Scottish Crown Estate draft strategic management plan: consultation analysis

Analysis of the responses received to the consultation on the draft Strategic Management Plan for the Scottish Crown Estate.


Executive Summary

This Executive Summary presents the main messages arising from the consultation on the draft Strategic Management Plan (the Plan) for the Scottish Crown Estate.

The development of the first Plan for the Scottish Crown Estate marks an important milestone within a wider programme of work to secure devolution and reform of the management of the Scottish Crown Estate.

The Smith Commission (2014) recommended that the management of Crown Estate assets in Scotland and their revenues should be devolved to the Scottish Parliament. This was done through provisions in the Scotland Act 2016 on the 1st April 2017.

An explicit commitment was made by Scottish Ministers to develop proposals to reform the long-term management of the Crown Estate in Scotland. The Scottish Crown Estate Bill 2018 was subsequently introduced to the Scottish Parliament in January 2018. Crown Estate Scotland (Interim Management) was established to manage the assets, ensuring a smooth transfer for staff, tenants and other stakeholders. Its core purpose is to invest in property, natural resources and people to generate lasting value for Scotland.

The Scottish Crown Estate Act 2019 was granted Royal Assent on the 15th January 2019. It provides a new legislative framework for the management of Scottish Crown Estate assets.

The consultation sought views on the Plan: its vision, objectives, priorities and policies, as well as the ways in which it can be routinely monitored. Once finalised, it will be laid before the Scottish Parliament.

A total of 34 responses were received to the consultation.

