The recent announcement from the High Ambition Coalition at the UNITED NATIONS that 30 percent of the High seas will be protected – is a story of hope that big changes are possible. We need that kind of High Ambition Courageous Coalition here in Scotland. 

We wholeheartedly support the impulse motivating the HPMA policy: more umbrella ecosystem protection is urgently needed.  However the Bute House Agreement was a political deal brokered between coalition parties. Whilst the intention was good, it would need to evolve significantly and become evidence based before it could achieve anything like what is needed in the inshore area –  we cannot afford to have policies driven by political expediency.  We would therefore be concerned if the policy is implemented purely to fulfill a political commitment without a much deeper independent analysis of the issues involved as well as how to achieve a just transition – before it is implemented. We need politicians who have the spine to serve what is in the public good – even if that does not serve their career. 

We share our analysis below in the hope that the HPMA’s consultation can represent a turning point – but it needs to evolve. We urgently need solutions driven by scientific and economic evidence to recover our seas and fisheries, otherwise we face some costly unintended consequences. This blog attempts to take the reader by the hand and explain what has gone wrong, the evidence we have, and what would work better. In the hope the HPMA process could evolve and become the turning point we need. 

UN reference


Sea Change Wester Ross is a cross-sector thinktank bringing together perspective’s and representatives from low impact fishing, Wild fishery boards, tourism & heritage, scientists, academics, artists and writers.  We are a voluntary group originally formed to reverse the damage done by the lifting the 3 mile limit and to advocate for the recovery of the Wester Ross Marine Protected Area. An area of vital importance as the largest ‘Maerl’ MPA in the world. Our concerns now include the expansion of open cage aquaculture and its multiple impacts – including on maerl. The north west is one of the last strongholds of this keystone species in Europe. We have no commercial interest to declare – as a group we speak for the public interest. That often aligns with the low impact creel and dive fisheries interests.


On a local scale HPMAs or no take zones will be welcome to conservationists if carefully located – however the implications of buying into an unreformed HPMA process at a national level would be to accept a policy which fails to meet the need of our times. 

We need an integrated, holistic and evidence based approach to ensure that fisheries and conservation measures work together in order to achieve three aims:

  • Maximise recovery of the inshore ecosystems and fisheries. 
  • Minimise impact on sustainable jobs 
  • Make a transition to a marine economy based on truly sustainable principles and a low impact and low carbon fishery. 

To achieve this we need to decommission the trawl and dredge sector and manage the creel and dive fisheries much better, with the aim to be able to fish indefinitely avoiding the collapse- recovery-collapse spiral of decline across each fishery which is our historic and current trajectory. 

European legislation, DEFRA (1) and Scottish Marine policy all recognise preferential access to the low impact fishers is the way forward. However HPMA’s appear to have an inherent bias towards the trawl and dredge sector as they stand. This is the very sector which is the root cause of the need for HPMAs in the first place – as will be explained below. This anomaly needs addressing. 


(1) DEFRA’s 2020-7 vision recognises that under 10m inshore fleet has much wider economic, social and environmental benefits which makes it the most socially, sustainable and economic way of fishing.“In 2027 fisheries management secures long-term benefits for the whole of society. The overall priority of fisheries management is to get the best possible long-term economic benefits for society through effective management and moderate levels of exploitation, within the two following constraints:”….

Access to fisheries continues to be available to small-scale fishing vessels, even if in some cases that is not the most economically efficient way of harvesting the resource. This is because the wider economic, social and environmental benefits of small-scale fishing can outweigh the comparative inefficiency in harvesting the resource and make a significant economic and social contribution to the lives of individuals and coastal communities, for example, by providing jobs, attracting tourists, providing high-quality fresh fish and maintaining the character and cultural identity of small ports throughout England.”


When the UN Secretary General starts to sound like an activist or Extinction Rebel – warning us that Government’s cannot be trusted – then things are serious.  Sadly whilst we recognise the huge pressures on Governments, we also observe that there is a good deal of evidence for regulatory capture by the industries and multinationals which we most need to regulate. Equally much peer reviewed science and economics – often commissioned by the Government itself, is either ignored when inconvenient or buried in the long grass to avoid tackling the big problems.

The truth may be inconvenient but we ignore it at our peril.  

There is also plenty of reason to worry when one reads the IPPC report – whilst also noting how the Scottish Government and its marine agencies resist change. But we are still in the moment the greeks called kairos – the opportune moment to act.  That window may close and the decision taken from us by a system collapse – that is unless we grab the moment. Carpe Diem. 

Trust in Governments is essential but for many in coastal communities Scotland’s marine agencies have forfeited that trust.  Particularly Marine Scotland. Therefore we advocate an independent enquiry – we seek independent scientists and economists to review Government policy to find the best solutions and unpick fact from fiction. 


The GENOME Project is an example of an amazing global gathering to solve a problem for the whole of humanity. This is ecosystem thinking or working like a hive where the individuals serve the whole regardless of nation.  This project joined up brilliant minds and experts across the world. Scotland could initiate a similar approach to harness the knowledge to achieve the best evidence led solution – but this would require facing the truth. But it would provide a story of possibility.

As a coastal nation we have some of the world’s leading marine scientists, fisheries experts and economists. These are vital but It would be helpful if conversations didn’t just include the sciences but included artists, storytellers, communicators, social scientists, mythologists, re-wilders, psychologists and philosophers and writers.

Rarely is this the case but all have complimentary wisdom about how the human story can change. In our unbalanced culture the emphasis on science and economics rarely includes the understanding that humans live in a world made from “stories” not facts. The wild, nature and beauty is also important for our psychological wellbeing. And animals have rights too and are sentient like us. We need to be more holistic and inclusive in our thinking across the board. 

Partisan competitive politics can hijack good ideas. For something as serious as our nation’s future a cross party committee like the RAI Committee could supply the unity and the courage to be high ambition and look deeply at the evidence and the impact of all the cumulative issues in the seas. Yet this requires becoming a seeker of the truth and deep self awareness at a personal and cultural level. As Jung said our world hangs on a thin thread and that is the psyche of man. We now more than ever require a depth of awareness of human psychology and the disowned shadow projections and denials of a culture that needs to evolve fast to survive.

If Scotland acted wisely on independent evidence it could be the world leader it already (wrongly) claims to be – the only way is to decommission damaging industries to achieve “good environmental status”.  This means biting that bullet. It is already a legal obligation which Scotland signed up to as part of Europe’s Marine Strategy Framework Directive which is now Scottish Law.  We need to apply that and that will need a culture change at Marine Scotland and other agencies. For at the moment Scotland is bottom of the class with its head buried in the sand.

(Reference to legislation which turned European marine law into Scottish Law at the close of Brexit needed)

(2) UN chief accuses governments of lying in damning climate speech | The Independent

Trust in public institutions: Trends and implications for economic security | DISD


The three core elements of the Bute House Agreement need much more clarity.  Without clarity on the exact meaning of the proposal we can only outline our concerns and offer an alternative policy which we think could achieve what is needed. 

1- 10% of Scotland’s seas made into highly protected areas (we assume this is intended to be what is better known as “No Take Zones” – given it is differentiating itself from the Marine Protected Area network which has a wide variety of management measures and counter to most peoples logic – actually allows parts to be open dredge and trawl in many cases.

We want to check if HPMA is 10 percent of inshore and 10% offshore or needs to be found inshore only? 

2- A cap on effort within 3 nautical miles. 

What a cap means is uncertain. Does it maintain existing levels of fishing with no expansion? Or does it mean reduced effort?  If the plan is to push existing levels of fishing in to a smaller area, this will force the same amount of fishermen into smaller areas where they will compete for less ground – this could make the situation worse in the 90 percent of areas not protected. But if this is a “cap” or a ban /reduction on fishing effort and a reduction of trawl and dredge inshore this would be meaningful and achieve a great deal. 

