Consultation outcome

Annex 2: summary of points raised in meetings

Updated 28 February 2023

Introduction

This annex describes comments, views and perspectives from stakeholders at online and in-person meetings, which were hosted by Defra as part of the consultation. These comments have been treated as responses to the consultation and have been organised based on whether they refer to general comments or specific pilot highly protected marine area (HPMA) sites. Notes were taken for all workshops and drop-in events. Handwritten notes were taken for in-person events, whilst online sessions were recorded, automatically transcribed and these were used to generate summary notes. Throughout this annex, responses are presented as they were recorded directly from stakeholders and have not been amended with respect to facts or evidence presented.

Responses have been organised based on whether stakeholders presented general views about HPMAs, specifically inshore or offshore sites, or with reference to one or more specific HPMA site. Within sections regarding general points or specific sites, we have broadly grouped the responses by theme, although this does not entail a detailed thematic analysis of all responses. We describe points made by the affected participants or in relation to these themes (for example, commercial fishing) for each meeting. Note that some stakeholders will have attended more than one meeting, including across multiple sites and presented similar responses.

General points

Commercial fishing

Online meetings with fishing industry representatives

A national fishing industry organisation believed that the cumulative impact of displacement is extremely high, noting the pressures of spatial squeeze from offshore wind and other marine protected area (MPA) measures faced by the fishing industry and believed that affected stakeholders were not involved in discussions around displacement. The organisation noted that, as a result of displacement, the potential environmental impact of activities such as dredging and bottom trawling would move to more natural surrounding areas. The organisation also felt that the recovery of sites with the absence of human pressures would not be possible due to the impact of climate change and species distribution changing. Additionally, the organisation believed the monitoring process needs to consider the effects of displacement to industry and stressed the importance of engaging with the industry.

Commercial fishing respondents thought that a good baseline was required before further decisions were made on HPMAs.

Online Allonby Bay candidate HPMA Q&A stakeholder workshop

A national fishing industry representative pointed out Defra’s analysis being based on 2016 to 2021 data and that displacement and spatial impacts would be significantly different from 2021 onwards due to growing impacts of spatial squeeze. They highlighted that analysis focused on a small area and did not reflect wider issues such as the cumulative effects of other MPAs and offshore wind, noting that displacement could lead to massive changes in the operation of vessels and potentially undermine fisheries management.

Online North East of Farnes Deep (NEFD) candidate HPMA Q&A stakeholder workshop

A national fishing industry representative felt that the approach to HPMAs was more ideological in contrast to similar work done previously. They noted a report on spatial squeeze which suggested that a third to half of current fishing areas would be lost due to other sea uses including offshore wind and nature conservation which would have an enormous impact and raised concerns of further unintended consequences of HPMA designation. The organisation believed that there was potential chaos for fishing fleets because of displacement, including from other programmes. The organisation believed that no prioritisation had been given to the most crucial fishing areas and that considering alternate areas to fish would be suboptimal to commercial fishers’ initial choice. The organisation stressed their belief regarding the current inadequacy of government policy, noting that there was not a comprehensive government-level attempt to understand the displacement of fishing activity in line with its conservation and energy ambitions.

Online ISPS candidate HPMA Q&A stakeholder workshop

A national fishing industry representative stated the importance of taking macro level displacement into account.

Online Dolphin Head candidate HPMA Q&A stakeholder workshop

Fish producer organisations noted that documents were strong on hyperbole but not on evidence and specifics for example, some terms not being clearly defined. One producer organisation believed that only the fishing industry’s economy would be detrimentally affected as every other industry had been excluded. They stated that there was a lot of inconsistency regarding focus on other activities in comparison to the great focus on fishing.

In-person Inner Silver Pit South (ISPS) workshop

Regarding displacement, Fishers explained the great difficulty in moving to and fishing in another area already being fished and which “belonged” to others. Commercial fishing respondents stated that there was an assumption they could move, though it had reached a point in which they were unable to. The Fishers suggested that some aggregate dredging areas were coming to the end of their life so consideration should be given to designating them instead. Additionally, commercial fishing respondents mentioned that a legal precedent concerning visual and cumulative impact had been set (referring to offshore wind in Sussex).

Online NEFD candidate HPMA focus group

An EU fisheries producer organisation was concerned that MPAs and windfarms being placed on top of fishing areas increased pressure on the fishing industry and stressed that protected areas should be placed in areas that commercial fishers were not dependent on. The organisation also raised the issue of fishing prohibition causing displacement and having knock-on effects to surrounding areas which would in turn cause further impacts on fishing with the cumulative effect being greater pressure put on commercial Fishers.

Online Dolphin Head candidate HPMA focus group

A fish producer organisation stressed that fishing (as all other activity was excluded) was the only detrimentally affected activity and this could effectively be seen as discriminatory. They believe that the HPMA process is no more than a political experiment at the expense of the fishing industry. The organisation urged understanding of their perspective: HPMAs would be taking a guaranteed negative effect on a possible positive effect since outcomes are not exactly known. They emphasised that, with the consultation documents, annexes and presentations, displacement and its effects have been skimmed over with no in-depth analysis. They noted that the effects of displacement needed to be understood and that the figures used were incorrect and many more people would be affected in reality. The organisation also stated that nobody knows what will happen with climate change regardless of HPMA designations and the effects of outside influences could overshadow the effects of HPMA designations. The organisation did recognise that climate change is having an effect and there is concern of it affecting people’s livelihoods however, and understood that HPMAs would help combat climate change.

Online non-site-specific focus group for candidate HPMAs

A national fishing organisation suggested that it is difficult to determine whether HPMAs are good overall if the wider issue of displacement and spatial squeeze and change is not addressed adequately, and that this is what the wider fear of commercial Fishers are predicated on. They understood that unintended consequences were difficult to model and foresee but there were some foreseeable consequences (such as traveling further due to displacement or into pristine areas, increasing fuel use and costs), leading to a greater negative environmental impact. The organisation noted there would be a displacement effect due to HPMA designation which would impact fishing businesses and communities and the supply chain.

Anchoring and other marine uses

Online meeting with recreational sea users

A recreational boating organisation expressed surprise at the lack of sites in the southwest. The organisation noted that the UK Coastal Atlas of Recreational Boating data may not reflect locations people stop at for safety reasons and suggested the use of marker buoys around the sites for boaters.

