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How to ‘flip’ a paper park: Success in the North Sea carries lessons

A puffin with a beakful of sand eels. Dogger Bank has a unique biodiverse ecosystem rich in sand eels that supports North Sea food webs, including seabird populations. Image by Steve Higgins via Flickr (CC BY-NC-ND 2.0).

A puffin with a beakful of sand eels. Dogger Bank has a unique biodiverse ecosystem rich in sand eels that supports North Sea food webs, including seabird populations. Image by Steve Higgins via Flickr (CC BY-NC-ND 2.0).

  • A recent study found that 27% of surveyed marine protected areas (MPAs) were likely “paper parks” that fail to confer real ecological protection.
  • There are different kinds of paper parks, including those with overly permissive rules and those where the rules are not followed or enforced.
  • Discussions among conservationists have turned to how to “flip” paper parks to make them more effective. This can require changing park rules, often only through sustained pressure on governments, or improvements in MPA management, which can be costly.
  • It’s a crucial time for figuring out how to make MPAs more effective; in December, nearly 200 countries signed a landmark agreement to conserve 30% of Earth’s land and sea by 2030, committing to more than triple MPA coverage within seven years.

Dogger Bank, a sandbank in the North Sea the size of Washington state, was designated a marine protected area more than decade ago to conserve its sensitive seabed habitat. Yet for most of that time, industrial fishing vessels legally dragged damaging gear across the seabed, prompting NGOs to cite it as one of Europe’s emblematic “paper parks,” where the designation of MPA had not led to substantive change.

Last year, it finally got some real protection: The U.K. government banned bottom-towed fishing, including bottom trawling, a destructive fishing practice, in its section of Dogger Bank, which accounts for two-thirds of the MPA.

“We saw that you could flip from being protected only on paper to being protected in reality,” Thomas Rammelt told Mongabay by phone. Last year Rammelt co-founded the Doggerland Foundation, a Dutch NGO that works on North Sea conservation and has spearheaded discussions on “flipping” parks.

It’s a crucial time for figuring how to make MPAs more effective. At the COP15 U.N. biodiversity summit in December, nearly 200 countries signed a landmark agreement to conserve 30% of Earth’s land and sea by 2030 (“30×30”). If they follow through, this will more than triple MPA coverage within seven years, as current global coverage is less than 10%.

But the hard part is making sure MPAs offer actual ecological protection and socioeconomic benefits. There are already plenty of paper parks around the world that do neither; in many cases, there’s not even a management plan in place or staff ensuring the rules are followed. A study released in May found that 27% of surveyed MPAs were likely paper parks, and the lead author told Mongabay that’s a conservative estimate — the global percentage is probably higher.

There are different kinds of paper parks, including those with overly permissive rules like Dogger Bank had and those where the rules are not followed or enforced. Experts say flipping them requires changes to park rules, as happened in the U.K. only after NGOs sustained pressure on the government, or improvements in MPA management.

Map of Dogger Bank. Image by Emilie Reuchlin / Doggerland Foundation, Netherlands.
Map of Dogger Bank. Image by Emilie Reuchlin / Doggerland Foundation, Netherlands. Image from Google Earth (May 2023).

When the rules are too permissive

Dogger Bank is a shallow sandbank where upwellings create a uniquely biodiverse ecosystem that supports North Sea food webs, including seabird populations. However, commercial interests have made species there into the basis of industrial food webs. Dutch- and Danish-owned vessels target amino acid-rich fish called sand eels for use as feed in raising pigs and fish. They also heavily target flatfish for human consumption. The vessels use bottom trawling or demersal seining gear, both of which have now been banned in the British section of Dogger Bank, but continue to be used in the Dutch and German sections.

Initially, all three countries were members of the European Union, and followed EU protocols that turned their Dogger Bank areas into “Sites of Community Importance” by 2012 and, later, “Special Areas of Conservation” — types of MPAs.

