Firth of Lorn Management Plan Comments Sheet
Collated Responses from 2nd Draft Consultation Period (August 2004)
General comments
Scottish Natural Heritage
The way the Plan refers to the Argyll Marine SACs Management Forum is very
inconsistent. Sometimes it is "AMSMF", sometimes its "the forum" sometimes if "The
Forum". SNH suggest “AMSMF” and “the Forum” for some variation.
In Management Actions SNH suggest stronger language, for example sometimes the
Plan states "it is proposed..." or "it is recommended...". If it's not "the Forum has
agreed..." it should at least be "the Forum recommends..." since the Plan is presenting
a consensus view therefore should show that issues have been discussed before a
balanced view is followed. Using the same language in the Management Actions for
each activity is repetitive but when the Plan is used later people will generally only be
referring to the section of the Plan relevant to their activity rather than reading it right
through.
Hebridean Partnership
HMNPP cannot sign any management agreement that clearly opposes a majority view,
including all of the major stakeholders and a relevant authority, especially an
agreement which may be detrimental to the favourable conservation status of the
species/habitats that are of special community interest, and for which the site has been
designated.
Due to the tight deadlines imposed and as Chairman of the HMNPP unless a review of
the outcome is forthcoming I would be unable to be included as a signatory of the SAC
Management Agreement, this decision would be subject to a full meeting of HMNPP.
NB. This is not withdrawal from the management process and the Partnership would
currently wish to continue receiving information. As an individual I feel that the current
proceedings are being “railroaded” through in contradiction of the majority view, a
majority made up not of “conservationists” per se but actual stakeholders of the Loch.
The current process is not democratic nor does it give adequate protection to species
or habitats.
The aims of SNH, Habitats Directive, through Natura 2000 and HMNPP are
concomitant:
The SNH aim: “Scotland’s natural heritage is a local, national and global asset. We
promote its care and improvement, its responsible enjoyment, its greater understanding
and appreciation and its sustainable use now and for future generations”.
And mission statement: “Working with Scotland’s people to care for our natural
heritage”.
Article 6 (1) of the Habitats Directive states that: “For special areas of conservation,
Member States shall establish the necessary conservation measures involving, if need
be, appropriate management plans specifically designed for the sites or integrated into
other development plan, appropriate statutory, administrative or contractual measures
which correspond to the ecological requirements of the natural habitat types in Annex 1
and the species in Annex 11 present on the sites”.
And Article 6 (2); Member States shall take appropriate steps to avoid, in the special
areas of conservation, the deterioration of natural habitats and the habitats of species
as well as the disturbance of the species for which the areas have been designated, in
so far as such disturbance could be significant in relation to the objectives of this
Directive”.
HMNPP aims: “To protect the habitats, fauna and flora within the proposed park area.
To promote and encourage environmentally friendly, sustainable use of the seas and
land within the proposed park area”.
With these aims in common why is the stance from both the Natura team and SNH
different from HMNPP? In addition, the Partnership would welcome the rationale behind
such views.
Scottish Executive
Throughout the plan “secretary’s” of fishermen’s associations should read “secretaries”.
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Signatures for plan
participation
WHISCA
Include West Highlands and Islands Sailing Clubs Association
Scottish Executive
The Executive (all departments) should be removed from the list of signatories at the
start – as I’ve mentioned before any one department cannot sign up to the plan
because a collective view needs to be taken.
Executive Summary
WHISCA
Para 4: penultimate sentence is not well worded. Do you mean “At the present time the
degree of impact on the rocky reefs of the Firth of Lorn of this type of fishing is
unclear”? Suggest that there should be a hyphen between “dredge” and “disturbed”.
1.0 INTRODUCTION
1.1 The Habitats Directive
COMMENTS
WHISCA
Hyphen between “European” and “wide”
1.2 Argyll Marine Special
Areas of Conservation
Management Forum
1.3 Aims of the Management
Plan
Sealife Adventures
We welcome the commitment to “restoring habitats and species to favourable
conservation status”. I have concerns about the deterioration to rocky reefs which has
occurred over the last few years due to scallop dredgers working closer to and in gullies
between the rocky reefs.
