Lochs Duich, Long and Alsh MPA/SAC

Read our response to the 2015 consultation on management measures for this site here:

We do not support the preferred management approach for the Lochs Duich Long and Alsh
MPA/SAC, which would allow mechanical dredging in an area which overlaps with Annex 1 reef
features and burrowed mud habitats for 6 months of the year.

We agree with the management advice to remove/avoid pressure from flameshell beds and reef
features. However we do not agree with the management advice to reduce/limit pressure on the
burrowed mud features, as many of the component species of burrowed mud are highly sensitive to
disturbance by mobile demersal fishing gear such as trawling.

We note that the existing fishing area demarcated in the middle of this site is considerably larger and
different in shape to the equivalent zone illustrated in Marine Scotland’s fisheries displacement
study in early 2014. We request clarification as to why the shape of this zone has changed. However,
regardless of the shape of this permitted fishing area, we contend that the only approach that is
likely to fulfil the conservation objectives of this SAC/MPA is to prohibit the use of mobile demersal
fishing gear throughout the whole site. This would also have the effect of simplifying the problems of
fisheries compliance as it would otherwise be difficult to tell whether vessels are within the
permitted area. It is not appropriate to allow such fishing activities to take place on Annex 1 reef,
even at a lower vessel capacity, as any level of trawling and dredging has the potential to damage
reef structure or remove delicate species associated with these habitats. Historical data from the
VMS shows that considerable amounts of mobile demersal gear use have occurred on Annex 1 reef
habitats and this is likely to continue with the proposed approach. Furthermore, we are concerned
about the indirect effects of trawling and dredging, such as smothering of features due to increased
suspended sediment, especially given the proximity of the western boundary of the fishing zone to
the flame shell beds.

We suggest that with a site-wide prohibition on mobile demersal gear, the existing fishing area could
then be used to carry out research on the environmental impacts of creel fishing on burrowed mud
and Annex 1 reef features, as there is currently little documented research on this subject.

Read our response to the 2013 site consultation here:

Save Scottish Seas campaign members have assessed the Scottish Government’s MPA proposal for this site as part of its consultation response.

LINK supports the designation of the Lochs Duich, Long and Alsh possible Nature Conservation MPA for the protection of burrowed mud and flame shell beds. The boundary and area of the possible MPA is fully supported. The pMPA exhibits the most significant population of flame shells recorded in Scotland (and possibly the world), and is the only known loch where a wild (non-translocated) fan mussel has been recorded. The possible MPA also represents the most significant remnant burrowed mud communities in sheltered and shallow sea lochs of Scotland. We note this possible MPA overlaps with a previously designated SAC (primarily for protection of reef habitat) and management will need to refer to, and align with, the objectives of this SAC.
We support the conservation objective for the flameshell beds within the Lochs Duich, Long and Alsh pMPA to be ‘conserve’, due to its already great extent.

However, fishing pressure from towed/active gear should be removed, not just reduced, from the most sensitive burrowed mud features, particularly fireworks anemones. Burrowed mud should therefore be set to ‘recover’ since given the high sensitivity of this species to mobile fishing gear (Scotland’s Marine Atlas), historic fishing pressure is likely to have reduced the extent of this local population of nationally scarce species. Fan mussel needs to be added to the protected features list for this pMPA and a conservation objective set to ‘recover’, both for this local individual/ population (we cannot confirm whether the record is isolated or not) and to contribute to population recovery throughout Scotland. Although not an aggregation, addition of the species would be in line with the case for adding native oyster to Loch Sween and Northwest Scotland sea lochs.

Management Options:
Management activities associated with deep water burrowed mud habitat requires revision. We support and encourage designation of zones prohibiting all forms of disturbance by mobile and static gear, anchors, moorings diver-operated hydraulic methods, and expansion of new aquaculture ventures, to ensure sizable proportions of flame shell, fan mussel and burrowed mud communities, particularly those supporting fireworks anemones, are fully protected from disturbance and have opportunity for future enhancement. We particularly support closure of activities that impact on flame shell beds in the Kyle Akin area, and this management regime should be extended to deeper water habitats particularly the sensitive fireworks anemones of Loch Duich.
In the absence of detailed information relating to the impacts of aquaculture on proposed protected features within an MPA it is imperative that the precautionary approach be applied. Discussions with finfish farming interests cannot be used as a proxy for specific, detailed information and where doubt exists management measures must be precautionary.

Socioeconomic Assessment:
LINK acknowledges the important contribution of the National Trust for Scotland and the Marine Conservation Society in bringing this possible MPA to the consultation stage.

This contribution is an excellent demonstration of the high value that communities, both of place and of interest, put on the integrity of the marine environment. It also points to the existence of the non-use value of MPAs that has been largely omitted from the economic assessments.
The socioeconomic impact data presented in the BRIA indicates the small costs associated with designation and restricting damaging activities (less than £0.02 million pa GVA) will be outweighed by the medium to long term benefit of protecting the ecological integrity of the possible MPA so it can continue to provide ecosystem services to Scotland’s inshore waters. It is possible that the existing creel/ potting fishery, provided it is sustainably managed, will benefit from reduction in mobile gear which impacts on benthic communities. With the protection and enhancement of benthic habitats, there is likely to be improvement in recreational fish catch in the medium to long term.

The potential value of the Lochs Duich, Long and Alsh possible MPA to divers and sea anglers has been estimated at £6.9 to £14.6million based on willingness-to-pay measures (Kenter et al., 2013). Kenter et al. also found important emotional and well-being benefits associated with the Lochs Duich, Long and Alsh possible MPA, with interviewed local users and vistors scoring >4 (out of a maximum score of 5) for engagement, identity, spiritual, therapeutic, transformative and social wellbeing indicator.

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.
Note that the possible MPA also contains the Loch Duich Head Important Plant Area for marine algae. The reef system at this site is considered to be one of the best areas in the UK, there is also maerl. Threatened or rare species: Ascophyllum nodosum ecad mackaii, Cruoria cruoriaeformis

Check out the official documents relating to the Lochs Duich, Long and Alsh MPA on the Scottish Natural Heritage website.

Download the Lochs Duich, Long and Alsh MPA site summary

[1] Lochs Duich, Long and Alsh MPA site summary, SNH