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                                              Conservation without Frontiers

Marine Bill Team                                                           From:
Department for Environment, Food
and Rural Affairs                                                     PO Box 10
Area 2C                                                                Fishguard
Nobel House                                                           SA65 9LR
17 Smith Square                                               Tel: 01348 875389
London SW1P 3JR

24 June 2008

Dear Sir/Madam


1. The Coastal and Marine Working Group of Europarc Atlantic Isles
   appreciates the opportunity to comment on the draft of the Marine Bill.
   Overall it welcomes the proposals for the introduction of a system of
   marine planning and marine conservation zones. However, the Group has
   one major concern – how will the national importance of seascapes,
   including the marine dimension of our coastal landscapes, be recognised
   in the proposed system of marine planning?

2. The Group has concluded that:

       i.   A mechanism needs to be created to enable the national
            recognition of the marine dimension of our nationally important
            coastal landscapes and seascapes; and

       ii. in the absence of a means of formally recognising the national
           importance of these areas, it is not clear how the marine planning
           system proposed in the Bill can take into account their national

3. In this context it is important to stress that the term “seascape” is used as
   an umbrella, embracing not only the visual but also the wildlife, cultural,
   historic and recreational resources.

Background to Europarc Atlantic Isles and its Coastal and Marine
Working Group

4. The EUROPARC Federation – the Federation of Nature and National
   Parks of Europe – brings together a wide range of organisations and
   individuals involved in the policy and practice of managing parks and
   protected areas. Its members represent well over 300 nationally protected
   areas in 35 European countries. The EUROPARC Federation aims to
   raise awareness of and support for protected areas and to promote good
   management practices among them. Its overall purpose is to promote
   „conservation without frontiers‟. Through its activities, it seeks to
   establish itself as the “voice of parks and other protected areas in

5. EUROPARC Atlantic Isles is a Section of the EUROPARC Federation. It
   has an expanding membership of over 60 organisations who bring with
   them a wealth of practical experience, from national parks, regional parks,
   areas of outstanding natural beauty, local authorities, academic
   institutions, government agencies and non-governmental organisations. It
   is the only organisation to have such a comprehensive resource network
   spread across the United Kingdom, the Republic of Ireland and Iceland,
   and linking into the rest of Europe. The general purposes of the Atlantic
   Isles Section of EUROPARC are the same as those of the EUROPARC
   Federation, but with a specific focus upon the Section‟s member nations
   and protected areas.

6. In 2005 the Europarc Atlantic Isles [EAI] Committee set up a Coastal and
   Marine Working Group in recognition of the need to consider the many
   issues for coastal protected landscapes posed by the current discussion
   on the planning and management of the coastal and marine environment.
   Its membership is drawn from the UK, Iceland and Ireland, including
   National Parks and AONBs, the National Government Advisers, NGOs
   and the National Association for AONBs. The latter wishes to be formally
   associated with this submission. The work of the Group has focused on
   making the connection between land and sea in the context of coastal
   protected landscapes [AONBs, National Parks and Heritage Coasts].

Coastal Protected Landscapes

7. The map of protected landscapes in the UK at Annex 1 shows the
   significant geographical extent of protected landscapes – National Parks,
   Areas of Outstanding Natural Beauty and Heritage Coasts – around the
   coast of England, Northern Ireland and Wales. They are all land-based,
   with their seaward boundaries at the mean low water mark [MLWM].The
   table at Annex 2 lists all those areas. The submission does not address
   issues in Scotland as separate legislation is being prepared by the
   Scottish Executive and they already have the power to create coastal and
   marine national parks.

The Marine Dimension of Coastal Protected Landscapes

8. There are some coastal protected landscapes where the close relationship
   with the marine environment has been crucial to their designation. For
   example: in England, AONBs such as the Isles of Scilly, Cornwall, North
   Devon, Chichester Harbour, Norfolk Coast, Northumberland Coast,
   Solway Coast and Arnside & Silverdale; in Wales, the Pembrokeshire
   Coast National Park and the Anglesey, Llŷn and Gower AONBs; and in
   Northern Ireland the Antrim Coast & Glens, Causeway Coast and
   Strangford AONBs.

9. Others, designated for the importance of their inland landscapes, also
   have very important coastlines. For example, in England, AONBs such as
   East and South Devon, Dorset, Sussex Downs, Suffolk Coast and Heaths
   and Mourne in Northern Ireland; and English National Parks such as
   Exmoor, New Forest and North York Moors.

10. Yet others have only small but highly significant stretches of coast such as
    the High Weald, Kent Downs and Tamar Tavy AONBs and the Lake
    District National Park.

