Wee people make the news - Highly Protected Marine Areas Scotland

 I intended to re-write this in a more accessible form by hey ho just didn't get the time and as Scot Gov tend to not publish responses they dont like thought I wouldn't take that chance. 

Consultation Submission on the proposals to implement HPMAs in Scottish waters.

General Observations and comments on the proposals :

Please note that the responses below are to be taken as responses to all questions relating to all parts of the consultation and not confined to policy framework and site selection guidelines questions only.

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters. As a professional fisheries representative having worked with Scottish government and Marine Scotland for over 10 years to build professional, evidenced, transparent processes towards inclusive, consensus driven and stakeholder-invested decision making, I have never seen a worse presentation of a consultation.

I was part of the original process, building of the initial tranche of MPAs, then the call for PMFs and now this most recent, what I would term, wreckless, over-reach of HMPAs.

The Bute House Agreement would appear to be the catalyst in this most recent iteration of over egging of marine protection and it should be noted that although the BHA was given some window- dressing of legitimacy in that Green Party and SNP party members voted on the deal, non party members who many have supported those parties in the Holyrood election did not have any opportunity to allow their votes to be stretched to encompass a deal with the Green PArtry. The reach of the BHA was not detailed in the election manifesto of the SNP. So de-legitimacy  is embedded at the start of this entire process and has become a regrettable sleight-of -hand currency of operation  in the legislative behavious of the BHA partners.

I authored the EMFF funded ‘A Vision: The Future of the Clyde Fishery’ www.clydefishermenstrust.com/projects/science-policy in 2022.

My findings identify the following which are specifically relevant to this consultation but I would recommend that much of the document is relevant generally to the current context in which the  current HMPA proposals arise and that policy makers should appraise themselves of its contents as a transferable context to fishing in most parts of Scotland.

·         Need to improve ‘fishing literacy’. This refers to a lack of knowledge on the complexities of fishing, gears, species, vessels, regulation and the interconnected place of fishing socio-economically and culturally in coastal communities. A lack of ‘fishing literacy’ is demonstrated by this HMPA consultation process.

·         The protection of fishing grounds as an essential renewable high protein, omega rich low fat food resource for the benefit of the nation’s people at large against non food related removal and developments.

·         Fishing as the engine of renewal for a truly localised, low carbon modern industry providing jobs from catching to academic research to processing, supplying a domestic market and accruing income from export, improving the dietary outcomes of a nutritionally compromised and impoverished population, embedding  community wealth building into progressive procurement strategies for local authorities, purchasing locally caught seafood for ancho institutions, establishing re-use and added value of waste products, recycling and contributing to a circular economy.

·         An Integrated Clyde Fisheries Development Board modelled on the Highlands and Islands Development Board of the 1970s but upgraded to embrace modern challenges and needs in particular relating to replacing the fleet with a modern smart low carbon, high efficiency, high welfare fleet.

·         The disproportional influence of e NGOS on shaping fishing policy: the Vision identifies over 100 e NGOs which have as part of their policy an end to fishing in particular ‘trawling’  undefined in terms of size or gear  which matters because the financial clout of these organisations is highly influential and disproportionate on government, supermarkets and the public. Policy then for our remote and fragile communities needs to be cognisant of the origin of the thinking which drives such simplistic and dangerous mantras and be able to justify or reject them from a position of empirical knowledge which pertains to Scotland’s circumstance. Many eNGOs have multi million pound annual budgets, far greater than marine Scotland itself. These  operate as corporates in the interests of particular motivations employing all the techniques of the best advertising tools to shape the views of their target cohort. They  use of intemperate, emotive language, visuals, film and advertising campaigns, generate ‘rent-a-mob’ signatures for petitions to governments and apply direct pressure on buyers to influence government. Supermarkets are now bound into a negative loop through powerful eNGOs which undermines confidence in the fishing industry and creates a domino reaction of investment reticence by banks. Powerful lobby groups are dictating whether a fisherman’s catch will be bought or not.