Other benefits and impacts

Online meetings with environmental non-governmental organisations (eNGOs) and heritage organisations

eNGOs expressed concern at the potential designation of fewer than five sites (going against the Benyon Review’s recommendation of five minimum) and the UK government’s lack of leadership in committing to a greater number/percentage of HPMAs. eNGOs also noted the small size of sites and the negligibility of expected displacement as a result. One eNGO stressed the importance of HPMAs to everyone and to not let the HPMA project be derailed by a vocal minority.

A heritage organisation believed that public access should not be restricted to underwater heritage sites without good reason. The organisation noted that, though it may be hard to quantify, cultural importance should still be accounted for, and the fishing industry should be engaged on those grounds too, not just on economic activity.

Online meeting with marine industries

A UK shipping trade association highlighted that prohibiting ships’ discharges within HPMAs could result in vessels deviating to sub-optimal routes, noting that there is no regulatory scheme in place to prohibit vessels from discharging within sites. The organisation also flagged that only 30 to 50% of recreational craft carry AIS transponders so it is likely that half of those anchoring would not have been captured.

In-person ISPS drop-in session

A fisher believed that HPMAs were good as a general concept.

Online Allonby Bay candidate HPMA focus group

An eNGO stated that sites are protected by implementation not designation and that global evidence shows that there is greater benefit the longer an area is left alone. The eNGO also made a point that HPMAs support meeting requirements, many of which the UK is in breach of, and objectives under the Marine Strategy Framework Directive, the Fisheries Act and Habitats Regulations requirements.

Online NEFD candidate HPMA focus group

An eNGO noted the low coverage of 0.5% HPMAs in English waters and pointed out that though it isn’t known what recovery would look like, recovery levels were greater than expected in areas where trawling was stopped. Another eNGO noted that economic impacts have been given great consideration and suggested seeking to protect biodiversity hotspots were equally as important.

Online ISPS candidate HPMA focus group

One eNGO stated that HPMAs will recover habitats so will contribute to stock recovery though the degree of recovery would be dependent on management measures and illegal fishing levels.

Online non-site-specific focus group for candidate HPMAs

A renewable energy association believed that enforcement and monitoring were key to the success of HPMAs and that there needs to be robust scientific evidence for areas with strong potential for recovery. An eNGO added that some human presence/activities can be beneficial for biodiversity.

Another eNGO believed that marine spatial planning (MSP) would help commercial Fishers with spatial squeeze. The eNGO believed that HPMAs are an essential urgent action to combat the climate crisis and stated that there was lots of evidence to suggest HPMAs would help protect marine ecosystems. An additional eNGO said there is strong evidence to support the importance of HPMAs for spill-over and other ecological benefits and agreed on previous comments regarding marine spatial planning. The eNGO also said that the IA was lacking evidence on the positive health and wellbeing benefits which a thriving marine environment can have.

An academic suggested that sites are too small and may not be effective at the current sizes proposed and agreed with the national fishing organisation’s thoughts on marine spatial planning. The academic also suggested seascape planning and MSP were key to understanding and resolving unintended consequences for the marine environment. An eNGO also agreed regarding marine spatial planning and that small site size would limit the effectiveness of the HPMAs

Online Dolphin Head candidate HPMA focus group

An eNGO stated that there is a huge evidence base (from similar global research) for the potential impact and success of HPMAs, and that such protection could increase the abundance of different species and biodiversity. The eNGO noted that there are no ecosystems which can currently be considered in a fairly natural state and there was no safe space for migratory species to move through. The eNGO stated that designation should not be rejected on the basis of sites not returning to “pristine” condition due to the density of sea users but rather this means a baseline should be relied upon even more. The eNGO highlighted that there could also be potential spill over effects, including outside of the HPMA, which would increase abundancies and catch for the fishing industry. They raised the impacts of climate change on the dynamics of the ecosystem and said a baseline would be more appropriate and would potentially lead to significant improvement for biodiversity and ecosystem. Regarding climate change effects, they said that “having a balanced ecosystem within the HPMA could provide resilience for both the larger marine ecosystem and the fishing industry to environmental change”.

Another eNGO highlighted Emma Sheehan’s paper “drawing lines at the sand” and raised Lyme Bay MPA as an example of how to conduct baseline monitoring:

• recovery is monitored by simply observing what exists in the site and is returning or appearing, not an exact advance target
• scientists selected indicator species and monitored how they changed overtime
• effects from the MPA expanded to unprotected areas

The eNGO pointed out that the notion of HPMAs not leading to recovery would need justification and what recovery would look like would be seen going forward. They suggested that there should not be a question of whether there will be recovery (and should be given demonstration if no recovery is suggested) but what the trade-off is. They suggested that particular industries appear to be disadvantaged over others as they are required to do environmental economic IAs before rather than after, which does not apply to fisheries and MPAs. The eNGO said models would require ground truthing and would require direct input from, and data shared by, potentially affected commercial Fishers. The eNGO stressed the shared responsibility of displacement impacts on the environment, commercial Fishers and their livelihoods, and that the pilot HPMA process looked to designate and implement management measures in the best possible way. They stated that the pilot HPMA process is an ideal opportunity to trial different approaches to data gathering and collaborative work for the best way forward. The eNGO stated that displacement was a challenge but also a management issue which historically there has been a lack of interest in doing, stressing that there is no legal right to increasingly extract resource. The eNGO highlighted that banning fishing on a proportionally tiny area of English seas (0.5%) and UK seas (0.125%) leading to such an impact on fishing that it causes overfishing everywhere else would imply that fleet capacity is too high - they believe this would not be the case, adding that there is a localised element to that. The eNGO disagreed with the notion that an area which might protect some depleted fish stocks could not be protected due to overfishing of those species elsewhere and added that this fishing pressure should be reduced rather than moved around.

Another eNGO stated that “HPMA designation, and importantly future management, should have the benefit of protecting existing ecosystems and ensure areas are able to recover from previous impacts” and believed that a baseline had to be created based on how designated sites are monitored. They noted that “the current HPMAs are a pilot, so one issue that needs to be considered is if designation will protect blue carbon stores if rolled out”. Another eNGO stated that “shifting baselines are a real issue when it comes to targets for biodiversity improvements.”

Online meetings with fishing industry representatives

A national fishing industry organisation felt that the recovery of sites with the absence of human pressures would not be possible due to the impact of climate change and species distribution changing.

Management, compliance and enforcement

Online NEFD candidate HPMA focus group

An EU country fisheries group stressed the importance of regulating water quality and activities around HPMAs which will have knock-on impacts on the marine environment.

