Management Proposals of Inshore Fisheries Groups

Consultation on the initiatives developed by Inshore Fisheries Groups with the potential for environmental impact.


5.0 Environmental Baseline

5.1 Introduction

5.1.1 This section of the report contains detailed background information on Scotland's marine environment by environmental topic area.

5.2 Biodiversity, Flora and Fauna

5.2.1 Scotland's seas are among the most biologically diverse and productive in the world, supporting an estimated 6,500 species of marine animals and plants, excluding microbial flora 46 .

Marine Habitats

5.2.2 The seabed is a critical component of marine ecosystems. Six broad habitat types occur in Scottish waters (Figure 5): intertidal rock, intertidal sediment, subtidal rock, shallow subtidal sediments, shelf subtidal sediments and deep-sea habitats. These are described in the following paragraphs 47 .

5.2.3 Intertidal rock, which comprises approximately 48% of the Scottish coastline, includes bedrock, boulders and cobbles and is affected by a number of physical factors ( e.g. wave exposure, salinity, temperature and tides). The upper regions of many rocky shores are relatively species-poor, particularly on exposed coasts, but areas nearer to the bottom of the shore can be very species-rich. These areas are popular resting and foraging places for many animals ( e.g. grey seal, otter and various wading birds). For species at the limits of their range, pressures include climate change ( e.g. increasing sea temperatures, changes to rainfall patterns) and invasive non-native species.

5.2.4 Intertidal sediments comprise around 50% of the Scottish coastline and include mobile shingle and gravel; sand or mud or combinations of these (including sandflats and mudflats); and saltmarsh in the upper shores. These habitats support communities of animals that are typically species-poor but highly productive ( e.g. burrowing worms and bivalve molluscs). Pressures include physical disturbance, changes in wave regimes, sea-level rise, and damaging recreational activities. Some features in these areas are sensitive to fishing methods, e.g. seagrass beds are sensitive to suction dredging for cockles and blue mussel beds are sensitive to demersal fishing operations.

5.2.5 Subtidal rock habitats consist of bedrock, boulders and cobbles occurring below low water mark and the communities found in these areas are affected by the availability of light. Shallow areas are typically dominated by seaweeds; communities in deeper areas comprise exclusively marine animals. Subtidal rock is extensive on the west coast and around Shetland, but is only present in isolated pockets on the east coast. Flora and fauna supported by subtidal rock are vulnerable to physical damage ( e.g. from bottom-fishing gear, anchoring and coastal development) and to climate change, particularly increases in sea temperature.

Figure 5 : Modelled distribution of broad habitat types found in Scottish waters
(Source: Marine Atlas 2011)

Figure 5 : Modelled distribution of broad habitat types found in Scottish waters

5.2.6 Shallow (or inshore) and shelf subtidal sediment habitats cover an extensive area of the seabed, and include shingle, gravel, sand and mud. They extend to depths below the effects of wave patterns (around 50-70m) with shelf sediments extending to 200m depth. Inshore habitats also include lagoons and maerl beds. These habitats and the species they support are vulnerable to physical damage ( e.g. from dredging, bottom trawling, seabed development, and anchoring) and to pollution.

Protected Marine Sites and Species

5.2.7 Scotland's marine biodiversity is protected by a range of European, UK and Scottish-level designations:

  • Special Areas of Conservation ( SAC), including both onshore and offshore SACs. These cover eight different habitat types (estuaries; lagoons; large shallow inlets and bays; mudflats and sandflats not covered by seawater at low tide; reefs; sandbanks which are slightly covered by seawater all the time; submarine structures made by leaking gases; and submerged or partially submerged sea caves) and three species (bottlenose dolphin, grey seal and common seal).
  • Special Protected Areas, many of which are of international importance for bird species ( i.e. seabirds, waders, ducks, geese and swans).
  • Sites of Specific Scientific Interest, and
  • Fisheries management areas (Tables 8 and 9).

In addition, Ramsar sites are designated for their internationally important wetlands, protected as SPAs or SACs, depending on their features. 48 These sites are summarised in Figure 6; details are provided in SNH/ JNCC (2012). 49

5.2.8 The Habitats Directive 50 affords protection to certain species of plants and animals (European Protected Species). In the marine environment these include cetaceans, basking sharks and seals. Entanglement of baleen whales in static fishing gear has been observed in Scottish waters, i.e. minke whales entangled in creel lines and other ropes. At the time of reporting (2010), such incidents were not considered to be a conservation threat in Scotland 51 .

