, the meeting felt that stocks are:

“as good as they have been for thirty years.” [direct quote from the Mallaig meeting]

Again, this is attributable to:

• The withdrawal of super-crabbers from the local waters- this is an issue to which a permanent solution to would be welcome.:
• A movement away from crab to other species as the bounty from the Far East market for crab settled a few years ago:
• The increase in the Minimum Landing Size in 2018 was expected to show benefits after 7-8 years. This is currently only visible in the bulge in the numbers of juveniles and undersize animals that are being returned. There is a desire to assess the full impact of this change prior to introducing further measures.

This anecdotal evidence is supported by the graph (2022) from https://www.nature.scot/doc/official-statistics-marine-and-terrestrial-species-indicators-experimental-statistic

While this report includes an 8% reduction in marine biodiversity (2016-2019) within that figure:

“…..From 1994 to 2019, the average abundance of 14 species of breeding seabird fell by 41%”

The indicators for aquatic species appear, at worst, stable and in some species proliferating considerably.

Support for Intervention Measures:

At the more northerly meetings where there is support for intervention with stock protection measures the reasons given for that are:

• The inconsistent and higher MLS for lobster in the NW encourages poaching of near-sized lobsters and their transportation to ports where they can legally be landed. Especially Wick, Scrabster and the Outer Isles:
• Visiting high capacity boats catching high volumes of stock before moving on:

It is noteworthy that the overspilling of the Outer Isles industry to deploy their surplus creels on the NW Coast should be accounted for when assessing the success or otherwise of the Pilot Programme operating there.

The Threat to Stocks

At all meetings a discussion on threats to the stocks took place. Skippers felt that, despite the reduction in effort in recent years, the following issues remain an unquantified threat, and worthy of scientific interrogation:

• Warming sea temperatures encouraging invasive predatory species- particularly a summer invasion of squid and octopi- the latter being believed to be preying on crab and lobster at a significantly enhanced rate in recent years:
• Algal blooms:
• The effect of the aquaculture chemicals and waste on water quality, and indirectly on crustaceans, molluscs and bi-valves (see the Minute from the Lochinver meeting).
• Unlicensed (hobby) fishing. All meetings expressed the view that any change would require to encompass the unlicensed activity being carried out on a small scale. The preferred route is to bring it within a permit system.

Summary:

On balance, the industry in the NW does not support the need for increased regulation of the Crab and Lobster fishery, as proposed, but only by a majority. There is a sizeable minority of fishers, largely north of the Inner Sound, who would welcome intervention due to the incursions into their local area.

Many of those directly involved in the industry do not recognize the stock levels portrayed in the MD Stock Assessment Report. Reports were made at some meetings (particularly Broadford and Mallaig) of plentiful stock, high levels of juveniles and discard rates of 300% as skippers dutifully observed the recently increased MLS.

The industry is not resistant to enhanced restrictions to protect species and manage stocks sustainably. These measures and their resultant financial hit for the industry, should not be introduced without careful consideration following the creation of a sound, scientific, evidential base. This scientific endeavour requires to take an empirical approach to calculating the threat to crab and lobster stocks from both current fishing activity and the other listed emerging threats, which have not yet been considered.

Until that data was available there is limited support for a move to increased regulation.

Alastair Hamilton

Chair

22nd February 2024