This document highlights a series of legal, procedural and ecological shortcomings of the Welsh Government’s current policy for the implementation of a series of Highly Protected MCZs in Wales.

The Welsh Government’s proposals outline the introduction of highly protected MCZs where all “extractive and depositional activity will be prohibited”, these areas go beyond simple no-take-zones and may affect a wide variety of sea users. The Welsh fishermen, their communities and others people who enjoy the sea fear that this blanket approach to marine management will impact commercial fisheries, recreational angling and related tourism activities.

Uncharted Waters highlights some key shortcomings and impacts of the current policy:
1. There is no legal requirement for HPMCZs – it appears that Marine and Coastal Access Act 2009, under which these sites will be designated, does not include any legal requirement for the implementation of “highly protected” MCZs and that the current proposals go beyond the stated aims of MCZs within the Act.

2. An adequate MPA network already exists in Welsh Waters – Welsh Government figures state that 75% of the coastline and 36% of Welsh territorial waters has already been designated for marine conservation, mainly in the form of European Marine Sites such as Special Areas for Conservation and Special Protection Areas. In fact close to 50% of territorial waters between 0-6 miles from the shore, where the majority of fishing and recreational activities take place, are already protected for conservation. Surely this represents a coherent network of MPAs in Wales?

3. The HPMCZ policy in Wales is unreasonable – the approach and criteria used to implement the HPMCZ policy in Wales is inconsistent with those employed in England and Scotland which are seen as more democratic. The process in Wales appears to have been driven as much by advocacy of single issue groups and personalities as based upon scientific evidence.

4. Disproportionate effect of HPMCZs on the inshore fishing families and communities – the HPMCZs proposed by Welsh Government are all bar one sited close inshore where the majority of fishing and recreational activity takes place. The prohibition of these activities on small coastal communities will result in far reaching social, cultural, and economic impacts. Many Welsh fishermen have family histories describing fishing and making a living from the sea for many generations. These family traditions and the aspirations of the next generations are now threatened by the imposition of HPMCZs.

No guarantee that HPMCZs will benefit biodiversity or commercial fisheries – the claims that HPMCZs will deliver significant gains in either biodiversity or fisheries benefits have been overstated by both Conservation Agencies and some green pressure groups.

There is in fact a lack of evidence in northern temperate waters of any significant positive effect of such sites. In short, the WFA believe that HPMCZs are the wrong tool for the job.

6. The negative effects of HPMCZs on other conservation sites has not been considered – the current HPMCZ policy has not adequately assessed the effects of displacement of fishing effort and other activities excluded from these sites to other areas. We have recently witnessed in Wales the effects of displacement on the Cardigan Bay scallop fishery when fishing vessels excluded from traditional fishing grounds in Lyme Bay were forced to look for fishing grounds elsewhere. This pattern could be repeated around Wales by all manner of fishing and recreational activities.

The WFA fully support Welsh Government’s commitment to the UK vision for ‘clean, healthy, safe, productive and biologically diverse seas’ but believes that there are better ways to achieve it. The WFA has recently produced a report entitled “Striking the Balance” which outlines an alternative ecosystem-based approach to MCZs, one that would promote ecosystem recovery and resilience and better our understanding of the marine environment but without adverse impact to fishermen and local communities. The WFA urges the Welsh Government to give serious consideration to WFA’s alternative proposal and to abandon the 2nd and 3rd stages of the current consultation to focus on the delivery of a truly ecosystem-based solution for Wales’s marine environment and the fishing and tourism communities who depend on it.

Uncharted Waters can be downloaded here: http://bit.ly/Oz1WrP

Striking the Balance can be downloaded here: http://bit.ly/QcTGQX

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