The Scottish Fishermen’s Federation (SFF) and its constituent associations will meet with Richard Lochhead, the Cabinet Secretary for Rural Affairs, Food and the Environment, in Glasgow this Monday (6 July) to highlight their anger and dismay over recently announced management measures for Marine Protected Areas (MPAs), which threatens the viability of inshore fisheries on the West coast.

The Scottish Government announced on 11 June the management measures for 11 inshore MPAs and nine Special Areas of Conservation (SAC). The measures were greeted with dismay by inshore fishermen as they went far beyond the defined purpose of the MPA project, prohibiting fishing over much greater sea areas than what appeared to be agreed during the lengthy consultation process.

Many West coast inshore fishermen are fearful that their operations will no longer be viable and that they will be forced to fish in more exposed and stormier offshore areas.

Commenting upon the letter, SFF chief executive Bertie Armstrong said there was an over-whelming feeling within the industry that these new MPA management measures represented a significant breach of trust.

He added: “The Scottish fishing industry fully supports the rational protection of the marine environment, and in accordance with the Cabinet Secretary’s own guidance on Marine Protected Areas, the parallel principle of continued sustainable use of the sea.  A coherent project was run over the last four years by the Scottish Government with full participation from the industry to deliver these objectives of healthy and productive seas. During this consultation, a comprehensive plan, containing much concession and compromise by the fishing industry, was forged.

“To our astonishment, we find that the Cabinet Secretary’s actual decisions have disregarded the orderly process which went before and overreached mightily in placing restrictions which will damage local communities.  For the life of us, we do not know why he has done this and will be seeking an explanation.

“Given that there are radical changes to the industry such as the discard ban coming along by the end of the year, we are now very concerned about what support we may be able to rely upon from the Scottish Government having just had an example of effective abandonment.”


Dear Cabinet Secretary,

Marine Protected Areas – Management Decisions and Breach of Trust

In preparation for the Scottish Fishermen’s Federation meeting with you on Monday 6 July in Glasgow, an explanation of our headlines may be helpful.  We are grateful for the meeting, held at the behest of the SFF.  We note that the meeting will be in two parts, the first dealing with issues on Marine Protected Areas (MPAs).  That is the subject of this letter.

Background.  As you know, the use of MPAs for the purposes of environmental protection have never been opposed by the SFF.  Instead, our insistence was on a coherent, evidenced process that would meet the conservation objectives and the principle of sustainable use, both of which are embedded in the relevant legislation and stated very clearly in your own guidelines.  In the beginning, the approach adopted by you in the Scottish Marine Protected Area Project (in sharp contrast to initial methods used elsewhere in the UK) seemed to fit the bill.  The SFF have taken care since the inception of the project to participate with a will.  Given the rational structure of the project, we are on public record as occasionally expressing approval.

You will recall that the process was heavy with consultation, beginning with a series of workshops over a 15 month period in 2011/12.  We regarded the participation of the fishing industry as essential and set about providing it.  We made one of the most significant input streams to the project, having recognised the importance to us of proper environmental protection and the potential harm to sustainable use that could result from information gaps or mishandling in the decision-making.

Change of behaviour by Scottish Government.  Given the background and work to date and the reasonable Marine Scotland document delivering the consultation on designation, the Federation and more specifically several member associations were astonished by the decisions taken by you and announced in the consultation on management measures for 11 Inshore MPAs and nine SACs issued in June.  Several sites in this first tranche bear little or no resemblance to the process which preceded your decisions.

You have chosen to reach well beyond the defined purpose of the MPA project, and we do not understand why.  In the four Marine Conservation Orders issued for consultation, two – the South Arran MPA and the Wester Ross MPA are particular examples of excess.  Scallop dredging has been excluded despite the Marine Scotland preferred options, agreed by the Statutory Nature Advisor, of zonal management including this use.  To quote your earlier consultation on area designation: “This approach would deliver all the management requirements.”  That is the crucial point – the whole project was designed to do just that and not to take unsubstantiated decisions impacting upon established sustainable use.

You have recognised in your own figures that there will be economic damage, but have chosen to trivialise it by grossing-up as a percentage of the wider industry.  For those affected the damage is anything but trivial.  If you regard them as dispensable then we must point out the grossing-up effect of loss of single or small number of vessels in local communities is likely to be gravely damaging.  We are attempting to commission further socio-economic work, but the time allowed even with your extension of the consultation period may well overtake us.

We are extremely disappointed with the contents of your consultation document, where an attempt seems to be made to justify some of the decisions in a way that takes no account of your own rules and guidance.  In considering weighted evidence, you seem to have chosen to make much of the input of Sunnyside Primary School in Glasgow.  It is no doubt an honourable institution, but in the sober, important and impactful process of choosing management measure for MPAs, this indicates a disturbing vulnerability to manipulation or worse, an attempt to do so.

Breach of Trust.  These are words that we would not use lightly but that is what we feel has overtaken us.  Having been part of the validation of a rational process to meet management requirements, to which with considerable effort and expense we contributed, we simply cannot see why you took the decisions you did.

The mistrust generated by this goes beyond the immediate subject.  We are in a period of exceptional change and potential upheaval, with the new CFP including the discard bans and a short, sharp journey to MSY.  If this is the way you have chosen to behave in the context of a well-defined process, what support can we depend upon now?

Next steps.  These are strong words, but it is as well that you understand the strength and depth of reaction to your behaviour in this matter and its implication for the relationship between the industry and government.  We ask that on Monday you explain to us why you took the decision to accept damage to parts of the industry by going beyond the well-defined requirements.  Further, pending our discussions, we request that you make arrangements to reconsider the decisions you have indicated in the June consultation on management measures, allowing a meaningful timescale for the work.

Yours sincerely

Bertie Armstrong

Chief Executive, Scottish Fishermen’s Federation