Ms Sin?ad Loughran:

In terms of the statement made by the IEN, we absolutely would not think that it is overly critical. We would 100% agree with the statement made. There are a number of weaknesses in areas of the Bill that are of serious concern to us. The Bill is not actually focused on conservation. There are a number of areas in which the absolute minimum could be done and the conservation objectives of the marine protected areas could be at risk. Some of those weaknesses, which we have already touched on, are in the weak language in terms of percentage coverage by 2030, with the words "up to" rather than "at least" used in terms of the strictly protected coverage. If we are looking at marine protected areas, the ocean and all the species within it as our greatest ally to mitigate climate change, then 10% is the absolute minimum for strictly protected areas. The features that can deliver those climate benefits absolutely need strict protection and there is no way around that.

In terms of the legislative priority and conservation being at the core, we spoke about appropriate development and existing licensed activities being allowed to continue after an MPA has been designated. The wording within the legislation is very unclear as to what exactly would constitute this but also in terms of how those existing licences would go about this. If it is not in line with the conservation objectives of the MPA, there should be a phasing out of those activities and a just transition approach applied where appropriate.

In terms of other effective area-based conservation measures, OECMs, and offshore renewable energy, we obviously would not see offshore renewable energy as being part of an MPA. BirdWatch Ireland is part of BirdLife Europe and Central Asia. Even offshore renewable energy would not be a feature within OECMs. An incredibly high standard of conservation must be delivered in order for measures to be considered OECMs. That is not reflected in the Bill either. There is no definition of the kinds of activities that can be allowed within an OECM. That is a real concern. It is assumed that offshore renewable energy can fit within OECMs and therefore contribute to 30 by 30. BirdWatch Ireland would not even see OECMs being part of 30 by 30. They are an additional tool that can deliver conservation benefits. Some of those really stringent criteria relating to OECMs mean that if they are to be included, they really need to provide very high standards in terms of ecological representation and conservation benefits that are similar and equivalent to those that an actual MPA would deliver. The nature of offshore renewable energy and many OECMs is that they simply cannot do that because they are introducing new or alternative habitat. They do not benefit the entire ecosystem. They might benefit one or two species perhaps but it is not an ecological representation.

On the overall ambition and our existing commitments, there are a lot of gaps in respect of the habitats directive and the birds directive. Clarity is needed on the International Union for Conservation of Nature, IUCN, list that would be included for identification of potential marine protected areas. At the moment, 23 of Ireland's 24 breeding seabird species are on amber or red lists. The vast majority of them would not be considered threatened under the IUCN list. That is of real concern to us.