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


5 Possible Marine Protected Areas

5.1 While a large number overall responded to the consultation, individuals in particular commented on only one p MPA; ones that were close to their home or of interest to them. This means that at the questions on each of the p MPAs there are fairly small numbers responding. Details of comments on each individual site are given in the next chapter.

5.2 Through these site summaries, tables show the total numbers commenting; this includes standard, campaign plus and campaign responses.

5.3 The following table gives an indication of the location of individuals who submitted standard responses and those who submitted campaign plus responses [3] on each of the sites, based on the postcodes supplied. Those in the 'lives near area' column live in the local authority areas closest to the p MPA.

5.4 As can be seen in the following table, Loch Creran attracted the fewest comments (one) while the Small Isles attracted the most (61).

Table 5.1

Location of individual respondents in relation to territorial p MPAs

p MPA

Standard responses

Campaign plus

Lives near area

Lives outwith area

No post-code

Lives near area

Lives outwith area

No post-code

Clyde Sea Sill

5

3

2

13

29

6

East Caithness Cliffs

-

5

1

5

38

5

Fetlar to Haroldswick

2

5

-

-

43

5

Loch Creran

-

1

-

-

1

-

Loch Sunart

1

3

-

-

1

-

Loch Sunart to the Sound of Jura

1

2

1

-

1

-

Loch Sween

1

2

-

-

1

-

Lochs Duich, Long and Alsh

2

1

-

-

1

-

Monach Isles

-

3

-

-

43

5

Mousa to Boddam

1

2

-

-

2

-

North-west Orkney

1

2

-

-

1

-

NW sea lochs and Summer Isles

12

4

2

-

1

-

Noss Head

-

2

-

-

1

-

Papa Westray

1

4

-

1

42

5

Small Isles

6

7

-

3

40

5

South Arran

4

4

1

28

17

1

Upper Loch Fyne and Loch Goil

5

3

2

1

1

-

Wyre and Rousay Sounds

-

3

-

-

-

-

5.5 As the following table shows, only a small number of individuals commented on offshore p MPAs.

Table 5.2

Location of individual standard respondents in relation to offshore p MPAs

p MPA

Individuals responding

East of Gannet and Montrose Fields

3

Faroe-Shetland sponge belt

4

Hatton-Rockall Basin

2

North-east Faroe Shetland Channel

3

Rosemary Bank Seamount

2

The Barra Fan and Hebrides Terrace Seamount

2

Turbot Bank

2

West Shetland Shelf

4

5.1 Clyde Sea Sill

5.1.1 The protected features that the Clyde Sea Sill p MPA will conserve are:

  • Biodiversity: Black guillemot, fronts, and circalittoral sand and coarse sediment communities
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed

5.1.2 Respondents were asked: 'Do you have any comments on the case for designation, management options and socioeconomic assessment for the Clyde Sea Sill possible Nature Conservation MPA?' and 32 respondents commented; ten individuals and 22 organisations across organisation types. Many other individuals (48) submitted a campaign plus response, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area. The table below shows the total numbers commenting on this p MPA.

Table 5.3

Number commenting on the Clyde Sea Sill p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

32

Total

1,706

Designation

5.1.3 This p MPA is one of three proposed in the Clyde area, along with Upper Loch Fyne and Loch Goil and South Arran; many comments on this p MPA relate to all three of these sites.

5.1.4 One environment/conservation respondent asked that their third-party proposal to extend the Sanda Island SSSI to protect razorbills be reconsidered and commented on the importance of the area for a range of seabird species.

5.1.5 A small number of respondents commented on the need to include protection for the kelp forests. Three environment/conservation respondents expanded on this issue asking that kelp habitats are added to the protected features as they support not only black guillemot but also the wider ecosystem. These respondents also commented on the importance of the front and suggested mobile species that benefit from the effects of the front "should be afforded protection where qualifying criteria dictate."

5.1.6 Clarity on the descriptors of the front was requested as was work to understand the effects of the front in the area.

5.1.7 Another environment/conservation respondent felt that the 'conserve' status given to the protected features in the area should be changed to 'recover' although another from the same group supported the 'conserve' status.

5.1.8 There was also support for the other biodiversity protected features; circalittoral sand and coarse sediment communities, and fronts.

5.1.9 However, three of the mobile fishing respondents commented on this p MPA and said that the protected features are "Not noted as threatened features on the OSPAR list of Threatened/declining Species and Habitats" while an individual commented that the Black Guillemot was classified by Birdlife International as 'least concern'.

5.1.10 Several respondents pointed out that data used for species counts are 15 years out of date and wanted to see this addressed.

5.1.11 A small number of the organisations, recreation/ tourism, local authorities and public sector, simply noted the proposals for the Clyde Sea Sill or voiced their support for this p MPA.

Management options

5.1.12 In relation to the management options on renewables, one energy respondent commented that cables will pass through the area for a renewables projects and that this may cause a temporary impact on habitat and marine birds. Commenting on another proposed development, another energy respondent asked for the probable cable route through the Clyde Sea Sill area to be recognised within the management options.

5.1.13 Environment/conservation respondents however wanted to see the impacts of various installations in or proposed for the area assessed fully. One wanted to see monitoring work and mitigation of the impact of installations and cables on bottlenose dolphin, minke whales and basking shark and for site management to consider these species, along with the harbour porpoise.

5.1.14 The management options for static and mobile fishing gear were welcomed by some organisations, mainly from the environment/conservation group, as were the options against the introduction of predators.

5.1.15 In relation to reducing or limiting pressures from demersal mobile/active gear, one environment/conservation respondent commented that this would need to be "fully discussed with skippers in the area and other stakeholders (including environmental and wider community stakeholders)".

5.1.16 In relation to the three p MPAs in the Clyde, one environment/conservation respondent wanted to see a more holistic approach to fisheries management measures.

5.1.17 A small number of respondents noted and appreciated that anchorages are not considered capable of affecting the protected features.

Socioeconomic aspects

5.1.18 Respondents across various organisational groups felt that designation would be beneficial to the area in terms of the economy and well-being; some respondents cited studies around these subjects. Sea-bird and wildlife tourism is considered by respondents as already important and respondents felt designation would help ensure that this continues.

5.1.19 One local authority did not think there would be any negative impact from the designation on their area, although they said that this could not be confirmed until the management measures are confirmed. Another commented that they support the designation at present but any additional restrictions on mobile gear should be considered alongside other proposals for the Clyde as, cumulatively, they could have negative economic impacts on the area.

5.1.20 One environment/conservation respondent was concerned that analysis and assessment of socioeconomic impacts needed to be carried out in a more holistic way. They identified some gaps such as a lack of analysis of socioeconomic costs and economic impact which they felt would be harmful in the event of a p MPA not being designated.

Summary - Clyde Sea Sill

There was support for the designation of this MPA and for the protected features; there were requests to include the kelp forest and other seabird species.

Several respondents pointed out that data used for species counts are 15 years out of date and wanted to see this addressed.

The management options were welcomed.

Respondents, across various organisational groups, felt that designation would be beneficial to the area in terms of both the economy and well-being.

5.2 East Caithness Cliffs

5.2.1 The protected feature which the East Caithness Cliffs p MPA will conserve is:

  • Biodiversity: Black guillemot

5.2.2 Respondents were asked for comments on the case for designation, management options and socioeconomic assessment for the East Caithness Cliffs p MPA and 22 respondents commented; six individuals and 16 organisations mainly from the public sector and environment/conservation groups.

5.2.3 Again, many individuals (48) submitted a campaign plus response, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area. The table below shows the total numbers commenting on this p MPA.

Table 5.4

Number commenting on the East Caithness Cliffs p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

22

Total

1,696

Designation

5.2.4 The environmental/ conservation organisations commented on the importance of the area for seabirds such as razorbill, black-legged kittiwake, northern fulmar and common guillemot. Mobile fishing respondents, however, commented that black guillemot is not on the OSPAR list of threatened species.

5.2.5 Again, there were calls from individual and environmental/ conservation respondents for the kelp forests in the area to receive protection. Some felt that this p MPA should be considered in the draft seaweed consultation.

5.2.6 An energy respondent said that it is not clear what the effects of the designation would be on a wind farm proposed for the area.

5.2.7 Again, several respondents pointed out that data used for species count is 10 or 15 years out of date and wanted to see this addressed.

Management options

5.2.8 There was support for the management option to remove or avoid set nets and comments on the need to monitor this, from various respondent groups. Environment/conservation organisations wanted to see the EU's Action Plan for reducing incidental catches of seabirds in fishing gears if any fishing practices that cause seabird bycatch or mortality started in the area. These respondents commented that monitoring would be important.

5.2.9 There was also some comment that both set nets, scallop dredging and benthic trawling should be banned from the area. One local authority felt the management options may need to be reviewed if fishing areas are reviewed or if there are developments in finfish aquaculture such as cage top-nets. A static fishing respondent wanted to ensure that creel fishers would not lose any fishing opportunities in the MPA.

5.2.10 There was welcome for the alignment of this p MPA with the existing SPA in the same area.

5.2.11 Respondents also welcomed the management option measure to reduce or avoid the spread of mammalian predators and support for the development of biosecurity plans in relation to breeding habitat next to the area.

5.2.12 An energy organisation wanted the opportunity to discuss a transmissions project that may overlap with the area. One public sector respondent offered details of existing cables in the area; this respondent offered information on assets such as cables and pipelines across the p MPA areas.

5.2.13 A small number of individuals asked that the RSPB be involved in the management of the site.

Socioeconomic

5.2.14 A small number of individuals said that ecosystems are more important than any socioeconomic considerations as once they are gone they cannot be recovered.

5.2.15 Some of the environment/conservation respondents commented that "Costs have been identified in the BRIA which relate to port and harbour activities. However, management of these activities have not been proposed in the management options paper. The link between these is spurious and must be clarified if the estimates are to be used in ministerial decision making."

5.2.16 In relation to the Strategic Environmental Assessment, the need for at-sea feeding areas to be protected was mentioned by one environment/conservation respondent.

5.2.17 One local authority felt that deep mud habitats have only been under pressure since nephrops fishing started in inshore waters. They said that nephrops can be caught by creel fishing and added "Subject to measures to manage gear selectivity and fishing effort it is envisaged that such a fishery could present real economic benefit to local communities and the removal of gear conflicts between static and mobile gear could present advantages for Scotland's seas."

5.2.18 A respondent from the static fishing group also felt good management and a reduction in mobile gear would bring socioeconomic benefits.

Summary - East Caithness Cliffs

There was support for designation and for protected features in this p MPA and requests to include the kelp forest and other seabird species.

Some felt that this p MPA should be considered in the draft seaweed consultation

Several respondents pointed out that data used for species counts are 15 years out of date and wanted to see this addressed.