Monitoring – I am concerned that the relevant authorities do not currently have the
resources to properly monitor the SAC’s. The majority of species on rocky reefs are
very small and detailed monitoring is required. The monitoring which was carried out by
the relevant authorities on the rocky reef 230 metres from the Lunga fish farm site did
not detect the damage that occurred as a result of the farm’s activities
2.0 SITE OVERVIEW
2.1 Site Description
COMMENTS
WHISCA
Can the new map show the depths referred to?
2.2 Reasons for Designation:
Rocky Reef Habitat and
Communities
Sealife Adventures
Harbour porpoise is a species requiring the designation of protected areas and is a
protected species, this must be taken into account when reviewing the fishing methods
used within the SAC. SNH have failed to designate SAC’s for the protection of the
harbour porpoise. The sightings forms submitted to Hebridean Whale and Dolphin Trust
show that Firth of Lorne SAC to have the highest sighting rate for harbour porpoise.
Because forms include a time, sightings are effort related. We call on SNH to upgrade
the designation to A or B in the Firth of Lorne SAC.
WHISCA
3rd line: suggest “wave- and current-sheltered”
3.0 MANAGEMENT
OBJECTIVES
3.1 Conservation Objectives
COMMENTS
Alistair Bullock – MRI Ltd.
Line 5 should read complements
Sealife Adventures
Since the conservation objective of the SAC is to avoid deterioration of the rocky reefs
why does SNH allow fishing methods which have been demonstrated to damage these
reefs to continue? In particular we have demonstrated that scallop dredging is
damaging the rocky reefs not only by direct impact but also by silt deposition.
Independent scientific studies have shown this at Skomer (Bullimore B 1985,) , in the
Clyde ( Hall-Spencer ), in Lyme Bay (Devon Wildlife Trust,2004), Strangford Lough(in
preparation). These studies show that Scallop dredging devastates attached fauna on
all seabed type studied including rocky reefs. We submit that the rock type has no
bearing on the damage as it is the fragility of the fauna that is relevant. We have
submitted witness evidence supported by video of damage to the rocky reefs caused by
scallop dredgers in the Firth of Lorne, we note that R Handy commented on similar
damage in the consultation, we are also investigating further report of damage within
the SAC and expect to video this soon. We also have photographic evidence of
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dredgers heeled over, putting out black smoke having come fast in rocky reef areas.
We believe that the advice currently proposed by SNH should be changed to a ban on
scallop dredging in the light of new evidence. We would point out that the SNH
publication applying the precautionary principle to decisions on the natural heritage
states that the adaptive precaution can only be applied if the industry is co-operative
and if a negative feedback regime can be established. We submit that the former is
unlikely and the funds are not available for the latter.
WHISCA
Complements (not compliments!)
3.2 Sustainable Economic
Development Objectives
Scottish Natural Heritage
3.2 - para last. Would prefer to see the last sentence replaced with "Overall, there
should be a presumption that any resource use is done in a way that is sustainable and
that it is compatible with the requirements of the Habitats Directive"
4.0 ACTIVITIES AND
MANAGEMENT MEASURES
4.1 Management of Fishing
Activities
COMMENTS
Sealife Adventures
The statement that sea fishing is an important provider of employment cannot be
ignored however it should be justified by giving actual numbers instead of emotive
statements. In the whole working population of the areas surrounding the SAC there
would not be a large majority of fishermen or associated employment and more
importantly if you looked at the numbers employed in scallop dredging it would not be
greater than 5 out of a working population of several hundred. In a review of 1997
fisheries statistics scallop dredgers represented 5% of the regional fishing fleet.(Gill,
1999). We do not underestimate the importance of these jobs but our argument that if
dredging was stopped in the SAC the local boats would have to steam a bit further to
other grounds but the SAC represents a tiny proportion of the scallop grounds available
to them.
