Proposal to designate Red Rocks and Longay as a Marine Protected Area

Although the site is of national importance for its concentration of skate egg laying areas, the topography of the site, being steep rock pinnacles and boulder slopes, is such that it is not a location that is ever likely to have mobile gear towed through it.
This is more than likely the reason that the egg site has been inherently protected from trawl and dredge habitat destruction to date.
The current MPA proposals only seek to prejudice against the static gear sector and would have a negligible impact in protecting the eggs from disturbance, most of which are wedged below or between large rocks atop rock pinnacles.

Despite disagreeing that the site should be designated an MPA. Should it become one, I agree with the majority of management advice issued by NatureScot and am very concerned that Marine Scotland are consulting on management measures that do not reflect that advice.
Specifically the advice relating to creel fisheries and are that Creelers might retain some access to the site, is ignored.

Marine Scotland’s consultation options do not reflect NatureScot's advice and this fact directly prejudices the interests of the local creel fishermen.
The local creel fishermen have already lodged a formal complaint that previous interim management measures did not reflect the earlier NatureScot management advice, but instead appeared to be imposed due to being requested by the mobile gear, Trawl and Dredge sector (SFF and SWFPA).
This appears to follow a wider historic pattern of Marine Scotland managing fisheries in the interests of a narrow group of stakeholders to the prejudice of other stakeholders and the wider public interest. It is neither reflective of evidenced based decision making, nor in the interests of good governance, that the management measures being consulted on do not reflect the scientific advice.

All the discovered eggs are located on hard substrate at depths shallower than 35m, therefore creeling, predominantly below 40m depth, is very unlikely to interact with the eggs.
All the eggs are located on hard boulder/cobble ground where it is very unlikely that creelers would be targeting for prawns (prawns live in burrows in soft mud).
Further, there is very little likelihood of the creel fisheries interacting with the eggs due to the target creel species predominantly living in soft substrate and the eggs being largely protected in boulder, between and under rocks, areas atop pinnacles.

Assuming the MPA is implemented, and with regards to the buffer zone surrounding the area, then the likelihood of damage caused by each activity should be considered when implementing spatial management measures. i.e., the higher the likely impact of an activity, the wider the buffer zone should be. Those activities with lower likely impact should have smaller buffer zones.

Diving will have virtually no impact, angling is likely to have negligible impact (assuming a catch and release policy) and creel fishing will also have a negligible impact for the reasons stated above.

However Trawl and Dredge, though historically not carried out in the site, due to the specifics of the terrain (rock pinnacles and boulder fields), will continue to have considerable impact in the habitat used by the breeding skate in areas directly adjacent the site. Skate, though not targeted, will continue to be a significant bycatch from these fisheries and it is nonsensical to protect a site which is unlikely to be fished by these destructive methods, while allowing the area directly adjacent, along with the wider habitats of the Inner Sound, to be constantly hammered by them, likely causing significant harm to the species.
Dredgers and Trawlers can currently encircle the site scraping the bottom all day every day, causing untold damage, with significant bycatch, without any restrictions imposed on them. It’s unfathomable that the proposals do not seek to change this.

Further, pelagic net fishing should also be prohibited from the MPA. Flapper skate have been observed on multiple occasions just below or at the surface. Little is known about the specific breeding and laying behaviour of flapper skate, and so, employing the precautionary principle, the entire water column, should be protected from commercial net fishing.
I see no proposals for management measures to reduce mortality or minimise habitat modification by mobile dredge and trawl activities adjacent to the site and question why the precautionary principle is not being applied to mobile gears where they have the potential to impact the integrity of the site.

For the reasons stated above, access for creel fishing should be retained within the site.

The static gear industry will be disproportionately impacted in relation to their likely impact and should not be excluded from the site.

Insufficient effort has been made to assess the economic impact of the closures on the local static gear sector.