Phase 2 MPA measures and PMF review minutes: Coastal Communities Network - 16 January 2020

Attendees and apologies

Attendees:

• Marine Scotland (MS)
• Community Association of Lochs and Sounds
• South Skye Seas Initiative
• Coastal Communities Network (CCN)
• Save Seil Sound
• Community of Arran Seabed Trust (COAST)
• Friends of Sound of Jura

Items and actions

Following a presentation from Marine Scotland, the group discussed Coastal Communities Network's (CCN) general concerns regarding the proposed measures. 

General points

CCN did not consider any of the proposed management options to be sufficient or proportionate to meet legal objective to protect PMFs, and felt that they are fundamentally unworkable. 

CCN queried why MS are only considering protection measures for 11 most sensitive PMFs, and felt that measures should be brought in collectively for all 81 PMFs.

CCN felt that it is insufficient to limit measures to existing scope of exercise, and felt MS need to broaden it further to bring in measures for greater environmental benefit.

Carbon sink; CCN felt that MS should additionally consider blue carbon value of some PMFs when applying protection, and also be aware that the act of dredging moves sediment and releases CO2 into atmosphere. 

CCN felt that it is entirely reasonable to expect fishers to adapt/change industry to suit the modern situation given the current pressures facing marine biodiversity. 

CCN felt that MS should be visiting members of their network around Scotland, as we have been doing for the Regional Inshore Fisheries Groups (RIFGs).

CCN requested that MS share maps of proposed management areas with network and give opportunity for environmental groups to offer feedback.

Action:

• MS to consider sharing maps of proposed management areas, with PMF data, with all stakeholders who attended workshop in October   

CCN questioned the anticipated status of the 11 PMFs in question following each of the management options shared at the workshop in October.

CCN were concerned that there is insufficient data to properly reflect the extent of the 11 PMFs, and given legal obligation of MS to protect features, suggested that we apply the precautionary principle and apply additional management/protection for features.

CCN expressed concern that none of the options provided to date will allow us to meet General Policy 9 of the National Marine Plan on Natural heritage, which states that development and use of the marine environment must not result in significant impact on the national status of Priority Marine Features.

CCN requested that MS share SNH advice on the national status of PMFs in relation to the proposed management options in advance of public consultation, and suggest they will submit Freedom Of Information (or Environmental Information Regulations) to request for information if MS do not voluntarily share. 

Action:

• MS to investigate if/when we can release SNH advice for PMFs in relation to each proposed option

CCN felt that option 1 will be insufficient from the outset due to exclusion of records (e.g. northern sea fan). 

Action:

• MS to discuss suggestion of excluded northern sea fan records, in relation to Option 1, with SNH

CCN felt that burden of proof should be put onto fishing industry, so that industry proves absence of PMFs rather than environmentalists proving their presence.

CCN proposed implementation of 3 mile exclusion limit for mobile bottom-contacting gear, and highlight that the Scottish Creel Fishermen’s Federation suggest that whitefish stocks have been decimated and may be beyond recovery even using this measure.  

MS stated that the 3 mile limit had been ruled out at the scoping stage and was not being considered.

MS highlighted that whilst the proposed options 2 & 3 provide a more precautionary approach, they both cover east coast which doesn’t have any PMF records and this may present challenges. 

CCN suggested Scottish Government should provide financial and logistical support to affected fishers to make transition to alternative industries by helping to modernise or make transition to mitigate impact of measures.

CCN question where REM vessel tracking will stand up in court.

Action:

• MS to get further details on REM vessel tracking from sea fisheries policy colleagues to understand how evidence will support prosecution following fishing infractions, and report back to CCN

CCN queried use of buffers around PMF records. 

SNH to confirm buffers for PMF records, inc. depth variance, for CCN.

CCN believed that most other countries are ahead of Scotland in terms of their marine protection, and suggest MS replicate Norway model for applying management measures and preventing gear conflict.

