Planning Scotland's Seas: 2013 - The Scottish Marine Protected Area Project – Developing the Evidence Base for Impact Assessments and the Sustainability Appraisal Final Report - Appendix E - Marine Site Reports
This is Appendix E for the pMPA Impact and Sustainability Report containing the detailed site by site reports. Published separately due to size.
Part 1. Inshore Sites
Clyde Sea Sill ( CSS)
Site Area (km 2): 714
Site Summary
Table 1. Summary of Proposed Protected Features, Data Confidence and Conservation Objectives | [ CSS] | ||||
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Proposed protected features | |||||
Biodiversity Features Black guillemot, fronts, circalittoral sand and coarse sediment communities. Geodiversity Features Marine Geomorphology of the Scottish Shelf Seabed - sand banks, sand ribbon fields, sand wave fields. Site Description The Clyde Sea Sill MPA proposal stretches across the mouth of the Clyde Sea on the west of Scotland. The proposal runs from the Mull of Kintyre to Corsewall Point on the Rhinns of Galloway. |
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Summary of confidence in presence, extent and condition of proposed protected features and conservation objectives | |||||
Proposed Protected Feature | Estimated Area of Feature (by scenario) (km 2) | Confidence in Feature Presence |
Confidence in Feature Extent |
Confidence in Feature Condition |
Conservation Objective and Risk |
Biodiversity Features | |||||
Black guillemot | *Lower: 29.05 Intermediate: 29.05 Upper: 29.05 |
Yes (Seabird 2000 census) | Yes | Not known | Conserve |
Fronts | Lower: 713.30 Intermediate: 713.30 Upper: 713.30 |
Yes (Ocean thermal imagery, 2000 - 2009) | Yes | Not known | Conserve |
Circalittoral sand and coarse sediment communities | Lower: 528.31 Intermediate: 528.31 Upper: 528.31 |
Yes (Marine Scotland surveys, 2012) | Yes | Not known | Conserve |
Geodiversity Features | |||||
Marine Geomorphology of the Scottish Shelf Seabed - sand banks, sand ribbon fields, sand wave fields | Sand Bank: 4.99 Sand Ribbon Field: 34.06 Sand Wave Field: 146.08 |
Yes (Defra research, 2009; SNH & JNCC review, 2012) | Yes | Not known | Conserve |
Key: * Estimated area based on best available data References: Area of Feature: GeMs Confidence in feature presence and extent: SNH (2012a) |
Summary of Costs and Benefits
Table 2a. Site-Specific Economic Costs on Human Activities arising from the Designation and Management of the Site as an MPA (present value of total costs over 2014 to 2033 inclusive) | [ CSS] | ||
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Human Activity | Cost Impact on Activity | ||
Lower Estimate (£Million) | Intermediate Estimate (£Million) | Upper Estimate (£Million) | |
Quantified Economic Costs (Discounted) | |||
Commercial Fisheries* | 0.000 | 1.616 | 3.232 |
Energy Generation | 0.011 | 0.022 | 0.022 |
Military | See national costs | See national costs | See national costs |
Telecom Cables | 0.007 | 0.007 | 0.007 |
Total Quantified Economic Costs | 0.018 | 1.645 | 3.261 |
Non-Quantified Economic Costs | |||
Commercial Fisheries |
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Energy Generation |
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Military |
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Telecom Cables |
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Note: For detailed information on economic cost impacts on activities, see Table 4. * These estimates (present value of total change in GVA) assume zero displacement of fishing activity and hence are likely to overestimate the costs. |
Table 2b. Site-Specific Public Sector Costs arising from the Designation and Management of the Site as an MPA (over 2014 to 2033 inclusive) | [ CSS] | ||
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Description | Public Sector Costs | ||
Lower Estimate (£Million) | Intermediate Estimate (£Million) | Upper Estimate (£Million) | |
Quantified Public Sector Costs (Discounted) | |||
Preparation of Marine Management Schemes | None | None | None |
Preparation of Statutory Instruments | None | 0.041 | 0.045 |
Development of voluntary measures | National assessment | National assessment | National assessment |
Site monitoring | National assessment | National assessment | National assessment |
Compliance and enforcement | National assessment | National assessment | National assessment |
Promotion of public understanding | National assessment | National assessment | National assessment |
Regulatory and advisory costs associated with licensing decisions | 0.002 | 0.003 | 0.003 |
Total Quantified Public Sector Costs | 0.002 | 0.044 | 0.048 |
Non-Quantified Public Sector Costs | |||
None identified. |
Table 2c. Summary of Social Impacts and Distribution of Quantified Impacts arising from the Designation and Management of the Site as an MPA (over 2014 to 2033 inclusive) | [ CSS] | |||||||||
