The Barra Fan and Hebrides Terrace Seamount MPA

LINK supports the designation of the Barra Fan and Hebrides Terrace Seamount possible Nature Conservation MPA to protect burrowed mud, offshore subtidal sands and gravels, offshore deep-sea muds, an area of the Hebridean continental slope, the Hebrides Terrace Seamount and associated features, including orange roughy and seamount communities and geodiversity features representative of the The Barra Fan and Peaches Slide Complex Key Geodiversity Areas. The boundary and area of the possible MPA is fully supported on the basis of the information provided. It should be noted that the possible MPA lies right on the boundary between the Scottish and Irish marine areas. The Hebrides Terrace Seamount, while mostly in Scottish waters, straddles the boundary.

The seamount rises from the seafloor to a height of 1 km, and supports a diverse range of sea life, including cold-water corals, deep sea sponges, and fish species such as orange roughy. The seamount is thought to be significant to the health of Scotland’s seas due to its effect on movement of underwater currents, which bring food to the area. The resulting rich diversity supports many fish species, which in turn attract larger marine animals, such as sharks and cetaceans.

We accept the conservation objective of ‘conserve – feature condition uncertain’. However, we note that selection guideline 2d was not considered to be met for the protected biodiversity features in this site as sensitivity analyses concluded that there is a risk that features have been modified by human activity.

Management Options:
Management options for protected features of uncertain condition must be evidence-based, account for the known vulnerability of the protected features to human activities and make appropriate use of the precautionary principle.
Although we acknowledge uncertainty in the evidence of the condition of the seamount habitat, the area is likely to be enhanced by restriction of damaging activities by mobile and static gear (e.g. otter trawling,). We also advocate that these activities do impact on PMFs such as burrowed mud, offshore deep sea muds, and offshore subtidal sands and gravels and their constituent species.
We are concerned that no management options are provided for the large-scale biodiversity search features seamounts and continental slope. Seamounts and continental slope are included as a biodiversity features based on the increased primary production and biodiversity, management options to protect this wider biodiversity should be included.

There is limited attention in the management options document concerning pelagic trawling and purse seining activity, and as such no informed assessment can be made regarding sustainable harvesting of associated pelagic and demersal fish species. We further support and encourage designation that prohibits all forms of future disturbance by mining and exploration, and new oil and gas facilities, particularly with respect to Scotland’s vision for a full shift to sustainable electricity production and reduction in carbon footprint.

Limiting these activities will to ensure the Barra Fan & Hebridean Terrace Seamount communities are fully protected from disturbance in perpetuity, and have opportunity for future enhancement. For any proposed licensed activities, they must be managed through a stringent consenting process, as directed by the Marine and Coastal Access Act and Marine (Scotland) Act. However, we emphasise that the expansion of licence activities in possible MPAs should be avoided if alternative sites can be located.

It is important that management of this possible MPA takes account of its position on the Scottish/Irish waters boundary. Every effort should be made to make sure that management of activities, particularly over the seamount, are consistent across the boundary.

Socioeconomic Assessment:
The socioeconomic impact data in the BRIA report indicates the relatively modest, worst case, costs of designation for commercial fisheries as £0.3 – £0.4 million pa. As indicated in the comments under Management Options Report, it is difficult to make informed comment on the contribution of the Barra Fan & Hebrides Terrace Seamount possible MPA to pelagic and demersal fish stocks, and associated fishing activity options. Relatively modest displacement costs associated with fisheries with habitat damaging activities that employ bottom mobile gear 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 offshore waters. The BRIA report indicates expected costs of undertaking stringent environmental impact assessment procedures for oil and gas sector proposals may range from £1.6 – £5.8 million. We argue that these projected costs would be absorbed by the economic value and wealth of this industry, with likely alternative sites and opportunities being accessible in the short to medium term.

Representative seamount habitat ecosystems are essential for Scotland’s MPA network due to their biological diversity and important ecosystem drivers. Seamount ecosystems are relatively uncommon worldwide. There are concerns with the negative impact of fishing on seamount ecosystems, with well-documented cases of stock decline, for example orange roughy decline due to overfishing in the vicinity of seamounts off Tasmania. Ecological damage is mainly caused by bottom trawling, and large demersal netting which exploit populations of fish that exhibit mass aggregation behaviour in the vicinity of seamount seascapes.
Sperm whales are known to use this region and should be considered in the management options.