Select Committee on Science and Technology Written Evidence

Memorandum 8

Submission from the Royal Society for the Protection of Birds


    —  This response focuses on the use of marine sites of special scientific interest, and the impact of climate change on UK seabird populations.

    —  There are serious shortcomings in the current marine nature conservation framework. Progress on the designation of marine Special Protection Areas in UK waters (required by EU legislation) is unacceptably slow, and hampered by inadequate data.

    —  The UK's nationally important marine wildlife needs better protection, and the forthcoming Marine Bill must include provisions to identify and designate Nationally Important Marine Sites, some of which will be highly protected, with all damaging activity prohibited.

    —  There is evidence that warming of UK waters is changing the food web, creating food stress for certain seabirds, adversely affecting their breeding success and survival, and ultimately reducing population sizes. The strong dependence of many seabird populations on sandeels, whose abundance is declining, appears to be a key pressure point.

    —  The Danish-led industrial sandeel fishery must not aggravate the depletion of local aggregations of this species on which breeding seabirds depend. There is a strong case for maintaining indefinitely the closed area for sandeel fishing off the east coast of Scotland/north-east England.

    —  The geographical spread of comprehensive research into climate change impacts on seabirds should be widened beyond the current relatively circumscribed area of Scottish North Sea coast to include other UK coastal regions. This should be accompanied by full integration of seabird research efforts into the Natural Environment Research Council-led Oceans 2025 programme.

    —  The RSPB is a member of Wildlife and Countryside Link, and the UK partner of BirdLife International. Both have responded separately to this Inquiry, and we fully support their responses.


  1.  The RSPB is Europe's largest wildlife charity, with more than one million members, and we manage one of the largest conservation estates in the UK, comprising 200 nature reserves. We are part of the BirdLife International partnership, a global alliance of independent national conservation organisations working in more than 100 countries. The RSPB's policies are based on detailed and comprehensive scientific research, and we have considerable expertise on the operation of terrestrial and marine ecosystems, and the factors governing bird population trends.


  2.  The RSPB, working with other NGOs through Wildlife and Countryside Link, is campaigning for better management, protection and conservation of important marine assets. We therefore welcome the proposals for a Marine Bill, and we responded in detail to the Government's Marine Bill consultation last summer. Although we were disappointed that there was no draft Bill in the 2006 Queen's Speech, we are heartened by the promise of a Marine White Paper this spring, and hope to see a full Bill in the 2007 Queen's Speech. This must deliver strong measures for nature conservation—if it does not, it will be a squandered opportunity.

  3.  The RSPB is concerned about serious shortcomings in the current marine nature conservation framework.

  4.  The identification of marine Special Protection Areas (SPAs), required by the EU Birds Directive, is crucially important to the conservation of seabirds of European importance, but is far from complete: to date, only one true marine SPA has been designated in UK waters.

  5.  The European Court of Justice (Case C-6/04, European Commission vs United Kingdom, 20 October 2005) has confirmed that the EU's Birds and Habitats Directives apply within the territorial waters and the continental shelf and superjacent waters of the UK. The Court also required the UK to implement surveillance requirements for habitats and species of Community interest, necessary in order to determine whether the UK is meeting its conservation obligations under the Habitats Directive.

  6.  Among other things, this means the Government must now identify, designate, monitor and manage a complete network of European protected areas to meet the requirements of those Directives in the marine environment: SPAs for birds and Special Areas of Conservation (SACs) for other habitats and species of European Community interest. Robust and comprehensive surveillance data will be essential to underpin decisions on both the identification and long-term management of these sites.

  7.  The Joint Nature Conservation Committee (JNCC) has responsibility for surveying and identifying potential marine SPAs to recommend to government for designation. JNCC has identified a three-element approach to this work, which we broadly support: (1) seabird breeding colony SPA extensions; (2) inshore aggregations of non-breeding waterbirds; and (3) offshore aggregations away from the coast at any time of year (eg foraging seabirds from breeding colonies).

  8.  Elements 2 and 3 are the most challenging, requiring substantial additional survey and analysis to ensure that the resulting marine SPA network is fit for purpose, identifying sites that reflect the most important areas for seabirds in the pelagic environment.