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Key Areas of Social Impact | Description | Scale of Expected Impact across Scenarios, Average (mean no. of jobs affected) | Distributional Analysis | |||||||
Location | Fishing Groups Predominantly Affected | Social Groups Affected | ||||||||
Region | Port | Rural/ Urban/ Island | Gear Types Most Affected | Vessels most affected | Crofters | Ethnic minorities | With disability or long term sick | |||
Employment with consequent impacts on: Health, Crime, Environment, and Culture and Heritage | Commercial fisheries - Loss of jobs (direct and indirect) | Lower: 0 jobs Intermediate: 3 jobs Upper: 5 jobs |
West West N. Ireland West |
Ayr Campbeltown Belfast Oban |
Impacts concentrated in urban and rural coastal areas | Nephrops trawls Dredges |
Lower: N/A Upper: <15m |
No Impact. | No breakdown of fisherman employment by ethnic origin. | No employment data but unlikely to be employed in fisheries.. |
If any energy generation developments do not proceed as a result of designation (due to additional costs, project delays, loss of investor confidence), there may be significant social impacts due to job losses (non-quantified). | ||||||||||
Note: For detailed information on socio-economic impacts by sector, see Table 7a. For more detailed information on distributional impacts of quantified costs by sector see Tables 7b and 7c. |
Table 2d. Site-Specific Benefits arising from the Designation and Management of the Site as an MPA (over 2014 to 2033 inclusive) | [ CSS] | |
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Benefit | Description | |
Ecosystem Services Benefits (Moderate and High Benefits) | Relevance | Scale of Benefits |
Non-use value of natural environment | Low - Moderate. Wrecks and the protected features, and a contribution of the site to MPA network, has non-use values. | Low - Moderate |
Other Benefits | ||
Tourism | Higher biodiversity due to designation, and presence of designations, may attract more tourism activity to local economy. | |
Contribution to ecologically coherent network | See report Section 7.5. | |
Note: For detailed information on ecosystem services benefits, see Tables 9 and 10. For detailed information on other benefits, see Table 5 (activities that would benefit) and Table 8 (contribution to ecologically-coherent network). |
Summary of Overlaps and Interactions between Proposed Designated Features and Human Activities
Table 3. Overlaps and Potential Interactions between Features and Activities under different Scenarios, indicating need for Assessment of Cost Impacts on Human Activities from Designation of the Site as an MPA | [ CSS] | ||||||||||||||||
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Aggregates | Aquaculture (Finfish) | Aquaculture (Shellfish) | Aviation | Carbon Capture & Storage | Coastal Protection | Commercial Fisheries | Energy Generation | Military Activities | Oil & Gas | Ports & Harbours | Power Interconnectors | Recreational Boating | Shipping | Telecom Cables | Tourism | Water Sports | |
Biodiversity Features | |||||||||||||||||
Black guillemot | - | - | - | - | - | - | L/I/U | L/ I/ U | L/I/U | U | U | U | L/I/U | - | L/I/U | L/I/U | L/I/U |
Circalittoral sand and coarse sediment communities | - | - | - | - | - | - | L/ I/ U | L/I/U | L/I/U | L/I/U | - | L/I/U | L/I/U | - | L/I/U | L/I/U | L/I/U |
Fronts | - | - | - | - | - | - | L/I/U | L/I/U | L/I/U | L/I/U | L/I/U | L/I/U | L/I/U | - | L/I/U | L/I/U | L/I/U |
Geodiversity Features | |||||||||||||||||
Marine Geomorphology of the Scottish Shelf Seabed - sand banks | Not considered to be sensitive at the levels of exposure expected from human activities; thus, not considered in the context of management. | ||||||||||||||||
Marine Geomorphology of the Scottish Shelf Seabed - sand ribbon fields | |||||||||||||||||
Marine Geomorphology of the Scottish Shelf Seabed - sand wave fields | |||||||||||||||||
Note: L = Lower Scenario; I = Intermediate Scenario; U = Upper Scenario. Normal font indicates that there is an overlap between the activity and proposed designated feature under that scenario, bold indicates that the overlap results in a potential interaction between the activity and proposed designated feature that has resulted in cost impacts under that scenario. For detail of management measures assessed under each scenario for each activity, and results of the cost estimates, see Table 4. |
Human Activity Summaries
Human activities that would be impacted by designation of the site as an MPA
Table 4a. Commercial Fisheries (assuming zero displacement of fishing activity) | [ CSS] | ||
