The most important news humanity has ever received

George Monbiot called it “The most important news humanity has ever received” (but ignored). To ensure our Ministers are listening we include a large section of his Guardian article in our response to the Government’s invitation to join a national dialogue on our seas. What could be more important than the sea and life on Earth? With that in mind we thank the Government for the invitation as long as it is not a further excuse to tarry – for there is work to be done. Grab a coffee and read on, this is long but it has some important stuff to say. We’ve not minced our words because our diagnosis is the problem is political not scientific.

Sea Change’s response to the Scottish Sea Fisheries National Discussion 12 July 2019.

Firstly, thank you to the Minister for this invitation and the fine words and intentions.

the paper should act as a catalyst for us to move forward together…I want to hear what you think. I want to take on board your concerns and your ideas. I want your buy-in. This paper is not a formal consultation but a genuine discussion opportunity to explore change, support status quo and unearth creativity.”

Sea Change look forward to an on-going dialogue about how to creatively navigate Scotland’s marine crisis and move out of the “status quo” intelligently. For that is urgently needed. Scotland needs to help lead the world by example. Let us also name the crisis too, for it needs to be named and acknowledged, particularly by the Government. This is necessary before we can collectively recognise the urgent need to take action. At this stage only radical solutions are left.

Question 1. Do you have any ideas or views on chapter 1 where the Scottish Government identified a range of areas around achieving our vision for environmentally conscious and sustainable fishing ?

 We are fishing the bottom of the bottom of the food chain. We are fiddling whilst Rome burns. We are avoiding looking at the problem let alone tackling it. This is not just over fishing. There are a multitude of other crisis unravelling the ecosystem simultaneously. Chemical overloads, ocean plastic, acidification, climate change/temperature rises, not to forget invasive species. These pressures on the stocks are in the wider context of a global crisis of unsustainable consumption, population rises etc etc. We need the Government to acknowledge this accurately and publicly. This will give more confidence not less. It will give confidence that there are leaders willing to face reality and lead us through the real challenges ahead. We need leaders with the courage to do the right thing whether it be politically popular or not.

As a richer nation, consuming the worlds resources at levels way beyond developing nations, we have that duty. The world is connected, deeply interwoven regardless of Brexit or Independence. Every choice we make, every decision we take each day can determine the fate of future generations and the planet. The fate of humans and of the Earth may hang on what we do during the next few decades. That is not melodrama. That is fact. We are at the cusp of massive ecological change and we need to evolve together as a species. We have to think differently to survive.

Road trip and face to face dialogues

Sepa learnt a great deal from their national coastal ‘tour’ last year. They spoke directly to people in coastal communities. We believe these face to face meetings are essential as they include members of the public in the dialogue. The ministers rightly say the sea is a “common resource and invaluable national asset” what they omit to say is we collectively face a national and global challenge that the human race has never in its history had to face before. Creative innovation, joined up thinking and discussion is essential to avoid badly informed choices. The road to hell is paved with good intentions. We don’t have time for more mistakes.

We welcome much of what is articulated in the discussion paper such as “an ecosystem based approach“ and management ensuring “sustainable, resilient stocks and avoiding damage to fragile habitats”. The Context section of the paper also says the Scottish Government’s National Performance Framework, specifically the National Outcome, is to ‘enhance (the sea) for future generations’ and the related National Indicator to ‘Improve the state of Scotland’s Marine Environment’.

Enhancing and improving is good. The rhetoric is persuasive but we have long been concerned by the disconnect between words and actions. The decisions we experience being made ‘on the ground’ fall a very long way short of what is needed. The generations alive today are the most decisive generations in human history. We need to wake up to that.

Trust breaks down when fine words are spoken but actions do not follow. We still have Marine Protected Areas with dredgers and trawlers in them and salmon farms potentially expanding within them. MPAs need to be sacrosanct. They need to be the places with ecosystem-wide protection where this ‘enhancing’ and ‘improving’ can be generated from. We need to build resilience for what is to come.

We also need diverse coastal communities not dependent on jobs that destroy the ecosystem. We believe the dredge industry’s intensive footprint is around 15% of our inshore waters. Although they are able to fish in 95% of it most of the time. Some or most of this intensive footprint will coincide with areas of high biodiversity. That may be past tense – they may now be wastelands. We need to stop dredging in our inshore waters immediately unless they (the dredgers)  can prove to the public that they are doing no harm. Otherwise they are stealing our future.

The economic targets which suit politicians and big business chasing profits and lifestyle are totally out of alignment with the reality we are facing. Big businesses that create jobs but destroys the planet and future jobs are part of the problem. Supporting them puts our seas at risk and these consultations become an exercise in rhetoric which we do not have time for. Our concern is that the Minister’s are in regulatory capture to the sectors doing the damage. This is stealing from future generations.

What we need cannot be achieved with minor policy change.

On the 17th of December 2018 over 40 Groups wrote to the First Minister requesting sea bed reform and proper protection of our seas. This included the 3 Mile Limit. We fully stand by this letter outlining our collective action and the follow up correspondence. We await a meeting with Marine Scotland or even the First Minister if she can recognise the importance of this. (see link)


John Mcintyre, a scientist and ecologist who is one of the Sea Change thinktank members researched the 3 Mile limit and discovered that when it was lifted in 1984 – it was removed with the intention of replacing it with legislation that was simpler and more ‘fit for purpose’ in a modern world. It was not inviting a free for all. The second stage never happened. It appears it was forgotten in the short term thinking of political institutions.

Read: The Three Mile Limit – Sea Change Wester Ross

George Monbiot’s Guardian article (15 May 2019) also called “Net Curtains” on his blog may not be accurate to Scotland in every single detail but it truthfully states the general picture. As well as the fact that Industrial fishing is the biggest threat to our blue planet.

It asks why do we not act? Forgive the long quote but it seems the most succinct way to tell the story:

“It is the most important news humanity has ever received: the general collapse of life on Earth. The vast international assessment of the state of nature, as revealed on Monday, tells us that the living planet is in a death spiral. Yet it’s hardly surprising that it appeared on few front pages of British newspapers…..The more important the issue, the less it is discussed. There’s a reason for this. Were we to become fully aware of our predicament, we would demand systemic change. Systemic change is highly threatening. The first duty of a journalist is to cover neglected issues. So I want to direct you to the 70% of the plan- et that was sidelined even in the sparse coverage of the new report: the seas. Here, life is collapsing even faster than on land. The main cause, the UN biodiversity report makes clear, is not plastic. It is not pollution, not climate breakdown, not even the acidification of the ocean. It is fishing.

