Fighting to save the lives of seals by aiming to replace the Conservation of Seals Act 1970 with a Protection of Seals Act.

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Letter to the Editor of the Scotsman from Sue Wilson, Tara Seal Research

In response to an article which appeared in the Scotsman on 30 October entitled "Seals to be given better protection under new legislation", Sue Wilson has written a letter to the Editor:

Dear Sir,

In your article of 30.10.09 'Seals to be given better protection under new legislation', I must take issue with the comments by Richard Lochhead quoted in the article.

Firstly, his comment 'The bill will put Scotland at the forefront of improving seal protection, creating a new offence of killing or injuring a seal at any time, unless under licence'. I should clarify here that such an offence has already existed in Northern Ireland since 1985, the Isle of Man since 1990, the Irish Republic since 1976 and other EU countries including Sweden since 1988, Finland since 1982, Denmark since 1976–77, Germany since 1971–73, the Netherlands since 1962, and France....need I go on? Enacting this bill should therefore help Scotland to catch up with its EU neighbours in seal protection, but it will be nowhere near the forefront in this regard.

A retrograde step is already waiting in the wings of the new bill, and that is in the licensing system for killing seals to protect fisheries and fish farms. The new licensing system planned for Scotland will involve ‘Permitted/Potential Biological Removal (PBR), which provides a maximum number of seals that can be removed without affecting the wider population.’ This ‘PBR’ could potentially cover the licensed killing of tens of common seals and even higher numbers of grey seals in any one area. The licensing system even intends to over-ride the two species breeding seasons, meaning that pregnant females or mothers with dependent pups may be legally killed under licence. A licensing system for killing seals does exist in other EU countries, but the number of seals actually killed annually under such licenses, for example in Ireland, Germany and Denmark, is reported to be very small and in single figures. The planned system under the new Scottish bill would keep Scotland well to the bottom of any seal protection league table in the EU.

The debate really comes down to a matter of ethics rather than of population biology. Just because an animal population can theoretically be reduced to a 'PBR' limit does not mean that it is therefore morally acceptable to kill seals – or, for that matter any other animal species, including humans! A recent independent survey in Scotland found that 75% people polled did not want seals to be killed and only 12% thought that fishermen or salmon farmers should be allowed to kill seals. Surely society values and ethics should surely be reflected in legislation and in the way that legislation is implemented?

A new offence of harassment and disturbance of seals has also been proposed by the Parliamentary Committee for the new bill. This would bring Scotland’s legislation into harmony with that in Northern Ireland and the Isle of Man, under which it is an offence to intentionally disturb seals at haul-out sites. I am dismayed that Mr Lochhead should be expressing 'caution' at introducing such a humane and common-sense measure on the grounds that it might inhibit 'legitimate activities'. That is surely the point – intentional disturbance and harassment of seals at their breeding haul-out sites would not be a legitimate activity under the new bill. How could anyone possibly think that it is morally acceptable to harass seals at their haul-out sites? Disturbance is one of the principal reasons for separation of newborn pups from their mothers. Harassment is also a principal reason for haul-out site abandonment and loss of inshore habitat for seals, and when that happens, Scottish landscape and natural heritage is very much the poorer for it.

The Lib Dem member for Skye and Inverness West, Mr John Farquhar Munro, has, in my view, embarrassed his party by allegedly stating that 'Seals are not the friendly, cuddly mammal many people imagine them to be', in the context of apparently implying that their populations should be reduced in the interests of fisheries. I have spent much of my adult working life studying many aspects of seal biology, including social behaviour, the rearing of ‘orphan’ pups, the impact of human disturbance on breeding seals, seal diet, interactions with fisheries and fish farms, and investigating mortality by dissecting dead seals. I can assure Mr Munro, that it is my experience as a seal biologist (and not my imagination) that seals are just as ‘friendly and cuddly’ to each other as are humans and very much nicer to humans than humans are to seals. The shame is on Scottish human society which has not yet, it seems, learned how to appreciate or live in harmony with the beautiful, charismatic and flagship seal species in its coastal waters.

Yours sincerely,

Sue Wilson (Dr)
Tara Seal Research
Chairperson, Seal Conservation Society

Marine Bill - Conservation of seals - TNS System Three was commissioned by Advocates for Animals to measure public opinion amongst the population of Scotland. A sample of 1,003 adults aged 16 and over was interviewed in-home in 43 constituencies throughout Scotland over the period 3rd to 10th January 2008.

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