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According to VMS-based estimates and ICES rectangle landings statistics, Nephrops trawls, dredges, pelagic trawls, whitefish trawls and seines (over-15m) and nephrops trawls, pots, dredges and other gear (under-15m vessels) operate within the CSS proposed MPA. The value of catches from the CSS area was £398,000 (over-15m vessels) and £476,000 (under-15m vessels, indicated from ICES rectangle landings data) (annual average for 2007-2011, 2012 prices). Landings from the over-15m vessels were made predominantly into Campbeltown (48%), Portavogie (16%), Ardglass (9%), Girvan (8%) and Troon and Saltcoats (7%). For the over-15m fleet, dredgers operated in particular in the northern part of the proposed MPA across the area of circalittoral sand and coarse sediment, while nephrops trawlers operated mainly in the south-west part of the proposed MPA outside of this area of sediment. Provisional ScotMap data indicate that the annual average earnings from the CSS proposed MPA was £105,000, with over 40% from pots (velvet crab, brown crab and lobster), over 30% from dredges, and over 25% from Nephrops trawls. The spatial distribution of value from Nephrops trawls indicates that the majority of value is derived from further north than the CSS proposed MPA area in the Firth of Clyde. It is likely that the ICES rectangle estimate for the cost impact on <15m Nephrops trawls is an over-estimate. The coverage for ScotMap interviews in the region was 63.8% (total value of reported landings from the Fisheries Information Network for those vessels included in the ScotMap value analysis expressed as a percentage of the total reported landings for all vessels <15m). Therefore the ScotMap estimate is likely to under-represent the value of fishing by under-15m vessels, and the spatial representation of the value of fishing is less robust than in regions where coverage is higher. VMS data indicated that there are no foreign vessels fishing within the CSS proposed MPA. Management measures for the scenarios have been developed based on the sensitivity and vulnerability of the features to the pressures caused by different gear types and SNH recommendations. Unlike most other sectors, the potential cost of designation on commercial fisheries is a loss or displacement of current (and future) output, caused by restrictions on fishing activities. Any decrease in output will, all else being equal, reduce the Gross Value Added ( GVA) generated by the sector and have knock-on effects on the GVA generated by those industries that supply commercial fishing vessels. The costs estimates for this sector have therefore been estimated in terms of GVA. GVA estimates have been generated by applying fleet segment-specific ' GVA/total income' ratios to the value of landings affected. The GVA ratios have been calculated using data on total income and GVA from the Sea Fish Industry Authority Multi-year Fleet Economic Performance Dataset (published March 2013). Further details on the GVA ratios and the methodology for estimating GVA and employment impacts applied are presented in Appendix C7. It is important to note that all costs presented below assume that all affected landings are lost, that is, there is no displacement of fishing activity to alternative fishing grounds. In reality, some displacement is likely to occur and hence the cost, GVA and employment impacts presented in this table are likely to overestimate the costs. |
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Economic Costs on the Activity of Designation of the Site as an MPA | |||
Lower Estimate | Intermediate Estimate | Upper Estimate | |
Assumptions for cost impacts |
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Description of one-off costs |
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Description of recurring costs |
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Description of non-quantified costs |
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Quantified Costs on the Activity of Designation of the Site as an MPA (£Million) | |||
Total costs (2014-2033) | 0.000 | 4.523 | 9.046 |
Average annual costs | 0.000 | 0.226 | 0.452 |
Present value of total costs (2014-2033) | 0.000 | 3.327 | 6.653 |
Economic Impacts (£Million) | |||
Total change in GVA (2014-2033) | 0.000 | 2.197 | 4.394 |
Average annual change to GVA | 0.000 | 0.110 | 0.220 |
Present value of total change in GVA (2014-2033) | 0.000 | 1.616 | 3.232 |
Direct and Indirect reduction in Employment | 0.0 jobs | 2.6 jobs | 5.2 jobs |
Total costs = Sum of one-off costs and recurring costs for the site summed over the 20 year period. Average annual costs = Total costs divided by the total number of years under analysis ( i.e. 20). Present value of total costs = Total costs discounted to their current value, using a discount rate of 3.5%. Total change in GVA (2014-2033) = The change in direct GVA in the sector for the site summed over the 20 year period. Average annual change to GVA = Total change in direct GVA in the sector for the site divided by the total number of years under analysis ( i.e. 20). Present value of total change in GVA (2014-2033) = Total change in direct GVA in the sector for the site discounted to current value, using a discount rate of 3.5%. Direct and Indirect reduction in Employment = The average (mean) reduction in direct employment in the sector plus the indirect reduction in employment on the sector's suppliers. |
