Publication - Consultation analysis

Designating a deep sea marine reserve in Scottish waters: consultation analysis

Summary of the analysis of consultation responses submitted on the designation of a deep sea marine reserve, the West of Scotland possible Marine Protected Area. The consultation opened on the 27 September 2019 and closed on 31 December 2019.

62 page PDF

1.6 MB

62 page PDF

1.6 MB

Contents
Designating a deep sea marine reserve in Scottish waters: consultation analysis
Annex B: Coding framework

62 page PDF

1.6 MB

Annex B: Coding framework

General

G1: Respondent is supportive of the creation of the West of Scotland deep sea marine reserve.
G2: Respondent has reservations in relation to the creation of the West of Scotland deep sea marine reserve.
G3: Respondent supports the creation of the West of Scotland deep sea marine reserve but raises some concerns and/or makes additional recommendations or comments regarding the designations.
G4: Respondent is against the creation of the proposed deep sea marine reserve but raises comments in support of the principle of an MPA and/or some aspects of the proposed deep sea marine reserve.
G5: No comment.
G6: Respondent provides a response, but it is unclear whether it supports or opposes the deep sea marine reserve creation.

The Site

S1: The deep sea marine reserve will help to protect and/or enhance biodiversity.
S2: The deep sea marine reserve will help to reduce carbon emissions and/or pollution.
S3: The deep sea marine reserve will help to ensure a good quality of human life.
S4: The deep sea marine reserve will help to meet national, regional and local environmental targets.
S5: The deep sea marine reserve will help to protect areas from the negative environmental effects created by industrial activity.
S6: The deep sea marine reserve will have a positive economic impact at a local, regional and/or national level.
S7: The deep sea marine reserve will have a negative effect on the quality of human life.
S8: The deep sea marine reserve will have a negative economic impact at a local, regional and/or national level.
S9 : The deep sea marine reserve will not create any positive environmental benefits.
S10: Action is required to stop destroying local, regional and/or national designated natural heritage and/or assets.
S11: Action is required to protect local, regional and/or national heritage against over-exploitation and destruction.
S12: The sea areas around Scotland are crucial areas for many species and features.
S13: The deep sea marine reserve will help to provide required environmental protection.
S14: The deep sea marine reserve is a good addition to the Scottish MPA network.
S15: The deep sea marine reserve will help to protect areas from the negative environmental effects created by the tourism industry.
S16: The deep sea marine reserve/Scottish oceans must be protected for future generations.
S17: The deep sea marine reserve will help to support and control tourists and visitors in the area. The designation will create clear guidelines for what actions and activities are acceptable in the deep sea marine reserve.
S18: The sea is important for carbon storage.
S19: Action is required to preserve wildlife.
S20: Industrial practices have had a negative effect on Scottish animal species and ecosystems.
S21: The deep sea marine reserve will create socio-economic benefits.
S22: The deep sea marine reserve is a shift in attitude in seeing our seas as a source of benefit to ourselves.
S23: Scotland’s oceans benefit human life and the climate.
S24: The boundary of the deep sea marine reserve needs to be amended.
S25: The proposed boundary encompasses areas of fishing activity in waters less than 800m in depth.
S26: Concerns raised regarding the legal and legislative powers that govern Scottish waters.
S27: Necessary legal powers and practical resources are required to ensure adequate protection is in place before the UK’s withdrawal from the EU.
S28: Support the recovery objectives identified within the deep sea marine reserve.
S29: The existing approach to management measures in support of conservation objectives should be used in the deep sea marine reserve.
S30: Support all the documents provided for the deep sea marine reserve designation.
S31: Transparency of the deep sea marine reserve assessment of the designation should be improved.
S32: Additional comments made regarding the species and habitat assessments.
S33: There should be higher consideration for ecosystem components in the pelagic zone and for marine mammals.
S34: The benefits of establishing the deep sea marine reserve outweigh the socio-economic impacts identified.
S35: In the Sustainability Appraisal, it is not clear how the “three scenarios” have been conceived as “reasonable alternatives”.
S36: Conflicting guidance and information regarding the Intermediate and Upper management scenarios presented is provided.
S37: Clarification is required to better understand the valuation figures assumed under the Lower Scenario.
S38: Respondent has undertaken their own public consultation on the designation and it was found to be strongly in favour of the designation.
S39: Deep sea marine reserve is a good precedent for other fisheries protections to be included in the network allowing for a more coherent approach to protective measures in the future.
S40: Alternative management measures are already in place meaning that the deep sea marine reserve designation is not required.
S41: The designations that the deep sea marine reserve look to protect are already protected by existing MPAs.