  9.  We are particularly concerned about JNCC's heavy reliance on European Seabirds at Sea (ESAS) data for element 3. Our concerns centre on the comprehensiveness of survey coverage in both spatial and temporal terms, essential to ensure we protect the right places. Much of the ESAS systematic survey data is at least 10 years old, with more recent data tending to be gathered in a patchy or ad hoc fashion, mainly from the outcomes of developers' project-specific environmental impact assessments. Given the strong evidence of a climate change-induced "regime shift" in the North Sea (see later section on climate change impacts on seabirds), data will become obsolete faster. Therefore, we doubt that the existing ESAS database adequately reflects current seabird distribution or the location of important concentrations.

  10.  In addition to these concerns, JNCC timetable estimates for completing this work vary from 2011-17, dependent on resources. Our concerns over the adequacy of available survey data leave us sceptical about the ability to meet even the 2017 timescale and deliver a coherent marine SPA network that complies with Birds Directive requirements. Even if this timescale were met, it would mean completion of the UK marine SPA network some 36 years after the Birds Directive came into force. This is unacceptable, both in terms of marine conservation obligations and the UK economy.

  11.  The Government must carry out an ecologically-driven assessment of the work needed to identify, designate and monitor a marine SPA (and SAC) network within a timescale that fits as closely as possible with its international commitments to implement a marine protected area network, ie by 2010. This would benefit both conservation and the economy, by providing greater certainty over the location and protection of our most important marine protected areas, such that they are fully taken into account in planning the future management and use of the sea.

  12.  Even when complete, however, the Natura 2000 network of SPAs and SACs will not offer sufficient protection to the full range of important marine species and habitats, to the UK's nationally important marine biodiversity or to the marine ecosystems that underpin so many goods and services. We are pleased that the UK's commitment under OSPAR (protection of the marine environment of the North-east Atlantic) to designate a well-managed, ecologically coherent network of marine protected areas (MPAs) by 2010 has also been identified as requiring new legislation through the Marine Bill. However, this legislation must also ensure proper protection of the UK's nationally important biodiversity. We are therefore calling for the designation, protection and management of Nationally Important Marine Sites (NIMSs) throughout the UK's marine jurisdiction.

  13.  To safeguard these sites, features and processes, the RSPB is calling, through the Marine Bill, for a new mechanism for the designation of a network of OSPAR MPAs and NIMSs, including provisions to create highly protected areas where all damaging activities would be excluded. This mechanism would replace the existing inadequate legislation on Marine Nature Reserves.

  14.  A network of sites should be designated to protect, conserve and secure the recovery and enhancement of vulnerable (rare, threatened or otherwise sensitive) species and habitats. Such a network should include geological and physical marine features, and ecological and geomorphological processes, as well as ecosystem structure and functioning. Sites must represent the full diversity and geographic range of species and habitats found in the territorial waters around England, Scotland, Wales and Northern Ireland, throughout UK waters and to the limits of the UK continental shelf, and throughout EU waters and the OSPAR maritime area.

  15.  New legislation must also include a duty, not just a power, to designate sites. The Statutory Nature Conservation Organisations (SNCOs) should be responsible for determining, on a purely scientific basis, site selection criteria (with a duty on the SNCOs to select sites according to agreed criteria, based on a regional seas approach). Social and economic considerations must not influence decisions about site identification, selection and designation. The impacts of the designation of sites on socio-economic interests should be considered through the preparation of management plans, with the engagement of stakeholders. These would ensure that any socio-economic activities within or affecting an MPA would take place within the context of its conservation objectives.

  16.  To secure effective management of sites, there should be a combination of both direct (ie proactive site protection management tools) and indirect (ie through the licensing of marine activities) controls over activities affecting (or potentially affecting) MPAs. There should be a strong presumption against activities that would have significant detrimental effect on MPAs.

  17.  Scientific data and information are required to identify, select and designate all forms of MPAs. Such data provides vital information on the location of particular species and habitats, their status, and which human activities they are sensitive to. Good data and information are also necessary to ensure an effective management regime is put in place for each designated site. Finally, there should be a requirement to monitor the status of the features protected by the site to determine whether the management plan is achieving its objectives.

