February 2019 impact inlocalecosystems.” and avoidnegative knockon fishing topreserve wildstocks for regulationofcleanerfish Government considertheneed recommends thattheScottish “The Committeestrongly turn unsustainable. increasing evidencethatthisfisheryisin in creelsforthispurpose,butthereis Five wrasse speciesaretrapped live fish” asasubstituteforthesechemicals. increasingly turnedtotheuseof“cleaner farms inScottishwaters,industryhas parasitic chemicaltreatmentsby salmon of EmamectinBenzoateandotheranti- As concernshavegrownabouttheuse and theScottish aquaculture industry Wrasse (“cleaner fish”) REC report,November 2018,Recommendation 28. AQUACULTURE INDUSTRY LICE CONTROL BY THE Wrasse (“cleaner fish”)andthe Scottishaquaculture industry Page1

controlling parasites their strikingappearance. recreational diversandseaanglers,given economic importance,particularlyto function, wrasse arealsoofhighsocio- In additiontotheirimportantecological or onhabitat-formingflora suchas kelp. other fish(includingcommercialspecies) and They feeduponcrustaceaandmolluscs kelp bedsinScotland’s coastalwaters. species whichinhabitrockyreefsand Wrasse areafamily(Labridae)ofseafish WATERS SPECIES FOR INSHORE – A KEYSTONE WRASSE play avitalroleinthewild which predateupon

Ballan Wrasse. Credit: OneKind. Available wrasse landings data suggest that local populations frequently Longevity collapse following the commencement 2 Some wrasse species - including ballan wrasse, of commercial fisheries.For example, the a key target species for the Scottish wrasse landings at ports such as Shieldaig, Portnalong, fishery - are slow growing and may have a Oban, North Harris and Lochmaddy all lifespan of more than 20 years. The removal experienced short term rapid growth in of mature specimens can adversely affect landings followed by rapid and substantive the reproductive potential of localised reductions. Such patterns are consistent populations. with over-exploitation of local fish stocks. The data are also consistent with the observed practice of Scottish wrasse fishermen, who Sex ratio alter their grounds from one year to the next. 3 The reproductive biology of wrasse is This is understood to be a response to local unusual; several species are nest-guarding, stocks being reduced below a level where with territorial males protecting the eggs as they can be economically exploited, and the they develop. The loss of adult males from a resulting need to move to new fishing grounds. population may therefore adversely impact Observations by recreational and professional on stock recruitment. Furthermore, some divers, sea anglers and initial scientific wrasse are protogynous hermaphrodites (i.e. analysis of local wrasse population declines smaller individuals are female that become following the commencement of wrasse fishing male when at a sufficiently large size). As a reinforces this analysis. result, size-based exploitation poses a risk to the sex ratio and presents a further risk VULNERABILITY TO to reproductive success. OVER-EXPLOITATION Wrasse are also unusually vulnerable to over- INADEQUATE GOVERNANCE exploitation and localised depletion, on ARRANGEMENTS account of their unique life cycle. In particular: A system of voluntary measures was developed by Marine Scotland after Limited home range consultation with the salmon farming 1 industry. Community groups, inshore Observations of wrasse in European seas have fishery representatives and environmental indicated high ‘site-fidelity’, suggesting that NGOs were excluded from the localised over-exploitation leads to localised consultations which drew up the measures. depletion. In effect, because of their limited As the measures are voluntary there are no range, when wrasse are removed from sanctions on fishermen who fail to follow an area, other individuals do not readily their requirements. recolonise it. Goldsinny Wrasse. Credit: Howard Wood. Wrasse. Goldsinny