Scientific Evidence

SC1: Concerns/Issues raised in relation to the Scientific Evidence for the deep sea marine reserve
SC2: Support the Scientific Evidence for the deep sea marine reserve. This includes support for the benefits that the deep sea marine reserve will create and the protection it will provide.
SC3: Respondent does not understand the Scientific Evidence presented.
SC4: Respondent provides a response, but it is unclear whether it supports or opposes the Scientific Evidence presented.
SC5: The deep sea marine reserve designation combined with other designations can support the protection of Scotland’s natural assets.
SC6: Respondent provides a positive comment regarding Scotland’s natural heritage and environment.
SC7: Marine Protected Areas help to protect ecology and the wider environment including, but not limited to habitats, ecosystems etc.
SC8: Respondent supports Scientific Evidence presented but raises some concerns and/or makes additional recommendations to support the evidence.
SC9: Scientific evidence presented does not quantify the benefits of preserving seabeds at such a depth.
SC10: Lack of confidence exists in the content of the evidence presented.
SC11: Oppose/Have reservations about the designation of the upper level management scenario.
SC12: An appropriate literature review was undertaken in preparation of the different Assessment’s for the proposed Deep Sea Marine reserve designation.
SC13: The deep sea marine reserve may act as a refuge from ocean acidification for cold-water corals.
SC14: It is not clear and transparent how areas for protection were chosen.
SC15: It is not clear what the thresholds used for assessing the sufficiency of evidence were for the different documents provided.
SC16: Clarification is required regarding the definition of “functional significance” in the Methods document provided.
SC17: Clarification is required regarding how the boundary for the deep sea marine reserve was set.
SC18: Concerns/Questions asked regarding why a number of other species have not been included for designation and inclusion in the Assessment’s undertaken.
SC19: Respondent raises awareness of the latest guidelines for applying the IUCN protected area management categories to MPAs.
SC20: Whilst wider seas measures targeted at whale conservation are absolutely vital, bans on commercial and spurious scientific whaling, added area-based protection from the cumulative impacts of fishing, noise, and deep-water extractive activities could further benefit their conservation status.
SC21: Concerns raised regarding the fact that decisions are being made on assumptions rather than reliable evidence.
SC22: The data has been collected through appropriate structured and verified data gathering programmes.

Conservation Objectives and Management Advice

C1: Concerns/Issues raised in relation to the Conservation Objectives and Management Advice for the deep sea marine reserve.
C2: Support the Conservation Objectives and Management Advice for the deep sea marine reserve.
C3: Respondent does not understand the Conservation Objectives and Management Advice presented.
C4: Respondent provides a response, but it is unclear whether it supports or opposes the Conservation Objectives and Management Advice presented.
C5: Respondent requests for additional management and restriction of industrial activity in the deep sea marine reserve area than what is currently proposed.
C6: Deep sea marine reserve should be monitored appropriately.
C7: The deep sea marine reserve designation should reduce, restrict or remove all damaging commercial vessel action.
C8: Noise pollution should be prevented/ considered as part of the management measures.
C9: There are several considerations regarding the deep sea marine reserve designation, but environmental conservation and/or enhancement should be prioritised.
C10: Species have been negatively affected because of pollution and/or human activity in Scotland’s oceans.
C11: Further information and/or action is required to support the implementation of the proposed practices.
C12: Support the management measures on mobile bottom fishing activity in waters >800m.
C13: Inappropriate to apply restrictions on mid-water fishing activity.
C14: Marine Scotland should consider and take account of instances where fishing operations enter the deep sea marine reserve to allow safe working.
C15: Support the case for the gathering of further evidence to support the deep sea marine reserve designation.
C16: Oppose/Have reservations on the designation of the intermediate level management scenario.
C17: Impacts created by industrial activity do not merit the management measures proposed.
C18: A definition of ‘natural processes’ should be provided.
C19: Propose changes to the Conservation Objectives outlined in the information provided.
C20: Propose to extend the prohibition of industrial activity in seas greater than >600m.
C21: It’d be beneficial to present information about the current status of features in the vicinity of overlapping with human activities.
C22: Concerns raised regarding the data sources used to help inform the Assessment’s and Guidance documents.
C23: Support the management measures but believe there are several points that warrant further consideration.
C24: Climate induced vulnerability and impacts on the marine environment should be emphasised in the management advice for the deep sea marine reserve.
C25: Intersectoral collaboration should form an important part of the management strategy for the deep sea marine reserve.
C26: Further use of GIS is encouraged.
C27: Seabirds will not benefit from the proposed management measures as outlined by the JNCC.
C28: Support the addition of the slopes shallower than 800m.
C29: Support the designation of the upper level management scenario.
C30: The JNCC management advice underestimates the pressure of demersal fishing activity on species on habitats that currently range from “moderately to highly vulnerable”.
C31: The information contained in this consultation lacks the sufficient detail necessary to fully understand the entirety of impacts experienced by the affected stakeholders if the deep sea marine reserve was to take effect.
C32: Respondent interested to continue a dialogue regarding the consultation to fully appreciate if the objectives of the designation could be achieved with more engagement.