  18.  Although marine science (survey and research) in the UK is among the best in the world, there are still gaps in our knowledge. We lack adequate coverage of data on both a spatial and a temporal scale for many species and habitats in UK waters. Our knowledge of the location and status of mobile marine species such as cetaceans and seabirds is even poorer. As noted above, these data gaps have already resulted in delays to the designation of marine SACs and SPAs. In addition, the Government's current reliance on industry surveys, carried out for environmental assessment purposes, must end, as it leads to conflicts and delays to projects when developers discover important wildlife at their chosen sites.

  19.  However, there is a view that, until we know which are the best sites for a particular feature, and where they are, no sites can be designated for that feature. If the same thinking continues, there will almost certainly be long implementation times for any new site protection mechanisms proposed through the Marine Bill. The knock-on effect would be that the UK would fail to meet its commitments to achieve targets for networks of protected sites, such as those under the Birds and Habitats Directives and OSPAR.

  20.  Data must be collected to fill existing gaps, with resources made available for that purpose. Where data does exist, resources should also be provided to ensure it is analysed as quickly as possible, and then made public. This is the information required to enable fully informed policy and management decisions regarding the designation of all types of MPAs to protect our marine natural resources and wildlife properly.

  21.  Delays in identifying, designating and protecting important marine sites leave them vulnerable to damage and destruction by human activities. Society cannot continue to use the absence of a complete data set and absolute knowledge of the UK's seas as a justification for negligence in providing improved site protection for marine wildlife.


  22.  The UK holds internationally important seabird populations, including over 90% of the world's breeding Manx shearwaters, over 70% of northern gannets and 60% of great skuas. We therefore have a special responsibility to protect them from adverse impacts. Many seabird populations have prospered over the last century, with the cessation of hunting, improved colony protection, and the creation of a gratuitous food supply through discards from fishing vessels. However, particularly on the north and east coasts, some species have declined substantially in the last two decades. There has been an increasing incidence of years in which black-legged kittiwakes, arctic terns and arctic skuas have struggled to find enough fish to feed their young.

  23.  A recent census of kittiwakes breeding on Shetland, for example, showed declines of nearly 70% (37,000 pairs) between 1985-88 and 1998-2002. In 2004, kittiwakes suffered their worst breeding success on record all along the North Sea coast as far south as the RSPB seabird colony at Bempton (Yorkshire), with widespread chick starvation. Breeding success of guillemots also suffered badly in Scotland, many not even attempting to breed. Productivity of several seabird species continued to be below average in many areas in 2005 and 2006, and in both years failures spread to the west coast, particularly Scotland and Northern Ireland.

  24.  In spring and summer, many of these birds are highly dependent (often >90%) on sandeels as prey for themselves and their young. There is some empirical evidence that sandeel recruitment (likewise cod recruitment) is reduced by poor planktonic feeding conditions due to warm winters. We already know that, since the mid-1980s, rising sea surface temperatures (SST) in the North Sea have profoundly changed (`regime shift') the assemblage and spatial distribution of plankton on which larval fish depend for survival and growth. There is, therefore, a strong presumption that climate change is creating food stress for certain seabirds, adversely affecting their breeding success and survival, and ultimately reducing populations.

  25.  The strongest evidence for this linkage comes from long-term demographic work by the Centre for Ecology and Hydrology (CEH) on kittiwake populations on the Isle of May (Firth of Forth), where warm winters depressing sandeel prey abundance and quality have been invoked as a key factor in the birds' poor breeding success. Winter survival of adult kittiwakes was also lower after warmer winters, and this is likely to compound population declines.

  26.  Poor breeding success was also linked to sandeel extraction by the Danish-led fishery on the Wee Bankie (Firth of Forth) in the 1990s. The relentless and unsustainable rate of decline (6% per annum) of kittiwake populations in this region (South-east Scotland) from 1989-2005 led to the establishment (by the EU Fisheries Council) in 2000 of a closed area for sandeel fishing stretching from North-east Scotland to Northumberland. In the first ever use of a seabird as a proxy for the status of a fish stock, threshold values of kittiwake breeding success were used as criteria for the establishment and lifting of this particular closure. The area has been closed continuously since 2000, and remains so today.

