There's a Welsh Government Consultation called "Scallop Fishing in Cardigan Bay – New Management Measures". We'd recommend responding to it if you care about our marine environment.
How to respond - one of the following
- Online form on the Welsh Government website
- By e-mail: fisheriesmailbox@Wales.gsi.gov.uk
- By post: Scallop Consultation
Marine & Fisheries Division
Llys y Draig
Penllergaer Business Park
Suggestions for consultation response
The consultation can be completed very quickly and straightforwardly using the on-line form or email.
Q 2. Do you agree with the introduction of a Scallop permit scheme which would apply to Cardigan Bay, allowing conditions to be applicable out to 12 nautical miles?
No! Reject the idea that Cardigan Bay SAC should be opened up to damaging dredging. You can reply to this question and no other. You can include reasons in the open box, Question 17.
Questions 3 to 16 relate to the conditions that would apply to permits granted. They assume that a permit scheme would be put in place. If you have, as recommended, replied ‘No’ to question 2, then there is no need to reply to any of these questions. However, you may respond to them with a Yes or No reply to each suggested condition if you wish. Were a permitting scheme to be applied (despite objections) then these responses would be taken into account.
Guidance on reasons for objection to a permitting scheme for scallop dredging in Cardigan Bay.
• There is extensive evidence that scallop dredging is a particularly environmentally destructive form of fishing. It is very destructive to seabed fauna, particularly, ‘epifauna’ living on the surface of the seabed, but also to ‘infauna’, organisms that live in the seabed itself. Epifauna and infaunal species provide feed for other animals in the food chain, while epifauna create habitats for other organisms.
• A recent review of the impacts of scallop dredging1 states, ‘Of all the fishing gears, scallop dredges are considered to be the most damaging to non-target benthic communities and seafloor habitats’ (p.1). With respect to the type of dredge, the ‘Newhaven Dredge’ which is used to land 95% of King scallops in the UK, the review states, ‘Thanks to their penetrative nature and close contact with the seabed, the use of Newhaven dredges can cause substantial physical disruption to the seafloor and associated ecological communities. Furthermore, as Newhaven dredges are relatively inefficient in capturing targeted king scallops, fishers tend to perform repeated tows within the same area, thereby exacerbating any impacts they have on marine ecosystems’ (p.11).
• Scallop dredging is associated with a high level of ‘by-catch’ (for example, fish, crustaceans and other organisms) with substantial injury and mortality to other species caught.
• The purpose of marine Special Areas of Conservation (SACs) is to help create an ecologically meaningful set of marine protected areas, directly protecting designated species and habitats. Such a network assumes mobility and interconnectedness, so loss or damage of any of these key components would undermine effective environmental protection.
• A key aspect of European environmental law in terms of the Habitats Directive, which authorises the setting up of SACs, is that for such areas to be effective ‘site integrity’ must be maintained. This means not just that designated species are focused on, but that the entire environment on which these species depend is protected. Maintenance of ‘site integrity’ implies that ‘typical species’ in the area are maintained. Scallop dredging threatens site integrity.
• There is extensive evidence that preventing fishing in marine protected areas, including SACs, results in very significant recovery of the environment, including harvested and non-harvested species. Such areas have also been repeatedly been found to enable recovery and increased levels of harvested populations in surrounding areas. The protected area provides a source of growth and increase in species that are then ‘recruited’ into surrounding areas.
• The use of ‘rotational areas’, such as that proposed for the Cardigan Bay SAC by the Welsh Government, within marine protected areas with insufficient time for recovery (such recovery often involving many years) is counterproductive and is not an effective way forwards.
• The evidence provided by the ‘Fishing Intensity Study’ conducted in 2015 commissioned by the Welsh Government, and conducted by the Bangor School of Ocean Sciences, on which the Government relies does not provide reassurance that scallop dredging can safely occur in the SAC. Specifically:
- experimental evidence shows substantial reductions in seabed species following dredging. These changes have the potential to harm designated species such as bottlenose dolphins by affecting their food supply.
- important changes in seabed species occurred even several months after areas were dredged. Increases in species abundance in sandy areas reported in the study and represented as a positive outcome of dredging, included large increases in scavenging and parasitic species.
