Phase 2 MPA measures and PMF review minutes: Sea Change Wester Ross - 19 February 2020

Minutes of Marine Scotland's meeting on 19 February 2020 with Sea Change Wester Ross prior to enacting phase 2 Marine Protected Areas (MPA) measures and Priority Marine Features (PMF) review.

Attendees and apologies

Attending organisations:

  • Marine Scotland (MS)
  • Sea Change Wester Ross (SCWR)

Items and actions

General points

SCWR felt that it was unfair for MS to arrange meetings around Scotland via RIFGs, as this does not enable non-fishery stakeholders to contribute to the development of proposals. MS highlighted that MS had told all stakeholders present at the October workshop that they could request a meeting with MS, and that we are meeting with many different stakeholders to enable all views to be heard.

SCWR queried how the Scottish sea fisheries national discussion fits in with this project. MS clarified that the process for developing MPA and PMF management started before the future of fisheries

SCWR sought clarification on whether the PMF and MPA management process originated from the Marine Strategy Framework Directive; MS clarified that the MPA/PMF process will contribute to MSFD objectives, but that the driver drivers differed for each project; EU driver for MPAs and National Marine Plan for PMFs. MS also confirmed that the MSFD will be incorporated into UK law following EU Exit.

SCWR highlighted that they do not agree with the framework behind the processes. They believe that there needs to be a proper ecosystem approach as they do not think that fragmented approaches are working to reverse the decline. 

SCWR voiced concerns that Marine Scotland appears to regard sea fisheries policy as a separate issue to marine conservation policy. MS highlighted that we are working closely with our sea fisheries policy colleagues throughout the development of proposals. 

SCWR voiced concern that some dredgers appear to be intentionally targeting PMF areas, and emphasised incidents of illegal fishing within MPAs. MS highlighted that the work within Marine Scotland to improve fishing vessel tracking and monitoring should support enforcement of MPA measures, and that all reports to MS of illegal fishing are followed up.

SCWR highlighted concerns about MS’s delay in implementing management measures and sufficient enforcement. They felt that PMF areas should be closed immediately to mobile bottom contacting fishing until the public consultation process is complete. MS recognised their concerns but highlighted how challenging it would be to implement a voluntary closure without full stakeholder engagement and public consultation, in advance of unconfirmed future measures.  SCWR said that the Minister Richard Lochhead had used powers given to Ministers to urgently close Wester Ross MPA when it was seemed urgent and necessary to protect maerl being damaged by dredging as Loch Carron had also been. MS highlighted that the Wester Ross MPA had not been designated using urgent powers and so had undergone the full process of stakeholder engagement, public consultation and impact assessment. 

MS highlighted that contentious management areas would likely cause issues in developing a voluntary agreement for the above. 

MS detailed Phase 2 MPA process and highlighted that Sound of Barra and Small Isles sites have been carried over from Phase 1 because they are so contentious. 

MS highlighted that we must follow legal process and work towards management measures, enabling stakeholders to participate in process throughout. SCWR disagreed with this process and felt measures should be implemented and enforced in advance of a formal decision post consultation (e.g. Loch Carron emergency MPA). MS highlighted that Ministers have asked officials to consider stakeholder opinions. SCWR said that Government needed to lead and take opinion with it rather than follow opinion.

SCWR acknowledged that it is important to gather opinions and that the process to develop PMF measures is not an easy one. They highlighted a broader issue about a lack of capacity to respond to all issues affecting the marine environment, stating that they are concerned that they may not be able to fully feed into development of measures affecting marine environment due to the number of parallel projects. 

SCWR highlighted that they feel MS should be more ambitious when developing management, and were surprised that MS have come to such different conclusions from SCWR based on available evidence. MS highlighted that all decisions are made using an evidence based approach, and that we must consider socioeconomic impacts as well as environmental. 

SCWR said they have considered economic impacts but believe the long term environmental and economic impacts need to be better considered as they are one and the same. They highlighted that economic opportunity comes directly from a healthy environment. 

SCWR felt that an ecosystem approach should be used when considering all measures, rather than protecting smaller discrete areas. MS highlighted that considerable work has been undertaken to designate a network of MPAs in recent years. SCWR voiced concern that only ~5% of MPAs are spatially protected from mobile bottom contacting fishing.

SCWR felt that the cumulative impact of different issues affecting the marine environment (climate crisis, biodiversity loss, microplastics, overfishing, etc.) requires MS to do all we can to minimise all impacts.

SCWR felt that dredging and trawling practices are outdated and should not be supported. MS encouraged SCWR to feed this opinion into Future of Fisheries Management discussions. 

SCWR highlighted a voluntary closure at Gairloch to support herring spawning which they do not feel is sufficient to protect maerl. They recognised that the intention of the closure was not to protect maerl, but highlighted that they believe maerl is an important feature for herring spawning. SCWR was most concerned that the closure was temporary and highlighted that maerl is impacted by one tow.

SCWR felt that the Gairloch voluntary closure area could prohibit all gear types during the weeks of the spawning period itself, but that it could be open to creel and dive fishing methods outside of that and should be otherwise closed to the mobile sector. SCWR did not feel that scallop divers need to be prohibited during the weeks the herring spawn as they do minimal harm to the seabed. MS highlighted that the area in question is covered by proposed Priority Marine Feature (PMF) management areas, so could be captured by this process. 

SCWR was concerned about the length of time that was taking to develop and implement protection, and highlighted that maerl and herring are two keystone species that require urgent protection. 

SCWR clarified that there may be a better more modern option than just bringing back the old 3 mile limit which could be more scientifically up to date but SCWR definitely believes that a blanket boundary should be implemented and policed, as they feel it is the simplest method of efficiently and effectively restoring a very damaged ecosystem. MS highlighted that options 2 & 3 using a 1.5 NM limit came from stakeholders during scoping exercise in 2018, but that a blanket limit is no longer considered to be a justifiable measure for this process since there are large areas where PMFs do not exist (e.g. Scotland’s east coast).  

MS said that the work to protect PMFs arose from a review to identify the 11 PMFs most vulnerable to mobile bottom-contacting fishing gear. This automatically created a bias against considering a boundary line. SCWR said that this is precisely the problem, highlighting that the species do not exist in isolation and that the ecosystem is interconnected. SCWR felt that we need an ecosystem approach which recognises the interrelationship of species and does not have a hierarchical list but sees it as a web of interconnection - which we do not fully understand yet. SCWR believed that the Ministers’ decision to select only a top list of PMFs to protect in the PMF review had created a flawed approach for two reasons:

  • because protection of only 11 species does not recognise that they all work together in an ecosystem
  • SCWR believe most of the (limited) records are from divers who target shallows near ports or access. They therefore believe this is a flawed process scientifically and has become more bureaucratic than scientific.  They highlighted that whole ecosystems need to recover and not just the top species within ecosystems. They believed that the main flaw in the process is that fish spawning and nursery grounds are not considered in this top 11 species. MS highlighted that some of the 11 PMFs provide spawning/nursery areas for some species

SCWR summarised that they feel the process has been far too slow, and that something like a 3 mile limit needed to be implemented as soon as possible. 

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