HPMA selection process

Online meetings with fishing industry representatives

A national fishing industry organisation said that they felt excluded from the Benyon Review and site selection process.

In-person ISPS plenary discussion

Some commercial fishing respondents felt there was a lack of involvement from commercial Fishers and they did not have fair representation.

Online Dolphin Head candidate HPMA focus group

A fish producer organisation believed the consultation process was flawed from the beginning as consultees did not have all information available to make an informed judgment and believed that the HPMA project was not appropriate and not science based.

General points about inshore sites

Commercial fishing

Online meeting with fishing industry representatives

A national fishing industry representative noted the proximity of Pacific oyster farms to site boundaries.

Recreational fishing

Online Allonby Bay candidate HPMA Q&A stakeholder workshop

A representative of recreational anglers suggested they were in support of HPMAs in principle though their biggest concern was the displacement of anglers, especially charter boats.

Online Non-site-specific focus group for candidate HPMAs

An organisation representing anglers welcomed HPMAs in principle and supported steps for ocean recovery though were concerned about the displacement of low-impact anglers and the evidence used for assessment. The organisation believed that sea angling was key in marine conservation and helping with the facilitation of data collection, monitoring and enforcement. The organisation also believed that for HPMAs to be effective, buffer zones around the site for recreational angling and other low-impact activities were needed so that their social and economic contribution to the local coastal community could be maximised.

Anchoring and other marine uses

Online Non-site-specific focus group for candidate HPMAs

An organisation for recreational boaters noted that alternative mooring locations and marking HPMA boundaries would help boaters. The organisation believed there would be a reduction in activity levels and impact would mostly be social (for example, effect on health and wellbeing) though there would be knock-on economic effects as a result of reduced activity. The organisation thinks suitable advanced eco-moorings can remove seabed impacts of anchoring without stopping core activity.

Online meeting with eNGOs and heritage organisation

A heritage organisation highlighted the cultural importance of Lindisfarne and the World Heritage site bordering Allonby Bay.

Online meeting with recreational sea users

A shooting organisation were content with the boundaries for the current inshore sites but suggested that there should be a balance between prohibited activities and activities which could occur under best practice principles.

Management, compliance and enforcement

Online NEFD candidate HPMA Q&A stakeholder workshop

A national fishing industry representative referred to inshore sites and the change in activities of IFCAs, believing this to adversely impact their ability to effectively manage fisheries due to greater time constraints, in turn affecting their relationship with commercial Fishers.

Online Allonby Bay candidate HPMA Q&A stakeholder workshop

A national fishing industry representative flagged the pressure IFCAs were facing due to MPA assessments, stressing that this had impacted the relationships between the IFCAs and Fishers, and fisheries management had been altered by inadequate resourcing.

General points about offshore sites

Commercial fishing

Online meeting with representatives of European Nations

An EU country government representative believed that <12m non-UK vessels do not travel to the offshore candidate sites.

Anchoring and other marine uses

Online meeting with heritage organisation

A heritage organisation stated that there may be undiscovered historic wrecks near the offshore sites.

Allonby Bay

Table 1: Summary of key risks and benefits noted in meetings by stakeholders for Allonby Bay candidate HPMA.

Stakeholder identified risks

• displacement of (limited) commercial and (more extensive) recreational fishing
• loss of recreational fishing-based tourism (charter boats, caravan park beach angling)
• knock on economic impacts to caravan parks, tackle shops, tourist businesses
• impacts on mental health and attachment to place
• lack of perceived necessity (good fishing and low impact of recreational fishing)
• flood risk defences/ restricted dredging
• long term viability of Maryport harbour – reduced boat numbers and dredging
• restricted dredging of nearby harbours Silloth and Workington

Stakeholder identified advantages

• bolster efforts to improve water quality
• protection desired for certain features such as Sabellaria reefs
• active promotion of the local area/ tourism
• manage peeler crab extraction

Commercial fishing

In-person Allonby Bay drop-in session

One Fisher believed that storm damage did more harm than fishing. Another Fisher complained about the HPMA proposal and process and believed that the workshop should have been better advertised. A part-time solo Fisher said that it was too dangerous to fish elsewhere due to his boat’s size and didn’t think the site needed protecting. The Fisher also suggested it was not possible to change gear and there were four other people in similar situations to him. The Fisher commented on what was fished for and his catch. The Fisher noted there was no bass permit and capped at 5 lobsters and 25 cod a day. The Fisher fishes for skate and lobster with gill nets and some people hook lobster and crab in the area, with some boat and shore angling for whelks and winkles in the area.

Concerns were raised about the impacts of fishing boats not being able to turn right (such as, to head North) out of Maryport harbour, and the knock-on effect on the harbour.

Fishers noted that the Marine Management Organisation (MMO) were looking for them to diversify from mobile gear. The fishers used pots and nets for skate, bass and thornback ray. They said that netting was seasonal, during which they catch lobster, thornback ray and bass, with the bass netting season typically being in September/October. The Fishers said there were too many seals for cod though some recreational fixed netting for it. The fishers noted there was not much trawling now though there was some along the site’s western boundary. The fishers commented that bait diggers historically came down from Newcastle, taking shore crabs, and commercial fishers came from Wales to fish the mussel beds.

Another fisher noted his catch and costs for the summer season (between April and September) including fuel, tackle and marina costs. The Fisher said that 90% of the fish were returned with only damaged fish kept for food. The Fisher said that cod had virtually disappeared from the Solway and there was no cod last winter due to trawling, habitat loss, and an increase in water temperature, in turn impacting business. He believed it was time measures were taken for improvements.

One commercial Fisher raised his concerns about recent investments he has made to fish in the area, and the potential impacts of the HPMA.

Recreational fishing

In-person Allonby Bay drop-in session

Recreational Fishers commented on their use of the site, stating that it was used for bait digging and angling club competitions, being popular to tourists and locals for shore angling. Recreational anglers were concerned about site enforcement citing people going out at night to catch peeler crabs in the spring. One recreational Fisher stated that they would continue fishing there regardless of designation, noting that they caught 5 to 6 skate, 3 to 4 cod and 2 bass per trip. The angler noted the mental health impact of prohibiting fishing in the area and commented on young people taking it up as a hobby over video games indoors.

A Fisher believed that only static gear, requiring anchoring, was used in the site. The Fisher stated that cod, salmon and bass came through the site, and that shore angling was mainly from Dubmill Point for bass fishing. The Fisher would not be able to relocate south of the site to catch skate.

