Luce Bay and Sands SAC

Luce Bay and Sands Special Area of Conservation (SAC) is selected for large shallow inlet and bays and sand dunes. Sandbanks, mudflats, sandflats and reefs can also be found there.

Luce Bay and Sands represents a high-quality large shallow inlet and bay. The sediments within Luce Bay range from mixed-sized boulders, deep sediments and highly mobile fringing sands, all of which support rich plant and animal communities typical of a large embayment in south-west Scotland. Water depths in Luce Bay are shallow, ranging from 0-10 m fringing the coastline and at the head of the bay. Shallow depths extend further out into the bay where the major sandbanks are located along the western and northern shores. The water deepens to 20 m at the site boundary between the two headlands. Most of the intertidal area of the bay comprises small boulders, often resting on sediment. Some larger boulders on the lower shores have spaces beneath and between them which provide shelter for false Irish moss Mastocarpus stellatus and permit rich under-boulder communities to develop, including ascidians, sponges and crustose coralline algae. In the subtidal area mixed boulders and sediment harbour a shallow-water community of sparse kelp Laminaria hyperborea and sea-oak Halidrys siliquosa, red algae and the dahlia anemone Urticina felina, typical of sand-influenced hard substrata. Much of the central part of Luce Bay consists of slightly deeper-water sediments that support a rich community of polychaete worms, bivalves, echinoderms, brittlestars, particularly Ophiura spp. The holothurian Labidoplax digitata has also been recorded in the bay. At Mull of Galloway in the west and Scare Rocks near the seaward boundary of the bay, tide-swept rocky reefs support L. hyperborea on shallow sublittoral rocks and very rich sponge- and hydroid-dominated communities below 10 m.

This site now has fisheries management measures in place.

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

Save Scottish Seas campaign members have assessed the management proposals and do not support Approach 2 (or Approach 3) proposed for the management of Luce Bay and Sands SAC. We support Approach 1, the prohibition on the use of mobile demersal fishing gear throughout the site.
We are fundamentally concerned that anything but Approach 1 for the management of the Luce Bay SAC will breach the Habitats Directive. It is not clear from the management advice or the consultation documents that an Appropriate Assessment under Article 6(3) of the Habitats Directive
has been conducted on current levels of fishing and the proposed management approaches where potentially damaging forms of fishing are permitted. Given the size of the permitted fishing zones in
approach 2 and 3 (which are larger in size than the alternatives originally set out in the stakeholder
workshops, October2014), and that they span a range of habitat types including highly sensitive ones
such as kelp (approach 3), we are concerned that allowing mobile demersal fishing to operate on
these features is already compromising the integrity of the site. This concern is compounded by the
recent Sweetman ruling by the Court of Justice of the European Union that found “site integrity must
be determined by reference to the lasting preservation of the constitutive characteristics of the site
concerned that are connected to the presence of a priority natural habitat whose preservation was
the objective justifying the designation of that site” (emphasis added).31 The Scottish Government
has stated that implementation of Approach 1 is not necessary to achieve the conservation
objectives32 and furthermore that this approach is not likely to be adopted anyway (verbal
communication, stakeholder workshops, October 2014). This cannot be stated until an Appropriate
Assessment has been carried out.
The designation of the SAC as a large shallow inlet/bay covers an area of varied and complex habitat
types, some of which require a high level of protection, such as reefs (Annex 1 feature) and maërl (Priority Marine Feature) and some of which are thought to be sensitive to impacts from mobile demersal fishing activity (e.g. kelp habitats). A number of these habitats are vital components of the wider ecosystem, as they act as refuges for juvenile fish and shellfish species, and Luce Bay is a known spawning ground for plaice, cod, scallops and many other commercial fish species. Proper safeguarding of this area is therefore likely to bring about long-term benefits for local fisheries, as well as promote wider ecosystem resilience.
We agree with the management advice to remove/avoid pressure on reefs, maërl beds and Sabellaria spp and support the prohibition of mobile demersal gear from these features. We suggest that sandbanks and other soft or mobile sediment features should also be managed under a remove/avoid recommendation, given the complex mosaic of habitat types that occur within the bay. The sandbanks to the north side of the bay support a diverse range of marine and coastal plants
and animals and the sand dunes which extend from the beach along the landward part of the SAC are part of a special system which hosts over-wintering seabirds.
We do not support Approach 3 for Luce Bay, and we are concerned that under this management regime mechanical dredging would be allowed on the kelp/seaweed communities. The impacts of mobile demersal gear on kelp beds are largely unknown, but research indicates that apart from the physical damage of towed gear on the kelp, increased sedimentation from dredging can cause a significant reduction in the growth rate and condition of kelp33. It seems counter-productive to allow dredging on, or even near, kelp beds, especially given that this is a habitat that forms a vital spawning ground for commercially important fish stocks. Furthermore, kelp beds have the potential capacity to store 313–900 g C m?2
yr?1 34 and are increasingly at risk from direct damage by
anthropogenic activities, storm events and climate change, which makes them less resilient to recovery following damage35. Emphasising their important role in carbon sequestration, a recent authoritative report estimated that coastal plants (predominantly kelp) around Scotland’s coast
potentially contribute a further 1.8 million tonnes of carbon/year into long-term storage in sediments.
The Solway Firth has two designated Special Protection Areas, one of which is part of Luce Bay (Loch Inch and Tors Warren) and is for the protection of over-wintering white-fronted geese (Anser albifrons flavirostris), which use the shallow, flat areas of the bay to feed between November and April. This species of goose has been assessed under international conservation criteria and is considered a priority species for conservation action. This site represented up to 3.8% of the wintering population of white-fronted geese37 (50% of the world population over-winter in the UK) and it is appropriate and important to consider the wider ecological needs of these birds, which are one of many wading and sea bird species that make use of this area.
Luce Bay is also a popular area for tourists, recreational fishermen and anglers, wildlife watchers and water sports enthusiasts, which support local communities and businesses in the surrounding area.
The tourism industry relies on the good environment condition of the bay and we suggest that the socio-economic benefits for the local community of the proposed management approaches should also be assessed. We recognise that there is a growing strong community interest in the Luce Bay SAC seeking a more ambitious approach to mobile demersal gear fisheries management in this site.
We recognise that Approach 1 will have short and mid-term impacts for a small number of fishing boats that currently fish the area. It is anticipated that a closure to bottom-towed fishing gear in this area will improve the wider ecological health of our seas and provide long-term, beyond-the-site benefits for commercial fishermen.

Read our response to the revised management measures for this site here:

You can view the full response to this consultation here.

Contact the Save Scottish Seas team

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