Cynulliad Cenedlaethol Cymru | National Assembly for Wales

Y Pwyllgor Newid Hinsawdd, Amgylchedd a Materion Gwledig | Climate Change, Environment and Rural Affairs Committee

Ymchwiliad i reoli ardaloedd morol gwarchodedig yng Nghymru | Inquiry into the management of marine protected areas in Wales




Ymateb gan : Cyngor Sir Ceredigion, Awdurdod Parc Cenedlaethol Arfordir Penfro a Dŵr Cymru o Grŵp Awdurdodau Perthnasol Ardal Cadwraeth Arbennig Bae Ceredigion

Evidence from : Ceredigion County Council, Pembrokeshire Coast National Park Authority & Dŵr Cymru of the Cardigan Bay Special Area of Conservation Relevant Authorities Group

Question 1

Has the management of Welsh seas received sufficient resource and strategic direction to enable sustainable management that supports the well-being of current and future generations? (250 words)

No, insufficient resources are provided and furthermore these are inconsistent across different sites. There is a lack of adequate and sustainable funding for appropriate staff time and a lack of resources for active management to take place.

The Cardigan Bay Relevant Authorities Group is made up of statutory bodies who voluntarily work together because of a shared interest in the Cardigan Bay Special Area of Conservation. Where some funding has been provided for officer time and resources for specific projects, successes by the RAG have been made. In 2016 temporary interpretation panels were installed at seven key locations along the coast of the SAC, to reduce disturbance to seals and their pups during the pupping season.
There is an 8 knot speed limit in place along the Marine Heritage Coast of the SAC to reduce disturbance to wildlife, along with provision of a water ranger and a voluntary code of conduct for commercial and recreational vessels. Funding for officer time allows the continued running of the ‘Dolphin Watch’ monitoring project, which has now been running for over 20 years, and informs the management of the site. However the voluntary code of conduct would benefit from the support of licencing and enforcement measures where necessary, a lack of support for the enforcement of regulations can undermine their credibility.   
There is a lack of strategic direction to successfully implement the conservation measures needed to bring individual sites up to favourable conservation status level for all habitat and species features of the site.

However where sites are supported by strong strategic direction and are adequately funded marine biodiversity can be protected from anthropogenic impacts, for example, the Skomer Marine Conservation Zone, where strict management provides appropriate protection through specific fishery byelaws, prohibiting the use of mobile fishing gear (dredges and beam trawls) and the taking of certain scallop species by any means. The site also benefits from an extensive research and monitoring programme.

Question 2

How should Area Statements, to be developed by Natural Resources Wales, cover Welsh seas? (For example should the sea adjoining each welsh Local Authority be included in its Area Statement, or should the marine environment be considered separately in one or more marine Area Statements?) (250 words)

As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Area Statements need to be overlapping with the management of MPAs. We feel that the seas should not be included in each Local Authorities Area Statement, splitting up the marine environment on a county-administrative basis would not be best practice ecologically, and we would anticipate that it would lead to inconsistency and to difficulties in implementation.
 The Area Statements will need to recognise that nutrient inputs from land management and discharges can impact on the marine environment. 

Area Statements will also need to work alongside the River Basin Management Plans developed by NRW to comply with the Water Framework Directive.

Question 3

How well are Wales’ MPAs currently being managed?

(This can include aspects such as the condition of sites, staffing to deliver management, surveillance and enforcement activities and the data on the extent of activities taking place in MPAs) (250 words)

A key issue, along with lack of adequate funding for staffing, is a lack of feature condition assessment to inform management. Therefore where management measures are in place, there is no assessment of their success.  We recognise that monitoring in the marine environment presents specific challenges, and we are aware that Natural Resources Wales would like to do much more to monitor and to protect these sites, but its resources are under continuing, and ever increasing, pressure. However it in unacceptable that so little monitoring and surveillance is currently being undertaken.
Without extensive research and monitoring along with the provision of adequately staffed and resourced sites effective management is challenging.
The RAGs have been effective in working to identify the pressures and threats on the sites features, but they need to be adequately resourced and supported with statutory enforcement to provide the necessary measures to manage MPA’s effectively.  

