Written evidence submitted by The Open Seas Trust – (ITS0025)

The Open Seas Trust

Scottish Affairs Committee Inquiry: Industrial transition in Scotland Evidence Submission

 

The Open Seas Trust is a Scottish charitable trust focused on protecting the UK marine environment and the things that live in it. Open Seas aims to support a shift towards more sustainable harvesting of shellfish and fish, and promotes sustainable alternatives to damaging fishing. Open Seas is responding to this consultation with a focus on the industrial transition in sheries.

 

  1. Which industries in Scotland have previously experienced industrial transition, and to what extent were these transitions effectively managed? In what ways did these historic transitions in Scotland differ in their causes, impacts and results? Relevant examples could include (but may not be limited to) coal, steel, heavy engineering, textiles, and shipbuilding.

        How were Scotland’s industrial transitions different in nature to those experienced in other parts of the UK?

        What have been the socio-economic impacts of these transitions, and in what ways do Scottish communities continue to be impacted by the legacy of them today?

        How effectively have UK Government policies and interventions, both existing and historic, mitigated the negative impacts of these industrial transitions?

 

Scotland’s sheries have quietly undergone an unjust industrial transition over the past 50 years which has been poorly managed. Although Scotland remains dominant in the context of UK fishing, landing over 60% of the UK’s overall catch, the shery has transitioned to one where larger and more industrial shing has come more to the fore, and sh stocks, in particular in inshore waters, have declined to the point that they are no longer commercially viable, meaning the inshore fleets now focus almost entirely on shellfish.

 

Less than a century ago, the number of shers in Scotland was three times what it is now, with Scotland’s Fisheries Board reporting over 14,000 shermen in 1938 (not including crofter fishermen), as opposed to less just 4,117 in 2022). A combination of depleted fish stocks, economic pressures, an ageing workforce, competing industry opportunities, and regulatory factors have all played a role in the decline of the sector over recent decades, alongside poor management, including controversial management decisions made in Westminster, prior to devolution.

 

Three key impacts on Scottish sheries are considered below: (1) The removal of the inshore limit; (2) the concentration of quota holdings; (3) the expansion of oil and gas.

 

(1)   The removal of the inshore limit

 

From 1889, for nearly a hundred years, Scotland’s inshore shers benefited from an inshore limit: legislation that prohibited bottom trawling - the practice of dragging heavy shing gear


along the seabed, destroying fragile habitats while sweeping up shellfish (and significant amounts of bycatch) - within three miles of Scotland’s coast. The limit was originally introduced because of the advent of steam trawling, in recognition of the damage mechanised bottom trawling would cause in inshore areas.

 

Subsequent to the publication of the Cameron Report (1970), in 1984 under the Thatcher Government, Scotland’s inshore limit was revoked. The Our Seas Coalition, an alliance of organisations committed to the sustainable use of Scotland’s inshore waters, highlights the fact that “Historical records now show that this decision was the result of lobbying by larger commercial trawlers and a Westminster government that failed to protect and respect the

socio-economic value of traditional inshore shing that had supported coastal and crofting communities for decades.”

 

This decision fundamentally changed the operating context for Scotland’s inshore fishers, including static gear shers like creelers - a shing practice that has minimal impacts on the seabed. In fact, creel shing requires intact and highly productive marine habitats, enabling shers to return to the same grounds year after year. With the removal of the inshore limit, the fragile but highly productive marine areas that lower impact shers relied on became fair game for industrial bottom trawling and scallop dredging vessels, both of which boomed as a result.

 

This had significant consequences for the inshore eet as a whole, and lower impact shers:

        Fragile habitats in these areas were (and continue to be) destroyed by these harmful shing practices, reducing the opportunity for sh to reproduce, hence contributing to the decline in key stocks, and also decreasing the productivity of the fishing grounds lower impact fishers relied on to sustain their livelihoods.

