Fisheries management measures within Scottish Offshore Marine Protected Areas (MPAs): consultation analysis

Views on proposed zonal fisheries management measures for offshore MPAs

Overview

Overall, most responses (66%) to this question indicated support for the proposed zonal fisheries measures. It should be noted that while campaign responses from Oceana and SE Link did not directly answer this question it is clear from their responses to other questions that their preference would be full site measures as is discussed in the next section.

Support for the proposed zonal fisheries management measures

Many respondents believed that Option 1 measures – around the proposed zonal fisheries management measures - were the result of extensive and inclusive stakeholder engagement, who had assessed and confirmed the measures' alignment with conservation objectives. These respondents felt that this process lent legitimacy to the proposed approach. This point tended to be raised in campaign responses, such as this one:

"Reasoning behind my support for measurers identified in Option 1 include:

• These measures were developed through extensive and inclusive stakeholder meetings with the final proposals being assessed by JNCC who confirmed that the measures would meet the conservation objective for the sites concerned.
• Measures under option 1 had the general support of the EU Advisory Councils, including NGOs and fishing bodies.
• Measures under option 1 would ensure MPAs are managed using the principles of sustainable use.
• Failure to follow the proposals that were developed through the lengthy and costly process would suggest the whole exercise has become meaningless and result in loss of trust by many […]” - [Individual].

Relatedly, some said that not following the proposals developed through a long and costly process could damage trust. They suggested that abandoning these measures would make the entire process appear meaningless and could lead to a loss of confidence among stakeholders.

Some respondents felt that Option 1 ensures that Marine Protected Areas (MPAs) are managed with an emphasis on balancing conservation with sustainable use practices. Indeed, there were suggestions that Option 1 would be more aligned with international goals for environmental and marine sustainability – including the UN Sustainable Development Goals – by conserving and sustainably using ocean resources. As mentioned in above quotation, some respondents believed that the measures outlined in Option 1 were in line with fisheries management guidance provided by Statutory Nature Conservation Bodies, and thus better for wildlife.

A few respondents raised a need to design a plan for strong enforcement of the zones, but did not add further explanation. Others highlighted that the zonal approach under Option 1 could be cost-effective, offering similar environmental benefits to a full site approach but at a lower cost, particularly for mobile bottom-gear fisheries. They noted that Option 1 would impose less economic strain on a sector already facing restrictions.

Several respondents in support of Option 1 thought it would help maintain the resilience of the fishing industry, thereby contributing to stable food security. They expressed concern that more restrictive measures could threaten the fishing industry's stability.

Moreover, those who viewed a zonal approach for Scottish offshore MPAs as the only viable option felt it enables for some fishing activities to continue to take place in the area whilst allowing the most vulnerable features within the site to be protected. They also felt that Option 1 would reduce the effects of displacement and protect national capital:

"A zonal approach also reduces the effects of displacement into other areas - especially important when alternative grounds are being dramatically reduced in size due to various reasons." – [Organisation]

A few respondents said they felt that Option 1 was the least detrimental option, and one that had already been agreed to by industry. They therefore wondered why Option 2 had been set out and consulted on, and maintained that Option 1 went at least some way in recognising the need for balance between conservation and sustainable fishing.

A couple of respondents said that, while they supported Option 1 generally, this support would vary on a case by case basis to management measures related to an individual site or area. Meanwhile, others called for a ban on bottom trawling as a bare minimum in all MPAs, while one respondent said that they supported Option 1 measures in relation to essential reefs and places of special interest only.

Opposition to the proposed zonal fisheries management measures

Many of those who opposed the proposed zonal fisheries management measures believed that full site fisheries management measures are the only means to suitably protect the NCMPA and associated marine ecosystems. Some felt that, while zonal measures might protect the marine environment, they will not improve the management of fisheries:

“We take a broad historical view and consider the wider needs of Scottish seas. As we know from the Scotland’s Marine Assessment 2020, our seas are not in good condition. We also know that there is a biodiversity crisis and that attempts to improve protections through HPMAs have been abandoned. We know that some of the problems are caused by unhelpful fishing techniques. These are reasons enough to suggest that we should apply maximal protection at this opportunity” – [Organisation].