It should also be pointed out that there are other fishing methods which could be
carried out which do not impact on the reefs in the SAC such as scallop diving which
would employ more people.
Scottish Executive
No comments on proposed management actions at this time. Perhaps worth noting
that fishing for razor clams is on increase on west coast, although perhaps not within
the cSAC area.
4.1.1 Benthic Dredging
Preferred Option – 1 2 3 4 5(please circle if you have an opinion) outline
other options or comments below:
Hebridean Partnership
“SNH is concerned about the potential impact that scallop dredging may have on the
Firth of Lorn SAC. However, we feel that the nature of the impact is not such that it risks
the complete loss of the feature (scallop dredging is likely to damage reef margins, but
is unlikely to destroy reefs entirely)”. (SNH response to 1st Consultative Draft)
SNH admitted that it has been unable to conduct species specific scientific studies
therefore unable to substantiate this statement and does not take into account the
question of potential sediment loading in this area which is prone to extreme and
complicated tidal influence.
At the management meeting it was clearly stated and recorded in the minutes that,
“scallop dredgers would not concede any more fishing grounds”; thereby the Adaptive
Precaution suggested by SNH is in contravention of their own guidelines. While
uncertainty exists there can be only one acceptable approach: the restriction of
dredging until a full and sound, species specific scientific evaluation is carried out.
HMNPP have already objected to the ultimate judgement going to SEERAD and the
Inshore Fisheries Branch to give the final say on conservation issues. Especially so
after the outspoken views given by the head of the Inshore Fisheries Branch at the
previous Firth of Lorn SAC management meeting. A balanced unbiased view is
severely in doubt.
Argyll & Bute Council through its Natura 2000 Officers and SNH appear to be in
contravention of the Habitats Directive. Following the relevant Articles within the
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Habitats Directive this also affects competent, relevant authorities and the Ministers.
Representatives of SNH and the Natura team should review their decisions. Especially
in light of unseen evidence and the possibility of new evidence emerging.
Due to the current untenable situation clarification has been sought from the Ministers.
If this situation continues in the same manner a decision from the European
Commission will be the only alternative.
Sealife Adventures
I am repeating several of the points I raised in the first consultation as I feel they
have not been addressed in the 2nd draft of the management plan.
Our preferred option was option 4 and it was stated that of the 15 responses to
the first draft 10 called for option 4 and one called for option 2. Why have these
responses and requests been completely ignored in the 2 nd draft?
We make the following observations:
Whilst scallop dredging was a traditional activity, due to recent major advances
in electronic technology, scallop dredgers are now able to navigate more
accurately. Resultantly they are concentrating on the areas close to the rocky reefs
and the gullies between these reefs, which were previously inaccessible. As divers this
has become self evident due to the increased siltation on the rocky reefs, and the
devastation to the adjacent seabed. We have supplied video to the forum of an area of
the seabed in Dun Chonnuill Sound, showing its state before and after scallop
dredging, and also of a rocky reef at the south end of the Garvellachs, where dredgers
have gone straight across the reef.
We read with interest the comment that the fishermen view their navigation
technology as a means of preventing contact with the reefs. Every day we see
dredgers heeled over giving our black smoke as they attempt to free their
dredges from rocky areas. I have photographs to prove this and also expect new
video evidence soon of damage to reefs from dredgers which has occurred
during August 2004.
Scallop dredging has changed markedly recently and this must be taken into
account when deciding whether to allow it to continue as it is no longer the
“traditional activity” imagined by SNH.
Dredging produces significant and continuous noise. (Shrimpton & Parsons,
2000). This noise which can carry for many miles could have an impact on
cetaceans. Wild life operators in the SAC have recently been watching many
Minke whales around the west end of the Corryvreckan. Since a dredger started
in that area last week there have been no sightings. This obviously impacts on
the income of tour operators in the area.
