A Comprehensive 2025 Review of Welsh Government Claims that Industrial Fishing in Welsh Marine Protected Areas (MPAs) Has No Negative Impacts
Recent statements by the Welsh Government, suggesting that a new scientific study has found no negative impacts from fishing on the condition of Marine Protected Areas (MPAs) in Wales, have prompted significant public and political debate. This report provides an exhaustive, evidence-based review of the scientific studies underpinning these claims and delivers a critical assessment of their credibility.
Executive Summary: The analysis reveals a profound disconnect between the political narrative and the scientific reality.
The central claim, that "no assessed habitat or species within the Marine Protected Area network in Wales were found to be in an unfavourable condition due to impacts caused by fishing", is a selective and misleading interpretation of the available evidence.
While a new Natural Resources Wales (NRW) condition assessment does attribute the primary cause of widespread MPA failure to water quality issues, this conclusion is reached through a narrow methodological lens that effectively isolates fishing from other pressures. It does not equate to a finding of "no impact."
The Welsh Government's position is heavily reliant on a single, highly controversial 2015 experiment conducted by Bangor University.
This study concluded that a specific type of seabed habitat in Cardigan Bay, dynamic sands and gravels, was resilient to scallop dredging and recovered rapidly. However, this report finds that elevating this localized and contested finding to a general principle for the entire, diverse Welsh MPA network is a scientifically unjustifiable extrapolation.
Key Judgements
The Welsh Government's Claim is Not Credible
The assertion that fishing is not causing negative impacts in Welsh MPAs is a political communication, not a scientific conclusion. It misrepresents the findings of the government's own agency, ignores a vast body of contradictory global science, and is built upon a foundation of contested and over-extrapolated research.
Welsh MPAs are in Poor Health
The most recent and comprehensive assessment by Natural Resources Wales (2025) shows that the MPA network is in a state of widespread failure, with 55% of assessed features found to be in an "unfavourable condition." The primary cause identified is nutrient pollution from land-based sources.
The Evidence Base is Contested and Narrow
The scientific justification for permitting bottom-towed fishing gear in Welsh MPAs rests almost entirely on the 2015 Bangor University study. This study has faced significant and credible scientific criticism, including the "shifting baseline" hypothesis, which posits that the experiment was conducted on an already-degraded ecosystem. Its findings on rapid recovery are a stark outlier when compared to global meta-analyses.
A Failure of the Precautionary Principle
The Welsh Government's approach inverts the precautionary principle. Instead of requiring proof of no harm before permitting a potentially damaging activity in a protected area, it has used limited evidence of resilience in one habitat type as justification for a permissive policy across the entire network, effectively placing the burden of proof on the environment to demonstrate harm.
Conclusion of Executive Summary
This report concludes that while the individual scientific reports from NRW and Bangor University have merit within their specific and often narrow parameters, their use by the Welsh Government to construct a narrative of benign fishing impacts is not credible. To restore confidence and ensure the effective protection of Wales's marine environment, a fundamental shift is required towards a more precautionary, transparent, and holistic approach to evidence-based management.
Deconstructing the 2025 Welsh MPA Assessment: A Case of Selective Communication
The immediate catalyst for this review is a series of statements made by the Welsh Government in mid-2024 regarding the impact of fishing on its MPA network. These statements have been central to the government's justification for not pursuing a ban on bottom-towed fishing gear, a measure being actively considered in English waters.
In a debate in the Welsh Senedd, Fisheries Minister Huw Irranca-Davies stated that a new study by Natural Resources Wales (NRW) was "critically important" and found that "no assessed habitat or species within the Marine Protected Area network in Wales were found to be in an unfavourable condition due to impacts caused by fishing".
This claim was presented as the primary evidence-based reason for diverging from the policy direction of England's Marine Management Organisation (MMO), which has proposed extensive bans on bottom trawling in its MPAs. The Minister asserted, "the evidence here does not identify such a need".
The Headline Claim and its Contradictory Reality
The political narrative is in direct conflict with the overarching findings of the report to which it refers. The comprehensive "Condition assessments for Welsh European marine sites (EMS)," published by NRW in June 2025, presents a starkly different picture of marine health.

