The Scottish Fishermen's Federation (SFF) has rejected a recent report issued by Oceana which described key UK fish stocks as "critical".
Calling the report a "misleading attack", the SFF has issued a detailed rebuttal of the report by its Chief Executive Elspeth Macdonald.
"This report is a naïve assessment based on only partial knowledge and limited understanding of fisheries science and management," Macdonald said in a written statement.
The Oceana report claimed that over a third of UK fish stocks are overfished, and around 25% have been reduced to "critically low population sizes". However, Macdonald says that fluctuations in fish stocks are "routine".
"Increases and decreases in scientific advice between years are absolutely normal. Scientific advice also contains margins of error. These and other factors are taken into account by fisheries managers in setting total allowable catches (TACs)," she explained."
"If TACs are set that exceed scientific advice, then that will have been carefully considered by fisheries managers within governments. We are fortunate in Scotland in having very well managed fisheries," she added.
Tackling the "at-risk" stocks highlighted by the Oceana report, Macdonald said that the Scottish fleet does not exceed its quotas for mackerel, and that the cod stock in both the North Sea and West of Scotland is "abundant".
"Fisheries managers in the UK set quotas for mackerel based on ICES scientific advice, and the Scottish fleet fishes within these limits. Some other countries involved in the mackerel fishery do exceed limits, but we do not."
The Oceana report had highlighted three stocks as particularly at risk, noting "Celtic Sea cod, West of Scotland cod and Irish Sea whiting" were often caught as bycatch. In response to this, Macdonald noted, "Scientists now acknowledge that there is no such thing as a West of Scotland cod stock."
"We have a northern shelf cod stock that covers the North Sea and West of Scotland, and ICES advice due to be published very soon is expected to show that it is in good health. It will be evident that science is catching up with what fishermen have been saying for years – that cod are abundant in Scottish waters and that the stock is healthy."
Macdonald also pointed to the Scottish Government's sustainability indicators for fish stocks as evidence of sustainable practices by Scotland's fishing industry.
"In 2020, an estimated 69 per cent of commercial fish stocks were fished at sustainable levels in Scottish waters," she said.
"This represents an increase of 35 percentage points from 2000. The percentage fished sustainably in 2020 is the highest level recorded since this data collection began (1991) and demonstrates the ongoing recovery of the commercial fish stocks."
"No-one has a greater interest in fishing sustainably than those who make their living from the sea, and we strongly support greater cooperation and knowledge sharing between fishermen and fisheries scientists so we can have the best possible information on which to base the best possible management," Macdonald concluded.
The Scottish Fishermen's Federation (SFF) was formed in 1973 to preserve and promote the collective interests of Scotland's fishermen's associations. The Federation plays an active role in advancing the interests of Scottish fishermen at national and international levels by lobbying government officials in Edinburgh, London and Brussels. The Federation also plays a key role in helping to inform: fisheries science; the management of the marine environment; inshore fisheries management; marine spatial planning; marine safety regulations and industry recruitment and training programmes. The Federation umbrella covers eight geographical/sectoral constituent associations representing around 400 vessels from inshore creel boats to pelagic trawlers.