• Fiona Smith

Natural Capital on our coasts - NCI's Marine Strategy Framework Directive Consultation submission

Natural Capital Ireland recently took the opportunity to input into the Public Consultation on the Marine Strategy Framework Directive (MSFD) Marine Strategy Part 3 Programme of Measures (PoM) - our response offers a natural capital framework to assist in assessing more accurately, and more holistically, the benefits and costs of the programme - read some key points here:


Screenshot of website with map of ocean around Ireland and UK
Ireland's Marine Atlas is a valuable online resource for data along our coastline which should be kept up to date

The Marine Strategy Programme of Measures (PoM) sets out the intention of the Department of Housing, Local Government and Heritage to put in place such measures that will achieve a Good Environmental Status (GES) for Ireland’s marine environment. Our reliance on the marine for food, climate regulation, energy, raw material and recreation, and for supporting jobs are highlighted – these elements are all dependent on our conserving and, where necessary, restoring, the natural capital bases of our marine environment.


Challenges highlighted include:

  • pollution

  • over-exploitation of living resources

  • incidental by-catch

  • non-indigenous species

  • underwater noise and damage to the seabed.


These are a direct result of our historic and current policies in relation to our marine environment. Measures to achieve a healthy marine environment require an overarching approach which accounts for, and values, the natural capital of our marine environment and coastal communities.


NCI believes the natural capital approach makes visible values -both benefits and costs - that are obscured or invisible in conventional evaluations of the economic and environmental impacts of policies across the whole range of human activity.

Natural capital approaches, and natural capital accounting specifically, build in the fullest possible range of environmental and cultural costs and benefits in the assessment of any policy and, crucially, can be used continuously to monitor the full performance of a policy into the future.


NCI's EPA-backed INCASE project is piloting this natural capital accounting approach in four river catchments across Ireland. The prevailing approach is the System of Environmental Economic Accounting-Ecosystem Accounting (SEEA-EA), adopted by the UN and in use by about 90 countries worldwide. It's a guide to integrating economic, environmental and social data into a single, coherent framework for holistic decision-making. (See the INCASE website for supporting info.) We encourage the Department to engage with the Ecosystem Accounts Division of the Central Statistics Office in order to contribute to the task of developing such Irish ecosystem accounts.


There needs to be more alignment of data collection and better availability of this data within all sections of the Department. The online Marine Atlas (developed by the Marine Institute) which provides access to Ireland’s marine data is a valuable online resource that should be kept live and up to date. There is insufficient research into the marine ecosystem and insufficient collection of relevant data, including to demonstrate the public good benefits of conservation designations that could impact on fishing activity as required by the National Marine Planning Framework. There is a need to direct more funding to the National Parks & Wildlife Service and the Marine Institute, to ensure that we have the data to better understand and protect marine habitats.


The Marine Strategy PoM has to be founded on a realisation that catches, a profitable industry, employment and prosperous coastal communities, all depend on the stocks of natural capital. The economic value of the catch would, very simply, be much higher if stocks such as cod, haddock and herring could be restored to former abundance. This will require some sacrifice in the short to medium term. A healthy marine environment is characterised by a functioning biodiversity and food webs comprised of many species of no direct commercial value but of crucial indirect value to the populations of commercial species.


Our submission also includes recommendations on better enforcement of existing protections and legislation, tackling marine plastic pollution, and the quantifying and working to enhance the tourism and recreational value of our coastal areas.


You can read the full submission here.

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