Scottish Seas

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A Scottish Perspective (Diversity, Topography).

A Scottish Sea Loch as an Example.

No Take Zones.

Changes to Scottish Legislation: Stop Seal Shooting.

A Scottish Perspective; what makes Scotland's coast so special.

Scotland's West Coast

The western coastal fringes of Europe are influenced by relatively warm ocean currents, the Gulf Stream separates and it is the North Atlantic Drift Current that heads towards Scotland, this has a warming effect on the climate, with high levels of precipitation. The west coast of Scotland is influenced by both northern and southern waters, a Boreal current meets the Continental Shelf Current from the south, this produces an up-welling of nutrients and an abundance of phytoplankton and zooplankton forming the base of the food chain. As a result, large marine mammals are found here; important numbers of Pinnipeds and Cetaceans.

A Gannet out at sea on the west coast.

Extreme Topography

Scotland's climate and coastal regions are inundated with inlets, some of which resemble fjoridic and fjardic regions of Norway, Scotland's coastline is huge, Argyll, a mid county, alone has a coastline longer than that of France. A very special area which includes species at their northern and southern limits, species diversity is equal to the warm coral reefs.

A Common Dolphin in the Sea of the Hebrides.

Species Diversity

The west coast of Scotland is a 'hot-spot' for cetaceans (whales, dolphins and porpoise), visitors include the World's second largest fish, the basking shark, along with rarer deep water rays. Scotland is home to two species of seal, the Common and Grey seals. The British Isles accounted for around 40% of the European Common (or Harbour) Seal, this has declined to around 30% in recent years. About 40% of the Global population of Grey or Atlantic Seals are resident here as well.

A rock pool on Staffa.

Scottish ecosystems are as vital as they are diverse.

Scottish Sea Lochs and Loch Etive (An Example)

Much of Scotland's west coast is highly indented, convoluted with fjordic sealochs. Fjords are deep and steep sided with sills at their entrance limiting the inflow of seawater. Often brackish due to the immense runoff in western climes. This leads to special and difficult conditions which can contain isolated deep waters. Even the sediments are special holding varvic deposits which can give a snap-shot in time.

Highlighting Loch Etive as an example, situated midway on the west coast is an outstanding example of a Scottish fjoridic sea-loch, the pictures below are all taken in the Loch Etive water catchment area.

High up on Rannoch moor, home to a former glacial ice field rivers feed to the east, Glen Coe and Loch Etive. Peaty waters create an eerie brown tinge to the surface waters of the sea loch.

Loch Etive's upper basin, with depths exceeding 140m and a narrow sill at Bonawe Narrows. Deep waters here can be isolated for well over a year. These can become anoxic.

Tidal flows can be strong with over a metre difference in height either side of the Connel Bridge, the Falls of Lora.

With a flow exceeding 10 knots salt wedges form, overfalls, eddies and mini whirlpools.

Loch Etive has numerous fish farms, the nearest seen here is a mussel farm and in the distance a fin-fish farm.

Not all commercial practices are safe. One of the problems when commercial companies operate in remote, rural, marine locations.

Fin-fish, especially salmon farming is a big and growing industry along the Scottish west coast. Currently however, it appears that profit overcomes environmental concerns. Planning consents are conducted by those working from a terrestrial background with little allowable input from individuals or environmental groups. Government and government agencies appear hell-bent on supporting growth, especially with China's insatiable taste for salmon, but a one percent increase in supplying China would require a 50% increase in Scottish production. In its current form, that is not sustainable. The potential for environmental damage on a huge scale is very real.

These buoys support mussel lines. Mussel farming has always been considered one of the more benign methods of marine aquaculture but once again caution is needed and it has not been as more and larger farms become established.

Sea lochs and oceans, have a carrying capacity, a limit to what they can sustain without adverse issues. It has been suggested that Loch Etive has surpassed its carrying capacity, yet still they allow expansion.

Mussels syphon water; in doing so they feed by extracting particles from the water and they are very efficient, multiply that by millions and effectively the loch has one highly efficient 'cleaning' mechanism. However, when that means mass removal of other species the problem can become great.

In recent years a previously unseen mussel competed with the commercial varity,

Mytilus trossulus out-competing with the current commercial mussel species Mytilus edulis, 

but this new mussel (actually turned out to be the original species not seen since the last ice age) species contained only 10% meat and shells were so fragile that they could not be harvested using the current commercial methods. The problem was so bad that the industry voluntarily ceased production in the hope that the edible variety might return. For further reading.

