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

2 Non-Standard Responses

2.1 The consultation attracted a number of different response formats; where respondents used alternative questionnaires or submitted campaign text. In total 14,371 respondents submitted non-standard responses and these are outlined below.

Table 2.1

Non-standard responses (campaigns) overview

	Number
Protection for seabirds	1,626
Protection for whales and dolphins	6,627
Support for the MPA network	4,803
Support for the South Arran p MPA	1,315
Total	14,371

Campaigns relating to seabirds

2.2 There were three similar seabird campaigns resulting in a total of 1,626 submissions. The texts submitted by large numbers of respondents, in relation to seabirds, are set out below.

2.3 The following text was submitted by 1,611 respondents either by email or hard copy.

I fully support Marine Protected Areas ( MPAs) for seabirds but I'm disappointed that the Scottish Government's proposed network of MPAs fails to include feeding areas for the majority of Scotland's iconic seabird species.

Seabird populations have dramatically declined over the past three decades. Currently seabirds are only protected on land - they need MPAs to protect them, and their feeding areas, at sea. At the moment seabirds only have a safe place to starve.

The Firth of Forth is the most important site on our coastline for sandeels, which are an essential source of food for Scotland's seabirds. This site must be protected and so should others like it.

I support the MPAs proposed for black guillemot, and believe all other seabird species should have similar protection. The Scottish Government must take action now and designate MPAs for seabird feeding areas to help stop these declines before our cliffs fall silent.

2.4 There were also smaller instances of similar campaign texts being submitted; five respondents submitted a fuller version of the text relating to a lack of protection for seabirds and support for the Firth of Forth Complex p MPA. Ten respondents submitted a shorter version of this text.

2.5 In addition, many individuals (48) submitted extended versions of one of these campaign texts supporting the protection of black guillemots. These campaign plus responses ^[1] have been included in the count of standard consultation responses. These respondents commented that black guillemots are under threat and echoed the campaign text supporting the designation of the 6 p MPAs which include black guillemot: Clyde Sea Sill, East Caithness Cliffs, Fetlar-Haroldswick, Monach Isles, Papa Westray and the Small Isles. Many of these respondents also wanted to see protection for other seabirds in general. Some specified the species they would like to see protected and suggestions included common guillemot, gannet, puffin, razorbill, kittiwake, black-legged kittiwake, shearwater, skua, petrel and gulls.

Campaigns relating to whales and dolphins

2.6 Another subject that attracted campaign responses was protection for whales and dolphins. Submissions from 6,627 respondents included campaign text with a further 13 instances of campaign plus responses, responses based on the campaign text, calling for greater protection for whales, dolphins and porpoises.

2.7 The following text was submitted by 6,037 respondents.

Scotland's whales and dolphins need MPA protection!

I fully support a Scottish MPA network and what the government is proposing is a good first step. But a coherent MPA network must include sites for whales and dolphins.

Scotland has more whales and dolphins than anywhere else in northern Europe, but they haven't been included in the proposed MPA designations. WDC provided scientific evidence for whale and dolphin MPAs, with the support of more than 36,000 advocates.

Alongside those 29 MPAs proposed by the government's own nature conservation advisors, Scottish Natural Heritage ( SNH) and Joint Nature Conservation Committee ( JNCC), please designate MPAs for whales and dolphins without delay.

The MPA network must be built upon. More species and habitats must be protected by the network and clear evidence supports this need, including for harbour porpoises.

Thank you for developing an MPA network that we hope will be well managed and world-leading. I strongly advocate and support will spread and share the word on this so others may want to help support your positive support for the dolphin/whale habitat

2.8 There were 225 submissions of a proforma with the following text. In this case, respondents could add their own comments to the text and many included their support for MPAs or conservation for whales, dolphins and porpoises.

I fully support a Scottish Marine Protected Area ( MPA) network, and what the government is proposing is a good first step. But, a coherent MPA network must include sites for whales and dolphins.

Scotland has more whales and dolphins than anywhere else in northern Europe, but they haven't been included in the proposed MPA designations. WDC, Whale and Dolphin Conservation provided scientific evidence for whale and dolphin MPAs, with the support of more than 36,000 advocates.

Alongside those 29 MPAs proposed by the government's own nature conservation advisors, Scottish Natural Heritage ( SNH) and Joint Nature Conservation Committee ( JNCC), please designate MPAs for whales and dolphins without delay.

The MPA network must be built upon. More species and habitats must be protected by the network and clear evidence supports this need, including for harbour porpoises.

Thank you for developing an MPA network that we hope will be well managed and world-leading.