CCN felt ecosystem services should be included in the Socioeconomic Impact Assessment (SEIA) to provide a balanced picture of gains against losses in economic analysis. MS recognised that it would be preferable to include this and confirmed that work is underway to address this shortfall to move away from qualitative analysis of ecosystem services and move toward quantifiable analysis in future projects, but highlighted that unfortunately this revised assessment is unlikely to be available for this process.

CCN said that the benefits of ecosystem services have been poorly described in the Consultation Document.

Action:

• MS to consider increasing detail on ecosystem services within final consultation document

CCN highlighted a report which has been prepared to provide a quantifiable analysis of economic benefits arising from on marine tourism; “Awaking the Giant” by Visit Scotland. The associated “Giant Strides” consultation is currently open, requesting input on Visit Scotland’s 5 year plan for Marine Tourism, and closes on Friday 17 January 2020. This is reported to suggest that marine tourism brings in annual income to the Argyll region of approx. £26M, vs. £13M from fishing industry. 

CCN asked when a report on impact of phase 1 MPA management measures will be publicised. MS highlight that report is expected to become available internally in near future, and will investigate when it will be made publically available. 

Action:

• MS to find out when report on Phase 1 MPA management measures will be made publically available and report back to CCN

CCN highlighted Options 2 & 3 don’t include management measures within MPAs – meaning that management is not in place within MPA to protect PMFs unless they are a feature of the site.

Giving an example of the above, CNN felt that is doesn’t make sense to allow dredging around Northern Sea Fan records in the Small Isles MPA, as is permitted within current management measures.

MS highlighted that maps for Phase 2 MPA management proposals have been updated since the workshop held in October 2019, and that these will be released with consultation. 

CCN expressed concern about displacement activity Loch Eishort. 

CCN felt that drop down video surveys are not an appropriate tool for surveying some species, and believed that large areas are data deficient. They believed we need more SeaSearch dive surveys, particularly for features offshore, and should take a precautionary principle to protect greater areas given the absence of data in some areas.

CCN highlighted that the figure of 30% seas protected by MPA is only sufficient if management and appropriate enforcement is in place.

CCN felt that measures with higher socioeconomic impacts would lead to the greatest improvement of fish stocks for fishers by protecting resource, habitat and increasing marine tourisms, and called for pragmatic thinking to protect the environment and the future of industry.

CCN highlighted that SG have commissioned a trial to explore alternative marine industries to fishing, e.g. seaweed harvesting from ropes. 

CCN felt that more emphasis should be placed on long term benefits rather than short term negative impacts of proposed management. 

CCN conceded that some measures are better than no measures whatsoever, but suggested they may to create a media and social media campaign to damage reputation of Marine Scotland should we proceed with Option 1, as they feel it is wholly insufficient.

CCN also suggested that if MS wishes to avoid a damaging publicity campaign coordinated by CCN, MS needs to get all interested stakeholders round the table to negotiate a proposal of management measures that all parties are content with. 

CCN requested that future reports not only reflect negative economic impact of measures, but also an approximation of the number of people that measures will directly and indirectly impact (as they feel it will be low number). 

MS invited CCN to suggest alternative measures which meet conservation objectives in areas where positive records exist (and exclude areas where null records exist).

Action:

• MS to investigate Firth of Lorne and South Arran MPA case studies

Action point summary 

• MS to consider sharing maps of proposed management areas, with PMF data, with all stakeholders who attended workshop in October
• MS to investigate if/when we can release SNH advice for PMFs in relation to each proposed option
• MS to discuss suggestion of excluded northern sea fan records, in relation to Option 1, with SNH
• MS to get further details on REM vessel tracking from sea fisheries policy colleagues to understand how evidence will support persecution following fishing infractions, and report back to CCN
• SNH to confirm buffers for PMF records, inc. depth variance, for CCN
• MS to consider increasing detail on ecosystem services within final consultation document
• MS to find out when report on Phase 1 MPA management measures will be made publically available and report back to CCN
• MS to investigate Firth of Lorne and South Arran MPA case studies