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

Red Rocks is currently the largest known flapper egg laying site, both physically and in egg concentration, making it of clear National and international Importance. There are only a very small number of other known egg laying sites, so all sites should be afforded protection from the most damaging forms of fishing and other marine activities.

Sadly, Scotland’s inshore ecosystem has been devastated by bottom-towed fishing gear which has impacted many fish species. This MPA is a hopeful step towards inshore recovery, but without a wider and urgent transition to low impact fishing gear throughout inshore waters the Scottish Government is simply tinkering at the edges of environmental and fisheries recovery.

With a minimum of 1000+ purses found over an extended area, this proves crucial importance of this site to the life cycle of flapper skate. Flapper skate are one of many species which have been badly impacted by poor fisheries and environmental management. Given there is strong evidence that this area is a nursery site, it is only right that it is protected in a way that promotes the recovery of this fish population.

We fully agree that Dipturus intermedius is a feature that should be protected within the Red Rocks and Longay permanent MPA.

We have no expertise in regards to the Quarternary of Scotland or the geological features mentioned. However, as flapper skate appear to prefer raised boulder ground in a depth range of 15-35m, it would be prudent to protect these features which form part of the Essential Fish Habitat for the species.

We have some concern that protection has not been afforded to the muddy habitats adjacent to the MPA boundary. Although limited, some research suggests that juvenile flapper skate, once hatched, move away from the egg laying habitat and utilise muddy habitats (this was suggested from evidence of bycatch in the Nephrops fishery and in Nature Scots advice). The water adjacent to the egg laying site is subject to bottom trawl and dredge fisheries for 6 months of the year and there are large areas of soft, muddy habitats. Protecting this burrowed mud feature will protect the juvenile hatched skates along with the breeding adults. In addition, tagging of flapper skate has shown that adult flapper skate spend much of their time in water between 100-200 and more recent work shows that flapper skate do use all depths available to them, and they move to shallower water to lay eggs. There is deeper water adjacent to the egg–laying habitat in the Inner Sound which adults may also use. Therefore, both adults and juveniles might be at significant risk to the bottom trawl and dredge fishery.

There are known maerl beds and flame shell beds to the west of this site’s boundary proposal. NatureScot advised that they should be part of this site and Marine Scotland has identified that they deserve better protection as long ago as 2018. These should be included in the list of protected features and the site should be extended to protect them.

The current boundary for the Red Rocks & Longay MPA only protects the egg laying sites alone and does not account for protection of hatched juveniles and breeding adults.

Allowing bottom-trawling and dredging to occur in the Southern Inner Sound Protected Area (which surrounds the proposed Red Rocks & Longay MPA) for 6 months of the year will put significant risk on the site integrity and could potentially injure or kill flapper skate.

An inshore limit on bottom towed fishing gear would ensure site integrity and robust protection for the flapper skate and associated features and essential fish habitat which it relies on.

We would like to stress that we fully support the advice to request licence for scientific and citizen scientific work and support allowing hand scallop diving and recreational diving activities as outlined in the CMA.

With regards to the buffer zone surrounding the area, we think that the likelihood of damage caused by each activity should be taken into account 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 impact should have smaller buffer zones.

We think that pelagic fishing activity should also be prohibited across the entire site. Flapper skate have been observed on multiple occasions just below or at the surface. Nothing is known about breeding/laying behaviour of flapper skate, and so, employing the precautionary principle, the entire water column should be protected from all fishing activity that may impact the life-cycle of flapper skate.

There is no clear justification for the proposed ban on creeling, given NatureScot’s statement that a reduction or limit on creeling should be considered, rather than removal of the activity throughout the site. We must look at a just transition towards low impact fisheries in our inshore waters. A prohibition on creeling does not seem to be a proportionate approach or consistent with fisheries management elsewhere. It would also have the secondary impact of disincentivising lower impact fishing methods.

We do not agree that creeling should be excluded as proposed. There is no clear justification for the proposed ban on creeling, given NatureScot’s statement that a reduction or limit on creeling should be considered, rather than removal of the activity throughout the site. We must look at a just transition towards low impact fisheries in our inshore waters. A prohibition on creeling does not seem to be a proportionate approach or consistent with fisheries management elsewhere. It would also have the secondary impact of disincentivising lower impact fishing methods.

We support the SCFFs management proposal to reduce or limit the intensity of creel fishing within flapper skate egg-laying habitat and strongly support the removal of Nephrops creeling from the list of prohibited activities, providing the activity is carried out at depths deeper than 40m and only on muddy and soft habitats. We contend that this is more closely aligned with NatureScot advice than the proposal.

We warmly welcome the change whereby diving is no longer banned from the site. We consider that the inclusion of diving (both creel and recreational) was a punitive move which had no basis in science. We welcome the fact that this has been rectified.

This coalition supports the reinstatement of an inshore limit on bottom-towed fishing gear and a transition towards low impact fisheries. Designations and management of protected areas should work for both fishermen and the conservation and recovery of the environment.

Under current proposals, we think the static gear industry will be disproportionately impacted in relation to their likely impact. We are concerned that piecemeal spatial management measures will unfairly impact all fisheries. We contend that it is incumbent on Marine Scotland to fundamentally reform the management of our inshore waters and for fisheries management measures to be coordinated as part of a more comprehensive package of inshore spatial management, rather than a series of protected areas and separate processes. It is vital that fishermen are supported through any transition.
https://www.ourseas.scot/frequently-asked-questions/#how-might-a-just-transition-work