2014 Consultation on the management of inshore Special Areas of Conservation and Marine Protected Areas - Consultation analysis report

19. Treshnish Isles SAC

19.1. Introduction

19.1.1. The Treshnish Isles were designated a SAC for their colony of grey seals and its reef habitat. The consultation presented two management approaches for this SAC, both of which would prohibit the use of suction dredges (boat or diver operated) throughout the SAC.

• Approach 1 would also prohibit the use of demersal trawls or mechanical dredges throughout the SAC.
• Approach 2 would prohibit the use of demersal trawls or mechanical dredges on a zonal basis.

19.2. We Asked

19.2.1. The consultation asked: 'Do you support the preferred approach (number 1) for managing this protected area?' A follow up question asking about support for the alternate approach was also asked.

19.2.2. The consultation also asked 'Do you agree with the economic, social, and environmental assessments of the impact of the management approaches?'

19.3. You Said

19.3.1. Many more respondents supported the preferred management approach for the site than did not. A full summary can be found in Table 19.1.

Table 19.1: Treshnish Isles SAC - Support for preferred management approach

	Yes	No	Other comments	No reply
Individuals (133)	9	-	-	124
Environment / Conservation (17)	9	1	-	7
Inshore Fisheries Group ( IFG) (3)	-	-	-	3
Industry / Transport (6)	-	-	-	6
Mobile fishing (8)	-	3	-	5
Local authority (3)	-	1	-	2
Local group (7)	1	1	-	5
Recreation / Tourism (13)	2	-	-	11
Static fishing (4)	3	-	1	-
Other (2)	-	-	-	2
Total (196)	24	6	1	165

19.3.2. One static fishing respondent commented without giving an indication of support or otherwise and this response is shown in the 'other comments' column in the table above. The respondent simply stated: "we support proportionate conservation measures with minimum impact on commercial fisheries".

19.3.3. Twenty of the respondents who answered 'yes' and three of those that answered 'no' went on to add comments. The key theme in comments from those supporting the approach was that it is appropriate to prohibit the use of mobile demersal fishing gear throughout the site. Several respondents added that this provides greater protection or facilitates recovery for marine habitats and/or meets the conservation objective.

19.3.4. One static fishing respondent added that they were pleased to see 'non-damaging' methods being allowed to continue and an individual respondent commented: "there should be management measures to ensure all creelers, even those under 12m and 10m have logbooks, VMS or other technology to chart their working areas. This might be an ideal area for research into reef rehabilitation, and also research on the impact of creels in one area over time, since mobile fisheries appear to believe creels do as much abrasion damage through impact as dredges and bottom trawling".

19.3.5. An environment /conservation organisation also commented on the importance of monitoring activity going forward in order to assess the impact of the management and the designation on species, habitats and marine users.

19.3.6. Two of the mobile fishing respondents that did not support the approach commented that whilst they recognised the need for management measures in an SAC to be more restrictive than for an MPA they felt this option was not in line with stated aims that allows for MPAs to be managed using the principle of sustainable use. Both commented that sustainable activity should continue to be permitted on non-qualifying feature habitat wherever possible.

19.3.7. The third respondent that did not support the approach and added further comment was an environment /conservation organisation. This respondent commented here, as in other areas, that they found options far too limited and felt this could be viewed as a bias in favour of the commercial fishing sector. The respondent suggested a 'no take' option which they recognised as unhelpful to local non-damaging fishing methods, but felt the current plan "does not allow for proper spatial planning".

19.3.8. Those who did not support the preferred option were asked: 'Do you support the other approach?' Four respondents, comprising three mobile fishing respondents and a local authority answered 'yes' whilst the remaining two respondents (a local group and an environment /conservation organisation) answered 'no'. Four respondents that had already indicated support for the preferred approach also took the opportunity to note that they did not support the alternative.

19.3.9. Two mobile fishing respondents who supported the alternative approach commented that Approach 2 allows sustainable activity to continue while still achieving the conservation objectives for the qualifying features within the SAC. In addition, these respondents noted that Approach 2 affords additional protection to non-qualifying features, namely seagrass and maerl beds, within the SAC and believed this to be beneficial to the network as a whole.

19.3.10. A third mobile fishing respondent that supported Approach 2 caveated their support with the comment that they had "supplied scallop plotter details of the area and would urge Marine Scotland to take note of these details to see if any more of the grounds can be opened up if features are shown to be unlikely to be damaged by fishing effort".

19.3.11. The final respondent supporting Approach 2, a local authority, commented: "Approach 2 is a more flexible approach to management and seeks to allow some small areas of non-reef habitat to continue to be fished. It is however noted that the economic impact of Approach 1 is not significantly greater and that this approach is likely to be easier to implement and enforce".

19.3.12. Only one of the two respondents who did not support either the preferred approach or Approach 2 added comment at this question and they reiterated points made in their rejection of Approach 1.

19.3.13. Finally, in this section, ten respondents answered 'yes' and six respondents answered 'no' in response to whether they agreed with the economic, social, and environmental assessments of the impact of the management approaches.

19.3.14. Five of the respondents that answered 'no' added further comments at this question. One of these, an environment /conservation organisation, despite answering 'no' commented that: "The risk of direct damage to the protected reef features from heavy towed gear and to their smothering from sediment suspended by trawling and dredging, far outweighs any very marginal short-term socio-economic gain".

19.3.15. Two environment /conservation respondents commented that the assessment has failed to consider the broader benefits that the proposed measures may bring, whether economic, social, health and/or environmental.

19.3.16. Another environment /conservation organisation noted the assessment that the static gear activity is currently "moderate" and that there is no proposal to introduce a limit to the static fishery to ensure this situation is maintained. The respondent commented that they "would welcome further consideration of precautionary safeguards against any future - potentially damaging - increase in effort or scale of static gear use in the site". A second respondent in the same grouping that answered neither 'yes' nor 'no' also suggested a need to monitor the use of static gear,

19.3.17. One mobile fishing respondent noted that the environmental report was not available at the outset of the consultation.

19.4. We Did

19.4.1. Please see broad issues section regarding creel fishing and the environmental report.

19.4.2. The Scottish Government welcomes the support for the preferred approach. We remain of the view the view that this approach is the most practical solution. Implementation of a zonal approach would result in tiny zones virtually impossible to monitor from a compliance perspective.

19.4.3. This SAC also protects grey seals. Rather than revisiting management of this site at a later date we intend to include a precautionary prohibition of set nets in the SAC.

19.4.4. We intend to implement the following measures for Treshnish Isles SAC by an Order under the Inshore Fishing (Scotland) Act 1984;

• To prohibit the use of the following fishing methods - suction dredge, mechanical dredge, beam trawl, demersal trawl, and set nets - throughout the SAC.

19.4.5. The measures and their ecological value are shown in appendix 19.