Our preference would be a policy that aligns with the evidence for a ban inshore on trawl and dredge. As well as no more expansion of salmon farms /and a plan to decommission open cage salmon farming. 

3- More Management measures for MPAs. 

Proper management for the MPA network is an urgent requirement. MPAs should not have bottom towed trawl or dredge inside them at all – nor any further expansion of open cage salmon farms. Indeed industrial methods of fishing and farming need to be phased out of the inshore – they are not sustainable.  That is an evidence based comment not a personal opinion.

Our concern is that apart from a “CAP on effort” –  there is no plan for the 90 percent not protected or to decommission, reduce or ban industrial fishing methods other than in the 10 percent.   This is a major flaw. 

Our Preferred Policy. 

As members of the Oursea’s coalition we favour moving directly to ecosystem protection across the whole of the inshore area and the return of a variation of the 3 mile limit.

This would be a modernised version to account for open cage salmon farms and dredgers.

 Indeed it would be an exercise in good Government if a proper exploration of the science and economics behind extending the previous 3 mile Limit protection out to 12 miles could be undertaken – as a phased decommissioning policy over time.

A boundary line is policeable. However a complex patchwork of different measures has proven – at least in the case of the MPA network to be un-policeable with regular incidents of illegal dredging around Scotland. With only a small handful of MPAs with complete protection from dredgers – which amounts to a very small percent of the inshore protected –  even these are getting illegally fished regularly.  

Marine Compliance seems unable to cope. Or even unwilling judging from calls to compliance which have varying response from efficient and willing to apathetic and disinterested. There is an institutionalised culture that needs changing. 

It has required very active community and fishermen volunteers to gather evidence, survey and raise the alarm when illegal fishing continues – which puts enormous pressure on individuals. We need to be practical if resources are limited. But the main reason to decommission to a boundary line is to restore the ecosystem, build climate resilience and a more low impact fishery. 


A scallop dredge

The ocean is the lifeblood of Earth. Of all the marine species, 98% live on or in the seabed. (reference: The fish and sea mammals that swim in the water column also depend on the seabed for feeding and spawning grounds or nursery areas – or at the very least their food does.

The seabed stores vast amounts of carbon. The creatures of the seabed recycle nutrients and their actions are connected to water quality. In other words life on earth depends on the health of the seabed and it’s creatures. Everything is connected. 

 A good deal of the breeding and nursery grounds for the commercial fisheries are in the inshore shallower areas were we fish the most intensively on the seabed. Dragging heavy metal over it. It is NOT like ploughing a field. It is like ploughing a virgin rain forest with birds and animals in it. We destroy their homes, foods, breeding grounds and lives. We need to eat but so does the next generation.


The Inshore is 90,400 sq kilometres of sea bed. If 10 percent is found inshore (within 12 nautical miles of the coastline) this would be 9040 square kilometres protected. Wester Ross MPA is 600 Square Kilometres. So 10 percent would be the equivalent of 15 X  Wester Ross Marine Protected Area. 

If this amount of area were to become “no take zones” this would be likely to displace many low impact creel fishermen, (as well as dive fishermen and anglers ). This would have a considerable economic impact on coastal communities like Wester Ross with a considerably large low impact fishery – and this would be without a corresponding and significant benefit in ecological recovery.  

Around 80-90 percent of the inshore fleet are creel and dive boats. 

Whilst we support NTZ’s which are good fishery tools if well located, we see a far more urgent need to decommission trawl and dredge across the whole inshore – not just the 10 percent, and rather than to displace the low impact fishermen to find ways to manage the fisheries to maximise productivity and ecosystem recovery and minimise damage.

Low impact fishing – in most habitats is compatible with restoration if not over fished. This ensures recovery whilst maintaining jobs in coastal communities. This is common sense wisdom.

See the section below on artisanal fisheries co-existing with conservation. Whilst the Scottish Entanglement Alliance is key to solve the problem of creel expansion and that is a serious issue. This is easily solved if the Government has the will. Instead it has pulled the plug on funding for S E A which is the reverse of what it needs to do. 


If the root cause of the damage to our seas – as well as why we need HPMAs in the first place – is because we have allowed trawlers and dredgers to drag metal teeth and nets over the inshore seabeds since the 3 mile limit was lifted (which has done enormous damage). Then why is the policy not focused on dealing with the root cause of the problem over the whole ecosystem  – rather than to allow the damage to continue in 90 percent of the seas? 

Independent marine scientists like Professor Callum Roberts amongst many others, advise that the ecological and economic benefits of removing trawl and dredge from the inshore are obvious. He speaks for the majority of marine scientists working outside of the Scottish Marine Agencies – which sadly in our opinion have lost site of the wider public interest that they serve and have become too close to the mobile sector and industrial fishers. 


10 percent protection will not restore our food security if 90 percent of the sea floor is still damaged. As we discovered during Covid, we are highly vulnerable to the challenges of global pandemics and supply chain breakdowns.

We need our food security. It is vital. 

When the 3 Mile Limit was lifted in 1984 the purpose behind the deregulation of “red tape” was to replace layers of historic regulation with up to date evidence and a more modern and simplified regulation. That never happened for a variety of reasons and instead the   

“freedom to trawl”  became the default policy and reform never happened.  Forgotten about in the gold rush perhaps, or just a lack of political understanding of the sea. We have paid a very very heavy price for that. Rather than a low impact fishery we have a high impact fishery. 

We also have politicians who have little marine understanding, and think in terms of economics and votes, which is just not joined up thinking when we are a part of Nature and reliant upon it for our survival. This separation consciousness is at the root of the problem.

Currently around 90 percent of the landings in Scotland for (prawns) is caught by trawlers- producing a low value product with a very high environmental and carbon footprint. 

This is not sustainable. Forty years after the lifting of the 3 Mile Limit we now have ample evidence to know that protecting the seabed from the most damaging industrial processes allows for low impact fisheries to begin to thrive. That should be our goal. Even if it is a painful reality that needs facing. 

Ironically the HPMA’s proposals have a built in  bias in favour of the very method of fishing (trawl and dredge) that has CAUSED the damage and risks disproportionately harming the low impact fishermen which could be encouraged to be the custodians of our future fisheries. 

That is why so much fear has been created because its been badly thought out and managed and because of that – the fear has generated opposition. All good policies can expect opposition but this has made good policy even more difficult to implement by stirring up a storm of fear over a policy which just doesn’t work.


80-88 percent of Scotland’s fishing fleet are low impact fishermen (hand dive and creel fishermen) if you count boats. With 10 percent of areas highly protected this would mean that a percentage of low impact fishermen as well as trawl and dredge fishermen would have to be relocated/displaced.  

Unless there is SPATIAL SEPARATION This is likely to lead to conflict between sectors as the same number of fishermen compete in a smaller area – the 90 percent. 

Logically this would also lead to an intensification of fishing, causing more fishing and greater damage to the seabed habitats, likely to be spawn, nursery and feeding areas for some species. 

And also deeply concerning is the continued bycatch of fin fish and flapper skate in the 90 percent unprotected. Wasted fish are arguable one of the core reasons preventing fin-fish recovery.

This all falls way short of dealing with the true nature of the problem we face. Not much different from the existing policy of damaging habitats and fishing down the food chain until fisheries collapse or are no longer productive. 

 In short would the 90 percent be left to decline further and further? What management of the 90% is proposed? We do not know. 


One of the unintended consequences of lifting of the 3 mile limit was gear conflict caused by competition for ground between the low impact fishers and the industrial fishers – competing for the same species and ground.

Prawn trawlers and prawn creelers on the same ground and Scallop hand divers, crab and lobster fishermen and scallop dredgers also on the same kind of ground. Often in much shallower water than the prawn trawls.

