Marine Conservation Society
Skomer Marine Nature Reserve

Public response to submission to WWMC website questioning HPMCZs

The following message was submitted through the WWMC Contacts form:

could you please tell me why you think people are making misleading and incorrect implications and claims about the impacts of Wales’ possible highly protected Marine Conservation Zones on recreational and other activities that are benign and will require little or no management. when all that is being said is directly out of the consultation document and indeed the proposed wording which is found on pages 88,89 and 90 of that document as i see it you are just giving a very biased view of HPMCZs it has been a flawed consultation from the start backed up by flawed and very questionable science and i am interested to know why you feel they are even needed as a high level of protection already exists in a large percentage of welsh coastal waters i am sure you will not respond but i can live in hope and may even change my stance if you can prove undeniably that HPMCZs will be of benefit

As it raises several important issues we thought we would post our reply on the website.


Dear A

Since you were not expecting a reply I hope this doesn’t come as too much of a surprise.

You ask several questions and make several statements that I will try and respond to one at a time, though not in the same order as it makes sense to explain some things before others.

1) “Flawed consultation”.  We wholeheartedly agree that the consultation has been flawed.  Actually, we’d be inclined to be much less diplomatic.  What’s more, all the non-governmental conservation organisations that have been lobbying for HPMCZs for many years agree too.

The consultation document is indeed very poor – easily misunderstood and ambiguous.  It needs a huge amount of effort to dig down to the relevant details and also needs familiarity with other documents (such as the Site Selection Guidance) to even begin to understand parts of it.

The engagement process by the Welsh Government has been equally as bad, possibly worse.  Liaison with local communities and all interests other than fisheries (who had been promised one-to-one meetings by Welsh Government for months before the consultation) was too slow and too late.  In many cases answers and clarifications have been even less clear than the document.

2) “Flawed and very questionable science”.  We do not agree that HPMCZ science is flawed and very questionable.  What do you base this assertion on?  What HPMCZ science have you read that is flawed and questionable?

There is huge body of careful research published from studies in MPAs across the world.  The PISCO report linked from the MPA Science page of the WWMC website summarises some of this in an accessible and readable way.  The CCW report on evidence of benefits and opportunities from HPMRs goes into more detail, particularly from a British Isles context – it also downloadable from the website.  There is considerably more robust MPA science out there and it is being added to all the time.

However, there is no guarantee that science or evidence will be used responsibly.  It may be used without really understanding it or without good awareness of all the relevant science available.  It certainly appears that Welsh Government have done so in this case, though that still doesn’t undermine the case for HPMCZs.

But all too often, when someone wants to attack science they cherry-pick bits and pieces in isolation or out of context to try and undermine it or to support a particular ideological position.  Attempting to cast doubt on scientific evidence by claiming lack of 100% certainty (see below) or that it is flawed is a well known technique to avoid having to provide evidence to support a contrary position.

3) “a high level of protection already exists in a large percentage of welsh coastal waters”   By this we assume you are referring to marine Special Areas of Conservation.  Whilst 36% or so of Welsh territorial sea area is indeed designated as marine SAC, designation does not equal protection.

In fact, the SACs have resulted in extremely little additional protection for Welsh seas and at the last assessment well over half of the designated conservation features were judged to be unfavourable.  The only really significant additional protection across all Welsh marine SACs was the introduction of a ban on scallop dredging a couple of years ago – and that was certainly largely a result of two complaints to the European Commission about the damage being caused and lack of protective management.

So no, there certainly isn’t a high level of protection in a large percentage of Welsh coastal waters.

4) “why you think people are making misleading and incorrect implications and claims”  There are two ways of interpreting this question: what is the evidence for WWMC to make this claim; or what are people’s reasons for making misleading statements.  One at a time –

The evidence is that we have heard at meetings and one-to-one conversations and read online and in the press many people making claims that everything from diving to dog-walking, sailing to building sandcastles will be banned in HPMCZs.  Most of the time they cannot explain where they got these ideas from – simply that they think it might happen.  Some will accept clarification when it is offered – either by reference to the relevant parts of the document or by Welsh Government officials or by marine staff from the Countryside Council for Wales, WG’s nature conservation advisors.  But some simply people simply keep repeating these things will be banned despite being corrected and reassured that they are wrong – why is that?

The reasons – we cannot say for sure, but perhaps either some people simply do not believe what they are told, or it could be that some are deliberately using scare-tactics to generate opposition.  If you are one of those whose activity would be banned from HPMCZs under the proposals, for example commercial fishermen, doesn’t repeating that diving and other recreational activities will also be banned make good sense to scare people into joining your side in opposition?

5) “all that is being said is directly out of the consultation document”  What is being said is not actually directly out of the document.  It is an interpretation based on misunderstanding one part of the document out of context and disregarding all the other parts that give a clearer picture.  In particular, Table C in Annex 4 gives a far clearer explanation of what may (and the document stresses may) need to be managed in some way and under what circumstances – and that management most assuredly does not automatically equal prohibition.  Certainly the information in the document could have been far clearer but it would have needed to be site specific and that detail is promised for future rounds of consultation.

giving a very biased view of HPMCZs”   WWMC has done its best to provide an evidence based view of both the need for and the benefits of HPMCZs.  Our view is certainly based on acceptance of the need for healthy ecosystems and biodiversity and understanding that these are necessary and vital part of the planet’s life support systems for humans as well as every other living thing.  If that is bias, then we’re guilty.

6) “prove undeniably that HPMCZs will be of benefit”  Two problems with this.  Firstly, it is impossible to actually prove anything before it happens – all that can be done is base expectations on previous experience.  Secondly, science doesn’t work that way.  It is a common misunderstanding that it should “prove” things or provide 100% certainty – it doesn’t.  Science is about collecting evidence, testing hypotheses and determining the probability that something is the case.

Scientific assessments of the effects of Marine Protected Areas are based on these principles.  They collect the best evidence possible.  The sea is a very dynamic and changeable place so it should be no surprise that the detailed effects of MPAs differ from place to place, but the important thing is that the same general patterns emerge time after time.  So, can we say specific changes will happen at a specific time?  No.  But we can predict the kinds of changes that are likely or probable to happen.  Exactly this happened in the Skomer MNR when scallop dredging and collection was prohibited in 1989.  It was predicted that the population might recover.  It took ten years before it got going, but since then it has taken off and volunteer divers are again helping MNR staff resurvey the population this year.

So yes, the consultation is bad, but the need and case for HPMCZs is rock solid.

We don’t expect to change your mind though we have tried and will be delighted if you do.

Because you raised several important issues we will be posting this on the website for the benefit of others.

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