11. The variety of coastal scene and of the character of the boundary between
    land and sea is enormous, ranging from hard rocky cliffs with occasional
    sandy coves; to offshore islands; low soft cliffs and sand dunes, with
    extensive beaches at low tide; estuaries, often with extensive intertidal
    areas; historic towns, villages and harbours; and numerous combinations
    of these features.

12. The special qualities of these coastal protected landscapes are derived in
    no small way from their intimate relationship with the marine environment.
    The connections are many and diverse, with social and economic as well
    as environmental dimensions:

      the special landscape/seascape qualities are derived from the many
       moods of the sea, the wide open vistas and feeling of wilderness

      the great majority of these areas are bounded by waters recognised as
       nationally and internationally important for their wildlife [see Table in
       Annex 2]; in many cases there are strong connections between land
       and sea, for example sea birds nesting on land and feeding at sea and
       seals resting and pupping on beaches

      the natural processes in the marine environment [erosion, deposition
       and sediment transport] impact on the form of these coasts and
       provide spectacular scenery

      there are strong cultural and historic ties between these areas and the
       adjacent marine environment e.g. they are often a source of inspiration
       for artists

      the popularity of these areas for visitors and recreational use depends
       on the retention of the diverse and high quality environment that exists
       - this is especially significant in the context of the proposals for coastal
       access set out in the Bill

      the high quality of the water underpins all these special qualities

      significant economic benefit is derived by local communities from the
       intimate relationship between land and sea, not least in the tourism

National Recognition of this Marine Dimension

13. There is no means of recognising the national importance of the marine
    dimension of these coastal protected landscapes. The current system of
    planning and management of coastal protected landscapes is not
    integrated with the marine environment. There is an artificial divide
    between land and sea, with no recognition of the continuum between
    them, which is so important for our coastal protected landscapes. The
    statutory management plans and development plans for these areas stop
    at the mean low water mark, thus rendering them incapable of use for
    planning and managing the special qualities derived from the marine

14. The question of whether or not it would be appropriate to include the
    marine environment within a National Park was considered in some depth
    during the Inquiry into the Proposed South Downs National Park [PSDNP].
    The Inspector, in his report to the Secretary of State in 2007, concluded

       “I am not convinced, therefore, that there is a legal basis for including marine
       areas beyond MLWM in the PSDNP”

   He went on to say that:

       “I derive no pleasure from this conclusion. The evidence submitted by the
       SDC and other objectors on this matter reveals that much of the marine
       environment beyond MLWM is of considerable importance…….The available
       evidence convinces me that the PSDNP would be enhanced if it was legally
       possible for the marine environment to be included.”

   He noted that the then Countryside Agency did not dissent and that it did
   not dispute that:

       “the intrinsic qualities of the marine area identified by the SDC and others
       could satisfy the statutory natural beauty and recreational opportunities
       criteria” [for designating national parks].

   He went on to recommend to the Secretary of State that

       “consideration be given to statutory provisions that would allow marine areas
       beyond MLWM to be part of a National Park.”

15. The recommendation has yet to be considered by the Secretary of State
    because the Inquiry into the proposed designation has been re-opened.
    Nonetheless the recommendation is significant in its recognition of the
    importance of the marine dimension of a coastal protected landscape and
    that it stems from debate in a Public Inquiry. The draft Bill provides an
    opportunity to address this issue.

The Draft Bill and Coastal Protected Landscapes

16. The Working Group considers that the draft Bill is an important opportunity
    to secure the connection between these coastal protected landscapes and
    their marine dimension. As drafted, the draft Bill is silent on these matters.
    There is no mention of “seascapes” in the grounds for designating Marine
    Conservation Zones [MCZs]. They relate only to marine flora and fauna,
    habitats and features of geological or geomorphological interest.

17. In the Marine Bill Consultation document of March 2006, Defra had
    indicated that

       “10.53 We are proposing to establish a mechanism that can conserve and
              promote the recovery of:

              a   vulnerable species and habitats;
              b   representative species and habitats;
              c   physical marine features and ecological processes.

       10.54 The mechanism could potentially protect;

              d   physical features of geological or geomorphological interest;
              e   historic sites [including wrecks, ancient landscapes and other
                  marine historic assets];
              f   important seascapes and views from land;
              g   spawning and nursery areas [migration routes and other areas that
                  are important for the protection of commercial fish stocks;
              h   areas for marine ecosystem research or educational purposes.”