In the EU, MPA designation doesn’t automatically mean an area gets new, stricter fisheries rules. Protections are limited by Article 11 of the Common Fisheries Policy, which states that any country with a “direct management interest” in a fishery that’s affected by a proposed conservation measure — such as banning trawling in an MPA — can have a say in the policy, potentially blocking any change.

Article 11 is “debilitating EU conservation policy,” Rammelt said. “How can you negotiate a 100% closure of an MPA if you are negotiating with another country’s fisheries industry? It’s impossible.”

European plaice (Pleuronectes platessa), a species commonly fished using bottom-towed gear on Dogger Bank. Image by Lars Laursen via (CC BY-NC-SA 4.0).

Rammelt and Doggerland co-founder Emilie Reuchlin spent years on Dogger Bank negotiations while working for other NGOs, but said they felt industry influence made securing meaningful protection difficult.

“[F]inally you see after many years of negotiating that not much protection is achieved and you scratch your head and say, ‘what can I do next,’” Rammelt said.

Reuchlin told Mongabay she favors holding governments to account to uphold treaties and laws, including the 30×30 agreement and the EU Habitats Directive. This means using legal means when necessary, she said.

This approach helped her allies succeed in the U.K., where, as Brexit was nearing finalization, NGOs worked together to build the legal and public-opinion case to ban bottom-towed fishing in Dogger Bank.

In 2020, U.K.-based Blue Marine Foundation sent a series of communiqués to the U.K. government, essentially threatening to sue if the government did not protect Dogger Bank. The group also partnered with other organizations to produce a scientific assessment of fishing activities in the MPA that showed bottom-towed fishing had adverse effects on the site’s habitat and species.

In June 2020, Greenpeace’s U.K. branch sent a sailboat around the sandbank area for two weeks and ran across 19 industrial trawlers. “They [the trawlers] should have absolutely no place in a marine protected area, especially one like Dogger Bank because the seabed is what was meant to be protected,” Chris Thorne, a Greenpeace oceans campaigner, told Mongabay.

Greenpeace campaigners drop a granite boulder into the Dogger Bank marine protected area
Greenpeace campaigners dropped a granite boulder into the U.K. section of the Dogger Bank marine protected area in the North Sea in 2020. This was one of 34 boulders the group dropped, creating an underwater barrier to bottom trawling. Image © Suzanne Plunkett / Greenpeace.

Then, Thorne and his team took action: They dropped 34 boulders into the sea at strategic locations to create an underwater barrier against trawling the U.K. section of Dogger Bank. They got support from celebrities and politicians from all major parties, some of whose names were painted on the boulders.

Late that year, international marine conservation NGO Oceana, with support from other organizations, began pressuring the U.K. government to protect all its offshore MPAs, including Dogger Bank.

In February 2021, the U.K. government announced a proposal to regulate trawling on Dogger Bank. However, after one year, no such plans had been finalized, so Blue Marine Foundation made a more formal legal threat. Then, just as the NGO was about to follow up with an actual lawsuit, in April 2022, the U.K. government instituted the complete bottom-towed fishing ban in Dogger Bank, as well as partial bans in three other MPAs.

Thorne said he believes the boulder drops were key.

“It really captured media and public attention,” he said. “It really pushed the issue of MPAs up the political agenda, a boost it really did need.”

The ban on trawling in the British section of Dogger Bank had an immediate impact, with apparent activity reduced to nearly zero, indicating strong compliance.

More large-scale “flips” remain possible in the U.K. and Europe. The U.K. is currently considering bottom-towed fishing gear restrictions for dozens more offshore MPAs with sensitive seabed habitats, and plans to implement new rules by next year. This would be a marked shift in a country where as of 2019 bottom trawling occurred in 97% of MPAs, according to findings reported in The Guardian.

Meanwhile, in February, the European Commission released an action plan calling for a ban on bottom trawling in all EU MPAs by 2030 — a potentially monumental step. However, the action plan is not binding and faces strong opposition. NGOs are also petitioning EU nations to enact such bans in their own waters immediately.

Grey seals (Halichoerus grypus), a species that frequents Dogger Bank. Image by Bouke ten Cate via Wikimedia Commons (CC BY-NC-SA 4.0).

