Science and Technology CommitteeWritten evidence submitted by the Marine Conservation Society


The Marine Conservation Society (MCS) is the UK charity dedicated to the protection of our seas, shores and wildlife. MCS campaigns for sustainable fisheries, clean seas and beaches, protection of marine life and their habitats, and the sustainable and sensitive use of our marine resources now and for future generations. Through advocacy, community involvement and collaboration, MCS raises awareness of marine conservation issues and promotes individual, industry and government action to protect the marine environment.

We welcome the Committee’s inquiry into Marine Science and the opportunity to submit evidence.

Response to Questions:

1—Q. 1/2/3 Since 2007 has there been improved strategic oversight and coordination of marine science? What progress has been made in delivering the 2010 Marine Science Strategy? How effective have the Marine Science Co-ordination Committee (MSCC) and Marine Management Organisation been, and what improvements could be made?

1.1 While marine science co-ordination and oversight seems to have improved, MCS is still concerned that there is insufficient investment in new marine science; specifically seabed and habitat surveys. This lack of investment is causing issues for nature conservation and the MCZ network (covered under Q.4), as well as economic development.

1.2 The marine economy currently contributes more than £47 billion1 annually to the UK economy, with the potential to significantly increase. The vast potential for expansion in the marine economy demands greater investment in our understanding of the science that underpins these goods and services. Only by better understanding these ecosystems can we exploit them both sustainably, and therefore in the long term, most productively.

1.3 Of relevance to these points is the following paragraph from the Marine Science Strategy, which states:

“The potential of the marine environment to increase food and energy security is clear but more work is needed on defining its full potential, including the limits on sustainable production and the changes in human behaviour needed to achieve a correct balance. Marine science will have an important role to play in informing such decisions—for example, through seabed and habitat mapping—and in assessing the efficacy of such policies by monitoring and interpreting observed outcomes.”

1.4 We would therefore recommend that there is further investment in seafloor and habitat surveys to reflect the importance of our seas to UK nature conservation and also the importance of maritime industries to the UK economy.

2—Q. 4 (i) Has the selection of proposed Marine Conservation Zones (MCZs) been based on robust scientific evidence?

2.1 It is important to note that the Government’s own recommendation for MCZ site selection was not initially premised on the need for “robust” scientific evidence in affirming the presence of a habitat feature. The burden of proof was qualified as having to use “the best scientific evidence available”. Moreover, a lack of what might be termed “robust” evidence was acknowledged as being a characteristic of the marine environment. In line with this recognition, the Government’s own advice on site selection was that a lack of evidence should not be invoked to justify not selecting sites—”network design should be based on the best information currently available. Lack of full scientific certainty should not be a reason for postponing proportionate decisions on site selection.”2

2.2 This position was ratified by the Government’s own statutory Nature Conservation Bodies in July 2012 upon reviewing the proposed 127 MCZs.3 The Government’s Science Advisory Panel (SAP), in reviewing the first iteration of MCZs,4 has also stated that:

“We emphasise that the MCZ process requires the use of the “best available evidence”. Some level of uncertainty in data is inevitable, and project teams should use the data provided unless there is robust evidence to the contrary available for particular areas.” (Paragraph 2.1.1)

2.3 If the burden of proof on site selection has therefore shifted to require “robust scientific evidence”, such a position needs to recognise that any such consideration can only take in place in the context of the scientific evidence of decline. In this context it is important therefore to acknowledge the “robust evidence” which demonstrates the need for MCZs. This scientific evidence of decline is both robust and compelling, and set aside the accuracy of the best available science used in the selection of the proposed MCZ sites, heightens the justification for designation of all 127 sites at the earliest opportunity.

2.4 The scientific evidence of decline:

The evidence in support of the need for MCZs is unequivocal, largely because of the evidence of the decline in benthic habitat and ecosystem integrity.

Charting Progress and Charting Progress 2 revealed that benthic habitats including rock, sediment and deep sea habitat are degraded by bottom trawling. This is confirmed by scientific peer reviewed literature on trawling and dredging impacts over temperate seabed habitats.

