Leading Journal of the Irish & UK Fishing Industries


Tommy Finn, Chair of Clyde Fishermen’s Association releases detailed response to Clyde Cod Box Closure

“As the Chair of the CFA I am absolutely shocked to the core at this decision which will see many of our members unable to fish sustainably for almost 3 months. We can’t understand the lack of communication with our small scale fishing communities, or indeed the families and businesses they support not only around the Clyde but in wider Scotland, Northern Ireland and the EU. This impacts not only fishing but wider policy areas such as Scottish Trade, Tourism and the Food and Drink Sector. It impacts the core general socio-economics of our communities. It’s going to impact not only boats, crew and factories, but also school numbers and jobs in local shops and services. In Campbeltown alone we have seen the closure of our creamery and a local renewables factory. The Government talk of initiatives to repopulate the rural communities, but such an action seems almost aimed at driving out fishing families who are already settled in the Clyde area.

Perhaps we could understand the decision if there were clear, balanced and genuine environmental benefits, but we haven’t seen the science or the rationale to justify this action as proportionate. We could have proposed selectivity options which would have achieved similar aims and allowed fishing to continue, this is sensibly the approach taken in the Irish Sea, but there has been no dialogue on any options or solutions.

This decision has completely changed the original purpose of the protection which fishermen ironically initially championed over two decades ago. I personally was one of the fishermen who championed this closure aimed at protecting cod stocks from net fishing, I am completely perplexed at how a Government we collaborated with to achieve something so positive together can now change the very purpose of the conservation objectives. I am even more concerned that this decision seems to have been influenced heavily by the Bute House Agreement rather than the recent Scottish Government Future of Fisheries Management Strategy. We need the officials we voted for as a country to be accountable to us, our Ministers have duties to protect our sustainable fishing communities too.

We have co-operated with the Scottish Government and in many instances shared their sustainable vision for vibrant and well managed fishing communities, but we currently feel like our communities have been used as a wider political pawn and shut out of a crucial decision impacting them. Sadly this has not been the first time, and frankly we feel disrespected without reason. We hoped our Government would work with us collaboratively on issues of conservation and management, and we are disappointed beyond words or reasonable comprehension. We have to be better than this collectively.

We urge Cabinet Secretary Gougeon and Minister Slater to set a date with haste to speak with the inshore small scale fishermen (both mobile and static) who knew nothing of this intention. It is these families and the associated businesses to whom they are proposing to deny a sustainable living without reasonable process. We reiterate we support solid science and genuine balanced conservation and have played our part in trying to address data gaps, but this needs to improve.

We are sorry to find our communities in this position, but our door is open to communication with the Scottish Government and its Ministers, and we hope there is time to reach a fairer outcome before the 14th of February 2022. As our fishing communities voice we cannot merely accept this action, we would not be doing our jobs.”

As a mixed fishermen’s association with static and mobile fishing members we have made continuous efforts to find sustainable ways of ensuring our coastal communities can survive and work with Government and our Ministers across the board. We have followed process to the best of our abilities despite challenging circumstances at times, and we have championed the Scottish Government’s IFG Network and FMAC and IFMAC models.

As an association we proposed weekend bans on mobile fishing (the only area in Scotland to have such a scheme), we were a founding partner in creating a No Take Zone in the Clyde (again the only NTZ in Scotland) and over 20 years ago we also proposed the Clyde Box Closure in the Clyde to protect spawning stocks. We did this in collaboration with the Scottish Government who ultimately helped us to deliver these progressive measures. It is therefore incredibly demoralising and soul destroying to see such positive measures being turned against the sustainably minded fishermen who helped to create them, and all without any meaningful involvement.

Today the relatively new in office Fisheries Minister Mairi Gougeon has announced in Parliament that she intends to close a large expanse in the Clyde Marine Area, indeed the very area the CFA helped to bring fisheries measurements in through a Scottish Statutory Instrument more than 20 years ago. This new measure excludes all bottom contact fishing in the area, be it static/creel fishing or mobile fishing. This decision will have a horrific impact on the fishing families of the Clyde, and we are struggling to identify the reasons for this action. The area will be closed from the 14th of February to the 30th of April, this will mean a total loss of income for many of the small family boats for months, this is not a burden they can easily bare as these fishing communities have already had the hardest two years they can recall between Brexit and Covid. Income aside it will also have social and environmental impacts. Some families may sell up and relocate, families can’t survive for months with no income, this will impact not only the fishing economy, but also the wider socio-economy of fishing villages, towns and their facilities such as shops and schools. Environmentally this closure will push the local boats and Northern Irish boats who fish the Clyde into the smaller fishing areas which are left. This could mean unsustainably high fishing levels into smaller areas where previously the effort was sensibly spread.