- minimum thresholds for scallop dredging proposed in the study are unreliable. They are based on a single study, conducted at one point in time, and are not consistent for impacts on different seabed species.
- comparison ‘control areas’ in the study are likely to already reflect earlier scallop dredging and to not provide a good ‘benchmark’.
- physical seabed changes observed were in some cases sufficient to enable cumulative structural harm to occur
- the impacts of activity in the SAC cannot be considered in isolation from impacts of previous and continuing dredging activity outside of it.
- there is not sufficient evidence to support introduction of a rotational scheme which could be relied on not to harm protected species (e.g. bottlenose dolphins, Atlantic grey seals).
- there is not sufficient evidence to conclude from the study on which the Welsh Government is relying, that permitted scallop dredging at any level would not harm conservation status which is required by European law.
Scallop dredging is currently restricted around the Welsh Coast. It cannot occur anywhere within 1-nautical mile (NM) of the coast, out to 3 NM in some locations, and within significant portions of relevant Special Areas of Conservation, including, for example, the Pembrokeshire SAC (around the tip of the Pembrokeshire peninsula) and the Pen Llyn a’r Sarnau SAC (areas around the Llyn Peninsula). These spatial restrictions and others relating to gear and engine size are detailed in the ‘The Scallop Fishing (Wales) (No.2) Order 2010’.
There has historically been substantial dredging for King scallops within Cardigan Bay itself. The Cardigan Bay SAC, which extends out to close to 12 NM in some areas of the Bay, exists to protect a number of habitat types, and certain designated species including particularly bottlenose dolphins, Atlantic grey seals, and sea lampreys. At the moment, scallop dredging is prohibited in the SAC under the Scallop Order above, except in one defined area. The reason for the restriction is that there is much evidence that dredging can be highly damaging to the seabed and fauna occupying it, such that the ‘conservation status’ of the protected species could be prejudiced.
There are high concentrations of King scallops within the Cardigan Bay SAC. The surrounding areas have already been heavily dredged and ‘stocks’, according to the Government consultation document, are ‘depleted’. The scallop fishing industry has pressed the Government to open up the rest of the Cardigan Bay SAC because they claim it would provide additional income. They dismiss the idea that dredging is prejudicial to conservation of the designated species and habitats here.
The Welsh Government is proposing to override the Scallop Order in Cardigan Bay. They are specifically proposing that the Cardigan Bay SAC be opened up to scallop dredging (except for the area out to 3NM from the coast, which is viewed as a ‘nursery area’ for King scallops), by providing ‘permits’ to scallop dredgers with certain conditions attached (e.g. relating to gear, time allowed to dredge etc). The consultation is essentially about whether or not such a permitting scheme should be introduced.
The Welsh Government have commissioned a ‘fishing intensity study’ which involved dredging experimental plots within the SAC in 2015. They claim that this study has identified levels of dredging (‘thresholds) below which dredging would not be harmful, and which would justify opening up the SAC, likely on a rotational basis. The Government is relying substantially on this study.
Under European law, the Habitats Directive, no activity may be allowed in an SAC if it would be likely to prejudice the designated species or habitats (for example, the bottlenose dolphin population that regularly frequents this area). Case law that guides interpretation of this Directive says the definition of whether an activity is acceptable in an SAC is whether it has been shown ‘beyond reasonable scientific doubt’ that it would not be harmful.
The evidence on which the Welsh Government is relying does not prove that the species and habitats would not be harmed. Opening up the SAC in this way would be very bad for the marine environment. It seems clear that the Government is giving undue weight to fishing industry interests.
While the consultation document refers to ‘Cardigan Bay, the focus of the consultation is the Cardigan Bay Special Area of Conservation (SAC). This is where the scallops are that the industry wishes to have access to.
- The Welsh Government consultation documents are available here. The consultation documents provide links to the ‘Fishing Intensity Study’ on which the Government relies.
- The review of scallop dredging impacts referred to above is Howarth, L.M., and Beukers-Stewart, B.D. (2014) The dredge fishery for scallops in the United Kingdom (UK): effects on marine ecosystems and proposals for future management. Report: Marine Ecosystem Management Report: University of York, York.
- (Most of this blog post text is from the Green Party Wales.)