Memorandum submitted by Professor J D
Gage, Dunstaffnage Marine Laboratory, Oban
EXECUTIVE SUMMARY
Management of UK "Continental Shelf"
seabed is now the responsibility of Defra and devolved bodies
such as the Scottish Executive. The UKCS is a huge area but faces
serious threat to habitat and biodiversity from trawling. On the
continental shelf seabed habitat has been degraded by over fishing
at historical time scales. Deep-sea bed within the UKCS beyond
the shelf edge arguably may represent the only remaining large
pristine reservoir of marine biodiversity. But this continental
margin is subject to intense pressure by new deep-sea fisheries.
In the context of this wide-area, but physically episodic, impact
and its poor spatio-temporal resolution the traditional terrestrial
or coastal concept of Special Areas of Conservation (SACs) may
need to be reconsidered. Consultation on offshore conservation
needs to include a more comprehensive spectrum of academic expertise.
The urgency of marine conservation, particularly issues related
to commercial fishing, have an ecosystem dimension that deserves
more effective use of the marine community in the UK, particularly
that supported by the Natural Environment Research Council.
1. Recognition of finite rather than infinite
living resources and dilution capacity for waste in the oceans
has come late in the day. The explicit commitment of Defra's to
sustainable development is welcome and widely admired in European
countries such as Germany. Defra's commitment to influencing new
orientation in marine issues, such as the Common Fisheries Policy
(CFP) and Special Protection Areas known generally to marine conservationists
as marine protected areas (MPAs) is exemplary in a European context.
2. SEERAD (Scottish Environment and Rural
Affairs Department) has responsibility for UKCS seabed off Scotland
out to 12 nm, while Defra through the Joint Nature Conservation
Council (JNCC) is responsible for UKCS seabed from 12 nm out to
200 nm (most of which lies off Scotland). Because of the continuity
of the marine environment some issues are difficult to refer to
one or either body and I apologise in advance for comment deemed
inappropriate to the terms of reference.
3. On the continental shelf in areas such
as the North Sea there has been a substantial research investment
by bodies such as Defra to better understand the wider ecosystem
effects of fishing. How much has been translated into management
policy? Measures aimed to protect the seabed environment are needed
urgently. Areas closed to fishing might provide the best initial
means to conserve what remains of seabed biodiversity and encourage
restoration, as well as help maintain fish stocks at sustainable
levels. Where oil/gas structures exist the consequent exclusion
to fishing already provides refuge for some commercially targeted
species and provide attachment substratum for organisms such as
cold water corals.
4. As well as such inshore areas and the
adjacent continental shelf (including part of the North Sea),
the UKCS includes the continental margin (here taken here as the
continental slope and rise), part of an adjacent deep-sea basin,
the Rockall Trough, most of the Rockall Bank along with other
submarine banks, three large seamounts and the Wyville Thomson
Ridge and a large part of the Færoe Bank Channel and Færoe-Shetland
Channel. Further west it includes part of the Iceland Basin. The
vast majority of this area lies deeper than 200 m and is therefore
technically part of the deep sea. I understand that the JNCC is
at an early stage of considering areas of this huge seabed for
SAC status within the EU Habitats and Bird Directive. My comment
is that despite the considerable progress achieved in the Strategic
Environmental Assessment (SAE) process it is arguable whether
UKCS deep waters are in general yet sufficiently well-known to
allow effective conservation management by means of designation
of Special Areas of Conservation (SACs) and Special Protection
Areas (SPAs) in the terrestrial or coastal sense of areas with
defined boundaries.
5. The impact of the Strategic Environmental
Assessment (SEA) process which, I understand, is now operated
by Defra has been considerable. The new science has not only informed
hydrocarbon exploration and management, but also our broad-scale
knowledge of the UKSC, particularly that in the deep sea. It should
be recognised this builds on previously NERC-supported, ongoing
programmes of research in these areas undertaken by bodies such
as SAMS (previously the Scottish Marine Biological Association,
SMBA) dating back to the 1970s. It should be noted that this new
science continues a tradition started in Edinburgh in the middle
19th century which laid the foundations of deep-sea biology by
HMS Challenger. This has been undertaken as curiosity-driven projects
very largely by NERC or NERC-related scientists, rather than by
the fisheries laboratories.
6. The dilemma is that effective conservation
strategy is urgent because an increasing proportion of this UK
deep-sea area is becoming exploited by man, either by oil/gas
exploration (there are three producing fields in the Færoe
Shetland Channel) or deep-sea trawling.