 

 

The dire state of ‘fishing illiteracy’ is grimly evidence throughout the HMPA proposal document which is shot through with assumption, unevidenced statements, poor understanding of the complexity of fishing at all its levels, prey/predator interaction, vessels, gears, habitat and the interconnected economic network and reliance of all those involved from the boat deck to the supply chain lorry drivers or high end consumer. The vision further says that fishing needs a long term development plan removed form the vagaries of political expediency of which this and other knee jerk policy reactions is but the most severe in a long line of whim based policy to curry electoral support from vociferous groups. It is a sad observation that the MPA and now HMPA process has exemplified all that is wrong with developing policy where the most influential or politically astute bends the ministerial ear at the final juncture.

What I further observe and which I believe is also pertinent to the context of this consultation, is a deeper political ignorance of issues which is the midwife of not just poor but actively damaging policies such as this consultation proposes. There are few advising or developing policy or who seek to legislated as elected politicians who have any real proximity to the fishing community. I dislike   framing this as a city/ rural divide but there is a cultural and economic divide which can certainly be evidenced statistically in the differing expectations that those living in the Highlands and Islands can expect in terms of expectations of jobs, incomes, access to services and housing. The impoverished indigenous coastal communities are victim to and economic class who can buy room I n those communities for their own leisure which comes at the expense of the local people’s right to secure jobs, homes and community. This is an economic apartheid systemically driven by wildly unequal distribution of wealth through out the UK starting at the South East of England and continuing to the smarter streets of Edinburgh.Policy makers seem content to let this social and economic policy of inequality continue through active neglect and allow the indigenous resident to become the service capital for the needs of those who are economically superior. With urban aspirations divorced from the means of food production and the desire to live in a view rather than a working environment there begins the divide. To one section it is a landscape or marine environment in with to play and for the other it is to work. At its extremes the most affluent of the former indulge their personal mission of re-wilding back to an non-existent halcyon Eden.   

The ignorance that is driving policy is driven by a class of politician and civil servant that is now completely severed from the food producing community in this case wild capture fisheries. It goes further, those who fish are demonised and expendable.

What is also telling is the double standards to which fishing activity is held comparative to mans’ disturbance to the terrestrial landscape whether it be his cities, roads or farmed landscape. Terrestrial disruption would appear to attract less outrage than a ’perception’ of marine disruption through human activity. That evidence of any previous untouched marine state is a matter of guesswork is a fundamental flaw within the entire premise of these current HMPA  proposals.

 As one who has learned through enabling fisheries driven research, the importance of baselines, longitudinal data, timelines and importantly evidence of trends to make judgements, I find that the absence of  any of these within  the proposal should halt theses in their tracks. To propose closures, cessation of fishing, and thereby not just catchers livelihoods but all downstream associated socio economic benefits in the cause of some other, as yet undefined and unmeasurable ‘demonstrable benefit’ is extreme socio-economic cleansing of dependent communities.

What exists is an attempt is to fluff out what is a lamentable paucity of evidence into something that is no more than a woolly collection of intangible justifications and sound bite ‘feel good’ rhetoric.

The term ’just transition’ is the new buzz word however it does not apply to fishing of fishing communities.

‘Just transition is not a fixed set of rules but a vision and a process based on dialogue and a tripartite agenda shared by workers/industry and government that needs to be negotiated and implemented in its geographical, political, cultural and social context.’ source: Interenational Institute for Sustainable Development,.

No process of just transition dialogue is in train, in fact the opposite is the reality of these proposals with an end game that spells the loss to the fishing community their right to a livelihood.

Fishermen and their communities negotiate multifaceted dynamic environments constantly on all levels from nature to markets and that today mankind is collectively in a global state of uncertainty, politically economically and ecologically is merely an extrapolation of the norm for fishing communities.

In a political attempt to restore biodiversity to an impossibly undefined state at some point in what may be a halcyon past in the imagination of some, fishing communities will become the acceptable sacrifice.  To attempt this without a baseline or a realistic endpoint within an unstable environment is naïve. Fishermen have always detected subtle changes in the places for which they have in depth specific knowledge, although this knowledge is often thought of as lesser. If follows that to some they are a lesser class of persons, less worthy and expendable.

 

Question 1. What is your view of the aims and purpose of Highly Protected Marine Areas as set out in sections 2 and 3 of the draft Policy Framework?  

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

As one who took part in all of the earliest workshops on the first iteration of MPAs  which were at times challenging but brought all to the table in a spirit of true equality and respect this process is a wrecking ball in comparison.