Getting creel gear caught in a trawl net or prop is a great inconvenience for the dredge and trawl sector, but to the creel fisherman it can be disastrous to lose gear which is not insurable. Thousands of pounds have been lost this way. Livelihoods too.

For the dive fishermen they have had to put up with finding their fishing grounds wrecked by heavy metal dredgers. Pushing competing sectors into smaller areas will increase gear conflict which creates community division, a lot of stress and wasted money. 

Given that there is no mention of SPATIAL SEPARATION or corresponding reductions in numbers, the fishermen would be forced to compete more fiercely for ground. Gear conflict is generally at the creel fishermen’s expense, and they tend to be the losers in terms of ground and costly and uninsurable gear.

The HPMA policy is therefore counter intuitive if the aim is to recover the inshore, have a more sustainable fishery and give preferential access to low impact fishing.  It is also avoiding dealing with the real problems whilst looking as if it is “doing something positive” 

Actually its hard to know what the consequences are – positive or negative because of all of the uncertainty as well as pushing fishing grounds further away from home may cost more in fuel and carbon miles. 


Our request is to go back to the drawing board and create a policy based on evidence and address the root cause by beginning the process of decommissioning the damage causing industries? Our focus needs to be on managing fisheries for the long term with an eye on recovery of the stocks and habitats across the whole inshore. 


Scotland at least in theory adopted the policy of preferential access for low impact fishers as the stated policy. IF the 10 percent of HPMA is found offshore out to 200 miles, or is  spread over a mixture of offshore and inshore then the recovery would be less – and of course the detrimental impact on artisanal low impact fishers is less too. Equally it would provide an even less meaningful recovery of some of the most biodiverse areas of seabed closer to shore. 

The HPMA policy contorts common sense.

Protecting 10 percent is not an “ecosystem” based approach. When it ignores the ecosystems in the 90 percent unprotected. Potentially leading to an intensification of effort if the freedom to trawl and dredge in these areas continues. 

The Government should be encouraging and working with low impact fishers to become the custodians of the seas and our future fisheries. Not making life much more difficult by asking them to compete in areas with industrial fishers even more.

Restoring the WHOLE and managing fisheries within sustainable limits is the only way to achieve “good environmental status”. That means moving to low impact, low carbon fisheries with 100% protection from the trawl and dredge sector – enshrining this preferential access to low impact fishers as the way forward in the  inshore. 


“Management of The Scottish Inshore Fisheries; Assessing The Options for Change” 2012

The Government commissioned a report called “Options for Change” which was nearly 400 pages of analysis providing the economic evidence for excluding the mobile fishery from the inshore. The author described the return of the 3 mile limit in the Clyde as a “no brainer” from an economic perspective – let alone an ecological and climate perspective.  

Sea Change asked the authors to look more carefully at the Wester Ross area of the North West. The result was the same. It did help us secure a dredge ban in the Marine Protected Area  but the wider evidence for an inshore limit has been ignored by the Government. 

Indeed it has actively ruled it out.

There are countless examples of peer reviewed science that have been ignored.

If anyone is interested a list can be provided.

Options for Change was followed by SCFF’s economic analysis


Done by the same authors this looked at the prawn fishery and the benefits of creel fishing replacing trawl fishing inshore. Again a no brainer if what one’s aim is, is value for the nation, a low impact fishery and recovery of the seas. 


We need not only to consider the multiple impacts of prawn TRAWL fishing in terms of habitat destruction and the terrible bycatch of other species wasted and discarded – but also how Scallop dredgers  have devastating environmental impacts on Scotlands habitats.

Whilst scientific evidence is not really needed for this – a child can see that dragging 6 inch metal teeth over the seabed does incredible damage –  we nevertheless do have the science to reassure us that there is massive damage – particularly to maerl. 

This is not to mention the massive carbon footprint of both methods of fishing. 

Scallop dredgers have turned priceless keystone habitats into dust which are not reparable even in 1000 years.

Do diners know that when the tucked into the fish pie with a small meaty scallop inside covered in white sauce that Scotland’s equivalent of the barrier reef had been ground to dust to get it? And this was legal? 

A tragic loss to Scotland which will be felt by generations and generations. 

We fish species to collapse, destroy the keystone habitats and wonder why we have a crisis.  Yet the Bute House agreement side steps the measures to reverse that insanity. 


But this needs brave well informed politicians prepared to make policy on science and sound economics and in the public interest. Not party or politicians interests.

We need an ecosystem approach, valuing all parts of the web of life, and not just 10 percent, or a hierarchy of species. The system is entangled, yet we have split management of the seas into separate parts. Nature and Fisheries. They are one. 

Evidence from around the world suggests the greater the management and protection is, the better the recovery. It also suggests Artisanal fishing – if regulated well – can continue with improved management, and using a mix of no take zones and low impact fishing areas – recovery and jobs can both be possible.  


The irony of all ironies is that HPMAs are only needed  because we lifted the 3 mile limit.

It was after this that most fin-fish commercial fisheries collapsed.

The seas have been stripped of large fish, sea angling has collapsed, and we are now fishing the bottom of the food chain. It’s not just the 3 mile limit, its technological advancement, climate issues, plastics, acidification and other issues. However the last two shellfish fisheries have declined in size and catch per unit of effort. And that is the lifting of the 3 mile limit and the lack of management of creels too.  

The north west once had a super abundance of all kinds of fish and shellfish – due in all probability to the large blankets of maerl – a keystone habitat supporting fisheries that once carpeted the coastline before dredgers and trawls.  Herring spawns on maerl and these two keystone species fed the whole web of life.

Yet we do not address the problem with 10 percent HPMAs. 

They are political targets which do not address the root cause of the damage. It is cart before horse.


We only have one rational option and that is to manage a just transition to a low impact fishery across the whole ecosystem and to ask how much that will cost and how to do it well. 

Entangled Nature: why the whole of the inshore matters and why removing seabed damaging fishing is the only way forward. 

Whilst keystone habitats and species have higher interdependency than other species and are top of the list for protection  – we have not yet mapped all the links in the chain which holds the system together.

Until recently and in some countries we used to dredge maerl for garden fertiliser not understanding its keystone role. We now know that this destroys the fertility of the seas and undermines fisheries.

What we now dismiss as ‘ordinary’ seabed – and ordinary seaweed, in our hierarchy of species is also a nursery, or breeding ground to some species.

We should be cautious not to impose a hierarchical and bureaucratic approach to a system which works like a web, and is entangled in ways we may not have yet imagined. That is why low impact should be the future we base fisheries on. 

There is limited surveying of the sea bed and logic would suggest protect it until you know. Whilst the precautionary principle has to be carefully used it is necessary to apply it until you have surveyed. Instead it was give permission to fish it destructively – and then learn what is down there….

Some fish are more fertile the older and bigger they get – the mature ones can be many times more fertile. This suggests that No Take Zones can enhance fisheries – if locations are well considered. Adding resilience and productivity to the fisheries and improving the carbon sequestration.

If these are selected by marine scientists and fishery experts, working with fishermen – rather than by politicians and popular vote they are likely to enhance management. 

However knowledge of habitat and species and fishery is essential to select areas for maximum benefit and minimal economic impact to help restore fisheries and keep economies afloat. We have concerns about a political process driven without a sufficient knowledge base and detailed discussion.


The Green party dropped its manifesto policy on the 3 mile limit and signed up for a deal on  10 percent HPMAs. Why?  

We can only speculate.

Marine Scotland brokered the Bute House deal for the Scottish Government with the Greens.