This assessment, described as one of the most extensive in Europe, evaluated 85 designated features across 17 Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). The results were unambiguous: 55% of the assessed features were found to be in an "unfavourable condition".
The report highlights the need for "more action to improve habitat, biodiversity and water quality". This establishes a fundamental contradiction: the MPA network is broadly failing to meet its conservation objectives, yet the government claims a key pressure—fishing—is not a contributing cause.
Attribution of Pressures: A Methodological Interpretation
The resolution to this contradiction lies in the careful phrasing of the Minister's statement, specifically the qualifier "due to impacts caused by fishing." The 2025 NRW assessment methodology allows for the attribution of failure to specific pressures. The reports identify the primary reason for the unfavourable condition of many features as poor water quality, particularly "nutrient pollution, in the form of dissolved inorganic nitrogen (DIN)".
The sources of this pollution are identified as primarily land-based, including diffuse agricultural pollution and discharges from the water industry and private sewage systems.
This methodological separation of pressures provides the government with a powerful communication tool. It allows for the simultaneous acknowledgement of the poor state of the MPAs (thus fulfilling statutory reporting duties) while deflecting responsibility from the fishing industry.
By framing the problem as one of water quality, the political and regulatory focus is shifted upstream to farmers and water companies, sectors already under scrutiny for river pollution. This maneuver creates a "robust evidence-led" justification for maintaining the status quo on fisheries management, thereby protecting the economic interests of the fishing sector and associated coastal communities, which the Minister explicitly cited as a key consideration.
The Narrow Scope of "Fishing Impacts"
The credibility of the claim hinges on how "fishing impacts" are defined and assessed within the NRW framework. A review of international best practices for fisheries management reveals a much broader understanding of such impacts.
US Magnuson-Stevens Act Approach
The US Magnuson-Stevens Act requires the evaluation of all potential adverse effects on "Essential Fish Habitat" (EFH), including not just direct physical damage but also indirect effects on ecosystem functions, prey availability, and the cumulative effects of multiple activities. The framework considers impacts that are "more than minimal and not temporary in nature".
Canadian and European Frameworks
Similarly, Canadian and European frameworks recognize a wide range of threats from fishing, including habitat degradation, overexploitation, bycatch, pollution, and disruption of food webs.
In contrast, the NRW assessment appears to have adopted a narrower definition. By concluding that fishing is not the cause of "unfavourable condition," the assessment likely focused on whether fishing activities were directly preventing specific, designated features from meeting their defined conservation targets.
Overlooked Impacts in the NRW Assessment
Indirect Food Web Effects
The removal of benthic invertebrates or forage fish by trawling, which may not cause a habitat feature like "sandbanks" to fail its condition assessment but could have significant impacts on the protected species (e.g., seabirds, dolphins) that feed on them.
Cumulative Degradation
The chronic, low-level degradation of the seabed that may not push a feature into "unfavourable" status but reduces its overall biodiversity and resilience.
Impacts on Non-designated Features
Trawling affects the entire ecosystem, not just the legally designated features. A focus solely on the latter ignores the broader loss of biodiversity.
Ecosystem Function
The impact of trawling on crucial ecosystem functions like carbon sequestration from marine sediments, a major concern in the global scientific community, is unlikely to be captured in a feature-by-feature condition assessment.
Comparison of Key Welsh Marine Studies and Assessments
The Scientific Precedent: The 2015 Cardigan Bay Scallop Dredging Experiment
To understand the Welsh Government's current policy position, it is essential to analyze the scientific study that has served as its foundation for nearly a decade: the 2015 Bangor University report on scallop dredging in Cardigan Bay.
This study was commissioned by the Welsh Government following a complaint to the European Commission by conservation groups, which led to the emergency closure of the Cardigan Bay SAC to scallop dredging in 2009 due to concerns over impacts on bottlenose dolphins and reef habitats. The study's explicit purpose was to provide the evidence needed to determine if, and under what conditions, the fishery could be reopened.