5.2.9 The Marine (Scotland) Act 2010 and the Marine and Coastal Access Act 2009 introduced new powers to designate Marine Protected Areas ( MPAs) and require that a network of MPAs in UK seas is created to protect biodiversity and geodiversity. This network will contribute to agreements with international partners to create an ecologically coherent network of well-managed MPAs in the North East Atlantic. SNH and JNCC are currently working with Marine Scotland on proposals for nature conservation MPAs; their report to the Scottish Parliament in December 2012 included 33 nature conservation MPA proposals. Seventeen of these MPA proposals occur within territorial waters (Table 10; Figure 6). A further four MPA search locations remain to be fully assessed. 52

Table 8. Fisheries management areas (for nature conservation purposes)

OSPAR Region

Fisheries management area

Restriction summary

II

North-east UK sandeel closure ( CA1)

Year round closure on sandeel fishing with the exception of a commercial monitoring fishery with a precautionary Total Allowable Catch. Sandeel fishery. EC No. 40/2008

III

Lamlash Bay

Year round prohibition of all fishing for sea fish within Lamlash Bay, Isle of Arran, regardless of the method of fishing employed. SSI No. 317/2008

V

North West Rockall

Vessels are prohibited from bottom trawling and fishing with static gear, including bottom set gill-nets and long-lines, for the protection of vulnerable deep-sea habitats such as corals and sponges. EC regulation No. 40 2008

V

Darwin Mounds

Vessels are prohibited from using any bottom trawl or similar towed nets operating in contact with the bottom of the sea for the protection of deepwater coral reefs. EC regulation No. 602/2004

V

West Rockall Mound

Vessels are prohibited from bottom trawling and fishing with static gear, including bottom set gill-nets and long-lines, for the protection of vulnerable deep-sea habitats such as corals and sponges. EC regulation No. 40 2008

V

Hatton Bank

Table 9. Other existing fisheries management measures

OSPAR Region

Fisheries management area

Restriction summary

V

Blue Ling Management Area - edge of Rosemary Bank ( FRA)

Restriction of blue ling catch during the spawning season

V

Blue Ling Management Area - edge of continental slope ( FRA)

Restriction of blue ling catch during the spawning season

5.2.10 While not a statutory designation, Scotland's 29 Marine Consultation Areas ( MCA) highlight areas of conservation priority in the near-shore marine environment. Located around the coastlines of Scotland's western and northern mainland and isles, these areas represent high quality and sensitive marine habitats and species. They will eventually be superseded by MPAs.

5.2.11 SNH and JNCC have developed a list of Priority Marine Features ( PMFs), to provide a new focus for marine conservation activities across the three pillar approach set out in the Marine Nature Conservation Strategy. Some of these PMFs are UK Biodiversity Action Plan species and habitats. UK BAP priority species are those that are identified as being threatened and requiring conservation. There are 74 UK BAP priority marine species listed as priorities in Scotland. These include sea-fan anemone, fan mussel, native oyster and fireworks anemone. These species can be vulnerable to fishing activities. For example, the fireworks anemone is highly sensitive to mechanical damage from mobile fishing gear, particularly trawling for Nephrops and, to a lesser degree, damage from creels.

5.2.12 SNH and JNCC have made recommendations to Scottish Ministers on PMFs, which comprises a list of PMFs for inshore and offshore waters 53 . This includes such marine species as cod, herring, mackerel and ling. The Marine Atlas identifies key PMFs and the pressures affecting them (Table 11).

Shellfish stock levels

5.2.13 With the exception of squid which are highly mobile, shellfish species are widely distributed on the seabed. Different species have different habitat requirements and species distribution is dependent on the availability of suitable substrates. 54 The geographical distribution of different habitats around Scotland is highly complex, especially on the west coast, and in consequence shellfish populations are distributed patchily but in discrete aggregations.