An investigation by Greenpeace last year revealed that 29% of the UK’s fishing quota is owned by five families, all of whom feature on the Sunday Times Rich List. The smallest boats – less than 10 metres long – comprise 79% of the fleet, but are entitled to catch just 2% of the fish. The same applies worldwide: huge ships from rich nations mop up the fish surrounding poor nations, depriving hundreds of millions of their major source of protein, while wiping out sharks, tuna, turtles, albatrosses, dolphins and much of the rest of the life of the seas.

Coastal fish farming has even greater impacts, as fish and prawns are often fed on entire marine ecosystems: indiscriminate trawlers dredge up everything and mash it into fish- meal. The high seas – in other words, the oceans beyond the 200-mile national limits – are a lawless realm. Here fishing ships put out lines of hooks up to 75 miles long, which sweep the sea clean of predators and any other animals that encounter them. But even inshore fisheries are disastrously managed, through a combination of lax rules and a catastrophic failure to enforce them.

For a few years, the populations of cod and mackerel around the UK started to recover. We were told we could start eating them again with a clear conscience. Both are now plummeting. Young cod are being illegally discarded (tipped overboard) on an industrial scale, with the result that the legal catch in UK seas is probably being exceeded by rough- ly one-third. Mackerel in these waters, thanks to the scarcely regulated greed of the fishery, lost its eco label a few weeks ago.

The government claims that 36% of England’s waters are “safeguarded as marine protect- ed areas” (MPAs). But this protection amounts to nothing but lines on the map. Commercial fishing is excluded from less than 0.1% of these fake reserves. A recent paper in the Science journal found that the trawling intensity in European protected areas is higher than in unprotected places. These MPAs are a total farce: their only purpose is to con the public into believing that something is being done.

You might have hoped, in view of the European Union’s failures, that Brexit would provide an opportunity to do things better. It does, but it is not being taken. On the contrary, while the EU will introduce a legal commitment to prevent any fish species from being exploited beyond its replacement rate next year, the UK’s fisheries bill contains no such safeguard. There are no plans to turn our “protected areas” into, er, protected areas. The looting of our seas is likely, if anything, to intensify.

What makes all this so frustrating is that regulating the fishing industry is both cheap and easy.

If commercial fishing were excluded from large areas of the sea, the total catch would be likely, paradoxically, to rise, due to what biologists call the spillover effect. Fish and shell- fish breed and grow to large sizes in the reserves, then spill over into surrounding waters. Where seas have been protected in other parts of the world, catches have grown dramatically. As a paper in the journal PLOS Biology shows, even if fishing was banned across the entire high seas – as it should be – the world’s fish catch would rise, as the growing populations would migrate into national waters.”

Monbiot’s reference to the lack of regulation and out of sight-out-of-mind thinking is backed up by the article he refers to in the Guardian’s Environment Section on the United Nations on the state of the planet. I quote from this article:

“The warning was unusually stark for a UN report that has to be agreed by consensus across all nations. Hundreds of scientists have compiled 15,000 academic studies and reports from indigenous communities living on the frontline of change. Agriculture and fishing are the primary causes of the deterioration.”

”David Obura, one of the main authors on the report and a global authority on corals, said: “We tried to document how far in trouble we are to focus people’s minds, but also to say it is not too late if we put a huge amount into transformational behavioural change. This is fundamental to humanity. We are not just talking about nice species out there; this is our life-support system.”

“The guardian went on to say: The report shows a planet in which the human footprint is so large it leaves little space for anything else. Three-quarters of all land has been turned into farm fields, covered by concrete, swallowed up by dam reservoirs or otherwise significantly altered. Two-thirds of the marine environment has also been changed by fish farms, shipping routes, subsea mines and other projects. In the words of Robert Watson, the chair of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (Ibpes). “

“We have lost time. We must act now.”

Reference: Human society under urgent threat from loss of Earth’s natural life | Environment | The Guardian threat-loss-earth-natural-life-un-report

George Monbiot


It seems we are in trouble. Big trouble.

This is not just globally. Within a lifetime in Scotland fin-fish fisheries have collapsed. Sea Angling has gone. Priority Marine Features and habitats have been dredged and smashed and chemicals have poured in to the seas. Whales have become toxic. Fishermen know we are fishing the bottom of the bottom of the food chain. Salmon and sea trout are in trouble. Scotland’s most iconic fresh water pearl mussels virtually extinct.

Yet the Government talks of growth and targets.

What we need is a massive programme of restoration. Why do we not get this? Our culture seems to have blind spots somehow thinking this is acceptable or someone will deal with it. Or business as usual. Or “surely the government knows what it is doing?”

Even our scientific institutions are failing to inform people of the urgency and politicians are not dealing with it.

See John McIntyre’s graph of by-catch landed by Scottish prawn trawlers over three decades.

This was produced using Government statistics. The rapid decline of fish in the sea is clear to see. There would have been over fishing going on at the same time as the nephrop trawlers were catching their by-catch and recording it – but the trawlers would have been contributing to the rapid loss of fish with these vast quantities of fish caught as by-catch. Many bottom dwelling species in particular. Over time there was clearly less and less by-catch to catch. Much of this may have been simply discarded.

The problem is clearly not inadequate science, it is politics.

How do we respond in an inspired way and overcome the paralysis, the denial and the general overwhelm? There is much talk of the need for a new story. But before ‘healing’ and a new story we need an accurate diagnosis of the illness, or even our cultural insanity. Only then will we wake up to the need for solutions and inspired action – and do the right thing.


The Government talks as if growth can continue unabated. This is misleading and we do not have time for more of that. The graph above tells the story of Government paralysis in the face of pressure from industry.

As a developed nation in a highly interdependent world the developed nations need to set the example and do the heavy lifting. We need to set an example in our own seas. We also cannot keep raping the rest of the world to feed our desires for unsustainable levels of consumption. The very consumption possibly filling a void caused by our disconnection from Nature in the first place.

Each child in the west will consume many times the resources of a child born in Africa. The population problem and consumption of the worlds resources is OUR problem. We need to change. If we do not who else will?

The state of fishing and the sea is the big problem of our generation.