Methodology: A Large-Scale BACI Experiment
The study, led by researchers from Bangor University's School of Ocean Sciences, employed a Before-After-Control-Impact (BACI) experimental design, which is a standard approach for assessing environmental impacts. The key features of the methodology were:
1
Experimental Site
The experiment was conducted in a large (110 km²) area within the Cardigan Bay SAC that had been closed to scallop dredging since 2009. Crucially, the site was selected after surveys confirmed the absence of sensitive stony reef habitats, a key feature of the SAC. The seabed was characterized as a dynamic environment of mixed sediments, including sand, gravel, and pebbles.
2
Fishing Intensity Gradient
To mimic real-world fishing pressure, the researchers established 17 experimental plots. Four of these were left as unfished "control" sites. The other 13 were subjected to a gradient of fishing intensity by commercial scallop vessels using standard Newhaven-type dredges. The intensity ranged up to a maximum of 6.2 sweeps, meaning the seabed in the most heavily fished plots was trawled, on average, over six times.
3
Data Collection
A comprehensive data collection program was undertaken using the RV Prince Madog. Three distinct surveys were conducted: a "before" survey in March 2014, an "after" survey in May 2014 (immediately following the experimental dredging), and a "recovery" survey in September 2014 (four months later). Data included biological samples of animals living in the sediment (infauna) and on the sediment (epifauna), as well as physical data on the seabed structure from acoustic sonar.
Key Findings: Resilience and Rapid Recovery
The study's conclusions provided a powerful narrative of environmental resilience that has been readily adopted by policymakers.
Immediate Impacts
The experiment successfully detected the immediate effects of dredging. In plots that were swept more than twice, there were clear and statistically significant decreases in the abundance and biomass of seabed organisms, with reductions of 40-60% compared to the control plots. Acoustic surveys also clearly showed physical scour marks and the flattening of sand wave features at the highest fishing intensities.
Rapid Recovery
The most influential finding was the speed of recovery. By the time of the September survey, just four to five months after the dredging, the study found that the biomass and abundance of animal communities in the fished plots were "mostly indistinguishable" from those in the unfished control plots. The authors stated that differences in species composition were "no longer detectable". Physical marks on the seabed were also found to have been largely erased by natural sediment movement within 10-11 months.
Overarching Conclusion
The study concluded that for this specific type of dynamic, mobile sediment habitat, the disturbance from natural events like storms was of a similar magnitude to the disturbance from fishing. It suggested that the seabed could tolerate a certain level of fishing intensity—up to 3.5 sweeps per year in inshore gravel and 6.2 sweeps per year in offshore sand—without compromising the habitat.
This single, targeted experiment produced a clear, quantitative result that was highly attractive to policymakers seeking a "scientific" basis for management. Rather than a blanket ban, the study appeared to offer a pathway to a "sustainable" fishery by defining precise operational thresholds. This specific, actionable conclusion gave the study an outsized influence, allowing the Welsh Government to develop a new management plan for the scallop fishery based on its findings.
A Contested Evidence Base: Scientific and Public Scrutiny
Despite its influence on policy, the 2015 Bangor University study was immediately met with intense scientific criticism and public opposition, creating a deeply contested evidence base that persists to this day. The controversy highlights a classic "battle of narratives" where scientific evidence is framed and deployed to support opposing worldviews.
The most significant scientific challenge to the study's conclusions was articulated by environmental journalist George Monbiot, citing the expert opinion of leading marine scientist Professor Callum Roberts. This critique centers on the concept of a "shifting baseline."
The "Shifting Baseline" Critique
The "Lawn vs. Oak Forest" Analogy
The argument posits that the experiment was conducted on a seabed that was already severely degraded by a long history of scallop dredging and beam trawling, which was legal in the area until 2009. Therefore, the "before" state was not a healthy, pristine ecosystem but a simplified community of opportunistic, "weedy" species already adapted to frequent disturbance. The observed "rapid recovery" was not a return to ecological health, but merely a return to a chronically disturbed, low-biodiversity state. Professor Roberts famously likened this to stopping mowing a lawn for five years and expecting an oak forest; instead, one gets "a scrappy patch of weeds".