Table 4b. Energy Generation | [ CSS] | ||
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There are no energy generation activities currently operating within the CSS proposed MPA boundary or corresponding buffer zones. Thus, economic costs and management measures associated with energy generation in this proposed MPA are described in light of known possible future developments. The Sanda Sound (Oceanflow Energy, 35kW (nominal)) tidal energy project is a ¼ scale testing device in preparation for a larger scale future development. The development, planned for deployment in 2013, overlaps the MPA features 'black guillemot' and 'fronts' under all scenarios ( i.e. lower, intermediate and upper extent), with further extensive overlap observed through consideration of a 5km buffer (also overlapping the MPA feature 'circalittoral sand and coarse sediment communities'). Nevertheless, any associated costs of the Sanda Sound tidal development are considered sunk as the application process (agreement reached for lease, test device currently undergoing checks) has the potential to reach a conclusion prior to 2014. Within the CSS proposed MPA boundary, the 5km buffer zone of the possible Argyll Mull of Kintyre Tidal Array (Nautricity Ltd and Argyll Tidal Ltd, potential 3MW capacity in total) overlaps MPA features 'circalittoral sand and coarse sediment communities' and 'fronts' under all scenarios. The MPA feature 'black guillemot' also overlaps the 5km buffer for the potential Argyll Tidal Array development, but only under the upper scenario. An export cable route for the Argyll Mull of Kintyre Tidal Array will potentially pass through the CSS proposed MPA boundary, overlapping all three previously mentioned MPA features under all extent scenarios. Sanda Island SSSI is notified for black guillemots and extends to MLWS. Main breeding colonies within the CSS proposed MPA boundary are already managed through SSSI designation. Given the medium sensitivity of black guillemot to death or injury by collision, barriers to species movement, sub-surface abrasion/penetration and changes in water flow (tidal current), there may be additional management costs incurred. |
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Economic Costs on the Activity of Designation of the Site as an MPA | |||
Lower Estimate | Intermediate Estimate | Upper Estimate | |
Assumptions for cost impacts |
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Description of one-off costs |
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Description of recurring costs |
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Description of non-quantified costs |
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Quantified Costs on the Activity of Designation of the Site as an MPA (£Million) | |||
Total costs (2014-2033) | 0.012 | 0.024 | 0.024 |
Average annual costs | 0.001 | 0.001 | 0.001 |
Present value of total costs (2014-2033) | 0.011 | 0.022 | 0.022 |
Total costs = Sum of one-off costs and recurring costs for the site summed over the 20 year period. Average annual costs = Total costs divided by the total number of years under analysis ( i.e. 20). Present value of total costs = Total costs discounted to their current value, using a discount rate of 3.5%. |
Table 4c. Military | [ CSS] | ||
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18 military practice areas (Luce Bay (D402A; bombing), Campbeltown (D509), Campbeltown South (X556; minelaying), Mermaid (X5529), Sanda (X5530), Stafnish (X5523), Ailsa (X5524), Ballantrae (X5525) and Corsewall (X5526); five submarine exercise areas and four firing danger areas) overlap with the CSS proposed MPA. The military practice areas Luce Bay (D402A; bombing), Campbeltown (D509), Campbeltown South (X556; minelaying), Mermaid (X5529), Sanda (X5530), Stafnish (X5523), Ailsa (X5524), Ballantrae (X5525) and Corsewall (X5526) overlap with circalittoral sand and coarse sediment communities (all scenarios), fronts (all scenarios) and Black Guillemot (upper scenario only). Sanda (X5530) and Stafnish (X5523) also overlap with Black Guillemot under all scenarios. The five submarine exercise areas and four firing danger areas overlap with the features of the CSS proposed MPA to varying degrees under the different extent scenarios. The features and associated habitats which overlap with military activities have not been described as vulnerable to MOD activities in this proposed MPA. It is assumed that management relating to MOD activity will be coordinated through the MOD's Maritime Environmental Sustainability Appraisal Tool ( MESAT) which the MOD uses to assist in meeting its environmental obligations. This process will include operational guidance to reduce significant impacts of military activities on MPAs. It is assumed that the MoD will incur additional costs in adjusting MESAT and other MoD environmental assessment tools in order to consider whether its activities will impact on the conservation objectives of MPAs and also incur additional costs in adjusting electronic charts to consider MPAs. However, these costs will be incurred at national level and hence no site-specific cost assessments have been made. |
