6th August 2003.

Dear Minister

Re: Proposal to Establish a Marine National Park on the West Coast of Scotland.

I am writing to you as Chairman of the Hebridean Marine National Park Partnership (Hebridean Partnership - HMNPP).  As you may be aware our Partnership has, for the past year, been developing a proposal for a marine national park on the west coast of Scotland under the National Parks (Scotland) Act 2000.  Following extensive consultation with representatives of local communities and other stakeholders, the Hebridean Partnership is now in a position to present our proposal to you.  This is attached, in the appendices.

We warmly welcomed the Government’s recent commitment to marine national parks in, A Partnership for a Better Scotland: Partnership Agreement: -

“We will consult on the best strategy for protecting and enhancing all of Scotland’s coastline, building on existing policies and including the options of establishing a national coastline park and marine national parks, and consideration of current management and rental arrangements for the sea-bed.”

We trust that, in light of this commitment, the Scottish Executive will give very serious consideration to the proposal for a marine national park.  The Hebridean Partnership would welcome a meeting with you to discuss our proposal and how to take it forward.  We would be happy to host a visit to the west coast to enable you to see the situation at first hand.

Yours sincerely

Mark Carter, BSc. DWCF. LBIPP.
Chairman HMNPP.

Attachments:
Appendix one; Proposal to establish a Marine National Park
Appendix two; Hebridean Marine National Park Partnership: Constitution
Appendix three; Summary of HMNPP Questionnaire Survey
Appendix four; HMNPP Publicity Leaflet

Appendix One.

Proposal to Establish a Marine National Park on the West Coast of Scotland

Summary,
The Scottish, mid-west coast is unique for its biodiversity. It is vulnerable to increasing pressures from improved infrastructure and modern high-tech industries, these pressures include fisheries, aquaculture and tourism. There is an urgent need to protect the environment from these new and intensified pressures, but at the same time consideration needs to be given to the small rural communities and the economy in these fragile areas. The establishment of a Marine National Park could address these increasing problems. The Hebridean Marine National Park Partnership has been formally constituted by a group of local people from varied backgrounds, with the aims of protecting the habitats, fauna and flora, and promoting environmentally friendly, sustainable use of the seas within the proposed Marine National Park area.

Introduction,
The Hebridean Marine National Park Partnership was formed on the 2nd September 2002 and the Constitution (appendix two) was formally adopted at the inaugural meeting. The committee is comprised of people from a varied background from within the community and includes representatives from the fishing industry, aquaculture, tourism, business and the general public.

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.
• To promote educational programmes for schools, communities and commercial sectors.
• To establish a Marine National Park under the National Parks Scotland Act 2000.

Location,
The location of the proposed park lies between the following lines of latitude: 56˚∙05′N and 57˚∙05′N and the following lines of longitude: 005˚W and 007˚W.  (Map of the proposed area please see publicity leaflet; appendix four).
It includes Mallaig and the Isles of Rum and Canna to the North. The islands of Coll and Tiree to the West. The Gulf of Corryvreckan (between Jura and Scarba) and Crinan to the South. Oban and Fort William are the main towns to the East. The area incorporates all of the sea lochs and watershed.

The region is subjected to several oceanic currents, the relatively warm influence from the North Atlantic Drift and the cold Arctic currents combine with nutrient rich up-welling waters. As a result the location is frequented by species both at their most northern and southern geographical limit. The morphology, coastal exposure and extreme tidal flows contribute to this exceptional area. Habitats include: - maerl beds, Serpulid reefs, mudflats, saltmarsh and machair. Each of these varied habitats supports a wide range of differing fauna and flora.

Problems arising due to the location and industry include: - The west coast is within easy reach of several major cities and is prone to a large influx of visitors. As fishing effort is reduced in the North Sea, additional pressures will be brought to the west coast. The aquaculture industry is actively attempting to become more efficient at the cost of local employment and the development of huge installations.

