Planning Scotland's Seas: Possible Nature Conservation Marine Protected Areas. Consultation Analysis Report

Executive Summary

Background overview

Planning Scotland's Seas: Possible Nature Conservation Marine Protected Areas' was published for consultation in July 2013 setting out proposals for a number of new Marine Protected Areas ( MPAs).

The consultation ran from 25th July 2013 until 13th November 2013; respondents were invited to submit their opinions and views about the development of the MPA network and on the specific planned MPAs.

Overview of respondents

The consultation attracted 14,703 responses. This included 332 standard consultation responses (216 from individuals and 116 from organisations) and 14,371 submissions from the 11 campaign texts promoted by various organisations, briefly:

• Three relating to protection for seabirds attracting 1,626 responses.
• Three relating to protection for whales and dolphins attracting 6,627 responses.
• Three in support of the MPA network attracting 4,803 responses.
• Two supporting the South Arran possible MPA attracting 1,315 responses.

Overview of analysis

The consultation posed a series of questions on the network as a whole, the Sustainability Appraisal and the individual possible Marine Protected Areas (p MPAs).

The standard consultation responses were examined and key themes, which are similar issues raised in a number of responses, were identified at each question. Sub-themes; including reasons for opinions, supporting arguments, alternative suggestions or other related comments; were also noted. The key themes were then examined to identify whether any particular theme was specific to any particular respondent group or groups; for example was the theme more prominent in responses from individuals or from any organisational sub-group.

Overview of responses

The following paragraphs highlight the main themes that emerged in responses to the consultation.

MPA Network

There was support for an MPA network from almost all respondents, both campaign and standard. Many respondents stressed the need for protection for the marine environment.

Many respondents wanted to see the network offer protection for more species. Seabirds, whales and dolphins were mentioned most often in this regard.

There were comments on the need for designations to be based on scientific advice and up to date data and that the network and individual MPAs would need to be supported by robust and effective management.

Small numbers of respondents expressed some concerns. These related primarily to:

• the need to ensure that any management options are consulted and agreed before designation;
• the need to ensure that management options do not cause any adverse socioeconomic effects on local communities;
• that management options should take account of the need for energy provision;
• that more of the objectives should be set to recover rather than conserve;
• that there should be more species added to the protected features;
• the need for more MPAs or for MPAs to cover a wider area; conversely there was a smaller concern from others that the p MPAs will cover too large an area;
• and the need for fish production to be allowed to continue and develop in appropriate areas.

Proposed MPAs

The individual p MPA sections of the consultation attracted varying responses in terms of numbers and depth.

The designation and management options for all of the p MPAs were supported by most of those who commented.

Clyde Sea Sill: There were requests to include the kelp forest and other seabird species. Several respondents pointed out that data used for species count is up to 15 years out of date and wanted to see this addressed. A few respondents, across various organisational groups, felt that designation would be beneficial to the area.

East Caithness Cliffs: There were requests to include the kelp forest and other seabird species. Several respondents pointed out that data used for species count is up to 15 years out of date and wanted to see this addressed. There was welcome for the alignment of this p MPA with the existing SPA in the same area.

East of Gannet and Montrose Fields: A small number of respondents commented on the importance of the ocean quahog and offshore deep sea mud and gravel communities.

Faroe-Shetland Sponge Belt: While there was support for designation and for the management options, a number of respondents would support a smaller area. There were differences in opinion between sectors (particularly environment and fishing) over restrictions on fishing in the area.

Fetlar to Haroldswick: There were requests to include other seabird species. There were calls for the objective for horse mussel beds, maerl beds, and kelp and seaweed communities to be recover rather than conserve. A small number commented that they would like to see those involved in fishing the area are consulted over the plans for reducing or limiting pressures from any fishing activity.

Hatton-Rockall Basin: A very small number commented and supported the designation and management options.

Loch Creran: There were few comments on this site. A small number of respondents would prefer the objective of recover rather than conserve for the flame shell beds.

Loch Sunart: Some respondents would prefer the objective for the features, and especially the serpulid aggregations, to be recover rather than conserve. There were differences in opinion between sectors over restrictions on fishing in the area. Some commented on the need to involve local communities and all other stakeholders in the management of the MPA.

Loch Sunart to the Sound of Jura: There were several suggestions for changes including extending the area, reducing the area and adding various seabird species to the protected features. There were some differences in opinion between sectors over restrictions on fishing in the area. There were comments suggesting insufficient data, especially in relation to the common skate.

Loch Sween: Several respondents felt the objectives for the maerl beds and native oyster should be recover rather than conserve. There were calls for a more realistic assessment of fishing levels in the area and clarity over the likely levels of fishing restrictions. A small number asked for recreational anchorages to be reviewed to ensure these are not in the vicinity of maerl beds.

Loch Duich, Long and Alsh: Several of those who commented wanted to see the objective for burrowed mud set to recover rather than conserve. There were some calls to add fan mussels to the list of protected features, again set to recover.

Monach Isles: There were calls to include the kelp forests as a protected feature and a small number of comments that the designation would also benefit a range of other seabird species.

Mousa to Boddam: There were some suggestions that the boundary should change to include possible sandeel habitat beyond the proposed area. Some called for the objective for sandeels to be set as recover rather than conserve and for kelp forests to be protected. There were also calls for research into the impact of demersal dredge on sandeels.