The Authors' Rebuttal
The study's authors, led by Professor Michel Kaiser, forcefully rebutted this critique. They argued that the "lawn to oak forest" analogy was flawed because the experimental site is a naturally high-energy, dynamic environment subject to frequent storm-induced disturbance. They contended that such an environment would never support a complex, stable "oak forest"-like community but would naturally be dominated by resilient, opportunistic species. They pointed to the fact that even after a five-year closure, the area had not developed into a more complex habitat, supporting their view that its state was natural rather than an artifact of historical fishing.
Beyond the Benthos: Ignoring the Dolphins
A major point of contention was the study's narrow focus on benthic invertebrates, which critics argued ignored the primary reason for the SAC's designation: its importance for a semi-resident population of bottlenose dolphins.
The Sea Watch Foundation, which has monitored the dolphin population for decades on behalf of NRW, raised serious concerns. Their research indicated that dolphins have strong preferences for specific inshore habitats with mixed substrates and cobble reefs—habitats that were explicitly excluded from the experimental site.
They also noted that the dolphin population had shown a general decline since 2008, coinciding with an intensification of scallop dredging. They therefore cautioned that it was dangerous to extrapolate the findings from the offshore, gravel/pebble experimental site to the entire SAC, particularly the sensitive coastal areas vital for dolphins.
Funding, Peer Review, and the Erosion of Public Trust
Funding Source
A critical detail, seized upon by opponents, was that the experiment was partly funded by the sale of scallops harvested by the commercial vessels participating in the study. While this may have been a pragmatic solution to funding a large-scale experiment, it created a powerful perception of a conflict of interest, undermining the study's claims of impartiality in the eyes of the public and environmental NGOs.
The Government's Strategic Peer Review
In response to the wave of criticism, the Welsh Government commissioned its own peer review of the Bangor study. It selected two international fisheries scientists, Dr. Ian Tuck and Professor Kevin Stokesbury, who both lauded the research. They described it as being of the "Highest Scientific Merit" and meeting the standards of "Best Available Science". This was a clear strategic move to counter the public criticism and legitimize the controversial evidence base upon which the government intended to act.
Public Opposition and a Flawed Consultation
The subsequent public consultation on reopening the fishery was a flashpoint for the controversy. It generated over 5,000 responses, with an overwhelming majority opposing the proposal, alongside a petition with over 27,000 signatures. Many respondents cited the destructive nature of dredging and the flawed science. The consultation process itself was heavily criticized as being structurally biased, with questions framed in a way that made it difficult to register outright opposition, and it was even temporarily suspended due to a technical glitch that switched "no" responses to "yes".
Summary of Arguments For and Against the 2015 Bangor University Study
The Global Scientific Consensus on Bottom-Contact Fishing Impacts
To properly assess the credibility of the Welsh findings, they must be placed in the context of the wider body of international, peer-reviewed science. Decades of research have produced a strong global consensus on the impacts of bottom-contact fishing gear like trawls and dredges. This consensus view provides a crucial scientific baseline against which the exceptionalism claimed for Welsh waters can be measured.
Key Findings from Global Meta-Analyses and Reviews
A large body of evidence, including major meta-analyses synthesizing hundreds of individual studies, paints a clear picture of the effects of bottom trawling and dredging.
Widespread Depletion and Slow Recovery
A landmark 2017 global meta-analysis published in the Proceedings of the National Academy of Sciences (Hiddink et al.) quantified the depletion and recovery of seabed biota across sedimentary habitats. It found that a single pass of a trawl gear removes between 6% (otter trawl) and 41% (hydraulic dredge) of faunal biomass. Crucially, it calculated that median recovery times for biomass to return to 95% of its untrawled state ranged from 1.9 to 6.4 years. This is an order of magnitude longer than the 4-5 month recovery period reported in the Bangor study, marking the Welsh finding as a significant outlier. A subsequent 2022 analysis confirmed that while many regions have high seabed status due to low fishing intensity, heavily trawled areas like the Adriatic Sea are severely depleted.