7. Scientists will always ague that insufficient
is known in order to attract more funding. Whether or not the
second argument applies I leave to the committee to decide. The
first argument, however, is almost certainly true because, compared
to land we have only a very coarse resolution of the submarine
biosphere; too coarse perhaps except in a few areas to apply a
similar philosophy in delineating areas for conservation. Furthermore
it can be argued that because of its openness and the dispersal
capability of marine organisms as water-born larval stages the
natural restoration of impacted areas will be inevitable. This
argument is probably spurious because of the large and physically
episodic, rather than diffuse, scale of present impact.
8. Overall, oil/gas activities in deep water
seem to have had little adverse effect on the deep-sea environment.
But monitoring studies have been limited and the large-scale surveys
were undertaken some time after the start of oil/gas operations
in deep water.
9. It is now widely recognised that trawling
using aggressive rock hopper type gear for deep-sea demersal fish
species by EU fishing fleets has had by far the most serious impact
of man's intrusions on the seabed environment of the UK continental
margin. This is arguably the only genuinely pristine marine habitat
remaining off the UK. Although some (the authoritative International
Council for the Exploration of the Sea, ICES argues quite inadequate)
regulation is now in place collateral impacts on other, non-targeted
fish populations in the deep sea have been completely ignored
even though these include species, such deep-sea sharks and rays,
with known low fecundity, and probably low growth rates. Some
of these species are already thought to be endangered.
10. As well as the unknown effect of unwanted
by-catch thrown back as dead biomass, demersal trawling using
heavy rock hopper gear in particular causes severe physical damage
to attached seabed organisms, such as soft corals, sea pens sea
urchins and hard corals. In the case of the framework structures
created by slow-growing cold-water corals this will be irreplaceable
in our life time. Delicate and rare invertebrate organisms living
on glacial boulders uprooted by trawling probably will die. The
number of boulders dragged out of the seabed seems to have increased
dramatically on areas of the continental slope trawled using rock
hoppers. The soft sediment ecosystem on the continental slope
is one of the most bio-diverse on this planet, and is thought
to rival tropical rain forest and coral reefs in numbers of species.
The sediment-draped continental margins have not benefited from
levels of NGO and public concern applied to the latter, but may
be no less important to the planetary biosphere. Potential sediment-bottom
impacts remain as yet un-investigated in the deep NE Atlantic.
11. Cold water coral may once have been
common along the continental margin off Scotland; but deep-sea
trawling will certainly have severely damaged many of these reef
areas which are known from EU-funded 5th Framework studies by
SAMS and other European partners to shelter large numbers of seabed
species.
12. It is difficult to see how deep-sea
fisheries can be sustained much longer before stocks completely
collapse. Unfortunately, by that time probably irreparable damage
to the seabed environment will have been done which post hoc designation
of SAC status will do nothing in the short term to alleviate.
The only measure that might salvage some remnant of such seabed
biodiversity would be for the UK to persuade the European Commission
to take emergency measures to close the whole deep-sea fishery
in the UKCS (which must represent by now a tiny and rapidly declining
total fish catch of countries such as France).
13. Sea mountains (seamounts) within the
UKCS are even more impressive, volcanic structures, and have probably
already been targeted by deep-sea trawlers for species such as
Orange Roughy. These seamounts include the Anton Dohrn, Hebrides
Terrace and Rosemary Bank seamounts. All are located in the Rockall
Trough. Despite their size and likely scientific importance as
hotspots of unique biodiversity (the Anton Dohrn seamount covers
an area roughly the size of Greater London), and the distinct
possibility of trawl-related damage, no survey by deep-sea biologists
of these areas has been undertaken or commissioned by Defra or
JNCC.
14. Therefore the question is whether the
concept of SAC as marine protected areas can be usefully applied
to UKCS seabed. I am not aware of a detailed rationale justifying
this in deep waters. Yet this is worth examining in an expert
scientific manner because, as indicated in Paragraph 7, processes
in the seas differ from terrestrial habitat and biodiversity in
many ways.