The context of the evolution of HMPAs needs to be transparently acknowledged. Despite a historical process having previously been established with monitoring and guarantees of no further imminent development of MPA designations, HMPAs have emerged as a result of political discussions and not from a place of evidenced scientific or ecological need. In my own discussions with Marine Scotland staff implementing Historic MPAs and PMF sites in Orkney, the assurance was given that MPAs were not a tool to end activity but that fishing could not only continue but due to the ability of modern wheel house electronics not only could boats work inside MPAs but could do so around PMFs to within close proximity of historic artifacts or PMFs and not do them any damage. Vessel tracking systems were accepted by fishermen as a means of proving their own compliance and disproving false accusations of rule breach. This was the climate between MS and my fishing community in Orkney in 2020. The BHA has radically changed that and sprung on fishermen a rushed contortion to fit the concept of HMPAs into a credible narrative for the public in a time line that realists within fishing policy will know is impossible.

A report was due to be given in 2024 on the status of  MPAs indicating an agreed and understood process and time line was in place. Cumulative designations include sPAs as well as numerous  de facto closures and exclusions to fishing through other marine seabed developments (pipelines, shipping routes, cable routes, wind, wave and tidal farms, aquaculture and seaweed cultivation) .

The aim is ‘at least 10%’ of seas to be under protection. Where did that figure arrive from and how was it calculated, is it area or volume based? Even when the UK was in the EU there was a desperate push by SG and Marine Scotland to out legislate others in and attempt to be ‘world leading’ and ‘ambitious’. It opted to behave as an independent nation within the EU and apply the EU’s target MPA designations to itself rather than remain within the UK total. Even now Scotland exceeds the EU target total of 30% of protected seas with 37% of Scottish seas protected and PMF protections yet to be added. The desperation to appear world beating is rather pathetic when in reality the process MS is involved could be described as only world beating in terms of lack of credible process or demonstration of sound knowledge on the place of wild capture fisheries. This may sound harsh but having seen other fishing nations such as Iceland and Norway up close this is simply embarrassing.

Wild capture Fishing ‘damage’ is not evidenced or qualified nor ranked against terrestrial food production methods which not only ‘disturb’ the ground but pollute in other ways too ( fishing does not expel pollutants into the sea). This however is not to set one food production method against another but that some balance and perspective should apply.

The IUCN protected categories do not apply to Scotland’s fished waters and should not be retrofitted into the policy in order to enable enaction of the highest bar to human activity. Without any kind of baseline on any current status, against which to match effectiveness this is policy by wish and guess work and not any type of credible scientific methodology.

The vague benefits that might accrue where, ‘HMPAs would allow for more public enjoyment and appreciation of Scotland’s seas – and as well as enhancing the benefits that communities derive from the sea’ is meaningless. It ascribes to subjective feeling a value that cannot be pinned down. Indeed, it emphasises that for those who have been persuaded through propaganda that fishing is bad and the working-class communities that support fishing are expendable or can be directed to, as yet, unidentified alternatives, that they will ‘feel’ better or be less offended if they know there are no fishermen working. This is the reality of that aspiration.

Talk of ‘Blue carbon’ has become a trendy soundbite which again means very little other that those that use it see it as another means to limit fishing without evidence. It has become part of the language currency around disaster campaigning with a prior agenda to stop fishing. Research on blue carbon marine sinks is inconclusive but some ( Norwegian source unfound at time of writing) indicated it is only valuable in extremely deep oceanic trenches so deep as to escape oceanic turbulence and where sediment deposits accrue over very long time periods. There are no similar deep water trenches in inshore Scottish waters nor outwith the 12m limit. Crucially there is insufficient scientific evidence to justify exclusion of any fishing on the promise but unevidenced blue carbon sequestration theory.

‘some recreational activities to continue’ says the proposal. Recreational activities are those indulged in by those with leisure time and disposable income to spend on water pursuits many of which are expensive. This illustrates the class-based discriminatory thinking behind this proposal. Those who use the sea to earn a living and communities that are supported through year-round work via fishing will be supplanted by those who can afford to use the sea as a leisure park. In contrast later in the proposal (5,6) it states, ’some areas where HMPAs will not be situated as not practical or reasonable to remove or relocate existing activities or infrastructure’. Not so fishing which by this proposal it is deemed reasonable and practical to remove or relocate. Nor will HMPAs be sited in the Scotwind sites or the INTOG leasing round sites. This is a double standard in operation where foreign big business interests erecting windfarms or extracting oil with no direct benefit to local communities, get preferential treatment over the jobs and livelihoods of fishing people in coastal communities.