Work by the Partnership to date,
The committee, general members and interested parties have an immense knowledge of the area and the habitats and species found within. They are also aware that the area cannot sustain the current or expected additional usage. The Partnership compiled a questionnaire (appendix three), this was sent to Community Councils, local Councillors, and schools (throughout the Argyll and Bute, Highland and selected Western Isles regions). The questionnaire was also sent to organisations, businesses, and associations (including those from the fishing and aquaculture industries).
Coverage of the proposed park has been in the local papers and national papers; the Partnership produced a leaflet (appendix four), which has been distributed throughout the region. Community and local business involvement is paramount to this proposal and the Partnership’s first newsletter will be produced by the end of the summer period, with the view to providing current up-dates and the findings of the questionnaire.

Conclusion,
A Marine National Park will provide a single responsible body to oversee and regulate/coordinate with existing government departments. Thereby over coming some of the difficulties, experienced by the existing government departments. With the correct approach and educational programs, the users, observers and stakeholders will develop a greater understanding for the environment. This principle has already been experienced by the Partnership and reduces the need for policing.

The development of a Marine National Park could bring many benefits to the proposed park area, especially to the more remote rural communities. These benefits include: increased fish stocks and sustainable fisheries, increased tourism and an increase in revenue to the tourist related industries, whilst protecting vulnerable habitats and species. Development of a Marine National Park would also show compliance with the current European Directives and fulfil the current government manifesto.

The Hebridean Marine National Park Partnership is a community-based proposal. By working together, locals, organisations and government: the development of a Marine National Park would be a success and an asset to Scotland.

This proposal is submitted on behalf of the Hebridean Marine National Park Partnership. For further information please contact the Partnership Chairman: -

Mark Carter, BSc. DWCF, LBIPP.
Kinvara, Bonawe, Oban. PA37 1RL.
E-mail: hebridean.partnership@virgin.net
Appendix Two.

Hebridean Marine National Park Partnership

Constitution.

Approved and adopted at the Inaugural Meeting held on 2nd September 2002.

1. Name.

The organisation shall be called the “Hebridean Marine National Park Partnership”. Referred to as the “Partnership” in this constitution document.

• Location.

The area of the Park includes: Mallaig and the Small Isles to the North, Coll and Tiree to the West. The Gulf of Corryvreckan and Crinan to the South, Oban and Fort William to the East. It includes all of the sea lochs within the area and the “watershed” area that drains into the Park.

3. Aims.

To protect the habitats, fauna and flora within the Park area.

To promote and encourage environmentally friendly, sustainable use of the seas and land within the Park area and those that surround the Park area.

To promote educational programmes: to schools, communities and commercial sectors to enhance the aims of the Partnership.

Establish and maintain a Marine National Park under the National Parks Scotland Act 2000.

4. The Partnership.

The Partnership is open to all members of the community, resident or non-resident within the Park area.

The Partnership is open to all organisations, located within or out of the Park area.

The Partnership is open to all business and companies, located within or out of the Park area.

5. General Meetings.

The Partnership shall hold an Annual General Meeting (AGM) in each calendar year. Extraordinary General Meetings (EGM) shall be held when required.

Twenty-eight days notice of General Meetings shall be given to Partnership members with voting rights. Public notice will be issued, if practicable. 

Partnership voting rights: Any member wishing to vote at a General Meeting must have completed a voting registration form and submitted it, fully completed to the Secretary no less than twenty-eight days before a General Meeting.

Partnership voting rights; businesses, companies and organisations (entitlement: one vote each) wishing to vote at a General Meeting must have completed a voting registration form and submitted it, fully completed, stating the name of their representative to the Secretary no less than twenty-eight days before a General Meeting.

All proposed motions at a General Meeting shall be in writing and must be seconded.

• Office Bearers.

