Marine Conservation Zones (MCZs): Potential Site Options for Welsh Waters

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6 Νοε 2013 (πριν από 3 χρόνια και 10 μήνες)

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27 Heol y Wig / 27 Pier Street, Aberystwyth, SY23 2LN ￿ : 01970 611621 ￿: enquiry@waleslink.org

Cadeirydd / Chair: Dr Madeleine Havard Cyfarwyddwraig / Director: Susan Evans www.waleslink.org



Marine Conservation Zones (MCZs): Potential Site Options for Welsh Waters


Wales Environment Link (WEL) is a network of environmental and countryside Non-
Governmental Organisations in Wales, most of whom have an all-Wales remit. WEL is officially
designated the intermediary body between the government and the environmental NGO sector
in Wales. Its vision is to increase the effectiveness of the environmental sector in its ability to
protect and improve the environment through facilitating and articulating the voice of the sector.

WEL is a key stakeholder in the marine environmental sector and has been campaigning for
improved management of UK and Welsh seas for a considerable period. WEL was directly
involved in the campaign for a Marine Bill and was pleased to see the introduction of the Marine
and Coastal Access Act in 2009; we continue to advocate its implementation.

WEL welcomes Welsh Governments plans to introduce greater protection to Welsh seas. Well
managed Marine Protected Areas (MPAs), in addition to the use of other management tools
including marine planning and sustainable fisheries management will be critical if Welsh
Government is to achieve its commitment to the UK Governments vision of clean, healthy, safe,
productive and biologically diverse seas
1
.

This response is based on the views of WEL and incorporates comments received from
member organisations. It does not preclude individual members of the group from submitting
independent comment on behalf of their respective organisations. The member organisations of
WEL have differing views on the highly protected approach, and we therefore recommend
referring to our member organisations individual responses for more detail.

Our response is set out in relation to the proposals outlined in the consultation, with detailed
comments contained under the relevant headings below.

However in summary our response directly relates to our concerns in relation to;
· Resourcing  Delivery of new Marine Conservation Zones (MCZs) and existing MPAs
requires adequate resourcing both in relation to the points below, but also from the
creation of Welsh Governments new single environment body.
· Enforcement  Designation of new sites and management of the e xisting MPA network
requires effective surveillance and enforcement to ensure delivery of management
objectives.


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Defra (2009) Our Seas - A shared resource: High Level Marine Objectives. PB13258
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· Monitoring  To ensure that management is effective and lesso ns can be learnt from
new and existing sites, well resourced and timely research and monitoring is needed.

Welsh Environmental Management

The MCZ Project Wales comes at a time when the Welsh Government is reviewing its approach
to the management of the natural environment, with several new Bills proposed as part of its
emerging legislative framework. WEL supports Welsh Governments ambition to underpin future
environmental management within an ecosystem approach as envisaged in Sustaining a Living
Wales. The approach has the potential to be a powerful tool for embedding the Ecosystem
Approach at the heart of government decision-making with respect to the use and management
of Wales natural resources on land and in the marine environment. WEL considers the
ecosystem approach critical for achieving sustainable management of the marine environment,
to enable the integration of nature conservation, whilst recognising the importance of protecting
and allowing recovery of ecosystems that ultimately support a wide range of dependant
environmental goods and services.

WEL feels that it is crucial that MCZs are embedded and integrated in all emerging legislation.
The creation of a new environmental body in Wales has the potential to create a powerful
management organisation for the Welsh natural environment. However, it is essential that any
new body created is adequately resourced to deliver marine protection, effective monitoring and
enforcement. The creation of a new body and determination of its role and remit is a significant
task. We note that the new body will be created during the next stages of the MCZ project. WEL
therefore seeks assurance that during this period, prior to investment, and during the settling
period, there is sufficient capacity in the existing bodies to fully engage with the MCZ process
and other drivers in the Welsh Marine Environment such as the MPA Management Review.

Also relevant is the recently closed consultation on proposals for a Sustainable Development
Bill. The sustainable development duty must be strong and proactive if real change is to be
achieved. The outcome of the resultant Act should be no net loss of biodiversity, with a role to
enhance the natural environment and respect its limits while using only our fair share of the
earths resources. These principles should underpin the decision making process relating to the
creation of MCZs, ensuring coherent and consistent policies are developed across Wales,
enabling maximum benefit and long term enhancement to be achieved within the marine
environment.