Question 2. What is your view of the effectiveness of the approaches to manage the activities listed below, as set out in section 6 of the draft Policy Framework, in order to achieve the aims and purpose of HPMAs?

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

‘Damage’ remains undefined, unproven and is emotively used throughout the document in relation to fishing in an unbalanced way in particular where there is no equal comparison to man-induced disturbances of many kinds on the terrestrial landscape. The process of procuring food for human consumption incurs human interaction with the environment, marine or terrestrial. Wild capture fisheries are the original renewable resource of food and energy for humans supplying high protein, omega rich low fat nutrition without additives and with the potential to deliver increased low carbon food resilience and improved health outcomes to an impoverished and nutritionally compromised population especially in the deprived urban areas of Scotland. That this food resource should be jeopardised by ignorance on the indigenous fishing industry is breathtakingly short-sighted.

Fishing closures will force fishermen due to area displacement to more intensively work other remaining areas. There is no quantification on the effects of this or how  this will move small boat fishermen in particular to less safe areas requiring more fuel, less profit and decreasing viability. There is no ‘just transition’ offered in practice as there is no plan to measure the effects. Cumulative closures from wind farms, aquaculture and cable routes on top of a further 10% sea closure particularly in areas like the Clyde but not limited to there are already seeing catastrophic decreases in vessels and the loss of knowledge capital and skill succession. This should greatly worry policy makers unless there is an unstated agenda by government to allow fishing to disappear through studied neglect rather than proactive policy. It is hard given the last 10 years not to think that that is not the case.

Question 3. What is your view of the proposed additional powers set out in section 8.3.2 of the draft Policy Framework: “Allow for activities to be prohibited from the point of designation to afford high levels of protection.”

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

This could be described not unduly, as environmental totalitarianism without process or evidence and epitomises the class discrimination against working fishing communities that I have already alluded to earlier. This is historic and endemic to the highlands and islands where low incomes in a UK context have propagated a third world exploited status on indigenous working fishing communities. These communities of which fishermen and their families are an integral part, are excluded from accessing affordable rental or purchased homes in their own areas because of the spiralling economic inequality between populations in richer parts of the UK and the coastal communities. They are forced to sit back helpless as their communities are hollowed out and taken over by second home owners and a lack of any kind of development strategy other than seasonal non-unionised, insecure and low paid tourism provision to service (predominantly) wealthier visitors. This is socially and economically damaging for these communities where a proper long term development strategy for fishing as an engine of modern renewal could be developed (See ‘A vision The Clyde Fishery CFT 2022). Its suits the moneyed classes that exploit the scenic highlands and islands as their playground, to perpetuate a decaying working infrastructure that fosters notions of indulgent re-wilding and finds substance in policies such as what will result from this policy proposal forced denial to working communities to a extract a modest livelihood from the local raw resources on their marine doorstep. That this can be seen as anything but discriminatory to indigenous coastal fishing communities is tragic.

Cessation of fishing at one fell swoop in the name of unevidenced and spurious ‘higher protection’ and without any prior understanding or pathway to’ just transition’ will create hardship, remove populations and consign Highland and island communities finally to a servile fate as waiters and cleaners in air bnb wastelands.

Question 4. What is your view of the proposed additional powers set out in section 8.3.3 of the draft Policy Framework: “Establish processes to permit certain limited activities within a HPMA on a case-by-case basis for specified reasons.”

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

Fishing should not be banned inside HMPAs, cessation of fishing was never the intent at the first tranche of MPAs and if fact such was a promise made by government to fishing communities. There is no evidence to support any form of fishing ban so there should be no need for fishing exemptions. As stated earlier the sophisticated tracking methods now available as part of normal fishing boat electronics and that satellite navigation can be accessed on a mobile phone, can identify areas where specific features can be avoided and where fishing can continue around them. Fishing is a ‘lifeline’ activity and should be acknowledged as such where ‘lifeline services’ are awarded special status. Enabling exemptions will simply provide an unfair route for those who can lobby loudest, access the media through campaigns or with the biggest financial shoulders to win those exemptions via malleable politicians. It is unlikely due to the relative poverty of fishing representative bodies in comparison to the eye-watering wealth of many conservation lobby groups that exemptions will favour fishermen. This was what happened in the old days before the genuine attempt through the first MPA designation process to structure a workable inclusive decision-making process.