There shall be a Chairman (Mister/Madam), Vice-Chairman (Mister/Madam), Secretary and Treasurer. These positions are for a two-year period. The Chairman/Secretary and the Vice-Chairman/Treasurer on alternate years. Providing a continuity of two officers. An outgoing officer may be re-elected.

• The Committee.

The Committee shall consist of the Office Bearers and as many committee members as decided by the AGM (six general members being ideal).

Committee members shall be elected at the AGM by a simple majority of those present.

The Committee may co-opt people onto the committee when required between AGM’s.

• Proceedings of the Committee.

The Committee shall manage all general affairs of the Partnership.

The Committee may make and amend rules as necessary for the well being of the Partnership. These would be subject to the approval of the next General Meeting.

The Committee may meet as often as it may determine for the welfare of the Partnership but at least once every three calendar months.

The Committee shall meet on the request of the Chairman or of any three members of the Committee.

The Secretary shall give at least seven days notice, in writing if possible, of every meeting of the Committee, stating the agenda. Unless, urgent circumstances require shorter notice.

Accurate minutes of all meetings shall be made by the Secretary or in the absence of the Secretary, any committee member appointed by the Committee.

All matters shall be decided by a simple majority of the members present in accordance with the agreed method at the meeting of the Committee.

There shall preside at any Committee meeting the Chairman or in the absence of the Chairman the Vice-Chairman or any committee member appointed by the Committee.

The quorum at a meeting of the Committee shall be five; at least two shall be Office Bearers. The Chairman shall only have a casting vote.

The Committee may invite “interested parties” to the Committee but they cannot vote at committee meetings.

• Special Committees.

The Committee may appoint a Special Committee as required in the interests of the Partnership or Park. The Committee may also determine their terms of reference, powers, duration and composition; subject to their approval at the next General Meeting.

Special Committees shall at all times be answerable to and make regular reports to the Committee.

All Special Committees shall have the Chairman or Vice-Chairman or a committee member appointed by the Committee presiding.

• Finance.

The financial year of the Partnership shall be from 1st September to 31st August.

The Committee shall control the ordinary expenditure of the Partnership subject to the approval and direction of any General Meeting. No liability shall be incurred or any payment made without the Committees prior approval.

The Partnership shall maintain a bank/building society account in the name of the Partnership and all cheques shall be signed by: - the Treasurer and any one of the remaining Office Bearers. In extenuating circumstances cheques may be signed by any two Office Bearers, in which case the Treasurer shall be notified as soon as is practicable.

The Committee shall keep true accounts of all monies, assets and liabilities concerning the Partnership.

Prior to the AGM, the Treasurer shall submit the accounts to an independent examination (or to an examination as determined by the current legislation). An appropriate independent examiner will be elected at the previous AGM.

A certified statement of the Partnerships accounts that comply with the current legislation shall be produced at the AGM.

The Treasurer will lay before the Committee an up to date extract of the Partnerships accounts, a minimum of once every three calendar months.

• Funds and Assets.

All funds and assets belonging to the Partnership shall be applied to the promotion of the aims of the Partnership.

• Dissolution.

The Partnership may only be dissolved by a resolution passed by a majority of not less than two-thirds of voting members at an EGM called for this purpose.

In the event of dissolution the funds and assets of the Partnership remaining after satisfaction of all its debts and liabilities shall not be divided between the remaining members. The remaining funds and assets shall be donated to an organisation(s) of similar standing, decided at the EGM.

• Misconduct and Expulsion.

Non-compliance of the constitution or any conduct prejudicial to the interests of the Partnership or Park may on a resolution passed by a majority of not less than two-thirds of the Committee result in suspension or expulsion from the Partnership.

Any aggrieved parties may make a written appeal to the next General Meeting.

• Resignation.

Any resignation from the Partnership must be in writing to the Secretary.

• Alterations to the Constitution.

The Constitution may not be altered except on a resolution passed by a majority of not less than two-thirds of the Partnership present at a General Meeting.