Trawling is proven to decrease the biodiversity of infaunal habitats and the invertebrate community in and around sediments.5

Trawling affects rocky reef community (where it occurs), including degrading the habitat, reducing the abundance of both annual bryozoan growth, and upright sponge and other filter feeding organisms.

The chronic impact of trawling has been seen in the anecdotal record of both habitat change and fish catches.6 For example, the southern North Sea had a patch of native oysters the size of Wales at the end of the 19th century. This is now sand and shell gravel habitat.7

It is undoubted that the seabed productivity (growth and carbon capture and storage) has declined as a result of this bottom trawling over the past century. This is in part due to the loss of carbon from the system (biomass of fish), and the loss of filter feeding seabed organisms that gain nutrition from plankton.

Other industries that cause damage or destruction of benthic habitats include aggregate dredging, port development and oil and gas. These impacts, while still wide-spread in the case of aggregates, are generally site-specific and more quantifiable and localised.

Small-scale static gear fishers (using pots, traps, lines and nets) don’t generally impact the seabed unless used in excess, but then certainly not to the scale of the damage caused by trawling.8

In the UK demersal fish stocks have declined by 94% since 1884.9

2.5 The scientific evidence of the benefits of MPAs:

MPAs are an essential tool for the effective management of the marine ecosystem.10

MPAs coupled with sustainable management and sympathetic development can lead to the sustainable exploitation of marine resources, and a vastly more productive resource base.

A scientific review of MPA performance in 2009 has revealed that they result on average in a 450% increase in biomass, 120% increase in abundance, and 20% increased in biodiversity.11 MPAs in temperate seas in this review were more productive than MPAs in tropical seas at recovering biomass of previously exploited species.

If left alone, over time many marine habitats can recover and become productive again, as proven by the science undertaken in Marine Protected Areas in the Irish Sea (Isle of Man closed area),12 Georges Bank (USA),13 and Cabo Pulmo (Mexico).14 However, if the damage is too extensive, what has been lost may never be restored. As well as being used as a tool to aid recovery where damage has already taken place, marine reserves are an essential part of the package of precautionary measures that are needed to prevent healthy ecosystems from becoming degraded in the first place.

2.6 Has the selection of proposed MCZs been based on robust scientific evidence?

The ecological guidance governing the design of the network was peer-reviewed.

The ecological guidance was a technical document, however, it was also communicated to stakeholders in a short-hand version to enable quick uptake of the rules.

The network rules ensure that a representative proportion of both broadscale habitat and species and habitats of conservation concern should be protected in the network.

In the absence of complete marine ecosystem knowledge, protecting the broadscale habitat (such as coarse sand, mud in deep water, reef) is essential, as they act as surrogates for different species groups, and when protected within MPAs, will provide the building blocks for effective ecosystem management, as they will recover to a higher productive state.

2.7 What is the knowledge base on the distribution of different features?

The knowledge base on the distribution of features is variable across the network.

As the scale of the project is so large, it is inevitable that some areas will have less than perfect knowledge on the distribution and extent of habitat and species.

The stakeholder process allowed (predominantly fisher) stakeholders to move the boundaries, eliminating sites in areas of highest profitability to them. Inevitably, this led to many sites being designated in areas of lesser biodiversity interest being protected, and areas with less information.

However, in the broadest sense, the Science Advisory Panel, made up of nine individuals with excellent scientific background have stated that if the network were to be designated in full, the Government would achieve its policy goal of an ecologically coherent network.

2.8 The knowledge base on presence, extent and condition of features within sites.

The knowledge on the presence of features within the network is variable, particularly from inshore where there are numerous reports from diver surveys and drop-down video, to offshore where drop-down camera surveys, and side-scan sonar are rarer because of cost, and less human development and infrastructural projects.

There are 127 recommended MCZs within the network based on the presence of 1,205 features.

Each of these 127 sites will have a range of features and for these 1,205 features there is high, low or medium confidence on various features being present: (high = 41% (or 499 features); medium = 20%, (289) features, and low = 36% (436) features). However, just because a site has low confidence for some features does not mean it cannot be designated for other features.

