Cynulliad Cenedlaethol Cymru | National Assembly for Wales

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

Gwaith dilynol ar reoli Ardaloedd Morol Gwarchodedig yng Nghymru | Follow up work on Marine Protected Area management in Wales


Ymateb gan : Awdurdod Parc Cenedlaethol Arfordir Sir Benfro ac Awdurdod Parc Cenedlaethol Eryri

Evidence from : Pembrokeshire Coast National Park Authority and Snowdonia National Park Authority


1.         Thank you for the opportunity to contribute to the Climate Change, Environment and Rural Affairs Committee’s follow up work on Marine Protected Area (MPA) management in Wales. This is a joint response from Pembrokeshire Coast National Park Authority and Snowdonia National Park Authority[1].


2.         Pembrokeshire Coast National Park Authority and Snowdonia National Park Authority welcomed the publication of the Committee’s August 2017 report Turning the tide? Report of the inquiry into the Welsh Government’s approach to Marine Protected Area management.


3.         The report clearly identified what needed to be done to improve MPA management in Wales. We believe that the report has been influential and a catalyst for progress.


4.         We are pleased to see this follow-up to the MPA Inquiry which we hope will help to maintain and build on this progress.


5.         Pembrokeshire Coast National Park Authorityrepresents the two coastal national parks in Wales on the MPA Management Steering Group (MPAMSG). We regard this follow-on inquiry as an opportunity for others to comment on the Marine Protected Area Network Management Framework for Wales and Action Plan, so we have not responded to the questions relating to these.


What progress has been made by the Welsh Government against the recommendations in the Committee’s report? 


Comments on Recommendation 1

6.         Welsh Government published a MPA Network Management Framework for 2018-23 and an associated action plan for 2018-19 in September 2018. Natural Resources Wales’ (NRW) work to identify and prioritise the actions most likely to have strategic impact is welcomed.


7.         A letter dated 8th May 2017 from Lesley Griffiths AM, then Cabinet Secretary for Environment and Rural Affairs, was sent to coastal local authorities and other key contributors to the statutory management of Marine Protected Areas in Wales. This clarified amongst other matters the powers and duties of management authorities.


8.         These materials provide a basis for management authorities to become actively engaged in MPA management. However, it is our opinion that a stronger steer is needed if they are to fulfil their duties and responsibilities adequately.


Comments on Recommendation 2

9.         In 2015 the MPAMSG consulted stakeholders on four options for MPA site management. Responses showed a clear preference for a local approach with seven management areas.


10.       MPAMSG members took two options forward for further assessment:

·         Option 2 - a local approach with seven management areas

·         Option 5 - four management areas with more than one officer, depending on the area’s needs.


11.       MPAMSG meeting minutes for 27th January 2016 note that “a full time post at each of the current seven areas was the preferred option; however, a part-time post would be more practical and affordable. Group members expressed concerns over the enlargement of areas. It was suggested that when locality was lost, local authorities were less likely to support the areas.”


12.       It is the opinion of PCNPA and SNPA that Welsh Government (directly or via NRW) should provide the principal core funding for MPA site management, including EMS officer posts, with relevant authorities continuing to make additional contributions. Pembrokeshire Coast and Snowdonia National Park authorities are committed as relevant authorities to reducing pressures on and improving the state of MPAs via the RAG model.


13.       In conclusion regarding Recommendation 2, there has been a consultation and evaluation of management options, but proposals for funding an area-based approach, with each management area having a dedicated officer, have not yet been brought forward.


14.       We note that the two Special Areas of Conservation (SAC) for harbour porpoise in Welsh waters (designated in February 2019) were consulted on in 2016 and were submitted to the European Commission for approval on 30 January 2017. This process would have largely post-dated the MPAMSG discussions above. The local approach preferred by stakeholders would need to consider and reflect the two new (February 2019) additions to the MPA network.


            Comments on Recommendation 3

15.       Visit Wales’ 2018 Year of the Sea provided a good platform for awareness-raising. European Marine Site (EMS) officers have also capitalised on the public concern about marine plastic and worked with businesses to identify opportunities for reducing single-use plastics and to celebrate successes.


16.       We regard public awareness-raising of MPAs as an ongoing task. EMS officers have key roles in awareness-raising locally (residents and visitors[2]) and in communicating the importance of MPAs within the wider network.


Comments on Recommendation 4

17.       Natural Resources Wales and partner organisations have identified and prioritised the unregulated activities with the greatest actual or potential adverse impact on the condition of features within Wales’ Natura 2000 sites, with a view to implementing effective management to mitigate their impacts (May 2018). We welcome this work as a basis for managing threats common to many MPAs.


18.       We welcome the five new fisheries protection vessels which we hope will effectively protect Welsh waters and Wales’ fishing industry from illegal fishing activity.  We hope that the vessels will also help ensure that fishing activities within MPAs are compatible with site features.


Has the management of Welsh seas received sufficient resource and strategic direction?


19.       We understand that Welsh Government’s Marine and Fisheries Department has been allocated additional resources which have contributed to strategic MPA work and to funding actions identified in the 2018-2019 Action Plan. We warmly welcome this, and Welsh Government’s vessel replacement programme. We also welcome the Welsh Government / Natural Resources Wales Assessing Welsh Fishing Activities Project. We see a clear complementarity between such network-level effort and site- and feature-specific collaboration - which also increases network integrity.


20.       We warmly welcome Welsh Government’s Enabling Natural Resources and Well-Being in Wales funding, and suggest that it or successor schemes should include marine project proposals in future.


21.       Overall, it is our opinion that resources are insufficient to meet the tasks required for improvement given the state of MPA features. Therefore we wish to repeat the suggestion that Welsh Government (directly or via NRW) should provide core funding for MPA site management, including EMS officer posts, with relevant authorities making additional contributions. There are also opportunities to redesign policy in ways that would reduce some pressures on MPAs. We mention these briefly below.


How has the condition of Wales’ MPAs changed?


22.       We welcome the publication by NRW of indicative site condition assessments in 2018; monitoring is a cornerstone of management and NRW must have sufficient resources to provide timely monitoring data and conservation advice.


23.       The results of the indicative assessments are of great concern. For example, 9 of the 15 features evaluated in Pembrokeshire Marine SAC are in unfavourable condition, as are 7 of the 12 features evaluated in Pen Llŷn a`r Sarnau SAC. There is only low to medium confidence in the assessment of the 4 features identified as in favourable condition in Pen Llŷn a`r Sarnau SAC. In our view, insufficient progress has been made on the UK Marine Policy Statement commitment and the high level marine objective to live within environmental limits[3].


24.       We conclude this response with the observation that the UK’s withdrawal from the EU offers a prime opportunity to redesign fisheries management, within the context of the international agreements which will remain in force post-Brexit. In particular, it affords the devolved administrations the opportunity to design a common framework for ecosystem-based and equitable fisheries management, with appropriate resourcing and enforcement.


Thank you for the opportunity to input to this inquiry.

[1] Pembrokeshire Coast National Park Authority is also contributing to a collective response from the Pembrokeshire Marine Special Area of Conservation Relevant Authorities Group.

[2] A 2013 study estimated the Gross Value Added by marine recreation in a 92km2 area around the St David’s peninsula at £17.8m (conservative).

[3] “Biodiversity is protected, conserved and where appropriate recovered and loss has been halted; healthy marine and coastal habitats occur across their natural range and are able to support strong, biodiverse biological communities and the functioning of healthy, resilient and adaptable marine ecosystems; our oceans support viable populations of representative, rare, vulnerable, and valued species.”