A resolution for the alteration of the Constitution must be received in writing by the Secretary at least twenty-eight days before the General Meeting at which the resolution is to be considered. Such a resolution will include in writing notice of the alterations proposed to the Constitution.

Appendix Three.

Summary: HMNPP Questionnaire Survey Results.

The Hebridean Marine National Park Partnership designed and distributed a questionnaire to community councils, local councillors, relevant MSP’s, schools, relevant professionals, local organisations and businesses, relevant NGO’s and Associations. The questionnaire was designed to assess knowledge and opinion without introducing any bias.

The response to the postal questionnaire and HMNPP publicity leaflet (appendix four) approached 10% (National average response for this type of survey is 1%). The replies included, people and organisations who wish to be kept informed of progress and those who completed questionnaires. Of the completed questionnaires, 67% were for the establishment of a Marine National Park: of which 30% were for a Marine National Park with no concerns and 37% were for a Marine National Park with some reservations. 25% had no opinion regarding a Marine National Park, a proportion of which, thought that, “Something, has to be done”, but were unsure what form future developments should take. 

The questionnaire consisted of five sections as follows:

• Do you consider a habitat or species to be vulnerable in your area? (Please give examples).
• What do you think could be done to assist the habitat or species?
• How do you see a Marine National Park being of being of benefit to you or your area?
• What concerns would you have about a Marine National Park in or close to your area?
• Any additional comments.

A selection of responses from the survey follows, these have been categorised as benefits, concerns, specific problems and suggested solutions and additional comments. They are quoted where possible, or paraphrased for ease of reading.

Benefits.

It could be the main driving force to improve the marine environment, maintain biodiversity and enhance the quality of life. It may protect habitats and wildlife in the area.

The establishment of a Marine National Park in the Inner Hebrides would be overwhelmingly positive for the economy of the region. It would also probably be very constructive for the conservation of the marine environment, which should be the main factor driving the strategy.
It could give the appropriate legislative framework to protect the marine environment; and the framework to encourage sustainable use and development of the marine resources.

It would be a good starting point if it truly allows individuals to have a say in what happens to the marine environment and encourages them to take responsibility for it.

It will get people involved and committed to protect their wildlife and help get them to feel “ownership” of their own marine resources. It would help in the sustainability of fisheries.

It could raise the profile of an area where conservation is practiced in the true form of the word and raise the awareness of importance of conservation in the park and increase visitor numbers and provide extra jobs e.g. wardens.

The park could increase publicity and tourism to help the local economy. Ecotourism should be encouraged to provide an over view of the flora and fauna of the whole area, not just the small areas covered by the local tourist information office. Education would raise awareness of the importance of biodiversity conservation and the profile of the fragile nature of the marine environment.

Concerns.

Consultations must full and thorough, anybody attempting to create a marine national park must be 100% transparent about its aims. The local population need to be involved in the entire planning process of a national park. Not involving local communities sufficiently would cause resentment. Concern over additional regulations and bureaucracy from a “top down” designation with no community “ownership”. Control might be dictatorial by either, local politicians with narrow local interest or park authorities unwilling to consult and involve residents.

Danger of marine preservation rather than controlled development within conservation parameters. The park might cause the possible creation of a tourist “honey pot” with detrimental environmental consequences. “If nothing is done the fishing industry is doomed anyway”. Concerns re: affecting the livelihood of inshore fishermen. We are concerned that it will be viewed as a means to stop development of the aquaculture industry and in some quarters a tool for removing fish farms from the area altogether.

One returned questionnaire stated that humans were the vulnerable species and included that we should get rid of the scientists and conservationists. It went on saying that we already had too many SPA’s, SSSI’s, SAC’s etc. Close all SNH offices and departments. And that they should be reimbursed due to restrictions.

Specific problems and suggested solutions.