Marine Management & International Commitments

WEL welcomes Welsh Government plans to introduce greater protection for Welsh seas
through the MCZ Project Wales. Introducing new MCZs, along with existing MPAs will
contribute towards an ecologically coherent network of MPAs around the UK, to meet the UKs
commitment to several international agreements. For example, the UK is signatory to
international conventions, such as The Convention for the Protection of the Marine Environment
of the North-East Atlantic (the OSPAR Convention). The UK has a commitment under the
OSPAR
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Convention to create an ecologically coherent network of MPAs by 2012. WEL
welcomes the work currently being undertaken by JNCC and other organisations to determine
the objectives and characteristics of a UK ecologically coherent network. Evaluation of whether
an ecologically coherent network has been achieved will become more attainable when there is


2
OSPAR is the mechanism by which fifteen Governments of the western coasts and catchments of Europe, together with the European Community, cooperate
to protect the marine environment of the North-East Atlantic.
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a greater degree of certainty as to which MPAs are likely to be designated around the UK as
part of the various processes underway. WEL seeks to remind Welsh Government that they will
need to continually review Wales contribution towards the UK network over the coming years,
in light of developments in our MCZ process and that of England and the other administrations,
and introduce new sites as necessary.

WEL recognises that an ecologically coherent network of MPAs once formed, implemented and
well managed, will aid the protection of Welsh seas, and as such, we welcome Welsh
Governments step towards this. Used in conjunction with existing sites, MCZs could contribute
towards the protection of common nationally important habitats and species as well as the rare,
threatened and vulnerable, and allow damaged and degraded areas to recover. We therefore
feel that it is vital that the most relevant and appropriate areas are identified and designations
are undertaken swiftly to deliver adequate protection for our marine biodiversity.

Well managed MPAs will be critical to achieving the Marine Strategy Framework Directive
(MSFD) targets for Member States to implement programmes and measures to achieve Good
Environmental Status
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(GES) for the marine environment by 2016. For a network of MPAs to be
ecologically coherent, sites must work together to achieve the best outcome for marine
conservation and ecosystem recovery. This is achieved by ensuring adequate representation,
geographical coverage, and replication of key habitat types and species within protected areas.
WEL advises that the role of any proposed MCZs should contribute towards the delivery of
effective marine conservation and enable ecosystem recovery, and in so doing contribute to the
realisation of GES in Welsh waters.

WEL wishes to highlight Marine Spatial Planning (MSP), as an essential and powerful tool for
coherent management of the marine environment. We feel that a clearly defined spatial plan,
which draws together the threads of other policy drivers such as offshore renewable energy
ambitions, Shoreline Management Plans, the Welsh Fisheries Strategy and sustainable
development, is essential to ensure that the right developments are located in the right place.
MSP should be utilised as the overarching approach to all activities within the marine
environment ensuring delivery of both socio-economic objectives and ecological protection.
WEL also recommends that these essential duties towards the delivery and implementation of
MSP should be considered at the investment of the new single environment body and during the
further development of the MCZ Project Wales.

In addition to the OSPAR agreement and MSFD requirements as previously mentioned, the
Convention on Biological Diversity (CBD) and World Summit on Sustainable Development
(2002) also include commitments to establish, by 2012 an effectively managed, representative,
global system of marine protected areas, comprising both multiple use areas and strictly
protected areas at a UK level. The UK Marine Stewardship Report (2002) set out the
commitment to identify and designate relevant areas of the UKs seas as areas of marine
protection belonging to a network of well managed sites by 2010. WEL highlights these
commitments to ensure that in consideration of the designation of MCZs, Welsh government
uses potential sites to maximise the benefits to Welsh seas and the delivery towards national
and international commitments.