   The response to the question “Which of the purposes listed should the
   new mechanism cover?” revealed that 47% of the 108 responses stated
   that the new mechanism should cover all the purposes [a – h above]
   including important seascapes and views from land – a significant
   indication of the need to recognise formally these nationally important

18. However, the Marine Bill White Paper in 2007 narrowed the purposes for
    MCZs to nature conservation and indicated that:

       “Important seascapes and views from land would be considered within the
       marine planning process [which will be more appropriate to their large scale].
       The UK marine policy statement could include objectives describing the

       importance of seascapes and views and how we wish to treat them. More
       detailed plans would allow us to consider seascapes and views in the context
       of the priorities for specific areas.” [para 6.35]

   In the absence of the Marine Policy Statement it is not clear how
   „seascapes‟ are to be dealt with in the planning process. The Bill is silent
   on this.

19. Whilst it will be very important for the conservation of seascapes and
    views from land to be addressed in the Marine Plan process, the absence
    of any mechanism for defining our nationally important seascapes and for
    recognising the seaward extent of our coastal protected landscapes is a
    fundamental weakness of the marine planning system proposed in the Bill.

20. On the one hand, the national importance of marine flora and fauna will be
    recognised in statute through the designation of MCZs and certain aspects
    of the maritime heritage will be covered in the forthcoming Heritage Bill, so
    will therefore have a clear place in the planning process. On the other
    hand our nationally important seascapes, including the marine dimension
    of our coastal protected landscapes, will have no statutory means of
    recognition and will have no formal place in the planning process – for
    policies in the Marine Policy Statement and in the marine plans to be
    effective they must have something tangible like a designated area to refer

21. Just as our finest terrestrial landscapes are designated as National Parks
    and AONBs, so our finest seascapes, including the marine dimension of
    our coastal protected landscapes, should have similar statutory
    recognition, as will other aspects of our marine heritage. It is essential that
    the framework for the planning and management of the marine
    environment that is being put in place through the Marine Bill includes a
    statutory mechanism for their national recognition and for their national
    importance to be fully taken into account in all decision making. Without
    this national recognition, the special qualities of our finest coastal
    landscapes could be put at risk from inappropriate development.

Yours faithfully

Edward Holdaway
Edward Holdaway
Coastal & Marine Working Group
Europarc Atlantic Isles

                                             ANNEX 1


                                                                 ANNEX 2


    COASTAL PROTECTED                         SAC
        LANDSCAPES                  with marine component ##

Lake District              Drigg Coast
                           Morecambe Bay
New Forest                 Solent Maritime
North York Moors

Arnside Silverdale         Morecambe Bay
Chichester Harbour         Solent Maritime
Cornwall                   Fal & Helford
                           Plymouth Sound and Estuaries
Dorset                     Chesil Beach & Fleet
                           Isle of Portland to Studland Cliffs
                           Sidmouth to West Bay
East Devon                 Sidmouth to West Bay
High Weald
Isles of Scilly            Isles of Scilly Complex
Isle of Wight              South Wight Maritime
                           Solent Maritime
Kent Downs
Norfolk Coast              North Norfolk Coast
                           Wash & North Norfolk Coast
Northumberland Coast       Berwickshire & Northumberland Coast
North Devon                Braunton Burrows
Quantock Hills
Solway Coast               Solway Firth
South Devon                Plymouth Sound & Estuaries
Suffolk Coast and Heaths   Alde, Ore & Butley Estuaries
                           Minsmere to Walbersick Heaths & Marshes
                           Orfordness - Shingle Street
Sussex Downs
Tamar Valley               Plymouth Sound & Estuaries

Durham Coast
Flamborough Head           Flamborough Head
Spurn Head                 Humber Estuary
St Bees

Antrim Coast and Glens     Rathin Island
Binevenagh                 Bann Estuary
Causeway Coast             North Antrim Coast
Lecale Coast               Murlough
Mourne                     Murlough
Strangford                 Strangford Lough


Pembrokeshire Coast                     Cardigan Bay
                                        Carmarthen Bay and Estuaries
                                        Pembrokeshire Marine
                                        Limestone Coast of South West Wales

Snowdonia                               Llŷn Peninsula & the Sarnau

Anglesey                                Anglesey Coast: Saltmarsh
                                        Cemlyn Bay
                                        Menai Strait & Conwy Bay
Gower                                   Carmarthen Bay and Estuaries
                                        Limestone Coast of South & West Wales
Llŷn                                    Llŷn Peninsula & the Sarnau

Ceredigion                              Cardigan Bay
Great Orme

Note - # Heritage Coasts outside National Parks & AONBs

Note – ## Source of SAC information JNCC website – SACs with marine components
are those which contain qualifying marine habitats and/or qualifying marine species
under the Habitats Directives. The majority are coastal.


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