SSACN and representatives of 7 other organisations who recently made separate submissions to the public consultation on the management of MPAs and SACs have jointly written to Cabinet Secretary Lochhead expressing concerns that the guidance for developing the management of MPAs has been interpreted in a way which risks diluting the measures such that they will not be effective in securing the objective of the long-term health of our inshore waters.
Whilst collectively re-stating our support for the development of an ecologically coherent network of well-managed MPAs in Scotland we are concerned that:
- The conservation objectives of MPA sites have been too narrowly determined.
The contribution of a feature to the function1 of an MPA and wider seas ecosystem must be a primary factor in determining the conservation objectives. We are concerned that by only considering the conservation status of individual protected features in isolation, rather than considering their interconnectedness within the designated MPAs and beyond to wider marine ecological function, and vice versa, an opportunity to enhance the health of the marine ecosystem within and beyond MPA site boundaries risks being lost.
In short, the key point of protected areas is that the whole is greater than the sum of the parts.
We are concerned that the preferred management approaches risk failing s.83(b)(iv) and s.83(10) of the Marine (Scotland) Act 2010.
- Appropriate Assessments of fishing impacts may not be adequately carried out, and their findings adhered to.
Before management decisions are made Article 6(3) of the EC Habitats Directive requires an Appropriate Assessment of the implications of all forms of fishing activities carried out in SACs that are deemed to have a Likely Significant Effect on the relevant site.
Where the Appropriate Assessment reveals that fishing will adversely affect the integrity of the site, it must be prohibited or restricted, unless it is considered to satisfy the test of overriding public interest in Article 6(4) and, in such a case, relevant compensatory measures must be taken.
It is not good environmental management to protect the bare minimum and hope for the best.
We must use this opportunity for designing protected area management that genuinely future-proofs our natural marine ecosystem. In so doing we will also enhance the economic and social contribution that our seas make to coastal and other communities. Recognising that fisheries management within the MPA network closely interacts with wider fisheries policy considerations, we also look forward to Marine Scotland considering how to take forward its recently-commissioned work in this area, namely the Assessing the Options for Change (2015) report.
The letter was signed by the following :
Andrew Binnie, Community of Arran Seabed Trust
Nick Riddiford, Fair Isle Marine Environment Tourism Initiative
Kerri Whiteside, Fauna & Flora International
Alistair Sinclair, Scottish Creelers and Divers
Calum Duncan, Scottish Environment LINK marine taskforce
Ian Burrett, Scottish Sea Angling Conservation Network
David Ainsley, Sealife Adventures
Charles Millar, Sustainable Inshore Fisheries Trust
Category: Other Organisations