If Scottish produce and supporting local businesses, the environment and people are important then this snap decision is certainly wrong headed at best. It will likely have the impact of witnessing sustainably minded small but vital family businesses going to the wall along with further depopulation in areas like Argyll and Bute. It is quite unthinkable that a Fisheries Minister would act against progressive small scale fishing communities in such a way. This is not the relationship of mutual respect we genuinely hoped to forge with our new Fisheries Minister.

What communication and involvement have the fishing communities had to consider this process?

As some background we should be clear that the Minister did not request a meeting on this issue with these fishing communities impacted in advance, not even a phone call to explain personally the decision and understand it’s impacts or explore other potential alternative measures. It seems this policy decision was one which the Scottish Green Party may have pushed our SNP Fisheries Minister on from their position of vantage in Edinburgh and Glasgow, not from the depopulating areas of Kintyre and beyond which will feel this most keenly. Our fishing communities are left reeling at this shock decision.

It should be noted that prior to this announcement our umbrella organisation requested a general meeting with Lorna Slater as both the Minister for the Circular Economy and Biodiversity and as the MSP relevant to our office Headquarters. This request was surprisingly not supported, indeed the letter of reply in December 2021 even used the wrong organisations name in its reply and suggested contact with Minister Gougeon instead. We have requested a meeting with Minister Gougeon, but we would have far rather have done so in advance of this unexpected radical step.

As previously noted it was the fishermen themselves who initially suggested the Clyde Cod Box closure over 20 years ago to targeted net fishing of cod and worked with the Scottish Government to implement it. The purpose of which was to try and protect cod stocks from fishing, and the measures were geared more specifically to net fishing of targeted cod fishing, not prawn or scallop fishing by creels or mobile trawl as they do not target cod fishing and have a very low by catch of finfish as proven by observed science trips (less than 1%).

What about the science?

As already explained local fishermen believe this proposal is actually likely to place increased pressure on the smaller remaining open areas of the Clyde, and this is not likely to be positive for fish populations at all. Where once fishing had been spread out and less intense, it will now be unnecessarily intense in some areas. Our local fishermen do not consider this to be a positive management step.

The scientific rationale for this sudden closure is questionable. Science on the West Coast is generally quite data deficient often due to a lack of resources, this can mean that information on fish populations can be very limited, even the work which is available and cited in the original Cod Box Consultation is quite limited in the scope of its research. For three years the CFA, St Andrew’s University and Marine Scotland worked together to conduct neutral baseline surveys which aimed to try and assess basic cod and finfish populations, this happened in the Clyde Cod Box area. The trials were stopped in 2018 due to issues at Marine Scotland with staffing resources to take part, but the CFA and St Andrews University have been consistently requesting the trials are restarted and keen to support them in terms of resources. Without such trials the practical knowledge of the area is missing and informed policy decisions are difficult to take. As the Cod Box Consultation outlines the limited science for the whole West Coast on cod does seem to suggest that cod numbers are quite low, and therefore there could be an argument that the Clyde Cod Box closure has achieved little and is no longer required. The CFA/St Andrews University and Marine Scotland trials did seem to suggest that some limited spawning might be taking place in some specific small areas, but in reality a continuation of these trials would have been the key factor in establishing if this was the case. However it should be noted that muddy ground is not the optimum conditions for cod spawning, and much of the area selected for closure is muddy sediment. This is why it is all the more frustrating that the trials could not continue to offer a basic baseline of the situation. The CFA were keen not to commission work without the involvement of Marine Scotland and neutral scientists to avoid any accusations of bias in findings.