3
The Marine Strategy Framework Directive establishes a framework for the development of strategies designed to achieve Good Environmental Status in the
marine environment, by the year 2020. A network of MPAs is integral to this process.
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Benefits of Marine Conservation for Welsh Waters


MPAs are essential to the conservation and recovery of the marine environment and the wildlife
it supports, and therefore central to the achievement of sustainable development in our seas.
Healthy marine ecosystems play a direct role in supporting many industries, such as fisheries
and tourism. Marine industry is worth £2.5 billion a year with coastal tourism contributing £700
million to Welsh economy annually; both of which are heavily reliant on clean and healthy seas.
MPAs also help developers to identify more sustainable locations for projects. By highlighting
the most ecologically important areas, MPAs can help to steer investment away from
inappropriate locations, and ensure ongoing protection of valuable ecosystem services.

The marine environment is a key provider of many of the ecosystem goods and services, both
direct and indirect, on which we rely. The poorly controlled removal of goods from a system can
lead to problems of over exploitation, uncontrolled use of services and ultimately ecosystem
breakdown. Complex ecosystem functions can contribute to the delivery of several goods and
services, for example the construction and irrigation of complex burrow systems by mud
shrimps, known as bioturbation, facilitates cycling of nutrients, processing and burial
(sequestration) of carbon, and stabilisation of sediment. Ensuring protection of the ecosystem
that underpins all services is essential to the long term viability and provision of ecosystem
goods and services.

WEL recommends that Welsh Government uses the designation of new sites to form a network
of well managed MPAs, increasing resilience and ensuring the intrinsic value of the marine
environment recovers to ensure sustainable and long term use of the services provided. We
also recommend that the research opportunities presented through an effective monitoring and
review programme help develop our understanding of the ecosystem goods and services
delivered from a healthy and diverse marine ecosystem.

Existing Marine Protected Areas in Wales

In terms of scale, Wales has made considerable progress in the proportion of territorial sea
designated as an MPA; a figure that currently stands at over 36%. However, at the last
reporting round to the EU Commission in 2007 regarding the condition and status of marine site
features (habitats and species) within marine SACs and SPAs in Wales, of the marine species
and habitats that were assessed only 53% of species features and 46% of habitat features were
reported as being in favourable condition. Additionally of the habitats and species that were
assessed for status almost 100% of species and 79% of habitats were reported as being in
unfavourable status, meaning there were not under secure management to maintain or improve
their condition. WEL is calling for the improved management, enforcement and monitoring of all
existing MPAs in Welsh waters. It is our opinion that the proposed MCZs will not work
effectively in isolation, they require fully functioning and well managed European Marine Sites
(EMS).

A WEL commissioned report
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highlighted a number of shortcomings in EMS management in
Wales, with current management regimes often failing to provide adequate protection for site
features. In considering the current protection to nationally important features the report stated,
If a nationally important feature is not mentioned specifically within conservation objectives,


4
Jackson, E., Langmead, O., Evans, J., Ellis, R. and Walters, H.T. (2008) Protecting nationally important marine biodiversity in
Wales. The Marine Life Information Network for Britain and Ireland (MarLIN). Report to Wales Environment Link, November 2008.
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then it is likely that little if any effective protection will be afforded it (through the assessment of
plans or projects), even if the site description contains a lot of detail about it. It concluded that
consideration should be given to the use of other mechanisms, including the domestic Marine
Conservation Zones, to protect Important Welsh Features that are not directly protected by
European Marine Sites (EMS). The study found that existing EMS do not cover the entirety of
important Welsh features, and that a number of important Welsh species do not currently occur
in any of the existing EMS. For example Harbour Porpoise, an Annex II species does not
currently benefit from designation as a qualifying species of any of the 14 EMS, and is the only
one of 9 Annex II species occurring in Welsh waters without this level of protection. A further 5
BAP species
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are mentioned within existing EMS, but do not qualify as features in their own
right, limiting delivery of effective protection.

Marine ecosystems are dynamic, often unpredictable and ultimately highly complex systems.
WEL is concerned that with the focus solely on the designation of hpMCZs, the wider picture of
marine management, including that of the existing network in Wales, is missed. By failing to
protect even our best marine areas, we undermine the creation of this network of MPAs, and the
ability of our sea to adapt to the pressures of a changing environment. It should also be noted
that in 2007, information on condition but not status was sent to JNCC for collation with other
countries to be sent to Europe. The next reporting round to Europe, expected shortly, should
include information on status, to give an indication if the existing sites are faring better in terms
of securing effective management. This information should be fed into the decision making on
designation of any new sites to ensure that maximum benefit to the marine environment is
achieved.