2.9 Another proforma on this subject also allowed respondents to add comments and many of the 365 who submitted this commented on their support for marine protected areas or conservation for wales, dolphins and porpoises.

Alongside those marine protected areas ( MPAs) proposed by Scottish Natural Heritage there is good evidence to immediately include whales, dolphins and porpoises, please designate MPAs for whales and dolphins without delay.

The MPA network must be built upon. More species and habitats must be protected by the network and clear evidence supports this need, including for harbour porpoises.

Effective management should restrict damaging activities in each MPA so that adequate protection and recovery is possible within and beyond the boundaries of the site.

I fully support a Scottish MPA network and what the government is proposing is a good first step. Thank you for developing an MPA network that we hope will be well managed and world-leading.

Campaigns relating to the MPA network

2.10 There were also campaign responses in relation to the network; 4,803 respondents submitted one of the following.

2.11 There were 2,615 submissions of the following text.

To whom it may concern,

I am writing in response to the Scottish Government consultation on Possible Nature Conservation Marine Protected Areas. From Scotland's Marine Atlas it is clear that the seas around Scotland are in turmoil, with concerns and declines over most of the seabed, declines in common seals, seabirds and sharks, skates and rays, and ongoing concerns with fish stocks in many areas. Within a system that puts the marine environment at the centre of marine planning, I believe a network of well-managed Marine Protected Areas is essential to help reverse these historic declines and enhance the many important benefits the sea provides us all.

In answer to question 1, I firmly support the development of an MPA network in Scotland's seas. Of the 33 MPA proposals in the consultation, I want to see at least the 29 ecologically best choice sites designated as nature conservation Marine Protected Areas in line with scientific advice.

In answer to question 28, the Firth of Forth Banks MPA proposal must go forward to best represent offshore subtidal sands and gravels, ocean quahog and shelf banks and mounds in the southern North Sea in line with JNCC advice. The other choices presented do not make the same contribution to wider North Sea ecosystem function, are not ecologically equivalent and therefore are not acceptable alternatives. Sandeels and seabirds should also be protected features at Firth of Forth Banks.

In answer to question 30, core Central Fladen must be protected in line with scientific advice and I support the 'Central Fladen p MPA only' option to be included in the network. This would be the most ecologically coherent option, providing scope for tall sea pen recovery beyond what may be a remnant population in 'core' Central Fladen.

In answer to question 34, I do have a comment on the Sustainability Appraisal. I believe the Sustainability Appraisal does not fully account for the socioeconomic benefits that could arise from the proposed MPA network. For example, a recent study revealed that recreational diving and angling in 20 of the proposed MPAs in Scotland is valued at between £67 million and £117 million per year. In addition, divers and anglers questioned said they would make a one-off payment collectively worth between £142-£255 million to see these sites protected and damaging activities stopped. Similar studies are needed to demonstrate the benefits of the Scottish MPAs to other user groups.

In answer to question 35, even if the best 29 sites and the remaining four search locations become MPAs as I would like, I still do not view this to be an ecologically coherent network. Other species in need of MPA protection - such as spiny lobsters, heart cockle aggregations and burrowing anemones - must be added to future iterations of the network. Further MPAs for common skate and nationally important MPAs for seabirds are also needed. I will only consider the network ecologically coherent when all species and habitats that can benefit from spatial protection are adequately represented and when robust science shows the network supports and enhances the ecological linkages between the different MPAs.

(continued)
In answer to question 36, I do have further comments. The Scottish Government has a legal obligation to enhance Scotland's seas and, according to international recommendations, the MPA network must support the wider marine environment. For each MPA, effective management must therefore be in place so that species and habitat recovery is possible both within and beyond the boundaries of the site. Zonal management that protects only the remnant extent of marine species and habitats, particularly of vulnerable benthic features, is not enough given the context of ecological decline documented in Scotland's Marine Atlas.

2.12 There were 662 submissions of the following text.

Recover our seas with Marine Protected Areas

In response to the Scottish Government's consultation on Marine Protected Areas questions 1, 28, 35 and 36:

I support the proposals for a network of Marine Protected Areas in Scotland's inshore and offshore waters, but believe more must be done to protect, connect and actively recover the health of our seas, which has suffered long-term decline over many generations.