Marine Scotland likes to say they treat all fishery sectors equally and are “balanced” and fair. Unfortunately whilst that sounds fair and decent – it does not account for the very different environmental and economic impacts of the two sectors in the context of a Nature emergency. This “balance”   leads to a scientifically and economically incoherent policy in the context of the 6th mass extinction and a climate emergency and a world in which a species may be going extinct every 20 mins.


Having  rejected the 3 mile limit for consideration in the Future of Fisheries assessment despite widespread support for it in fishing and coastal communities – a deal was struck which contorted a common sense scientific and economic approach.

The unspoken objective of Marine Scotland – if actions speak louder than words – is  to avoid addressing the root cause of the problem across the whole of the inshore.


Impacting the mobile sector disproportionately is EXACTLY what is needed.

But Marine Scotland hide behind a mask of “fairness” whilst being unfair to the public and the next generations it is meant to serve.

A policy slanted in favour of the most damaging fishing methods at the expense of the low impact fishers becomes simply a way to limit meaningful change. And meet our real sustainability targets. Yet all this remains invisible to most as they just do not know.

We need that REAL change – we cannot fool nature, or the long term implications of failure on communities or fisheries. This has REAL LIFE IMPACTS. We are cheating ourselves. It is suicidal behaviour by the institutions were asked to trust.


 The results of Marine Scotlands policies to date are abundantly clear in the Scottish Governments own MARINE ASSESSMENT 2020 (leaked to the ferret and shared in the article below) 

Our energies need to be focused on how to solve the problem of putting trawl and dredge out of work – as well as shifting supply chains in a creative and compassionate way. Not remaining in denial of the problem for the sake of a party’s political ambitions. 

The 3 mile limit was abolished with the intention to modernise and rethink the management of the whole inshore. That rethink never happened – yet slowly the freedom to trawl has become enshrined in the mind set of the marine agencies and the  “free for all” or race to catch everything is the ‘normal right of the fishermen’ it surely is not.

We still need that root and branch rethink that in 1984 was the plan.Could politicians be brave and make the HPMA consultation  that opportunity? It is entirely possible to fish sustainably if well managed yet the Government has never achieved this – and the public remains unaware of how much commercial lobby’s impact fishery policy. We hope that is changing.


Subject: Facts and figures about Scotland’s sea area (coastline length, sea area in sq kms) | Marine Scotland Information


The freedom to trawl or dredge in 95% of the inshore area is considered a corner stone of our  open market policy. The right to trawl inshore has existed since 1984 when the 3 mile limit was lifted. Of course not all of the 95% is trawled or dredged as some ground is not suitable but the point is its policy to make it possible if the technology and habitat allow! 

Surely this is the problem we need to solve? 

The amount of the inshore area that is actually protected in the MPAs network from the mobile sector ( from dredge and trawl ) is currently less than 4.5 percent. Protecting a further 10% of the seas, or turning some of these MPA areas in to highly protected areas will not address our national problems. 

Especially if this 10% is spread between the inshore and offshore. And not part of an integrated and well considered policy. 

90% or 85% of the inshore area will still be open to dredge and trawl. 

With the dredge and trawl footprint being one of the key problems keeping our inshore from recovery this makes no sense.

The side scan :


Since the 3 mile limit was lifted 58% of the seabed is “highly disturbed” by trawl and dredge. This 58% refers to habitat loss on the seabed which will also be reducing the seas carbon storage. 

This figure originates from the OSPAR assessment portal which covers the period 2010–2015. It shows that up to 86% of the grid cells assessed in the Greater North Sea and Celtic Seas have evidence of some physical disturbance of the seafloor from bottom contacting fishing gears, of which 58% of areas show higher levels of disturbance. Areas assessed in the Celtic Seas and the English Channel have higher levels of disturbance than other regions.’

The OSPAR assessment shows the area between Wester Ross Marine Protected Area and Lewis have high levels of disturbance as do other areas around Scotlands inshore. This figure is specific to disturbance caused by towed demersal fishing gears.  This is likely to be Stornoway dredgers and trawlers and East Coast boats. 

The seabed footprint ignores the other impacts which are also happening at the same time:


– over fishing by pelagic (mid water) fisheries,

– demersal trawl bycatch, discarded fish

  the impact of salmon farms on the sea lochs with pollutants, chemicals and marine plastics,

– invasive species,

– disease, and genetic introgression and lice in wild fish caused by salmon farms

  cetacean entanglement

  sound and light pollution

– Nutrients and chemical land run off,

– climate change

The  list of human impacts could go on….if you were a creature in the sea there are multiple impacts that they experience simultaneously – they do not just experience the one impact the particular bureaucratic agency was set up to deal with or identify  etc etc. 

These animals live in the real world experiencing many of them at the same time.

The Satellite image of disturbed sea floor in Scotland comes from SCFF ’s 3 Mile Limit Pamphlet referencing Scottish Government figures in the Clyde.


The Scottish government has detailed assessments of seabed activity and damage from VMS and AIS records which will have most of the boats above 12 meters tracked and logged – why boats under this do not need to be tracked is hard to understand given they can do great damage – but none of these figures are publicly available. They are gathered in commercial confidence. Convenient for the industry.

However the Government figures did feed in to the Options for Change assessment of the 3 mile limit which was according to its author a ‘no brainer’ to bring it back.

Due to the “freedom to trawl policy”  in 95 percent of the inshore – a great deal of the inshore would benefit from urgent protection from trawl and dredge. 


In SCFF’s pamphlet on the 3 Mile Limit it says 

“It is possible to substantially improve the health of our inshore ecosystem and our inshore fishing industry in a relatively short space of time and with relatively little effort. The improvement could be so substantial as to double the amount of fishermen employed inshore, double the amount of vessels operating inshore and double the revenues generated from the area. Remarkably we think it is possible to do all this without increasing the present catch, and do so with substantially less environmental footprint. Further still the implementation of this proposal would simultaneously reduce the bethnic disturbance, discard and by-catch ratios for those fisheries to practically zero. 

Yet this has been ruled out by Marine Scotland and the Scottish Government.

This is even after the lifting of the 3 mile limit – when the Scottish Government’s fishery landing figures show a 98% decline in commercial fish landings – which was essentially the collapse of commercial fin fish.  Forcing fishermen in to shellfish fishing.

The fishery collapses are an indicator of massive declines in biomass of many of the fish species that were once abundant in the inshore. Once the fish were fished out the shellfish on the seafloor were targeted – continuing to impacts habitats and other species living there. 


The collapse of the white fish such as cod and haddock, whiting and then the hake, plaice, saith, whiting was preceded by the collapse of herring and mackerel fisheries. 

In the north west alongside these losses went fish which locals remember were once in abundance such as dabs, flounder, sole, turbot, and halibut. (and salmon and sea trout – another story)

Large bycatch species like flapper skate which could not escape the nets –  are now on the critically endangered list as a result of trawling.  All these fin fish fisheries have collapsed on the west coast and  have not recovered to commercially viable levels. 

Catching  adults and juvenile fish before they get a chance to breed or grow  as discarded bycatch should be stopped – but this destruction of future fisheries is compounded by the loss of the fish habitats by damaging the seabed (feeding, nursery and spawn grounds).

Trawling simply hampers recovery.  

The breeding habitats and feeding grounds are damaged and many are caught in trawls as by catch or offshore as the targeted catch in vast nets. 

Climate change adds to the problem as fish move north.


Ecological meltdown in the Firth of Clyde, Scotland: two centuries of change in a coastal marine ecosystem. – Abstract – Europe PMC

Alan Radford and Geoff Ridlington Options for Change

Management Of The Scottish Inshore Fisheries; Assessing The Options For Change –

The Misallocation of Nephroph Fisheries THE MISALLOCATION OF NEPHROPS STOCKS – SH2.pdf

Out of the Blue (SCFF on Blue Carbon for Cop 26)

Marine Scotland’s Mismanagement

Marine Scotland accused of destroying thousands of Scottish fishing jobs | The National

Nature Article on benefits of MPA and Management. 