WEL believes that a review of existing management measures for Welsh MPAs is an essential
step towards an improved, ecosystem based approach for the conservation and recovery of the
marine environment. We therefore welcome the review of MPA management structures in
Wales currently being undertaken by CCW with input from Welsh Government, with the aim of
informing a new Welsh MPA Strategy. WEL recommends that this strategy should be published
before the second iteration of the MCZ consultation, and that the recommendations should be
carefully considered prior to the final designation of any hpMCZs to ensure maximum benefit to
the Welsh marine environment. It is also of importance that the next round of reporting on SAC
and SPA feature and status is incorporated into the planning of additional designations.

The findings of the MPA Management Review and imminent report to the EU commission on
the status and condition of Natura 2000 sites will also be essential to the duties of the new
environmental delivery body. WEL believes it is vitally important that adequate resources and
powers are given to the new body to ensure it is able to deliver the management and protection
needed for the existing and new MPA suite of sites.

Marine Conservation Zones

The implementation of the Marine and Coastal Access Act, 2009 represents a decisive move
towards improved management of Welsh seas, in order to meet the UK and Welsh
Governments shared vision of clean, healthy, safe, productive and biologically diverse seas.

Under the Marine and Coastal Access Act, Welsh ministers are under a duty to report (M&CAA
article 124) to the National Assembly

on the extent to which the objective of creating a network


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Whiting (Merlangiusmerlangus), Plaice (Pleuronectes platessa), Salmon (Salmo salar), Herring (Clupea harengus) European eel
(Anguillaanguilla)
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has been achieved, and any further steps needed to contribute to the achievement of that
objective. The first report is due before or by the 31
st
December 2012, and then at 6 yearly
intervals following the first report. Amongst other specific requirements, the report must contain
information on the extent to which conservation objectives for each MCZ have been achieved
and any furthers steps needed to achieve conservation objectives. This creates a statutory
driver that links directly to ensuring effective management to achieve conservation objectives of
sites as part of an MPA network. The Act also states that due regard must be given to
obligations under EU and international law relating to the conservation or improvement of the
marine environment. We urge Welsh Government to ensure that this reporting duty is used to
assess and effect change in the management of all MPAs in Wales, in order to fully contribute to
a UK network and provide maximum benefit to the marine environment.

Whilst the aim to underpin existing sites with newly designated MCZs may address some of
these issues, it is clear that effective management, and resourcing and as necessary
enforcement is still required to ensure that European sites reach favourable conservation status
and condition.

The creation of Marine Conservation Zones (MCZs) in Welsh waters will be an important step
towards the effective management of the UKs valuable marine natural resources. Whilst
existing policy drivers refer to the creation of an ecologically coherent network, MPAs
throughout UK waters have not been designated as part of a single policy to create a coherent
network, but rather as individual designations in response to the aims of the relevant enabling
legislation. Most recently, the Marine and Coastal Access Act places a duty on appropriate
authorities to designate MCZs in order to create a network together with other MPAs. The
network must fulfil the following conditions:

· It must contribute to the conservation and improvement of the marine environment in the
UK;
· It must represent the range of features present in the UK marine environment, and
· That the designation of sites comprised in the network reflects the fact that the
conservation of a feature may require designation of more than one site.

WEL therefore recommends that Welsh Government takes the necessary steps to ensure these
conditions are met in Welsh waters.

MCZ Site Selection Process

WEL welcomes Welsh Governments plans to utilise the provision of MCZs under the MCAA to
introduce greater protection for Welsh seas. However, WEL is concerned that the eventual
designation of 3 or 4 sites will not fulfil their objectives as set out in the consultation and Site
Selection Guidance of contributing to the recovery and enhanced resilience of Welsh seas.
WEL would also seek to remind Welsh Government of its commitments as set out previously
under other conventions and in particularly that under the MCAA to deliver an ECN at a UK
level.