A charter boat owner who runs angling trips said that designation stated they would stop their income and, as it is a rural area, there were not many opportunities. The owner said that there were 6 to 10 recreational boats on a nice day and suggested that there was better fishing in the HPMA rather than further away.

Anchoring and other marine uses

In-person Allonby Bay drop-in session

The MMO observed heavy haul riding along the beach whilst a representative of Allerdale Council stated strong support for the site with a suggestion it should cover the entirety of the Solway Firth.

Online Allonby Bay candidate HPMA focus group

A harbourmaster noted that Allonby Bay had been undergoing considerable erosion for the past five years, with sands and lighter aggregates being deposited to the NE of Allonby Bay. The harbourmaster mentioned that there were occasional sailing and motorboat events in the waters off Allonby Bay, including dolphin and porpoise watching. The harbourmaster stressed the impact of designating the site with the worst-case scenario being that the port would close due to the channel being blocked with the knock on effect being that important businesses would close down resulting in many jobs being lost. They explained that a slight change in boundary would remove the mutual impacts.

An independent charity said that Visit Allerdale were actively promoting the local area and visiting the coast. They stated that Allonby Bay was popular with walkers and dog walkers, with much other recreational activity (horse-riding, windsurfing, kitesurfing, canoeing, swimming and motorised bikes) taking place. They noted that the car parks were often full and static caravans had easy access to the beach. The charity noted that the main issue was likely to be disturbance to birds due to the limited space between the watermark and road.

Other benefits and impacts

In-person Allonby Bay drop-in session

Local residents were concerned about the impact of designation on maintenance outlets due to the fear and risk of flooding. They highlighted that the flooding of homes had occurred on several occasions in the past 20 years. The Environment Agency have pledged to manage the beck outlet on an annual basis.

A Maryport Harbour representative was also concerned about the potential impact of harbour dredging on the site.

One attendee hoped that any designation would lead to better water treatment works, stating that the area had been struggling for some time for Blue Flag status.

Several attendees queried why the area was proposed for designation if it’s in good ecological condition.

Online Allonby Bay candidate HPMA focus group

An eNGO noted that due to its small size, it would likely be more effective at protecting sessile species over mobile species, unless the area was important for spawning.

It was mentioned that designation could potentially attract more people to the area, which may conflict with the designation itself.

Views on boundaries

In-person Allonby Bay drop-in session

A Fisher suggested pulling the site boundary 200 to 300 yards off low water to reduce the impact on anglers, noting that angling was important for pleasure and recreation with families.

Lindisfarne

Table 2: Summary of key risks and benefits noted in meetings by stakeholders for Lindisfarne candidate HPMA.

Stakeholder identified risks

• impacts of displacement on commercial potting inshore fleet and wider community.
• ripple effect of displacement further along the coast and increased gear conflict.
• lack of adaptive capacity of Fishers due to small-size of boats (health and safety risk to move offshore) & tidal island restrictions (necessity to move from Holy Island).
• de-population of Holy Island, loss of young families, erosion of island economy, school viability, coastal guard and emergency service provision, permanent resident/ labour pool, tourism/ business viability.
• impacts on mental and physical health over livelihood uncertainty.
• lack of perceived necessity due to existing conservation measures and low impact of potting (the only remaining fishery in the area).
• decimation of regionally valued fishing-heritage, history and culture.
• reduction in full time/ year-round shore-based shellfish processing employment in areas of high social deprivation (Eyemouth and Berwick).
• loss of anchoring threatens diving tourism businesses operating around the Farnes.
• water quality /river pollution /caravan park discharge is not addressed by HPMA/ missed opportunities to protected seagrass beds in the Fenham Flats area.
• concern over how the HPMA would be feasibly enforced / policed.

Stakeholder identified advantages

None identified

Commercial fishing

Online meetings with fishing industry representatives

A national fishing industry organisation queried why Lindisfarne was chosen, flagging the economic impacts on businesses of already existing designations.

Commercial fishing respondents believe that Natural England’s figures regarding Lindisfarne were incorrect. They also said that spiny lobsters were rarely caught in Lindisfarne. Commercial fishing respondents also stated that potting benefits the local community and has been sustainably managed and does limited damage meaning that further restrictions were unnecessary.

Online Lindisfarne candidate HPMA Q&A stakeholder workshop

A member of the local authority noted that 15-18% of Lindisfarne’s population were made up of Fishers. A national fishing industry organisation questioned the £3.5 million figure given for fishing vessels whilst NIFCA stated that their figures for first sales were roughly double (£6 million) the figures presented in the consultation.

In-person Lindisfarne Seahouses afternoon drop-in session

A commercial shell noted their processor is based in Eyemouth and that they had recently spent £150,000 on a new commercial boat and a new recreational boat. The Fisher said that it was not possible to go south of the site to fish as it would cause conflict with other commercial Fishers which would further affect coastal towns. The Fisher said that there were limited opportunities for adaptation as they could not change to gillnets due to wildlife and salmon being in decline. The Fisher said that there was no impact on birds, shellfish, dolphins and seals. Another local commercial Fisher said that the number of commercial Fishers were much fewer than the 40 identified pre-consultation.

A group of individuals representing a major local authority, fisheries management organisation and harbour stated that Berwick Shellfish had recently built a new factory based on the crab and lobster fishery. The group were also concerned about displacement from NEFD if it were to be designated, citing worry at the prospect of gill nets and longlines being used in the Lindisfarne area.

In-person Lindisfarne Seahouses evening drop-in session

A commercial Fisher stated that the area was currently very busy but manageable and closure would create huge spatial conflict, essentially a “civil war”, and outside the site would be decimated. The Fisher said that fishing the line would result in gear conflict, pot loss and ghost fishing. Another commercial Fisher said that leaving lobsters on the ground would lead to them becoming diseased, growing larger and eating smaller lobsters. A café owner who was also a Fisher expressed concern about the combined impact of being unable to fish and no customers visiting his café. One commercial Fisher mentioned that seals removed everything from nets so really only pots were viable, leaving little room for diversification. The potential settlement of oysters from a Pacific oyster farm nearby caused some concern. Commercial Fishers said that designation would not improve water quality and it was difficult to accept a proposal in which there was a clear path to ban fishing but not for the issue of water quality to be addressed. A trader emphasised that the fishery had existed for centuries and was properly policed by the IFCA, MMO, commercial Fishers and traders, highlighting that the fishery had grown over the past 15 years due to being policed properly.