Business and Regulatory Impact Assessment

B1: Concerns/Issues raised on the Business and Regulatory Impact Assessment for the deep sea marine reserve.
B2: Support the Business and Regulatory Impact Assessment for the deep sea marine reserve.
B3: Respondent does not understand the Business and Regulatory Impact Assessment presented.
B4: Respondent provides a response, but it is unclear whether it supports or opposes the Business and Regulatory Impact Assessment presented.
B5: Assets should be considered more in environmental value than financial.
B6: The deep sea marine reserve will have a positive effect on Scotland’s tourism industry.
B7: The Deep Sea Marine Reservation could have a negative economic impact on smaller businesses but changes for the purposes of environmental protection and/or sustainability are required.
B8: Supportive of the intermediate management scenario.
B9: It is not possible to fully quantify the potential loss or costs (to industrial activities) associated with the upper level management scenario.
B10: The Business Regulatory Impact Assessment and assessment of economic costs would benefit from engagement with stakeholders.
B11: It is recommended that the Business Regulatory Impact Assessment is revisited following the designation of the MPA and the agreement of the site-specific management measures.
B12: Concerns raised that despite EU regulations having banned bottom trawling in areas deeper than 800m water depth, it is not clear why priority was given to areas below and not above 800m depth.
B13: Value of the ecosystem services benefits for research and education in the deep sea marine reserve should be classified as “High” and not “Moderate”.
B14: The societal benefit of the deep sea marine reserve has been undervalued.
B15: It is not always appropriate or possible for biodiversity and ecosystem services to be traded off against social and economic considerations.
B16: Additional information provided to inform the Assessment’s completed for the consultation.
B17: The Business Regulatory Impact Assessment fails to consider the wider area of the deep sea marine reserve affected by the proposed designation.
B18: Management scenarios developed by Marine Scotland for the management of the deep sea marine reserve have been noted as being incomplete.
B19: The potential cessation of oil and gas developments within the West of Scotland area would result in both material social and economic impacts in terms of employment.

Sustainability Appraisal; including the Environmental Repot and Socio-Economic Impact Assessment

SA1: Concerns/Issues raised in relation to the Sustainability Appraisal for the deep sea marine reserve.
SA2: Support the Sustainability Appraisal for the deep sea marine reserve.
SA3: Respondent does not understand the Sustainability Appraisal presented.
SA4: Respondent provides a response, but it is unclear whether it supports or opposes the Sustainability Appraisal presented.
SA5: The proposals will totally restrict industrial activity in the deep sea marine reserve Area.
SA6: It would be reasonable to expect a graduated approach between the management scenarios for all affected industries.
SA7: The respondent notes the challenging nature of assessing deep-sea ecosystem goods and services has not enabled a detailed assessment of effects on ecosystem services.
SA8: The respondent notes the Sustainability Appraisal contains an uncertainty assessment about the impacts of the deep sea marine reserve on human activities.
SA9: The Sustainability Appraisal has gone into exhaustive, and questionable detail on the costs to commercial fisheries sector and made false claims about the costs to others.
SA10: The Sustainability Appraisal makes no attempt to quantify benefits to carbon storage even though workable figures are available.
SA11: There is a danger that reading this report policy makers will focus on the costs, because monetary values have been assigned, and ignore the benefits which may be far greater.
SA12: Conflicting guidance in the consultation overview document in comparison to the Sustainability Appraisal.


Contact

Email: marine_conservation@gov.scot