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Home , Brixham, East Devon, Lyme Bay

MBA MARINE BIOLOGICAL ASSOCIATION OF THE

MBA Executive Secretary: Dr Matt Frost Registered Office: THE LABORATORY Telephone: 01752 633333 CITADEL HILL Fax No : 01752 633102 Email: [email protected] PL1 2PB Web site: www.mba.ac.uk Director: Professor Colin Brownlee

Kate Little Head of Planning & Countryside East Council Knowle EX10 8HL Via email: [email protected]

26th March 2010 Dear Kate,

REF: 17-01-02. CROWN ESTATE CONSULTATION PROCEDURE FOR MARINE FISH FARMS PROPOSED MARINE SHELLFISH FARM OFFSHORE SHELLFISH LTD –

1. The Marine Biological Association (MBA) is a Learned Society established in 1884. The MBA has about 1000 members and runs The Laboratory in Plymouth where 60 staff work. MBA members have been at the forefront of providing scientific information to support marine environment protection, management and education and much of the scientific information that underpins decision-making about environmental protection has come from work undertaken at the Laboratory.

2. The MBA is a founder member of the Plymouth Marine Sciences Partnership, a federation of seven partners based in Plymouth all of whom tackle different aspects of marine science and technology research and training in a complementary way.

General Comment on application.

3. This is a well constructed document with much in favour of the application, including general government agency support for this type of development.

4. We note that the locations have been determined in discussion with Natural and therefore assume that appropriate searches of available data on seabed biotopes and species present have been taken into account and that none in the proposed locations are of particular marine natural heritage importance. However, reassurance that the proposed locations are not in areas where there is maerl (detached calcified seaweed) (which is reported near the proposed site) in particular would be welcome. If survey data is incomplete or if it is only based on acoustic survey, then seabed imaging surveys using high resolution video should inspect the proposed locations. Such surveys would ‘double’ as a reference to start monitoring.

Registered Charity number 226063 A Company limited by guarantee. Registered in England number 21401 MBA MARINE BIOLOGICAL ASSOCIATION OF THE UNITED KINGDOM

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5. The application involves three large areas (equivalent to one tenth of Lyme Bay)- This scale is, arguably, excessive: perhaps it would be more appropriate to develop one area first to test pitfalls. If no major problems arise the development could proceed with area 2 and then area 3.

6. The most significant issues seem to be associated with:  obstruction to navigation  possible conflict with the community (exclusion zone-displacement of trawling from farm areas 1 and 2)  Proximity of area 3 to the proposed SAC  the issue of sedimentation and unknown water quality issues

7. It is important to consider environmental impact (water quality and other parameters including sediment deposition and associated physicochemical effects) even though there appears to be no statutory requirement for a formal EIA. Voluntary monitoring as specified in the application document will undoubtedly go some way to detecting major environmental change but is unlikely to detect more subtle effects which will require a more rigorous approach. No specific details of the proposed monitoring programme are given.

8. Whilst the structures involved in the development of the mussel farm would indeed increase the range of habitats in the area and potentially attract significant populations of fish sheltering amongst the structures. However, ‘naturalness’ is much valued in terms of biodiversity conservation and unnatural structures are not considered beneficial in terms of conservation. So, will the same consideration apply to the mussel farm as was cited for Scylla – “it will not do any good for biodiversity conservation but it will not do any harm either”?

9. It may be worth noting that there is an excellent opportunity here for a rigorous ‘before and after’ study, and development of monitoring tools for similar applications around the coast (as these appear likely to become more frequent).The MBA has much to offer here.

10. The “continuing program of monitoring indicators of environmental change” (supplementary Supporting Statement, P27) is an important component of the future monitoring for the sites. However, it is noted that this is being done “on a voluntary basis” and no details are given of whether any changes in practice can be enforced if it is found that the site is causing detrimental changes to the marine environment.

11. Funding opportunities should be made available as part of any licensing agreement: a levy analogous with that applied to aggregate dredging operators might be one mechanism for this.

12. There is little reason to believe that the operation would not be beneficial in terms of generating income, jobs, and food resources – and there are few anticipated major environmental issues, (though as indicated above the scheme needs to be monitored with scientific rigour). This includes the question of disposal of associated wastes which appear to be destined for disposal at sea, albeit as a ‘low density stream’ during passage back to .

Registered Charity number 226063 A Company limited by guarantee. Registered in England number 21401 MBA MARINE BIOLOGICAL ASSOCIATION OF THE UNITED KINGDOM

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Dr Bill Langston Associate Fellow of the Marine Biological Association

Dr Keith Hiscock Associate Fellow of the Marine Biological Association

Dr Gerald Boalch Associate Fellow of the Marine Biological Association

Dr Matthew Frost Executive Secretary, Marine Biological Association

Registered Charity number 226063 A Company limited by guarantee. Registered in England number 21401