The management options were welcomed and there was welcome for the alignment of this p MPA with the existing SPA in the same area.

5.3 East of Gannet and Montrose Fields

5.3.1 The protected features that the East of Gannet and Montrose Fields p MPA will conserve are:

  • Biodiversity: Ocean quahog aggregations (including sands and gravels as their supporting habitat) and offshore deep sea muds

5.3.2 There were comments in 15 responses on this p MPA; three from individuals and 12 from organisations, many of the organisations were from the environment/conservation group.

Designation

5.3.3 Most of those who replied simply said that they are supportive or noted the findings and proposals in respect of this p MPA. Respondents commented on its importance in respect of the ocean quahog and offshore deep sea mud and gravel communities and some, from the environment/conservation group, pointed out that "The southern part of the p MPA includes one of very few examples of deep sea mud on the continental shelf in the North Sea warranting this added protection."

5.3.4 There were, however, comments from the public sector and energy groups that given the amount of oil and gas activity in the area this area does not represent a least damaged / most natural location.

Management options

5.3.5 There was support, from several respondent groups, for a large designated area prohibiting disturbance by bottom contact fishing gear and one environment/conservation respondent mentioned their support for the removal or avoidance of oil and gas activity while others commented on the 'many concerns' status, given within Scotland's Marine Atlas, of shelf subtidal sediments in the area.

5.3.6 One public sector respondent, however, was concerned as the p MPA covers an area that is significantly important for oil and gas production with the potential for a significant increase in activity in the future. This respondent suggested a smaller or alternative area for the features identified. They also asked that the management options should say early contact with the 'relevant' regulator as this will not always be Marine Scotland and that 'through the existing licensing process' should be changed to 'through the existing regulatory processes'. This comment was made in relation to many of the management options.

5.3.7 An energy respondent commented on the issue of oil and gas in the area and said: "The most likely management measure - minimising or avoiding the introduction of materials that alter the habitat type - might not be possible to comply with if maintenance is required on these pipelines."

5.3.8 An energy respondent commented that the proposed route of a high voltage link between Norway and Britain will pass through the south-east of the p MPA. They said "however the footprint of the cable is very small in comparison to the overall size of the proposed MPA. We therefore consider any impact on the proposed MPA as minor, and continue to liaise with Marine Scotland and the JNCC on the proposals."

5.3.9 A public sector respondent offered details of existing assets, such as pipelines, in the area.

Socioeconomic

5.3.10 One environment/conservation respondent noted that the Business and Regulatory Impact Assessment ( BRIA) indicates a moderate recovery for fish stocks; this was welcomed but, the respondent felt, would depend on the management options being applied. Others from this group commented that as the value of fish landed from this area is not substantial, it would represent a minimal impact to prohibit towed/active fishing gear in this area.

5.3.11 A public sector respondent said that the relevant Oil and Gas bodies do not feature in the consultation section of the BRIA and commented on technical issues around oil base mud cuttings mentioned in the BRIA. They also asked to be included in the development of any future management measures.

5.3.12 With regards the Strategic Environmental Assessment, one environment/conservation respondent wanted to see consideration given to the wider ecosystem in order to benefit other species such as fulmar and gannets which have been observed within the site.

Summary - East of Gannet and Montrose Fields

There was support for designation and for the management options. The importance of the ocean quahog and offshore deep sea mud and gravel communities was specifically noted. There were, however, concerns with regards to the economic importance of this area, especially with regards to Oil and Gas interests.

5.4 Faroe-Shetland Sponge Belt

5.4.1 The protected features that the Faroe-Shetland Sponge Belt p MPA will conserve are:

  • Biodiversity: Deep sea sponge aggregations, ocean quahog aggregations, offshore subtidal sands and gravels, and continental slope
  • Geodiversity: Quaternary of Scotland - continental slope channels, iceberg ploughmark fields, prograding wedges, Submarine Mass Movement - slide deposits, Marine Geomorphology of the Scottish Deep Ocean Seabed - sand wave field, sediment wave field

5.4.2 Twenty-one respondents commented on the Faroe-Shetland Sponge Belt; this included four individuals and 17 organisations, mainly from the environment/conservation and international fisheries groups.

Designation

5.4.3 The individual respondents and some organisations simply welcomed the designation or commented on the features, importance or uniqueness of the area.

5.4.4 A local authority pointed out that many of the features also exist in the North-east Faroe Shetland Channel p MPA and suggested reducing the size of either that p MPA or the Faroe-Shetland Sponge Belt p MPA.

5.4.5 A public sector respondent commented that this area overlaps with oil and gas activity and there will be additional activity in the future and felt consideration should be given to the size and location of the Faroe-Shetland Sponge Belt p MPA.

Management Options

5.4.6 The size of the p MPA also featured in responses about the management options. A local authority felt that those who fish the area may find the remove/avoid option more acceptable if the size of the area was reduced; they also commented on the need for further discussion with the fishing sector.

5.4.7 Four of the French fisheries respondents submitted the same response asking for a minor modification in the area that, they felt, would still allow them to fish in the area. They submitted a map of the area showing the modification requested. A Spanish fisheries respondent commented that Spain also has fishing interests in part of the area.

5.4.8 Environment/conservation respondents supported the removal of bottom contact mobile and static gear from the area. This group of respondents also wanted the management plan to include consideration of potential benefits to seabirds and the wider marine environment; white-sided dolphin, sperm whale, long-finned pilot whale and fin whale were also mentioned. These respondents also commented that monitoring will be important.

5.4.9 One environment/conservation respondent said they supported the removal or avoidance of pressures associated with oil and gas activities and a case-by-case consideration of these activities. This respondent did not feel the remove/avoid pressure in relation to oil and gas activities could be achieved given the current and proposed level of activity in the area. They also felt some management measures may be unfeasible or not economically viable and gave micro-siting as an example. This respondent questioned the size of the area, as did an energy respondent who also said that it may not be feasible to comply with proposed management measures such as micro-siting and minimising or avoiding the introduction of materials.

Socioeconomic

5.4.10 Environment/conservation groups saw the benefits of conserving the deep sea biodiversity in the area as outweighing that of trawling in the area.

5.4.11 Several from this group voiced concern about "inappropriate assumptions made in the socioeconomic assessment when calculating the costs of designation".

5.4.12 The French fisheries respondents provided details of their catch throughout the year along with its value. A Spanish fisheries respondent said that closing the area to trawlers would "entail financial loss for Spanish vessels active in this area."

5.4.13 In relation to the oil and gas activity in the area, a public sector respondent commented on the potential impact on current and future activity and said that they did not agree with the assumptions for oil and gas cost impacts "especially the intermediate estimate which appears to be virtually identical to the lower estimate".

5.4.14 An energy respondent said that the BRIA failed to recognise the costs involved in changing proposals such as finding alternative routes.

Summary - Faroe-Shetland Sponge Belt

There was support for designation and for the management options although a number of respondents would support a smaller area.

There were differences in opinion between sectors (particularly environment and fishing) over restrictions on fishing in the area.

5.5 Fetlar to Haroldswick

5.5.1 The protected features that the Fetlar to Haroldswick p MPA will conserve are:

  • Biodiversity: Black guillemot, circalittoral sand and coarse sediment communities, horse mussel beds, kelp and seaweed communities on sublittoral sediments, maerl beds, and shallow tide-swept coarse sands with burrowing bivalves
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed

5.5.2 Respondents were asked for comments on the case for designation, management options and socioeconomic assessment for the Fetlar to Haroldswick p MPA and 23 respondents commented; seven individuals and 16 organisations, mainly from the public sector and environment/conservation groups. Again, many individuals (48) submitted campaign plus text, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area. The table below shows the total numbers commenting on this p MPA.

Table 5.5

Number commenting on the Fetlar to Haroldswick p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

23

Total

1,697

Designation

5.5.3 Most respondents who commented simply voiced their support for the designation or highlighted the reasons for their support; this included the maerl beds and the high percentage of the British population of black guillemots found in this site. A respondent from the 'other' organisations group felt that there could also be wider benefits to Atlantic salmon and sea trout.

5.5.4 Several of the environment/conservation respondents commented that as the management options paper says 'any impacts to the horse mussel beds, maerl beds, and kelp and seaweed communities on sublittoral sediment will have already occurred', the objective for these features should be to recover rather than conserve.

5.5.5 An aquaculture respondent said that there have been shellfish sites in the location for many years and these "have been developed in a sustainable and considerate manner, which has contributed greatly to safeguarding and maintaining the biodiversity of the adjacent seas, upon which the sector depends for its economic wellbeing and future prosperity". This respondent wanted to see the sites continue, while ensuring the protected features are acknowledged.

Management options

5.5.6 Several respondents welcomed the management options suggested for this p MPA.

5.5.7 There was welcome for the inclusion of the Shetland Islands' Marine Spatial Plan and for the recognition of management measures already in place via the Shetland Shellfish Management Organisation. The academic/ scientific respondent making these comments also reported that work they had undertaken had filled a gap in information, in relation to towed fisheries identified in the management options paper and they confirmed "that there are no towed fisheries in the Bluemull Sound area of the proposed MPA".

5.5.8 There were calls, from aquaculture and the environment/conservation group to ensure those involved in fishing the area are consulted over the plans for reducing or limiting pressures from any fishing activity.

5.5.9 A recreation/ tourism respondent felt there would need to be monitoring of anchorage levels to ensure this does not cause damage, while an industry/ transport respondent requested information on the sensitivity of horse mussel beds to the Basta Voe anchorage.

5.5.10 Again, an environment/conservation respondent wanted to see consideration of seabird and the wider marine environment in the management plan. There were calls from several of the environment/conservation respondents to extend dredging restrictions across the area, extending anti-predator methods to a 5km radius from nest sites and relocating any farms causing damage.

5.5.11 These environment/conservation respondents also commented that in the absence of detailed information on the impacts of aquaculture, a precautionary approach should be taken, however a public sector respondent welcomed the risk-based approach. The public sector respondent asked for more information on whether assets such as pipelines had been considered under 'Activities considered not capable of affecting the protected features'. A respondent from the recreation/ tourism group asked if recreational diving was to be restricted.

Socioeconomic

5.5.12 There was concern, from the aquaculture group, over potential impacts on the shellfish business, with consequent impacts for employment and other factors in the area; more information is needed on this issue. A local authority also wanted to see the methodology used to arrive at the conclusion that any impacts from management options will be low.

5.5.13 Environment/conservation respondents commented that the designation will allow seabird and wildlife tourism to continue to bring socioeconomic benefits to the area.