        Meanwhile, it was possible for scallop dredgers and bottom trawlers to make large profits relatively quickly, by shing in these once-protected inshore areas, leading to the growth of the dredge and trawl fleets;

        Both industrial trawling and scallop dredging expanded rapidly in the decades that followed, and remain highly profitable parts of Scotland’s shery:

        The nephrops (langoustine / scampi) shery has become a particularly important fishery on the west of Scotland, landing approximately £64 million in value in 2022.

        The scallop shery in Scotland landed 14,000 tonnes in 2023 compared to just 60 tonnes in 1960 (Scottish Sea Fisheries Statistics 2023).

 

Despite their economic dominance, dredge vessels support comparatively fewer jobs than lower impact alternatives (like creel fishing with static gear). This is illustrated by the fact that over half of the active vessels in Scotland’s under-10m inshore fleet are creel fishing vessels, but in total they only landed 6% of the nephrops catch in 2021 (with 94% of the catch landed by dredges and bottom trawling vessels). Whilst the quantity of nephrops and scallops caught has expanded hugely in the past 50 years, jobs in Scotland’s sheries have fallen. This is an example


of how a poorly managed industrial transition has contributed to the hollowing out of a key part of UK food production, and caused significant harm to the environment.

 

Bottom trawling continues today, including in inshore areas, and remains responsible for very high levels of bycatch, as demonstrated by recent reports on Sky News and BBC Scotland regarding discard dumping by a trawler in Dunvegan Harbour. It’s vital that urgent action is taken to better protect fragile inshore marine habitats from damaging practices and tackle issues like bycatch.

 

Enhanced vessel monitoring, for example through a wider roll out of remote electronic monitoring (REM) with cameras and winch sensors, is a key step to support compliance with existing fisheries management measures, alongside stronger protections for priority marine features and fragile habitats.

 

(2)   The concentration of shing quota allocations

 

When it comes to commercial whitefish species, stocks in Scotland’s waters have also undergone significant changes over the past century, with sharp declines in many commercially important species like cod, and near collapses in the 1990s, in part due to overfishing / poorly managed fishing. The introduction of fisheries limits in the 2000s brought some recovery, particularly in the North Sea, where stocks of a number of commercial species have shown signs of improvement. However, this recovery has not been uniform: Our Seas state that “inshore stocks of species such as herring, cod, haddock, hake, turbot, saithe, whiting, and flounder have reached ‘commercial extinction’ in many areas, meaning they have been exploited to such an extent that it is no longer economically viable to sh for them.”

 

Following the loss of key commercial stocks in inshore areas, making it unviable for inshore fishers to rely on whitefish for their primary income stream, most commercial whitefish species are now caught almost exclusively by larger, pelagic vessels of 10m+ in size. This includes supertrawlers which can travel further and stay at sea for longer, chasing increasingly remote stocks. According to the Marine Management Organisation UK Seas Fisheries Statistics for 2023, vessels over 10 metres in length landed 99% of the landings of quota species by UK vessels. More than 75% of the total quantity of sh caught by all UK vessels in 2023 was landed by vessels over 24 metres in length, but these vessels represent only 4% of the UK eet by number. Without stock recovery, this is not going to change.

 

Across the UK, quota allocation - the distribution of the right to catch specific amounts of key commercial species - has been handed out on the basis of Fixed Quota Allocation (FQA) units, based on a vessel’s ‘historic track record’ (in short, a vessel is permitted to continue to sh for the stocks it historically was successful in catching). However, although vessels have been handed this quota for free by the Scottish Government (and likewise in England, Wales and Northern Ireland), they are nevertheless able to sell and lease their FQA units. With inshore stocks in decline, many FQA holders have done just that, with the result - both in Scotland, and


across the UK as a whole - that quota for key commercial species has been concentrated into the hands of those with the deepest pockets, in some cases bought by businesses that are based outside of the UK, siphoning the value of UK sh - a public asset - offshore. A Greenpeace investigation in 2018 found that, in Scotland, just ve families - all of which were on the Sunday Times rich list - owned 33% of Scottish FQA units, and, as Greenpeace reported: “When taking into account minority stakes, companies wholly or partly owned by these families hold close to half (45%) of all Scottish quota.”