North-east Faroe Shetland Channel: There were a number of comments on the importance of the area to the fishing industry with respondents asking for suitable monitoring and compliance of fishing activity as well as engagement with the industry. There was some concern that there are no management options to protect the continental slope.

North-west Orkney: Several of those who commented on this site called for the objective for sandeels to be set to recover rather than conserve. Most supported the proposal to limit any future sandeel fishery in the area.

North-west sea lochs and the Summer Isles: There were conflicting suggestions with some respondents wanting to see the area extended while others felt it should be reduced. There were calls to add seagrass beds and sea trout to the protected features. Some suggested the area should be called Wester Ross to give a clear local identity, foster local interest and give a greater sense of local ownership.

Noss Head: There was broad support for the designation and the management options for this p MPA.

Papa Westray: There were requests to include the kelp forest and other seabird species. A small number commented on the importance of the site for seabird and wildlife tourism and for anglers and divers.

Rosemary Bank Seamount: A small number commented; most supported the designation and the management options for this p MPA.

Small Isles: There were requests to include various marine mammal, shellfish and seabird species. There were some suggestions to extend the boundary to the coastline of Skye and to include the sea lochs of southern Skye and the sea areas around the Isle of Soay. Most of those who commented supported the management options and there were suggestions that measures should be set jointly for the p MPA and the SPA that it overlaps.

South Arran: There were many requests to include protection for seabirds. Many respondents asked for the boundary to extend around Arran and for bottom trawling and dredging to be prohibited in the area. These suggestions were opposed by fishing interests. There were calls for the objectives for protected features in this and the other Clyde p MPAs to be set to recover rather than conserve. Fishing interests disputed the basis for designating the protected features.

The Barra Fan and Hebrides Terrace Seamount: This area was described by several respondents as important or significant due to the effect of the seamount on underwater currents. Some respondents wanted to see changes to the boundary, stressing the importance of the area for fishing interests.

Turbot Bank: Several of those who commented on this site wanted the objective for sandeels to be set as recover rather than conserve. Respondents, from the environment/conservation and static fishing groups, listed both economic and wellbeing benefits from designating this area.

Upper Loch Fyne and Loch Goil: There were several calls for additional protected features and for all protected features in this area as recover rather than conserve. There were many suggestions and some requests for clarification with regards the management options.

West Shetland Shelf: A very small number commented on this p MPA and the comments made by the largest number was support for the designation and management options.

Wyre and Rousay Sounds: A small number of respondents commented on the impact of or on existing and proposed finfish farms in the area. There were also several comments on the importance of the maerl beds.

Alternative choices

For certain features there are options and alternatives to represent them in the network and respondents were asked their opinion on three areas where alternatives were possible.

Offshore subtidal sands and gravels, ocean quahog and shelf banks and mounds: There was a large support for the Firth of Forth Banks Complex. The main reason for this support was the importance of the area for sandeels. In addition, several respondents commented that the alternatives would not constitute an ecologically equivalent contribution to the network.

Burrowed mud feature in the Fladens: There was a large support for the Central Fladen only option. Respondents felt this would be the best way to protect the tall sea pen population.

Offshore subtidal sands and gravels, offshore deep sea mud, and burrowed mud: A very small number commented, most of whom supported the Geikie slide and Hebridean slope option.

Summary of key themes

The consultation attracted a large number of responses as well as a substantial number of campaign responses.

Overall, there was broad support for the possible Marine Protected Areas. At many of the p MPAs, however, respondents made suggestions for various changes to designation or management options.

There were a number of recurring themes including the following:

Many respondents felt that some species had been overlooked, mainly seabirds; whales; dolphins; and porpoises. There were comments that the proposed network would offer direct protection to only 39 of the 6,500 species and habitats in Scotland's seas. Some respondents considered this would mean that the network was not ecologically coherent and therefore not meet the duty under the Marine Act as well as failing to meet international commitments.

The feeling that the network should protect more species was the main reason given by those who said that the proposed network is not complete or ecologically coherent.

A number of respondents talked about the need to look at cumulative socioeconomic effects of the network as well as effects in each p MPA.

A few respondents expressed concerns over conflicts between Government targets for renewables and its goals for the marine environment. A small number asked for clarification and more certainty over the interaction of MPAs with existing and proposed installations and assets, for example pipelines and cables for oil and gas.

A small number voiced concern over economic impacts to international and national fishing fleets from the proposals and suggested alterations that would still meet environmental objectives. There were comments that any impact on mobile fishing would have consequences for both individual concerns and on coastal communities as well as for food security.

While many respondents supported a ban on bottom dredging and trawling others commented that these methods have been in use for many years without evidence that it is damaging the environment.

A small number commented on the number of p MPAs and the size of the proposed areas and suggested smaller more localised areas would be more appropriate, targeting more specifically the habitats and species designated for protection.

Several respondents supported the designation of the Skye to Mull search.

There was a degree of concern over a perceived lack of regard to both legislative and policy frameworks which, some said, had led them to be unable to support many of the proposals. Respondents felt that these had not been adhered to in relation to network design, OSPAR obligations and replication in particular.

Several respondents commented on the need for more data and for all decisions to be science-led and based on up to date, verified data. Others requested that the quality and use of evidence to underpin the scientific recommendations be externally reviewed.

Robust management and involving all stakeholders, in particular local communities, in managing MPAs was seen as important.