Summary - Fetlar to Haroldswick

There was support for designation and for protected features in this p MPA and requests to include other seabird species. There were calls for the objective for horse mussel beds, maerl beds, and kelp and seaweed communities to be recover rather than conserve.

The management options attracted broad support and there was welcome for the inclusion and recognition of existing measures.

Respondents wanted to ensure that those involved in fishing the area are consulted over the plans for reducing or limiting pressures from any fishing activity.

While there were some calls to extend dredging restrictions across the area, extend anti-predator methods to a 5km radius from nest sites and relocate any farms causing damage, there were also concerns over potential impacts on the shellfish business, with consequent impacts for employment and other factors in the area.

5.6 Hatton-Rockall Basin

5.6.1 The protected features that the Hatton-Rockall Basin p MPA will conserve are:

  • Biodiversity: Deep sea sponge aggregations and offshore deep sea muds
  • Geodiversity: Marine Geomorphology of the Scottish Deep Ocean Seabed - sediment drifts, Polygonal fault systems

5.6.2 Eight respondents (two individuals, four environment/conservation respondents and a respondent from tourism/ recreation) commented on the Hatton-Rockall Basin p MPA.

Designation

5.6.3 Several of those who commented simply supported the designation or commented on the importance of the area. Some of the environmental/ conservation respondents said that while there is good evidence of the presence of features, information is lacking on their distribution.

5.6.4 There were also calls for surveys to identify the full extent of deep sea sponge aggregations.

Management Options

5.6.5 The management options were supported by the environment/conservation respondents who also wanted to see monitoring of fishing activity and research on the type and extent of fishing activity in the area.

5.6.6 One respondent from this group asked that pilot whale and northern bottlenose whale be included in considerations. This group also commented on the need to rely on the North East Atlantic Fisheries Commission ( NEAFC) as the area is outwith UK fishery limits for enforcement; they commented that "the reliability of this process remains to be tested." Another of the environment/conservation respondents set out a list of regulation and management elements that they would like to see applied to deep-sea fishing in this p MPA.

Socioeconomic

5.6.7 Environment/conservation respondents commented that the relatively low cost of management options would be outweighed by ecological benefits.

Summary - Hatton-Rockall Basin

A small number commented and supported the designation and management options.

5.7 Loch Creran

5.7.1 The protected features that the Loch Creran p MPA will conserve are:

  • Biodiversity: Flame shell beds
  • Geodiversity: Quaternary of Scotland

5.7.2 Comments on Loch Creran were noted in 19 responses; two individuals and 17 organisations across most groups.

Designation

5.7.3 Most respondents voiced support for the designation.

5.7.4 Several of the environment/conservation respondents commented: "This possible MPA (overlaying the existing SAC for biogenic reefs) will be important to protect and enhance serpulid worm aggregations, flame shell beds and horse mussel beds. The area has already been declared a SAC and management will need to refer to, and align with, the objectives of the SAC. The congruence of the boundaries will simplify this." This group would prefer the objective of recover rather than conserve for the flame shell beds.

Management Options

5.7.5 The management options were supported by the environment/conservation respondents; these respondents wanted to see more protection with regards to pollution from finfish farms across the area rather than limited to the areas where aquaculture takes place.

5.7.6 A local authority, who also supported the options, was surprised that no additional management was suggested for moorings, while a tourism/ recreation respondent suggested a diver survey of the extent of the flame shell beds in case of any extension of the moorings at Creagan. Respondents from the recreation/ tourism group also suggested a diver code of conduct and monitoring of fishing and recreational anchoring.

5.7.7 One respondent from the industry/ transport group commented on the need to occasionally replace moorings for vessels serving a quarry; there are no roads to the site; when this occurs a diver survey is conducted and application for a new mooring is made. Another from this group noted that commercial shipping and anchorages are not anticipated to have an impact on the protected features in this p MPA.

5.7.8 A static fishing respondent was keen that no fishing opportunities for creel fishers would be lost in this area.

Socioeconomic

5.7.9 The area was described as hugely important for marine tourism and it was noted that management options are not expected to impact on existing activities.

5.7.10 One respondent from the industry/ transport group stressed the need for the importance of the loch for commercial shipping associated with the quarry to be recognised.

Summary - Loch Creran

There was broad support for the designation and management options.

Some would prefer the objective of recover rather than conserve for the flame shell beds.

5.8 Loch Sunart

5.8.1 The protected features that the Loch Sunart p MPA will conserve are:

  • Biodiversity: Flame shell beds, northern feather star aggregations on mixed substrata and serpulid aggregations

5.8.2 Twenty-four respondents commented on the Loch Sunart p MPA and this included five individuals and 19 organisations across groups.

Designation

5.8.3 The designation was supported by many who commented, although environment/conservation respondents and one from recreation/ tourism would prefer the objective for the features, and especially the serpulid aggregations, to be recover rather than conserve. There were comments on the importance of the area; as one individual commented: "This is a unique opportunity to preserve the potential building of a reef in its early stages".

Management Options

5.8.4 Mobile fishing respondents also supported the designation; one commented that they support the principle if fishing measures and aquaculture sites are not affected. Environment/conservation respondents supported the management options to remove or avoid pressures from fishing and farms in the area for serpulid reefs and flame shell beds and said that: "Existing aquaculture ventures will need to ensure they are compliant with updated or revised Environmental Management Systems to ensure operations minimise local and diffuse cumulative impacts, particularly with respect to water quality, erosion, sedimentation and disease".

5.8.5 However, a local authority felt that the management measures to restrict commercial fishing activities away from the features would be "virtually impossible to implement, or enforce." This respondent, along with an individual, felt that all mobile gear should be excluded. They also suggested 'go' (as opposed to 'no go') areas where a limited number of local static fishing vessels would be allowed to fish.

5.8.6 An industry/ transport respondent asked for information on the interaction between the Loch Teacuis anchorage and the serpulid aggregations in order to assess any impacts from management measures. A public sector respondent commented that any restrictions on anchorage within Loch Teacuis would mainly affect the local community, given the low number of craft that enter.

5.8.7 Mobile fishing respondents stressed the need to involve local communities and all other stakeholders in the management of the p MPA. A static fishing respondent was keen that no fishing opportunities for creel fishers would be lost in this area.

Socioeconomic

5.8.8 Again, a relatively small cost associated with designation was seen as being outweighed by potential ecological benefits by environment/conservation respondents. There were calls for harbour porpoise to be considered in the management options and also common eider, common tern, common gull and black guillemot.

5.8.9 A local authority queried the focus of the socioeconomic assessment and related timescales: "For example does the assessment consider the potential longer term economic benefits accruing from the short term loss in fisheries income. It might reasonably be speculated that exclusion of fishing activities from a particular area now may result in long term benefits in terms of the site becoming a nursery area from which mature fish can enter the fishery in the longer term, potentially providing greater benefits for future generations?"

5.8.10 A respondent from the mobile fishing group said it is important to consider all aspects of the socioeconomic assessment before designation.

5.8.11 A respondent from the mobile fishing group suggested that an area at the entrance to the loch should "be considered as a "scallop nursery" protected zone".

Summary - Loch Sunart

There was broad support for the designation and management options.

Some would prefer the objective for the features, and especially the serpulid aggregations, to be recover rather than conserve.

There were differences in opinion between sectors over restrictions on fishing in the area.

Some commented on the need to involve local communities and all other stakeholders in the management of the p MPA.

5.9 Loch Sunart to the Sound of Jura

5.9.1 The protected features that the Loch Sunart to the Sound of Jura p MPA will conserve are:

  • Biodiversity: Common skate
  • Geodiversity: Quaternary of Scotland

5.9.2 There were comments in twenty-nine responses on the Loch Sunart to the Sound of Jura p MPA. Five individuals and 24 organisations, across groups, commented.

Designation

5.9.3 There was broad support for this designation but also several suggestions for changes including:

  • Extending the area by 5km to the south west in the Sound of Jura to include the razorbill foraging area
  • Extending to the common seal SAC in southeast Islay and the north end of Lismore
  • Adding black-legged kittiwake, common guillemot and razorbill as protected features

5.9.4 A local authority suggested that one MPA should cover the area rather than the two suggested (in relation to Loch Sunart p MPA).

5.9.5 One industry/ transport respondent asked that Tobermory Bay and the near approaches be excluded in line with other harbours such as Oban as there is no historic evidence of common skate in this area. They commented: "Managing the Port within an MPA would put a considerable burden on our community Management and Governance of the Port, especially as we have new and long- term infrastructure proposals for the Port which will bring benefits to other more remote communities up and down the west coast."

5.9.6 Another transport/ industry respondent commented on the importance of being able to anchor and moor in Loch Linnhe and asked that the importance of the Sound of Mull and Firth of Lorn as shipping routes be recognised. They also proposed an alternative boundary that does not bisect the Glensanda Harbour limits.

5.9.7 There were calls, from the environment/conservation group, to find another site in addition to this in order to further protect the common skate.

5.9.8 A local authority and respondents from the mobile fishing group commented on a lack of data in relation to the common skate, particularly the distribution of juvenile skate and nursery areas. The mobile fishing respondents commented that the site proposed is too large; one said that once more data is available it would be preferable to designate smaller areas. The site was described as "an important, safe, commercial fishing area and within sections of the proposal, used by all the main finfish farms".

5.9.9 There was a comment on the need to include harbour porpoise as the site overlaps with areas critical to them.

Management Options

5.9.10 Most respondents supported the management options for this site.

5.9.11 There were calls for the management plan to consider potential benefits to seabirds and the wider marine environment.

5.9.12 Respondents wanted to see further research on common skate nursery grounds to support decisions about the area. There were also requests for more research on the impact of aquaculture, mooring and anchoring on common skate eggs and on the interaction between towed/active fishing gear and the common skate.

5.9.13 The environment/conservation respondents supported the reduction or limitation of mobile gear in the area and the removal or avoidance of bottom set nets and long-lines. They commented on the need for full engagement with the fishing industry and other stakeholders.

5.9.14 However, there were also comments that current regulations mean common skate are not targeted and if landed as bycatch are returned to the sea alive. Rather than further limiting the use of mobile gear it may be better to focus on other ways of further reducing fishing-related mortality. A local authority "would wish to see measures relating to better handling of by-caught skate and gear modification considered prior to determination of whether spatial measures are required."

5.9.15 A static fishing respondent did not want to see any limitations for mobile or static fishing without further scientific evidence while a local authority suggested keeping the site as a search location until additional research has been conducted. A respondent from the mobile fishing group commented that such a large area could have adverse effects on the mobile fishing industry.

5.9.16 There was a comment that if the wind development off Tiree goes ahead the cables will go through this area.

Socioeconomic

5.9.17 A small number commented on the economic contribution from sea angling in the area.

5.9.18 A local authority felt that the implementation of additional measures might have a greater economic impact than the recommended measures, for example measures to protect egg laying areas.

