Ms Ellen McMahon:

The biggest issue at present, in terms of marine protected areas, MPAs, is they are not enshrined in law, so we have the provisions under the Wildlife Act but they are limited in terms of their geographical scope. They only apply to the foreshore, so areas beyond 12 nautical miles are limited to designations under the habitats directive or the OSPAR Convention. The habitats and species which are not listed in these directives but might be locally, nationally or internationally important cannot be afforded the necessary protections.

The biggest issue we have with the national marine planning framework is that the plan we have at present does not meet the objectives of the marine spatial planning directive. Under article 5(2) of the directive, the objective is that these plans should contribute to "the preservation, protection and improvement of the environment, including resilience to climate change". However, by leaving out MPAs, that objective will not be met. That is why we recommend, at a minimum, there be sensitivity mapping to guide the development zones away from these sensitive areas.

There are other issues with the plan in that there are data gaps. The plans also need to take into account the temporal and spatial distribution of all activities, current and future, which is not there for all sectors in the current plan.

In addition to the lack of legislation for MPAs, enforcement is a huge issue. The European Court of Justice is taking Ireland to court over our failure to implement management plans across all of our current designated sites. Whether that is from a lack of resources, I am not 100% sure, but it is of massive concern. We need to get management sites in for the sites we have, get on with designating our MPAs and address the disparity between the national marine planning framework or we will exacerbate the issues that exist.