There is great resistance to acknowledging this as well as the real benefits of Marine Protected areas as well as fisheries management which includes protection. Even the need for areas which are No Take Zones. Yet there is plenty of good science from around the world to demonstrate that protecting fisheries will improve fishing.

We also need to be honest. Salmon Farming is not feeding the world, nor is it a low carbon industry. There may be a place for it, if highly regulated and reformed. Ideally closed containment with animal welfare considerations fully taken in to account. No more out of sight out of mind politics.

We need to apply the precautionary principle on stocks urgently and cap effort. Only firm leadership standing by the evidence can help at this stage…

We are delighted that you say “Our overarching objective will be to maintain the long term structure of small family owned businesses to support and increase inclusive long term economic growth of the Scottish fishing industry.” However the growth part is an issue. We need management of stocks not just growth.

The discussion document says “After whisky, seafood is Scotland’s second largest export.” and go on to say: “ Our future strategy will also support and align to the national food and drink strategy, Ambition 2030, which seeks to grow the value of Scotland’s food and drink sector – including the seafood sector – to £30 billion by the year 2030. “

This seems to us to be magical thinking. Restoring the sea whilst at the same time advocating MORE fishing and more expansion of open cage salmon farms (which damage ecosystems) is a contradiction. We need to make the right choice now.

We can’t have both. We can’t shift from a resource-exploiting economy to a ‘green restoration economy’ (built on allowing Nature to recover) and have growth at the same time. That is unless we focus our full attention on supporting, even inventing innovative new green marine industries or expanding eco-tourism in sustainable ways.

Looking for these new green innovative enterprise-business solutions which can feed us and create jobs is a priority – but no crackpot ideas please. We need joined up thinking. Ideas that are tested and thought through very carefully indeed in a cross-sector dialogue, where agencies and experts share knowledge and communicate.

Meanwhile we need to prioritise restoring fisheries by protecting them as stocks decline. We need to cap effort and stop fishing the bottom of the bottom of the food chain. Even these fish stocks are declining, over fished or threatened by dragging metal across the sea bed, climate change, acidification, warming seas and plastics.

This includes the proper management of creel and dive effort too to ensure areas are not over fished and agreements are kept to.

We need to ask ourselves as a culture whether growth has enhanced wellbeing. Wealth needs to be seen in more holistic terms than just the ability to consume more. Wild Nature is also a form of wealth and wellbeing. “Exploiting” or “harvesting” a marine environment as if it is an infinite resource supplying endless Government growth targets for political purposes – whilst treating Nature as an ‘object’ to feed our rapacious appetites for more – will not produce a viable future. Perhaps not enough-ness is our deeper cultural problem. As is our illusion of separation which perhaps feeds it.

The sea is our life support system.

Key to note is how much we are falling short even now: the latest EU reports and the Scottish Government report on MPAs 2018 acknowledge that decoupling economic growth from environmental degradation is not happening and that Good Environmental status, as required by the Marine Strategy Framework Directive and National Marine Plan is unlikely to be achieved by 2020, with aquaculture damage being a significant contributor.

Solutions? A round table gathering along the lines of the Genome Project

Interconnectivity and interdependence

The GENOME Project is an example of an amazing global gathering of knowledge and intelligence to solve a puzzle for the whole of humanity. This is ecosystem thinking where a web of individuals and groups problem solve together. This project joined up brilliant minds across the world. This remains the world’s largest collaborative biological project. We need this kind of working together to save animals, insects, fish, birds and habitats. Our species and the planet too. The focus needs to be on solving it intelligently, not just diagnosing the problem. Scotland could initiate a similar approach to harness the human imagination and innovation latent in our culture and enlist support to save the marine and land environment. This could even be an international effort.

This would provide a story of possibility.

This does not just need scientists and economists and ecologists but artists, journalists, storytellers, musicians. Every talent. Everyone.


We need politicians to speak up and educate the public. Speak the truth – lead us.

Look at what happened when David Attenborough showed just a fragment of the truth of plastics? Things changed overnight. People woke up.

The truth might just set us free.

Evidence from all over the world (California and New Zealand and other MPAs) show what is possible. We have included these sources in previous consultation responses and would be happy to share these if required again. However the Government has better access than we to these sources and needs to invite the authors to offer advice. We can learn from others. What has been learnt is that the greater the marine protection and enforcement – the better the long-term benefits to the economy and fisheries.

With reference to Scotland – it is vital that low impact fisheries are given sole access to the inshore waters and effort managed so it does not exceed what is sustainable in the true sense of the word. The logic of this is sound environmental economics – but there is much more evidence from world leading experts such as Professor Callum Roberts on MPAs which can easily be sourced. We suggest the Minister reads Professor Callum Roberts, The Ocean of Life.

There is plenty of socio-economic evidence here:

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The Government could invite marine scientists, environmental economists, fishermen, communities and the national and international marine and land ecologists in universities, and young scientists to speak for their generation – to set up a round table project. Not to fight for commercial interest and quota but to work out the best way to manage the seas for the restoration of the ecosystem, for the sustainability of current and future fishermen whilst supporting coastal communities. This is the discussion waiting to happen. We need “creative solutions”.

This would be a start. There is courage in numbers too. Especially if an environment of open dialogue is created and decisions are based on the best evidence. We would like to put forward at least one of our members to be involved: John McIntyre has been writing a book on global sustainability and looking at the issues of how land, sea and energy intersect for the last decade or more. He would be of great value as a participant.

The Government has tended to listen to the mobile sector over and above the low impact fishermen. This has to change. The mobile sector’s justifications need to be unpicked. This is not a personal judgement on the fishermen. It is simply fact that damaging the sea bed on the basis that it provides jobs and food has got us in to this trouble in the first place. This is short term political expediency not joined up thinking. The Government has never looked at the COSTS of this policy. In the short term they do indeed provide jobs and food. In the long run they destroy jobs, food and potential.

The COST of a degraded seabed over the long run needs to be assessed in economic terms to provide a proper context for decisions. We so often observe the Government assessing the costs to the mobile sector of any change as if this somehow is what matters most. This cheats the public. We need an evaluation of the costs of their continued destruction. It will be a price not worth paying.

The Govt needs to be more open to scientists and environmental economists who have been challenging the status quo – with good evidence – so far they have been ignored.

