Proposal to designate a Deep Sea Marine Reserve in Scottish waters

We very much support the establishment of this Marine Reserve. The NTS property of St Kilda is not only the nearest point of land to the reserve but it fundamentally depends on the marine resources in this area to support the seabird colony, which is the largest in the eastern Atlantic. The proposed reserve contains a wide variety of rich and extremely vulnerable marine habitats and species, some of which are still in good condition, although many have suffered damage from human activities in the past. The history of the fishery for the Orange Roughy is a case in point as the species is long lived (up to 150 years) and its population in this region was devastated by a relatively brief targeted fishery in the 1990s. Many of the habitats, particularly the faunal communities on the seamounts, including corals and sponges, but also others such as the fragile emergent macrofauna on the burrowed mud sediments, are extremely vulnerable to damage.

We believe that the evidence presented for the listed species and habitats eminently justifies their designation, but we wonder why a number of other species have not been proposed for inclusion. Foremost amongst these are the cetaceans. The ecological advice from JNCC notes that the proposed MPA is important for White-sided Dolphin, Sperm Whale and Fin Whale but it is also the most important site in UK waters for many of the smaller toothed whales (esp. Mesoplodon spp.) and the large rorquals, including the Blue Whale which is listed by OSPAR as Threatened or Declining and specifically requiring protection. Given the known distribution, we question the assertion that insufficient information is available to support their designation. Other species listed by OSPAR include the Black-legged Kittiwake, which feeds in the area. The ecological advice from JNCC correctly highlights that the continental slope here is very important for many seabird species, but especially the European and Leach’s Storm-petrels, both of which breed on the nearby NTS property of St Kilda. We question the assertion that these seabirds will benefit from the fisheries conservation measures adopted in the MPA (see below)

We strongly support the proposal to set objectives to allow habitats and species to recover. There is already evidence that some of the fish species have been depleted by excessive fishing in the past, and that some of the habitats have been damaged by mobile fishing gear. It is therefore important that they are allowed to recover.

We fully support the need to prohibit the use of mobile demersal fishing gear throughout the site. All of the habitats listed, including the muds and other sediments, are considered to be moderately or highly vulnerable to damage from mobile fishing gear. Many of the habitats offer some extremely valuable ecosystem services, especially the storage of blue carbon and provision of nursery areas for a large number of fish species. These could be damaged by the use of fishing gear, especially mobile gear but also, ín the case of the more fragile habitats, by static gear and long-lines. We consider that it is inappropriate to use static gear on the more fragile reef communities.
The JNCC advice suggests, inaccurately, that seabirds will benefit from the proposed fisheries measures. Seabirds do not fish near the seabed in such great depths of water but rely entirely on the pelagic species in the surface waters. It is therefore highly unlikely that they will benefit significantly from the controls on the use of bottom-contact mobile fishing gear.
There is already evidence available that mass mortality of some of the smaller toothed whales has been associated with the use of military sonar. Given the importance of the proposed MPA for cetaceans we consider that the use of such sonar will need to be controlled.

We have considerable concerns. It has gone into exhaustive, and questionable detail on the costs to commercial fisheries sector and made spurious claims about the costs to others (such as the cost of MESAT to the military sector which would be necessary whether or not there was an MPA). In contrast, faced with a level of uncertainty about the benefits in Ecosystem Services, including non-use values, it has failed to come up with any valuations, in spite of the fact that several techniques and statistics are already available (e.g. Brander et al., 2015. The benefits to people of expanding Marine Protected Areas. IVM Institute for Environmental Studies.). It even cites Gubbay (Gubbay, S., 2006. Marine Protected Areas. A review of their use for delivering marine biodiversity benefits. English Nature Research Reports, No 688.) that MPAs result in “overwhelming positive effects” on the biodiversity sector alone. It makes no attempt to quantify benefits to carbon storage even though workable figures are available. The assessment of medicinal and biotechnology use of deep-sea marine biodiversity is superficial. While acknowledging that General Public Non-Use values for marine protection, even in remote, deep sea areas could be substantial, it makes no attempt to review the existing techniques that have attempted to value this in the past (e.g. G. Riddington, A. Radford, & H. Gibson 2014. Management of the Scottish inshore fisheries; assessing the options for change. Marine Scotland Technical Report CR/2012/08).

The overall result is an incomplete and one-sided assessment of the costs of establishment with abrogation of any attempt to quantify its benefits even though it acknowledges, buried it the small print of paragraph 4.3.26, that they probably outweigh the costs. There is a great danger from reading this report that policy makers will focus on the costs, because monetary values have been assigned, and ignore the benefits which may be far greater.

Most of the criticism of the Sustainability Assessment is applicable to the Socio-economic Impact Assessment. There is an acknowledgement that all of the provisioning services (mainly in the commercial harvesting of fish) are only achieved by externalising their costs which may be substantial. Their net benefits have therefore been considerably over-estimated.