There have been many other areas around the country that have been devastated
by scallop dredging. In Strangford Lough , the unique horse mussel community
which supported many hundreds of other species in its centuries –old structures,
has been destroyed by scallop dredging. Over 90% of the mussels have been
wiped out. The UK has now been cautioned by Europe for failing to protect the
area and fines of E40000/ day have been proposed. Europe will act when areas
that should be protected are not and SNH should not ignore this.
Lyme bay in Devon has also seen damage done by dredgers and video evidence
of this has been gathered by Devon and Dorset wildlife trust.
There is not “potential” for damage there is actual damage occurring daily. The
management forum cannot justify allowing dredging to continue in sensitive
areas of the SAC on the grounds of economic impact on local areas and
communities that is a false claim and will be seen as such if the case were taken
up in Europe.
Only one local boat dredges the area of the SAC regularly.
Scallop dredgers are big, sea-worthy boats capable of fishing all areas. While the
scallop dredgers have a large political voice, they only represent about 5% of the
fishing industry. A typical dredger, towing 16 dredgers, ploughs an area of 6½ square
kilometers per 100 hours of fishing. Look at a chart of the West Coast of Scotland. The
areas we are looking at are extremely small. To close the small zones we are talking
about would not jeopardise any jobs in the dredging industry, although it might
occasionally involve a longer steam to some fishing grounds. It would however create
sustainable jobs in diver tourism and scallop diving.
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When the Labrador cod fishery was closed to all mobile gear, sealife proliferated. When
controlled zones were re-opened to dredging, scallop catches had significantly
increased, resulting in a five-fold increase in yield for the same fishing effort. The
experience worldwide is that closing areas provides improved fishing in adjacent areas.
The major man-made impact in the Firth of Lorne is from Scallop dredging. The
Habitats Directive puts a clear responsibility on SEERAD, as the responsible body, to
stop this increasing damage and indeed to restore the area.
One of the major requirements of the Habitats Directive is “management should enable
the natural habitat types and the species concerned to be maintained or, where
appropriate, restored at a favourable conservation status.”
Notice must be taken of the decline in certain species. With reference to the NCC study
of 1982, take site 20 as an example. This site was famous for Arachnanthus and
Pachycerianthus. Virgularia & Pennatula were also found. Despite several recent dives
Pachycerianthus has not been found and Virgularia and Pennatula are now rare. As
mentioned before it is now far more difficult to find Arachnanthus. It is important to
accept that these species attract divers to the area, bringing money and supporting jobs
in the local economy.
Because this is a SAC, the precautionary principle must be invoked and the reefs
protected (reference SNH booklet ‘Applying the Precautionary Principal to decisions on
the Natural Heritage’). If scientific work is undertaken it must be robust and of a high
enough standard to take note of changes on the reefs and must be able to stand up to
peer review. It should be stated that there is already a wealth of scientific evidence that
shows how damaging scallop dredging is, and in light of this SEERAD has a legal
responsibility to impose precautionary measures under the Habitats Directive. It could
be argued that the options proposed, except for option number 4, would not comply
with the duties imposed by the Habitats Directive.
The restriction on dredging must be statutory not voluntary as although the local boat
might comply there would be no such compliance by boats from out with the area.
WHISCA
1st para: “further afield, e,g. the Firth of Clyde, Isle of Man and Northern Ireland, to
fish.”
3rd para: coarser (not courser)
Last bullet: the plural of Secretary is Secretaries – this error is consistently perpetuated
throughout the rest of the document (at least 8 times), so I suggest you do a “Find and
Substitute” operation!
4.1.2 Benthic Trawling
4.1.3 Creel Fishing
4.1.4 Bottom Set Gill & Tangle
Nets
Sealife Adventures
Studies have shown that approx 10,000 porpoises die in mono and multi mono
filament nets each year-(Tregenza et al 1997, Northridge & Hammond 1999)
Note that Harbour porpoises are protected species requiring the designation of
protected areas. They are a priority species which are globally threatened. We
have many sightings of porpoises in the area and they must be protected by
banning tangle nets within the SAC.
