Phase 2 MPA measures and PMF review minutes: COAST - 13 February 2020

Minutes of Marine Scotland's meeting on 13 February 2020 with the Community of Arran Seabed Trust (COAST) prior to enacting phase 2 Marine Protected Areas (MPA) measures and Priority Marine Features (PMF) review.

Attendees and apologies

Attending organisations:

  • Marine Scotland
  • SNH 

Items and actions


  • introductions
  • Marine Scotland update on PMF/MPA process - stakeholder response, stakeholder meetings, project timeline, areas for development
  • AOB

MS gave background to PMF and MPA management projects to date; highlighting the stakeholder response following the workshop held on 01 October 2019, subsequent stakeholder meetings that have been arranged, and changes to the project timeline. The meeting was then used to discuss a number of concerns raised by the Community of Arran Seabed Trust (COAST):

COAST expressed discontent with the way that PMF protection measures are being looked at in isolation to other types of marine management within MS, and highlight that they feel that MS teams are overly siloed, exacerbating disagreement on management measures. COAST asked whether PMF management measures could be considered within the context of MS Future of Fisheries Management (FFM) project to provide a more joined up approach. MS highlighted that timescale for FFM will be much greater than that planned for PMF/MPA management, and so this process will continue with ongoing feed-in from Sea Fisheries colleagues, and clarified that MS Marine Conservation colleagues work closely with Sea Fisheries and Compliance colleagues. 

Question about timescales; Cab Sec committed to implement management measures for PMFs in 2017-18 Programme For Government; COAST highlighted frustration and discontent with time it has taken to bring measures to implementation stage. MS highlighted that the project timelines have been delayed for a number of reasons following the workshop in October 2019. Further stakeholder engagement has been required, data will need to be updated for SEIA, reasonable alternatives reconsidered and consultation documents redrafted, which means that proposals are unlikely to go out to public consultation before the end of 2020.

COAST highlighted that they understand that developing PMF and MPA measures is a difficult piece of work which is likely to cause disagreement amongst stakeholders no matter the outcome, and that within this meeting they primarily sought to clarify the context and boundaries of the project to better understand what may be feasible.

COAST suggested that measures should be brought into force much faster, citing the example of the emergency MPA which was designated for Loch Carron. COAST highlighted that MS had originally aimed to have a well-managed MPA network by 2016. COAST highlighted that action needed to be taken much faster to protected seabed habitats as damage has already occurred and there is an urgent need to address the biodiversity loss crisis.

COAST also expressed concern concerned by the time lag for science to feed into policy.

Question about economic analysis; COAST agreed with plan to update data to more recent years, but also stressed that  we need to consider historic employment data of recreational sea angling and commercial fishing so that the assessment also considers the economic benefits of activities that used be supported by more productive marine ecosystems as an indicator of what recovered marine habitats and ecosystems can support. This is important  in order to recognise within the economic analysis that recovered marine ecosystems have significant economic benefits to society including fisheries. They suggested MS review data going back 2-3 decades, as they felt that the current method using data over six years is inadequate and does not capture long term decline in fishing that has occurred and they feel is likely to continue regardless of PMF/MPA management. They suggested that MS should consider this decline when estimating economic impact of measures. MS highlighted that it’s more feasible to review data from past to identify trends than it is to predict data for the future, with equal rigor and accuracy.

COAST see current SEIA as focussing on highlighting costs to fishing sector, rather than also identifying that PMF/MPA protection can provide benefits for all. MS agreed that ecosystems services are not well captured in this SEIA, and that unfortunately it will not be possible to bring them in for this round of measures but we are seeking to include them in the future. COAST emphasised how important they considered it that the economic benefits from ecosystem services and blue carbon resources that can be provided by PMFs/MPAs are given greater recognition and properly incorporated into the economic assessment in order to provide a more complete picture of the benefits and costs of the PMF/MPA measures.

COAST stated that the economist on behalf of MS previously confirmed to them that blue carbon wasn’t included in SEIA due to it being ‘negligible’. MS highlight that this is likely because burrowed mud is one of the greatest marine carbon capture habitats, and so wouldn’t be captured by PMF project. MS agreed to consider including blue carbon in amended SEIA if we are able to quantify it.

COAST felt that by-catch should be included in SEIA landings data.

COAST highlighted that a statement by FM highlighted that biodiversity loss should be treated the same as climate change, and suggested that Ministers and Officials need to be less concerned about keeping everyone happy in the pursuit of tangible results.


  • MS to talk to MAU about how historic trends in the  fishing industry are captured in SEIA

COAST felt that much of Scotland’s marine protection is not effective, and isn’t supported by appropriate management. MS highlighted that REM will be in place by end of 2020 which should support enforcement of all management when implemented. 

COAST requested MS openly recognise all areas that could not be quantified in SEIA. MS highlighted that this exists in the form of a qualitative statement.

COAST are publishing research this week which shows that exclusion of fishing effort supports ecosystem recovery, regardless of PMFs. SNH highlighted that proposed management for PMF process will help to deliver some this improvement. 