WEL recognises that selecting sites based only on actual data sets ensures that there is clear
evidence of the habitats present. The approach has been taken as part of the ecosystem
approach in line with Sustaining a Living Wales, and considers whole ecosystems instead of
specific habitat or species. Whilst we welcome ecosystem based thinking, this approach does
not consider rare or sensitive features, those that would benefit most from additional protection.
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The weighting for habitat types and approach used leads site selection on a particular route and
does not consider factors such as mobile species. The decision to identify the areas of highest
habitat heterogeneity, does not allow full consideration of potential sites containing habitats that
are rare or particularly sensitive. The approach appears to select sites in isolation of what is
already designated within the existing MPA network and potentially missing sites that would add
the greatest value to the existing network or the best examples of certain habitats.

The 10 sites as currently proposed do not appear to address the most damaging activities,
indeed most site boundaries fail to cover areas where such activities currently occur. Whilst
WEL recognises Welsh Government wish to exclude certain areas due to other policy needs, as
addressed above, the suitable selection of sites could have provided added value in regards to
improved management of marine areas through exclusion of highly damaging activities.

Evidence Base

To date Government investment in understanding marine ecosystems has not been on an equal
footing with that of the terrestrial environment. Management of marine ecosystems has to a
certain degree been hindered by not having a full understanding of marine ecosystem
functioning and provisioning of goods and services. Valuable work has been conducted by a
range of stakeholders, including higher education institutions and the environmental NGO sector
in Wales, which could be better harnessed to increase our understanding of natural resources
within the marine environment and inform how these could be managed sustainably for the
future. Whilst more investment and greater coordination with regard to evidence gathering
would be welcomed, particularly the establishment of a Marine Evidence Group, risk-based
decision-making should utilise existing data, adopting a Precautionary Principle and utilising
expert judgement where necessary.

WEL supports the need for comprehensive data collection to improve our understanding of all
sites that are eventually chosen to become MCZs. It is essential to determine an accurate
baseline for the final sites in order to effectively monitor change and determine the level of
success. As change will undoubtedly take time, it is important that sufficient resources are
allocated for the monitoring and review of the sites. As well as increased understanding of the
ecological process, the 6 year review period will help to inform future decisions, from
management of existing MPAs to informing the designation of future MPAs. For some of the
proposed sites long term data sets exist, WEL seeks assurance that if these sites are not
progressed towards full hpMCZ status, resourcing is provided to continue the valuable
monitoring work at these sites.

Site Boundaries


WEL is concerned about the application of socio-economic filters during the process. With the
10 sites presented within this consultation being drawn from a much larger list containing 24
sites, decisions used to exclude or include certain sites, and documented within the
consultation, show that socio-economic factors have already been used, albeit at a high level.
The decision to remove all sites posing potential conflict with other policy drivers such as energy
security and the deployment of marine renewables has removed sites with important habitat
features. Within Milford Haven for example, Maerl beds, a UK BAP Habitat, are not covered by
any of the proposed sites due to the exclusion of 3 sites within the waterway. This process has
lead to the exclusion of some sites that would warrant additional protection, but are incompatible
with the approach and its effects on other policy drivers. The consultation requests further socio-
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economic factors to better refine the site options put forwards. This again raises concerns that
socio-
economic factors will be given an uneven weighting in comparison to ecological concerns.

Stakeholder Engagement

WEL would like to highlight and acknowledge the opportunity to increase our limited understand
of how the sea is used in Wales through the site selection process. Stakeholder engagement of
all marine users is essential to ensure that the full spectrum of knowledge is captured. This
information should be used to help inform future management decisions. We believe that
stakeholder engagement is instrumental to the success of MCZ implementation. However, we
have concerns regarding the level of effective stakeholder engagement during the MCZ
consultation process. This has resulted in considerable misinformation concerning the
proposed highly protected nature of sites by the general public and disillusion by sea users.