We welcome the initiative taken by local fishermen and Natura Officers to replace
bottom-set tangle nets with creels, in order to protect our valuable stock of porpoises.
To protect the interests of the local fishermen, who have been so far-sighted as to take
up this scheme, it is necessary to introduce a by-law immediately to prevent the use of
nets in this area. This will prevent boats from out with the area from using bottom-set
nets in the Firth Of Lorne.
4.1.5 Shellfish Diving
4.2 Management of
Gathering and Harvesting
from Foreshore
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4.2.1 Shellfish and Bait
Collection from Foreshore
WHISCA
Suggest hyphen between “Estate” and “issued”
4.2.2 Gathering Cast Seaweed
WHISCA
Potential Impacts: Can this location be shown on a map, in view of the area’s popularity
with yachtsmen?
Scottish Executive
On the seaweed point, the local Agriculture office can advise.
4.3 Management of
Aquaculture Activities
Scottish Executive
The Scottish Executive is actually the statutory consultee on fish farm applications (not
Sea Fisheries Divisions), but you can say that the Sea Fisheries Divisions comment on
potential implications for fishing.
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4.3.1 Finfish Farming
Sealife Adventures
My comments on the 1st draft are repeated here as they have not been included in
the 2nd draft.
There is a lack of scientific knowledge on the effects of finfish farming effluents on rocky
reefs. However, we have a video record, taken at three monthly intervals on the effects
of Lunga fish farm on the nearby reef. It is clear that some fauna living on rocky reefs is
less tolerant to siltation than the fauna living in and on sediment seabeds. The
precautionary principle must be invoked.
As well as being a SAC, part of this area is also a National Scenic Area. Finfish farming
supports a small number of jobs in Argyll, whereas tourism supports over 1/3 rd of the
working population, and brings over £700 million to the local economy over the year.
Fish farming jobs are very important, however the farms could be sited in areas of lower
conservation importance. The perception of wilderness is one of the major draws on
tourists to Scotland, and an inappropriate siting of fish farms has a negative effect on
our most important industry, and the jobs that it supports.
The situation where fish farms pay for their own environmental impact assessments
and surveys is clearly open to abuse. It became clear that the relevant authority, SEPA,
was unable to undertake sufficiently detailed and effective monitoring of the Lunga Fish
Farm site. It is important to point out that most of the species living on rocky reefs are
small in size, and detailed diver surveying is necessary which MUST commence
BEFORE the fish farm is installed.
While it is possible to survey the seabed, the effects of various effluents going into the
water column are unquantifiable. I believe that within the ethos of the Habitats Directive
that finfish farming is inappropriate in this SAC. Should another finfish farm be opened
in the SAC, local divers, including myself would ensure that it was subject to the most
rigorous, independent monitoring, using video techniques that are open to all to review.
Based on our experiences from the Lunga site, we believe that proper monitoring would
quickly show impacts to rocky reefs, even at some distance to the site.
SEPA cannot monitor effectively as was demonstrated in their survey of the
Lunga site. The fact that they have no concerns does not mean that no damage
occurred. We have demonstrated effect within the allowable zone of impact on
other fishfarm sites and this has been ignored by SEPA. SEPA are obliged to
take best available evidence but have so far refused to see the tapes we have of
the reef next to the Lunga fishfarm which demonstrate a decline from 24 to 2
Anthianthus dornii filmed between our baseline survey October 2001 and 18
months later. Note the SNH team could also only find two around this time.
Please include this information in the executive summary.
Placing moorings on the rocky reefs would be the smallest problem the area
would have to cope with if more fishfarms were sighted in the SAC. It shows the
short sightedness of the management forum that this is included in the draft as a
recommendation but there is no recommendation that there should never be
another fishfarm consent given within the SAC.