Question 4

What are the key issues affecting the effective management of multi-use MPAs? (250 words)

Marine Protected Areas are designated because of the special and high conservation value of the species and habitats that they contain. Therefore anthropogenic activities that compromise or degrade the status of these species may need to be restricted or prevented completely, in specific sensitive and high conservation value areas. There is continued conflict influencing the effective management of the site between the conservation of habitats and species and economic exploitation of resources in Marine Protected Areas.
Where monitoring demonstrates that activities present a threat to features, a willingness to implement meaningful measures to address the threats and so provide an appropriate level of protection is needed. Welsh Government should be confident to defend a decision to protect marine biodiversity and support the wellbeing of future generations, rather than favouring short term immediate economic gains which degrade sites and their features, benefit a limited number of individuals and often have no benefit to local communities; for example, the decision to open up previously closed areas to scallop dredging in the Cardigan Bay SAC.

There are currently no Highly Protected Marine Sites or No Take Zones in Wales that can be used for comparison with multi use areas to assess the benefits for site features.

Question 5

Do existing Welsh MPAs currently provide the right protection for the conservation of Welsh marine biodiversity? (250 words)

No, we recognise that a significant proportion of Welsh seas are designated for their conservation value, and we welcome the recent designations for harbour porpoise and sea birds; however designation of an MPA does not ensure protection of its habitats and species. Anthropogenic activities such as fishing, ghost fishing, marine litter, and disturbance are not currently adequately addressed.
MPAs in Welsh waters are multi use sites, with limited restrictions on anthropogenic activities that degrade the features of the site.
To provide the right protection for Welsh marine biodiversity the above issues need to be appropriately addressed. For example more could be done to provide waste disposal facilities at ports to encourage the landing of derelict fishing gear. The removal of waste disposal fees and adequate provision of disposal facilities at port would work towards reducing the level of gear currently ‘cut away’ and facilitate the active removal of derelict gear from the marine environment.  

There is currently no statutory regulation of commercial wildlife trip boat operators in Marine Protected Areas. The number of vessels operating in these areas and the duration of encounter time with each group of animals needs to be addressed. Proper management of these activities requires a national licencing system to manage carrying capacity and reduce sustained disturbance impacts on protected species features such as bottlenose dolphins. Proper management, through a robustly enforced licencing system, would protect both the dolphins and look after the social and economic well-being of future generations.
Although there are benefits from taking a voluntary approach to management measures such as engaging the good will of water users to follow a code of conduct, there is currently no clear direction through statutory measures. In some areas voluntary codes are not enough to deal with the current pressure on bottlenose dolphins key breeding and feeding areas e.g. New Quay harbour area and reef.

Question 6

What lessons can be learnt from current MPA management activity in Wales (including designation, implementation and enforcement)? (250 words)

Designation of a Marine Protected Area does not ensure the adequate protection of the habitats and species for which the area was designated. Without sufficient funding for appropriate staffing levels and resources, and in the absence of a joined up approach with informed thinking based on extensive research and monitoring, these sites are in danger of becoming ‘paper parks’ failing to protect the marine biodiversity for which they were established and preventing their conservation value being retained for the benefit of future generations.  
The absence of ‘no take zones’ or other areas where anthropogenic activity is restricted, prevents comparisons with multi use areas to assess the impacts to marine biodiversity and the benefits of the provision of fully protected marine areas.

Question 7

Are there MPA examples or practices elsewhere that Wales can learn from? (250 words)

In the Lundy Marine Conservation Zone strict management provides appropriate protection through measures removing anthropogenic impacts, including the establishment of a ‘no take zone’ allowing full recovery and protection of the habitats and associated species.
This then has a cascade effect, providing benefits for the local economy through both eco-tourism value and a higher level of recruitment of fish and shellfish species into areas outside of the site which are open to fishing; providing economic benefits to local fishermen and improving local fish stocks for future generations.

In Lamlash Bay, on the Isle of Arran, the Scottish Government designated Scotland’s first ‘no take zone’ in 2008. A one square mile area at the north end of Lamlash Bay set up to protect Maerl beds and to promote natural regeneration of all marine life.  
Surveys demonstrated that after five years, the seabed was 40 per cent more complex and healthier than the area outside the ‘no take zone’.  There are higher densities of scallops, crabs and lobsters, both older and larger, being recorded and increased numbers of juvenile cod and haddock.
The ‘no take zone’ has benefited the local economy by attracting visitors and divers to Arran.  As the area continues to recover, commercial fishermen will gain with bigger and better catches in the neighbouring overspill areas.