Severe Habitat Degradation
Bottom trawling is recognized as the most widespread direct physical disturbance to the world's seabeds. The process is akin to "rototilling the seabed". It reduces habitat complexity by removing or destroying biogenic structures (e.g., reefs created by sponges, corals, or mussels), flattens natural bedforms, and resuspends vast plumes of sediment. This sediment resuspension alters water chemistry, reduces light penetration (hindering photosynthesis), and can permanently change the nature of the seabed, for example, by washing away fine muds and leaving behind bare rock or coarse sand.
More Key Findings from Global Research
Extreme Vulnerability of Sensitive Habitats
While the Bangor study focused on dynamic sand and gravel, the global consensus is that the impacts of dredging vary enormously with habitat type. Biogenic habitats—those formed by living organisms—are particularly vulnerable. Studies have shown that scallop dredging has "profound, long-term impacts" on maerl beds (a type of slow-growing coralline algae that forms complex reef-like structures), with a single dredging event causing a >70% reduction in live maerl and no sign of recovery after four years. These complex habitats are vital as nursery and feeding grounds for a wide range of species, including commercially important fish.
Broad Ecosystem-Wide Effects
The impacts of bottom trawling are not confined to the seabed. The practice is associated with high levels of unwanted bycatch, which can include protected, endangered, and threatened species. By altering the benthic community, it fundamentally changes the marine food web. Furthermore, a growing body of research highlights the climate impact of trawling. Marine sediments are a critical global carbon store, and the physical disturbance of trawling can resuspend this carbon, potentially releasing it into the water column and ultimately the atmosphere as CO2, exacerbating ocean acidification and climate change.
Global meta-analysis recovery times compared to the Bangor study findings, showing how the Welsh study is a significant outlier.
The Welsh Exception: Legitimate Outlier or Unjustified Extrapolation?
The Welsh Government's entire policy on bottom-towed gear in MPAs is predicated on the idea that its marine environment—or at least the parts studied in 2015—is a special case, an exception to the general rules established by this overwhelming global consensus. The critical question for credibility is whether this claim of exceptionalism is scientifically justifiable.
The evidence strongly suggests it is not. While the findings of the Bangor study may be valid for the specific, high-energy, mobile sand and gravel habitat in which it was conducted, the Welsh MPA network is not homogenous. It contains a diverse array of habitats, as documented in NRW's own site-level reports.
To take the finding of resilience from one specific habitat type and apply it as a general principle to the entire network is a profound scientific over-extrapolation. It ignores the well-documented vulnerability of other habitat types that may exist within the MPAs and dismisses the global scientific consensus without sufficient justification.
The government's "evidence-based" approach is, in reality, based on a single, contested, and outlying piece of evidence that is used to justify a policy that runs contrary to the balance of global scientific knowledge.
Reconciling Contradictory Evidence: An Integrated Assessment of Welsh MPAs
Synthesizing the various streams of evidence—the 2015 Bangor experiment, the 2025 NRW condition assessment, and the global scientific consensus—reveals a policy framework built on a foundation of contradiction and logical fallacy. The Welsh Government's position is tenable only by narrowly defining problems, selectively interpreting evidence, and ignoring the core principles of environmental management.
The Limits of "Condition Assessment" vs. "Impact Assessment"
A fundamental issue is the conflation of an MPA "condition assessment" with a comprehensive "fishing impact assessment." The 2025 NRW report assesses whether designated features are in "favourable" or "unfavourable" condition based on a set of pre-defined conservation objectives. This is not the same as determining the full impact of fishing. A habitat feature, such as "subtidal sandbanks," might technically be in "favourable condition" (i.e., its extent and physical structure meet the targets) while simultaneously being ecologically impoverished by trawling. The assessment framework, by focusing on the designated feature's status, may not capture losses in biodiversity of non-target species, disruptions to the food web, or reductions in ecosystem function.
Contrasting Assessment Approaches
Welsh Approach
The Welsh approach, by attributing failure to the single most dominant pressure (water quality) and thereby exonerating others, fails to account for the complex, cumulative, and often subtle ways in which fishing degrades marine ecosystems.
US Essential Fish Habitat Approach
This approach contrasts sharply with more holistic frameworks, such as the Essential Fish Habitat (EFH) provisions in the United States. Under this system, managers are required to evaluate all "potential adverse effects of fishing on EFH," including a review of the "intensity, extent, and frequency of any adverse effect," the "habitat functions that may be disturbed," and the "cumulative effects of multiple fishing activities".