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Economic Costs on the Activity of Designation of the Site as an MPA | |||
Lower Estimate | Intermediate Estimate | Upper Estimate | |
Assumptions for cost impacts |
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Description of one-off costs | |||
Description of recurring costs | |||
Description of non-quantified costs | |||
Quantified Costs on the Activity of Designation of the Site as an MPA (£Million) | |||
Total costs (2014-2033) | See national costs | See national costs | See national costs |
Average annual costs | See national costs | See national costs | See national costs |
Present value of total costs (2014-2033) | See national costs | See national costs | See national costs |
Total costs = Sum of one-off costs and recurring costs for the site summed over the 20 year period. Average annual costs = Total costs divided by the total number of years under analysis ( i.e. 20). Present value of total costs = Total costs discounted to their current value, using a discount rate of 3.5%. |
Table 4d. Telecom Cables | [ CSS] | ||
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Three telecom cables overlap with the CSS proposed MPA boundary; Lanis 3 for a distance of 19.5km, Scotland-N.Ireland 2 for a distance of 19.4km and Sirius North for a distance of 18.6km. All three telecom cables overlap with circalittoral sand and coarse sediment communities (all scenarios), fronts (all scenarios) and Black Guillemot (upper scenario only). The possible cost associated with replacement of existing telecom cables at the end of their working life is provided. | |||
Economic Costs on the Activity of Designation of the Site as an MPA | |||
Lower Estimate | Intermediate Estimate | Upper Estimate | |
Assumptions for cost impacts |
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Description of one-off costs |
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Description of recurring costs |
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Description of non-quantified costs |
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Quantified Costs on the Activity of Designation of the Site as an MPA (£Million) | |||
Total costs (2014-2033) | 0.010 | 0.010 | 0.010 |
Average annual costs | 0.001 | 0.001 | 0.001 |
Present value of total costs (2014-2033) | 0.007 | 0.007 | 0.007 |
Total costs = Sum of one-off costs and recurring costs for the site summed over the 20 year period. Average annual costs = Total costs divided by the total number of years under analysis ( i.e. 20). Present value of total costs = Total costs discounted to their current value, using a discount rate of 3.5%. |
Human activities that would benefit from designation of the site as an MPA
Human activities that are present but which would be unaffected by designation of the site as an MPA
Table 6. Human Activities that are Present but which would be Unaffected by Designation of the Site as an MPA [ CSS] | |
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Activity | Description |
Oil and Gas | There is one pipeline within the CSS proposed MPA boundary that overlaps with features proposed for designation; black guillemot, circalittoral sand and coarse sediment communities and fronts. The presence of the existing pipeline is not expected to require additional management measures. The designation of the MPA proposal would not lead to additional management for black guillemot above that of the Sanda Island SSSI. |
Recreational Boating | There are no recreational boating anchorages located within the CSS proposed MPA that overlap with features proposed for designation, although three Crown Estate mooring points are present that overlap with feature extents for black guillemot and fronts under all scenarios. Neither feature is considered sensitive to pressures associated with anchoring, however; therefore no cost impacts are expected. Seven cruising routes intersect the CSS proposed MPA; three with low traffic and four with medium traffic. It is not considered that cruising routes will incur any management or assessment costs. |
Ports and Harbours | There is one port/harbour (Southend) within the CSS proposed MPA boundary. Southend overlaps the MPA feature fronts under all scenarios; however, management costs are not expected to be incurred. |