The Isle of Man currently has six Marine Protected Areas. Five are designated as Fisheries Closed or Restricted Areas, primarily for the enhancement of the scallop stocks. The sixth is a Marine Nature Reserve, designated for conservation and also for fisheries management. The longest running of the Fisheries Closed Areas is the Port Erin Closed Area, which was established in 1989 and is recognised worldwide for its success. Manx fishermen have seen the benefits of closing patches of sea bed to dredging and have since requested other areas also be closed or restricted.
In late 2011, Ramsey Bay and the Ballacash Channel were designated as the Isle of Man’s first Marine Nature Reserve as it has three habitats considered as priorities for conservation; horse mussel reefs, maerl beds and eelgrass meadows. They are also areas that are very important for juvenile species of fish and support hundreds of other animal species. By protecting these areas as a Marine Nature Reserve, the habitats and species will be allowed to recover from any damage that has been done and to thrive into the future.

The world’s largest coral reef ecosystem, The Great Barrier Reef, is facing multiple, growing threats from man-made and natural disturbances. Through the use of zoning, areas are provided for specific activities, and some areas are protected so that all human activity is prohibited. Researchers at the Australian Institute of Marine Science have shown that the reefs inside the protected reserves are better able to resist, and recover from, these disturbances.

The research team examined 20 years of data from 20 reefs inside no-take zones and 26 reefs that are open to fishing and other extractive activities on the GBR. They found that reef communities, such as fish and corals, in fully protected zones were less impacted by disturbance and recovered faster than outside no-take zones. (From the paper “Marine protected areas increase resilience among coral reef communities” by Camille Mellin, Aaron MacNeil, Alistair Cheal, Michael Emslie and Julian Caley

Research from fully protected marine areas in the UK and around the world demonstrates the benefits of well managed marine reserves; such areas need to be widely implemented and supported to maintain the integrity of our seas.

Question 8

The majority of Wales’ MPAs are designated under the EU Habitats Directive. How should the Welsh Government’s approach to MPA management take account of the UK’s decision to leave the European Union? (250 words)

The EU Habitats Directive - Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora has been transposed into UK law through the Conservation (Natural Habitats, &c.) Regulations 1994 and updated by the Conservation of Habitats and Species Regulations 2010.
The Regulations provide for the designation and protection of 'European sites', the protection of 'European protected species', and the adaptation of planning and other controls for the protection of European Sites.

The Regulations place a duty on the Welsh Minister to propose a list of sites in Wales which are important for either habitats or species (listed in Annexes I and II of the Habitats Directive respectively) to the European Commission.

However action to protect listed marine species and designate areas for their protection appears to only taken by Government when action is taken against them by Europe for failing to act. These actions may have led directly to the closure of parts of Cardigan Bay to scallop fishing in 2010 as well as the recent establishment of SACs to protect harbour porpoise. The loss of recourse to EU infraction processes will close an important mechanism for reminding Government and its regulators of their international nature conservation obligations. Therefore the impact on European Sites and their protected species is of concern following the UK’s decision to leave the EU. If SAC are re-designated following the UK leaving the EU, these Marine Protected Areas should be given at least the same protection and geographical area, or even should aspire to be better; with a strong recourse against damaging activities.

Question 9

If you had to make one recommendation to the Welsh Government from all the points you have made, what would that recommendation be? (250 words)

The marine wildlife found in Welsh seas is very special; we need fully resourced and properly managed marine protected areas to allow them to recover, for both wildlife and for our own social and economic wellbeing.

We need adequate funding and resources to be made available for appropriate monitoring and management, accompanied by statutory enforcement where necessary and the established of highly protected marine areas or ‘no take zones’ to allow areas within MPA’s to fully recover.

Question 10

Do you have any other comments or issues you wish to raise that have not been covered by the specific questions? (250 words)

The SAC Relevant Authority Groups have produced a Management Scheme for each SAC, systematically and effectively identifying the pressures and threats to site features and detailing the appropriate action to mitigate their effects. Appropriate levels of funding for staffing and resources, along with extensive monitoring and condition assessment of the features of the site, accompanied by statutory enforcement; would allow for the fully effective implementation of the Management Scheme by the RAG.

Each of the Marine Protected Areas in Welsh seas is unique and special and they are all very different.
Historically management has followed a ‘bottom up’ approach with high levels of engagement with local communities. The need for community involvement in MPA’s cannot be stressed strongly enough. The management of MPA’s is dependent on community support along with the site and local knowledge of the MPA Officer for each site.

Welsh Government has undertaken a series of reviews in recent years examining the best approach to marine management.  They consistently call for a higher priority and more resources to be given to the management of Marine Protected Areas in Wales.  The most recent report recommended that there should be seven management areas, with each area having a dedicated officer.  Although the findings received widespread support, they have not yet been taken forward as a result of the lack of funds to implement them.