 

The concentration of these valuable assets demonstrates a failure to deliver a just transition that benefits Scotland’s shers as a whole, and protects and preserves its natural and cultural heritage.

 

Reform of quota allocation: The UK is now an independent coastal state and the Scottish Government (and all UK Governments) have a key opportunity to reform quota allocation. This would represent a low-to-no cost, no regret route to incentivise sustainable, lower impact fisheries with enhanced focus on driving economic and social benefits in local communities. This is a measure required by the Fisheries Act 2020, which states:

 

When distributing catch quotas and effort quotas for use by shing boats, the national sheries authorities must use criteria that—

(a)   are transparent and objective, and

(b)   include criteria relating to environmental, social and economic factors.

 

Suggested criteria listed in the Act include: the impact of fishing on the environment; the history of compliance with regulatory requirements relating to fishing; the contribution of fishing to the local economy; and historic catch levels. The Act further states:

 

When distributing catch quotas and effort quotas…the national sheries authorities must seek to incentivise

(a)   the use of selective shing gear, and

(b)   the use of shing techniques that have a reduced impact on the environment

 

Reform of quota allocation is a vital step that the UK Government and devolved Governments can and must take to support and incentivise lower impact, more selective shing, and to bring environmental, economic and social benefits to local areas.

 

(3)   The expansion of the oil and gas industry

 

The discovery of oil and gas reserves in the North Sea in the late 1950s and 1960s meant that the fishing industry’s position as Scotland’s primary marine industry changed. During its height, there were nearly 180 oil and gas platforms in the North Sea (now nearer 110). 14,801 km of pipelines lead from these oil fields to northeast Scotland. Many of these are on traditional fisheries grounds and - despite the fact that some trawling still takes place on pipelines contrary


to some regulations - all of this has had a serious displacement impact on fishing. Concerns regarding displacement were somewhat alleviated by financial compensation and purchasing of other services, however this has set a precedent for compensation that cannot necessarily be replicated for every industry increasing activities in the marine environment.

 

Given that competition for space continues to grow - the expansion of offshore wind being the latest example - it is vital to establish processes to allow for sharing of space and a fair consideration of each marine user, including sheries. This is a core part of the Marine Scotland Act, passed in 2010 by the Scottish Parliament.

 

2.   Which industries in Scotland today are likely to experience industrial transition or decline in the near future? The Committee is interested to hear from a wide range of industries including, but not limited to, oil and gas and manufacturing, as well as growth-sectors in Scotland such as space and data technology.

        Which communities in Scotland could experience the effects of industrial transition or decline in the near future?

        What lessons can be drawn from a) previous governments’ industrial strategies and management of industrial transition b) other countries’ management of industrial transition?

        How can these lessons be applied to transitions affecting industries in Scotland today?

 

Scotland’s seas are becoming busier. There is an increasingly urgent need to balance access to and activities on the sea across diverse industries and groups to manage this “marine spatial squeeze”. It is essential that UK Governments, including the Scottish Government, balance the delivery of industrial ‘growth’ activities, for example clean energy, with the need to protect and recover the marine environment while supporting sectors like shing and marine recreation.

 

To address marine spatial squeeze, Open Seas is calling for:

        A robust spatial plan for shing (thereby delivering the duties of the Marine (Scotland) Act 2010): instead of leaving shing to defer to, or ll in around, new users in the sea, this plan should allocate “Go Fish Zones”, providing dedicated areas for certain types of fishing, giving fishing businesses (and other potential marine users) certainty. This would also ensure areas vital to conservation, for example protection of fish spawning grounds etc within Marine Protected Area. Norway offers an example of what effective marine spatial planning can look like, “including fully integrated fisheries management within the MSP process.”

        Balancing the areas lost to Scotland’s low impact fishing fleet with the designation of specific “Low-Impact Fishing zones”, covering the same proportion of the sea. These should be used to incentivise low impact fishing and those fishing businesses which are acting responsibly. Such incentivisation would create a ‘ratchet’, improving fishing practices and helping the Scottish Government meet its overall plan for sustainable, world-leading fisheries.