There is high confidence of the extent (area of coverage) for 16% (189) of the features. Again medium or low confidence in extent should not prevent designation; it just reflects lack of investment in marine surveys on the extent of features.

There is generally low confidence on the “condition” of features rather than presence of those features within the sites. The statutory advice given to DEFRA by the JNCC and Natural England in July 201215 states the following:

“We advise that some features or sites may appear to have less information than others in terms of contribution to the network design principles and ecological benefits; however, this may be a reflection of limited data and evidence rather than an indication of their importance” (Page 7).

Furthermore, Natural England and JNCC are clear in this advice that:

“Moderate and low confidence features should not necessarily prevent sites from being progressed for designation, particularly if there is confidence on the presence of the feature” (Page 10).

Condition’ is only rarely known prior to the designation and monitoring of sites. And in any case, it is usually clear from the scientific literature what affects human activities have from a variety of sources, and hence the condition. Thus, in many cases, the relevant appropriate management of different human activities can be carried out.

The level of confidence for the final recommended sites also has to be understood in terms of the ability of extractive stakeholders (particularly fishers) in many circumstances to move the boundaries of sites away from areas of greater information. As a result, it is clear that on the one hand the process has achieved greater stakeholder buy-in and support, whilst perhaps selecting the sites with lesser biological knowledge, or biodiversity richness.

Natural England have advised that as more information becomes available in the future, site boundaries, and management of human activities can be modified so as not to damage features.

MCS believes it isn’t necessarily the current condition of different habitats that is important from this process, but the implications of habitat recovery once damaging activities (particularly bottom trawling) are restricted, that is most important to the development of a fully functioning MPA network.

It is essential that the public and stakeholders understand that it is not unusual for marine mapping and monitoring to fail to provide cast-iron evidence of the presence or extent of features over such a vast scale.

It would cost UK PLC vastly greater sums to undertake the necessary surveys to provide cast-iron evidence of the extent and condition of benthic habitat and species. This can be relatively easily and cheaply undertaken on land. However, at sea, it is not either realistic or necessary to carry out such costly activities.

In order to anticipate these constraints, Government policy at the start of the process allowed for the best available evidence for designating sites.

A criticism from the Marine Conservation Society of the stakeholder-led design process was that there were not enough experienced UK marine biologists, with first hand in-depth knowledge of the distribution of features within different UK regions.

A criticism from the Science Advisory Panel that follows is that there was not enough dispensation to suggest sites that didn’t necessarily have one or more of the habitats or species listed within the ecological network guidance for the designation of sites. They would have rather seen more flexibility in the approach to designate sites.

Q.4 (ii) How well has the scientific evidence been balanced with socio-economic considerations and communicated to affected coastal communities?

2.9 The MCS welcomes the breadth and extent of stakeholder consultation involved in MCZ site selection. However, it is fundamental to recognise that the consideration of socio-economic factors was consistently applied as a means of determining preference between two sites of equal ecological importance, so as to minimise the socio-economic impact of designation.16

2.10 In this sense, socio-economic considerations were not “balanced” with scientific evidence, but the principal determinants in the application of scientific evidence. Several sites identified on the basis of their features, based on the best available scientific evidence, were reduced and moved following the consideration of socio-economics. For example, site NG1 in the Net Gain project as initially proposed was divided and reduced, with particular regard to proposed offshore wind and associated cable routes, to a selection of four significantly smaller sites. Only two of these sites were put forward in the final recommendations, against the advice of the UK Science Advisory Panel (SAP).17 In the Net Gain and Irish Sea Marine Conservation Zone Projects, sites were selected away from areas of socio-economic activity from the outset, rather than purely on biological grounds. This was the reason why, for example, the Flamborough-Helgoland frontal system, crucial for a range of marine wildlife, was omitted, and relevant scientific evidence not considered by the stakeholder group, despite clear advice from the SAP to do so.18 As a result, the locations of the final recommended sites cannot claim to be based primarily on environmental evidence.