Recreational fishing

Online Lindisfarne candidate HPMA Q&A stakeholder workshop

A representative of a greater local authority noted that angling did not occur in Lindisfarne.

In-person Lindisfarne Seahouses afternoon drop-in session

An Amble-based angler who has a boat and fishes the Farnes in the summer with his father, making 2 to 3 trips a year, said that approximately 70 litres of fuel was used per trip. The angler noted that there was nowhere else similar on the Northumberland coast to fish. The angler believes he is the only angling vessel fishing the area, though all fish were caught and released. The angler listed his catches from the boat being cod, pollack, coley and wrasse with catches from the shore being mullet and bass – the angler noted 17 shore trips in the HPMA this year so far with 12 the previous year). He noted the pier on the south side of Budle Bay being regularly fished. The angler knew of one charter boat from Seahouses and some boats occasionally from Beadnell Bay. He questioned the angling potential data, stating that there was little to no angling in Fenham Flats, and suggested boundary changes.

Online non-site-specific focus group for candidate HPMAs

An organisation representing anglers said that angling tourism was important to the local economy according to their local contacts.

Anchoring and other marine uses

Online meeting with marine industries

With regard to Lindisfarne, and citing their statutory duties under the Merchant Shipping Act 1995 (MSA), a General Lighthouse Authority and charity flagged that navigational aids there may occasionally need to be moved and maintained.

In-person Lindisfarne Seahouses afternoon drop-in session

A group of individuals representing a major local authority, fisheries management organisation and harbour did not see any benefits from ecotourism and believed designation would threaten scuba diving operators who anchored in the site due to high currents. They also stated that a third of harbour dues came from the HPMA area.

Online Lindisfarne candidate HPMA focus group

A member of the local authority stressed that Lindisfarne was a working area for fishing and was not for leisure, stating that there was no marina or mass recreational area, only some fishing boats. There is probably a long-distance cruising route for craft on passage along the east coast. A representative of a greater local authority stated that there was some use of the intertidal area (by walkers and dogwalkers etc) and that restrictions would push activities recreational (including use of the shore) or potting into other areas. An academic noted that boats went from Seahouses to Lindisfarne and Outer Farnes.

Other benefits and impacts

Online Lindisfarne candidate HPMA Q&A stakeholder workshop

The pollution from the Tweed and Firth of Forth was cited as a water quality issue in the site. An advisory committee believed that this area of the coast had not been degraded. A representative of a greater local authority was concerned about the knock-on impacts on local restaurants, hotels etc.

In-person Lindisfarne Seahouses afternoon drop-in session

A group of individuals representing a major local authority, fisheries management organisation and harbour noted a notion going through a local authority to reject the HPMA proposal due to its “devastating” effects. The group noted Lindisfarne as one of the poorest places in the world following the miners’ strike and noted that the community was still recovering from it. The fisheries management organisation would be open to revisiting the Berwick Coast recommended reference area from the Net Gain MCZ Project. The group noted the impact of caravan sites on water quality. They also believe that roughly 95% of mud and seagrass in Fenham Flats may be lost due to sewage from the Haggerston caravan site.

In-person Lindisfarne Seahouses evening drop-in session

There was worry about the livelihoods of local van drivers, buyers, boat servicers, engineers, hotel and caravan sites, cafes, shops and restaurants who were already struggling due to the economic situation. It was raised that many tourists visited Lindisfarne to angle which was profitable for the local economy. It was noted that a third of Lindisfarne’s tourism was nature-based. It was also noted that the effects of bird flu on the tourist trade from bird watchers was already being seen. An attendee noted that the increased carbon footprint of additional steaming time would cancel out benefits of protecting blue carbon. It was mentioned that skin divers needed to use anchors as there was not always someone on the boat. A local authority member was concerned about the potential impact of designation on recent largescale investment in a caravan site.

In-person Lindisfarne Holy Island drop-in session

There was great concern around the potential designation of Lindisfarne and its impact on the historic community. There were concerns about poor data and justification of the proposal, adding that Defra did not know the conditions of the site currently or what exactly Defra was aiming to achieve. The attendees commented that the site should be hugely degraded to justify the devastating impact of designation on the local community. The attendees elaborated further, stating that the tidal cut off of the island severely limited alternative employment opportunities, noting that: of the 127 islanders 61 work in or contribute to the local community and economy, of those 61 workers 16 are Fishers, and only 10 work away from the island. It was also mentioned that the closure would impact on storage and shellfish processing in Berwick. A community figure raised the prospect of allowing people to continue fishing in reserves and cited the Philippines as an example. Potential impacts on future investment and efforts to retain an island community were also cited. Additionally, there would be impacts on the island’s first responders, because 3 of the 5 coastguards are from fishing families.

Online non-site-specific focus group for candidate HPMAs

A national fishing organisation suggested that local restaurants would be particularly impacted by the effect of displacement in Lindisfarne.

Online Lindisfarne candidate HPMA focus group

A community figure in Holy Island highlighted that 40% of the island’s population is working and, of this, 30% were Holy Island commercial Fishers or from fishing families. An academic highlighted that most of the sensitive sites were not included in the proposed boundary and queried the exclusion of Fenham Flats and Inner Farnes, despite the inclusion of Outer Farnes, given the notable presence of large seabird colonies. An eNGO suggested a more focused no-take zone to support sustainability of fisheries in partnership with the community.

Management, compliance and enforcement

Online meeting with recreational sea users

Regarding Lindisfarne, a shooting organisation suggested that wildfowling wardens at the existing NNR may be able to help with monitoring the site.

HPMA selection process

In-person Lindisfarne Holy Island drop-in session

Several people said that the data presented was inadequate and that it would have been preferable for Defra to visit the site earlier in the process.

North East of Farnes Deep

Table 3: Summary of key risks and benefits noted in meetings by stakeholders for North East of Farnes Deep candidate HPMA.

Stakeholder identified risks

• spatial squeeze of fishing vessels amongst other users (wind farms especially)
• potential cumulative regional economic impacts of two candidate sites being co-located next to each other
• commercial fishing displacement and increased gear conflict/ fishing intensity at bordering areas
• loss of future fishing ground potential (such as squid)

Stakeholder identified advantages

• potential to restrict foreign fishing fleets (sandeel vessels)
• protect deterioration of prawn fishery in Farnes Deep

Commercial fishing

Online meeting with fish producer association

A UK fish producer organisation believed that the estimated revenue figure of £10,000 for the NEFD was too low due to the highly dependent Nephrops fishery in the area.

