Upper Loch Fyne and Loch Goil MPA

Yes, we fully support the proposed protection for the recovery of flame shell beds and the conservation of seagrass beds in the Upper Loch Fyne and Loch Goil MPA. These habitats are highly sensitive to a range of anthropogenic impacts, including mobile demersal fishing gear, and little is understood about the potential impacts of anchoring and static gear (which may also be high, depending on the intensity of deployment in the area). Flame shell beds are important ecosystem engineers and provide a nursery ground and refuge for many species, including commercial fish and
shellfish. The ecological and economic importance of these habitats justifies the highest possible protection.

We do not support the use of activities such as deployment of static fishing gear within flame shell bed recovery areas. While we acknowledge that static fishing methods, such as creeling are thought to be more sustainable and less impactful on the marine environment, we contend that the recovery areas should be no take zones. Flame shell beds are slow growing and slow to recover following disturbance. Given the conservation objective of ‘recover’ for the flame shell beds in this MPA, we think it is essential that all pressures are removed from these areas to maximise recovery potential. If a permit scheme were to be implemented in these areas for creeling, it would need to be subjected to an environmental impact assessment first in order to ensure that a carrying capacity in terms of the number of creels was not exceeded and damage to the flame shell bed is not likely to occur. The recovery areas would also need to be closely monitored to ensure that illegal or ‘ghost’ creeling was not occurring. Furthermore we would not support activities such as anchoring or
deployment of moorings adjacent to the flame shell beds without environmental impact assessment to determine whether there is a risk of damage (e.g. abrasion from chains/ropes in extreme
weather).

We would support activities that do not directly impact on the marine features within the site, such as recreational sea angling and recreational SCUBA diving.

We do not support the proposed approach 2a for managing the rest of the site. We do not support the proposed approach 2b for managing the rest of the site.

We agree with the management advice to remove/avoid pressure for flame shell beds, horse mussel beds and ocean quahog. These features are all sensitive to activities which cause abrasion (e.g. some mobile demersal fishing gear) and are slow-growing, long-lived species that are slow to recover following disturbance.

However we do not think that the management advice for burrowed mud and sublittoral mud and specific mixed sediment communities goes far enough for the conservation of these habitats and their component species. Figure P3-7 in the consultation documents show records of species which
inhabit or occur on the surface of these muddy sediment habitats, including fireworks anemones, horse mussels and ocean quahog. While we note that the permitted fishing zones in Approaches 2a and 2b predominantly avoid these species records, it should be emphasized that these are known records and it is likely that these species are dispersed throughout the MPA. All of these component species make a vital contribution to the integrity and resilience of these habitats through helping to stabilise sediments and through long-term bioturbation as a result of burrowing activity. A more precautionary approach should be taken in this site to place higher priority on the muddy habitats and their conservation as a whole (with their component species) in order to ensure the conservation objectives are met. Given that the advice is remove/avoid targeted fishing for ocean quahog, a species associated with mud and mixed sediment communities, and their risk of being bycaught in Nephrops fisheries, such a precautionary approach is merited for this species alone, even before considering the numerous other infaunal and epifaunal species associated with these sediments. We therefore contend that management advice should be remove/avoid pressure from the sublittoral mud and specific mixed sediment communities and burrowed mud habitats in this site.

We agree that a zonal approach to fisheries management is not suitable for this MPA and therefore do not support Approaches 2a and 2b. Given that Upper Loch Fyne and Loch Goil are narrow waterbodies, and that the boundaries of the proposed fishing permit zones have been delineated
very close to many of the protected features within the site, we believe that there is a risk to the overall integrity of the site and therefore to the achievement of the conservation objectives.

Furthermore, as discussed for the South Arran MPA, prohibiting mobile demersal fishing activity from the Upper Loch Fyne and Loch Goil MPA will contribute toward improving the ecological status of the wider Clyde Sea area and, as a secondary outcome, toward a more strategic and sustainable
spatial approach to managing the Clyde Nephrops fishery. The productivity of the Nephrops fishery would be improved by an ecosystem approach to management in which the infaunal biota that bioturbate the sediment and maintain the complexity and stability of the entire habitat are
adequately protected.

Therefore we contend that the use of mobile demersal fishing gears should be prohibited throughout this MPA. We support the continuation of static fishing on the burrowed mud, provided that this is subjected to an environmental impact assessment to ensure that the carrying capacity of
the lochs is not exceeded. The use of static gear in this site should be monitored closely to ensure that this practice is conducted sustainably.

We recognise that this approach 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.

LINK supports the designation of the Upper Loch Fyne and Loch Goil possible Nature Conservation MPA to protect burrowed mud, flame shell beds, horse mussel beds, ocean quahog, sublittoral mud and mixed sediment communities. The presence of fireworks anemones (Pachycerianthus multiplacatus) in Loch Goil is confirmed and needs to be added to the protected features. Loch Goil is also the only known location where the Arctic relic seasquirt Styela gelatinosa has been recorded and merits recognition as a feature that would get consequential protection. Both sea lochs also have excellent examples of sheltered rock reefs which merit listing as protected features (in line with the general point regarding representation of EUNIS Level 3 habitats in answer to question 35).

LINK supports the conservation objective of ‘recover’ for flame shell beds. Conservation objectives for all other features, listed as conserve (feature condition uncertain) should also be set to recover following a precautionary approach.

Management Options:
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.
Moorings – the Fireworks anemones in upper Loch Goil that are near the moorings were recently surveyed during a MCS Seasearch survey. They don’t appear impacted but we would recommend no new moorings deeper than 15m at the head of the loch (to allow a buffer zone from where the anemones start at 15m) or at the very least robust EIAs that locate anemones before positioning mooring blocks away from them.

Fishing – we are concerned about the resolution of sensitivity mapping for burrowed mud since it doesn’t resolve the presence of fireworks anemones or mud volcano worms which are highly sensitive to mobile gear. Burrowed mud should therefore be rated as high sensitivity following the precautionary approach assuming presence of fireworks anemones (unless fireworks anemones have been proved not to be present). So we disagree with the advice to only consider reducing or limiting pressure of towed gear in areas with confirmed mud volcano worms and fireworks anemones.
We support the removal of fishing pressure from flame shell beds and horse mussel beds, but also from ocean quahog areas and muds which may contain fireworks anemones. Simpler in management terms would be to exclude mobile gear from the MPA.
Static gear – should remove this pressure from flame shell beds, horse mussel beds and fireworks anemone aggregations.
Fishing – diver collection. This should be ‘remove pressure’ since advice is to ‘exclude’ certain activities.

Socioeconomic Assessment:
LINK acknowledges the important contribution of 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 potential value of the Upper Loch Fyne and Loch Goil possible MPA to divers and sea anglers has been estimated at £7.7 to £16.1 million based on willingness-to-pay measures (Kenter et al., 2013) . Kenter et al. also found important emotional and well-being benefits associated with the Upper Loch Fyne and Loch Goil possible MPA, with divers and anglers responding to questionnaire scoring >4 (out of a maximum score of 5) for engagement, therapeutic, spiritual, transformative and social wellbeing indicator values.