2.11 This, critically, has not been communicated effectively to the broader public. The media narrative, particular in Wales, and general public perception of MCZs is that they represent arbitrary environmental designations, to the likely detriment of the local economy. The lineage of site designation needs to be clearly presented to the public, to prevent the erosion of stakeholder buy-in and the development of misconceptions about the environmental effectiveness of the network. Arguably, the selected sites are not the best representation of the habitat diversity that needs to be protected.

2.12 Despite this, given the centrality of socio-economic considerations, to have achieved a portfolio of 127 sites which the Government’s independent Science Advisory Panel has argued will meet the environmental goal of achieving an ecologically coherent network should be regarded as a triumph. To not designate all 127 sites would be to disenfranchise those stakeholders who have navigated a complicated and expensive process that, guided by socio-economic considerations, if implemented in its in entirety will achieve its environmental goal.

2.13 Each of the four regional MCZ projects had considerable lengthy input from relevant commercial and recreational stakeholders. Each project region had a wide variety of stakeholders to represent their sector that all had considerable input into the process. A breakdown of the sectors represented at the regional stakeholder group meetings is as follows:

Industry (22).

Commercial fishing (24).

Government bodies and regulators (20).

Recreational interests (20).

NGOs and charities (12).

Other (18).

2.13 The ecological network guidelines were flexible enough to allow stakeholders to pick areas based on the best ecological knowledge available, combined with an understanding that relevant percentage areas of each broad scale habitat needs to be protected to ensure that sites are both viable, and not spaced so far apart that there is no site that is ecologically isolated.

2.14 Stakeholders at the regional scale were informed of they suggested by individual local groups that were often convened at the county level, or lower. For example, within the Balanced Seas (southeast) project region, the Isle of White, Solent, Sussex and Kent, Thames and Essex were all local groups that were gathered into local group meetings.

2.15 Thus, the recommendations were communicated to both national and local stakeholders on a continuing basis between mid 2010 and Autumn 2011. This positive feedback between the regional and local stakeholders helped enable greater local buy-in to the location of the recommended sites.

September 2012

1 Marine Management Organisation, August 2012,

2 DEFRA, Guidance on the proposed approach to the selection and designation of Marine Conservation Zones under Part 5 of the Marine and Coastal Access Act, September 2010.







9 Thurston, R.H., Brockington, S, Roberts, CM (2010). The effects of 118 years of industrial fishing on UK bottom trawl fisheries. Nature Communications 1:15



12 Bradshaw C, Veale, LO, Hill, AS, Brand, AR (2001). The effect of scallop dredging on Irish Sea benthos: experiments using a closed area.Hydrobiologia 465(1):129–138

13 Fogharty, MJ, Murawski SA (2005). Do Marine protected areas really work? Georges Bank experiment provides dues to longstanding questions about closing areas to fishing. Oceanus: 1 February 2005.

14 Aburto-Oropeza, O, Erisman, B, Galland, GR, Mascareñas-Osorio, I., Sala, E, Exequiel Ezcurra, E. (2011). Large Recovery of Fish Biomass in a No-Take Marine Reserve. PLoS ONE 6(8): e23601. doi:10.1371/journal.pone.0023601


16 Explanatory note 335 to the Marine and Coastal Access Act 2009 states, “Where there is a choice of alternative areas which are equally suitable on ecological grounds, socio-economic factors could be more significant in deciding which areas may be designated as an MCZ.”

17 UK Science Advisory Panel (SAP) Draft response to Net Gain 3rd Iteration Report, May 2011, Paragraph 2.9.3, (note the Net Gain website and public access to previous iterations of MCZs is currently unavailable as of 7 September 2012). The SAP response also states that “we remain concerned that largely un-quantified [i.e. before an impact assessment is prepared] socio-economic issues based on stakeholder views are having a strong influence on the choice of individual sites at the earliest stage of each discussion... the primary purpose of MCZs is to conserve habitats and species that are representative and important indicators of ecological health; protection of unproductive areas of the seabed will not accomplish that.” (Paragraph 2.2),

18 Eg ibid, Paragraph 2.9.14

Prepared 9th April 2013