See Sea Change’s First Public Consultation Response

Bill Ballantine & Goat Island Evidence etc 

Lyme Bay – Blue Marine Evidence on how creel fisheries can be compatible with sustainability.

Photo from Seachoice of Bycatch


With only scallop and prawn fisheries left – and the smaller crab and lobster fishery declining – we are fishing the bottom of the food chain – with just two main species left as viable commercial fisheries.

These fisheries, scallop and prawn have declining stocks.

Professor Ben Halpern commented in 2014 that with just two fisheries left and no resilience built in to the system Scotland’s ecosystems are at risk of an unexpected unravelling of the system and from that recovery can be difficult.

How close are we to that process in the Clyde or the North Sea, or the Minch and other overfished ecosystems? 

We do not know. WHY? No one is asking that question.

But Ben Halpern’s observation suggests we need to ask that.  Lessons have not been learnt from other collapses. 


Marine Scotland says Ninety-five percent of UK records of inshore and deep burrowed mud are from the northern North Sea and the sea lochs of western Scotland and the Hebrides and are of international importance. Yet Burrowed mud is mostly  trawled for prawns – damaging this important carbon sink.

According to some reports it has greater carbon storage than peatland and the amazon? Yet we allow it to be damaged by trawlers for scampi a low value product with a massive cost.

Newspaper and science sources tbc?

The impact of damaging the seabed by metal dredge  – and depopulating the fish which are wasted as bycatch must also have a huge carbon footprint which is not measured as far as it is possible to tell.


Millions and millions of tonnes of fish, shellfish and sea mammals have been killed simply to discard as BYCATCH from trawl and dredge fishing since the lifting of the 3 mile limit.

Not all of it gets brought up on deck and declared. Much goes unrecorded. Some is illegally sold but who can blame fishermen for being horrified by the wastage and prohibition on using it or selling it. 

The dredge leaves damaged and dieing creatures on the seabed – uncounted.

The dead fish discarded and habitat loss is an inevitable by product of a non exclusive trawl and dredge method of fishing. Both have now been dragging metal across the seabed for many decades in most of the sea.

The damage is unthinkable to consider and many divers are eye witnesses to the wastelands created. One of SCFF’s chairman Ali Hughson who wrote a letter in 2014 asking for it to stop.

It fell on deaf ears.

Wastelands in the Sea by a Scallop Diver on Vimeo

John McIntyre is a scientist and Earth Systems expert and member of Sea Change. He produced a graph showing the decline of bycatch in the Scottish trawl fleet.

This was an indicator of bycatch declines  – it will only be an indicator and we can extrapolate that the declines will be even more stark as the dredge bycatch is not counted but was going on simultaneously.

The decline indicates fish species caught in bycatch and landed diminishing rapidly around the time of the 3 mile limit. This is unlikely to be a result of better fishery methods or escape holes in nets. Trawlers still regularly discard large fish and flapper skate they catch in their nets which cannot escape. But the graph indicates how gradually there was  less and less to catch.

Shortly after the 3 mile limit was lifted scientists in the Clyde counted 10,000,000 juvenile fish being wasted in 10 months in trawl bycatch. ( figure from : Fish Discards Number and Kg per 100kg bulk from Trawls from Jul 06 to March 07.)

Professor Callum Roberts referred to the damage done in the Clyde in a scientific paper as an “Ecological Meltdown” – this is referenced above. 

None of this has led to policy change.


For nearly 4 decades this destruction is likely to have prevented recovery. On top of the rug being pulled from under the oceans feet by other aspects like climate, acidification, plastics all reduces its resilience.

The rate of discarding in the Clyde sea Nephrops fishery has been estimated at between 66-80% according to the Clyde Ecosystem Review. See section  6.8.3 of this review.

This means the bycatch biomass (fish left to die on the deck or tossed overboard dead or landed ) is wasted and often exceeds the shellfish actually brought to market and eaten or fed to farmed salmon.

On land in any other industry this would be an obscenity.  

The current problem is in part a result of a lack of planning at sea, something required by the Marine Scotland Act and the National Marine Plan. We have the policy framework we rarely actually implement it.  


(we can only imagine the difference between hand dived and dredged – for there is no comparison between a dredge and a hand)

This fig. was on page 4 of Reducing The Footprint – Moving towards Low Impact Fisheries.

By Seas at Risk . It says:

The fuel needed to catch and land a kilo of Norway lobster (prawns) can be reduced from 9 litres to 2.2 litres by switching from conventional trawl fisheries to creel (trap/basket/pot) fisheries. Such a switch would also reduce the impacted seafloor area from 33,000 m 2 to 1.8 m 2 per kilo landed Norway lobster. Similarly the amount of discard would be reduced from 4.5 kilo to 0.36 kilo per kilo landed Norway lobster. Not only would such a switch to creel fisheries significantly reduce environmental impacts, it would provide the consumer with a Norway lobster that has not been squashed in a trawlers net and is thus of a better quality, higher value to the community with less cost.

Whether this square footage is 100 percent accurate is not the point – its accurate enough to reveal a truth that there is no comparison between the damage done to the seabed by trawler and that done by creel fishing. None. 

And the value of the prawn caught by creel is a great deal higher with less seabed damage and by catch. Yet  speaking out about trawling has often had their voices suppressed and debate shut down.We need the debate. But not one that blames the fishermen but works to solve the problem, given they have been encouraged by Government to fish in these ways. 

What is also to be noted is Ninety percent of the stock is fished by trawlers and 10 percent by creel fishermen. This tells a story of a policy which is economically incoherent unless your only interest is feeding a mass market at the cheapest possible consumer price. 

This might have been a goal 50 years ago but we now have to deal with the Nature emergencies. 




The Scottish Government has produced many good policy initiatives that stay in the long grass – whilst offering reassuring rhetoric about sustainability and proposals in the pipe line.

Wonderful glossy brochures and good branding do not fool nature.

And much peer reviewed science and evidence which could have led policy has been suppressed or ignored – in favour of listening to commercial lobbies offering jobs. 

The 2020 report

Government leak reveals destruction of marine wildlife

The results have been a rapid loss of vital habitats over the last decade – still being trawled and dredged LEGALLY outside and inside MPAs. 

For much of the Marine Protected Area Network does not exclude trawl and dredge nor salmon farms which have been attempting to expand against many communities wishes. 

Then there is the problem of Marine Protected Areas that ARE protected but are also being trawled and dredged ILLEGALLY.

Sadly dredgers target maerl one of our most fragile keystone species which can take a 1000 years to recover. Often in Wester Ross the MPA which this group spent years working with SCFF to protect. The consequences of the all of this has been devastating and quietly reported in the Governments own Marine Assessment 2020 whilst declaring it positive. 

Some of the most vulnerable species in the last 10 years have declined to almost nothing left and the losses have been rapid and alarming to many species as the leaked report suggests.

Threatened are maerl, serpulid worms, horse mussel/ blue mussel reefs

 Especially worrying is the fact that herring spawning on maerl is still open to dredgers, as is the maerl in Orkney.


Read on if you are not familiar with the marine ecosystem as this may help you get a sense of what is at stake – for those that dive or understand the sea –  this is skippable. 

For those unfamiliar with the sea – Imagine a large forest where animals, small mammals, birds and insects live in trees, bushes and scrubs with fruit and vegetables growing. Communities living around the forest harvest the animals and large insects by hand or by catching creatures in traditional basket traps. These are relatively inefficient methods, but they have a low impact on the forest and a relatively low carbon footprint when compared to other methods. They also provide the community with jobs, food and a high value fresh product to sell to market and to local food outlets. Hardly any of the trees or bushes are harmed by the picking. This method,  if well managed can continue indefinitely and  the forest can regenerate and survive this level of harvesting. 