It is my understanding that under the Habitats Directive the onus is places on
those responsible for a potentially damaging impact to prove that they are not
causing damage to conservation interests of an SAC. Why is this not included in
the draft management plan?
Scottish Executive
FRS does not issues FEPA licences for fish farm developments such as cages,
moorings etc. FRS licence the construction of shoreline facilities such as jetties, piers,
slipways, outfalls etc.
4.3.2 Shellfish Farming
WHISCA
Description of Activity: Last two sentences should read as one (comma instead of full
stop & small “a”)
Potential Impacts: Remove space following “pseudofaeces”
Scottish Executive
As for finfish, and FRS do not issue licences for trestles and tables or cages, even if in
inter-tidal zone.
4.4 Management of
Recreation and Tourism
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Activities
4.4.1 Anchoring and Mooring
WHAM Association
Correct name of organisation to Anchorages
2nd para – suggest altered to read – Anchoring is not regulated by any authority and is
regarded as a public right associated with the public right of navigation. The
Admiralty….
WHISCA
Description of Activity: Scottish Islands Peaks Race. Suggest “en route” should be
italicised.
Potential Impacts: “outwith” (in the sense of outside of) is one word, notwithstanding the
spellchecker!
Management Action: The last point is entirely superfluous – by definition this is how
every mooring should be. Better say that the mooring should carry a notice defining the
maximum tonnage of vessel it is designed to secure – visiting mariners can then
interpret this in the light of conditions obtaining at the time.
4.4.2SCUBA Diving
WHISCA
“Although both organisations produce Safe Diving Practice Guidelines,….., there is
(?no) oversight to ensure that all members of BSAC and SSAC adhere to these
guidelines.”
4.4.3 Charter Boat Operations
WHISCA
Cruising yacht use of the SAC is essentially similar to the charter boat operations,
except as regards the MCA Code of Practice requirement, and could probably be
referred to in this section. This significantly increases (probably more than doubles) the
economic importance of leisure marine activity in Argyll (from marinas, boatyards and
other infrastructure).
4.5 Management of Effluent
Discharges and Marine
Dumping
4.5.1 Trade Effluent
WHISCA
Potential Impacts: Suggest “nutrient- and chemical-rich effluent”
Management Action: Outwith again…..
4.5.2 Sewage Effluent
WHISCA
Responsibilities: MCA - outwith
4.5.3 Marine Littering and
Dumping
Scottish Executive
FRS would not use FEPA to control the disposal of litter or garbage from vessels as
such as this is more of a Merchant Shipping issue. But they do control the sea disposal
of dredged material.
4.6 Management of
Shipping/Boating Related
Activities
4.6.1 Oil Tankers, Cargo
Vessels, Ferries, Fishing
Vessels and Cruise Ships
WHISCA
Suggest the vessel’s name Lysfoss should be italicised.
Potential Impacts: Inter-tidal is one word elsewhere. Separate “break” and “down”.
Scottish Executive
FRS has a pivotal role to play in responding to marine incidents and provides 24 hour
seven day a week emergency cover to respond to oil and chemical spills and shipping
incidents. FRS would, with SNH, also look to chair any environmental group set up to
respond.
4.6.2 Boat Maintenance and
Antifoulant Use
WHISCA
The plural of marina is marinas.
Scottish Executive
FRS does not licence the use of antifoulants
4.7 Management of LandUse and Coastal
Development Activities
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4.7.1 Coastal Construction
SEETLLD
Add to responsibilities: administering Harbour Orders under the Harbours Act 1964 for
marine construction
4.7.2 Agriculture
4.7.3 Forestry
WHISCA
2nd sentence: FC Scotland manages its own forests for multiple-benefits. (Private ones
may differ.)
4.8 Management of Scientific
Research
Scottish Natural Heritage
SNH are the licensing authority for European Protected Species research that required
disturbance / capture e.g. tagging cetaceans.
Scottish Executive
It would be more accurate to say “FRS is responsible for licensing deposits in the sea
below MHWS”.