5.9.19 While an environment/conservation respondent said that management measures seem to protect the status quo rather than regenerating biodiversity, a mobile fishing respondent commented on the need for a socioeconomic assessment before designation and pointed out that this is an "important safe fishing area in winter months in particular", an area that supports local communities that rely on fishing.

Summary - Loch Sunart to the Sound of Jura

There was broad support for this designation but also several suggestions for changes including extending the area, reducing the area and adding various seabird species to the protected features.

While there was broad support for the management options, again there were some differences in opinion between sectors over restrictions on fishing in the area.

There were comments on a lack of data, especially in relation to the common skate.

5.10 Loch Sween

5.10.1 The protected features that the Loch Sween p MPA will conserve are:

  • Biodiversity: Burrowed mud, maerl beds, native oysters, and sublittoral mud and mixed sediment communities

5.10.2 Twenty respondents commented and this included 16 organisations across groups and four individuals.

Designation

5.10.3 Respondents supported the designation with environment/conservation respondents suggesting that the maerl beds may be more extensive. Some of these respondents felt that the objectives for the maerl beds and native oyster should be recover rather than conserve as it is probable that fishing has impacted on these features. There was a comment that the habitats and species in the topography around the Macormaig Isles are not well described.

Management Options

5.10.4 Respondents commented on the need for a more realistic assessment of fishing levels in the area and clarity over the likely levels of restriction on mobile and static fishing gear. There were also comments that recreational anchorages should be reviewed to ensure these are not in the vicinity of maerl beds. A public body commented that the anchorage at Ashfield is recreational rather than commercial; restriction on anchorage should be limited as otherwise this may affect the number of visitors to the area.

5.10.5 Again, a static fishing respondent was keen that no fishing opportunities for creel fishers would be lost in this area.

Socioeconomic

5.10.6 There was a feeling that designating this site would contribute to the local economy through additional tourism.

Summary - Loch Sween

There was broad support for this designation and management options. Some respondents felt the objectives for the maerl beds and native oyster should be recover rather than conserve.

There were calls for a more realistic assessment of fishing levels in the area and clarity over the likely levels of fishing restrictions. Some asked for recreational anchorages to be reviewed to ensure these are not in the vicinity of maerl beds.

5.11 Lochs Duich, Long and Alsh

5.11.1 The protected features that the Lochs Duich, Long and Alsh p MPA will conserve are:

  • Biodiversity: Burrowed mud and flame shell beds

5.11.2 Twenty-two respondents, including four individuals and 18 organisations across groups, commented on the Lochs Duich, Long and Alsh p MPA.

Designation

5.11.3 Respondents mainly supported the designation and commented on the importance of this area. Some environment/conservation respondents wanted to see the objective for burrowed mud set to recover rather than conserve. There were calls to add fan mussels to the list of protected features, again set to recover and one call for all features to be set to recover rather than conserve. A local group wanted to see Kyle Rhea included in the area.

5.11.4 Environment/conservation respondents also commented that this p MPA overlaps with an existing SAC and said "management will need to refer to, and align with, the objectives of this SAC".

Management Options

5.11.5 Management options were agreed by respondents. A static fishing respondent wanted to ensure that no opportunities for creel fishers would be lost. A local authority respondent suggested that management would be more efficient if mobile fishing gear is excluded from the whole MPA and made a similar comment about diver collected horse mussels.

5.11.6 Environment/conservation respondents commented: "Existing aquaculture ventures will need to ensure they are compliant with updated or revised Environmental Management Systems to ensure operations minimise local, and diffuse cumulative, impacts, particularly with respect to water quality, erosion, sedimentation and disease."

Socioeconomic

5.11.7 Respondents from the environment/conservation group felt displacement costs would be outweighed by ecological benefits.

5.11.8 One local authority felt that deep mud habitats have only been under pressure since nephrops fishing started in inshore waters. They said that nephrops can be caught by creel fishing and said this could present real economic benefit to local communities.

Summary - Loch Duich, Long and Alsh

There was broad support for this designation. Some respondents wanted to see the objective for burrowed mud set to recover rather than conserve. There were some calls to add fan mussels to the list of protected features; again set to recover.

There was also broad support for the management options.

5.12 Monach Isles

5.12.1 The protected features that the Monach Isles p MPA will conserve are:

  • Biodiversity: Black guillemot
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed, and Quaternary of Scotland

5.12.2 Nineteen respondents commented on the Monach Isles p MPA (three individuals and 16 organisations across most of the groups). Again, many individuals (48) submitted a campaign plus response, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area.

5.12.3 The table below shows the total numbers commenting on this p MPA.

Table 5.6

Number commenting on the Monach Isles p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

19

Total

1,693

Designation

5.12.4 The designation was supported by respondents; there were calls to include the kelp forests as a protected feature and for the MPA to be considered in the draft seaweed policy consultation. Respondents commented that the designation would also benefit a range of other seabird species.

Management Options

5.12.5 The management options were also supported; there was a call to ensure access for swimmers and divers and that creel fishers should not lose any opportunities through the designation.

Socioeconomic

5.12.6 Commenting on the BRIA, environment/conservation respondents said that it contains costs relating to part and harbour activities but that these have not been included in the management options.

5.12.7 A local authority asked that distinction be made between surface set nets and bottom set nets. Local accountability and control was seen as critically important as was consultation with local stakeholders on feature
sensitivities and management proposals.

5.12.8 Mobile fishing respondents said the reference to set nets as a risk should say surface set nets as bottom set nets do not pose a threat to the guillemots.

5.12.9 There were a number of comments on the need to manage tangle net fishery if current prohibitions are lifted.

Summary - Monach Isles

There was support for designation and for protected features in this p MPA and requests to include other seabird species and for kelp forests to be protected. Some felt that this p MPA should be considered in the draft seaweed consultation

The management options were broadly supported.

5.13 Mousa to Boddam

5.13.1 The protected features that the Mousa to Boddam p MPA will conserve are:

  • Biodiversity: Sandeels.
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed

5.13.2 Nineteen respondents commented on the Mousa to Boddam p MPA (five individuals and 14 organisations across most organisation groups).

Designation

5.13.3 Respondents agreed with the designation of this site although there were some suggestions that the boundary should change to include possible sandeel habitat beyond the proposed area. There were calls to change the objective for sandeels from conserve to recover and for kelp forests to be protected.

Management Options

5.13.4 Respondents from the environment/conservation group asked that research be carried out into the impact of demersal dredge on sandeels.

5.13.5 There was a query from a public sector organisation as to whether assets such as pipelines and activities associated with the engagement of those assets have been considered.

5.13.6 While a recreation/ tourism respondent said there would be a need to monitor static fishing gear, a static fishing respondent was keen that no fishing opportunities for creel fishers would be lost in this area.

Socioeconomic

5.13.7 The importance of seabird tourism to the area was noted; the birds are reliant on fish stocks, which are in turn affected by any decrease in sandeel spawning stock biomass. Environment/conservation respondents commented that this "should be considered as part of the environmental baseline and a switch away from cannibalism should be considered as a benefit of designating this site".

Summary - Mousa to Boddam

The designation was agreed although there were some suggestions that the boundary should change to include possible sandeel habitat beyond the proposed area.

Some called for the objective for sandeels to be set as recover rather than conserve and for kelp forests to be protected.

There were also calls for research into the impact of demersal dredge on sandeels.

5.14 North-east Faroe Shetland Channel

5.14.1 The protected features that the North-east Faroe Shetland Channel p MPA will conserve are:

  • Biodiversity: Deep sea sponge aggregations, offshore deep sea muds, offshore subtidal sands and gravels, and continental slope
  • Geodiversity: Quaternary of Scotland -prograding wedge; Submarine Mass Movement - slide deposits; Marine Geomorphology of the Scottish Deep Ocean Seabed - contourite sand/silt; Cenozoic Structures of the Atlantic Margin - mud diapirs

5.14.2 Eighteen respondents (three individuals and 15 organisations from many of the groups) commented on the North-east Faroe Shetland Channel p MPA.

Designation

5.14.3 Most respondents supported the designation.

5.14.4 Respondents from the international fisheries group acknowledged the importance of protecting the deep sea sponge habitat but, commenting on the importance of the area to the French fleet, proposed different boundaries which would still offer the conservation objective.

5.14.5 A local authority, energy respondent and public body commented on the size of the site and suggested that the area could be smaller.

Management Options

5.14.6 There was acknowledgement that the area is important to the fishing industry and respondents said that monitoring and compliance of fishing activity as well as engagement with the industry will be necessary.

5.14.7 Environment/conservation respondents were concerned that there are no management options to protect the continental slope in the p MPA from damaging activities. This group also said that oil and gas exploration should not be allowed in areas that overlap "the very limited extent of deep sea sponge aggregations, or where they are sufficiently in the vicinity of those aggregations to risk their conservation status from down or up-current events".

5.14.8 Respondents from the international fisheries group proposed a new shape for the MPA "allowing the conservation objective for the habitats and a better alternative for the French fleet".

Socioeconomic

5.14.9 There was some concern, from environment/conservation respondents, that inappropriate assumptions had been made in calculating the cost of designation, with comments that the benefits of conserving deep sea biodiversity outweigh the benefits of trawling. There were also comments that this p MPA is a critical habitat for white-sided dolphin, sperm whale, long-finned pilot whale and fin whale and that these should be included when looking at management options.

5.14.10 The international fisheries respondents submitted the annual value of their landings of mainly hake and saithe and commented that activity in this p MPA takes place all year round.

Summary - North-east Faroe Shetland Channel

Most respondents supported the designation but there was acknowledgement of the importance of the area to the fishing industry with respondents asking for monitoring and compliance of fishing activity as well as engagement with the industry.

There was some concern that there are no management options to protect the continental slope.

5.15 North-west Orkney

5.15.1 The protected features that the North-west Orkney p MPA will conserve are:

  • Biodiversity: Sandeels
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed - sand bank, sand wave field, and sediment wave fields

5.15.2 Eighteen respondents commented on the North-west Orkney p MPA; (four individuals and 14 organisations, including many from the environment/conservation group).

Designation

5.15.3 Respondents from the environment/conservation group supported the designation although some called for the objective for sandeels to be set to recover rather than conserve. Respondents noted that there has been no strategic monitoring of the sandeel population but using seabird health as a proxy it would seem that the sandeels in the area are in poor condition and undersized.

5.15.4 The importance of the spawning stock in the area was noted as was the contribution to the economy from seabird tourism in this area and the need to consider the seabird population.

