Rose House Circular Road Douglas ISLE OF MAN IM1 1AZ PORT ERIN CABLE REEF PROPOSAL Summary of responses to the consultation 30th July 2009 The enclosed summary of views received as part of the consultation process is not exhaustive, and does not comment on every individual question raised by those responding to the Department. It is intended to be an impartial summary of the main issues raised. Responses by the Department are made in italics.
CABLE REEF CONSULTATION: REVIEW OF RESPONSES AND INITIAL RECOMMENDATIONS Number of proposals sent out in June 2009: Academics/ Education / Consultants: 23 Government: 57 Fisheries (Anglers, Divers, Hobby Fishing, Fishing Vessel Owners, Sea Food and Sailing): 114 Conservation/Environment: 35 Community (inc community groups): 14 Commissioners: 22 TOTAL: 265 Number of responses received (17 th July 2009 deadline): Academics/ Education/ Consultants: 4 Government: 8 Fisheries: 4 Conservation/Environment: 6 Community: 7 Commissioners: 8 TOTAL: 37 (14% response rate) Summary of Responses The vast majority of respondents, 29 out of 37, were either strongly in favour, or in favour, of the proposals with some reservations. 4 respondents made no comment, and 4 respondents had major concerns with, or objections to, the proposal. Many of the positive responses suggested that the scale of the trial could be much larger, or that a number of other areas could be included in the trial.
The reservations expressed included comment on the potential environmental impact of the trial, perceived problems with the scientific design, and the potential hazard of placing these structures on the seabed. These will be discussed specifically below. Concerns Environmental Impact Early removal A number of commentators requested that the trial be halted immediately, if significant adverse environmental impacts were detected. The point was made several times that the trial should concentrate on evaluating benefits of these structures, and not simply be a way to licence dumping at sea. DAFF would require removal of these structures is significant adverse environmental impacts are seen. BT has confirmed that if requested by DAFF they would fund an early end to the project, with disposal of the structures in a licensed land fill site. Heavy Metal Poisoning Several respondents expressed concern about the potential leaching of either zinc or copper from the structures. Several request were made that cut ends of the cable be sealed, to reduce the possibility of a negative impact, as well as monitoring of the seawater to see if leaching was occurring. The amount of copper within the cable is very small- up to 160g per metre of cable. A typical 10 metre yacht will apply about 10kg of copper oxide based antifouling paint every year. The copper oxide reacts much more rapidly with seawater than the pure metal. Additionally, the copper is right in the centre of the cable, protected by thick polythene insulation which will have a lifetime of hundreds of years. In the trials commissioned by DAFF, short sections of cut cable in small seawater containers showed no measurable release of copper even after 6 months. The copper in the cable is not exposed to the marine environment and even if it were would not dissolve and thus be unlikely to have any measureable impact. The strength of tidal flows, and small volume of copper exposed to seawater, would make monitoring of copper levels within the area unfeasible. Tests on new cables, undertaken for DAFF by Southampton and Bangor Universities, indicated that there was some leaching of zinc in the initial stages of the trial, but that this dropped quickly after emersion. The structures to be used in this trial will be made from redundant cable that has been recovered from the sea, and the levels of leaching from these cables are expected to be very low. DAFF will however investigate the feasibility of sealing the cut ends of the cables prior to immersion. DAFF have also asked Southampton University to monitor the potential for Polyaromatic Hydrocarbons (PAH), found in the bitumen coating the cables, to enter the food chain. Animals grazing on the cables, such as sea urchins, will be collected and their bodies analysed for PAH content as part of the monitoring work.
Impact on the Scallop Population Two respondents expressed concern about the potential impact of the trial on the scallop population in the area, both through changes to the physical environment, and to an increase in habitat attractive to predators. One respondent suggested that other areas, of less importance to the scallop fishery, be used for this trial. The closed area is of crucial importance to the Island s scallop fishery. Monitoring of scallop densities within the area has taken place since the area was closed to fishing, and will continue. Additional monitoring of scallops close to the reefs, and in a similar control area, will be undertaken during this trial. As a precaution, the trial will not be placed on the areas of highest scallop density within the Closed Area. As with any other negative impact, if a significant threat to the scallop population is detected, DAFF will be able to ensure that BT remove the structures for disposal in landfill. There are not funds to site additional trials in Douglas Bay closed area. It would be extremely difficult for DAFF to obtain the approval from the Government s insurer to place these structures where fishing with mobile gears was permitted, and where we would have much less data on the seabed flora and fauna than is the case for Port Erin Closed Aea. Tidal Scouring Two concerns relating to tidal scouring were raised: that scouring would rapidly erode the structures themselves, causing them to collapse, and that seabed erosion would occur, possibly with damaging environmental consequences. There is little evidence from cable reefs in the USA that tidal scouring has lead to erosion of cables. However, this will be monitored. There is also little evidence of any significant scouring resulting from the mooring blocks that have been placed on the borders of the closed area for over a decade. However, this too will be monitored during the project. Scientific Design A number of very helpful, and in some cases very detailed, criticisms of the scientific design of the trial were made, along with suggestions to improve the scientific value of the trial. Concerns included the numbers of replicates, the effects of tidal shadowing on the structures and the type of controls structure. These have been passed on to the academic team at Southampton University, and DAFF expects to agree revisions to the proposed trial design once the Department has discussed this in detail with them. It is clear that a great deal of thought had gone into some of the replies received, and DAFF is grateful to respondents for their assistance with this. Other Potential for snagging fishing gear or divers Several respondents cited the risk of the structures snagging fishing gear or posing a threat to divers. Fishing with mobile gears and gill nets is already illegal within this area. There is a risk that pots fished on the structures could become snagged, as with potting in areas with rocky gullies or similar natural obstructions, although fishermen will be able to avoid the structures fairly easily- they will
show up clearly on echo sounders, and will be marked with buoys. The structures will be built so that it is impossible for divers to enter them. Size and scale of the trial should be much larger Several respondents asked that a more ambitious, larger scale trial be put in place. A larger scale trial would enable the Department to more effectively monitor the benefits and impacts of a reef. However, the costs of extending this work would be considerable, and the scale of any negative impact seen would also be correspondingly greater. The results of this project may well assist in future deliberations about a potential artificial reef in European waters. Any No take zone will affect angling interests - There is no intention that this exercise will lead to a no take zone for anglers in the closed area as a whole. DAFF would like the trial structures to be free of angling whilst colonisation of the structures is monitored, but there would be an expectation that the structures, if left in place, would then be opened up to fishing. The involvement of anglers fishing within Port Erin closed area, through keeping detailed catch records that could be passed to scientists involved in the monitoring, could be very helpful. Community involvement. A number of individuals have requested that this consultation should allow for feedback between DAFF and those with an interest in the proposal. DAFF will invite Southampton University to attend an open meeting in Port Erin, in advance of any structures being placed on the seabed, to discuss the potential for involving local divers and anglers in ongoing monitoring, further mitigation of any potential impacts, and the precise siting of the structures. Siting- shallow water is better for divers, siting should be shallower than 25m to allow kelp to colonise the structures DAFF accept that community involvement will be greater if divers can easily access the site. As well as avoiding areas of highest scallop concentration, the Department will aim to site these structures in no more than 25m of water at ELWS.