SEETLLD
SEETLLD responsible to issue Section 34 Consents under Coast Protection Act 1949
for scientific research that may cause a hazard to navigation
5.0 MONITORING
Scottish Natural Heritage
Perhaps there should be some reference made to the WFD and what this is going to
mean - a task for SEPA to do?
5.1 Site Condition Monitoring
Sealife Adventures
We welcome the requirement for site condition monitoring, and hope that the resources
will be made available to the relevant authorities for this to be effective. Methodology
has to be appropriate to the impacts occurring. The SNH definition of the precautionary
principle states that a lack of scientific evidence should not be taken as a reason to
delay taking action on negative impacts.
SNH also states that one of the circumstances under which the precautionary principle
must apply is within a SAC.
It follows that the need for monitoring must not be used as an excuse for not taking
action to prevent further damage to the Firth Of Lorne SAC
5.2 Compliance Monitoring
5.3 Review of Existing
Consents
Sealife Adventures
We have evidence of damage to fauna on the Lunga fish farm site, during the period
the farm was in operation, including a huge decline in the population of the UK-BAP
species, the Sea-fan Anemone. We would welcome the opportunity to present this
evidence to the relevant authorities, when the Lunga fish farm consent is reviewed.
We believe that the site is not in keeping with the requirements of the Habitats
Directive, and consent should be withdrawn.
6.0 IMPLEMENTATION &
REVIEW
6.1 Implementation of the
Argyll Marine SAC
Management Plans
6.2 Management Action
Implementation Timetable
It is important that the reviews of consents are independent and open to public scrutiny
It is a requirement of the habitats directive for the industry to prove that it is not causing
damage.
COMMENTS
WHAM Association
Correct name of organisation to Anchorages
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WHISCA
SCUBA Diving: delete “has been developed for distribution”
Sewage Effluent: delete reference to Loch Creran.
Boat Maintenance & a/foul Use: Marinas
7.0 References
8.0 Glossary
MCDU Office note
Add MRC/FCS catchment management plan
ACBA Code of conduct
Scottish Natural Heritage
Scottish Natural Heritage. There is still some confusion over references to the status of
the site as it is of course still a candidate site. Generally speaking it is referred to as a
SAC but there are exceptions e.g. in the glossary the definition for a European marine
site is a "candidate SAC..." Actually they are not, as strictly speaking the name
European only applies at the moment to sites adopted by Europe or SACs.Glossary Regulations. There is no need for a reference here to the Northern Ireland version and
it is suggested that it is deleted. Also, if that is deleted, then the final part needs to be
amended to say "domestic legislation"
WHISCA
Add: Benthic, Demersal
9.0 APPENDICES
Appendix I – Management
Forum Structure and Members
List
Appendix II – Appropriate
Assessment Procedure
Appendix III – Competent and
Relevant Authority
Responsibilities Relating to
Marine SAC Activities
COMMENTS
WHISCA
Include West Highlands and Islands Sailing Clubs Association
Scottish Natural Heritage
Scottish Natural Heritage. Recommend that it is amended as follows "The Regulations
require that, where an authority concludes that a development proposal unconnected
with the nature conservation management of a Natura 2000 site is likely to have a
significant effect on that site, it must undertake an appropriate assessment of the
implications for the conservation interests for which the area has been designated."
SEETLLD
Under SEETLLD, aquaculture, marine recreation, effluent discharges and marine
dumping section
Remove “out with harbour order area” because Section 34 Consent under Coast
Protection Act 1949 may be required if the harbour order does not confer on the
harbour authority the necessary power to carry out works etc.
Add “responsibility for preventing navigation. Issue navigation consent under Section
34 of Coast Protection Act 1949.”
Appendix IV – Scottish Natural
Heritage Conservation Advice
Appendix V - Diving Code of
Conduct
Scottish Natural Heritage
Appendix V Is this meant to apply to all Argyll sites as it mentions Creran
and FoL?
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