  27.  Reversing the adverse effects of warm winters will—at best—be a very slow process, and CEH scientists have therefore argued that, as a precautionary measure, the current closure of the commercial sandeel fishery should remain in place "indefinitely", to safeguard the kittiwake population in the hinterland. The RSPB strongly supports this recommendation.

  28.  Since 2004, the Danish fleet has been subject to a new set of harvesting rules for sandeels, such that the main regulating tool is not now a blanket Total Allowable Catch, but a level of fishing effort predicated on the strength of sandeel recruitment (which is monitored annually, right up to the traditional start of the sandeel fishing season in spring). Since the inauguration of this new regime in 2005, fishing effort has been curtailed, with adverse knock-on effects on industrial fish processing capacity in Denmark. Accordingly, Denmark may well argue for the lifting of the closed box off eastern Scotland in order to increase its fishing opportunities for sandeels.

  29.  The RSPB therefore continues to urge the UK Government to be vigilant and to resist any request from Denmark to lift the ban on purely socio-economic grounds. Rather, Ministers must support indefinite closure, in view of the continuing decline of the kittiwake population in the region.

  30.  According to the Marine Climate Change Impacts Partnership (MCCIP) Annual (2006) Report Card, "While no direct link has been shown between SST increases, low sandeel biomass and poor seabird breeding performance, the circumstantial evidence is compelling". However, useful as this is as a broad framework, and although seabirds (as top predators) have manifest value as indicators of marine ecosystem status, the mechanisms underlying these trophic (ie food chain) linkages are likely to be complex and subject to high levels of uncertainty. Detailed research is required to identify these mechanisms, to differentiate between and give due weight to human (eg sandeel fishing) and environmental drivers (eg long-term change in SST), and ultimately to predict and mitigate change.

  31.  There is therefore a need for multi-disciplinary work to address, coherently and strategically, the monitoring of seabird populations, climate change, oceanography, plankton community dynamics, fish stocks and commercial fisheries. Such a programme will be invaluable in predicting the impacts of projected changes in climate on the marine environment, and providing the evidence base to underpin policy-making and design of monitoring programmes. Initial efforts in this direction have already been made by JNCC, with the inauguration in 2005 of the multi-disciplinary Seabird Monitoring Programme Liaison Group.

  32.  For this work to be successful, however, certain conditions must be met. Firstly, while there has been a traditional focus on the North Sea, which must be maintained (it is one of the best-studied regional seas in the world, with high-quality data sets and long time series), effort must also be spread across a range of UK waters. This would allow capture of responses to a variety of anthropogenic influences, such as fisheries, and fundamental differences in oceanography (bathymetry, hydrography etc). Only by working across a range of locations will we be able to gauge and understand the causes of variation in seabird performance across sites and years, and predict long-term impacts on populations.

  33.  Secondly, there is a growing need to integrate the efforts of different research agencies to facilitate the linkages between different trophic levels and to combine these with expertise in oceanography and climate. A significant step in this direction has been made with seven prestigious UK Marine Centres recently joining forces to seek funding from the Natural Environment Research Council for a coordinated strategic research programme, Oceans 2025. This strategy will pursue a number of research themes highly relevant to the Committee's Inquiry, including "Climate, ocean circulation and sea level", "Biodiversity and ecosystem function" and "Integration of sustained observations in the marine environment".

  34.  The creation of this consortium is a huge step forward in addressing the need for coherence between disciplines. However, the role of seabirds in the ecosystem is a glaring omission from this new integrated structure, and all the more surprising because due weight is given to the role of other top predators through the inclusion of the Sea Mammal Research Unit. An obvious way to redress this would be to include in Oceans 2025 CEH's internationally important work on the mechanisms and processes linking seabird population status and behaviour to diet and the marine trophic structure. Oceans 2025 would benefit greatly from the great strides this group is making in unravelling the impacts of climate change on UK seabird populations. For its part, CEH's synergy with the seven other Marine Centres in Oceans 2025 organisations would be of immense benefit in progressing this vital seabird work.

January 2007

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