The Fallacy of Generalization
The central flaw in the Welsh Government's logic is the generalization from a specific, contested case to a universal principle for its entire MPA network. The 2015 Bangor study demonstrated the resilience of a specific benthic community in a specific dynamic sand and gravel habitat within Cardigan Bay. The government has taken this single data point and extrapolated it to justify a permissive stance on bottom-towed gear across all its MPAs.
This is a profound logical fallacy. The Welsh MPA network is not a monolith of dynamic sand. It is a mosaic of different habitats, including estuaries, mudflats, reefs, and saltmarshes, each with its own unique ecology and sensitivity to disturbance. Applying the resilience findings from a storm-battered sandbank to a more stable or structurally complex habitat is scientifically indefensible. It is akin to testing the fire resistance of a brick and concluding that an entire house made of wood, glass, and thatch is also fireproof.
A Failure of the Precautionary Principle
This policy approach represents a stark departure from the precautionary principle, a cornerstone of modern environmental law and management in the UK and Europe. The principle dictates that where there is a threat of serious or irreversible damage, a lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation.
The situation in Wales presents a textbook case where precaution is warranted. There is significant scientific uncertainty and controversy surrounding the impacts of dredging, as evidenced by the intense debate over the Bangor study. The study's findings are an outlier compared to the global consensus. The impacts on the majority of habitats within the Welsh MPA network have not been studied at all.
In this context, a precautionary approach would be to restrict or prohibit the potentially damaging activity (bottom-towed fishing) in protected areas until there is robust evidence to prove it is safe and compatible with conservation objectives. The Welsh Government has done the opposite. It has seized upon the single, contested piece of evidence that suggests resilience and used it to justify a permissive policy, effectively demanding proof of harm before it will act. This inverts the precautionary principle, placing the burden of proof on the environment and its advocates, a concern explicitly raised by stakeholders during the public consultation.
Credibility Assessment and Concluding Analysis
This report's final analysis delivers a differentiated judgement on the credibility of the evidence and the claims made based upon it. It is crucial to distinguish between the credibility of the underlying scientific work and the credibility of the political communications that interpret it.
75%
Credibility of the 2015 Bangor University Study
As a piece of scientific research, the study is a valid, large-scale BACI experiment. Its methodology for measuring the response of the specific benthic community in its chosen location is robust. Therefore, its credibility is high within these extremely narrow parameters. It provides valuable data on the response of a specific community in a specific dynamic habitat to scallop dredging. However, its credibility as a basis for general policy is low. Its applicability to other habitats is questionable, the "shifting baseline" critique remains a significant and plausible challenge, and the perception of a conflict of interest from its funding model severely undermines its authority in the public sphere.
65%
Credibility of the 2025 NRW Condition Assessment
The data collection and analysis underlying the 2025 report are likely robust and credible. It represents a significant and valuable effort by NRW to establish a baseline for the health of Welsh MPAs. Its conclusion that many MPAs are in poor condition and that water quality is a major driver of this failure is a credible and important finding. However, its credibility as a comprehensive fishing impact assessment is low. The methodology, by design, isolates pressures and appears to use a narrow definition of "impact." It cannot be credibly used to make a blanket statement that fishing is having "no negative impact."
15%
Credibility of the Welsh Government's Claim
The credibility of the political claim that "no assessed habitat or species... were found to be in an unfavourable condition due to impacts caused by fishing" is very low. It is a carefully worded statement that is technically true based on a narrow interpretation of a specific report, but it is profoundly misleading in its overall implication. It represents a selective use of evidence to support a pre-determined policy position. The claim is built on a logical fallacy (over-extrapolation from the 2015 study), it inverts the precautionary principle, and it wilfully ignores the vast body of contradictory national and international scientific evidence. It is a clear example of "policy-based evidence-making" rather than "evidence-based policymaking."
Conclusion
In conclusion, the Welsh Government's narrative of benign fishing impacts in its MPAs is not supported by a credible or comprehensive assessment of the evidence. It is a political construct designed to navigate the conflicting pressures of environmental protection and economic interests, but it does so at the cost of scientific integrity and the long-term health of the marine environment.