15. JNCC have highlighted four sites as
potentially qualifying under Annex I of the Habitats Directive
as "offshore SACS" within the UKCS beyond the 12-mile
limit of current legislation for marine protected areas. The first
is the Darwin Mounds (now in a welcome but long-awaited announcement
by Fisheries Minister Ben Bradshaw to receive emergency protection
with a prospect of designation as an Area of Special Scientific
interest, SAC, under the EC Habitats Directive). Although important
it is certainly not the only, or perhaps even "the best example
of a cold water coral reef known in UK waters". This is because
at least one moderately large inshore cold-water coral reef site
off the Western Isles in Scotland recently has been surveyed in
detail by SAMS and Scottish Natural Heritage (SNH).
16. Other sites I understand are being considered
by JNCC include the seamounts mentioned above. But I gather their
case lacks sufficient supporting environmental information. These
seamounts remain to be included in any SEA known to me. I believe
the most comprehensively robust science should always be available
to such decision making.
17. In order to meet the challenge of man's
ever-increasing impact on the seas so cogently argued by Defra
there is a recognition not only for broad public awareness of
the marine environment, but also more reactive and "joined
up" strategies to provide Defra with information based on
robust science. It follows that in order to harness the full range
of talent and skills in marine science to meet these challenges,
partnership with other responsible bodies funding environmental
research ought to be encouraged to the full. However, because
EC fisheries research has since 2000 been substantially devolved
to national governments each Government was allocated a share
of the total to distribute in whatever way it thinks fit. The
result, in the UK, has been that these monies were given by the
Treasury exclusively to the Government Fisheries laboratories
in Lowestoft (Cefas) and the Fisheries Research Laboratory (FRS)
Aberdeen (the latter under the control of SEERAD, the Scottish
Executive Environment and Rural Affairs Department). The consequent
withdrawal of EC funding underpinning "Study Projects in
Support of the CFP (Common Fisheries Policy)" blocked a flow
of funding to Universities, previously a system of competitive
bidding for funds from clusters of collaborating academic institutes
across Europe. This effectively reduced funding to an area of
environmental science in which UK academics were at the leading
edge of research. Since then a number of collaborative projects
appear to have been funded. But the amount overall may be disproportionately
small in relation to the expertise available in NERC and the Universities
and the total budgets of the fisheries laboratories.
18. The Natural Environment Research Council
(NERC) is seen by Defra as providing support across many aspects
of marine science helping to underpin fisheries management. These
presently include topics such as climate change, biodiversity
and marine productivity. I am optimistic that ecosystem-level
effects of fishing will also eventually be included in NERC's
mission. These effects have been shown in authoritative Sloan
Foundation-funded Census of Marine Life (CoML) research to have
a long historical dimension in Europe. Over fishing is thought
to be a prime determinant of the degraded biological status of
present-day marine environment in coastal waters worldwide (Jackson
et al. 2001[3]).
19. In any case such turf boundaries are
contrary to Defra's aspiration for the best possible science to
be applied to understanding the processes and influences that
impact on the marine environment to inform policy-making and marine
management in this area. This is particularly so where they relate
to SACs, SAEs and the identification by the Department of Transport
of MEHR areas. Any contrary policy limits potential support to
NERC's own research centres and collaborative centres such as
SAMS on environmental issues related to fisheries matters while,
ironically, allowing the Government Fisheries Laboratories to
continue to compete for NERC responsive-mode research grants.
20. If the Committee's review prompts greater
commitment by Defra or SEERAD to research the almost completely
unknown impacts on deep-sea floor habitat currently trawled over
by EU fishing fleets then I suggest that in the short term it
would be more cost-effective to fund presently available expertise
in the Universities or collaborative centres such as SAMS, rather
than attempt to acquire this itself.
21. Defra's declared aim is to make best
use of marine science. Existing coordinating bodies might then
include ecosystem effects of fishing in their remit so that the
present serious knowledge gaps (particularly in the UKCS) can
be addressed with the urgency these issues deserve. These should
be considered along with the necessary environmental information
to inform offshore and high seas conservation, such as marine
protected areas.
22. It can be mentioned here that progress
towards High Seas MPAs is developing rapidly, and the hope is
that areas such as seamounts will achieve protection as a result
of UN action within a few years as a result of work by the World
Conservation Union (IUCN). It would look silly if Defra, after
its refreshing new vision were to be left behind and find itself
obliged to adopt conservation measures for the UKCS that had already
been adopted by the UN for the high seas beyond the UK's territorial
seabed.
12 September 2003
3 Jackson JBC and 18 others (2001) Historical overfishing
and the recent collapse of coastal ecosystems. Science 293:629-638.
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