(Submitted as a personal response to the consultation: would be interested to hear any other comments that were made in response to http://www.scotland.gov.uk/Topics/marine/marine-consultation)

Background

My comments are confined to the territorial waters element Southeast Marine Region (Between Montrose and Berwick and out to the 12-mile limit), as that is where the bulk of my interest and experience lies. Not only does this area see the densest marine traffic (including all Grangemouth refinery traffic) in and out of the Firth of Forth but it also is to be the focus of three major offshore wind farms. With an average depth around 50m, concern about sustainable stewardship of the seabed becomes a concern because of the demands made on it.

Map of Scotland’s Seas: (Note how much larger they are than Scotland—or England

Issues of Concern

Currently there is no proposal for an MPA in the Southeast Marine Region. Because of its proximity to dense population centres and various pressures on it, the provision of an MPA should be considered for five reasons:

1. Inshore (generally above the 20m depth line), unregulated fishing of crustaceans and removal of shore-bound shellfish (razor clams, whelks, mussels, etc) is damaging stocks and undermining sustainability. This lack of reserved areas (c.f. Maine USA) means conservation is actively discouraged and the free-for-all that devastated fish stocks and led to EU quotas is underway. The concept of Several Orders founders on the lack of local inshore fishermen’s organisations to define, legislate, implement and enforce them.
2. The shallowness of water in the area allows easy trawl and dredge access to the seabed of the whole area. While prawn/langoustine fishing is generally non-destructive, scallop dredging is damaging to seabed life in general. Both are currently carried out without regulation and the demand from this area, being so close to its markets, is far heavier than, say, in the Western Isles.
3. Whereas most wildlife is found to the North and West of Scotland—especially seabirds, a huge exception to this are the Forth islands that are home not only to the largest gannetry in the world and major puffin colonies but also to the Scottish Seabird Centre which is an award winning world leader in making Scotland’s maritime wildlife accessible to a wide public in a sustainable way. These populations have been threatened in the past (e.g. overfishing of sand eels by Danish fertiliser processors and invasion of Bass Mallow that decimated puffin colonies by blocking their nest sites). To continue with an open season in their key fishing area (most can fly less than 20km from base to feed in the nesting season) risks decimating their food sources.
4. Because of its very different geography to the heavily indented West Coast and the absence of any significant sheltered waters protected from Northeasterlies, there are no 24/7 quiet water sites where fish farms or shellfish farms would be viable as an alternative.
5. From an economic development viewpoint, local fisheries in the Southeast Marine Region are barely exploited. Most of the catch is wholesaled at points like Eyemouth; most of the local catch is consumed by visitors in Spain. With no security of supply, the incentive to invest in keep tanks, hatcheries, shared marketing and distribution to a disorganised spectrum of retail outlets means this situation is likely to continue indefinitely, despite Scotland being a byword in fresh quality foods in which East Lothian is generally a leader.

Possible Actions

If the present situation continues, then all five of the concerns raised above are likely to continue and probably worsen. It appears to make little sense to provide MPAs in remote sites if those accessible by the bulk of the population (especially in the tourist season when they are joined by thousands of English and foreign tourists) are to lack any and suffer the consequences to wildlife and its sustainability. Actions to be considered before significant and irreversible damage occurs would include:

1. Consider an MPA for the outer Forth and Tay that would permit continued fishing of all species but with effects on feed-stocks for wildlife monitored and capable of triggering restrictions.
2. Facilitate the establishment of fishermen’s associations empowered to manage inshore stocks and receive financial support in providing infrastructure such as hatcheries and regulating access to areas for specific species to both enhance and protect stocks and businesses in a long-term sustainable manner.
3. Lobby the appropriate government to avoid intrusion by others into the fisheries, including those that are known to be a key species in sustaining wildlife.
4. Consider establishing a hands-on enabling agency that combines fisheries research (c.f. the former Seafish research unit at Ardtoe) with guidance in stock conservation and funding for infrastructure through the local fishermen’s associations so that they are seen to be both necessary and useful.

Conclusions

The consultation on Marine Protected Areas is timely but appears to have been poorly conceived when it comes to the special conditions in the Southeast. By being the most accessible and visible and having the most potential to provide economic benefits from marine resources, this should be considered as a prototype how an MPA could be seen as a force for progress and good, instead of the reactive and bureaucratic tangle of the (deep-sea only) CFP that causes such anger among our professional fishermen of the Northeast.