5.2.14 The overall assessment of shellfish stocks provided by Scotland's Marine Atlas broadly suggests that those in the south and west are heavily exploited, compared to stocks in the more northerly and easterly part of Scottish waters which show signs of general improvement. Nephrops occur in areas of soft and sandy mud. On the west coast, the abundance of the three stocks (North Minch, South Minch and Clyde) declined in 2012.

Figure 6. Existing protected areas, other area-based measures, possible Nature Conservation MPAs and MPA search locations

Figure 6. Existing protected areas, other area-based measures, possible Nature Conservation MPAs and MPA search locations

Table 10. Possible Nature Conservation MPAs in Scottish territorial waters 55

Name

Code

Protected features

Territorial waters

Clyde Sea Sill

CSS

Biodiversity protected features - Black guillemot; circalittoral sand and coarse sediment communities; fronts

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed - sand banks, sand ribbon fields, sand wave fields

East Caithness Cliffs

ECC

Biodiversity protected features - Black guillemot

Fetlar to Haroldswick

FTH

Biodiversity protected features - Black guillemot; circalittoral sand and coarse sediment communities; horse mussel beds; kelp and seaweed communities on sublittoral sediments; maerl beds; shallow tide-swept coarse sands with burrowing bivalves

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed

Loch Creran

LCR

Biodiversity protected features - Flame shell beds

Geodiversity protected features - Quaternary of Scotland

Lochs Duich, Long and Alsh

DLA

Biodiversity protected features - Burrowed mud, flame shell beds

Loch Sunart

LSU

Biodiversity protected features - Flame shell beds; northern feather star aggregations on mixed substrata; serpulid aggregations

Loch Sunart to the Sound of Jura

SJU

Biodiversity protected features - Common skate

Geodiversity protected features - Quaternary of Scotland

Loch Sween

LSW

Biodiversity protected features - Burrowed mud; maerl beds; native oysters; sublittoral mud and mixed sediment communities

Monach Isles

MOI

Biodiversity protected features - Black guillemot

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed; Quaternary of Scotland - landscape of areal glacial scour

Mousa to Boddam

MTB

Biodiversity protected features - Sandeels

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed

North-west sea lochs and Summer Isles

NWS

Biodiversity protected features - Burrowed mud; circalittoral muddy sand communities; flame shell beds; kelp and seaweed communities on sublittoral sediments; maerl beds; maerl or coarse shell gravel with burrowing sea cucumbers; northern feather star aggregations on mixed substrata

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed - banks of unknown substrate; Quaternary of Scotland - glaciated channels/troughs, megascale glacial lineations, moraines; Seabed Fluid and Gas Seep - pockmarks; Submarine Mass Movement - slide scars

Noss Head

NOH

Biodiversity protected features - Horse mussel beds

Papa Westray

PWY

Biodiversity protected features - Black guillemot

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed - sand wave field

Small Isles

SMI

Biodiversity protected features - Black guillemot; burrowed mud, circalittoral sand and mud communities; fan mussel aggregations; horse mussel beds; northern feather star aggregations on mixed substrata; northern sea fan and sponge communities; shelf deeps; white cluster anemones

Geodiversity protected features - Quaternary of Scotland - glaciated channels/troughs, glacial lineations, meltwater channels, moraines, rock basins, streamlined bedforms

South Arran

ARR

Biodiversity protected features - Burrowed mud; herring spawning grounds; kelp and seaweed communities on sublittoral sediments; maerl beds; maerl or coarse shell gravel with burrowing sea cucumbers; ocean quahog; seagrass beds; shallow tide-swept coarse sands with burrowing bivalves

Upper Loch Fyne and Loch Goil

LFG

Biodiversity protected features - Burrowed mud; flame shell beds; horse mussel beds; ocean quahog; sublittoral mud and mixed sediment communities

Wyre and Rousay Sounds

WYR

Biodiversity protected features - Kelp and seaweed communities on sublittoral sediment; maerl beds

Geodiversity protected features - Marine Geomorphology of the Scottish Shelf Seabed

Table 11. Key Priority Marine Features and Pressures (from the Marine Atlas)

PMF

Pressure

Seagrass

Suction dredging and bait digging

Blue mussel beds

Demersal fishing and bait digging

Native Oyster

Over fishing

Northern sea fan and sponge communities

Bottom fishing gear

European spiny lobster

Vulnerable to overfishing

Horse mussel beds

Damage from mobile fishing gear

Flame shell beds

Sensitive to damage from mobile fishing gear and dredging.