COAST enquired how MS arrived at reasonable alternatives, and if 3 mile limit has been fully considered. MS highlighted that the three mile limited had been ruled out following scoping consultation, as it could not be justified as a reasonable measure for protecting PMFs as distribution data does not provide sufficient evidence for such management. MS discussed existent issues with proposed 0.5 NM limit as it cannot be readily justified on east coast of Scotland where there are no records for the 11 PMFs.

COAST questioned if MS will put measures in place for remaining 70 PMFs. MS highlight that we are only considering measures for features considered most sensitive. SNH clarified selection criteria and reasoning behind selection of 11 PMFs.

FEAST sensitivity tool; SNH clarified that it looks at all pressures that might occur on known habitat, and creates a summation of these pressures. It does not currently capture the intensity of individual pressures that are occurring e.g. fishing pressure, at present.

MS highlighted that the PMF records used for analyses are the best currently available, but acknowledge that there may be unrecorded habitats that are not currently captured. MS will therefore have a review process in place to enable new evidence to be captured (likely within timing of National Marine Plan, every 5-6 years). 

COAST expressed a desire for larger spatial management areas due to large likelihood of there being a number of areas with PMFs that have not yet been surveyed, and highlighted that the impact that fishing would have was not assessed upon removal of 3 mile limit in 1984. They suggested fishers should apply for marine licence to fish specific areas rather than protection applied to areas with known feature records.

COAST suggested that MS need to promote ocean literacy within fishing industry to encourage them to understand how fisheries management will help to protect the industry in the future. They also highlighted a World Wildlife Fund (WWF)/Guardian article published yesterday (12 Feb) which outlines biodiversity loss and corresponding loss to fishing sector. MS highlighted that many fishers see impact of measures on a personal scale rather than industry wide and may be less accepting of personal impacts. 

COAST felt that MS need to stop subsidising & supporting mobile bottom contacting gear sector, and that management is required for all fisheries sectors. They are publishing a paper today/tomorrow showing impact of MPA management, and are concerned about the potential increase in un-managed fishing pressure, e.g. increase in number of scallop divers, that may occur in South Arran MPA as a result of the research.


  • COAST to share link to paper published on 13 February 2020

COAST expressed discontent with the way that RIFGs have been set up in that there is no wider stakeholder involvement even though fisheries has implications for other sea users. They feel that the current West Coast management plan is not fit for purpose and is not delivering tangible benefits.

They also highlight that ongoing management is required for MPAs, to enable sustainable harvest of stocks to be opened up where possible following recovery.

COAST asked if MS have concerns about process going forward to meet international and national commitments. MS confirmed that Marine Strategy Regulations have transposed Marine Strategy Framework Directive (MSFD) into UK law following EU Exit, and so SG will continue to use the same time-lines, measures, indicators, etc. as previously. Going forward we will have more of a focus on working with the OSPAR commission. MS highlighted that a new UK governance structure has been set up for the Marine Strategy; a Marine Strategy Policy Leads group under which the Monitoring and Assessment Reporting Group (MARG) sits, and MS chair the new Programmes for Measures group. MS highlighted that EU Exit may make it easier to implement management measures for offshore MPAs in the future. 


  • MS to send COAST information about the new UK governance structure for the Marine Strategy

COAST questioned if MS are achieving GES under the Marine Strategy. MS confirmed we are performing well on some descriptors such as for hazardous substances, although some legacy chemicals will take a long time to break down. MS highlighted improvement is happening on a number of fronts e.g. trajectory is in right direction for fish indicators to achieve good environmental status. More recent measures within EU Common Fisheries Policy have improved the situation but awaiting confirmation to see how this carries through in UK fisheries Bill. COAST would like to see encouragement of and more specific support for small-scale sustainable fisheries. 

Remote Electronic Monitoring (REM); COAST asked if we know what programme the REM for inshore fleet will use (e.g. SIFID vs. anchor lab). MS highlighted that the tendering process was still ongoing.

COAST asked SNH about the strength of PMF records. SNH acknowledges that biotope tagging is a subjective process with some known issues. Quality assurance processes are in place for all records before they are uploaded to GEMS database; SNH hoping to have data from 2019 EMFF survey checked and published by May 2020.

COAST flagged issue with consultation document title “Protecting Scotland’s Coastal Biodiversity” as they don’t feel it is clear enough for stakeholders to understand what the document is about.

COAST overall content that MS are listening but concerned MS policy isn’t keeping up with the findings from scientific studies. COAST still keen for greater spatial measures to be presented as a reasonable alternative to ensure that unsurveyed PMF records are given some level of protection from mobile bottom contacting gear.


  • COAST to send MS and SNH link to papers published with Edinburgh Law Society 
  • COAST to send MS and SNH link to paper published this morning evaluating MPA management and recovery in the South Arran MPA

COAST asked SNH if Priority Marine Feature management advice will support SNH MPA advice. SNH indicated that it will. 

Action point summary

  • MS to talk to MAU about how historic trends in the fishing industry are captured in SEIA
  • COAST to share link to paper published today
  • MS to send COAST information about the new UK governance structure for the Marine Strategy
  • COAST to send MS and SNH link to papers published with Edinburgh Law Society 
  • COAST to send MS and SNH link to paper published this morning evaluating MPA management and recovery in the South Arran MPA
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