Online NEFD Candidate HPMA Focus Group

An EU country fisheries organisation did not think that NEFD’s habitat would change within the next 10-15 years. The organisation said that NEFD was an accessible site for sandeels, though revenue varied yearly.

In-person North Shields drop-in session

Fishers noted that non-UK effort was greater than UK effort in the site. They added that at some point, constant displacement becomes untenable and explained that displacement requires more than just moving to a new location; different gear would also be needed. One noted that displacement has both an economic and environmental impact for commercial Fishers, highlighting the importance of considering future fishing careers. A Fisher explained that he wanted to protect the Farnes Deep area due to prawn deteriorating but that, conversely, there was potential for development of the squid fishery.

Management, compliance and enforcement

Online NEFD candidate HPMA Q&A stakeholder workshop

An eNGO suggested comparing likely proposed management measures as opposed to what’s currently in place (in the MCZ) to observe enhanced ecosystem services benefits and highlight the differences between the MCZ and HPMA.

Views on boundaries

Online NEFD candidate HPMA focus group

A Danish fisheries organisation noted that most Danish activity was in the south of the site where fishing banks were located and suggested that the south border of the site was moved north slightly to remove pressure on Danish commercial Fishers.

Inner Silver Pit South

Table 4: Summary of key risks and benefits noted in meetings by stakeholders for Inner Silver Pit South candidate HPMA.

Stakeholder identified risks

• spatial squeeze of fishing vessels amongst other users (wind farms especially)
• commercial fishing displacement and ripple effect of displacement / increased gear conflict over potting grounds
• cumulative effect of different types of displacement pushing boats further offshore
• lack of perceived necessity due to (perceived) low impact potting in the area / potting restricts (more damaging) trawler access to the area

Stakeholder identified advantages

• could address higher soft-shelled crabs seen in recent years.
• potential protection and recovery for Sole, Mackerel, Whiting and Cod, and some sea birds
• protection and recovery of a site that is unique in terms of its depth and the existence of wildlife generally not found in surrounding North Sea habitats - the Silver Pit is a unique feature within the Southern North Sea known as a biodiversity hotspot for marine wildlife
• the site is unique in terms of the lack of human intervention and, excluding fishing, limited marine activity due to its depth unlike the rest of the North Sea seabed – a HPMA would further enhance this
• there is potential for positive socio-economic impact from HPMA designation through growing a sustainable eco-tourism industry

Commercial fishing

In-person ISPS plenary discussion

Some Fishers suggested that the ecosystem rebuilds itself after a strong gale, based on evidence of debris on pots. They also stated that the English spider crab was beginning to come up north, showing how things were changing on their own ecologically.

Commercial fishing respondents said that Grimsby was most likely to be impacted and noted conflict between crab Fishers, and with trawlers also, in the area was likely to be exacerbated by designation, with the ripple effects of displacement and gear conflicts difficult to assess. Commercial fishing respondents said that potting protects the fishery from trawling, and were frustrated that this was not recognised, and may have enabled recovery of the marine environment too. Also, commercial fishing respondents said they used the site seasonally and did not use the site in winter, but they left their gear there to prevent trawlers from moving into and operating in the space. They added that no crab fishing occurred in the middle section of the deep water, only trawling. Commercial fishing respondents highlighted that “we [are] getting to a stage where at least the static gear is saturated in place, and is in the position where they similarly cannot adapt, on parallel with the windfarms and more immovable activities”.

In-person ISPS drop-in session

A Fisher stated that most commercial Fishers in the site were based in Grimsby and whether they fished for lobster or crab depended on bait and conditions. The Fisher believed that the area was fairly self-regulated based on the large number of tides. The Fisher said that it was possible to diversify gear, but it was pointless as the alternative was cod which was in the same area so fishing the species would be prevented by the proposed HPMA also.

In-person ISPS harbour visits

A Fisher could see some benefits of a HPMA in general if it did not personally impact them. Fishers commented that there would be issues moving to new areas if the proposed HPMA went ahead. A Fisher had concerns over displacement and noted that some boats were more aggressive. A Fisher believed that boats from Grimsby fish within the site. A Fisher stated their crew was local with the furthest being from Hull. It was said that no limit existed on pot numbers so there were more pots in the area. A Fisher stated that they fished to the north of the site, not within the site, mostly for crab. A Fisher noted that a lot more soft-shelled crabs had been seen and thought that this had been the case since the “Beast from the East”. It is believed there is a plentiful supply of lobsters in the area, especially on the edge of the deep channel, with one Fisher noting that catches have stayed high since he had started fishing in the area. Commercial fishing respondents said that there was a range of use of the area, with several advising it was used for whelk and lobster potting, whilst the deeper channel was used for potting and scallop dredging and communications between both types of commercial Fishers. They also confirmed use of the area by French trawlers.

In-person ISPS workshop

Commercial fishing respondents pointed out that activity in the area was a result of displacement already and there was better fishing in the site now than 30 years ago. Commercial fishing respondents also stated that 30 years ago there were many beam trawlers in the site and scallop dredgers had also gone now, adding that there was now primarily only potting. Some commercial fishing respondents stated that potting for crab was the only activity in the site and that other grounds may not be suitable for crab fishing. Some commercial fishing respondents said that trawlers were mainly in deeper water around the edges of the pit. Commercial fishing respondents pointed out that trawling activity can repeatedly be carried out, but once pots were down nothing else could pass. Additionally, commercial fishing respondents raised health and safety as an issue, noting that pots could be set on some tides which end up with dangerous bar tight lines. Commercial fishing respondents also said that the area was good for lobster so it would be difficult to replicate and fit a full set of gear elsewhere. Fishers stated that there were lots of stones in the area so it would not be good for mobile gear. One Fisher said that it was their first time seeing spider crab in the site and that they had never seen it before.

Commercial fishing respondents believe that Bridlington to Cromer must be the most densely used fishing area in the UK and believe that there are probably more Grimsby boats fishing the site but, through displacement, would also affect Bridlington. Commercial fishing respondents stated that they would lose business as a result of ISPS’ designation and may need to try new areas as a result. However, commercial fishing respondents said that bigger boats had no time to try new grounds. Commercial fishing respondents also stated that designation would displace trawlers who were after whiting through the middle section of ISPS. Commercial fishing respondents think that spatial squeeze means they are being forced into smaller areas for fishing which creates gear conflict and a concentration of fishing effort leading to greater damage. When asked about changing the boundary, commercial Fishers said that every little bit had an impact.