Question 5. What is your view of the proposed additional powers set out in section 8.3.4 of the draft Policy Framework: “Activities which are not permitted in a HPMA but are justified in specified cases of emergency or force majeure.”

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

The policy per se is not supported due to its poor evidence base but it should be noted in any case that force majeure is part of shipping law which includes fishing vessels and as a safety necessity should obviously over-ride any other prohibitions or we will have indeed reached a stage where indeterminate subjective emotions  override tangible human well-being.

Question 6. What is your view of the proposed additional powers set out in section 8.3.5 of the draft Policy Framework: “Measures for activities allowed and carefully managed in HPMAs.”

I most strongly and vehemently oppose the proposals for HMPAs in Scottish waters.

‘carefully managed enjoyment and appreciation’ is a phrase which exemplifies the tenor of this proposal. It is vague, woolly subjective and both anodyne and highly dangerous. Who is to define whose enjoyment is to be identified as legitimate and what ‘appreciation’ entails and following that how or what the limits of managing such enjoyment and appreciation might be. At its conclusion the pursuits of the leisure class are ranked above the economic needs of the indigenous working fishing class.

 

Question 7. Do you have any further comments on the draft Policy Framework, which have not been covered by your answers to the previous questions?

Below are quotes from the text of the HMPA proposal and or its supporting documents .not limited to the draft Policy Framework Due to my limited personal capacity at this point in time to order these within a coherent argument as I would have liked and due to time constraints I have identified them here with comment as necessary.

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·         Bute house Agreement; ‘The measures we have agreed for enhanced marine protection will make Scotland an international leader’. The driver is not only ’keep up with the ‘ but surpass ‘the Joneses’ rather than work from a basis of identified need. This is not how any policy should be made.

·         ‘waters contain valuable blue carbon hotspots’. This statement lacks evidence, cannot be evidenced due to the lack of research on the topic and does not define value. This renders this statement meaningless other than as a seller’s marketing-speak and is not how policy should be made.

·         ‘restoring marine habitats’. Reference to this aspiration is so vague as to be meaningless or highly damaging but crucially refers to no point in time, no baseline and no process or expectation of what ‘restoration’ might look like particularly in an already highly dynamic environment subject to climate change.

·         ‘world leading suite of HMPAs covering at least 10% of our seas’. The driver is to be ‘world leading’ for an unspecified reason but one might guess it comes from ‘small man’ syndrome or a meaningless need to strut above others rather than to create policy based on evidenced need. There is no determination to be’ world leading’  through devising conservation measures that are envied because of their inclusive, evidenced and transparently agreed process. Notably the reverse is the situation. 10% is a figure that comes from no place other than it might be an easy round number for calculation. The marine environment of Scotland’s seas is so diverse that a simple percentage cannot be applied as a general measure over those different habitat types and qualities. As the sea is three dimensional it could be asked whether are we talking about spatial surface area, seabed area or volume and depth quantity? This is unclear but such a common failing of terrestrial thinking  is such as this which is frequently transferred to the marine environment to the detriment in particular of fishermen. Tidal behaviour for instance at different depths can be very varied within a single ‘core’ of water column.

·         ’offshore and inshore’. Scottish Government has jurisdiction out to 12 nm.  ‘inshore’ is defined differently in different contexts. The assumption is that it is inside 12nm. However areas of Scotland’s waters can vary hugely within that parameter from the Oceaninc volatility 12 miles from the Western Isles or Orkney to the shallower East coast or the contained sealochs of the West. What ‘inshore’ in practice means for the purposes of this consultation are areas easily accesses by the public, and crucially where small boat fishing enterprises operate. These skews the concept of inshore to that which is accessible rather than a defined category evolved through methodological process.

·         ‘by providing sites which will provide protection from all extractive destructive or depositional activities including all fisheries….. while allowing other activities such as tourism or recreational water activities at non-damaging levels (making them equivalent to marine parks)’.  This is economic discrimination of the fishing communities by denying them their right to work and earn an income from the resources of the sea where they live. This is effectively consigning working fishermen to the dole queue and throwing them off the sea (as many were evicted from the land in previous generations) to allow others to exploit their working environment for pleasure. This is nothing less than an economic clearance and discriminatory eviction of indigenous populations of coastal fishing communities.