Whilst WEL welcomed the creation of the Stakeholder and Citizen Advisory Group (SCEG) and
our representation on the group, the level of activity of the group has to date has been limited
despite strong interest by several members for the group to be more active. Also there have
been concerns that Welsh Government engagement with the SCEG to be perceived by many
Welsh marine stakeholders as being that of a top-down approach. More effective engagement
with SCEG members may have resulted in clearer terms of reference, and two-way dialogue
between Welsh Government and SCEG members. WEL would welcome clarity as to the role of
the SCEG in the next steps of the MCZ project. WEL is aware that the SCEG group proposed a
public participation plan to support the launch of the consultation, and raises concern that Welsh
Government opted to develop its engagement plan in isolation of the outputs from the SCEG.

Feedback from the consultation on site selection guidance indicated the need for extensive
engagement/ consultation with interest groups/ individuals. Welsh Government acknowledged
this and pledged We are/ will arrange a variety of meetings with key sectors and interested
groups, together with public events, throughout the consultation process. Unfortunately the
engagement plan during the consultation has appeared ad hoc, and has led to a greater level of
conflict and confusion than expected.

WEL has welcomed the use of public meetings during the consultation period, and believes
them to be a valuable mechanism to address stakeholder concerns. Whilst we appreciate the
limited resources available to undertake public outreach, it is clear that a number of lessons can
be learnt from these events, including the potential for Welsh Government to have held a
greater number of well publicised meetings (bilingual where possible), clearer frequently asked
questions, or a section of the consultation website to indicate where the nearest public meeting
was to be held. WEL would like to highlight the significant level of mis-information cited by many
sectors and individuals, for example, in the media that has unnecessarily inflamed discussions
and meetings. We feel more should have been done to address this and give clarity to Welsh
Government proposals. We would welcome a summary of recent public meetings to be
produced and made available through the Welsh Government website. WEL also believes that
the objectives of designated MCZs need to be clearly defined and expectations must be
managed for their outcomes.






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Cross Border

The designation of MCZs within Welsh waters needs to act in cohesion with MPAs designated
in inshore and offshore waters around the UK, to create an ecologically coherent network along
with existing MPAs, including those of European importance.

It should be noted that English-led regional projects have recommended MCZs within Welsh
offshore waters, and a number of these in areas adjacent to Welsh territorial waters. These
potential sites are now under consideration as part of the wider Defra MCZ project for English
inshore and UK offshore waters. Although predominantly selected by non-Welsh stakeholders,
these recommended sites lie within the Welsh marine planning area, and within the Welsh
Fisheries Zone. As a result, management duties may fall within the jurisdiction of the Welsh
Government and the Common Fisheries Policy. WEL therefore feels it is essential that any sites
designated as a result of this consultation are situated where they add the most value to the
existing MPA network within Wales and in conjunction with the UK network in order to deliver an
ecologically coherent network at a UK and European level.

Delivery and Enforcement

It is evident when considering existing MPAs in Welsh waters that designation is merely the
start of a process towards improved marine ecosystem health  effective management is what
delivers results. WEL seeks assurances from Welsh Government that any new sites will be
adequately resourced and appropriately managed, as a designation lacking appropriate
management will not constitute the protection required to assure success.

In response to concerns over Government(s) preference for voluntary management in MCZs,
WEL commissioned a report to investigate the role of voluntary measures in the protection of
MPAs
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. A clear finding was that a voluntary approach to management was not deemed
appropriate for MCZs in Wales, particularly as these sites are intended to deliver high levels of
protection. It is also important to consider the need for stakeholder buy in to the designation of
any new sites. Without backing from stakeholders, enforcement of management measures will
be extremely resource intensive.

WEL seeks a commitment from Welsh Government to provide funds sufficient to not only
manage the new and existing sites, but to deliver a comprehensive management plan, which
should include a resourced plan for monitoring and review. This will help the sites realise their
full potential both in terms of increasing understanding of the ecological functioning of Welsh
seas through scientific research and in ensuring that the sites are delivering towards a UK
ecologically coherent network.

As mentioned previously, the new sites are part of a much wider network in Welsh waters. The
existing network also requires a commitment from Welsh Government to the continuation of
funding and resource allocation to deliver the associated conservation objectives. Whilst CCW
is undertaking its management review, and will publish recommendations in due course, it is
important to highlight the importance of the existing resource in the form of local expertise within
the European Marine Site officers, their associated Relevant Authority Groups, the Skomer
MNR team and local coastal forums such as Pembrokeshire Coastal Forum and the Severn
Estuary Partnership. These are established groups that have developed working relationships


6
Prior (2011) An investigation into the use of voluntary management measures for the protection of UK marine biodiversity
10

with a wide range of stakeholders and will be essential to the delivery of management plans for
both existing and new sites.