Fishers believed that the number of boats recorded was over the top, and that some VMS pings were probably from vessels steaming slowly. Commercial fishing respondents said that they were not convinced of the spill-over from designation and that there were natural feature boundaries for crab and lobster.

Anchoring and other marine uses

In-person ISPS workshop

Comments were made that wind farms were expanding, and that shipping was increasing, thereby increasing the likelihood of anchorages.

Other benefits and impacts

Online meeting with heritage organisation

A heritage organisation noted that the ISPS is a glacial feature and there is a lot of historic interest in the area.

Online ISPS candidate HPMA focus group

An eNGO said that designation would potentially protect and recover species (such as sole) that were currently going through stock difficulty, further expanding on this by potentially protecting and recovering species (such as cod, whiting and mackerel) facing stock difficulty in the southern North Sea specifically. The eNGO added that ISPS was an important site for seabirds.

Another eNGO emphasised ISPS’ uniqueness in terms of its depth and the existence of wildlife generally not found in surrounding North Sea habitats, further highlighting that the Silver Pit is a unique feature within the Southern North Sea known as a biodiversity hotspot for marine wildlife. The eNGO also emphasised ISPS’ uniqueness in terms of the lack of human intervention and, excluding fishing, limited marine activity due to its depth unlike the rest of the North Sea seabed. The eNGO noted that the main socio-economic activity was fishing and that other industries working offshore tend to avoid ISPS given its depth and physical complexities. The eNGO suggested that there was potential for positive socio-economic impact from HPMA designation through growing a sustainable eco-tourism industry as marine mammals had been spotted in the area. The eNGO noted the Silver Pit’s incredible importance regarding marine wildlife.

Management, compliance and enforcement

Online meeting with representatives of European Nations

An EU country government representative noted the strange shape of ISPS and thought that enforcement of this would be difficult.

HPMA selection process

In-person ISPS harbour visits

Fishers highlighted issues with communications saying that they were not notified of these proposals and were not able to attend the consultation due to the need to be out fishing. Commercial fishing respondents said that most of the Fishers were unaware of the HPMA proposal and were concerned about the potential economic impacts it may have. A Fisher had heard of the proposal through a family member who had engaged in afternoon discussions at the harbour.

Dolphin Head

Table 5: Summary of key risks and benefits noted in meetings by stakeholders for Dolphin Head candidate HPMA.

Stakeholder identified risks

• spatial squeeze of fishing vessels amongst other users (wind farms, gravel extraction, natural features)
• commercial fishing displacement and increased gear conflict/ fishing intensity at bordering areas
• impacts on non UK fishing vessels (French)
• increased fuel costs in accommodating the site

Stakeholder identified advantages

• the Fisheries Management Plan and the Specialised Committee on Fisheries would cover the impact on Channel non-quota species and mitigate displacement
• would be beneficial for top predators in the area
• no-take zone generally increase local fish stocks which improve biodiversity and positively impact the economy
• would provide protection and allow recovery of cetaceans and the key species they feed on

Commercial fishing

Online Dolphin Head candidate HPMA Q&A stakeholder workshop

A national fishing industry representative believed that the site-specific information was not reliable and that there was an absence on the economics of a coherent government approach to displacement. An eNGO pointed out that, according to the IA, the economic impact was a result of the existing MCZ and not the candidate HPMA.

In-person Dolphin Head in-person presentation and open forum

A fishing association based in the southeast made several comments on the potential designation of Dolphin Head as a pilot HPMA. The association described the HPMA proposal as an “experiment” and that it would not be supported by the fishing industry. They explained that more than 166 boats would be displaced into surrounding areas as a result of designation and that commercial Fishers were already experiencing spatial squeeze meaning that surrounding areas would very quickly become exhausted. The organisation explained that displacement into surrounding areas would increase interaction with new gear types and new commercial Fishers and it would not be possible to switch to new gear types, with challenges including: dredge boxes to the east, scallop fisheries and EU vessels to the south, being unable to fish north due to natural benthic habitats and displacement would occur in the northeast and southwest of the site. They added that commercial Fishers may be put out of business by high order displacement. The impact of displacement was stressed as being a chain reaction and exponential in effect.

The association explained that due to the wind and tide the area’s fishing grounds moved frequently. They noted that the number of under 10 vessels are three times the number of larger boats. They also noted that the approach used to allocate fishing effort using boat speed did not work for potting because potters used a speed of less than two knots. They believed that the revenue figures estimated and presented were ‘exceptionally low’, adding that commercial Fishers’ greatest expense was fuel.

In-person Dolphin Head drop-in and focus group

A Fisher that was also a fishmonger was “very upset” about the site proposal. They described that they were currently building a boat, costing them a total of £1.3 million, to use for potting within Dolphin Head and, although the proposal would not immediately impact them, they planned to fish in the site in the future. Including the vessel under construction, they had another boat which was originally built as a ring netter but was since converted to a potting boat due to Sussex IFCA’s netting ban. They explained that scallopers smashed the seabed, leaving no lobsters only scallops, and that lobster fishing in Sussex had collapsed. They also explained that 95% of crab mortality was caused by targeted fishing, with the rest down to sand boats, capital and maintenance dredging, bycatch from beamers, and bycatch from trammel nets. They believed that the minimum landing size for lobster and crab was too low and that the ban on berried hens was counterproductive due to causing an imbalance to the sex structure, adding that the ban should instead be on crabs and lobsters with missing claws. They clarified that they saw the advantages in having ‘no-go zones’ but did not see it for potting. They highlighted staffing as a key issue for fishing vessels and suggested the MMO aggregate category A, B and C licenses to make it easier for commercial Fishers to move between static and mobile gear. They additionally explained their views on the effects of thunderstorms on marine life, which freely removed oxygen through ionisation.

Online Dolphin Head candidate HPMA focus group

A fish producer organisation stated there are both ecological and economic disadvantages to designating Dolphin Head and many questions to consider as a result for example, the effect of displacement to other areas, including ecologically, and fishing previously unfished/lightly fished grounds. The fish producer organisation highlighted that both UK and EU vessels would be forced into areas occupied by other industries and other sectors of the fishing industry due to the criteria used. They stressed that displacement was about more than just being displaced into other fishing areas but about being displaced into other sea user areas. They elaborated, stating that it was not just about over capacity of the fishing industry but about the sea in the eastern English Channel being over capacity for all sea users which would have an exponential effect on the eastern English Channel due the effect of spatial squeeze and its shape and size – being at a saturation point.

