The following is a submission by Ashley Hayden to the public consultation on the MPA Advisory Group’s Report, July 2nd 2021.
My name is Ashley Hayden, I am 60 years of age, born in London, England on the 26/11/1960 to parents both who emigrated to England from Greystones, Co. Wicklow in 1956, the family moved back to Ireland permanently in June 1970.
My current area of occupation since January 2016 has been within the sector of Tourism and Travel.
I have written and campaigned since 2007 about marine conservation, marine habitat destruction, marine species decline and possible solutions to address the above issues through articles published in magazines and on my website “anirishanglersworld.com”.
I presently reside in Co. Wexford, Ireland.
This submission is based on fifty years active involvement with Ireland’s coastal marine environment through the medium of artisan fishing off Greystones, Co. Wicklow in my teenage years (long lining, trammel netting and potting) and recreational sea angling (counties Wicklow, Wexford, West Cork) from the age of 10 to date.
In that fifty year period I have witnessed continuous marine environmental decline to include fish stocks decline and disappearance, species range increases due to lost species void filling, habitat destruction and pollution with no improvement at all, the graph continuously downwards.

In my opinion a functioning MPA should include the following elements:
- Is stakeholder driven – stakeholders being recognised as all citizens and not just those who have an active or professional interest in the marine.
- Be community managed – locals know their area best – having an active stake leads to better protection.
- MPA’s should work for communities so they have to be functioning to gain acceptance, therefore commercial and recreational fishing along with other activities have to be allowed albeit under strict management guidelines designed and agreed collectively by all.
- All fishing gears or practices should be benign and the idea of no take zones in certain areas to protect and rehabilitate will and should be incorporated into future management plans.
- Local fish species quotas, size limits and recreational bag limits will apply.
- MPA’s should be interlinked – the marine habitat is a connection of migrations driven by the seasons and tidal flows.
- Ireland should create an all encircling coastal MPA out to the 6 mile limit (under EU law we have jurisdiction out to 6 miles) and adjust marine management legislation across all Government Dept’s to reflect a new environment led commercial approach.
- Where national parks touch the coastline their range should be extended out to the six mile limit, ie, Co. Wicklow.
- MPA’s will include an academic research mandate linked to local Universities, Schools and Colleges.
That when established in time MPA’s will garner enormous credibility for Ireland internationally, will underpin efforts to maintain and increase onshore and offshore biodiversity, will resurrect a now severely limited local artisan commercial fishing industry, will enable Ireland to market quality fish and shellfish, an International standard tourism recreational sea angling product and will act as a catalyst for marine cultural, heritage, tourism, educational and recreational activities such as diving, sea kayaking, natural history engagement and small boat hire.

The Expert Group provides a definition of what an MPA could be:
“A geographically defined area of marine character or influence which is protected through legal means for the purpose of conservation of specified species, habitats or ecosystems and their associated ecosystem services and cultural values, and managed with the intention of achieving stated objectives over the long term”.
I somewhat agree with this statement, however where I find fault is that as a nation we should just protect, rehabilitate and manage/maintain Ireland’s marine environment in total we should not need a specific local reason to implement protection or conservation, the reason being that all species and habitats are interlinked, one species/habitat cannot in human terms take preference over another, all are important, that is the law of nature.
That is why I recommend a nationally managed all encompassing MPA out to six miles underpinned by a future approach to fisheries management/legislation based on lower volumes and high quality products that command premium prices.
No one area of Ireland’s marine ecosystem is more important than another.
The marine expert group recommends the inclusion of existing legally protected marine sites which is admirable but an incorrect approach – most of these sites as we know are not fully protected anyway.
The right approach is just to be all encompassing – in my lifetime believe it or not the all encompassing approach was practiced by default – each local fishing harbour or port looked after its own patch. I observed this lifestyle operating along the south Dublin to north Wicklow coastline in the 1970’s.
The Bulloch harbour/Dalkey fishermen worked and protected the seas between Dunlaoghaire and Dalkey Island, the Homan family worked Killiney Bay from Dalkey to Bray Head and the Greystones artisan fishers worked from Bray Head south to the Breaches shoal.
The above all changed after Ireland joined the European Union in 1973 and applied a volume approach driven by Bord Iascaigh Mhara with the intention of developing a modern full time commercial fishing fleet to compete globally.
This approach, reflected by this submission process, has passed its sell by date and needs to be majorly readjusted. Commercial fishermen, their livelihoods and by extension families are actually taking the wrap for what has been Government policy for fifty plus years. In short the playing pitch needs to be changed.

