Science and Technology CommitteeSupplementary written evidence submitted by Marine Conservation Society (MCS)

On behalf of the Marine Conservation Society (MCS), I would like to thank the Committee for the opportunity to provide oral evidence on 28 November 2012 to the inquiry into Marine Science. The MCS has monitored the inquiry with great interest, and welcomed the breadth of evidence submitted on not only the Marine Conservation Zone (MCZ) process, but discussions more broadly around the strategic and investment plans for marine science.

In light of the greater detail on MCZ proposals set out on 14 December 2012 within the Department for Environment, Food and Rural Affairs consultation, I would like to take one final opportunity to highlight the response of the MCS to the relevant questions posed by the inquiry. This letter does not seek to alter the evidence set out in the MCS’s original submission, but highlight our key views on the Committee’s lines of inquiry now that greater clarity has emerged on the Government’s proposals.

Use of “best available” science—The Committee has heard evidence on the recent shift in the burden of proof required for MCZ site designation; away from the original guidance of using “best available science” to the need for “robust science”. The MCS believes that the Government’s original guidance on the site selection process to use “best available science” accurately gauged the evolving nature of our scientific knowledge of the marine estate. The Statutory Nature Conservation Bodies (SNCBs) and Science Advisory Panel also argued that the pursuit of “robust” science should not be used to justify delaying site designations. Furthermore, the Committee has heard evidence that the notion of obtaining “robust” science within the marine estate represents a limitless pursuit, with significant economic costs. While informative, we do not think it is essential to have detailed data on the hundreds of individual features prior to designation, but believe designation could primarily be based on broadscale habitats, which we believe is usual practice internationally eg Australia.

Ecologically Coherent Network—Government claims to still be committed to designating an Ecologically Coherent Network, but how it can achieve this without designating the full network of MCZs is not clear. Defra’s Science Advisory Panel of independent scientists, as well as both the SNCBs, stated that all 127 are needed if the Government is to achieve its international commitments to designate an Ecologically Coherent Network. The Sea Users Development Group has also joined eNGOs in producing a statement in support of an Ecologically Coherent Network of Marine Protected Areas. Government is beginning to argue that they already protect 24% of our seas in Marine Protected Areas, but this is misleading on three counts. Firstly, these sites are not actually protected eg not one site has a ban on all bottom towed fishing gear; secondly Government includes Special Protection Areas in this statistic that are designated solely for birds and do not protect wider marine habitats; and thirdly 24% relates only to inshore waters—across our whole seas only 12.8% is protected. We therefore still need the 127 MCZs, which amounts to 15.3% of English waters out to 200nm and added to the 12.8% existing sites would result in just 28.1% designated in sustainably managed MPAs.

Due consideration of socio-economic Impact—The Committee has heard a number of witnesses emphasize that the substantial consideration of socio-economic impact throughout the MCZ proposal stages often resulted in ecologically important sites failing to make the final recommendations. While the MCS was disappointed that a number of ecologically important sites were lost, it also acknowledges that this reflected the distinctive nature, and great strength, of the MCZ proposal process; in contrast to the selection of other Marine Protected Areas, MCZs considered throughout not only the scientific evidence of conservation need, but the potential socio-economic impact on local stakeholders. Indeed, the Committee has heard how site selection based on more “top down” and strictly scientific approaches have generated much resentment within local communities, most recently evident in the Highly Protected Marine Conservation Zone process within Wales. The MCS feels that it was the breadth and local nature of this engagement with stakeholders throughout the site selection stage that accords value to the whole network of 127 sites proposed.

However, the MCS is now concerned that the Government’s proposals to designate only a small number of sites disenfranchises the vast amount of peoples time and public money that went into getting the network to this stage. Moreover, the MCS does not believe that socio-economics should be invoked at this late stage as justification for not designating sites. The due regard for socio economic impact throughout the proposals stages ensured that the proposed network represents a working compromise between ecological protection and mitigating socio-economic impact. Failure to designate sites at this late hour on the basis of socio-economic concerns fundamentally undermines the process that has led to this stage.

Finally, the MCS remains concerned that while the Impact Assessment within the Government consultation has ascribed best estimated costs to each MCZ site (frequently as little a £1,000 per site per year), no attempt has been made to quantify the potential benefits of individual MCZs, or the network as a whole. This is particularly concerning in light of the fact that the Government currently believes that the cost of designating the full network of 127 sites would be as little as £8 million per year. The MCS believes that were such studies to be undertaken, they would likely demonstrate the clear economic benefit of an Ecologically Coherent Network. To place this in context, the Scottish Environment Link recently published a report which suggested that a network of Marine Protected Areas in Scotland’s seas could provide economic benefits worth £10 billion.

On behalf of the MCS I would like to thank you again for the opportunity to contribute to the inquiry, and look forward to seeing the Committee’s final report.

January 2013

Prepared 9th April 2013