5.15.5 A recreation/ tourism respondent felt that the designation did not fit with government targets for doubling farmed salmon production: "It is patently obvious to us that the requirement of at least 3 tonnes of wild oily fish (sand eels) caught to produce one tonne of farmed salmon is the very definition of unsustainable practise - without even touching on the sea lice issue".

Management Options

5.15.6 An energy respondent wanted to discuss this p MPA as it overlaps with a transmissions project.

5.15.7 There was particular support for the proposal to limit any future sandeel fishery in the area.

5.15.8 Environment/conservation respondents felt that the suggestion for no additional management is contradictory to the ambition set out for the MPA and "fails to meet the duty in the Marine Act to protect and where appropriate enhance the health of the marine environment."

5.15.9 A local authority respondent said they would be concerned if the p MPA significantly affected potential development of offshore renewables in the area.

Socioeconomic

5.15.10 The value of tourism from seabirds and wildlife was noted; respondents felt that the future of this industry depended on good management of the environment.

5.15.11 A respondent from the mobile fishing group pointed out that sandeels are protected elsewhere and that they do not appear on the OSPAR list of threatened or declining species; this respondent therefore questioned the legality of designating on this basis and expressed concern over any attempt to limit fishing in the area.

Summary - North-west Orkney

Most respondents supported the designation although some called for the objective for sandeels to be set to recover rather than conserve.

Most supported the proposal to limit any future sandeel fishery in the area.

5.16 North-west sea lochs and the Summer Isles

5.16.1 The protected features that the North-west sea lochs and the Summer Isles p MPA will recover are:

  • Biodiversity: Flame shell beds and maerl beds

5.16.2 The protected features that the North-west sea lochs and the Summer Isles p MPA will conserve are:

  • Biodiversity: Burrowed mud, circalittoral muddy sand communities, kelp and seaweed communities on sublittoral sediments, maerl or coarse shell gravel with burrowing sea cucumbers, and northern feather star aggregations on mixed substrata
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed, Seabed Fluid and Gas Seep, Submarine Mass Movement, Quaternary of Scotland

5.16.3 Comments on the North-west sea lochs and the Summer Isles p MPA were noted in 47 responses; this included 19 individuals and 28 organisations across most groups.

Designation

5.16.4 Environment/conservation respondents supported the designation or called for it to be extended to cover "all maerl beds and other seabed habitats used as fish spawning grounds around Wester Ross". In particular, most individuals wanted to see the area extended to include Loch Gairloch. Other respondents, including aquaculture, felt that the area is too large and suggested a reduction in size to focus on specific locations.

5.16.5 There were calls to add seagrass beds and sea trout to the protected features.

5.16.6 Some respondents suggested that the area should be the Wester Ross MPA to give a clear local identity, foster local interest and give a greater sense of local ownership.

5.16.7 Mobile fishing respondents voiced concern over the evidence given in support of the protected features.

Management Options

5.16.8 There was support from many respondents for the management options for this p MPA; however, a number of mobile fishing respondents voiced opposition or concerns.

5.16.9 An aquaculture respondent asked for more detail on developing finfish aquaculture in the area; they said: "as a small business which only operates in this proposed MPA, this has potentially significant effects on my business." A mobile fishing respondent commented that too many areas are being closed to fisherman.

5.16.10 An energy respondent wanted to discuss this p MPA as it overlaps with a transmissions project.

5.16.11 Some individuals and one from the mobile fishing group called for the area to be managed by local fishermen. Respondents from this group also voiced concern over erosion of fishing rights. A static fishing respondent wanted to see robust management and added a caveat to their support for the p MPA that creel fishers should not lose any fishing opportunities.

5.16.12 A respondent from the other organisation group questioned whether the timeline set would be sufficient for the audit and review process.

5.16.13 Other respondents wanted to see research to investigate interactions between active/mobile gear and the protected features.

5.16.14 There were calls to consider porpoises within the management options.

Socioeconomic

5.16.15 An aquaculture respondent and several individuals felt that the costs of designation and displacement would potentially be much greater than detailed and that social costs had not been adequately accounted for.

5.16.16 Concern over potential loss of jobs was voiced by a small number of individuals and respondents from the mobile fishing group. These respondents pointed out that the area had been fished sustainably for at least 50 years using low horsepower vessels and light gear "and have avoided areas where the proposed features are located". This group said: "Zoning of the areas currently fished by prawn trawlers and scallop dredgers should be identified to ensure that modern technology is used to avoid the designated features within the MPA".

5.16.17 Environment/conservation respondents and also several other individuals felt that there would be economic benefits from continuing or increased tourism, diving and sea angling.

5.16.18 A local authority commented on costs to existing operations with the site and queried the figures presented for this p MPA: "The values quoted are an order of magnitude greater than those for other sites. This appears to be slightly incongruous and the Council would ask that the figures presented be reviewed."

Summary - North-west sea lochs and the Summer Isles

While there was support for the designation there were also conflicting suggestions; some wanted to see the area extended while others felt it should be reduced.

There were calls to add seagrass beds and sea trout to the protected features.

Some suggested the area should be called Wester Ross to give a clear local identity, foster local interest and give a greater sense of local ownership.

There was support from most respondents for the management options

5.17 Noss Head

5.17.1 The protected feature which the Noss Head p MPA will conserve is:

  • Biodiversity: Horse mussel beds

5.17.2 There were comments on the Noss Head p MPA in 18 responses including 3 from individuals and 15 from organisations across various groups.

Designation

5.17.3 Many respondents simply said that they support the designation of the Noss Head p MPA.

Management Options

5.17.4 An energy respondent wanted to discuss this p MPA as it overlaps with a transmissions project.

5.17.5 Most of the others who commented voiced support for the management options for this site.

Socioeconomic

5.17.6 Several respondents from the environment/conservation group commented on the potential value to divers and anglers in terms of both economics and well-being.

Summary - Noss Head

There was broad support for the designation and the management options for this p MPA.

5.18 Papa Westray

5.18.1 The protected features that the Papa Westray p MPA will conserve are:

  • Biodiversity: Black guillemot
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed

5.18.2 Nineteen respondents, five individuals and 14 organisations, commented on Papa Westray. In addition, many individuals (48) submitted a campaign plus response, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area. The table below shows the total numbers commenting on this p MPA.

Table 5.7

Number commenting on the Papa Westray p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

19

Total

1,693

Designation

5.18.3 Respondents supported the designation of the Papa Westray site. There were calls for kelp habitats to be added to the list of protected features and a suggestion, from environment/conservation respondents "that this MPA is considered in the parallel draft seaweed policy statement consultation, and particularly with regards to guidance developed for the harvest of wild seaweed."

5.18.4 Environment/conservation respondents pointed out that biosecurity on the islands would help safeguard seabirds breeding on Papa Westray including Arctic tern and Arctic skua.

Management Options

5.18.5 There was broad support for the management options. One local authority did voice concern that the p MPA may affect possible future development of offshore renewables in the area.

Socioeconomic

5.18.6 Respondents commented on the importance of the site for seabird and wildlife tourism and for anglers and divers; it was hoped that designation of the Papa Westray site would ensure this continues.

5.18.7 A local authority felt the socioeconomic assessment too high level to consider the impact on local communities and the local economy.

5.18.8 One mobile fishing respondents commented that the site overlaps Draft Plan Option TN3 for tidal and said that tidal arrays should be discouraged from this site to protect diving birds.

Summary - Papa Westray

There was support for designation and for protected features in this p MPA and requests to include the kelp forest and other seabird species.

Some felt that this p MPA should be considered in the draft seaweed consultation.

There was broad support for the management options.

5.19 Rosemary Bank Seamount

5.19.1 The protected features that the Rosemary Bank Seamount p MPA will conserve are:

  • Biodiversity: Deep sea sponge aggregations, seamount communities and seamount features
  • Geodiversity: Quaternary of Scotland- iceberg ploughmark field; Submarine Mass Movement - slide scars, Marine Geomorphology of the Scottish Deep Ocean Seabed - scour moats, sediment drifts, sediment wave fields, Cenozoic Structures of the Atlantic Margin - Rosemary Bank Seamount

5.19.2 Ten respondents, two individuals and eight organisations (mainly from the environment/conservation group) commented on the Rosemary Bank Seamount p MPA.

Designation

5.19.3 Most respondents who commented voiced support for the designation of this p MPA. There were calls for protection for whales and dolphins in this area.

Management Options

5.19.4 There was support for the management options on this p MPA although one recreation/ tourism respondent would rather see controls on aggressive fishing methods than a ban. A static fishing respondent was keen to ensure no loss of opportunity for creel fishers.

5.19.5 Comments on including the seamounts protected feature in the management options were noted in responses from the environment/conservation group: "Given that the site designation has been suggested based on the wider functional significance of the site, and in particular the seamount's significance as a spawning ground for blue ling and blue whiting, management options should be established in ways that maintain or enhance this overall function".

5.19.6 There was a request for clarity over the geographic extent of the measures for the removal or avoidance of pressures associated with mobile bottom contact gear, and of set netting from areas of deep sea sponge aggregations and of seamount communities.

Socioeconomic

5.19.7 Environment/conservation respondents wanted to see wider ecological benefits considered in management options and socioeconomic assessment. Some of these respondents saw displacement costs as modest when compared to ecological benefits. One from this group set out a list of regulation and management elements that they would like to see applied to deep sea fishing in this p MPA.

Summary - Rosemary Bank Seamount

A small number commented; most supported the designation and the management options for this p MPA.

5.20 Small Isles

5.20.1 The protected features that the Small Isles p MPA will conserve are:

  • Biodiversity: Black guillemot, burrowed mud, circalittoral sand and mud communities, fan mussel aggregations, horse mussel beds, northern feather star aggregations on mixed substrata, northern sea fan and sponge communities, shelf deeps, and white cluster anemones
  • Geodiversity: Quaternary of Scotland

5.20.2 The Small Isles p MPA attracted comment from 34 respondents (13 individuals and 21 organisations including many from the environment/conservation group). Again, many individuals (48) submitted a campaign plus response, as described in Chapter 1, calling for the protection of black guillemots and for other seabirds to be protected in this area. The table below shows the total numbers commenting on this p MPA.

Table 5.8

Number commenting on the Small Isles p MPA

Number commenting

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 [and variations]. (seabird campaigns)

1,626

Campaign plus responses

48

Standard responses

34

Total

1,708

Designation

5.20.3 There was broad support for this p MPA however respondents made a number of suggestions and these included:

  • That the designation should include basking shark, minke whale and harbour porpoise, and native oysters.
  • That the objective for fan mussel aggregations and northern feather star aggregations should be recover rather than conserve.
  • That the objective for all protected features in the area to be recover rather than conserve.
  • That other seabirds and the Manx shearwater colony should be added as a protected feature.