A marine national park status could help protect all habitats and species. General solutions and suggestions include a code of conduct for both residents and visitors, and improved awareness of the ecosystem and biodiversity of the area. To highlight sensitive and delicate areas, establish a forum to consider overall implications of human economic activities.

In certain areas water quality is seen to be a problem. Specific areas are subject to immense pressures by commercial fishermen and aquaculture. Educational programmes would raise awareness of importance of local habitats and species, and the restriction in vulnerable areas to more conservation orientated fishing methods such as the use of creels and diving.

Suggestion of building on existing sites, rather than new unspoilt areas. Shipping routes and oil spillage are of concern and could be prevented with a ban on big tankers close to the inshore areas.

Seals and other species are being shot and drowned by fish farms, a call to ban fish farms from harming such species, including a ban on acoustic deterrents at the entrance of lochs and rivers.

Lists of vulnerable species included: - minke whales, porpoise, otters, birds of prey, other birds, including gannets, gulls, puffins and terns. Invertebrates such as shellfish, freshwater pearl and fan shell; Atrina fragilis. Concern was mentioned for the maerl beds and serpulid reefs. Emphasis is required on species/habitat protection with greater resources put into management and enforcement of protected areas/species.

Shallow clear water benthic communities are threatened by aquaculture and fisheries (through trawling and dredging). We could identify and protect vulnerable sites (in addition to existing SSSI’s SAC’s etc), and use management plans with stakeholders.

One response from children from a Primary school stated that, “Fishermen are catching too many haddock and cod”. Their comment on how to improve the situation: “Don’t catch as many”.

Commercially targeted species and associated by-catch/discard were listed as being at risk. Suggested solutions include: - Sustainable fisheries management, involving all fishermen and more developmental control. Community ownership with no-take zones.
Gear restrictions, including mono (and bi) filament nets and long-line fishing.
No catch areas. Sensible fishing controls, with distinction for spawning grounds.

Benthic habitats are increasingly vulnerable to damage from trawling (rock hopper nets) and dredging. Suggestions made include: Establish fixed gear reserves in sensitive areas. Closure of areas and limitations on fishing effort. Ban commercial fishing and encourage fish farms to lower prices. Reintroduction of a ban on mobile fishing gear i.e. no dredges within a three mile offshore limit.

Aquaculture. Problems include: - Farmed escapees mixing with wild salmon and trout stocks, altering the gene pool. Disease and parasites spreading to wild populations and other areas. Effect of sea-lice treatment chemicals on non-target marine copepods and larvae. Organic wastes from excess food and fish waste. Solutions include: Moratorium on salmon farming, strict controls and limitation to fish farming development. Cooperation of the fish farm industry and an aquaculture free zone.

Additional comments.

The west coast is a Mecca for sea kayaking, drawing people into the area with minimal impact. A sustainable recreation that can bring economic benefit to marginal coastal communities.

Many yachtsmen are keen environmentalists or at least interested in wildlife, information from a marine national park would be most welcome.

The land and islands should be included in the scenario. One person would like to see a locally based school or institute. Concern due to over influence of the fishing lobby in relation to economic importance. Failure to account for the environmental impact of aquaculture.

Comments also included the following:
GOOD LUCK. I’m fully supportive. The SCA would fully support the proposal for a marine national park. Can the area be extended? This concept has much merit. No concerns – something has to be done. Happy to see matters on the move. WELL DONE!!!

Conclusion.

The results of this survey reflect the general opinions of the vast majority of people spoken to. There is a very real need for “something” to be done. It is also paramount that local people must have a say and be involved in the management process, whatever the future direction for marine concerns.

Financial consideration to existing businesses is a very important issue which must be addressed, although in reality the actual numbers of those adversely affected will be low. There is a concern due to the over influence of the fishing lobby in relation to economic importance and a failure to account for the environmental impact of fishing and aquaculture industries.

The potential benefits of a Marine National Park should far out weigh any negative issues. However, an open and an informative approach is of vital importance to the success of any future developments.