Serpulid aggregations

Vulnerable to demersal fishing

Burrowing sea anemone

Main pressures are from dredging and demersal fishing

Northern Feather Star

Main pressures are from dredging and demersal fishing

Fan mussel

Particularly sensitive to damage from scallop dredging and other fishing gear.

Heart cockle

Threatened by dredging and demersal fishing activities

Ocean quahog

Risk from mechanical damage particularly caused by bottom fishing gear.

Burrowed mud

Vulnerable to trawling for nephrops, bottom trawling and creeling.

Maerl beds

Extremely sensitive to physical disturbance and smothering as a result of scallop dredging and bottom trawling.

Maerl of coarse shell gravel with borrowing sea cucumbers

Especially damaging to physical disturbance from scallop dredging.

Inshore deep mud with burrowing heart urchins

Particularly vulnerable to damage from benthic trawling for nephrops.

Shallow tide-swept coarse sands with burrowing bivalves

Likely to be targeted for scallop dredging and surf clam fisheries. Sensitive to over fishing and physical disturbance.

5.3 Water Quality and Ecological Status

5.3.1 There are various mechanisms in place for monitoring and managing the quality of Scottish waters. Each takes a different focus and approach:

  • The Water Framework Directive establishes a framework for the protection of inland surface waters (rivers and lakes), transitional waters (estuaries), coastal waters and groundwater, with the aim of ensuring that all aquatic ecosystems meet 'good status' by 2015. 56 , 57
  • River Basin Management Plans ( RBMP) 58 have been prepared for the Scotland and Solway-Tweed River Basin Districts ( RBD) to address the requirements of the Water Framework Directive in relation to the management of Scotland's river systems. Both plans also provide an overview of the state of the water environment for their districts.
  • Scotland's coastal waters are monitored by SEPA to measure performance and compliance with targets for coastal water quality status under the Water Framework Directive.

5.3.2 In all, 63% of Scotland's water bodies were at good or better status in 2010. Of these, some 96% of coastal waters, 86% of estuaries, 63% or rivers and 54% of lochs were classed as in 'good' or 'better' condition in 2010. 59 While 96% of coastal waters in Scotland were classified as in excellent or good condition (grade A or B), 95% were reported as having achieved an improvement in condition. 60

5.3.3 However, some coastal water bodies and a particularly high proportion of transitional waterbodies (76%) 61 remain at risk of not meeting the objectives of the Water Framework Directive by 2015. A further 480 rivers, 57 lochs and one estuary (Upper Forth estuary 62 ) were classed as being in 'poor' or 'bad' condition, with a further 407 rivers, 48 lochs, 5 estuaries (Girvan Harbour, Montrose Basin and Forth, Clyde, and Ythan estuaries) and 28 coastal waters classified as being in 'moderate' condition for the same period.

5.3.4 Much of the coast in the north, north-east, east, north-west, the Minch and west of the outer Hebrides is classified as being of high water quality (Figure 7). Waters in the Little Minch and south to the southern extent of the Mull of Kintyre are generally classified as 'good' quality, as are waters south of Argyll, around northern Orkney and the Shetland Isles, parts of the east coast and the outer Forth area. While these waters would be sensitive to any degradation in water quality, they may also have a greater capacity to withstand effects without it compromising quality status. Waters in the Inner Firth of Forth, Inner and Outer Firth of Clyde, Loch Linnhe and the Sound of Mull, Solway Firth and the coastal area off Fraserburgh are all classified as having 'moderate' quality.

5.3.5 Reported pollutant discharges from boats are recorded annually for the Maritime and Coastguard Agency ( MCA). In Scotland, the records for 2009 63 show the following incidents were reported:

  • In western Scotland (Dumfries and Galloway, Ayrshire, Inverclyde, Argyll and Bute, and the Highlands and Islands region to Cape Wrath) a total of nine vessel-source pollution incidents were reported.
  • In Orkney and the Shetland Islands one vessel-sourced pollution incident was reported.
  • In eastern Scotland (the northern and eastern shores of the Highlands and Islands region from Cape Wrath, Moray, Aberdeenshire, Angus, Fife, Lothian and Scottish Borders) reported some 29 discharges from vessels.