5.20.4 There were comments, from environment/conservation organisations and individuals, that the boundary be extended to the coastline of Skye and should encompass the sea lochs of southern Skye and the sea areas around the Isle of Soay as these are important areas for sea trout. This would also mean that other features could be included such as maerl beds, seagrass beds, burrowed mud habitat, blue mussel beds, kelp and seaweed on sublittoral sediment, low or variable salinity habitats, native oysters and basking shark. Should this not be possible then, respondents requested, a Research and Demonstration MPA should be developed. There were reports of voluntary survey work underway in the lochs and requests for the lochs to be surveyed properly.

Management Options

5.20.5 Respondents supported the management options; there were suggestions that measures should be set jointly for the p MPA and the SPA that it overlaps.

5.20.6 There was a request from the environment/conservation group that this p MPA is considered in the draft seaweed policy statement consultation, especially with regards guidance for harvesting wild seaweed.

5.20.7 While there was support for the management of bottom impacting gear in the Sound of Canna; some respondents felt the entire site should be protected in this way. Also in relation to the Sound of Canna, respondents from the environment/conservation group recommended that the licensed dredge spoil sites be rescinded.

5.20.8 A tourism/ recreation respondent commented that only bottom and fixed gear fishermen will be affected and asked for information on the cumulative effects of measures on this group across the network. Again, a static fishing respondent supported the p MPA but wanted to be sure that this would not have any negative impacts for creel fishers.

5.20.9 There were calls for rigorous assessment of any future aquaculture developments in the area.

5.20.10 A local authority noted that fishing activity does not have the same environmental scrutiny as aquaculture within this p MPA and gave as an example: "Loch Kishorn, this was previously designated by SNH as a Marine Conservation Area in order to afford some protection to the sea pen population. This meant additional scrutiny during the development of fish farming but had no bearing on fishing pressure to the extent that one of the few remaining locations that sea pens are found in significant numbers within the Loch are amongst the fish farm anchors."

5.20.11 A mobile fishing respondent commented that low horsepower prawn trawlers and scallop dredgers have been working in the area for nearly 50 years without evidence of impacting upon the protected features. They said that "Zoning of the mobile tows can be easily agreed with skippers so that they can avoid the features within the site and that would be a sensible management plan for that area". This respondent wanted a tonnage and horsepower cap to ensure large vessels do not fish the site. They also stressed the need to avoid displacement of current mobile gear activity "as that would simply divert effort onto other areas that are fully-exploited and possibly create additional gear conflict amongst static gear vessels".

Socioeconomic

5.20.12 Respondents commented on the importance of this area for seabird, angling and wildlife tourism and felt the MPA designation could promote this and therefore benefit the local economy further.

5.20.13 There were calls for further survey work to identify deep relic mud features in the peripheral deep basins adjacent to the Sound of Canna.

5.20.14 Environment/conservation respondents said: "As this is the best remaining area of deep burrowed mud in inshore waters it is essential to set up a monitoring programme that allows assessment of the expansion and recovery of the species and habitats in areas adjacent to the core zone"'.

5.20.15 The importance of the area for shellfish farming and scallop diving was also mentioned; respondents felt this would benefit if the seabed is protected from dredging. Respondents from the environment/conservation and local authority groups felt that the displacement costs would be outweighed by ecological benefits.

5.20.16 Respondents commented that the p MPA has the support of local communities.

Summary - Small Isles

There was support for designation and for protected features in this p MPA and requests to include various marine mammal, shellfish and seabird species.

There were some suggestions to extend the boundary to the coastline of Skye and to include the sea lochs of southern Skye and the sea areas around the Isle of Soay.

Respondents supported the management options and there were suggestions that measures should be set jointly for the MPA and the SPA that it overlaps.

5.21 South Arran

5.21.1 The protected feature which the South Arran p MPA will recover is:

  • Biodiversity: Maerl beds

5.21.2 The protected features that the South Arran p MPA will conserve are:

  • Biodiversity: Burrowed mud, herring spawning grounds, kelp and seaweed communities on sublittoral sediments, maerl or coarse shell gravel with burrowing sea cucumbers, ocean quahog, seagrass beds, and shallow tide-swept coarse sands with burrowing bivalves

5.21.3 Forty-three respondents commented on the South Arran p MPA including nine individuals and 34 organisations across most groups. In addition, many other individuals (1,315) submitted campaign text, as mentioned in Chapter 2, calling for the area to extend around Arran and for a return to the 3 mile limit with no trawling or dredging until fish stocks have recovered. Others (46) submitted a campaign plus response, as described in Chapter 1, based on the campaign text. The table below shows the total numbers commenting on this p MPA.

Table 5.9

Number commenting on the South Arran p MPA

Number commenting

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 [and variations]. (South Arran campaign)

1,315

Campaign plus responses

46

Standard responses

43

Total

1,404

Designation

5.21.4 The proposal for this p MPA came partly from a 3rd party local environment group. This organisation both replied to the consultation and also produced an alternative questionnaire as described above. In their detailed response they described the reasons behind their proposal: that the area includes a diversity of habitats, some of which are important contributors to carbon sequestration and climate change mitigation and that there is widespread support in the area for a ban on dredgers and bottom trawlers. They also commented that "many residents on Arran, visitors to the island and respondents to the MPA consultation would prefer the MPA to extend all round the Isle of Arran."

5.21.5 There was broad support from most respondents who commented for the designation, with particular support for the protection of the seagrass and maerl beds. This p MPA is one of three proposed in the Clyde and some respondents voiced support for all three. Respondents, from the environment/conservation group asked that the objectives for protected features in all three be set to recover rather than conserve as there is evidence of a decline in species richness. There was a call from individuals and a local group for seabirds to be protected within this p MPA.

5.21.6 Some of the environment/conservation respondents asked that the objective for seagrass beds should be set to recover rather than conserve as they may have been damaged by the anchorage in Whiting Bay. Respondents also asked that the other protected feature habitats in the area are set to recover "since the ecological status of the possible MPA is only 'moderate' as a result of morphological alteration from commercial fishing."

5.21.7 There was a query from an aquaculture respondent who asked for clarification as to "why this location is considered a good example of burrowed mud within the network?" A local authority made a similar comment and also voiced concern over the evidence used to support the inclusion of some benthic features.

5.21.8 Respondents, mainly individuals but also from the environment/conservation group, wanted to see bottom trawling and dredging prohibited in the area.

5.21.9 In lengthy and detailed responses, mobile fishing respondents submitted views on the 3rd party proposal to draw the boundary for this p MPA at the old 3 mile limit. These respondents said no evidence had been produced, and erroneous assumptions made, in producing the proposal. They also commented on a lack of evidence for describing the introduction of scallop dredging following the abolition of the 3 mile limit as being responsible for the destruction of the seabed. These respondents pointed out that scalloping has always been legal in fishing areas in the Clyde. In addition, the mobile fishing respondents said there had been no corroboration of the evidence submitted to support the existence of maerl at the Iron Ledges.

5.21.10 The organisation that had made the 3rd party proposal said that their data was verified by an independent consultant and the application assessed by SNH, after which the size was increased to include a maerl bed north of Blackwaterfoot.

5.21.11 The mobile fishing respondents discussed the protected features and commented that Kelp and seaweed communities on sub littoral sediment and tide-swept algae communities and Maerl or coarse shell gravel with burrowing sea cucumbers, do not appear on the OSPAR list of threatened and/or declining species, and that seagrass beds are already protected. In relation to the maerl beds, these respondents said that while these appear on the Region 3 OSPAR list, they are already protected in the Lamlash Bay NTZ which is within the boundary of the p MPA. These respondents said "designation is for the purpose of contributing towards the OSPAR ECN only, there cannot be any designation which is not for that purpose". They also wanted to see far less replication of protected features within the network. These respondents called for any evidence used to be corroborated and wanted management measures to be agreed before designation takes place. Supporting the MPA process and the intention to create a network, on OSPAR guidelines, these respondents said that in order to turn their support into assistance, "fishermen must be persuaded that the process being followed is fair and reasonable and that sacrifices which they will be asked to make are at the minimum needed to ensure compliance with the Law". They concluded that this test is not being met "in relation to compliance with the Act, the UK Act and the OSPAR Convention."

Management Options

5.21.12 Most of those who commented, particularly individuals and environment/conservation respondents, supported the management options for this site. One environment/conservation respondent, however, said that a more holistic approach to managing fishing activity across all three Clyde p MPAs should be adopted and that cumulative impact rather than case-by-case should be considered.

5.21.13 Respondents, a local authority and an organisation in the environment/conservation sector, said that the designation of this MPA will contribute to marine tourism and marine education.

5.21.14 An aquaculture respondent said that the management options should deal with pressures on a local rather than area-wide basis and that management will prove flexible and adaptable, for example in areas where a feature is predicted but is not actually present.

5.21.15 Commenting on anchorages, an industry/ transport respondent cautioned that removing anchorages would have significant impacts on safety; these anchorages are used by recreational rather than commercial vessels. On this subject a recreational/ tourism respondent said: "We welcome the commitment to explore further whether there might be an adverse effect of the anchorage in Whiting Bay. Any prohibition of anchoring would be likely to have a greater impact on the local community than on visiting recreational sailors."

5.21.16 A respondent from the static fishing group said that further evidence is needed before any changes to fishing patterns, adding that "we believe that as this area has been fished sustainably over a number of years by local fishing vessels and communities, there appears no logic to the recommendations."

Socio-economic

5.21.17 Respondents commented on the benefits designation would bring, not only to the environment but also in relation to tourism in the area, and therefore the local economy. Increased biodiversity would also benefit commercial fishermen and contribute to the local economy through sea anglers, divers and other marine activities.

5.21.18 One local authority commented that figures indicate management measures closing parts of the area to mobile fishing gear would have a "not insignificant" economic impact.

5.21.19 A local authority wanted to see the economic impact of the planned Clyde MPAs to be assessed cumulatively as well as individually.

5.21.20 A respondent from the aquaculture group suggested that costs associated with planning applications should be considered at a local level as well as nationally.

Summary - South Arran

There was broad support for the designation in both campaign responses and other responses and there were also many requests to include protection for seabirds.

Many respondents asked for the boundary to extend around Arran and for bottom trawling and dredging to be prohibited in the area, these suggestions were opposed by fishing interests.

There were calls for the objectives for protected features in this and the other Clyde p MPAs to be set to recover rather than conserve.

Fishing interests disputed the basis for designating the protected features as well as the proposed management options.