·         ‘apply a cap to fishing activity in inshore waters’ Again, where is the evidence of need for this and if this applies to all gears and all sizes of vessel, why and where is the just transition plan or islands impact assessment, for those disadvantaged or the impact assessment of displacement fishing caused by those forced out of the area to other areas.

·         ‘ceiling from which activities that disrupt the seabed can be reduced’ Wild capture fishing is a renewable resource of sustainable food (food being energy for humans) and all food provision causes human disruption to some part of the planet. Fishing grounds are identifiable and although shoaling fish may move, sessile species remain and repopulate particular seabed habitats. The stability of the behaviour of these stocks does not mean that seabed disturbance is carried out opportunistically to ‘hit lucky’ as one might when fishing in a river (which may be how many unacquainted or wild capture fishing may presume). Known fishing grounds can be mapped. They are significantly less than  terrestrial comparisons with grain crop mono cultures or the presumed assumption that this is what takes place in the marine environment, ( the legacy of fishing illiteracy referred to earlier). Olex and marine mapping will show the fished grounds and how these are discrete to specific places and not a wanton ‘ disturbance’ of ground. There are double standards applied to ploughing, harrowing, planting and reaping of terrestrially grown food when compared with fishing gears and their use or ‘disturbance’.

·         ‘the recovery of PMFs which mostly lie within inshore waters’. What is the measure for recovery and from what perspective or point  of eradication does the PMF in question require re-establishment? Can the said PMF be recovered given other man-made inputs or effects like increasing weather volatility, storm disturbance, sea temperature rise, salinity fluctuations or pollutants?

·         ‘protection of blue carbon’ so far a sound bite construct without the research or evidence to support closures on a flimsy pretext but becomes part of the currency of conservation propaganda without backed up substance.

·         ‘account to be taken of socio-economic factors’ the reality of life being that for those who are not employed within government organisations in the coastal communities, fishing, processing, and the related supply chain is the only option for them. Tourism remains low paid and seasonal and the socio-economics of removing primary source economic activity will lead to wealthy pensioner ghettos exacerbating difficulties for local populations unable to access housing, further depopulation, community and service collapse.

·         ‘guided by just transition principals’ a weak phrase like this gives no comfort to those who will lose access to their working environment. ‘guidance’ is not mandatory and provides no guarantees, therefor the principles are worthless. The failure of just transition blights Scottish history from the ‘improving’ sheep farming lairds of the first clearances through the 1980sThatcherite decimation of the 80s of the industrial heartland of the country and crucially its mining and steel communities left on a scrap heap to fester and create a legacy of human misery spawning issues of poor mental health and addictive coping mechanisms.

·          It would seem that for the right of some, culturally urban in outlook,  to ‘feel better’ about a marine environment they are wholly divorced from, the real time livings of others must be sacrificed.

·         ‘HMPAs will allow for protection and recovery of marine ecosystems’. There is no defined baseline nor system of benchmarking how this might occurr. Man as a predator is part of the ecosystem and protected species such as seals and shark (spur dog) have altered the ecosystem already. Will these restrictions on protected species be lifted in order that  there be a return to a true in order unadulterated state?

·         This will ‘ contribute to halting biodiversity loss’ and ‘mitigate and adapt to effect of climate change’. There is no evidence to say how this will be done, how it will happen and how it will be proved to have done what it thinks it can.

·         ‘limiting or prohibiting specific human activities that may have negative impacts’ this in fact says that despite there being no proof that something has a negative impact it will be prohibited on a supposition. Qualified indeterminate language like this is unsuitable for building policy which removes the rights to employment of others. Fishing is a food provider yet it is deemed less worthy than recreational activities ‘which may still be allowed’. As we grind deeper into a crisis of austerity, cost of living, domestic hunger it beggars belief that recreation is prioritised over accrual of food through wild capture fishing . The policy reads like a right-wing charter to trap coastal fishing communities into third world status within their own homes dependent on a trickle down service economy model hopefully waiting at the bottom of the pile for the disposable income of those from much wealthier places.

·         ‘this will provide the best possible chance…..vital ecosystem services…food and marine industries ( para 7 policy)Coastal communities need more than the rhetoric of a policy of the lottery of chance. They need certainty that their way of life is valued, invested in and secured, and not being continuously undermined and threatened.

