Response to the Scottish Government Consultation on Inshore MPA/SAC Management – Revised Conservation Orders

Summary

• LINK members support the Scottish Government’s process to establish a network of well-managed marine protected areas and develop proportionate management of anthropogenic activities within the sites. Evidence indicates that well-managed MPAs will not only result in an improvement to the environmental condition of Scotland’s seas, but should provide secondary benefits in the form of increased fishing opportunities and positive displacement to areas that may not have previously be fished.
• LINK members are concerned that the amended derogations for the three draft Marine Conservation Orders (MCOs) will reduce the likelihood of conservation objectives being met (by leaving protected features vulnerable) and diminish the potential for increasing the health of the Scottish Marine Area (by, amongst other things, leaving other Priority Marine Features at risk).
• LINK members are disappointed that these proposals appear to be a step backwards, applying derogations to areas where fishing has historically taken place, rather than where the ecology requires it, and increases boundary complexity. Respondents to the original consultation (2014/15) called for simplicity to support effective monitoring and compliance, which are dependent on co-operation from sea users and integration of Automatic Identification Systems (AIS) in all fishing vessels. The environmental and economic basis for the MCO revisions need to be more transparent, particularly where fisheries derogations appear to have been amended to accommodate key fishing grounds.
• The revised MCOs risk compromising the life history of some of the protected features. For example, fishing derogations in shallow areas likely to be important for common skate spawning and nurseries in Loch Sunart to the Sound of Jura MPA/SAC, and foraging grounds for breeding black guillemot in Small Isles MPA.
• We support the Scottish Government’s proposal to assist fishing businesses that may be affected by the management measures, (such as displacement and diversification of fisheries) by supporting access to funding, such as the European Marine Fisheries Fund. Any other secondary implications due to new fisheries