As the consultation notes, much of the enforcement is likely to fall to the Welsh Government
Fisheries Unit. WEL notes that this team does not appear to have sufficient capacity to
effectively deal with illegal activities within existing Welsh MPAs at present, therefore we seek
assurance that additional resources will be allocated to ensure that the new sites achieve their
aims. WEL, like other marine stakeholders in Wales, including the fishing industry, have
significant concerns that Welsh Government does not presently have sufficient enforcement
capacity to deliver existing obligations. As such, further responsibility for MCZs emerging from
the English Regional Projects, could place additional strain to an already limited resource within
Welsh Government Fisheries Unit.

WEL welcomes the proposed Boat Tracking Service of scallop vessels in Wales and its addition
as a tool to enable effective management. The approach may free up some much needed
resources, enabling a more focussed approach on MPAs. However we feel further work is
needed to establish effective management across the entire MPA network. WEL notes that the
Environment Agency has a number of enforcement staff, which deal primarily with inshore shell
fisheries and recreational angling. As such there could be potential efficiency savings in utilising
this capacity within the new single environment body to aid the fisheries unit further. We
understand that within CCWs MPA management review recommendations there will be an
emphasis on streamlining the current management approach. Whilst we accept that a more
efficient approach to management and enforcement will enable a greater spread of resources,
this should not result in the dilution of what can be viewed as an already limited resource. WEL
therefore seeks assurance that resourcing of existing enforcement is supplemented to ensure
the effective management of both proposed MCZs and existing MPAs.

Impact Assessments

WEL strongly advocates that a level playing field is applied to the scrutiny of all data information
received through the consultation process, both ecological and socio-economic. If submitted
information, either qualitative or quantitative, is to act as data and be given due regard within the
decision making process, then good data standards should be in place to ensure that it is
robust.

WEL would welcome further consideration of the positive benefits that introducing greater
protection for Welsh seas could provide, including the benefits for tourism and ecosystem goods
and services. Unfortunately, at present the consultation places greater focus on the potential
negative aspects and impacts of the creation of highly protected areas as proposed. Instead,
WEL believes it would have been a more effective approach to have an upfront explanation of
the types of benefits that Welsh Government expects to achieve from undertaking this process.
In this manner, the larger picture would have been clear to all stakeholders, and the balance
being sought between potential negative effects and benefits.

During the development of the Impact Assessments for the second iteration of the consultation,
WEL asks Welsh Government to fully consider the benefits that will be associated with
designating new sites. This should address the benefits to all social, economic and
environmental considerations, with reference to the ecosystems goods and services provided by
the underpinning marine biodiversity, and should include consideration of the marine
environments intrinsic value.

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Next Steps

WEL considers it essential for Welsh Government to deliver a swift response to the consultation.
To this end, we would welcome a summary of consultation responses providing clarification of
any misinformation in consultation responses to ensure that stakeholders feel their contribution
to the consultation has been worthwhile. Furthermore, WEL would welcome a prompt statement
by the Environment and Sustainability Minister to provide clarity on policy proposals and next
steps and the associated timeline with the MCZ project. To maintain momentum in the
consultation, WEL recommends that the second iteration follows as soon as possible, and
provides a clearly set out timeline and approach for taking forward the MCZ Project towards
designation in 2014.

Furthermore, WEL urges Welsh Government to publish their MPA Management Strategy and
recommendations from the CCW review as soon as possible, and use the recommendations to
ensure cohesion between the existing MPA network and potential new MCZs.


The following WEL members support this document:


Marine Conservation Society

RSPB Cymru

Wildlife Trusts Wales

WWF Cymru





















Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape,
wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd âu hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun,
bywyd gwyllt ac amwynder yng Nghymru
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Reg. Charity No: 1022675 Rhif Elusen Gofrestredig: 1022675