It should also be noted that for around five years the CFA have been raising what local fishermen believe to be key issues impacting cod stocks on the West Coast. One of those issues is climate change. As the water in the Clyde heats up cod stocks are moving North, this is a pattern also witnessed by our Nordic neighbours who have very detailed science generally. However as the cod move further North new stocks are moving in, namely skate and spurdogs (a small shark). Both species are protected, but fishermen note the incredible increase in both stocks from their first hand experience. This changing of stocks means a changing eco-system, but it should be noted that skates and spurdog are both predators of cod and other finfish such as hake. If spurdog, skates and indeed seal numbers are high (as they are in the Clyde and West Coast) then it must be practically expected that the fish stocks which they predate on will experience declines, it’s a balance of nature. Keeping in mind that fishing gear in the Clyde is incredibly selective and bycatch of fish such as cod is scientifically observably very low then the cod population is more likely to be impacted by temperature change and predation from other species. Again local fishermen are extremely frustrated as they have been pleading for years to help conduct partnership science on these issues of predation interaction and stock levels. Indeed spurdog pilot schemes have happened in the South Coast of England which were very similar in nature to that which West Coast fishermen have continually asked to do, however in five years we have not been able to progress this work with Marine Scotland due to their limited staff resources. Again very frustrating for local fishermen who are keen to work not only with what they see anecdotally, but also with what neutral science can prove. Science helps to inform not only fisheries management but also local conservation where required, its badly required on the West Coast of Scotland.

It should be noted that the biomass of finfish in the Clyde has actually increased since the 1940’s. The size and species of fish have changed through the years but it is a little known fact that fish biomass has indeed increased, it certainly would not be obvious by some of the current campaign narratives circulating publicly. We really have to work together on neutral science and communication to improve our coastal fisheries management particularly inshore, it’s not reflexive at the moment.

It could be noted that there are Cod Closures in the North Sea, so its perfectly reasonable to expect them in in other areas too. A few key things to remember are:

  • There are significant targeted cod fisheries in the North Sea which do not apply in the Clyde
  • The science in the North Sea is more precise, so proportionate and specific spawning areas can be identified and closed, in the Clyde case a huge marine area is being closed to local small boats who are not targeting cod at all. Much of this huge area will not be spawning ground at all, the science isn’t there to demonstrate conclusively where these areas are and much of the seabed ground is in fact mud.
  • The closure of the Clyde Cod Box was never directed at shellfish fisheries with low bycatch, it was directed at finfish net fisheries of cod to protect the stocks. So this instrument has been extended into a management measure which it was never intended to be in the first place. It is generally felt this decision has been achieved through lobbying and political pressure outside normal process which has resulted in a Ministerial decision without any direct dialogue or understanding of the fishing communities perspectives.
  • The North Sea is a much larger area with much larger boats, the inshore fleet face displacement, more intense area specific fishing and safety issues as small boats are forced out of their areas of safety. They can’t simply “move on”.

So what about the process?

There has been a long standing Clyde Cod Box Consultation which has run for a number of years. The CFA have generally supported the seasonal closure of targeted cod fisheries. Normally the consultation has been public, or has been circulated by Marine Scotland around their FMAC and IFMAC networks, which includes fisheries stakeholders and eNGOs. Last year a consultation was circulated to FMAC members on the 15/09/21 asking for views on the Clyde Cod Box to be returned by the 13/10/21. From what we understand some well funded lobby groups and scientists who are affiliated/work with these lobby groups started to question the process of consultation which Marine Scotland operated. Consequently the consultation was re-opened and extended on the 20th of October 2021 to the 4th of November 2021, during this period an orchestrated social media campaign was delivered by the network of lobby groups which tend to be against current small scale models of community fishing. These groups funded significantly externally to the communities which are under consideration.

At this stage CFA, SFF and CIFA started to raise concerns with Marine Scotland that a campaign seemed to be targeting the Clyde fishing communities, this had previously happened in 2015/2016 and led to a Ministerial decision going outside the agreed MPA process in the Clyde. The Clyde was the only area in Scotland where this happened and it was feared it was happening again, but this time the fishing communities have very little resilience to continue. We heard no more about the results of the consultation and where assured that Marine Scotland would look at results fairly. We also note that Scottish Government Consultations should be live for 12 weeks, this has not happened. Neither have we received feedback or dissemination.