5.3.6 Future trends in the number of oil spills are difficult to predict as these are related to industrial activity and arise mainly from accidents, either as oil spills in fuelling activities, running aground or as chemical discharges from oil and gas installations.

Seabed and sediments

5.3.7 The quality of the water environment is closely linked with both the quality of sediments and biodiversity. Marine sediments play a key role in marine ecosystems, in supporting the benthos and ultimately in maintaining life throughout the water column.

5.3.8 In general, the marine sediments around Scotland are sandy or gravelly and originate from deposits during the Quaternary glaciation. Strong currents and wave action may also have prevented deposition of recent muddy sediment or have winnowed it to leave a coarse-grained lag deposit. Muddy sediments occur principally nearshore or, further offshore, in depressions on the sea floor, where currents may be relatively weak. They also occur beyond the shelf break (200 m water depth) to the west of Scotland. The concentration of calcareous material varies greatly in seabed sediments reflecting the amount of shell material in different areas; locally, they can be very high. 64

5.3.9 Some methods of fishing, such as bottom trawling and dredging, can cause physical damage to the seabed and surrounding area (see paragraph 4.4.12).

Figure 7: Coastal and Transitional Waters Classification
(Source: Scotland's Marine Atlas 65 )

Figure 7: Coastal and Transitional Waters Classification

5.4 Climate Change

5.4.1 In the marine context, climate change has been predicted to lead to an increase in water temperatures, rise in sea levels, changes in wave heights and changes to our coastlines. Since 1961, average temperatures in all parts of Scotland have risen for every season 66 and over the last three decades, sea-surface temperatures around the UK coast have also risen by approximately 0.7ºC. 67 At the same time, the seas are becoming more acidic, particularly those to the north and west of Scotland, as increasing amounts of atmospheric carbon dioxide are absorbed at the sea surface. This change in acidity is already causing concern for marine ecosystems and many organisms that share it 68 .

5.4.2 Sea levels around the UK rose by about 1 mm/yr in the 20th century (corrected for land movement), although it is estimated that recent increases has been higher than this. 69 Under projections from the UKCIP09 model 70 , further rises of between 12 and 76 cm are projected by 2095 71 , with the added potential for further adverse impacts on coastal areas and transitional waters. It should be noted that lower probability scenarios suggest this rise could be even greater.

5.4.3 Changes to sea levels, increased wave height and storm surges could have serious repercussions for the marine and coastal environments, and the many industries operating in them. Even now, climate change is already impacting on the marine environment, and increasing the vulnerability of some habitats and species to future pressures.

Impacts of climate change on fisheries

5.4.4 Changes in the climate could result in a shift in distribution and changes in the abundance of fisheries through a loss of certain habitats and species, changes in species, changes in species migration and impact on breeding cycles and food supplies. Climate change may also favour some species leading to, for example, increased diversity of seabed marine life due to the warming of the air and seawater temperatures. 72 Risks from pests, diseases and invasive species may increase. There may also be a decline in ocean primary production and the effects on increased ocean acidity. 73

Vessel fuel emissions

5.4.5 Carbon dioxide ( CO2) is the primary greenhouse gas emitted through human activities. The main human activity that emits CO2 is the combustion of fossil fuels (coal, natural gas and oil). Red diesel is used by the majority of fishing vessels (also known as marine diesel or gas oil). There are 2,095 vessels in the Scottish fleet and 68% of them (1,415) fish in the inshore area. The predominant fishing method used is static gear (pots and creels) with 1,042 (74%) operating with static gear only, 264 vessels (19%) operating mobile gear only and 109 (8%) using both types of gear. 74

5.4.6 Greenhouse gas emissions from the fishing fleet are influenced by a number of factors including abundance of fish (stocks), the steaming distance to fishing grounds and the technology used. 75 For example, there are 105 Nephrops trawlers of an average length of 15m and under 250 kW (engine size) operating in the west of Scotland. On average, vessels consumed 390 litres of fuel per day at sea costing £158 per day. 76 There are 993 vessels under 10m using pots and traps (based at ports in the UK). On average vessels consumed 134 litres per day at sea costing £54 per day. 77

5.5 Cultural Heritage

5.5.1 Given Scotland's geographical position on a nodal sea route linking northern Europe with the world, its seas have historically also been of international importance. 78 A wide range of archaeological sites can be found on the foreshore and seabed, ranging from the remains of ships and aircraft lost at sea to harbours, lighthouses and other structures at the coastal fringe. These historic assets are a non-renewable resource, and their survival is conditioned by a complex interplay of natural and man made factors.