Table 1: Summary Analysis Table

Questions Assessment of Feedback Main Comments For and/or Against
Q1 - Are the opportunities to contribute to sustainable development appropriate for the Scottish Crown Estate? Vast majority agreed
  • Explicit commitment placed on sustainable development was welcomed.
  • Agreement that the sustainable management of the diverse portfolio of assets should be a key consideration in decision-making processes.
  • Respondents were reassured by the definition used and the examples provided.
  • The proposal that a flexible ("unique") rather than a one-size-fits-all approach to decisions on sustainability was considered a sensible approach.
  • A concern raised, but not by many, was that that environmental wellbeing could be "out-ranked" in decision-making processes by economic or social considerations. A greater emphasis on community empowerment was also mentioned by some respondents.
Q2 - Do you feel that the vision in the draft Plan meets your expectations for the Scottish Crown Estate for the next five years? Vast majority reported that expectations were either fully or partially met
  • Feedback confirmed a positive strategic direction, strong alignment with the National Performance Framework, and support for the commitment to involving and empowering communities. However, there was a strong sense that economic or monetary benefit should not have priority over the wider benefits of social and environmental wellbeing.
  • Some felt, however, that the vision could be strengthened.
Q3 - Do you believe that the objectives, priorities and policies contained in theme 1 will allow us to achieve our vision for the future management of the Scottish Crown Estate? Vast majority agreed
  • Much of the feedback confirmed the close alignment between the theme 1 objectives, priorities and policies and the Plan's vision statement, and contribution to key policy areas (e.g. climate change, community empowerment, land reform, community-led regeneration).
  • Some feedback that there could be a stronger commitment to supporting and involving communities. Also that there could be stronger and more explicit linkages to, for example, City Growth Deals and National Islands Plan.
  • Various comments around the term "equivalent scale", including that it would need to be further defined, and some concern that non-economic benefits can be difficult to quantify, and that in some cases economic benefit would be the priority.
Q4 - Do you believe that the objectives, priorities and policies contained in theme 2 will allow us to achieve our vision for the future management of the Scottish Crown Estate? Vast majority agreed
  • Strong support for the proposal that a "one-size-fits-all" approach would not be practical given the diversity of the Scottish Crown Estate assets. Flexibility was considered key.
  • Both national and local bodies expressed support for increased opportunities for local control, management or enhanced input to decision-making through opportunities for transfer, delegation or pilots. Efforts to take account of the ambitions of local communities, a commitment to greater levels of local control and enhanced input to decision-making were all welcomed.
  • Some concerns raised regarding the extent to which complexity of reporting arrangements could deter communities from taking on the management of an asset(s), and that communities might not have meaningful input to decisions regarding local assets.
Q5 - Do you believe that the objectives, priorities and policies contained in theme 3 will allow us to achieve our vision for the future management of the Scottish Crown Estate? Vast majority agreed
  • Support for the proposal that all of the net revenue from the estate should be used for the benefit of Scotland, in particular coastal communities (i.e. coastal communities should benefit from net revenue from marine assets out to 12 nautical miles).
  • Accountability and transparency in decision-making processes were said to be important in helping to ensure that coastal communities benefit. The importance of having appropriate processes and mechanisms in place to ensure that the management of Scottish Crown Estate assets does not become fragmented was emphasised.
Q6 - Do you feel the objectives, priorities and policies will deliver success to the Scottish Crown Estate? Vast majority agreed
  • Some comments that the term "success" would need to be defined, and take due consideration of socio-economic benefit and environmental wellbeing.
  • A wide variety of feedback provided, including that success would depend on having inbuilt flexibility in the Plan's implementation and delivery, and the importance of communities as key stakeholders in coastal developments.
Q7 - Do you feel there are other opportunities for revenue generation that have not been identified in the draft Plan? Less than half felt there were other opportunities
  • A wide range of individual comments provided. These range from scope to more closely link the Scottish Crown Estate to developments included as part of Growth Deals to carbon offset projects, and from payments for delivering public good to opportunities that seek to improve the resilience, efficiency and productivity of rural estates.
Q8 - Do you feel the objectives, priorities and policies will impact you positively, negatively or have no impact on you as an individual or as part of an organisation? Majority reported that the impact would be positive
  • The potential to generate considerable income to meaningfully engage and empower local communities, and to support community projects and programmes was mentioned in a few cases.
  • A variety of wider positive impacts were mentioned, including increased influence and sense of local ownership, and more sustainable management and use of Scottish Crown Estate assets.
  • Where the impact was reported to be negative, some concerns were raised including that benefits might not be retained within local communities, and that a loss of local control in decision-making risks disillusionment with the process. A further concern was the potential administrative burden that could be placed on communities.
Q9 - Do you feel the objectives, priorities and policies align and take account of wider Scottish Government objectives? All respondents reported either fully or partially
  • Much of the feedback expressed support for the aims of the Plan and its aspiration to more fully involve communities in the management of individual assets.
  • Some respondents called for closer links to be made between the Plan and wider strategies and plans, namely the Land Use Strategy, Growth Deals, National Planning Framework, Local Development Plans, emerging Regional Spatial Strategies, National Islands Plan, Island Community Impact Assessments, National Marine Plan, Climate Change Plan, Climate Change Adaptation Plan/Programme, and priorities related to the historic environment.
Q10 - Do you have any comments or additional suggestions on the arrangements for monitoring and review of the Plan? Majority provided comment
  • It was felt that there should be explicit reference to engagement with stakeholders and the public as part of the monitoring and evaluation requirements (and this should also be reflected in the suite of indicators developed).
  • The arrangements were felt to be relatively high level, and there would need to be further development work undertaken and more detail provided on the process and a common set of outcomes and indicators.
Q11 - Would you add or change anything in the Business and Regulatory Impact Assessment? All reported that they would not add or change anything
Q12 - Would you agree that the Business and Regulatory Impact Assessment is wide ranging enough? Majority agreed
  • No significant wider feedback was provided to this question.
Q13 - Do you have any views on the evidence set out in the Strategic Environmental Report? Majority did not have any views on the evidence
  • Where respondents did provide views on the evidence, a long list of individual points were raised.
  • Examples include that there could be reference to the State of Nature 2019 report and the Intergovernmental Science Policy Platform on Biodiversity and Ecosystems Services (IPBES) report as references to the condition of biodiversity in Scotland and more broadly. There was also a perceived lack of clarity in relation to the historic environment where undesignated but known sites were omitted from the text and figures in the Strategic Environmental Report.
Q14 - Do you agree with the conclusions and recommendations set out in the Strategic Environmental Report? Majority agreed
  • Few comments were provided by those in agreement. Individual comments were that there could be greater links to the Climate Change Plan, and of the benefits associated with building maintenance and improvements within the historic environment (and contribution to place-making).
Q15 - Do you have any comments to make on our Equality Impact Assessment? Vast majority did not have any comments to make
  • No common themes emerged where feedback was provided.
Q16 - Please tell us about any possible impacts the proposals contained in this consultation document may have on groups of people with protected characteristics. -
  • Few comments were provided to this question, and no common themes emerged.
Q17a - Do you agree with the conclusions for the Island Communities Impact Assessment? Majority agreed
  • Few comments were provided by respondents who expressed agreement. The only comment provided was that any impact assessment should not be a tick-box exercise.
  • Individual comments were mentioned by those not in agreement. Comments included a perception that the formula presented for return of Crown Estate revenues discriminated against islands who are most impacted by a high level of marine development activity. A wider comment was that the public consultation mechanisms were flawed and should be reviewed.
Q17b - Do you agree with the conclusions for the Child Rights and Wellbeing Impact Assessment? Majority agreed
  • No comments were provided by those respondents who agreed with the question.
  • Individual comments were provided by a couple of respondents who did not agree. One respondent commented that the document was not available to review, and another felt that it was a time-wasting and superfluous measure.
Q17c - Do you agree with the conclusions for the Fairer Scotland Duty Impact Assessment? Vast majority agreed
  • Very few comments were provided to this question.
  • Comments included that impact assessments should not be a tick-box exercise, and another said that the document was not available for review.
Q17d - Do you agree with the conclusions for the Data Protection Impact Assessment? Vast majority agreed
  • Very few comments were provided to this question.
  • One respondent commented that the document was not available for review.
Q18 – Do you feel there are any other Scottish Government policies which should be taken into account? Majority answered no
  • Only a few respondents made reference to wider policies.
  • One respondent mentioned the importance of not losing sight of the Community Empowerment Act.
  • Another respondent felt that stronger links could be made with Growth Deals, National Planning Framework, and Local Development Plans, and emerging Regional Spatial Strategies.

Contact

Email: scottishcrownestate.consultation@gov.scot

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