·         ‘HMPAs will protect the resourced we all rely on’  This is flannel it is undefined and generalises to the point of meaningless the undefined ‘resources’ and a ’we’ In only  can on ly assume excludes fishermen.

·         The defining of HMPAs refers to IUCN and cherry picks ‘high levels of protection’ without any of Scotland’s seas meeting the criteria defined by IUCN. The policy has used IUCN to pluck the most stringent levels of restrictions and then sought to cobble its desire for the exclusion of human activity into this particular fishing into the policy.

·         Proposed description of HMPAs cannot be evaluated because they are still just ‘proposed and not defined’. Responses cannot be made on an indeterminate and undefined concept.

·         ‘carefully managed enjoyment and appreciation’ is a phrase which exemplifies the tenor of this proposal. It is vague, woolly subjective and both anodyne and highly dangerous. Who is to define whose enjoyment is to be identified as legitimate and what ‘appreciation’ entails and following that how or what the limits of managing such enjoyment and appreciation might be.

·         Similary to above ‘harm’ would be prohibited. Harm is a subjective term without any definition, and where harm may be defined and evidenced and we assume again fishing for the purpose of this consultation is a ‘harm’, then in order to provide jobs food and viable communities  will there be a permissible level of the ‘harm’ that others perceive  in order to allow procurement of food and accrual of income and retention of working fishing populations in the coastal communities. If not then why is economic harm permissible to fishermen and their communities. Is it a lesser harm and if so shy?

·         ‘recovery to a more natural state’ again this is vague language, undefined, and what point in history are we to pin this preferable ‘natural state’ to, a childhood summer holiday 40 years ago? 100 hundred years ago, the last ice age? This is not how to make policy.

·         ‘Where possible mitigate the potential negative socio-economic impacts of designating a site’ this offers no guarantees to those who will lose their fishing livelihoods, it gives no guarantee of any form of just transition for them and it underlines the discriminatory attitude to working coastal communities and fishermen in particular from policy makers divorced from the realities of working fishing lives. If policy dictated a supermarket was to close  or any other job ended, then redundancy at least would be offered, however there would be such an outcry that this would not happen. The fragmented, weakened voices and scattered nature of the fishing populations makes them an easy target to liquidate from sight in pursuance of ‘world leading’ kudos.

·         ‘aim to mitigate where these are significant’ This is the fallacy of terrestrial thinking where a single fisherman’s entire livelihood may be lost yet he is insignificant in the bigger picture. This can never be  a comparison of like with like or monetary significance attributed to relative circumstance. This has been the way all fisheries objections to ground loss over the last 20 years where grounds  have been incrementally lost to other developers. From aquaculture to environmental designations to the Orkney EMEC site to wind farms, fishermen cannot demonstrate significant loss because their pattern of working is dynamic and not confined to a site specific value but as part of many sites which contribute to a total mosaic value. It suits government not to see this imbalance in the system in order for it to allow property rights to the sea bed for corporates.  Other fishing jurisdictions like Norway place higher value on the bespoke fishing grounds and needs of highly individual operators who get a say on whether development goes ahead or no .

 

·         The Benyon report refers to socio economics being trumped by ecology of data. This re-iterates a direction or thinking that places people  indigenous working fishing communities) below conservation and as ultimately  dispensable

·         ‘best available’ science is not the ‘best science’ or ‘peer reviewed’ science. This leaves the door open to  the ‘only’ science which may come from dubious or agenda driven sources. In a world of evidential armoury there needs to be a baseline and  transparent criteria for what constitutes  science and what does not.

·         ‘several organisations’  that will advise include ‘Nature scot’ which is funded by Scottish government and which many within the fishing community feel has become too close to environmental lobby groups in Scotland who are promoting ‘one-size-fits-all’ agendas such as the blanket 3nm trawl ban. Blanket measures never work in a fishing context ‘A vision The future of the Clyde Fishery’ identifies this in detail.

 

In a spirit of constructive contribution to the consultation I would urge that the recommendations offered in Clyde Fishermen’s Trust document ‘A Vision The Future of the Clyde Fishery ‘www.clydefishermenstrust.com/projects/science-policy be considered as a blueprint pathway for moving towards a modern, carbon conscious seasonally adapted and community empowered model of primary source resource utilisation.