Power Interconnectors | Two existing power interconnectors and one consented power interconnector (Western HVDC Link) overlap with the CSS proposed MPA. Both existing power interconnectors and the one consented power interconnector overlap with circalittoral sand and coarse sediment communities (all scenarios), fronts (all scenarios) and Black Guillemot (upper scenario). No cost impacts are foreseen, as it is assumed that there will be no review of the existing consents. |
Water Sports - Windsurfing | There is one popular windsurfing location (Southend) within the CSS proposed MPA. Water sports activities including windsurfing are assessed as not requiring any additional management measures. It is also considered that no additional benefit to windsurfing from management measures applied to other activities will occur. |
Social and Distributional Analysis of Impacts from Designation of the Site as an MPA
Potential Contribution of the Site to an Ecologically-Coherent Network
Table 8. Overview of Features Proposed for Designation and how these contribute to an Ecologically Coherent Network of MPAs | [ CSS] | ||||
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Feature Name | Representation | Replication | Linkages | Geographic Range and Variation |
Resilience |
Black guillemot | Provides representation of the southern limit for black guillemot in OSPAR Region III. | Represents one of six potential MPA areas that will protect black guillemot in Scotland's seas. | Will be reviewed in light of Northern Ireland proposals to determine connectivity with wider MPA network. | Represents the southern limit of the species' range in the UK and provides a link with the population in Northern Ireland. | Not listed as threatened and/or declining on OSPAR list, although there is evidence to suggest declines in Scottish seas. MPA may increase resilience. |
Fronts | Provides representation for a topographic and density-driven front in OSPAR Region III. | Represents one of three potential MPA areas in OSPAR Regions II and III covering shelf seas. Replication is therefore provided in the network. | Not currently understood for fronts. | Each potential MPA is considered to cover functionally significant examples, reflecting different shelf fronts in a range of settings. | Not considered to be threatened and/or declining. No need to represent a greater proportion within MPA network. |
Circalittoral sand and coarse sediment communities | Information not available. | ||||
JNCC (pers. comm.); SNH and JNCC. (2012). Assessment of the potential adequacy of the Scottish MPA network for MPA search features: summary of the application of the stage 5 selection guidelines. Available online from: http://www.scotland.gov.uk/Topics/marine/marine-environment/mpanetwork/engagement/270612. |
Anticipated Benefits to Ecosystem Services
Table 9. Summary of Ecosystem Services Benefits arising from Designation of the Site as an MPA [1] | [ CSS] | |||||||
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Services | Relevance to Site |
Baseline Level | Estimated Impacts of Designation | Value Weighting | Scale of Benefits | Confidence | ||
Lower | Intermediate | Upper | ||||||
Fish for human consumption | Moderate. Habitats make contribution to food webs. | Stocks not at MSY | Nil | Low. Some recovery of benthic species possible. | High, site fishing grounds are valuable | Nil - Low | Moderate | |
Fish for non-human consumption | Stocks reduced from potential maximum | Nil | ||||||
Gas and climate regulation | Nil - Low | Nil - Low | Nil | Nil | Minimal | Moderate | Nil | High |
Natural hazard protection | Low | Low | Nil, would not affect stability of coastline | Moderate, Clyde is valuable for marine activities | Nil | High | ||
Regulation of pollution | Low | Low | Nil | Minimal - Low, maintained by protecting seabed features | Low - Moderate, for recreational use of waters | Nil - Low | High | |
Non-use value of natural environment | Low - Moderate. Wrecks and protected features, and contribution of the site to MPA network, have non-use value. | Non-use value of the site may decline | Nil, no change in key characteristics of site | Low - protection of key characteristics of site from minor decline | Moderate - protection of key characteristics of site from decline, and/or allowing some recovery of values | Moderate | Low - Moderate | Low |
Recreation | Moderate | 7 active dive sites, Sea angling | Nil | Low - slightly higher biodiversity encountered by divers | Moderate | Low | Moderate | |
Research and Education | Moderate | Biological and geological features have research value but there are substitutes | Nil, no change in key characteristics of site | Low - protection of key characteristics of site from decline, improving future research opportunities | Low | Nil - Low | Low | |
Total value of changes in ecosystem services | Low for lower scenario, moderate for upper scenarios | Low - Moderate | Low |
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