Several respondents were of the view that zonal measures would likely degrade any value in the MPAs both through fragmentation and practical difficulties in their establishment and enforcement, and fail to meet Good Environmental Status and site conservation objectives:

“The only way to achieve Good Environmental Status is to stop nibbling around the edges and end the destruction and disturbance of the seabed through damaging and extractive activities. Full site closures, to damaging fishing practices, is the only way to make a reasonable difference and afford meaningful protection to these habitats, avoid cascading impacts to mobile species and improve ecosystem integrity” – [Organisation].

There were also concerns that zonal measures could make protected features in several key areas more vulnerable, with some providing examples for specific sites (which are discussed later in this report):

“The proposals inappropriately leave protected features exposed in several key areas - this is most stark in the Central Fladen MPA where protection is less than 50%, but also the case in, for example, the North-west of the Pobie Bank SAC where areas of reef which were clearly demarcated for protection in the designation process at the North-west corner of the site are not included in the zonal proposals. This will prevent the achievement of the conservation objectives and site integrity. Scientific analysis highlights that it is unlikely that protecting less than half of the designated feature in Central Fladen MPA will allow it to recover from its current unfavourable status”. – [Organisation].

Others opposed to the proposed zonal measures emphasised the importance of full site measures in reducing fishing pressure both within and out with MPAs. There were specific calls for the exclusion of longline gear and the prohibition of bottom towed fishing techniques, which were considered to have the most significant impacts on benthic habitats:

“Bottom towed fishing should be banned in full in all MPAs. It is not in accordance with Scotland's requirement to obtain Good Environmental Status, as it is highly damaging to the seabed. Without full protection from such fishing methods, the seabed will not be able to recover” – [Individual].

Several of those in opposition of the proposed zonal measures were of the view that the approach is based on flawed logic and assessments and is therefore unsound. They raised that the socio-economic impact assessment assumes fishing effort will be lost and not displaced under Option 2, while the strategic environmental assessment assumes fishing effort will not be lost and instead will be displaced. They were concerned that the consultation documents did not address these mutually exclusive assumptions, and “therefore incorrectly [argue] that “Option 1” would be both cheaper and better for the marine environment” [Organisation].

Meanwhile, a couple of respondents felt the zonal measures proposed for some of the areas will put fishers ‘out of business’, with one commenting on the make-up of stakeholder engagement attendees and a perceived lack of input by local fishers:

"Measures based on historic data which is flawed and composition of workshop attendees skewed towards environmentalists. Lack of input from local fishermen whose livelihoods would be affected by these measures." – [Organisation].

Conversely, one respondent suggested beginning by implementing slimmer zonal areas to observe the effects of the measures, as larger zones may “wipe out many, if not all, fishing grounds” [Individual].

Neutral views on the proposed zonal fisheries management measures

Several respondents said they had a neutral position in relation to the proposed zonal fisheries management measures. Some said this was because the proposed measure provides adequate protection to the protected feature in some instances, but not in others.

Other respondents felt that the current proposal lacks clarity around critical details of the zonal measures, and thus felt unable to make an informed decision for or against the options presented:

“Key information, including on the timing of implementation, the size and location of exclusion zones, seasonal restrictions, the types of fishing that would be permitted, and associated monitoring and enforcement to ensure compliance are lacking. Without these details, it is impossible to assess the potential effectiveness of these measures, making it difficult to support them in their current form” - [Organisation].

A few respondents selected having a neutral opinion about the proposed zonal measures, though their written comments indicated their support or opposition for the measures.

Summary

In summary, the proposed zonal fisheries management measures (Option 1) received a mix of support, opposition, and neutral feedback. Supporters emphasised the extensive stakeholder engagement process, aligning the measures with conservation goals, and maintaining a balance between conservation and sustainable use, especially for the fishing industry.

They argued that Option 1 was more practical and cost-effective, ensuring the resilience of both the marine environment and the fishing community. However, critics contended that zonal measures would not provide sufficient protection for marine ecosystems and could hinder the achievement of conservation objectives. Concerns were raised over the potential fragmentation of protected areas and the continued threat of damaging fishing practices, particularly mobile bottom-gear fishing. Some respondents remained neutral, citing a lack of crucial details about the measures’ implementation, making it difficult to fully assess their effectiveness.