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

Planning Scotland’s Seas: Possible Nature Conservation Marine Protected Areas was published for consultation in July 2013. It set out proposals for a number of new Marine Protected Areas (MPAs). Independent analysis of written consultation responses was

8 An Ecologically Coherent Network

8.1 Respondents were asked: 'On the basis of your preferences on which p MPAs should be designated, do you view this to form a complete or ecologically coherent network, subject to the completion and recommendations of SNH's further work on the 4 remaining search locations?'

8.2 One-hundred and one standard responses, across respondent groups, contained an answer to this question.

8.3 Sixty-six said no; this was made up mainly of individuals and environment/conservation respondents, although a small number from energy, local groups, mobile fishing and other organisations also said no. This figure also includes several of the campaign plus responses.

8.4 Thirty-five said yes; this included 18 individuals and organisation responses from a number of respondent groups; no environment/conservation respondents said yes.

8.5 It should be noted, however, that while respondents ticked 'yes' subsequent commentary indicated that some hold the opposite view; it appears that at least seven of these respondents hold the opposite view. This discrepancy may have been because of the questionnaire design; at previous questions respondents were given a 'yes' box to tick if they wished to comment on the question, rather than as a question in its own right

8.6 Four of the campaigns (5,529 submissions) included text saying no.

Chart 8.1

Whether forms a complete or ecologically coherent network

(Base: Standard responses 332)

Chart 8.1 Whether forms a complete or ecologically coherent network (Base: Standard responses 332)

8.7 As can be seen in the chart above, over three-quarters of standard respondents did not give an answer. The table below shows the numbers saying that the proposed network will not be ecologically coherent.

Table 8.1

Whether view this to form a complete or ecologically coherent network

Number saying No

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. (network campaign)


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. (network campaign)


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. (network campaign)


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. (South Arran campaign)


Standard responses




8.8 Most of those who said 'no' commented further and a main theme raised in these responses was the need to protect far more species: "However, these proposed MPAs will only offer direct protection to 39 species and habitats, a tiny proportion of the 6,500 species and many important habitats found in Scotland's seas. This runs entirely contrary to the OSPAR recommendations which ask that network areas include 'the range of species, habitats and ecological processes (for which MPAs are a suitable measure)'".

8.9 The need to include more seabirds featured in responses as did a call for "The inclusion within the network of the full representative range of Scottish marine species and habitats ( e.g. addition of non- MPA search features)".

8.10 Respondents wanted to see the other four search areas designated as MPAs in addition to those included in this consultation; this would deliver protection for minke whale, white-beaked dolphin, Risso's dolphin and basking shark.

8.11 Some of the environment/conservation respondents gave lengthy replies to this question, in which they mentioned many of the points discussed above amongst many other detailed comments and suggestions. These respondents commented on issues around connectivity, size, management measures, additional features and representation amongst many others.

8.12 One from this group commented on the need to include finfish and shellfish "Fish species which can be of 'keystone' importance within 'natural' inshore marine ecosystems around Scotland include herring which spawn on the seabed (and which can be an important food for salmon and sea trout), sea trout, salmon and juvenile gadids. None of these were included on the list of MPA search features. Therefore, we do not believe that a 'natural' ecosystem approach has been followed".

8.13 There was concern, particularly from mobile fishing respondents, over the amount of replication across the network. These respondents felt that some features had been protected across several sites, or that some features had been designated even though they are not noted as threatened features on the OSPAR list of Threatened/declining Species and Habitats.

8.14 A small number of environment/conservation respondents asked whether there would be an opportunity to submit further third-party MPA proposals before the next review of the network in 2018.

8.15 Individuals commented on the need to widen protection to other species; many mentioned all seabirds abut others included finfish, whales, dolphins and porpoises.

8.16 Fourteen respondents included the answer "NO, because this consultation response form does not include the Skye to Mull search Area".

8.17 Several respondents called the proposals 'a step in the right direction'.

8.18 Only a small number of the 35 who said 'yes' commented. Some, from the aquaculture group, said they would prefer a reduction in the overall size "The current 'broad brush' approach is inappropriate and needs to be more targeted to ensure the species and features get the protection they need". Individuals and some from recreation/ tourism felt the network should be as large as possible. As mentioned above, commentary in a number of the 'yes' responses indicated that the respondents hold the opposite view.

Summary - Ecological coherence

A large number of campaign respondents said that the network will not be ecologically coherent.

Most were looking for better representation but fishing groups thought there was too much replication.

There was a difference of opinion amongst standard respondents, although a relatively small number commented.

A main concern was that the network should protect more species.


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