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

Strategic Environmental Report (SEA)

A significant number of responses contained no comments, or respondents skipped the question. Comments which were made on the Strategic Environmental Report (SEA) largely reiterated points from questions 1 – 4, with responses generally indicating support for either Option 1 or 2 measures, and emphasising different pieces of evidence from the SEA, or highlighting areas respondents felt were missing from it.

Missing economic impacts

Amongst those who oppose Option 2 measures, the primary theme in responses were that the assessed environmental impacts of Option 2 management measures do not demonstrate significant benefits over those in the Option 1 proposals, and that the SEA did not adequately capture the economic harm that will take place under Option 2, and especially the disproportionate impact that the measures will have on the mobile demersal gear sector. Many respondents also emphasised that they felt the Option 2 measures were not developed with enough stakeholder engagement or consultation.

Contrastingly, some felt an inaccurate portrayal of impacts was presented through the SEA due to its lack of reporting of the economic benefits, and overrepresentation of economic disadvantages, which could occur from the additional environmental protections under Option 2:

“The SEA does not provide an evaluation of the economic impacts of environmental outcomes, such as benefits to wildlife tourism… respondents have a limited and incomplete picture of potential impacts, which is likely to influence their responses.” [Organisation]

Displacement effects

An additional critique of the SEA expressed by numerous respondents was that they felt it didn’t include a comprehensive consideration of the potential for displacement effects from Option 2:

“Adverse effect of displacement of fishing activities have been severely underestimated.” [Organisation]

Many were concerned Option 2 measures would lead to increased intensity of trawling activities in non-protected areas, thereby actually harming Scotland’s ability to achieve good environmental status and felt the assessment did not consider these impacts from expected behaviour change/fishing patterns due to these measures. Others argued the methodology used in the SEA did not fully account for these impacts specifically from foreign vessels which fish in the areas; a few also noted this will be compounded by other sectors (e.g. offshore renewables) which are already spatially restricting fishing activity, which they did not feel was adequately captured in the report or examined in the assessment.

A few also voiced their concern about the impacts of these measures on inshore MPAs and marine ecosystems, in part due to displacement effects, and emphasised the need to prioritise the protection of shellfish beds when implementing any measures.

Spillover effects

On the other hand, respondents in support of full site (Option 2) measures felt that the SEA was biased towards the zonal measures, and did not adequately assess the positive environmental impacts from spillover effects, and overestimated the risk and impacts from potential displacement effects:

“It appears, for some sites, that the Government is giving more weight to the negative impact of displacement of fishing activity and potential effects from other gear types than the benefits of the spillover effect…If the Government is concerned about an increase in fishing effort outside of the site, then appropriate management, monitoring and enforcement of fishing activity should be used to mitigate the risks, and these risks should not be used to underestimate the overall environmental benefits of protecting the whole site.” [Organisation]

However, a few respondents felt the estimations of benefits from the spillover effect were actually overestimated in the SEA, and disputed the approach used to achieve the findings in the report:

“Having worked on spill-over the estimation of potential for these benefits is reliant on an oversimplified approach that would not be acceptable to peer-reviewed science.” [Individual]

Concerns for marine wildlife

There were some additional comments about animal welfare considerations being overlooked in the report, such as one suggesting the SEA should:

“address how specific conservation measures and fishing restrictions could improve the living conditions and reduce the stress and mortality rates of marine animals within MPAs. Including welfare criteria would ensure that management measures are not only environmentally sustainable but also ethically aligned, enhancing Scotland’s leadership in marine conservation and animal welfare.” [Organisation]

And one respondent noted they felt the impacts on wild salmon and sea trout were not properly assessed:

“We are disappointed that in the category of fish species, that wild Atlantic salmon and sea trout are not mentioned given their status both as an endangered species, Marine Priority Species and their significance to Scotland’s culture and economy. There has been no assessment of the impact on salmon and sea trout as Marine Priority Species or on the status of Special Areas of Conservation where Atlantic salmon (or other symbiotic species such as Freshwater Peal Mussel) are protected, where post smolts from these catchments travel through these MPAs.” [Organisation]

General approval

Finally, there were a couple of comments generally expressing approval of the SEA, namely that it provides a good summary and that due to lack of current benchmark evidence, as expressed in the report, this assessment is useful to have for future reference as a point of comparison.

Summary

The majority of comments in response to the Strategic Environmental Assessment were on aspects respondents felt should have received greater emphasis in the report, including economic impacts (both harms and benefits from Option 2), ecological impacts from Option 2 such as displacement effects (harmful) and spillover effects (beneficial) and general concerns for marine wildlife. However, there were also a number of responses which stated they approved of the SEA and is methodology, citing it as a good source of evidence.