An EU country fishing organisation stated that fishing effort was very high in the area and fishing vessels would have to move meaning displacement would be extremely difficult, especially with the huge amount of industrial activity in the area meaning increased fishing efforts and obvious consequences on resources. The fishing organisation highlighted that the fishing industry still did not know the full consequences of the UK’s EU exit, noting that 612 ships had lost access to UK waters and have consequently moved to the south and middle of the Channel in the Dolphin Head site, adding that many species were without quota. The organisation stressed that English commercial Fishers did not catch much whelk in the French side and, if a limit was placed on the species, several commercial Fishers would have to move into the English side which may increase presence in Dolphin Head. The organisation also commented “about displacement: fly shoot fleet strongly increased in recent years; it is not included in the data. Defra launched a consultation on fly shoot management especially in the 6-12nm, the consequence will be displacement of the fleet more in mid Channel”.

The EU fishing organisation also spoke about thornback ray, stating that there was a report on the functional area noting a nursery in Thames Bay and most of the Channel being a habitat for the species, adding that the species was at its highest level historically. An eNGO disagreed with the organisation and stated that the assessment of thornback ray stock was poor and that it did not necessarily mean high or maintaining an adequate level of stock. An English fishing organisation added that ICES highlighted thornback ray in Dolphin Head and have done a stock assessment, noting that ICES is the best available evidence and shows that stock is at its highest level since 2006. Another French fishing organisation also made comments on thornback ray, stating that it was a category 3 stock. The organisation noted that “thornback ray is a category 3 stock (advice based on survey), ICES advice shows that the stock size indicator has had a high increase since 2011 (indices multiplied by 5 between 2011 and 2016), with a stabilization now (but still 9% increase)”.

An eNGO noted that the impact on Channel non-quota species would be covered through the Fisheries Management Plan and the Specialised Committee on Fisheries so there are management mechanisms to come into place for displacement. The eNGO noted that several non-quota fisheries in the Channel were catching too much already, and some stocks (such as cuttlefish) were already struggling. They also stated that the south coast Fishers they have engaged with about fly-shooting have said that catches of non-quota species have dramatically increased, and this is having a detrimental effect on fish stocks and Fishers not using those methods.

Recreational fishing

Online Dolphin Head candidate HPMA focus group

A fish producer organisation agreed with the data on low angling activity in Dolphin Head.

Anchoring and other marine uses

Online meeting with marine industries

A UK shipping trade association noted that an International Maritime Organization (IMO) Traffic Separation Scheme (TSS), containing the main shipping lanes in the English Channel with high vessel traffic, was around Dolphin Head.

Online meeting with representatives of European Nations

An EU country government representative highlighted a possible correlation between Dolphin Head’s seabird population and the influence of shipping on it.

Online Dolphin Head Candidate HPMA Q&A stakeholder workshop

A fish producer organisation noted the lack of focus on/mention of shipping though it is a major activity in the area, explaining that the whole Dolphin Head site was highly active with shipping. Additionally, the organisation suggested that HPMAs could be co-located with offshore wind farms as they had baseline surveys, monitoring, and buy-in from the fishing industry already.

In-person Dolphin Head in-person presentation and open forum

A fishing association noted that there was a traffic separation scheme near to Dolphin Head meaning that there was an issue in potential ship collision.

Online Dolphin Head candidate HPMA focus group

A fish producer organisation believes HPMAs are a sensible idea but should be implemented in a low-use area rather than a highly used area already oversaturated with multiple marine industries.

The fish producer organisation agreed cetaceans were in the area and that certain activities affected them and their mortality, noting shipping as an activity ignored by the consultation. They noted that shipping would be allowed to continue and would not be rerouted bringing into question the “whole-site” approach. The organisation also highlighted that other future marine activity in the site does not exist at present so in reality would have very little if any effect as they can be easily avoided.

An EU country fishing organisation said there was great difficulty in understanding the social and economic consequences of Dolphin Head’s designation, highlighting that it was a highly trafficked area in the eastern part of the English Channel, probably one of the most important in the world and the most trafficked of the 5 candidate HPMAs.

An eNGO also commented on vessel activity. The eNGO noted that “international shipping can be controlled on environmental issues via an internationally agreed PSSA designation”. The eNGO added that “recreational activity - indicated by AIS and Safetrx data - is probably very low for this area, but you will need to confirm with RYA.” The eNGO additionally noted the difficulty of referencing sites in an area with a long history of fishing (and other activities) in the English Channel and believed bringing up baseline monitoring in the English Channel was a false issue.

Other benefits and impacts

Online meeting with heritage organisation

A heritage organisation noted that Dolphin Head may be of interest due to the aggregate area.

In-person Dolphin Head drop-in and focus group

A Fisher that was also a fishmonger noted the impacts from poison due to sewage which did not clear as the English Channel was too narrow and was concerned about TBT impacts from dumped dredge material. They also noted that all the kelp from Selsey to Shoreham had died.

In-person Dolphin Head in-person presentation and open forum

An eNGO commented that the proposed HPMAs are essential and to consider the big picture benefits they could bring.

Online Dolphin Head candidate HPMA focus group

An eNGO believed that HPMAs would definitely provide benefits, especially for top predators in the area. The eNGO stated that the English Channel was a highly industrialised area so it would be a shame to not introduce a HPMA to observe what happens, noting an example of a no-take zone which increased local fish stocks by 70%, which improved biodiversity and the economy. The eNGO also made several points regarding cetaceans. They spoke of cetaceans in Sussex which were struggling with the destruction of breeding areas for fish like bass and bream, highlighting that the site was a key target area for horse mackerel commercial Fishers, which is a key food source for the Atlantic Bottlenose dolphin over the winter. The eNGO stated that cetaceans in the eastern English Channel were predominantly small (such as harbour porpoises, bottle-nosed dolphins and common Atlantic dolphins) and they were generally not impacted by ship strikes, noting there have been interactions and the occasional issue. The eNGO added that data showed the predominant cause of cetacean mortality was from bycatch, directly from fishing operations.

HPMA process

Online Dolphin Head candidate HPMA focus group

A fish producer organisation stated that if the success criteria is unknown then it is difficult to know what success is and whether the policy will succeed.

A French fishing organisation questioned the selection of a site in a high traffic area and noted that the designation of Dolphin Head would affect the rest of the Channel.