        Empowering and improving access to and the accountability of local fisheries decision making: Scotland’s Regional Inshore Fisheries Groups are already tasked with developing sheries management plans but they are not doing so effectively. Too often, they remain industry talk-shops, without proper representation from the wider communities they should serve, and with limited accountability. England’s Inshore Fisheries Conservation Authorities (IFCAs) are an alternative example of relatively effective regional fisheries management.

 

More detail on each of the points above is set out in Open Seas’ Ease the Squeeze report.

 

In addition, supporting lower impact approaches to be scaled up in fisheries could offer an important potential avenue to boost the seafood sector, given the significantly higher price per kilo lower impact products often attract, compared to dredged and trawled alternatives, reflecting their premium quality. For example, prioritising effective management for the dive scallop sector to facilitate the creation of new jobs in coastal communities, contributing to shift into more sustainable shing practices that can yield better catch value, while ensuring the best health and safety standards.

 

The actions above are vital, alongside reform of quota allocation to ensure the distribution of fishing quota - a valuable public asset - incentivises lower impact, more selective fishing, and aligns with transparent environmental, social and economic criteria to bring maximum benefits.

 

3.   To what extent is the UK Government’s forthcoming industrial strategy, Invest 2035, geared towards the challenges and opportunities facing Scotland today?

        What are the barriers to and enablers of industrial growth in Scotland, both now and in the future?

        To what extent does the Industrial Strategy Advisory Council reflect the make-up and priorities of Scottish industries? How can the Council ensure the needs and interests of Scottish industries are represented within the UK Government’s policy-making processes?

        How can the UK Government achieve its objective of an industrial strategy with a

place-based approach’? What should such an approach look like, and how could it deliver for Scottish industries?

        How will the UK Government’s approach cohere with the Scottish Government’s economic plans, including its Green Industrial Strategy and National Strategy for Economic Transformation?

 

While sheries are not considered a “growth driving sector” within Invest 2035, clean energy industries are. Parts of the economy which are not counted as “growth driving sectors”, but nevertheless represent a significant part of Scotland’s cultural, social and economic heritage - for example lower impact sheries - must not be squeezed out or overlooked as a result of the prioritisation of “growth driving sectors” at any cost. Equally conservation of the marine environment must be incorporated into any industrial strategy.


Marine spatial management that adequately balances the interests of all sectors reliant on the seas, plus the need to protect and restore a healthy marine environment, is of paramount importance in enabling the growth of the offshore wind sector. Recent studies have shown the majority of shers are concerned about decisions to privilege the rapid development of offshore wind, and it is critical these concerns are addressed. A balanced framework for marine spatial management would ensure all relevant industries and sectors have adequate space to undertake core activities, meeting social and economic needs, while also protecting fragile marine habitats and enabling green growth. This approach would also offer greater certainty to the shing sector, helping to minimise trade offs between “growth driving industries” and other sectors.

 

It is vital that the application of a top down strategy does not mean opportunities to drive growth and investment in other areas are missed, or the environment is compromised, due to a siloed approach focusing only on specific industries, sectors or cities. It is also essential that impacted communities have meaningful opportunities to shape decision making, particularly where decisions designed to drive growth are expected to impact lives and livelihoods in both the short and longer term. This is vital to minimise the risk of potentially negative consequences of top down decision-making, as per the decision to remove the inshore limit in the 1980s. An approach to investment and growth that enables, values and is responsive to local input is key to secure buy-in from communities with regard to key decisions - particularly where those decisions affect sectors of great cultural, social, economic and environmental consequence, like sheries.

 

Other steps to make shing fairer, for example reforming shing quota allocation to ensure quota goes to fishers taking action to bring social and economic benefits to Scotland’s ports, and reduce their environmental impacts, are also essential to ensure a sustainable future for fishing in Scotland and across the UK, as well as supporting climate and environmental targets.

 

 

March 2025