When the rules aren’t followed

Dogger Bank is an offshore MPA with no small-scale fishers or coastal communities with livelihoods immediately at stake, so the NGO focus is fully on ecological protection. Many paper parks, especially in the Global South, face more complex situations, with people living in and around them or industrial actors that aren’t forced to follow the rules.

NGOs have largely moved away from “fortress” conservation that strictly protects an area from human disturbance, and tried to engage local people in the management of MPAs. Ideally, this is done from the beginning, so there’s no need to try for a “flip” later on, experts say.

“If you don’t already include all stakeholders in that first [design] phase, how would you expect that everyone would respect those regulations?” Verónica Relaño, head of Somos Oceanos, a marine conservation organization working in countries such as Argentina, told Mongabay. Relaño led the aforementioned study finding a 27% paper park rate as a doctoral student at the University of British Columbia.

“So everything for me starts in the first phase,” she said, adding that “flipping” is still a good option for existing parks.

Small-scale fishers in or around MPAs may need alternative livelihoods to reduce economic pressure to break MPA rules, Jo Albers, an environmental economist at the University of Wyoming who researches MPA economics, mostly in low-income countries, told Mongabay.

There haven’t been many economics studies of how MPAs function best in low-income settings, Albers said. “Instead it’s just assumed that there’ll be perfect compliance,” she said.

Better compliance requires not just community engagement but also enforcement, which can be expensive, she said, and most countries just don’t have the necessary resources.

That’s especially true considering that enforcement problems often can’t be solved solely at the community level. In parts of Africa, industrial vessels, some foreign-owned, regularly violate the rules of inshore exclusion zones, a type of MPA reserved for small-scale fishers. And the problem isn’t exclusive to the Global South. The European Mediterranean also faces systemic violations of rules prohibiting bottom trawling in MPAs, undermining conservation efforts.

Good governance and anti-corruption efforts are needed to tackle these issues, experts say. Local small-scale fishers often support reforms, and voice their desire for increased enforcement to NGOs or government actors, Antonio Di Cintio, a doctoral student in marine areas management at the University of Pisa in Italy, told Mongabay. Di Cintio led a recent literature review indicating that strong enforcement, along with stakeholder involvement and good communication, is key to creating an effectively managed park.

“They say, ‘Please help us get rid of industrial fishing that keeps doing big, big damage,’” he said.

Small-scale fishers set a net close to shore on Nosy Faly, an island in northwestern Madagascar, as an industrial trawler fished further offshore in 2021. At the time, Nosy Faly fishers accused industrial vessels of violating a near-shore exclusive access zone reserved for small-scale fishers. Image by Mongabay.

What’s paper and what’s real?

Internationally, there’s no standardized method for evaluating MPAs or determining whether an MPA is a paper park. In 2021, scientists representing some three dozen institutions teamed up to develop a system called the MPA Guide, explaining it in a paper in the journal Science. They advocated grading MPAs on a four-part scale with regard to potentially harmful activities such as fishing or dredging: “minimally protected,” “lightly protected,” “highly protected” and “fully protected.”

How widely the MPA Guide or another system will be taken up remains to be seen. A dizzying array of ecological and socioeconomic factors makes standardizing impact assessments difficult, experts say.

“With conservation, it’s large areas, it’s many people, it’s not this controlled environment,” said Albers, the economist.

Yet activists aren’t sitting still in places where they believe the case for more conservation is clear.

“We simply don’t have time to sit around the table and talk for 10 or 15 years,” Reuchlin of Doggerland said.

A puffin with a beakful of sand eels.
A puffin with a beakful of sand eels. Dogger Bank has a unique biodiverse ecosystem that supports North Sea food webs, including seabird populations. Image by Steve Higgins via Flickr (CC BY-NC-ND 2.0).

Correction 7/27/23: The original version of this story mischaracterized some aspects of the timeline of the effort by NGOs to compel the U.K. government to protect Dogger Bank. We’ve updated the story to clarify the timeline and the leading role that Blue Marine Foundation played. We regret the error.

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