Boats and moorings in Loch Etive were inundated with mussel spat (young mussels), so much so that it could become a problem. Boats moored outside of the loch but close-by had far fewer mussels and a combination of acorn barnacles and algae. Barnacles and algae in the loch were becoming less apparent. An altered ecosystem.

Is this a case of too much? More research is needed but the 'Precautionary Principle' as enshrined in the Rio 'Earth' Summit should have been utilised, often in Scotland's marine planning it is not.

Commercial activities need to look more closely at the very environment which supports it. Salmon farming is currently one of the worst offenders, where profit comes first even at the cost of the industry.

Peru and Chile have seen catastrophic collapses, Scottish salmon farming could be going the same way without enforced legislation.

It is not just aquaculture, mobile fisheries such as scallop dredging and benthic trawling destroy fish breeding grounds, few areas are given adequate protection.

There is room in our seas for production, activities and the environment such as the kayakers seen in the overfalls in the Falls of Lora, but only with real care.


Marine Protection - Marine Reserves - Marine National Parks: No-Take-Zones

Protection within the marine environment can take a variety of names from; - Marine Reserves, Marine National Parks, Marine Protected Areas, Marine Conservation Areas and more, all with a variance on the actual protection that they afford.

What is known that marine protection when applied with some degree of 'No-Take-Zones' work. No-Take-Zones are just that; nothing taken out, and in some cases nothing put in. Successful marine protection has seen fishing targeting the boundaries of the protected area with fishing effort reduced and both catch (quantity and species size) increase, including species diversity.

What is needed in any protected marine area is a region or regions of no-take, areas where nature can recover and regenerate. The size required for protection varies depending on location and commercial pressures. When the concept of no-take-zones or Highly Protected Marine Reserves were covered by the Royal Commission's 25th Report, 'Turning the Tide' in 2004 it was estimated that UK waters required 30% No-Take in order to sustain future commercial use and maintain species biodiversity and fish stocks.

Any designated protection without areas being left to recover, left to flourish are little more than paperwork exercises. Attention to detail in the wording of such protection vital, or the protected area/species becomes meaningless as has been seen in the Lismore Special Area of Conservation (SAC); designation Common Seals. Within this SAC the resident salmon farming company still shoots seals under a Scottish Government license, flouts seal haul-outs with debris and harassment; it even uses acoustic deterrents in a known cetacean hot-spot!

Once designated any protected area MUST be actively monitored and illegal activities penalised with deterrents that actually deter what can be hugely financially lucrative businesses.   

Changes to Stop Seal Shooting in Scotland

Following the recent debates before the Scottish Parliament under the Animals and Wildlife (Scotland) Bill (Stage 3), the situation of shooting seals under license from Marine Scotland is to end.


While the Scottish government is still to update its information pages the relevant points taken from the reading of the Bill are as follows: -

Section 29 (10A)

1, The Marine (Scotland) Act 2010 is amended as follows.

  1. In Section 110 (Seal Licenses) REPEALED (N.B. in relation to fish farms, please check sections, includes damage done and non-lethal provisions).
  2. Section(s) 121, 123, 124, REPEALED (N.B. powers around land and entry, please check sections).

In Section 7/128. Penalties

  • Summary conviction, to imprisonment for a term not exceeding 12 months or a fine not exceeding £40,000 (or both).
  • Conviction on indictment, to imprisonment for a term not exceeding 5 years or an unlimited fine (or both).


Marine Scotland Update:

The Marine Scotland website has produced the following in respect to the effect of the US Imports under the Marine Mammal Protection Act with regard to the shooting of seals by UK fish farms.



“Part 6 of the Marine (Scotland) Act 2010 seeks to balance seal conservation with other pressures and requirements, such as species conservation. On 1 February 2021 changes to Part 6 came into force which removed two reasons for which licences to kill or take seals could be granted. These are protecting the health and welfare of farmed fish and preventing serious damage to fisheries and fish farms:

  • it is an offence to kill or injure a seal except under licence or to alleviate suffering
  • a number of seal conservation areas around Scotland have been introduced, designed to protect vulnerable, declining Harbour seal populations
  • a seal licensing system, providing a well-regulated and monitored context for seal management in Scotland is in operation”.



The 'Bullet', Cheaper than Non-Lethal Methods

Double Skinned Anti Predator Nets (of the same mesh size) or Closed-Containment Prevent Most issues.

Numerous NGO’s, small groups and individuals have been pushing for an end to the shooting of seals in Scotland for many years, during deliberations of the Marine (Scotland) Bill many NGO’s formed the Seals Protection Groups, the author of this report was Coordinator to the group. The Marine (Scotland) Act 2010 repealed the Conservation of Seals Act 1970 in Scotland but the latter is still in force in England and Wales.


