Response to Scottish Government invitation to comment on Offshore MPA/SAC proposed management measures

Summary

• LINK members welcome the fact that the proposed management measures are in the public domain and that we have the opportunity to comment.
• We welcome that the proposed measures will help protect many fragile designated
  features, preventing some further decline.
• We do not consider that they address all of the ecological concerns facing these offshore
  habitats and are unsure to what extent the measures will help enhance the extent and
  functioning of protected features and Scotland’s wider seas.
• LINK supports the application of sound science to identify the sites and the process by which
  the proposed management measures have been determined. However, where data is
  lacking and/or confidence is low, some of the proposed approaches are not sufficiently
  precautionary.
• We support the proposed site-wide prohibition of mobile demersal fishing gear in the
  following sites:
  •  Rosemary Bank Seamount ncMPA
  •  Norwegian Boundary Sediment Plain ncMPA
•  We support the proposed site-wide prohibition of mobile demersal fishing gear in Anton
  Dohrn SAC but recommend a review of the site boundary at future network reviews.
• We welcome elements of the proposed management approaches in the remaining sites but
  have remaining ecological concerns, including:
  • proposals where mobile demersal gear is allowed between 600m-800m
  • the lack of continental shelf-break habitat being protected (200-400m) in continental
    slope sites
  • the degree to which measures will ensure site integrity is achieved in some reef SACs
  • the proportion of sedimentary habitat protected in some of the continental shelf
    sites
  • the lack of precautionary or experimental restrictions on mobile demersal fishing
    gear within sandeel sites
  • the extent to which set nets are prohibited, exposing vulnerable species such as
    deep sea sharks and cetaceans to entanglement risk
• A monitoring strategy should be developed that includes offshore research and better monitoring of bycatch in order to inform meaningful adaptive management and build up a baseline of scientific data against which future change can be measured. Sufficient
  resources should be made available to successfully monitor and, where necessary, ensure compliance with the management measures across the sites.
• LINK members remain committed to continued constructive engagement with the Scottish
  Government’s welcome and potentially world-leading MPA project.