The mobile sector must be treated with respect and concern for their welfare – but boundaries must be set, and a time set for transition to a lower impact marine economy.

A faulty root thought?

The problems we face are symptoms of a faulty root thought. In a nutshell the lack of consideration for our interconnectedness with nature when political decisions are made is at the heart of our problems. The illusion of our separateness is out of date.We are all related. Nature is incredibly intricate, interconnected, entangled and intelligent. It is only our blindness which creates the illusion of our separation.  Plastic and chemicals used to help humans are killing bees, bugs and whales and so much else. We did not know until a few decades ago that the chemicals designed to help feed humans were killing species which also help feed humans – such as bees. But we rushed ahead without due caution or even respect for these small creatures role in our ecosystem. When making decisions about jobs and the exploitation of natural resources we must consider the interconnectedness of everything. Even the intelligence which connects it. We live in a universe where a butterfly flaps its wings can impact the other side of the world. One politicians decision can destroy a planet or restore it.

Nature does not have a voice but it is speaking in the infertility and death of whales through toxic overload. It is also speaking in the micro-plastic soup our fish are ingesting and we in turn digest. The bays around the west coast which used to “bubble” with fish are silent. The silence speaks volumes just as Rachel Carson noted in Silent Spring. Ironically just as technology has made it increasingly possible to marvel at Nature’s extraordinary beauty, complexity and our deep interconnectedness with it, we are also increasingly likely to destroy it because our culture has become so separated from it.

Sea Change is a thinktank and coastal community group. We live in a ‘wilderness’ which is no longer wild. We talk a great deal about the existential threat we face and the risk of an extinction crisis caused by an expanding population, consumption beyond sustainable levels and so many people in denial. Our politicians included.

Dry bureaucratic language helps keep us divorced from what we know and feel. It denies us our access to a sense of wonder and respect for the extraordinary complexity and intelligence in nature. Government agency papers call the sea a “resource” to be harvested, extracted or exploited reducing sea life to an “object” to be consumed. In the same way “collateral damage” and “surgical strikes” deny the experience of the impact of a bomb. Our very language disassociates and separates us. Yet without the almost invisible plank- ton in the oceans, we would not have life on Earth.

The graph below from research carried out by Prof. Callum Roberts shows how much harder it has got to catch fish. This increasing difficulty means extra steel and fossil fuels are used to catch the same number of fish – it is also a map of vanishing fish stocks.


There was nothing difficult about working this out. The data used to make the graph is from the governments landing tables. To spell it out, this data is available to the Government. So why the delay, discussion or argument about change? Time ran out decades ago. If we don’t act then our children will starve. No ifs no buts. “The Limits to Growth.” is an essential read. Every time a businessman promises jobs or distorts the truth to make a short term profit and degrades the environment in doing so, someone in the future is likely to pay the price. Even die. Democracy works on an unspoken promise that those in or working for government will act to protect the interests of their citizens. When they fail to do this democracy is broken. There is a failure of trust.

We can now see the extraordinary life forms deep in the oceans. Astronauts have shown us the beauty of our Earth from space. The Hubble telescope shows us galaxies light years away into the stars. Yet somehow we can’t stop ourselves risking it all.

We know scientifically as well as intuitively that our fate and nature’s cannot be disentangled. Science is telling us over and over again – we are deeply interconnected at every level. Some of what science is now saying was ancient indigenous knowledge, but we now have instruments that can prove it. We can make a more complete story. Surely we won’t decide to destroy it just so we can have more stuff?

We will answer the questions on a more practical note now.

Maximum Sustainable Yield

We are delighted that the Government says it “ WILL commit to the precautionary principle and the Maximum Sustainable Yield”
We are glad it supports the UN Sustainable Development Goals which set out to restore fish stocks ‘at least to levels that can produce Maximum Sustainable Yield as determined by their biological characteristics’.

The Precautionary Principle

When the Govt. says it WILL apply precautionary principles, this needs to be a real commitment. We shall be holding the Government to account on that.


We need to get absolutely serious about cleaning up the plastic that litters the coast and oceans and stop adding to the litter – over the side of boats has to be over. Heavy penalties must be applied to offenders. Equally the councils can design ways to keep dustbins with lids that keep shut. In coastal areas these fly open in a storm and dispel all their contents in to the sea. The lids need designing to stop this.The councils need to provide more community dustbins for tourists otherwise it gets dumped on roadsides. Beaches, roadsides and river sides need to be cleaned of plastic too. They are disgraceful.

Wrasse & razor clam fishery

A fishery should not be allowed until there is a full assessment of the stocks. Unregulated fisheries like wrasse is a major concern in the area like Wester Ross as it potential unravels another part of the ecosystem we urgently need to allow to restore. Even if the MPA was not set up for the recovery of the ecosystem, it should have been and we want the best chance that Wester Ross will support fisheries in to the future. Wrasse fishing should not be allowed in a MPA until there are proper controls.

Razor clam fishing is also an issue. We need to see the precautionary principle applied to this urgently.

Tamperproof Vessel tracking should be fitted on all vessels. It should be illegal to be at sea without them. Why would the Govt NOT want this? The technology is available. The Scottish Parliament voted in support of vessel tracking on all Scottish fishing vessels in December 2018, so to do anything different would be against the will of our elected representatives. This is the will of the people. This needs implementing ASAP. This would send the correct message to the boats illegally fishing that the government is committed to stopping it.

What concerns us is how will the rules be enforced effectively once established? We must have enforcement with teeth. The consequences of illegal fishing should be the removal of the fishing licence. They can’t break the rules again if they can’t fish. Fines do not deter sufficiently. This would be a good deterrent.

Creel fishing also needs more regulating and checks in place. Anything can be overfished. This includes checking unlicensed hobby fisherman with supposedly just a few creels for the pot.

Black fish and illegal fishing

Black fish and illegal fishing must be dealt with urgently, particularly on the East coast. We cannot afford to allow fishermen to steal and plunder from the public and future generations as well as driving stocks to collapse from unrecorded fishing on the scale it is going on.

There need to be criminal prosecutions of the worst culprits who are well known.

By-catch & discards

We need to urgently implement by-catch reduction programmes that are sensible, thought out and not wasteful. Until trawling or dredging is banned we need to find ways to create a market / commercial use of the by-catch. For example sell by-catch fish in the local stores and at the ports to buyers and local people. Make the wastage of by-catch a morale crime, if not a legal one. Help fishermen set up ways to get it used. Better still ban trawling from inshore waters.

