Lochcarron Flame Shells : An Open Letter to Fergus Ewing & MS Conservation Team

Could the Lochcarron Flame Shell incident be a turning point for Scottish Seas?


Dear Mr Ewing, I would like to add my voice to the many other voices along the coast such as coastal community groups, creel and dive fishermen, marine scientists, NGO’s, recreational divers and underwater cameramen. All have expressed concern about the damage to the lochcarron flame shell bed after it was recently dredged. I know from what you said at the Inshore Fisheries Conference, where we met briefly, that you are currently considering your response.  I very much hope you will take the following into consideration.

My greatest hope, which I believe is shared by many others, not just across Scotland but across the UK and the world, is for Governments to show real courage, vision and leadership at this critical junction. The global picture is well known; global warming, acidification, and depleted seas from over fishing are changing the world around us as population pressures increase. This wider global context makes current decisions at a national and local level of huge significance – for we are all connected.  My hope is that this tragic incident is a turning point for Scotland’s seas.  We desperately need better stewardship by fishermen, the public and the Government. We are all in the same boat.

It was a great step forward when the Government chose to appoint Maree Todd MSP as a Species Champion for the flame shell. I believe this was a recognition of their significance, not just as a species but because they provide a habitat for other species too. Could this latest incident be an opportunity for us all to rethink the inshore fisheries strategy and explore how we can improve it to fully protect our national marine assets?  It would be good to see that the appointment of Species Champions is really meaningful.

The issue is not so much whether Lochcarron should have been made an MPA, but a much larger issue about whether scallop dredging is appropriate in inshore waters. This latest incident sadly highlights the failure of the Inshore Fishery Strategy as it is. However it does provide a real opportunity to learn and do better as well as to start to use spatial management as a solution.  It has been a decade since the initial recommendation to use this as a tool to protect inshore waters. Spatial management could also be used to help solve the gear conflict issue. Could it be time to take this seriously and make it work? (See the Poseidon report recommendations, Bryce Beukers-Stewart and The MCS response in 2015 to the king scallop conservation consultation)

On the 22nd April, Sea Change Wester Ross’s volunteers were involved in a seabed survey. The intention was to map some of the ordinary, as well as extraordinary species and habitats within the Wester Ross Marine Protected Area.  This was Earth Day and some Seasearch divers generously agreed to help us. One of the divers had just witnessed the impact of the dredger in lochcarron and had filmed the smashed up flame shell bed.  He reported what he had seen. Everyone who heard this was deeply saddened at the long term destruction for a few pounds of scallops. Particularly as we know dredgers have been damaging habitats like these regularly.
We still know so little.  What is being lost is often lost without record. The reason many of us are prepared to offer our time as volunteers to survey the sea is because we do not know where all the important nursery grounds, spawning grounds and important habitats are. Yet we have allowed dredgers to legally smash up these area’s before we do know. Very often we have allowed it even when we do know too,  as Lochcarron indicates. Until recently, with the exception of divers, few could see what we were losing.  Technology is now making these losses visible and divers are fishermen are speaking up.  The public is also waking up to the fact that what goes on in the sea would have been outlawed long ago if it were replicated on land.  We need to catch up and apply common sense,  now that we know better.
As I said at the Inshore Conference, I would like to encourage you to act in the wider public interest, rather than allow a minority of  fishermen who use dredgers to have a disproportionate influence.
I hope your response to Lochcarron will be a decisive moment for our seas and you will choose to use spatial management as a tool to protect our nation’s biodiversity. Whilst you must indeed listen to fishermen, I hope you will act on behalf of the nation as a whole. These species are our natural heritage, important for future generations as well as being important habitats which sustain other life, biodiversity and our fisheries too.
I hope your response will be to increase protection and exclude dredging until the inshore waters are more fully mapped. This gives time to identify areas where there is rich biodiversity which needs protection and then closures to mobile gear can be applied intelligently.
Evidence should be provided before dredging an area and proof required that there is no significant impact. Why is it that dredgers escape the legal requirements other industries need to provide?
Other industries are forced to use EIA’s to identify where important marine features are – particularly Priority Marine Features (PMFs). This should now be made the case for dredgers. There needs to be a precautionary approach as part of spatial management which excludes scallop dredging in areas likely to contain PMFs or in fact any habitats that are important for spawning, fish nurseries or areas of rich biodiversity. However, first we need to identify these areas and gain sufficient knowledge to make decisions based on evidence, and apply proper caution until we have that.
The divers in our Marine Protected Area noted that there was a surprising lack of fin fish. There may be a multitude of factors involved  – but one of them surely must be damage to the nursery and spawning grounds by dredging?  We need real evidence, research, and proper mapping of the inshore waters before we can  assess the harm done and prevent further damage, before it is too late.
As one diver said a child can see that running ‘ancient farm implements’ over fragile ecosystems does damage – sometimes decades of it.  Do we need more evidence before we use basic common sense? If we do then Lochcarron supplies it.
We need to reverse the current policy where despite abundant scientific and video evidence documenting the negative impact of dredging, it is still incumbent upon marine scientists, divers and concerned members of coastal communities, to provide evidence of harm. Surely we do not need to rely upon citizens to provide evidence to protect our seas? Governments are meant to protect the nations assets for us.

MPAs were set up to protect PMFs from mobile gear fishing – this was in recognition of the impact mobile gear was having. SNH’s 2009 report Scallop Fisheries: a view from the statutory nature conservation agencies provided evidence of the negative impact of dredging.

Surely common sense would suggest that Dredgers need to give a good reason why they think they can go into an area,  not knowing what is underneath, and drag their heavy metal gear across it? We are devastating habitats and making species extinct at an alarming rate and this new act of destruction in Lochcarron deserves real thinking about.

Could this also be an opportunity for the mobile sector to take responsibility for better practice too? It would be good if they could show they intend to minimise damage and care about damaging PMF’s rather than just defending their assumed rights to continue to do so?  Fishermen do care about the sea and we could encourage them to be custodians too, we all would benefit.

The General Policy 9(b) in the National Marine Plan gives policy protection to ALL PMFs. How is the Marine Scotland inshore fisheries team implementing the inshore fisheries strategy to ensure that this General policy 9(b)  is being met?  I agree with Marine Link’s assessment that in spatial management one size doesn’t fit all since some areas within 3nm may not be so badly impacted by scallop dredging where as some other areas are extremely vulnerable. Likewise some areas beyond 3nm could be very vulnerable to damage, and habitats deeper than 50/75m can also be very vulnerable to dredging. We need to base decisions on knowledge of the area and make sensible decisions which preserves all the important areas not just PMFs.
I sympathise with politicians who often feel pressured to take decisions based on short term demands or party political agendas. Indigenous leaders try to make decisions looking 7 generations ahead. This may be ambitious for modern politicians but we should aspire to a long term view – after all we will be judged by future generations for how we act now. It would be good to think the right choices were made.
We very much hope you will choose to make this an opportunity and a turning point. That way we might be able to look back on this sad  act as a positive moment in the history of our seas. I look forward to that.
Best wishes Sara Nason

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