Our guidance on responding to the marine consultation

Fisheries management measures within Scottish inshore Marine Protected Areas (MPAs) and proposed Priority Marine Feature (PMF) management areas

 

Why this consultation matters

Scotland’s seas are home to internationally important wildlife and habitats, including whales, dolphins, seals, seabirds, and a range of seabed habitats, from burrowed mud to living reefs. But Scotland’s seas are in decline. Loss of marine nature and the effects of climate change, as well as increasing human activities, mean that our seas are in poor health. Many of Scotland’s threatened marine species and habitats are identified as needing protection through Marine Protected Areas (MPAs). 

The Scottish Government is consulting on new fisheries management measures designed to protect these species and habitats in MPAs. These measures include restrictions to bottom trawling, dredging and some forms of static gear (nets, lines and pots).

Following protection measures for the most vulnerable inshore sites in 2016, and for offshore sites in 2025, this is one of the biggest opportunities in decades to improve protection for Scotland’s marine environment.

Your response matters. Decision-makers do not only count responses. They consider the issues raised, the strength of public support for different options and local knowledge and experience. A personal response can help strengthen protection for Scotland’s seas.

 

How to take part in the consultation

EITHER

  1. Complete the online consultation form. The Scottish Government has produced a video explaining how to complete the consultation questionnaire.

 

OR

  1. Submit a Word document response to the following email address: [email protected]

If you find the online form difficult to navigate, you can simply submit a written response – download the “Respondent Information Form” on this page: https://www.gov.scot/publications/proposed-fisheries-management-measures-inshore-marine-protected-areas-mpas-proposed-priority-marine-feature-pmf-management-areas-consultation-paper/documents/ 

 

You do not need to answer every question – it is fine just to focus on the sites or issues you care about the most.

 

 

Share your own experience

Local knowledge is extremely valuable in consultations like this. If you have personal experience of:

Consider including these perspectives in your response. Real-world examples can help decision-makers understand how measures affect people and nature in practice, rather than just in theory. 

 

What we recommend

For many of the sites, the consultation only proposes one option. Where there are two options, we recommend supporting option 2, as it offers stronger protection than option 1.

While option 1 proposals could help preserve marine species and habitats in their current state, we are concerned that these proposals would only protect an already degraded marine environment. Scotland’s marine environment has been in decline for many years, and we believe option 2 offers our seas a better chance to recover.

If you have any questions or wish to discuss the options further, please contact Scottish Environment LINK on [email protected].  

 

Marine protected areas (MPAs, SACs and SPAs)

Generally, option 2:

Suggested wording:

I support option 2 because it provides stronger and more effective protection for the site’s protected habitats or species, to give protected species and habitats a better chance to recover. The Scottish Government should take the approach that gives the best chance of nature recovery, where evidence shows a risk from fishing activities.

 

 

Where measures should go further

While option 2 is the strongest option available in the consultation, there are some important areas where the consultation does not go far enough. You may wish to include additional comments asking the Scottish Government to strengthen measures further.

 

Better protection for marine mammals 

For species such as harbour porpoise, dolphins, whales, basking shark and seals:

 

Tackling whale, basking shark and seal entanglement

You could support:

 

Better monitoring and enforcement

You could also suggest:

 

Protecting food supplies for seabirds and marine mammals

Many seabird populations are declining dramatically, and marine mammals are at risk. You may wish to support:

 

PMF protection outside MPAs 

The consultation also proposes protection for 11 Priority Marine Features (PMFs) outside MPAs, such as maerl beds, seagrass beds, horse mussels and flame shell beds. These habitats provide food, shelter and nursery areas for marine life, and can take decades to recover if damaged.

However, the areas proposed for these additional protections are relatively small, offering protection only to remnant patches of habitat that haven’t been removed by human impacts. Where there is a choice between options, we recommend supporting option 2, as it generally protects a larger area and includes more habitat.  

Suggested wording:

I support option 2 because it provides stronger protection for Priority Marine Features and offers greater confidence that sensitive seabed habitats can recover from previous damage.

 

Ask for stronger PMF protection

The current proposals are an important step but do not fully address the scale of seabed degradation in Scottish waters.

We recommend that, in addition to asking for option 2, you also ask the Scottish Government to:

  1. Protect a wider area for these PMFs – the proposed management areas are relatively small. We think a wider, more joined-up range of their area should be included in the proposals, as this will allow seabed habitats to recover and function with much greater resilience.
  2. Protect more PMFs – there are 81 PMFs in total, with only 11 being supported with management measures in this consultation. Many important habitats and species, such as kelp beds, remain outside the proposed management areas. Additional PMF protection is needed to support recovery of marine ecosystems and improve overall ocean health.

Suggested wording:

I welcome the proposed PMF measures but believe they should be expanded to cover a wider range of PMFs and a larger proportion of their known distribution.

 

Understanding the assessments of benefits and costs

The consultation includes estimates of the costs and benefits associated with the proposed measures. These are highly technical and legally required for the purpose of the exercise.