The analysis reveals a profound disconnect between the political narrative and the scientific reality. The central claim—that fishing is not causing negative impacts in Welsh MPAs—is a selective and misleading interpretation of the available evidence that fails to account for the complex, cumulative, and often subtle ways in which fishing degrades marine ecosystems.
Recommendations for an Evidence-Based Management Framework
To move beyond the current impasse of contested evidence and restore public and scientific confidence in the management of Welsh MPAs, a fundamental shift in approach is necessary. The following recommendations are proposed for the Welsh Government, Natural Resources Wales, and other relevant stakeholders.
Adopt a Genuinely Precautionary and Risk-Based Approach
In line with established principles of environmental law, the default management position for MPAs should be precautionary. Bottom-contact mobile gear should be prohibited in all designated features and habitats known to be sensitive to such pressures (e.g., reefs, maerl beds). For other habitats where impacts are uncertain, the burden of proof should be on demonstrating that the activity is compatible with the site's conservation objectives before it is permitted.
Commission a Network-Wide, Holistic Fishing Impact Assessment
The Welsh Government should fund a new, independent assessment that moves beyond the narrow scope of the current "condition assessment." This new assessment should evaluate the direct, indirect, and cumulative impacts of all fishing gears on the entire MPA network ecosystem, including non-designated features, food web dynamics, and ecosystem services like carbon storage. This should be guided by international best practices, such as the EFH assessment framework.
Diversify the Evidence Base and End Over-Reliance on a Single Study
Management decisions must cease to be predicated almost entirely on the 2015 Bangor study. New, independent research should be commissioned to investigate the impacts of various fishing gears on the diverse range of habitats found across the Welsh MPA network, with a particular focus on those identified as potentially more sensitive than the dynamic sands and gravels previously studied.
Additional Recommendations
Commit to Transparent Communication and Methodology
To rebuild trust, NRW and the Welsh Government must commit to full transparency. Scientific reports should be communicated to the public and policymakers in a manner that fully and clearly articulates their limitations, uncertainties, and the scope of their applicability. The methodologies used for pressure attribution in condition assessments must be published and clearly explained. Selective messaging that misrepresents the overarching scientific picture must be avoided.
Reform Stakeholder Engagement and Consultation Processes
The significant public opposition and criticism of the 2016 scallop consultation demonstrate a breakdown in trust. The Welsh Government should reform its consultation processes to ensure they are genuinely open, unbiased, and capable of capturing public sentiment fairly. Management decisions for MPAs should be co-developed with a balanced range of stakeholders, including the fishing industry, environmental NGOs, the scientific community, and local communities, to ensure that outcomes are both ecologically sound and socially equitable.
By implementing these recommendations, the Welsh Government can establish a more robust, transparent, and scientifically credible framework for managing its Marine Protected Areas. This would not only better fulfill the conservation objectives of these sites but also rebuild public trust in the government's commitment to evidence-based environmental stewardship.
Works Cited
  1. Fishing has 'not caused harm' in Welsh MPAs - Fishing News, https://fishingnews.co.uk/news/fishing-has-not-caused-harm-in-welsh-mpas/
  1. Welsh Government Agency Study of MPAs Finds No Negative Impact from Fishing - Afloat, https://afloat.ie/port-news/fishing/item/68309-welsh-government-agency-study-of-mpas-finds-no-negative-impact-from-fishing
  1. Natural Resources Wales / Further action needed to protect Wales's marine protected areas, https://naturalresources.wales/about-us/news-and-blogs/news/further-action-needed-to-protect-wales-s-marine-protected-areas/?lang=en
  1. Widespread Failure In Wales Marine Protected Areas - Afonydd Cymru, https://afonyddcymru.org/marine-failures/
  1. Report To The Senedd Cymru | Welsh Parliament On The Marine Protected Areas (MPAs) In Wales, https://senedd.wales/media/dd0bvfob/gen-ld17000-e.pdf
Additional references available in the full report, including scientific papers on bottom trawling impacts, the 2015 Bangor University study, and international best practices for marine protected area management.