We are not qualified to advise on solving the issue of discards. However the fishing methods which create by-catch such as trawling and dredging seem out of keeping with modern times. Discarding at sea is wasteful, but catching it in the first place is the real problem.

The MPA network

The Scottish Government must complete the MPA network urgently.

Cetaceans – a special task force.

Much wider measures to support cetaceans is urgently needed. We realise there are MPAs in consultation for some species but more can be done. A special task force could bring together the science from across the world to identify what is harming them and identify ways to protect them better.

Fish farm acoustic deterrent device’s should be banned from areas with cetaceans. Solutions to reduce toxins of all sorts and plastics are urgent. The Navy and cetacean experts could work together to ensure sonar exercises do not harm whales. There must be a way to avoid this. No naval person would want to kill a whale. We need joined up thinking. Cross sector talks. These animals attract tourists and have economic benefits to coastal communities. However that is not the reason to protect them, if these animals, which have swum the seas from before the human race existed, go extinct on our watch it is simply a crime.

The Priority Marine Feature Review commits to measures that will limit the impacts of trawling and dredging on seabed habitats. This was instigated in 2017, but there is still no progress.

Sea Change favours the 3 Mile Limit simply because of the urgency for an immediate boundary and simple policeable protection. Scallop dredging and bottom-trawling should be banned inshore, except where it can be proved that these fisheries can operate without harm to the seabed. The dredgers and trawlers could work with the scientists doing the PMF review to identify areas where they CAN dredge or trawl – if indeed there are areas. Rather than the other way around. The first action as an outcome of this national discussion should be the immediate decommissioning of boats to be able to prevent more damage, and the process of reinstating the 3 mile limit boundary line.

Research on the benefits of protection to fisheries

We need more research on the benefit to fisheries of conservation measures. As well as an accurate assessment of the long term costs to the fisheries of the mobile sectors impact.

In Sea Change’s first consultation response in Jan 2015 we outlined the loss of all the major fishery’s in Wester Ross and the NW. We will not repeat that sorry story. However only 3 years in to recovery that has not changed significantly although we have seen juvenile fish on many survey dives which is a hopeful sign – and significantly shoals of herring spawning south of the MPA is a hopeful sign too (if illegal dredging is stopped).

Herring spawning on maerl beds and herring recovery protected

We want the herring fishery to recover in the area before exploitation of fish stocks is allowed on a commercial scale. All the maerl beds in the area where herring spawns need very careful policing and protection and the boundary line extended to create a protected zone if needed . This is a top priority for marine compliance.

More widely West coast cod has collapsed and has not recovered. Trawl by-catch and dredging is a major concern especially for bottom dwelling fish such as common skate which is now on the IUCN red list. The Common Skate was once one of the most abundant rays in the northeast Atlantic, now one of the most threatened.

Question 2: With regards to the themes in Chapter 2 on future governance, engagement and accountability, what are your thoughts?

Including Community groups

Community groups are often excluded from stakeholder discussions. Yet we represent a way of seeing which has no direct commercial interest and we speak on behalf of the largest stakeholder – the public. Even if there is a spectrum of opinion within the public, and we articulate an informed, more conservation orientated voice, it is nevertheless an important voice. We are freer to speak out than some with commercial interests or jobs in the sector. That independence of view is precious. However so far Sea Change has not been invited to contribute to the Regional Marine Plan despite being active in campaigning for Wester Ross MPA. We feel we could contribute something of value and would at least like to be heard.

Failure of political leadership to speak the truth to the public

This opportunity to take part in a discussion is particularly welcome because an informed public is essential. We hope that coming out of this national discussion process, our politicians will be encouraged to explain the challenges and crisis to the public more, in ways that help activate behavioural change. The lack of leadership so far has had an impact in communities, on scientists and fishermen. Despite some good local MSPs, the Ministers themselves have glossed over the crisis in public. In fact the talk has been of growth and support for big business expansion. We are concerned about the way this indicates overly cosy relations and regulatory capture by commercial interests.

Social disclosure

Speaking up in coastal communities about gear conflict or environmental damage can be problematic. Yet it is vital for the public to be informed enough to be discerning, as well as motivated enough to change behaviour. Scientists who have spoken against the status quo regarding salmon farms have paid the price – at least in the past. Many speak of being bullied and controlled, their opportunities shut down. Fishermen have experienced the same over gear conflict and can be reluctant to speak up. If politicians and public figures spoke more honestly – public opinion might follow and the national discussion widen into the broader public. The suppression of an open dialogue at a local and national level is harmful. People think if the politicians aren’t speaking about it openly surely it can’t be that bad?

Our Governments response to this existential threat cannot be a policy change. Ways of articulating the need for large scale changes must be considered.

Storytelling a new story?
There is a lot of talk amongst environmentalists of the need for a new story – not a fake story, a lie or a spin, but the best true story of who we can be. What we COULD do together. But also what we need to do. Admitting the reality but also how we can rise to the occasion is vital now.

Storytelling seems key to overcoming the paralysis and denial as well as ensuring people feel their contribution can make a difference. If each individual feels they can make a difference, the collective can turn things around.

The circular green economy v growth and consumption?

The sciences are now showing that rather than being a species which at root is selfishly motivated – we are also a social and empathetic species. We are capable of sacrificing our own benefit for others, even other species. The development of a more evolved society may not be about more consumption. Many people are reducing consumption for the sake of the planet or other species and nations. Particularly young people. This is hopeful. The message needs to spread by example. Can our politicians be that too?

The government could be encouraging ways to grow the alternative green economy. Enterprise which is sensitive to human and ecological health impacts. Enterprise which makes recycling and the circular economy central to their system. Supporting jobs which work in harmony with Nature will in the end make a richer society. Maybe less stuff. But possibly richer in other ways. There is a grassroot movement for this which has yet to find its expression in Government. We hope that will change.

Question 3  explores chapter 3’s discussion around access to our waters and the role of Scotland in future fisheries negotiations as part of the UK. 

We would like the Government to favour access to local low impact small fishing vessels in inshore fishing grounds.

Question 4. Regarding Chapter 4 ‘s discussion aim to establish fishing opportunities for long term future sustainability and accessibility. 