There are some downsides – it is a relatively expensive product being hand picked and the baskets do have to use bait in the traps. Tragically sometimes larger animals can get caught in the ropes around the baskets – but with ingenuity and intention these issues can be mitigated if proper investment is made to solve them. 

This type of harvesting in the sea is the equivalent to hand diving for scallops which does minimal harm to the seabed and creel or pot fishing for prawns, crab and lobster.  Between 80-90 percent of Scotlands fishery harvesters (creel and dive fleets) use these low impact methods.  

But they only catch 10 percent of the forest’s bounty.  

Who catches the 90 percent landed to market  how do they do it? 


The forrest also has more nomadic industrial harvesters who use machines that drag metal and nets across the forest floor – but they need to log the trees and bushes to get to their bounty on the forest floor. The small mammals and insects living below the trees, scrubs and bushes. 

They are not able to target specific species so they find the right habitat that they live in and drag their nets and catch everything from mushrooms, voles, rabbits, monkeys when they catch the small insects and small mammals they want. The habitats are destroyed. 

The big animals have already been caught and eaten – hunted to commercial extinction and there are only the small mammals / “insects” left ( scavenging prawns and scallops) 

Logging the trees is considered efficient because the machines can catch vast quantities at a time but they also cut down the forests and habitats  –  this damages the chance to get more in the future and of course this harms the other animals in the forests who get captured in the machines and huge nets. Their carcasses are left to rot unused because they are not allowed to sell them.  

Their fuel costs of towing heavy metal through the forest is huge in comparison and the forest releases its carbon into the atmosphere….


Larger animals are now rarely seen. Sometimes the dead animals make up  MORE than the catch that gets sent to market. .This logging and deforesting has gone on at an industrial scale for 40-50 even 70 years in some places – leaving large areas which are stripped of trees and farmed for a small amount of catch and the forest stripped of its large animals –  with few left to catch, live and breed for the habitats are mostly gone.

In just 40 years we have accelerated destruction and done what took hundreds of years to do to the land. The Earths marine ecosystem has gone from an abundant and rich ecosystem to large swathes of destroyed seabed with few fish left. We are now in the 6th extinction crisis. 


In terms of boats and fishermen the loggers (trawl and dredgers) are only around 10-20 percent of Scotlands fleet. They often have to employ cheap foreign labour brought in to do the job  – this way they catch about 90 percent of the annual landings of prawn.  The prawns sold as scampi sells for a fragment of the value of the hand harvested and pot caught animals. 

But they do provide jobs and the consumer gets a cheap product with no idea of the true cost. 

This industrial process has stripped the forest and when the small amount of large animals who are left to breed produce offspring – they are caught in the trawl and dredge nets before they can breed again. The loggers can’t avoid catching these animals when dragging nets along the seabed and the larger Fat old fish tend to be fertile. Its a spiral to destruction. 

the bycatch leaves the animals carcasses rotting or are scavenged discarded and unused. 

The Scottish Government considers the market demand for these cheap low quality food snacks is vital to protect – whilst the destruction of the underwater forest and the logging machines goes unseen as underwater forests turn large areas of once beautiful rich seas into barren wastelands. 


In addition the two types of harvesters are competing in the same areas of forest.

In these areas the loggers destroy the hand harvesters baskets – which cost these traditional harvesters a lot of money, which they can’t get back. 


The industrial harvesters deforesting the sea bed and catching many uneaten and discarded fish are slowly destroying the underwater forests ability to store carbon and create oxygen. The forest is no longer resilient as storms hit it –  making it weaker and weaker as time goes by and the people’s food supply is lost.  

Plastics, acidification and warming seas all have a further toll. Reducing resilience and its ability to bounce back.  Invasive species enter the picture and micro plastics and toxins get filtered up the food chain, first into the stomachs of the small animals and right up the trophic scale to the small amount of large animals still left – some of which – like Whales – have become infertile as a result. 

Chemicals and nutrients pour in from industrial farming and off the land and the whole sea gets warmer and more acid making the animals skeletons and shells more fragile – whilst animals move northwards with climate change…..

The rotting carcasses of many forest animals, birds and insects are left amongst the stumps of trees and torn plants – 


Forgetting that modern farming has demonstrated that this reduces soil fertility anyway.

Unlike more nomadic dredgers,  trawlers may tend to work the ground more frequently – having removed the forest they can harvest the small creatures that live down burrows and scavenge the seabed.

Of course this “ farming “ of the prawn areas reduces the size and number of the prawns over time as it catches the breeding stock too – but this style is more like monoculture farming on land in which the habitat and other animals are repeatedly caught in bycatch and stripped away to focus on one crop. 

Trawlers argue this is sustainable fishing as the trawls can put diesel in the boat and go out at catch their target species from the “farm” in a repeated fashion. Having stripped the ecosystem of everything else as well as the prawns prey, the prawns are essentially able to be ‘farmed’ or harvested repeatedly. 

What is not accounted for is the loss to the target species, the loss to the habitats and the killing of all other species too big to escape the nets in the area as bycatch and the knock on impacts on climate change. 

Fast growing habitats like kelps if left to recover can restore within 5-7 years. Others might never be restored. 

Productivity declines in ever decreasing circles as the ecosystems become less and less able to bounce back ..…

And burrowed mud the habitat for prawns is one of the best carbon sinks. Being destroyed.


Our technology could strip the sea bare for short term profits if we chose. At the moment we are clearly choosing that – by an large.  

We need to consciously choose not to but to the public and many MSPs the whole world under the waves is  invisible.  This fact as well as the misplaced trust in the Government to regulate it on our behalf has allowed this collapse /recovery model/  to continue rather than manage fisheries for long term sustainability.

During war we have to manage our trigger happy fingers on the nuclear button – and we need to be more conscious of our capacity to destroy than ever before. This is what Karl Jung meant when he said “The world hangs on a thin thread and that is the psyche of man”

Our cultures ability to deny the truth and avoid responsibility and ignore our cultures ‘shadow’ projecting it elsewhere – is part of how we got into the mess. 

Trawling, dredging and salmon farming all have a high carbon footprint. They also produce vast waste and fish mortality.  It is possible more fish ( in biomass ) die in the process of feeding the nation by industrial methods – than get to market.


When assessing Scotland in world terms – and from the point of view of 19 different human impacts and stressors –– it is found Scotland competes with the South China seas for the nation with the most damaged seas in the world. The map below says it all.  

This is assessing some of the cumulative impacts. Not all.

This excludes the Aquaculture statistics. Include them and we are perhaps  bottom of the class. Worst than South China Seas? Thats not certain but whatever it is – its not good.

It is important to note that apart from Ben Halpern’s global map no study has been undertaken to assess all the stressors and the cumulative impacts on the ecosystem accounting for ALL human impacts that are accumulating in our seas and which the sea creatures are being forced to adapt to or go extinct.  This is because we have separated Nature into separate parts – with each agency blind to the whole problem. No one currently knows the whole picture.

Ben Halpern et All (2015) reference 


This is peer reviewed science.

Yet the Government still calls our fishery a world class sustainable fishery which is leading the world.  We very much hope the rest of the world is not following Scotland’s highly industrialised fisheries model with little management and much emphasis on meeting market demand, with the freedom to trawl even in the most fragile breeding grounds.

It is not an exemplary model of the future.  

Advanced industrial nations have prided ourselves on our industrial efficiency but efficiency when it comes to killing one another or the exploitative harvesting of Nature – is not a sign of an advanced civilisation. To consciously choose to work in a more artisanal and less efficient but more respectful way would be proof of civilisation.