Many respondents supported the management options for this site

5.22 The Barra Fan and Hebrides Terrace Seamount

5.22.1 The protected features that The Barra Fan and Hebrides Terrace Seamount p MPA will conserve are:

  • Biodiversity: Burrowed mud and offshore deep sea muds, offshore subtidal sands and gravels, orange roughy, seamount communities, continental slope and the seamount
  • Geodiversity: Quaternary of Scotland- iceberg ploughmark field, prograding wedges, Submarine Mass Movement - continental slope turbidite canyons, slide deposits, Marine Geomorphology of the Scottish Deep Ocean Seabed-scour moat, Cenozoic Structures of the Atlantic Margin - continental slope, Hebrides Terrace Seamount

5.22.2 Seventeen respondents commented on The Barra Fan and Hebrides Terrace Seamount p MPA; two individuals and 15 organisations, many from the environment/conservation and international fisheries groups.

Designation

5.22.3 Many voiced support for the designation of what several respondents described as an important area; the seamount was described, by environment/conservation respondents as "significant to the health of Scotland's seas" due to its effect on underwater currents.

5.22.4 There was a concern that the area could be developed for oil and gas in the future.

Management Options

5.22.5 The management options were noted or agreed by many of those commenting on this p MPA.

5.22.6 Respondents commented that the area is located on the Irish / Scottish boundary and one environment/conservation respondent said that efforts should be made to ensure management is consistent across the boundary.

5.22.7 Other issues raised by the environment/conservation group included:

  • A request for clarification on the features presented as point localities.
  • Consideration of sperm whales within the management options.
  • The need for a stringent consenting process for proposed licensed activities.
  • Concern that there are no management options for the large-scale biodiversity search features seamounts and continental slope.
  • Comments on ecological damage caused by bottom trawling, and large demersal netting on or near seamounts.

5.22.8 The international fisheries group commented on the importance of the area to the French and Spanish fleets, with the Spanish fisheries respondent commenting that the habitats covered by this p MPA are not listed as of special interest in the Habitat Directive and suggesting the designated area be limited to the seamount. The French fisheries respondents wanted only the western part of the area to be designated to allow fishing to continue in the east saying in particular that the protection for orange roughy does not seem relevant for the eastern part of the area.

5.22.9 The need for robust management was stressed by a static fishing respondent who also wanted to ensure that creel fishers will not lose fishing opportunities in the designated area.

Socioeconomic

5.22.10 Many of the points made in relation to the management options were repeated here and in addition, many of the environment/conservation respondents commented on the socioeconomic impact data in the BRIA which, they felt, indicated modest displacement costs which would be outweighed by the ecological benefits. One from this group set out a list of regulation and management elements that they would like to see applied to deep-sea fishing in this p MPA.

5.22.11 The international fisheries reported that the options for this area would lead to financial losses for the French and Spanish fleet while a public sector body was concerned that there may be impacts on investment opportunities in relation to oil and gas activity in the area.

Summary - The Barra Fan and Hebrides Terrace Seamount

There was broad support for the designation and management options although some wanted to see changes to the boundary, stressing the importance of the area for fishing interests.

5.23 Turbot Bank

5.23.1 The protected feature which the Turbot Bank p MPA will conserve is:

  • Biodiversity: Sandeels

5.23.2 Thirteen respondents commented and this included two individuals and 11 organisations; many of the organisations were from the environment/conservation group and many voiced support for the designation of this p MPA.

Designation

5.23.3 There were comments, from the environment/conservation group, that the objective for sandeels should be recover rather than conserve and some commented that there has been no sandeel monitoring in the area, therefore its status is unknown. The environment/conservation group also commented that many seabirds from mainland colonies also use the area; this should be considered when deciding the management plan.

Management Options

5.23.4 The environment/conservation group did not want to see a targeted sandeel fishery in the Turbot Bank p MPA. This group also commented that there is no discussion of bottom impact on sandeels although dredging takes place on the site and that evidence is needed to show this does not impact on the sandeels. There were also calls to include offshore subtidal sands and gravels as a protected feature in this area.

5.23.5 There was again support for the p MPA from a static fishing respondent with the proviso that creel fishers will not lose any fishing opportunities.

Socioeconomic

5.23.6 Respondents, from the environment/conservation and static fishing groups, listed economic and wellbeing benefits from designating this area. The environment/conservation groups also said: "A decrease in sandeel spawning stock biomass induces a higher cannibalism for cod and whiting, leading in turn to a decrease in spawning stock biomass and yield for those predator species. This should be considered as part of the environmental baseline and a switch away from cannibalism should be considered as a benefit of designating this site."

5.23.7 Again, there were requests that the objective for sandeels change from conserve to recover so that the site may "benefit the wider North Sea through the provision of sandeel larvae, and contribute to attaining the obligations under the Birds Directive for the seabird colonies using the site for foraging."

Summary - Turbot Bank

There was broad support for the designation with some also calling for the objective for sandeels to be recover rather than conserve.

5.24 Upper Loch Fyne and Loch Goil

5.24.1 The protected feature which the Upper Loch Fyne and Loch Goil p MPA will recover is:

  • Biodiversity: Flame shell beds

5.24.2 The protected features that the Upper Loch Fyne and Loch Goil p MPA will conserve are:

  • Biodiversity: Burrowed mud, horse mussel beds, ocean quahog, and sublittoral mud and mixed sediment communities

5.24.3 Comments on the Upper Loch Fyne and Loch Goil p MPA were noted in 38 responses including 12 from individuals and 26 from organisations; many of the organisations were from the environment/conservation group. This p MPA is one of three proposed in the Clyde area, along with Clyde Sea Sill and South Arran; many comments on this p MPA relate to all three of these sites.

Designation

5.24.4 Many respondents who commented voiced support for the designation of the Upper Loch Fyne and Loch Goil p MPA.

5.24.5 Environment/conservation respondents wanted to see fireworks anemones and the Arctic relic seasquirt Styela gelatinosa in Loch Goil added to the protected features as well as the sheltered rock reefs in both lochs. These respondents wanted to see objectives for all protected features in this area as recover rather than conserve.

5.24.6 An aquaculture respondent asked for clarification on the pressures that sublittoral mud and mixed sediment communities are sensitive to as, they commented, this feature is not considered in the Feature Activity Sensitivity Tool ( FEAST matrix).

5.24.7 Individuals felt that whitefish stocks in the Clyde have been affected by overfishing, dredging and trawling. There were reports of serious gear conflicts and creels being lost and comments on the need for good management and good communication.

5.24.8 A local authority supported the designation but noted that there is uncertainty over the distribution of the protected features. This respondent pointed out inconsistency in different documentation between recover and conserve which needs to be corrected and clarified.

Management Options

5.24.9 An aquaculture respondent had several queries and requests for clarification on the management options such as what is meant by expansion in the 'reduce or limit pressures associated with expansion of existing finfish farms etc'.

5.24.10 An environment/conservation respondent made a large number of points. They wanted all objectives to be set as recover rather than conserve. This respondent cautioned that any shellfish farms should be sited away from finfish farms to avoid any contamination of farmed and wild shellfish. They saw finfish farms as incompatible with MPA objectives and wanted to see no further expansion and for existing farms to complete environmental impact assessments. Other comments included disagreement with SNH recommendations on trawling and dredging; this responded saw the need for proper regulation of bottom trawlers and said that trawling and dredging should not take place within the Clyde MPAs. Creeling should also be managed to ensure sustainability and scallop diving should be kept under regular review.

5.24.11 Other environment/conservation respondents commented that management must consider the whole area and not just sites with aquaculture activity as some pressures such as pollution are not contained to these sites. As well as removing bottom mobile gear, these respondents also agreed that pressures associated with static gear should be removed from the flame shell and horse mussel beds but some also wanted to see it removed from ocean quahog areas and muds which may contain fireworks anemones.

5.24.12 One environment/conservation respondent said that a more holistic approach to managing fishing activity across all three Clyde p MPAs should be adopted and that cumulative impact rather than case by case should be considered.

5.24.13 Individuals were concerned that there had been overfishing in the past and some wanted to see trawling, dredging and creel fishing stopped in the area.

5.24.14 A static fishing respondent supported this p MPA with the proviso that creel fishers will not lose any fishing opportunities. Another from this group wanted to see more evidence before any changes to fishing patterns are implemented and also commented on the importance of this area to the Kintyre fleet in winter months.

Socioeconomic

5.24.15 A environment/conservation respondent said that: "The socioeconomic Sustainability Appraisal assumes that there will be no displacement of fishing effort and that there will be a net loss of income to fishermen. However the Strategic Environmental Assessment assumes that there will be displacement and this may have a detrimental impact on other areas." Another respondent noted an inconsistency between the BRIA and management options paper.

5.24.16 While some respondents from the environment/conservation group felt that displacement costs would be outweighed by ecological benefits, another from the same group was concerned "about the resultant socioeconomic losses where sustainable operations may be curbed or altered, particularly due to indirect effects of fishing activity displacement".

5.24.17 A local authority wanted to see "the economic impact of management measures for the three MPA proposals within the Firth of Clyde are considered cumulatively as well as individually".

5.24.18 One aquaculture respondent wanted to see costs associated with new planning consent considered in the socioeconomic assessment.

Summary - Upper Loch Fyne and Loch Goil

There was broad support for the designation with some also calling for additional protected features and for all protected features in this area as recover rather than conserve.

There were many suggestions and some requests for clarification with regards the management options.

5.25 West Shetland Shelf

5.25.1 The protected feature which the West Shetland Shelf p MPA will conserve is:

  • Biodiversity: Offshore subtidal sands and gravels

5.25.2 Twelve respondents commented on the West Shetland Shelf p MPA and this included four individuals and eight, mainly environment/conservation, organisations.

Designation

5.25.3 Most respondents who commented at this question supported the designation of this p MPA.

Management Options

5.25.4 Environment/conservation respondents welcomed the proposals to prohibit bottom-contact mobile fishing gear in this area, and welcomed this approach in the current Windsock Fisheries Area. These respondents suggested there should also be some designated zones prohibiting static gear "to ensure sizable proportions of marine fauna have reduced pressure from harvesting and have opportunity for future enhancement." There were also comments on the need to regulate any licensed industry activities.

5.25.5 A public sector respondent offered details of existing assets, such as power cables, in the area.

5.25.6 The management options say that that no additional management is required in relation to bottom contacting mobile gear as no mobile gear fisheries currently take place in the area. There was concern, from a mobile fishing respondent, over this option as they felt that where there is no evidence of damage, there should be no management measures.

Socioeconomic

5.25.7 Respondents from the environment/conservation group saw the figures on displacement and cost of designation as relatively small when compared to potential ecological benefit.

Summary - West Shetland Shelf

A small number commented on this p MPA and supported the designation and management options.