Protection of Plant and Animal Species and Habitat
As stated already in this submission no one species or habitat should take preference over another as all are interlinked – domino effect.
In half my lifetime I have seen first hand the effect of change caused by the removal of both habitat and species. Taking the north Wicklow coastline as an example – Government sanctioned removal of the permanent mussel banks by dredging for mussel spat caused habitat destruction on a grand scale which ultimately destroyed what was once a productive mixed fishery off Greystones, Co. Wicklow.
Today based on media research one would think that Ireland’s seas are still productive and that Ireland’s most productive seas always were and still are on the West and South West coast.
Shifting baselines of experience and ignorance (in the true sense of the word) of how the marine presents both today and in the past has applied big time in creating this way of thinking. The seas and lifestyle that I fished and walked within between Dalkey Island south to Kilcoole, Co. Wicklow, from the age of ten until my early twenties, were as productive as any, in fact they would make the Blue Planet series look tame.
Basking shark, Dolphin, Porpoise, Grey seal, Cod, Pollack, Coalfish, Plaice, Black sole, Lemon sole, Flounder, Turbot, Mullet, Ray, Tope, Mackerel, Bass, Wrasse, Conger, Brown crab, Lobster, all growing to a large average size and in good numbers.
All the above and more either gone or severely diminished today, the whole ecosystem changed beyond recognition to what it was up to the mid to late 1970’s.
In short, I would not afford legal protection to any one ecosystem, oceanographic, cultural or other natural process or feature ahead of another as part of any future MPA network. My belief is that legal protection should apply to all as they are all interlinked and play their part in creating a healthy dynamic marine environment.
I have seen in my lifetime off the north Wicklow coastline how an ecosystem reacts to the large-scale removal of key species, in this instance permanent mussel reefs and huge stocks of cod, the negative trophic cascade has been both astonishing and revealing as to how nature operates. This negative dynamic affects not only the underwater world but also land based cultural, commercial and heritage based human activities.

Other Effective Area Based Conservation Measures (OECM’s)
To include wrecks, spawning/nursery areas, renewable energy sites. Again, I would reiterate that all are considered and not one has special preference over another as they are all interlinked. The above concept is based on how Ireland should economically exploit its marine resource into the future; ironically it is a preference led approach that to date has brought us to this submission process in the first place.
Any future management approach needs to place the resource first, rehabilitate where necessary and manage at a level and volume of exploitation that maintains and improves instead of decreasing.
14 Key Principles Stated in the Report of the MPA Advisory Group 2020
From meeting Ireland’s International commitments, to Climate change, Protection and Recovery, Carbon sequestration, Conservation and Restoration, Education and Research, International interactive networking, New legislation and the setting up of a coordinated marine body encompassing inputs from all necessary Government Departments.
I have alluded to most if not all of the above in my narrative to date and would agree that the fourteen points in principle set out a roadmap for improvement of Ireland’s marine resource.
While I would not disagree with the approach I still am not convinced that future administrations will place the environment ahead of how the economy functions today. The body language from my perspective suggests the Government will tweak the current failed business model because politically it is easier to achieve, which ultimately will result in a false economy and a waste of good time.
Ireland’s marine environment/economy will only recover and become as productive as it was pre 1970’s if we apply a low volume high quality business model. This does not mean less profit but instead sustained profit over time which will result in greater benefits for all society into the future.
How should Ireland expand its MPA network?
In my experience most of the Irish general public and politicians do not know a great deal about the marine other than that it is there. It certainly does not feature on the average person’s radar unless they want to go and visit the beach and in terms of both the average citizen and politician they have no idea of the damage that has been wreaked on Ireland’s marine resource.
The above is not a subjective opinion but instead is an objective assessment based on fourteen years writing and campaigning on the subject.
To successfully deliver a functioning MPA network I would prioritise engaging with people who understand the marine and how it functions/functioned both now and in the very recent past.
Therefore I would be sitting down with commercial fishers, recreational fishers and those that earn a living from the sea in a tourism capacity (past and present) from whale watchers to angling charter skippers to accommodation providers and anyone in between.
The conversation should be predicated on the current failed business model and the design of a new business model that reflects an environment led approach.
In short, the current Government (to include National and EU) has to accept that it drove the narrative that led to decline, that exploitation of the marine resource to date across all commercial sectors was sold as a viable career alternative (which they are). That these careers can still exist into the future but that they will have to be prosecuted in a more benign fashion.
To achieve a new business future will involve paying off and decommissioning but this will be delivered in tandem with future new environmentally friendly management structures and legislation which will preserve and maintain the various business sectors into the future, albeit they may be smaller, but correspondingly especially in the case of fisheries will be more productive in terms of profitability.
The MPA advisory group report 2020 in its latter stages discusses stakeholder engagement and possible future legislation changes to achieve goals and cites working examples such as the Dundalk Bay Cockle Fishery and how the aquaculture sector liaises with Government when it comes to Natura 2000 sites.
In my lifetime legislation on the marine has been a top down approach that has resulted in a resource that today benefits very few due to massive decline. To give an example on Ireland’s east coast off Co. Wicklow the only commercially viable fishing option today is whelking. Yet in my lifetime the resource supported many families across a wide range of fin fish, shellfish and crustacean fisheries. These jobs are gone now because the fish are gone, not because of cultural shifts in society. In fact the idea of eating fish has never been greater in the Irish mind.
Any future plan for the marine has to start from the bottom up and has to be managed locally within the framework of a national plan that is designed and bought into by both Government and the people who will manage/exploit/protect the resource for all the citizenry of Ireland to enjoy and be proud of.
In short, the Government has to trust the citizenry and vice versa – Us and Them have to be removed from the marine equation, permanently.
The above are the views of Ashley Hayden BA MSc and represent my submission to the process which will ultimately result in the creation of a Marine Protected Network around the coastline of Ireland which will rehabilitate what has been lost to the benefit of all Irish citizens into the future.