With regards to the use of the word sustainable, perhaps we need to invent a new word. Sustainable is now so abused. Dredgers are using it and fish farmers too – this model of sustainability has nothing to do with supporting biodiversity or ecosystem thinking and the interrelationship of species that supports life. This kind of “sustainability” is about sustaining multinational’s income (securing more monopoly-like control) and farming the sea like a monoculture. Prawn trawling and dredging erases biodiversity and “farms” the sea for one species alone. It is given justification on the basis they are “feeding the world” to help everyone. Let’s not be fooled. Yes jobs and businesses are the engine of the economy and vital to provide wealth. But we have a choice about what kind of jobs get subsidies and government support. We need to encourage innovation for greener businesses not unsustainable ones.

In our answers to question 1 we have stated our thoughts on MSY. We have also stated that dredging and nephrop trawling should be phased out. A priority should be to phase dredging and trawling out of all MPAs as soon as it is reasonable to do so. Especially maerl MPAs.

The fishermen need to be dealt with fairly, respectfully and supported through the transition – but it would be good to begin that process asap. The long term benefits could, if properly managed, outweigh the price of compensation and decommissioning.

We welcome the application of Total Allowable Catches (TACs) for shellfish species, especially for stocks where there are clear management recommendations, such as west coast lobsters and crabs. We also require the precautionary principle applied to these stocks.

Question 5. Asks for responses on Chapter 5 and the discussion of possible options for access to fishing in distant waters and new entrants. 

We would require more understanding of international fisheries issues to comment. However we only support properly managed, well policed, low impact fishing in our inshore waters. Fishermen working in their home patches are likely, on the whole, to be better custodians.

Question 6. Asks for thoughts on chapter 6 which identifies a broad range of themes and points around the future management of the inshore fishing industry? 

We favour the 3 Mile limit from the shore not the baseline. With only low impact fishing in the inshore areas. Damaging fishing methods should be banned unless fishermen can prove they do not cause harm to the seabed or ecosystem.

The MPA network should expand its remit to include fisheries recovery as part of their legal management orders. This would change the MPA network from a network giving legal protection to a short list of endangered Priority marine features and recognise everything is connected and the MPAs would work better if the focus was on ecosystem wide recovery. This will enhance shellfish stock conservation measures.

MPAs currently only have legal status around the conservation objectives of PMF species and habitats. This is a wasted opportunity.
MPAs were originally designed to give ecosystem protection to support the recovery of fisheries as well. It would be good to have this as a legal status not as a  by-product of banning dredging in a few MPAs. With this in mind MPAs which have trawling zones like Wester Ross should have these phased out. Trawling in MPAs sends the wrong message but also damages ecosystem recovery, the sea floor and stocks. In Wester Ross MPA burrowed mud has “conserve status”. We would like to know what monitoring of its condition is taking place, as we believe this needs managing to ensure the recovery and resilience of stocks.

Compliance and enforcement needs real teeth and technological solutions to track all fishing vessels. We need to end gear conflict and vandalism. Improved vessel tracking across the fleet will help but new legislation is also required to give enforcement powers to Marine Scotland for investigating offences rather than relying on Police Scotland. A well funded, dedicated and expert enforcement team is needed to investigate incidents and intelligence gathering.

Question 7.  The questions asks for ideas the future funding of the fishing industry are identified in Chapter 7 for discussion. 

Fuel subsidies should be removed from environmentally damaging fishing such as trawling and dredging immediately. Scallop dredging uses high volumes of fuel per kilo of landed catch. According to the Sustainable Inshore Fisheries Trust this would save £14m every year. This could be used to support data collection.

Question 8. The Scottish Government understands that access to labour is a considerable concern for the industry. In Chapter 8 we identify a range of discussion points connected to access to labour and working in the fishing industry – what are your views on this area?

The Seafood Slavery Risk Tool suggests that some of the UK fleet may be involved in modern slavery. There is also considerable anecdotal evidence ‘on the grapevine’ of bullying, blackfish, prostitution and money laundering on the East coast ports in particular. This is connected with criminal activity and needs to be stopped.

Question 9.  The Scottish Government believe it is right for the fishing industry to contribute to costs associated with science, research and development in the future. Chapter 9 consider options for this what are your views?

The industry should contribute to the costs of science and research by using the savings gained from the removal of fuel subsidies. This would enable the Scottish Government to channel more money into vital research, ensuring this is independent of the commercial sectors.

Question 10.  Finally, considering the long term sustainability of the Scottish fishing industry for future generations do you have any other ideas not covered elsewhere in the discussion paper?

Yes we need more joined up thinking across the board, land and sea.

Chemicals: could we be in danger of  Silent Spring Plus?

People wonder why biodiversity is declining so steeply.

The danger of the accumulation of chemicals – a cocktail of chemicals – on the land and in the sea, without any certainty of the long term impacts, is a high risk factor. Combine fish farm chemicals with chemicals that run off the land and are flushed in to the sea and rivers as well as over the side of boats, and alarm bells ring.

Much of this would be preventable if the precautionary principle was applied as intended.

The National Rail Network has just cut down millions of trees beside the railway and injected the cut stumps with glyphosate. Much of this will end up in the groundwater and river systems and therefore the seas in the end. The cocktail of chemicals that harm bugs is not helping. Glyphosate should be banned until proven SAFE not the other way around. Currently permission is given to use it until proven harmful.

An ecologist in Sea Change says the case of the massive decline of eiders in the space of the last 15 years throughout the whole of the northern temperate zone, could possibly be a tell-tale example of general toxicity levels – cocktails of pesticides and residues – building to a point where reproductive failure occurs.

See are-dying-from-the-same-vitamin-deficiency-1.320018

These are quotes from this article:

“Thiamine deficiency in the studied species – blue mussels, common eiders, American and European eels, Atlantic salmon and sea trout – has been proven using chemical and biochemical analysis.”

“We cannot rule out the possibility that the observed thiamine deficiency is so serious that it con- tributes significantly to the ongoing global extinction of many animal species,” says Lennart Balk. Other researchers have identified this loss of biological diversity as the most serious of all threats to life on Earth today.”

