The Scottish Fishermen’s Federation (SFF) have demanded a response from Richard Lochhead on questions about his decision-making on Marine Protected Areas (MPAs).  In a letter, the SFF has accused the Scottish Fisheries Minister of placing management measures which are irrational and deeply damaging to fragile communities, disregarding his own mechanism to develop properly evidenced protection for the marine environment.

SFF Chief Executive Bertie Armstrong said: “This is a serious matter and we have no idea why the Minister has seen fit to abandon his own transparent and documented process.  He describes the proposed measures as “ambitious”, which is a very curious word to use in relation to the potential destruction of several local fishing communities.

“The tragedy is that there is no need to do this at all – the protection of features and biodiversity can be met by sticking to measures already explored and agreed.

“There has been a storm of protest from the affected parts of the inshore industry and we are demanding time and the cooperation of Scottish government to do the currently missing analysis on protecting sustainable livelihoods.

“All the components of a bright and successful inshore industry are available: fish to sustainably catch and a fleet to do it, markets to serve and further develop and, if handled rationally, a suite of measures to properly protect the environment.”



Dear Cabinet Secretary,

Ministerial Decision-Making on MPAs – Timescale and Scope of Further Work

Thank you for meeting the SFF delegation on 6 July on the subject of management measures for Marine Protected Areas.  At the meeting you said you would consider an extension of time beyond the current deadline of 9 August to allow essential work and your staff indicated afterwards that we might expect a decision on or about 14 July.  We have not had any such indication – will you tell us, please, whether you will grant further time?

Regrettably, the delegation at the 6 July meeting unanimously felt that you had not absorbed the delivered message and some brief repetition may be helpful. You will recall that the central point of difficulty for us is your departure from an agreed process to determine, in an evidenced and meaningfully consulted way, the best arrangements for MPAs.  As explained in our letter of 3 July and at the meeting, your decisions if executed will inflict needless damage on the coastal communities affected, as described so lucidly by those victims whom you met.

The Absence of Evidence.  Any socio-economic damage to vulnerable communities would be regrettable, but at least would be understood were it to be clearly required as a sacrifice for the longer-term protection of the environment.  This is not the case here – your decision-making is heading straight for gratuitous damage to communities. To the surprise and disappointment of the delegation that met you, no actual evidence for your decisions was produced or described – that is the reason for our request for more time.  As explained on the 6 July, we have already sought to commission the essential, currently missing, socio-economic work, but have been unable to do so in time to meet the current deadline.

Wider aspects of the Management of Inshore Fisheries.  In parallel with the introduction of MPAs, there are several other streams of activity relevant to the health of the Scottish inshore industry, particularly but not exclusively that on the west coast.  The truth is that no credible analysis work has been done, despite the existence of clear and accessible methodologies in particular those aimed at development of a rational policy of support for sustainable livelihoods in fragile communities.

Frustratingly, all the components of a potentially thriving inshore industry exist – fish to catch sustainably, an existing industry to catch them, markets to serve and develop and, if handled rationally, a balanced policy to protect biodiversity.  We see a clear danger that opaque and less than rational decision-making on fishing management measures may have extremely damaging consequences – it is no exaggeration to suggest that some of the more fragile communities may suffer from clearance.

The request for more time be allowed is repeated – a postponement of decision-making until the autumn would be appropriate. We offer to cooperate with Scottish Government to quickly define and agree the analysis required.

Yours sincerely

Bertie Armstrong

Chief Executive

Scottish Fishermen’s Federation

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