5.26 Wyre and Rousay Sounds

5.26.1 The protected features that the Wyre and Rousay Sounds p MPA will conserve are:

  • Biodiversity: Kelp and seaweed communities on sublittoral sediment, and maerl beds.
  • Geodiversity: Marine Geomorphology of the Scottish Shelf Seabed

5.26.2 Twenty respondents commented on the Wyre and Rousay Sounds p MPA; three individuals and 17 organisations (mainly public sector, recreation/ tourism and environment/conservation).

Designation

5.26.3 Most of the comments made by respondents supported the designation of the Wyre and Rousay Sounds p MPA although one local group wanted to see it extended around the south and east of Wyre. There were several comments on the importance of the maerl beds.

Management Options

5.26.4 The management options were supported by most of those who commented.

5.26.5 A public sector respondent questioned the description of the anchorage in the area as commercial; they saw it more as historical and would support its removal due to the proximity to power cables. An industry/ transport respondent, however, said that safety factors may have led to this anchorage and this should be taken into account in any proposal to relocate. There was a comment that the summary contradicts the text of the management options with regards recreational anchoring.

5.26.6 A recreation/ tourism respondent was concerned about the effect on maerl beds of a number of salmon farms in the area and an environment/conservation respondent said they would support relocation of any farms that are causing damage to protected features. A proposed finfish farm was noted; some respondents felt this would have a negative impact on the maerl beds; one mobile fishing respondent said that there had been flaws made in assumptions over pollutants in respect of this application. Other respondents noted their support for the proposed management option to limit development of new sites or expansion of current finfish farms. Respondents from various groups commented on the need to ensure no harmful chemical effects from salmon farming in the area.

5.26.7 Commenting on farms in the area, a local authority supported the acknowledgement there would not be any restriction or infringement on existing farms and wanted to see minimal disruption to their operations. This respondent also said they would oppose any measures to restrict the activity or growth at a crab, lobster and scallop fishery in the area.

5.26.8 There were comments from the environment/conservation group on the need to monitor any impact caused by static gear and hand-dived bivalve fishery. This group also commented on a lack of detailed information on the impacts of aquaculture and said that precautionary management measures should be used.

5.26.9 A mobile fishing respondent queried a limit on hand-diving saying that "if conserving maerl is the objective of the designation then this management option would seem to be irrelevant."

5.26.10 A public sector respondent offered details of existing assets, such as power cables, in the area.

5.26.11 Commenting on a potential tidal energy development in a nearby site, environment/conservation respondents said: "it is imperative that any possible impact on changes to the tidal regime affecting the excellent quality habitats in Wyre and Rousay Sound should be fully considered."

Socioeconomic

5.26.12 Environment/conservation respondents commented that static gear and dived fisheries may benefit from a reduction in mobile gear in the area. These respondents also felt there would be positive benefits; both economic and in relation to emotional wellbeing; amongst divers and anglers.

5.26.13 There was a call for a "comprehensive socioeconomic study into the current and non-damaging nature of the fishing activity in the area" and for guarantees that current fishing activity would continue.

Summary - Wyre and Rousay Sounds

Respondents supported the designation and management options.

A number of respondents commented on the impact of or on existing and proposed finfish farms in the area.

5.27 Site summaries

5.27.1 This Chapter presents summaries of responses, from both campaign and standard consultation responses, relating to the sites discussed in Chapters 5.1 to 5.26.

Summary - Clyde Sea Sill

5.27.2 There was support for the designation of this MPA and for the protected features; there were requests to include the kelp forest and other seabird species.

5.27.3 Several respondents pointed out that data used for species counts are 15 years out of date and wanted to see this addressed.

5.27.4 The management options were welcomed.

5.27.5 Respondents, across various organisational groups, felt that designation would be beneficial to the area in terms of both the economy and well-being.

Summary - East Caithness Cliffs

5.27.6 There was support for designation and for protected features in this p MPA and requests to include the kelp forest and other seabird species.

5.27.7 Some felt that this p MPA should be considered in the draft seaweed consultation

5.27.8 Several respondents pointed out that data used for species counts are 15 years out of date and wanted to see this addressed.

5.27.9 The management options were welcomed and there was welcome for the alignment of this p MPA with the existing SPA in the same area.

Summary - East of Gannet and Montrose Fields

5.27.10 There was support for designation and for the management options. The importance of the ocean quahog and offshore deep sea mud and gravel communities was specifically noted. There were, however, a small number of concerns with regards to the economic importance of this area, especially with regards to Oil and Gas interests.

Summary - Faroe-Shetland Sponge Belt

5.27.11 There was support for designation and for the management options although a number of respondents would support a smaller area.

5.27.12 There were differences in opinion between sectors (particularly environment and fishing) over restrictions on fishing in the area.

Summary - Fetlar to Haroldswick

5.27.13 There was support for designation and for protected features in this p MPA and requests to include other seabird species. There were calls for the objective for horse mussel beds, maerl beds, and kelp and seaweed communities to be recover rather than conserve.

5.27.14 The management options attracted broad support and there was welcome for the inclusion and recognition of existing measures.

5.27.15 A small number of respondents wanted to ensure that those involved in fishing the area are consulted over the plans for reducing or limiting pressures from any fishing activity.

5.27.16 While there were some calls to extend dredging restrictions across the area, extend anti-predator methods to a 5km radius from nest sites and relocate any farms causing damage, there were also concerns over potential impacts on the shellfish business, with consequent impacts for employment and other factors in the area.

Summary - Hatton-Rockall Basin

5.27.17 A small number commented and supported the designation and management options.

Summary - Loch Creran

5.27.18 There was broad support for the designation and management options.

5.27.19 Some would prefer the objective of recover rather than conserve for the flame shell beds.

Summary - Loch Sunart

5.27.20 There was broad support for the designation and management options.

5.27.21 Some would prefer the objective for the features, and especially the serpulid aggregations, to be recover rather than conserve.

5.27.22 There were differences in opinion between sectors over restrictions on fishing in the area.

5.27.23 Some commented on the need to involve local communities and all other stakeholders in the management of the p MPA.

Summary - Loch Sunart to the Sound of Jura

5.27.24 There was broad support for this designation but also several suggestions for changes including extending the area, reducing the area and adding various seabird species to the protected features.

5.27.25 While there was broad support for the management options, again there were some differences in opinion between sectors over restrictions on fishing in the area.

5.27.26 There were comments on a lack of data, especially in relation to the common skate.

Summary - Loch Sween

5.27.27 There was broad support for this designation and management options. Some respondents felt the objectives for the maerl beds and native oyster should be recover rather than conserve.

5.27.28 There were calls for a more realistic assessment of fishing levels in the area and clarity over the likely levels of fishing restrictions. Some asked for recreational anchorages to be reviewed to ensure these are not in the vicinity of maerl beds.

Summary - Loch Duich, Long and Alsh

5.27.29 There was broad support for this designation. Some respondents wanted to see the objective for burrowed mud set to recover rather than conserve. There were some calls to add fan mussels to the list of protected features; again set to recover.

5.27.30 There was also broad support for the management options.

Summary - Monach Isles

5.27.31 There was support for designation and for protected features in this p MPA and requests to include other seabird species and for kelp forests to be protected. Some felt that this p MPA should be considered in the draft seaweed consultation

5.27.32 The management options were broadly supported.

Summary - Mousa to Boddam

5.27.33 The designation was agreed although there were some suggestions that the boundary should change to include possible sandeel habitat beyond the proposed area.

5.27.34 Some called for the objective for sandeels to be set as recover rather than conserve and for kelp forests to be protected.

5.27.35 There were also calls for research into the impact of demersal dredge on sandeels.

Summary - North-east Faroe Shetland Channel

5.27.36 Most respondents supported the designation but there was acknowledgement of the importance of the area to the fishing industry with respondents asking for monitoring and compliance of fishing activity as well as engagement with the industry.

5.27.37 There was some concern that there are no management options to protect the continental slope.

Summary - North-west Orkney

5.27.38 Most respondents supported the designation although some called for the objective for sandeels to be set to recover rather than conserve.

5.27.39 Most supported the proposal to limit any future sandeel fishery in the area.

Summary - North-west sea lochs and the Summer Isles

5.27.40 While there was support for the designation there were also conflicting suggestions; some wanted to see the area extended while others felt it should be reduced.

5.27.41 There were calls to add seagrass beds and sea trout to the protected features.

5.27.42 Some suggested the area should be called Wester Ross to give a clear local identity, foster local interest and give a greater sense of local ownership.

5.27.43 There was support from most respondents for the management options.

Summary - Noss Head

5.27.44 There was broad support for the designation and the management options for this p MPA.

Summary - Papa Westray

5.27.45 There was support for designation and for protected features in this p MPA and requests to include the kelp forest and other seabird species.

5.27.46 Some felt that this p MPA should be considered in the draft seaweed consultation.

5.27.47 There was broad support for the management options.

Summary - Rosemary Bank Seamount

5.27.48 A small number commented; most supported the designation and the management options for this p MPA.

Summary - Small Isles

5.27.49 There was support for designation and for protected features in this p MPA and requests to include various marine mammal, shellfish and seabird species.

5.27.50 There were some suggestions to extend the boundary to the coastline of Skye and to include the sea lochs of southern Skye and the sea areas around the Isle of Soay.

5.27.51 Respondents supported the management options and there were suggestions that measures should be set jointly for the MPA and the SPA that it overlaps.

Summary - South Arran

5.27.52 There was broad support from both campaign and standard consultation respondents who commented for the designation along with requests to include protection for seabirds.

5.27.53 Many respondents asked for the boundary to extend around Arran and for bottom trawling and dredging to be prohibited in the area; these suggestions were opposed by fishing interests.

5.27.54 There were calls for the objectives for protected features in this and the other Clyde p MPAs to be set to recover rather than conserve.

5.27.55 Fishing interests disputed the basis for designating the protected features as well as the proposed management options.

5.27.56 Many respondents supported the management options for this site

Summary - The Barra Fan and Hebrides Terrace Seamount

5.27.57 There was broad support for the designation and management options although some wanted to see changes to the boundary, stressing the importance of the area for fishing interests.

Summary - Turbot Bank

5.27.58 A small number commented and most supported the designation with some also calling for the objective for sandeels to be recover rather than conserve.

Summary - Upper Loch Fyne and Loch Goil

5.27.59 There was broad support for the designation with some also calling for additional protected features and for all protected features in this area as recover rather than conserve.

5.27.60 There were many suggestions and some requests for clarification with regards the management options.

Summary - West Shetland Shelf

5.27.61 A small number commented on this p MPA and supported the designation and management options.

Summary - Wyre and Rousay Sounds

5.27.62 Respondents supported the designation and management options.

5.27.63 A small number of respondents commented on the impact of or on existing and proposed finfish farms in the area.

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