The Manchester United legend thinks the £37.1 million January signing lacks pace - and wants the England striker to stay at Old Trafford.
The former United midfielder was discussing record-signing Angel Di Maria and where he would fit into Louis van Gaal's side and observed that Spaniard Mata is not fast enough to be effective on his own.
Indeed, Scholes believes Di Maria's introduction can help as the 26-year-old is 'a great player' but 'doesn't have any pace.'
"He [Di Maria] could also play in the same side as Mata. Mata is a great player but he doesn’t have any pace and needs to be played with others who do," Scholes wrote in the London Evening Standard.
Reports suggest Van Gaal could let the 23-year-old leave Old Trafford this summer, though Scholes wants him to stay with United - as he believes he can score 15-20 goals a season.
"I hope Di Maria’s arrival does not mean that Welbeck leaves," Scholes said.
"Danny has a lot to offer, not least the raw pace that is lacking in United at times. His problem has always been that he has not scored enough goals.
"I would have liked to see him given a run in the team of 10 to 15 games. It is going to be hard for him to get that now, with so many players ahead of him, but he is certainly capable of 15 to 20 goals a season."
United travel to Burnley for their next Premier League game, when their recent shock 4-0 defeat to Milton Keynes Dons will still be fresh in their memory.
|Wayne Rooney||Man Utd||FW||17||29||2,448|
|Robin van Persie||Man Utd||FW||12||21||1,584|
|Danny Welbeck||Man Utd||FW||9||25||1,459|
|Juan Mata||Man Utd||MF||6||15||1,230|
|Javier Hernández||Man Utd||FW||4||24||839|
As Opta stats show, meanwhile, Welbeck and Mata were the club's third and fourth highest scorers last season respectively.