5.5.2 Coastal erosion poses a major threat to archaeological sites in many areas, a threat that likely to be exacerbated given predictions of the likely effects of global warming ( i.e. sea level rise, increased intensity of storms, erosion and risk of flooding). However, man-made activities such as anchoring, certain types of fishing, and coastal and marine development are also known drivers of change in the marine historic environment. 79

5.5.3 Many sites lie wholly within the marine environment; however, it is believed that there are many more unprotected sites of interest on and around the coastline. 80 The Orkney and Shetland coasts, in particular, contain many Neolithic and Mesolithic structures that are now below sea level. As such, Scotland's seabeds and inter-tidal areas contain the remains of many important historic assets, ranging from artefacts and structures deposited on the seabed, structures built on the seabed or in inter-tidal areas, and submerged sites that were previously above sea level.

5.5.4 While the survival of prehistoric remains is likely to be mainly focused in the sheltered sea lochs and enclosed bays of the east coast of the Shetlands, Orkney and Fair Isle 81 , and in submerged caves and gullies, the following potential locations for the survival of prehistoric archaeological material on the seabed have also been identified 82 :

  • On the shelf to the west of the Hebrides.
  • The Hawes Bank and seabed around Coll and Tiree.
  • Around Islay, Jura, Colonsay and Oronsay.
  • The Rum and Canna coastline.
  • In sheltered inlets and reaches to the east of the Hebrides.
  • In sheltered inlets around Skye.
  • On submerged islands located between the Northern Irish coast and the south Hebridean islands.
  • In the sea to the east of Orkney and Shetland.
  • Off the east coast of the Scottish mainland.

Designated sites

5.5.5 While the number of heritage assets within the marine environment is significant, there are relatively few that have been afforded statutory protection through designation. At present Scotland has 34 statutory designated sites wholly within the marine environment. These include eight designated wreck sites around the coast, nine scheduled monuments including seven wrecks in Scapa Flow, four listed lighthouses and 13 sites designated under the Protection of Military Remains Act 1986. 83 Several battlefields have also been identified in coastal locations.

5.5.6 Coastal sites include World Heritage Sites (St Kilda and the Heart of Neolithic Orkney), scheduled monuments, gardens and designed landscapes, archaeological remains, listed buildings and other sites located in conservation areas. 84

5.5.7 The Marine (Scotland) Act 2010 85 provides for the designation of Historic MPAs. The designation process will include a review and transition of existing designated wreck sites and underwater scheduled monuments to MPA status and identification of further priority sites, in line with guidelines and criteria drawn up by Marine Scotland. Further guidance on the management of changes within MPA sites is also currently being progressed.

5.6 Evolution of the Environmental Baseline without the Management Proposals

5.6.1 The management proposals include measures to be taken forward at a national level with regard to the management of inshore fisheries and will therefore be a key delivery mechanism for such management. The majority of the proposed measures relate to the management of fisheries, and have the potential to promote sustainable stocks and healthy ecosystems. In the absence of the management proposals, over-fishing of some of the species that are close to being, or currently are, over-exploited is likely to continue; stocks of edible crabs, for example, are currently over-exploited in some areas.

5.6.2 Damage to benthic habitats, particularly from bottom trawling and dredging, is likely to continue, with or without the management proposals. There are likely to be some indirect benefits from proposed measures to continue to seek sustainable fisheries accreditation.

5.6.3 Current trends regarding the ecological status of some water bodies are likely to remain the same in the absence of the management proposals. The same applies to the historic environment.

5.6.4 Current climate change trends may continue in the presence or absence of the management proposals. Much depends on the realisation of other activities aimed at the mitigation of, and adaptation to, climate change, e.g. CO 2 emissions from terrestrial transport systems. The management proposals do not seek to address climate change, in terms of adaptation to changing conditions. However, they do include measures to improve fuel efficiency.

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