Two fishing industry organisations have criticised aspects of a recent ecologically sensitive analysis of the western Irish Sea for potential marine protected area (MPA) designation.
In a joint statement, the Killybegs Fishermen’s Organisation (KFO) and Irish South and East Fishermen’s Organisation (IS&EFO) say that the report is a “good starting point” but has not addressed “some key issues”.
It “should not be used” for informing offshore renewable planning on this basis, they argue.
The “Ecological sensitivity analysis of the western Irish Sea to inform future designation of Marine Protected Areas (MPAs)” report published last month identified a list of 40 sensitive species and habitats in a sea area which has been targeted for extensive offshore windfarm development.
It was commissioned by the Department of Housing, which holds responsibility for marine planning.
The two organisations criticise the report’s decision not to include species or habitats already listed in the EU Birds and Habitats Directives or species individually managed under the EU Common Fisheries Policy (CFP) and socio-economic impacts.
This decision was due to the fact that legal provisions for their conservation and sustainability are already in place, according to the report’s authors led by Prof Tasman Crowe of UCD’s Earth Institute.
“ Until these additional issues are considered, the report should not be used for informing the ORE planning process or for identifying areas suitable for MPAs,” the two organisations state.
“Given the importance of these issues and their dependence on the output of the ecological sensitivity analysis, it is essential to establish a transparent review and revision process through which issues may be highlighted and addressed,” they state.
The KFO and IS&EFO also say that there is “no official consultation process on the report, and the current informal approach whereby stakeholders may submit observations is far from robust or transparent”.
“ These issues call into question the validity of the output of the current analyses for ORE planning and MPA identification and highlight the urgent need for a more comprehensive approach and report,” they say.
The organisations say that four levels of stakeholder engagement were defined in the report, namely “inform, involve, engage and disseminate”.
“The seafood industry were involved in the first, third and fourth levels, whereby they were informed via email of the project and offered an opportunity to submit feedback, invited to an in-person information session where a broad overview but no specific details of the analytical method was presented and discussed and finally invited to an online presentation of the final report and results where questions could be asked,” they state.
“All of these engagement levels essentially concerned informing stakeholders,”they note, but say that “no specific details of the analyses were presented in the Level 1 and Level 3 sessions, therefore it was not possible for seafood industry stakeholders to make a meaningful input into the process”.
“For example, the key features chosen for the sensitivity analysis and the underlying data were not known to the seafood industry prior to the presentation of the final report,”they state.
The level 2 “involve” stage appears to be where data and feature selection were discussed in detail, but “this level was restricted to involving only key government and agencies stakeholders, and the seafood industry was excluded… despite their extensive knowledge of the area and features within”.
“The reasoning behind this exclusion, as highlighted in the report, was the limited time available for the study,” they note.
“ The KFO and IS&EFPO understand that this was not the choice of the report authors,” they say, and they say this was the fault of the Department of Housing, which commissioned the study with a tight deadline of just four months.
“All future processes for identifying potential areas for MPAs or for assessing potential sites for ORE developments should involve all stakeholders early at every step and level of the process,” they say, as “the only way to ensure a successful outcome”.
Excluding habitats and species that are listed in the EU Birds and Habitats Directives was “a flawed decision that resulted in a significant data gap in the sensitivity analysis and led to the incorrect interpretation of the areas that were not deemed to be potentially sensitive” the organisations note.
This situation is “particularly notable in the case of sandbanks, defined in Annex I of the Habitats Directive as “sandbanks which are slightly covered by sea water all the time”, they state.
They note that Ireland’s National Parks and Wildlife Service (NPWS) has identified the Irish Sea as having “the greatest resource of sandbanks in Irish waters”.
“To date only the Long Bank and the Blackwater Bank, both located off Wexford, have been designated as special areas of conservation (SAC) in the western Irish Sea,” they state.
“ Some of the largest sandbank, including the Kish, Arklow and Codling remain undesignated and have also been highlighted as areas for ORE developments with monopile-based wind turbines,” they state.
“One would assume that as sandbanks are listed in Annex I of the Habitats Directive then they would be considered sensitive habitats regardless of whether they were legally designated as SACs or not, and any analysis of sensitive habitats in the western Irish Sea would highlight these areas for protection,” they state.
“Neither the Kish, Arklow or Codling bank were highlighted as sensitive areas in the sensitivity analysis report,” the organisations say, questioning why non-designated sandbanks were excluded from the analysis.
The report is also confusing in relation to a range of infra and circa-littoral sediment types included as features that met the criteria for inclusion for spatial protection, they state.
The organisations also say that the exclusion of seabirds from the ecological sensitivity analysis, as they are considered under the EU Birds Directive, is “also a significant issue”.
Since the report’s publication, the same department which commissioned it has announced the proposed designation of a large special protection area (SPA) for birds in the northern part of the Irish Sea, and this “completely changes the perception of the outputs of the report”, they say.
“Offshore wind turbines are well proven to cause disturbance and displacement of seabirds and are likely the most damaging activity that could occur within an SPA,” they note, and failure of the report to highlight this “indicates a significant deficiency”.
The two organisations also say there are “significant issues related to the data used in the analyses”.
“Most of the data was fisheries-dependent data, which is biased towards areas that are of key importance for commercial fishing,” they say.
“ Fishermen will try to avoid areas with, for example, a high abundance of juveniles as these are of no commercial value and will represent wasted effort. Therefore, an analysis which is mainly based on VMS and logbook data is biased towards identifying areas with fishing operations,” they point out.
“The resultant sampling data is not a true representation of the species range and does not capture the diversity of life present in the Irish Sea,” they say.
“The lack of data, despite being mentioned in the report, is not immediately apparent to the general reader and requires further extensive reading of the appendices,” they state.
“There are also specific examples where the data used for assessing individual features is questionable,” they state, citing ray distribution data as an example.
“The bottom trawl survey data were collected in the Irish Sea from 1993-2012 and as such, are older than the 10 years defined in the report as “relevant to the current distribution” of mobile species,” they state.
“Another example of questionable data is the delineation of the herring spawning grounds in Dundalk Bay,” they say.
“There is no evidence to support this delineation, and it was made purely on the basis of the presence of a coarse sediment substrate type, which is also widely found further south in the Irish Sea,” they state.
Other issues raised include an “overly simplistic” analysis of carbon sequestration; omission of seafood provision in terms of protein and nutrients as an “essential ecosystem service”; and failure to include decommissioning of ORE developments as a significant pressure source on ecosystems.