The article ”Widespread Episodic Thiamine Deficiency in Northern Hemisphere Wildlife” (DOI: 10.1038/srep38821), written by researchers from 5 countries and 13 universities and other re- search institutions under the leadership of Professor Lennart Balk from Stockholm University, has been published in Scientific Reports within the Nature Publishing Group (NPG) and is freely available

Toxins and chemicals are likely to be at the heart of much biodiversity loss and population declines or crashes. The literature reports a 50-60% decrease in numbers throughout the Baltic, NE Scotland and the Clyde. A tipping point may have been reached in the toxicity of the mussels (eg in the Clyde, Lochbroom and the Baltic). Fish farm chemicals have been adding to the cocktail.

Chemicals and toxins needs to be regulated and the precautionary principle applied.

The EU’s food safety watchdog has given glyphosate a clean bill of health but has been accused of plagiarism by copying the main safety arguments from the industry’s application. In addition, papers released in the USA allege that the main producer of glyphosate, Monsanto, has been ghost writing safety studies, covertly paying European scientists and has unduly influenced regulatory authorities to support the continued use of glyphosate. Friends of the Earth believe it is a serious threat.

This could be harming fisheries too.

There is a desperate need for more research in this area even if it is fraught with difficulties precisely because of the difficulty of separating out different chemicals, their sources and effects. In the past we have had companies deny tobacco and organophosphates were harmful. We need to learn from the past rather than repeat mistakes. Our addiction to chemical solutions may be doing more harm than good.

If we want the wild salmon back then we will have to manage the land better too. We have to reforest the watersheds to provide clean water and insects for the young salmon. The reforestation will capture carbon and if carefully managed provide timber for housing (and boats) wood fuel for local use and habitat for deer (that we can eat.) We could create woodland crofts and start working out what kind of agroforestry will work.

Socio-economic report

In 2014-2015 Sea Change members read the Management of Scottish Inshore Fisheries; Assessing the Options for Change. This was produced by Grid Economics and commissioned by the Scottish Govt. Options for Change concluded that it was a no brainer to bring back the 3 Mile limit from a socio-economic point of view in the Clyde. We felt it was a report which should have represented a paradigm shift. However we felt it did not adequately flesh out the potential in the north west for real benefits to flow from a properly protected area. We knew local knowledge could provide additional insight and worked with the economists to produce our own socio-economic report which expanded on Options for Change in the Wester Ross area. This was submitted to the Government in 2015. It was as accurate as we could make it and calculated the potential benefits of protection. It sketched out an alternative greener economy based on low impact fishing, and recovery which would enhance fish stocks, angling and tourism.

We hope for much more support for this restoration project. For example we would like to see Loch Broom recover its former oyster beds for example…


We would like to see research on solutions to cetacean entanglement properly funded and encouraged. If creel fishing is the greener way forward (if effort is properly managed) this is an absolute necessity. These creatures are highly intelligent and these deaths are unthinkably painful and slow.

Future generations may see the failure of leadership as criminally negligent 

On page 1 of the discussion paper, under context it states “The Scottish Government is committed to delivering a sustainable, evidence based approach to the management of Scottish fisheries based on high quality scientific data.”

We support the need for rigorous science. Yet our experience is the Government often acts on political expediency, ideology, even hopeful thinking, and not always the science. The precautionary principle provides an essential safety net. Evidence as well as common sense suggests that we do not need to seek proof beyond reasonable doubt before acting to protect species. Saying “we need more science” can be, on occasion a political tool used to kick important decisions in to the long grass.

We would never have got into the mess described above if this was not true. Either ignoring or suppressing information is a form of negligence which is potentially criminal. Future generations will investigate why information took so long to be published as well as acted upon. They may well question why evidence that offered a path out of the mess was buried. We ask that now.

There are many examples – a few are below.

MIAP – Wild fish at risk from fish farms

1- In 2011 the Scottish Government initiated the gathering of scientific information to map areas of coastline where wild fish were most sensitive to interactions with salmon farms. This was to rate wild fish areas according to their vulnerability. We believe with good evidence that Marine Scotland’s “Heat Map” will be very similar to MIAP’s (Managing Interactions Aquaculture Project ) model of sensitivity for wild fish interactions. Partly because much of the science would be from the same or similar sources. MIAP showed that Wester Ross was rated in the highest category of sensitivity.

Marine Scotland’s heat map has not been published. It needs to be. This heat map is urgently needed to protect areas which present too high a risk to wild fish and need to be off limits to aquaculture. Previously the Highland Council said that until such time as the Scottish Ministers advised them to use MIAP as a material consideration in determining a planning application they are unlikely to consider is as anything other than a background consideration.

If MIAP or Marine Scotlands heat map was used it would be unlikely that open cage fish farms would be sited in the area.

Eight years on from MIAP, Marine Scotland have still not published their version of this. We question why.

We must be given this evidence to protect wild fish. If not the Government needs to be transparent about why this is taking so long. In the absence of that, the suspicion is that Norwegian multinational interests are being put before the national interest and support for the survival of two iconic species of fish – the salmon and sea trout as well as the ecosystem and many other people’s jobs.

Wester Ross is a maerl MPA

3- In 2004 SNH produced a wonderfully colourful leaflet on maerl beds. The text in this SNH leaflet explained how important water quality is for maerl as well as the impacts of fish farms …..They said “the discharge of nutrients and particulate matter from fish farms is a risk and the careful siting of farms is important to reduce impacts”.

Mowi’s (formerly Marine Harvest) salmon farm in Loch Ewe was sited near to a maerl bed. The farm had a very poor track record of benthic surveys. Emamectin and other chemicals were poured in to the sea. The science on maerl had only researched impacts up to 100 meters from fish farms so no one looked much further. There has been little  consideration of cumulative damage or the precautionary principle applied here. As far as we know this maerl bed was not being monitored. A recent drop down camera survey suggest it is not in good shape. We intend to check this and will be reporting on video to the community soon.

These situations destroy trust in the agencies meant to be safeguarding our environment especially when it is clear the science indicates one thing yet actions are not followed through on.

The science on maerl and fish farms has been written about extensively in our responses to the Parliamentary committee’s enquiry on salmon farming. It is viewable on our web- site.

Rural Economy and Connectivity Committee Salmon Farming in Scotland – Sea Change Wester Ross salmon-farming-scotland-submission-sara-nason-member-sea-change-wester-ross/

However it took until 2019 for MOWI to agree to closure under pressure, mostly from wild fish groups who had campaigned for years yet their concerns were not taken seriously. In the meantime MOWI has damaged wild fish around Loch Maree, which by all accounts has destroyed many jobs. It has also most likely done decades of damage to this maerl bed.