We heard no more of the consultation. We were informed very shortly before the Ministers statement that a public announcement would happen in Parliament which would see a closure of the Clyde Cod Box and that no static or mobile fishing would occur in the area from the 14th of February until the 30th of April. We have seen no science to back this specific act, no socio-economic rationale and have had no explanation from the Fisheries Minister. We aren’t clear at all if this decision is in anyway related to the Clyde Box Consultation (which clearly didn’t follow 12 week protocol) or if this is purely a Ministerial Decision. We are aware that the Scottish Green Party feel that this action reflects the sentiments conveyed about protecting spawning grounds which are outlined in the Bute House Agreement, however as already noted its not clear where the actual spawning grounds are, and the area ear marked for closure far extends where any specific spawning grounds could be, its mostly muddy area where cod generally don’t spawn according to some scientists. This is not similar to the precise area closures in the North Sea, yet again the Clyde seems singled out for a deviation from process, just as we witnessed in 2015/2016. This is perhaps all the more frustrating as the CFA have attempted for a number of years to support up to date science about stocks and spawning patterns, and this was halted.

What Next?

We are in complete shock and disbelief that this process has been handled in such a way. This feels like a re-run of the break in process which only the Clyde faced in 2015/2016 national MPA process. Local fishermen could be forgiven for feeling that the area they sustainable fish in small boats not targeting cod at all are being relentlessly attacked by a policies which are not being implemented in other marine regions, and indeed policies which don’t follow transparent consultation guidance. The lack of communication, consideration and involvement is staggering and directed towards fishing communities who have done their upmost to support balanced conservation. The stretching of the original purpose of the closure to fit some “new objectives” is confusing. It is true that the Bute House agreement mentions fishing interaction and the protection of spawning grounds, but a programme is already underway to develop that separately nationally so our question is why hi-jack this over 20 year old process to deliver another outcome? We can’t believe this would be the decision of civil servants who actually understand the process, rather a political decision.

It feels less than transparent, there certainly has been less engagement than may have been required if national process was followed for spawning ground identification, as other regions will. To suggest closing a huge area to small scale community boats where tiny pockets of spawning “might” be present, (but as far as we know the data isn’t there to collaborate, although not through to the lack of local fishermen trying) is not using the precautionary principle, its rational is hard to define or understand. It’s throwing caution to the wind for fishermen and their families. It will see small fishing communities who have tried to trust their politicians and process penalised again disproportionately without so much as a discussion. What it does seem to suggest is that lobby groups have more effectively played the system yet again, and it seems to suggest they may also have a very productive relationship with the Scottish Green Party. It also sadly demonstrates that Scottish Clyde Fishermen have reached out, but sadly they can’t rely on their Ministers to protect, work with or support their communities, and this is the most upsetting realisation. Coastal fishermen are the backbone of communities, they have supported the Scottish Government’s process during Cabinet Secretary Fergus Ewing’s productive time in office, but they have now been let down again. They don’t want special treatment, they just want fair and transparent treatment, and this is no “just” approach to working with the national Scottish assets of our fishing communities and indeed our world class supply of seafood.

We hear of “just transition”, but how can leaving families in rural communities with no income for months be just? Sustainable fishermen want to fish sustainably, to leave what they can for the next day, and more than that for their children and grandchildren. They don’t want compensation but it hasn’t even been discussed and it should be if this proposal proceeds as is as it feels like decommissioning by stealth. Death by a thousand cuts to the small family fishing boats. If this can happen to the balanced fishermen who work 4 day weeks and want to help protect the environment and support science, then what else next?

Our fisherman reached out to Minister Slater to help explain to her our sustainable vision and how circular economies work in small fishing communities, but the rejection to even meet is a worrying sign. Politician’s need knowledge of their constituents before influencing or making decisions which will impact lives in a negative way. There are measures which could have been applied, for example selectivity of gear measures are used in similar cod boxes in the Irish Sea, a discussion about potential options to allow more protection and coastal fishing to continue would have been expected. Section 6 of the Scottish Marine Plan notes that:

Existing fishing opportunities and activities are safeguarded wherever possible”

It was possible in this case, and it’s been disregarded.

We need answers to what has occurred here, because the fishing communities can’t accept this without challenge, it is not in Scottish interests to do so. We invite Minister Gougeon to urgently speak to the Clyde fishing communities.