Therefore, the Scottish Government must implement the ecologically best 29 Marine Protected Area proposals, as recommended by its own scientific advisors (Commissioned report no. 547 Advice to the Scottish Government on the selection of nature conservation Marine Protected Areas ( MPAs) for the development of the Scottish MPA network - http://www.snh.gov.uk/docs/A990246.pdf). Evidence suggests that the features within the Firth of Forth Banks Complex are of functional significance to the overall health and diversity of Scotland's seas more widely. The Firth of Forth Banks MPA therefore must be designated, because it is JNCC's preferred proposal and the suggested alternatives to the site do not make equivalent contributions to the network.I do not believe the proposed network to be ecologically coherent. I firmly urge the Scottish Government to extend the MPA proposals to protect vulnerable species excluded from the proposed network. There is already good evidence to support the immediate inclusion of whales, dolphins, basking sharks and nationally important populations of seabirds, such as puffins and kittiwakes. These - and those species already dropped from the proposals; spiny lobsters, heart cockle aggregations, burrowing anemones - must be added to the network. The network will only be ecologically coherent when all species and habitats that can benefit from spatial protection are adequately represented and when sound, properly-resourced science shows it to be based on the ecological linkages between the different MPAs.

International recommendations say a network of MPAs must interact and support the wider environment and the Scottish Government has a legal obligation to enhance Scotland's seas. For each MPA, the strongest and most effective management must be in place so that recovery is possible within and beyond the boundaries of the site. Zonal management that puts in place measures to protect only the remaining coverage of species and habitats is not enough, given the context of ecological decline documented by Scotland's Marine Atlas.

2.13 There were 1,526 submissions of the following text.

I care about the future of Scotland's seas and believe that the creation of a well-managed network of Marine Protected Areas ( MPAs) is vital so that we can continue to enjoy the many benefits of healthy marine ecosystems.

Please find my response below to questions 1, 28 and 35 of the MPA consultation:

1. I support the development of a network of MPAs in Scotland's seas. I believe the proposed Nature Conservation MPAs must be designated in line with scientific advice, and be supported by effective management that ensures the conservation and recovery of marine ecosystems.

28. The Firth of Forth Banks is unique and must be designated as a Nature Conservation MPA. The scientific advice clearly recommends the designation of this site over the alternative proposal of Turbot Bank and Norwegian Sediment Plain.

35. The network of MPAs as consulted on is not complete and the Scottish Government must commit to creating additional MPAs as soon as possible to protect species including basking shark, minke whale, white-beaked dolphin, Risso's dolphin, common skate and sites for birds at sea.

Campaigns relating to the South Arran p MPA

2.14 The South Arran p MPA also attracted campaign responses. Submissions from 1,315 respondents included campaign text.

2.15 One version of the campaign text supporting the South Arran p MPA attracted 726 responses.

I agree with the location and designation of the proposed South Arran Marine Protected Area as part of an ecologically coherent network of Clyde and Scottish MPAs. The area proposed around the South of Arran is a positive step forward and will help the sea bed and sea life to recover, but will only be effective if bottom trawling and dredging is prohibited from the whole area. In my view the MPA should extend all around Arran and be linked to Clyde-wide spatial and effort control measures designed to recover the health and productivity of the Clyde Sea. Black guillemot should be included as marine priority feature of the Arran MPA.

I support COAST's proposed management options and disagree with Scottish Natural Heritage's management recommendations. All bottom towed trawls, dredgers and hydraulic gear should be excluded from the entire proposed MPA not just from a few areas as SNH propose. This is vital if we are to conserve and recover the nature conservation features throughout the proposed MPA. Properly managed creeling, shellfish diving, and angling should be allowed.

A healthy and productive Clyde Sea is essential to the economy of coastal communities around the Clyde and the West of Scotland. Increased biodiversity and productivity will benefit commercial fishermen, recreational sea anglers and also tourism, which is the most important economic driver in the Clyde.

The Scottish Government has a legal obligation to achieve good environmental status in Scottish waters by 2020 and must be able to demonstrate a well-managed network of MPAs are in place by the end of 2016. MPAs should be regarded as integral to the achievement of healthy and productive seas and effective ecosystems management. It is not good enough to view them as simply a way of protecting a few 'relic' species and habitats. The Government needs to show that it is managing our seas for the benefit of everyone in Scotland.

2.16 In addition, 44 individuals submitted campaign plus versions; an amended or extended version of this text; and these have been included in the analysis alongside the standard responses.

2.17 There were also 589 submissions of an alternative questionnaire focussed on the South Arran p MPA. Respondents answered the question 'Do you support the development of an MPA network in Scotland's Seas (with 3 MPAs in the Clyde)?' and commented on the South Arran p MPA designation, management options and socioeconomic assessment.

These respondents said yes to MPAs and to the South Arran p MPA, asked for a ban on fishing, said that MPAs would boost tourism and asked that the whole of Arran, rather than just the South, should be designated.

2.18 The following chart shows the origins of all responses to this consultation.

Chart 2.1

Responses (Base: 14,703)