 

What are these assessments for?

These assessments are intended to help decision-makers and the public understand:

They are one source of evidence among many and should not be viewed as predictions of exactly what will happen.

 

Why should they be treated with caution?

Many environmental benefits are difficult to measure in monetary terms, so they are presented in these assessments in descriptive terms. Possible environmental benefits include things like the recovery of the seabed, increased ecosystem resilience, improved carbon storage, benefits to wildlife, and better functioning ecosystems.

Similarly, economic impacts can be difficult to estimate accurately because they depend on how industries adapt over time. They are presented in these assessments as estimated losses in monetary terms. This makes them very difficult to compare to the possible benefits, as they are not presented in the same terms. It’s like comparing the quality of apples vs cheese.

We think that these assessments can be biased in that:

If you want to mention the assessments in your consultation response, you could highlight that:

 

Additional resources to help you respond 

Supporting sustainable fishing 

Protecting the sea and supporting fishing communities must go hand in hand. The Scottish Government should provide sufficient short-term support to help affected businesses through the transition so they can adapt, survive and benefit from a more productive and resilient marine environment these measures should help to create. Fishers should be able to capture greater value from a healthier ecosystem.

The cost of change should not fall on the shoulders of fishing businesses. There must be significant investment of resources in helping affected operators adapt and remain viable – simply compensating loss may not be sufficient or desired. We would like to see well-resourced opportunities for support such as collaborative local management, gear modification, moving to lower-impact fishing methods, vessel adaptations, market and added-value opportunities, and training and skills development. 

Lyme Bay Fisheries and Conservation Reserve in southwest England is an example where restrictions on bottom-towed gear led to collaborative management, improved seafood branding, better cold storage and landing facilities, marketing of sustainable products and fisher-led governance. Ecological recovery was evidenced alongside reported benefits for many local static gear fishers. Examples like this show that conservation outcomes are strongest where governments invest in helping fishers adapt, participate in and benefit from the recovery of the marine environment.

 

Evidence of long-term decline in Scottish marine ecosystems

Breeding seabird abundance in Scotland fell by around 41% between 1994 and 2019, with species such as kittiwake and puffin affected by climate change and food shortages – and that was before the avian flu outbreak.

The most recent national seabird census found that almost two-thirds of Scotland’s breeding seabird species declined over the last two decades.

Historically widespread habitats such as seagrass meadows, maerl beds and native oyster reefs have become fragmented and greatly reduced in extent, making them less resilient to pressure and less able to support marine life.

The Scottish Government recognises that marine ecosystems have experienced historic degradation and that restoring habitats is necessary to improve biodiversity and ecosystem resilience.

 

 

Glossary of terms

Marine Protected Area

Designated areas of seas or coasts where human activities are restricted by law to protect or recover marine species, habitats, and cultural resources.

 

Special Area of Conservation (SAC)

A strictly protected site designated to safeguard rare, threatened, or valuable natural habitats and species of international and national importance. 

 

Special Protection Area (SPA)

A strictly protected site designated for rare, threatened, or valuable bird species. In this consultation, these are sites for breeding or non-breeding seabirds.

 

Bottom trawling

Fishing by towing a large, heavy net along or just above the seabed.

 

Hydraulic (suction) dredging

A fishing method that uses jets of water to disturb the seabed and dislodge shellfish.

 

Mechanical dredging

Fishing by dragging metal gear across the seabed, often used for scallops.

 

Gill net

A net fixed in place which catches fish and can accidentally entangle seabirds, marine mammals and basking sharks.

 

Longline

A fishing line with many baited hooks that is dangled in the water. Seabirds sometimes get accidentally caught on these.

 

Maerl beds

A slow-growing habitat formed by hard (calcified) living algae. It provides a home to lots of smaller species and is very delicate, and takes a long time to recover from damage.

 

Seagrass

An underwater flowering plant that provides habitat for fish and other species and can help to absorb and store carbon from the atmosphere (which can help tackle climate change).

 

Horse mussel beds

Aggregations of horse mussels, a type of shellfish, that create habitat for lots of other species.

 

Flame shell bed

A shellfish with a distinctive fringe of bright orange tentacles. They grow in large numbers and bind gravel to make nests, which also bind together with neighbouring nests, creating a complex habitat for other species.

 

Intertidal

The area between high and low tide. It is only sometimes covered by seawater, depending on the tide.

 

Subtidal

Areas that remain underwater all the time.

 

Quaternary of Scotland

Seabed deposits and landforms created during the Ice Age and post-glacial periods.

 

Bycatch

Animals caught unintentionally by fishing that is targeting other commercially-sought species.

 

Remote Electronic Monitoring (REM)

Cameras and sensors installed on fishing vessels to record details about the fishing trip and what is in the catch, to help with monitoring, compliance and data collection.

 

See also NatureScotland Young Sea Changers Scotland’s jargon buster.

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