The UK is home to significant global populations of Grey (Atlantic) Seals Halichoerus grypus (approx. 40%) and Common (Harbour Seals, specifically the European sub-species) Phoca vitulina vitulina (previously 40%, more recently 30%), Scotland holds around 90% of both UK species.


The following bodies and acronyms can be confusing but please bear with it as it is import, one affecting another and so on but they do bring us to the current position.


Under the above legislation the Natural Environment Research Council (NERC) has responsibility to provide scientific advice to government regarding seal populations and ‘management’. NERC appoints the Special Committee on Seals (SCOS) to formulate advice, conducted by Sea Mammal Research Unit (SMRU).

N.B. In our view, the term 'management' is taken by the industries and government plus its Agencies is reference to shooting in the first instance, non-lethal methods exist but to date the industries involved have great influence over relevant authorities, government and politicians; we see little change while the bullet remains the cheapest option.


In the US the Marine Mammal Protection Act 1972 (MMPA), affords protection to all marine mammals and provides provisions for ‘take’ under certain exemptions. The relevant amendments under the List of Foreign Fisheries (LOFT) in 2017 are of particular interest and it is these changes that have caused the UK changes, as imports where marine mammals have been concerned include incidental take as well as ‘licensed’ activities such as shooting of seals. 


Amendments under the 2017 List of Foreign Fisheries (LOFT) applies to importing fish and fish products, it bans fish from commercial fishing operations that result in incidental or serious injury of marine mammals. There is a five year ‘notification’ system to allow for countries to adapt and it is now that the Scottish salmon industry and the Scottish Parliament  have been forced to consider the matters before the loss of exports.

Marine Concern have been concerned that under the current Presidency and the previous actions of Trump that these provisions may be overturned, that said it may not just be down to the US President as it appears that the MMPA follows requirements from the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), we will be watching this closely. Interestingly, Marine Concern reads that the LOFT regulations also apply to the mobile fishing sector, salmon netsmen and salmon anglers.


The bottom line here is that the ‘harvesting nation’, must

prohibit intentional killing of marine mammals.

It has become apparent that the UK/Scottish Authorities were working behind the scenes to gain exemption from the MMPA legislation but they failed. It is a process that they have used before and it worked in the dismissal of two EC complaints where the salmon farm in question killed 38 seals in two days, 50 in one season, obliterate the colony in a protected SAC….for seals. Despite NGO actions this farm remains in place adversely affecting the ‘protected’ seals.


Since the implication of the Marine (Scotland) Act 2010, the Marine Scotland website is where official figures are listed, these suggest that around 2,000 seals have been shot under license, since the 2011. However, many NGO’s consider that the actual figure to be much higher. Before the Act was in place when there were no constraints on the shooting of seals and nobody was checking, Save Our Seals Fund, estimated the real count to be around 10,000, this due to pressures brought by the Seals Protection Groups and others was probably reduced to around 5,000 but nobody knew for sure, but bodies of shot seals were common place around Scottish shores.


Currently licenses to shoot seals are administered by Marine Scotland, using a Permitted Biological Removal (PBR’s) figure. Many in the science sector suggest that when a population is in decline the PBR should be zero but not in Scotland. The figures reported for 2017 are shown below, please remember that there are NO independent checks and reporting is done on a self-reporting system. In addition, it is our view that the geographical method of recording on the west coast, bias in favour of returning high figures, hiding discrete lows in certain areas. Most shooting takes place in remote rural marine locations and salmon farming per-se does not hold good environmental credentials.


Marine Concern has suggested that the up to date figures should take in to account, ‘Struck and Lost’, pregnancy and lactating, shot seals unreported, when these figures are added to the official figures a more realistic total is achieved. It is important for the reader to understand the mindset of some involved, combined with profit margins of large multinational companies.  


Marine Scotland's 'official' figures for 2017; Grey 245, Common 113   (358)

Additional numbers added due to being pregnant and/or lactating       (35%)

Additional figures added due to 'Struck and Loss'                                 (50%)

Additional figures added due to lack of reporting, [conservative]          (25%)

Seals Shot in Scotland More Likely to be 800 plus per Year!


Shooting seals is not just about killing but also welfare, the use of acoustic deterrents also adversely affects cetaceans, unfortunately, despite being a legal requirement not to injure cetaceans this amendment did not pass the Parliamentary process. Marine Concern hopes that legal action being viewed now will bring justice to the marine environment and effective penalties for those involved.  

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