Wrasse (“cleaner fish”) and the Scottish aquaculture industry Page 2 Shortage of ROLE OF THE 4 stock data AQUACULTURE INDUSTRY No substantive wrasse stock assessments have been conducted in Scotland, so there is Under the voluntary measures, responsibility no information as to whether the stocks are for maintaining data on fishing vessels at risk of collapse. As a result, the voluntary engaged in the wrasse fishery (Measure measures cannot ensure that the fishery 5.2) has been given to the salmon farming abides by the Precautionary Principle or industry’s trade body, the Scottish Salmon meets the Maximum Sustainable Yield Producers Organisation. Responsibility (MSY) standard required by the Common for ‘auditing’ the fishery lies with private Fisheries Policy. Furthermore, the catch salmon farming companies themselves and landings data that are recorded are (Measure 6.3), which cannot be acceptable. fragmentary, as there is no requirement The aquaculture industry is encouraging on fishermen under the voluntary the unsustainable expansion of the fishery: measures to collect or submit data on the SIFT has seen correspondence from within species of wrasse caught, nor the details the Scottish aquaculture industry to members of the catch that are returned to the of the Scottish fishing industry, specifically . However in 2017 the Scottish Salmon sea encouraging fishermen to consider targeting Producers’ Organisation acknowledged wrasse and highlighting that fishermen can that approximately half of the wrasse its earn up to £190,000 per annum from wrasse. members use were wild caught. Analysis by the Open Seas Trust estimates that this And demand is growing for Scottish equates to approximately 480,000 wrasse. wrasse, despite the absence of baseline With a conservatively estimated weight for information about stocks. Analysis of each wrasse this equates to some 217 tonnes growing salmon farm demand for cleaner fish of wrasse per annum. This does not tally with (both wrasse and lumpfish) projects that by landings reported by the Marine Management 2020 up to 10 million cleaner fish per year will Organisation or by Marine Scotland. be needed by the salmon farming industry in Scotland. Data from Norway indicate that 36% The fishing season is in the of cleaner fish used in aquaculture are wrasse. 5 breeding season If this represents a model for the data-poor Under the voluntary measures, the Scottish Scottish fishery, then demand for wild wrasse wrasse fishing season runs from 1st May can be expected to increase substantially. to 30th November, which suits the salmon Efforts by the salmon farming industry to farming industry. This coincides with the breed wrasse for supply to salmon farms wrasse breeding season, though, against all have yet to result in production levels which norms of good fisheries management. come close to meeting current, let alone Minimum and maximum landing future, demand. For example, in 2015 75,000 sizes are inadequate wrasse were produced (c. 3 tonnes) and in 6 2016 118,000 were produced (c. 4 tonnes). The Given wrasse species’ vulnerability to size Scottish Government reports that production related exploitation, highly specific minimum tonnage of wrasse in 2017 fell back again and maximum conservation reference sizes to 58,000 wrasse (i.e. less than 1% of the are vital to maintain balanced stocks and predicted demand by 2020). reproductive potential. The minimum and maximum sizes in the voluntary measures are We believe Marine Scotland and the Scottish simplistic and depend upon whether wrasse Government are failing in their duties under belong to ‘small’ or ‘large’ species, in contrast the Nature Conservation (Scotland) Act 2004 to the detailed Landing Size regulations by not using statutory powers to act and enforced in English wrasse fisheries. prevent damage to the wrasse population.

Wrasse (“cleaner fish”) and the Scottish aquaculture industry Page 3 It is the duty of every public body and office-holder, in exercising any functions, to further the conservation of biodiversity so far as is consistent with the proper exercise of those functions. Nature Conservation (Scotland) Act 2004, Section 1 Cuckoo Wrasse. Credit: Howard Wood. Wrasse. Cuckoo

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SIFT is not opposed to the use of In addition to evidence from proper 1 cleaner fish in aquaculture, but this 2 scientific stock assessments that a would require either the responsible use of catch would not damage local populations, farmed wrasse and lumpfish, or a genuinely any wild wrasse fishery would have to be sustainable and properly regulated fishery properly regulated. The Devon and Severn based on sound science. Inshore Fisheries and Conservation Authority has set a good example here: when it was In advance of these changes, a moratorium concerned about wrasse catches in its area on the wild fishery for all wrasse species, (for the Scottish salmon farming industry), under the Inshore Fishing (Scotland) Act it brought in effectively monitored and 1984, is essential. enforced mandatory measures to collect accurate data, and implement quotas, spatial management and temporal restrictions. Scotland can and should follow a similar approach under the same 1984 legislation.

The Sustainable Inshore Fisheries Trust (SIFT) is a Scottish charity that aims to promote the sustainable management of Scotland’s inshore waters so they bring the maximum sustainable social and economic benefits to all of Scotland’s coastal communities.

Sustainable Inshore Fisheries Trust is a Registered Scottish Charity 5 Rose Street Edinburgh EH2 2PR No. SC042334, Scottish Charitable Company Limited by Guarantee, Registered No. SC399582. www.sift-uk.org

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