Marine Strategy Framework Directive Consultation

Marine Strategy Framework Directive Consultation

MCNI Response

The MSFD Consultation response from Marine Conservation Northern Ireland

Question 1. The overall opinion is that the State of the Seas document has made a positive contribution to the debate on the state of Northern Ireland territorial waters we are not in a position to discuss the other documents with direct relevance to our seas around the Northern Irish coast. It does however suffer from a lack of consistent evidence based data. We refer in particular to some of the observations made concerning commercial fishing and the impact that sector has had on the indigenous and non-indigenous species which provide the MSY.

Question 2.

At this present time there is are a number of important pieces of information being researched to contribute to the body of work on our marine and its environment. While this is an on-going process and this material will in the future contribute greatly. We are not aware of any current material evidence which may affect the conclusions of the initial UK Assessment.

Question 3.

The characteristics for the GES Descriptor appear to be consistent with the definition of the overarching aims of the Directive and recognise gaps in the existing knowledge base. MCNI have already intimated this fact in Q2. And the relevant foot note below.

In The Celtic Seas the need to be honest with regard  fish communities and the current stock levels is a critical factor to the over harvesting of certain target species that is why the Cod and Haddock stocks have been relentlessly fished to virtually unviable levels by the Commercial Northern Irish fleet and other EU community fleets. There now remains a focus of prolonged targeting on prawn.  The high percentage of viable prawn stocks exist primarily because the predatorial species have been fished to levels incapable of providing their role in the food chain.

The recently renewable sector through wind and wave tidal energy is an addition to the already viable oil and gas industry. MCNI believes that the competing interests sharing the marine environment and its sea bed requires effective management. There is a continuing need to inform the industry and the management of these resources and offer important new advances in energy capture. Research is still being identified and will contribute to the body of research independently provided.

Question 4.

The need for on-going and important research to identify trends is an essential element of ensuring that an effective and strategic approach is adopted to ensure viability of all commercial species rather than knock out each species and target the remaining to exhaustion.

The exploration and research of the sea bed and existing habitats most also remain high in the respective Government Departments agendas. This crucial to ensuring that both fin fish, crustacean and sea mammals continue to sustain safe numbers both for environmental and commercial (where necessary) harvesting.

Question 5.

Yes with a continuing commitment to maintaining up to date, well researched informative and corroborative evidence provides the opportunity to achieve the GES. It is within our communal grasp. Government need to utilise more of their volunteer assets. Those who use the marine for commercial, social and environmental benefit have a duty of care as does the statutory authority. They provide a valuable intelligence which Government should harness and where particular expertise exists, a contractual and financially funded contract would produce a cost effective and additional logistic resource.

Question 6.

The GES Targets are feasible but will require a well-publicised and sensibly invested in enforcement systems. Among these measures appropriate resources are dictated to provide a satisfactory safety net against abuses and infringements. The process of self-regulation has so often in the commercial fishing sector has proved wholly inadequate and repeatedly abused through the black fish catches and the financial benefits of taking the chance against discovery.

The introduction of effective and adaptable policy through legislation which addresses the abuser whether corporate organization in the exploitation of sea bed aggregates to the small lobster potter operating 800 pots for lobster and red crab.

Question 7.

Yes largely this is accurate but an appropriate joined up and out of silo mentality needs to be introduced as a government department culture, something sadly lacking and detrimental to all GES descriptor developments.

Question 8.

The question of cost does have to be given serious consideration but in the light of our custodial responsibility in protecting and managing the marine and its environmental benefits the cost of monitoring needs to be capable of meeting a through and accountable monitoring process.

As identified earlier the use of volunteer organisations trained and recruited through best practice systems and tender contract would provide a further enhancement to the monitoring and information gathering required in the provision and introduction of legislation needed to create and maintain a marine GES.

Question 9.

The gap filling can best be achieved by the production of research based evidence which can be introduced to inform the legislation and applied to update and improve it.

Question 10.

Largely yes they certainly outline the essential issues.

Question 11.

Apart from the specific areas discussed earlier the overview of MNCI appears supportive and positive towards the issues raised to achieve the Descriptor GES.

Question 12.

Given the time scale and the level of work required MCNI would suggest that budgets need to be established by Government Agencies to achieve the GES measure.

Foot note Q2

Commercial catches of species controlled by Common Fisheries Policy are already under stress which has led to limitation of commercial fleet days at sea. This has resulted from their catching potential efficiency increasing year by year at an estimated 4% and as a result has led to non-quota species such as Pollack, coalfish, flounder & elasmobranchs and many other species to suffer decimation at an industrial level.  While fish stocks deplete they face an increasing high technology response from an ever increasing industrial exploitation which has the potential to fish species out within two years. These non-quota fish provide an essential contribution to the Northern Ireland Recreational tourist product both by visiting and local day trip anglers.