It would be good if an investigation by the Government agencies responsible was begun to look in to the extent of the damage to this maerl bed and why this was not better regulated so this could be learnt from. Even if the horse has already bolted SNH is still saying fish farms are okay near to flameshells in Lochcarron with little or no science on it…

This is included here because maerl and flameshells supports many fisheries.

Herring spawning on maerl in the Gairloch area was first reported by Scallop divers then filmed the following year and broadcast on BBC Blue Planet UK. We believe the south of the MPA may have supported spawning on the maerl and seabed too. It would likely also be a nursery ground for herring. This whole area needs careful policing and the licences immediately removed from any fishermen working illegally.

It is good to hear that SEPA has recently turned down a couple of fish farm applications in Orkney as a result of their proximity to maerl.

With this new understanding in mind we urgently request the Ministers make a statement to the effect that “maerl MPAs” like Wester Ross – where there is an abundance of maerl across the whole MPA – with still some of it likely to be unmapped – is declared off limits to new and expanded fish farms.

The area coincides with good creel and dive ground which would be impacted by fish farms and it is also (according to MIAP) the highest level of risk for wild fish too. These three concerns, amongst many others provide enough reason to close the MPA to the expansion of fish farms as a principle. As well as conduct an investigation in to the existing stresses caused by fish farms.

This would begin to mend the breakdown in trust as well as prove that the Government did stand by the precautionary principle as well as the legal obligations of the MPA.



4- We have a copy of “Scallop Fisheries: a view from the statutory nature conservation agencies” which is the 2009 Agency Position Paper (Produced by England, Wales and Scotland’s SNH)

This 2009 paper makes clear scientific statements about the impact of dredgers. As the science is stated so clearly a decade ago we have to conclude that the reason the fishery has been allowed to continue with little restriction (despite the known scientific advice) is because of political pressure. It is clear that the Government has given the mobile fishing lobby higher status as the key stakeholder – ignoring the public interest and the science, in order to create jobs in the short term – but fully understanding the impact in the long term.

Since 2009 there are fewer and fewer scallop grounds unaffected by the dredging. The Government is culpable, not the fishermen.

We quote from parts of this:

Scallop dredging can alter the nature of the seabed, reducing the structural complexity of habitats leading to more homogeneous (structurally uniform) habitats and thus reduced biodiversity. Loss of habitat structure and loss of the diversity of associated organisms is likely to adversely affect the function and the productivity of the habitats. This includes those essential (e.g. nursery/ feeding areas) to other commercially important species

It goes on:

  • “One of the most important effects is a reduction in the abundance of species …… (such as branching hydroids and bryozoans). These species are significant be- cause they are frequently of importance to the life-history of a wider variety of seabed species. For example, it is thought that this ‘turf’ is of importance for the settlement of larvae and their early life on the seabed, and this is equally true of scallops”.
  • Therefore taking account of the impact that mobile gears have on the seabed is of as much importance to the fishery as it is to the conservation of biodiversity. Recent research, e.g. in relation to the importance of maerl as a nursery habitat for juvenile queen scallops, illustrates the beneficial role that unfished areas (or areas of reduced fishing intensity) may have for scallop abundance and quality.Juvenile queen scallops show a strong preference for pristine live maerl (PLM) over impacted dead maerl (IDM) or gravel.”
  • (Photo displayed below)

• The close relationship between the quality of the seabed and the biology of the scallop means that many management measures for the fishery have the potential to result in biodiversity benefits – and vice versa. In particular, spatial management measures and changes in fishing operations that reduce the intensity of fishing/ bottom-contact time are relevant.

The picture illustrates how live mearl is more attractive to scallop spat than dead mearl, (even if some of Lamlash bay science studies have shown that scallop and maerl interactions are not quite so clear cut in the wild as in the laboratory, possibly due to the condition of the maerl.)

The UK Agency’s went on to advocate areas closed to all scallop exploitation (No Take Zones) as well as spatial closures to all mobile gear exploitation.

No NTZ’s have been created since and as far as we are aware, from the MPAs created since 2009 including the ‘Maerl MPAs’ only Wester Ross MPA and South Arran MPA were fully closed to scallop dredging. These closures were as a result of immense pressure from the fishermen and community including us.

What of the other Maerl MPAs? Are they still being dredged

if so this should be the top priority to close them.

Our answer to the problem of displacement of scallop dredging effort is to simply ban all dredging and return the 3 mile limit – this would lead to the decommissioning of the trawl and dredge boats with compensatory schemes for the fishermen which were fair. It will be worth the cost. It is not in anyway an appropriate way to fish. The fishermen would need to be treated with respect during this process so their needs could be dealt with but their fears over this should not be allowed to dictate policy.

The unspoken assumption which appears to underpin this discussion document despite the fine words and commitments which we support, is how can we continue to exploit this finite resource for more growth whilst just tweeking policy.

We cant. We need a low impact green economy which is built on our co-existence with nature and its restoration. The government needs to stop giving priority to mobile gear fishing lobby’s who destroy the potential basis of our planets future, and start listening to sane people offering low impact solutions and support more ‘green’ jobs. The Ministers seem to have a blind spot where they protect the industries doing the damage and do not adequately incentivise those providing low impact alternatives.

We sympathise with the exhaustion many officials feel at the thought of another long process but ignoring this will only make it all the worse.

Sea Change is a member of the Coastal Community Network. Through CCN, as well as directly, we have sent many responses to Marine Scotland, SEPA and SNH as well as our MSPs and the Ministers on the salmon farm debate as well as the collective action taken by 40 groups asking for seabed reform, as well as the return of the 3 Mile Limit on the west coast.

We are amongst many thousands of people represented by all these groups sharing a desire for full scale reform.

A final thought

A book was written by Robert Wright called Nonzero: The Logic of Human Destiny. This author suggests that the times we live in are so complex that we are more and more interdependent and connected. This is forcing us to seek out what in Game Theory is called non zero sum solutions. We are needing to join the dots more because the era we live in is bringing everything in to co-relationship with everything else. Solutions which recognise this interdependency and serve us all are the only ones which will serve the need for political and social evolution. In short we need to make an evolutionary leap.

We need a paradigm shift in politics – we need to learn from our mistakes admit the predicament we are all in and do things differently. That is if we want future generations to survive to be able to marvel at the wonder of nature as we do.