Evidence from around the world on Marine Protected Areas and No Take Zones ( NTZ ) is that they help improve fisheries if well considered and managed.  The Torridan Box was not well managed despite the fishermen asking Marine Scotland to do so, so it is not the finest example.

Well managed and appropriate to the seabed habitat – artisanal fisheries can co-exist with recovery if managed well and the NTZ  are sensibly chosen by species fished and habitat. 


Lyme Bay in England is an example of a successful low impact fishery which exemplifies how well managed low impact fisheries can coexist with habitat and fishery recovery. Whilst it is not a prawn fishery – but a crab and lobster creel fishery – with different ground and species – it does suggest that sustainable levels of fishing are compatible with recovery and can co-exist.

This was only possible once trawl and dredge were banned – there is abundant evidence of how rich seas existed where indigenous communities managed fishing in an artisanal way. No take zones should be part of a recovery plan for well managed fisheries but we need habitat and fishery specific measures.


To mitigate bycatch of cetacean from creels the Scottish Entanglement Alliance is developing trials for weighted ropes and in future even ropeless creels may be possible.

These are vital considerations and should be funded by the Scottish Government. 


There are a few species which are so fragile as to be exceptions needing full protection from all fishing.  Some types of Maerl and Serpulid worms are prime examples.

Some of the more  scattered maerl beds which move into waves with storm surges – may not be damaged so much by creel fishing given  these habitats are rarely targeted by  crab or lobster or prawns creels as they are not the target habitat for the species they catch – so protection is primarily only urgent from scallop dredgers.   

Essentially the main habitat for creels is burrowed mud and we are told that even the sea pens tend to rebound from creel according to Professor Jason Hall Spencer.

Therefore the benefit v the cost of banning creel and dives needs proper assessment before unnecessarily harming jobs. 

Lyme Bay References can be found on Blue Marine’s website.


Adding to the destruction of trawl and dredge, is the footprint on the seabed of open cage salmon farms. Located in the western sea lochs and Islands of Scotland,  food waste and sewage falls to the seabed and rots – smothering the habitats below and attracting scavengers which eat the poisoned feed which holds chemical anti-lice treatments. Killing many of the crustaceans. 

The intense impact of organic waste feed and faeces is quite local – although it can be carried on currents as far as 4km away – but the less visible impacts of salmon farms are multiple and cumulative.  Especially if there are many farms in the same area. 

See film Jason Hall Spencer in the Highlands Pink Maerl and Salmon Farms

The main issues are listed below – but by no means all of them: 

  • The impact of flesh-burrowing sea lice swarms which come off salmon farms (due to the high density of fish in pens)  generate huge numbers of lice which attach to migrating wild salmon and sea trout – so they are eaten alive or weakened and become easy prey. Destroying populations. 
  • As salmon and sea trout populations plummet the survival of other species such as fresh water pearl mussels come close to extinction.  Or already are. 
  • Farm escapees cause genetic introgression in the wild fish and can impact the ability of wild fish to survive as their evolutionary adaptability to each river system is hampered  – held in their DNA/ genetic evolution unique to each area.
  • The river system and watershed is harmed as the dieing salmon – once in great abundance – fed the whole ecosystem, animals, birds and the trees too. 
  • The impact of the extra nutrients from fish farms flow into the water and cause slow growing species to die off slowly as the habitats they are adapted to change. 
  • In Wester Ross this particularly damages maerl and fish farm nutrients can encourage filamentous algae growth which can slowly undermine or kill maerl which needs light.
  • The Impact of sea lice chemicals on crustaceans and plankton in the surrounding area can have very long lasting impacts on the  abundance of crustaceans in the area. 
  • A proportion of plankton is crustacea – damaging the whole fertility of the water column and feeding for other species. 
  • The salmon are treated rather like battery chickens and enclosed in high density feedlots farms. Often eaten alive or diseased. 
  • Around a quarter of all salmon die in the process. Often painfully. 

These dead fish known as “Morts” range from  25% mortalities in some years to sometimes 40 % or more on particular farms. A direct result of the industrial process and welfare conditions of fish bred in close proximity. 

  • Farms cause a great deal of plastic pollution including the white balls of polystyrene.
  • Their impact on other countries fisheries – and the carbon cost of catching and transporting the feed is also a moral concern. Plundering of fish for salmon feed in developing countries – stripping the bottom of the ecosystem out (kril and anchovy etc) which will no doubt do massive harm across the board.


The figures below are a broad overview of the industry which is as high carbon as beef farming. Contrary to “feeding the world”  – salmon farming is a problem to solve. Each calorie of salmon produced costs 50 calories of energy at vast cost to the environment.  See John McIntyres blog below. 

The True Energy Cost of Salmon Farming (50 calories in to 1 calorie out) – Sea Change Wester Ross


Implementing a patchwork of HPMAs or reimposing the three-mile limit without a long-term plan to maintain employment during the transition and without a long-term plan to create sustainable work after the transition would be harmful. 


The first question to ask is if we need to reverse the lifting of the 3 mile limit for Scotlands seas to thrive what is the cost of a just transition?

If roughly 300 boats need to be decommissioned from trawl and dredge, what jobs would be lost from fish processing and transport from the loss to the consumer of this mass market food. The consumer can learn to eat differently but jobs lost are a real concern.  

How long would we have to wait for the benefits of this long term policy in terms of more jobs around the celebration of restored nature and recovered fisheries? 

How many jobs could be moved to low impact fishing from trawl and dredge in a sustainable manner?

Options for Change did begin to explore this. But another question is Do we even have an option if we want to avoid climate chaos and ecosystem collapse? 

How fast would the fin-fish recover? How could we manage fisheries better when they do?

How do we best look after the losers in this tragic scenario. 

Non of the questions above are being asked because we are still in denial at a political level and yet they need to be. 


During the 2018 Salmon Farm enquiry by the RACCE Committee it became clear that despite the Scottish Government’s support for Norwegian Multinationals (producers of vast amounts of salmon farms in our west coast sea lochs) Scotland is not the main beneficiary of this polluting industry in terms of profits and tax.

Norway is. Yet our ecosystems pay the price as do other sectors. 

We also give subsidies to them.

Scotland gets production and management jobs and good export figures – but the price of this is a loss of jobs in other sectors as well as ( sometimes irreparable ) damage to the productivity of the seas. (This is particularly true of fish farms sited close to or on Maerl) 

This has done 1000’s of years worth of damage. 

See Jason Hall Spencer talk: Pink Maerl and Salmon Farms – Jason Hall Spencer in the Highlands – YouTube


Decommissioning open cage salmon farms may not be as painful as imagined if the Government did the economic analysis. As Michael Wigan put it during the 2018 Salmon Enquiry we are selling Scotland’s seas for a ’string of beans’ to Norwegian multinationals.

During and after the 2018 Salmon enquiry, it became clear the Government had never assessed the environmental COST to other marine sectors and that these job losses had been and were considerable. 

For a government never to measure this would surprise many –  but the received wisdom and unexamined assumption was that it was the saviour of the west coast.

So the questions were never asked. Politicians just bought in to it without question. 

However following a case study by Sea Change exploring the COSTS to other jobs, WildFish Scotland and SIFT did an analysis resulting in the report below which shows how unclear it is whether Salmon farming produces a net gain or a loss to Scotland. This needs further independent examination given the price we pay for hosting these Norwegian farms in ecological damage and its carbon footprint is huge.  

That  is not to mention our conscience with regards to fish welfare and the vast mortalities, and stripping the poor countries ecosystems to feed the rich countries.

The authors said: 

The Scottish Government failed to assess the costs the salmon farming industry causes to other economic sectors and has only considered those benefits the industry brings. Further economic evidence is needed including a comprehensive Cost Benefit Analysis.  Report co-author Dr Geoffrey Riddington noted that:The Scottish Governments support for salmon farming industry expansion relies exclusively on estimates about income and employment creation. The reality is that the industrys damage to Scotlands inshore waters must result in many other stakeholder groups being worse off. At no time has the Scottish Government even identified these stakeholder groups, let alone calculated the extent of their costs.”

The report estimates that the salmon farming industrys Gross Value Added”, which has been extensively quoted and relied on by Highlands and Islands Enterprise and Marine Scotland, is possibly exaggerated by 124%, whilst employment could be overestimated by a massive 251%and that, given an evidence base that is partial, incomplete, unreliable and even irrelevant, it is difficult to understand how the Scottish Government can sensibly address the question of whether further damage to Scotlands marine environment is a price worth paying.” 

The report also questions the way the salmon farming industrys economic contribution is reported, noting how a widely reported £2bn turnover figure for aquaculture companies and their trading partners has been conflated with overall economic impact. The report notes that such turnover figures do not relate to any coherent economic performance indicator and should not influence public policy.”

The charities also commissioned an of the report. The peer review concludes that the evidence on which Scottish Government relies for expanding salmon farming is “partial, incomplete and inappropriate for use in assisting public sector decision makingand that if the Scottish Government does propose to support expansion of the Scottish aquaculture sector then a proper assessment needs to be made.”

Wild Fish Report

New Scottish Government study confirms the severe damage being done to wild salmon populations by salmon farming | Wildfish

Global salmon farming harming marine life and costing billions in damage | Marine life | The Guardian

Economic report on costs of salmon farming – CCN Scotland

If a further enquiry became part of the HPMA consultation process – and a full economic and carbon evaluation of salmon farming was done to build on the RACCE committees 2018 salmon farm enquiry this might lead to a conclusion that the cheapest option is to decommission open cage salmon farming and instead create  a long term sustainable low impact economy ?


Transforming from a high carbon to low carbon economy which restores Nature may seem like bitter medicine in the short term – but it is medicine which will restore our nations health and moral conscience and well being.  Painful medicine now gives us a chance    but to allow the commercial lobby’s to dictate policy that serves a small minority and not the nation makes no sense in a marine economy and climate so dependent upon the oceans. 

It rather does beg the question whether this is all overlooked for the sake of the drive for independence and the true cost to future generations and the planet of allowing the end to justify the means.


We do not need more science, or more intervention by commercial lobby’s – we need the political will to act on the evidence to date. If Scotland were to model what a truly progressive state was it would be dealing with this.

Yet the scientific evidence is being ignored and buried. We live in one world where the scientific evidence is terrifying – the other where our Government sells us the idea of being  one of the most “sustainable” countries – as if like advertising a brand – if you say it enough people might believe it – which doesn’t help in the real world in the sea.

Even dredging islabelled SUSTAINABLE in Shetland. This makes no sense to us.


The MPA process was a conservation approach focused on protecting features.

This excluded fisheries and their nursery, feeding and spawn grounds from consideration – as well as salmon and sea trout. Keystone species like herring were not protected, even on their spawn grounds like maerl – and it would be impossible to find a MORE important habitat if you tried. 


This example demonstrates the blind spots when agencies do not create an integrated ecosystem approach which looks at fisheries and conservation objectives holistically together. Land and sea are linked. An integration of fisheries and conservation management addresses the cumulative ecosystem impacts of in a holistic manner…What we currently have is a separation between agencies which has partly led to the environmental disaster occurring in the sea.


The HPMA consultation would be a good opportunity to evolve our inshore policy to serve Scotland and bring us into the 21st Century in response to the Nature emergencies that imperil us. But that will is only likely to come only from admitting what is at stake and seeing the reward from action. If like addicts, we wait until we hit rock bottom before we act it may be too late. 

Scotlands Marine Atlas back in 2011 gave an indication of the state of our seas and marine scientists like Professor Callum Roberts and Professor Jason Hall Spencer have explained to Sea Change members how far we have moved away from the historic baseline – particularly since the lifting of the 3 mile limit.

We would like to imagine a return to some of the riches our seas once had.  

Scotland’s Marine Atlas: Overall Assessment (2011) | Marine Scotland Information

Scotlands Marine Assessment 2020 mentioned above shows that even since this 2011 baseline our seas have had huge declines in reefs and habitats. 

We need independent scientists with peer reviewed papers to feed in to this debate to know why this happened. Then we need an evidence based solution not a political deal. 

But most of all we need action and change.

THE REWARD for taking the bitter medicine?

If we want to provide the best value for the nation, for the environment, the economy, the climate and communities – then removing trawl and dredge is a no brainer. As is open cage salmon farming in the sea.

Changing this over the long term would be transformative. 

Common sense tells us that 6 inch metal teeth and heavy metal chain bags dragged over fragile habitats or forests of seaweeds – will lead us no where.  Keystone habitats and carbon sinks are being destroyed as you read this page.

Yet according to marine scientists the recovery could be rapid at least for the fast growing habitats and fisheries. Maybe not the more fragile species like maerl, blue mussels beds or serpulid worms.

But the remnants would survive and slowly return? If we don’t go too far. 

Building the future green economy whilst showing respect to those who will suffer from this change ( Even if they have been the cause)  is what a civilised society working holistically for the benefit of all needs to do. 

THE COURAGE TO ACHIEVE OUR GOALS –  AN High Ambition Courageous Coalition? 

If Scotland wishes to be a leading fishing and conservation nation with restored seas and well managed fisheries with food security – then we need courageous politicians. 

There is an exciting story to tell of a more Earth centred economy which could perhaps lead to a higher quality of life that comes from transitioning from high impact industrial food production to low impact nature based production. Postponing decisions until catastrophe removes our choice is not wise. 

Its like an alcoholic binge drinking until they are in a ditch with no way out but up, or death.

We could reverse a good deal of the 40 years of industrial level destruction and restore Scotland’s seas – the benefits are enormous.  But we need a transition plan.

We also need to encourage the low impact creel and dive fishing to be the custodians of the future and incentivised them. Sadly HPMAs do the reverse. 

Science can fly us to the moon but it hasn’t yet been able to save the Earth because we are not behaving rationally. If a child was sick, the caregiver responsible would be unlikely to seek the advice of a salesman whose ultimate raison d’être was to sell a product to them? They would seek an independent doctor whose raison d’être was to heal. Currently our agencies seem to be acting on advice of the snake oil salesman and ignoring the doctor. 

To produce an evidence based plan there could be a gathering of marine scientists, economists and fishery experts involving fishermen and communities and all stakeholders.

 The story which underpins our cultures exploitation of nature is one of separation . We face a Nature emergency – as a result of our forgetting that we are part of Nature and what we do to the planet we essentially do to ourselves..

We offer this as constructive feedback to request that the Bute House Agreement  evolves. The medicine might be bitter in the short-term, but generations ahead will appreciate the courage of politicians who did face the problem.

But we do need a well considered plan. It is cart before horse to focus on 10 percent HPMA – when the majority of our waters are still fished by trawl and dredge and there is no transition plan to a low impact fishery. 

With that in mind we support SCFF’s petition for a variation of the 3 Mile Limit to be considered by the RAI committee enquiry.

From the Governments perspective the ambitions for restoration should not stop at the 3 miles –  given irrevocable damage is being done up to the 12 miles and offshore too. 


The side scan image –

Sources: Many UK Universities supply peer reviewed science which is independent and we have drawn upon this as well as many conversations with marine scientists and fishermen. 

John McIntyre, a Sea Change member has spent a decade or more analysing the Earth system and the marine issues – he can supply checkable data to guide understanding.

Jason Hall Spencers assessed as a ball park figure  that he thought around 50 percent of the maerl beds have been damaged or had gone. This tally’s with scallop divers eye witness accounts of a lot of maerl beds disappearing in the last 13 years.