| Objective 1
- The best public value approach to the use of assets and its application to fishing rights was welcomed by one respondent.
- Paragraph 53 – a respondent posed some questions and called for greater clarity regarding the example noted in the consultation paper around the sale of a small area of foreshore to the local community for less than market value. The questions posed were: a) does this mean that a sale of a small area with little impact on the Estate as a whole is more likely to be granted?; b) to what limit?; c) many small sales could account for a large area of the Estate? Will small area/value sales/leases consider Estate sales already agreed that month, year, within the five years or overall?
- Further, another respondent highlighted that community groups have had experience of wider community and sustainability benefits clearly being demonstrated but not taken into account in lease arrangements. This respondent supported a proposal for a 'Community Organisation Support Exemption' and the development of clear, consistent and fair policies in terms of working with communities.
- A respondent suggested that there could be consideration of not-for-profit community groups managing assets. It was further reported that these groups provide vital local services, cannot compete with commercial developers and should not be charged commercial lease charges (e.g. a concessionary lease for not-for-profit asset managers could be developed and implemented).
- One respondent commented that reference to the Monarch "owns" the assets was inaccurate and should be deleted.
- Paragraph 57 – a business case should support any sale.
| Objective 2
- The fact that Objective 2 safeguards a single entity approach to seabed leases was welcomed by one respondent. It was reported that this would help prevent competitive allocation of leases that disregard environmental considerations and allowing re-siting of existing fish farms.
- A few respondents welcomed confirmation that the seabed is a national strategic asset that Scottish Ministers does not wish to become fragmented. One went on to suggest that Scottish Ministers are asked to ensure that any sales of coastal or foreshore assets are assessed to ensure that they would not hamper the development of Carbon Capture and Storage.
| Objective 2 (cont'd)
- A respondent commented that seabed sales must be permitted where they are required to facilitate a major development that is going to benefit the wider community (e.g. the purchase of seabed to facilitate the financing of a Deep Water Port development).
- It was proposed that the Plan should recognise and facilitate the aspirations of coastal community landowners who wish to become managers of the adjacent seabed out to 12 nautical miles. Here, it was emphasised that the sea is an "intrinsic and inseparable part of community life in the Scottish islands and just as important as the land".
- Clarity was called for regarding whether "opportunities to increase value to Scotland" includes environmental value or environmental wellbeing.
- This objective discusses the disposal of an asset with Ministerial approval (e.g. seabed). However, it does not set out here that the asset could be sold (e.g. seabed), but that the activities within that asset (e.g. cabling) could be retained.
- Paragraph 57 – a business case should support any sale.
| Objective 3
- The reference to "island proofing" was noted by one respondent who added that this is a statutory duty, and not something which Crown Estate Scotland (Interim Management) can choose to do or not do.
- This objective sets out the requirement for management plans. However, there is no definition as to how these plans will account for National or Regional Marine Management Plans (only the National Islands Plan is mentioned – Para 62).
| Objective 4
- Paragraph 64 – one respondent agreed that a manager must have regard to the likely effect on the overall value of the Scottish Crown Estate when developing policies around community empowerment for the estate. It was suggested that this could be considered in terms of whether any change will improve outcomes or at least sustain the principles of the vision (i.e. financial benefit, and the wider long term social, economic and environmental benefits).
- Paragraph 64 and 72 – another respondent commented that despite the strong appetite of many island communities to be recognised as key stakeholders, Crown Estate decisions can often seem to be taken at a very remote distance from the people and places most directly affected by change.
- Paragraph 64 – another respondent commented that an arbitration or appeals procedure might be an appropriate adjunct to the Plan.
| Objective 4 (cont'd)
- Paragraph 64 - managers should also take account of local policies and strategies such as locality plans and Local Outcome Improvement Plans. Consideration should also be given to local and regional energy strategies.
- Paragraph 65 – reference to the expectation that it would be "standard practice" for a manager of an asset to involve the local community and support requests to purchase/manage assets was welcomed by one responded.
- Paragraph 65 – the manager should engage in the same way as any other relevant body in considering community transfer of participation requests.
- A respondent felt that new managers or owners should be supported with advice and guidance on their responsibilities for environmental protection and management, in order to maximise the benefits the estate provides.
- A respondent supported the notion of community empowerment through management of assets, but emphasised that the process should be made as simple as is possible, that it should allow local decision making, and that sufficient safeguards should be put in place to ensure any environmental benefits gained from previous management are not lost under new management.
| Objective 5
- A respondent commented that it would be important for holistic and joined up discussions on ports and harbours to take place, including consideration of the infrastructure needed around the Scottish coast to ensure the best facilities are available for the whole fishing fleet to continue producing world leading food.
- It was suggested that there could be value in investment to enhance east coast port facilities in the expectation of Scotland eventually regaining major maritime trading traffic with the EU.
- It was suggested that the Plan should contain specific provision for facilitating carbon-free shipping (Hydrogen production from Renewables in ports), expansion of Floating Offshore Wind and commercialisation of Wave Energy
- A respondent felt that the potential for growth in aquaculture could be mentioned (i.e. the need for innovation to address current issues of pollution and sustainability e.g. overfishing of 'cleaner fish' such as wrasse).
| Objective 5 (cont'd)
- A respondent felt that the sustainability of island communities may better be served through successful initiatives to harness low carbon energy resources locally than by large scale strategic developments designed to turn a profit for remote shareholders. They added that blue growth presents many opportunities and the potential of conflicting ambitions across assets that are shared over different areas, organisations and communities. They added that development should not be at the expense of the marine environment, and that the views of local communities most directly affected by strategic projects concerned with energy transition or aquaculture should always shape developments.
| Objective 6
- Paragraph 74 – one respondent welcomed recognition that the Scottish Crown Estate can make a significant contribution to the regeneration of coastal areas. The respondent, however, felt that there could be a more explicit commitment to supporting community-led regeneration.
- While the Climate Change Plan is mentioned and welcomed, a respondent felt that the wording does not suggest it is a priority. It was suggested that this could be re-written as follows: "Managers should consider the potential for investments that contribute to the achievement of Scotland's Climate Change Plan and Climate Change Adaptation Plan". Another respondent commented that the Scottish Crown Estate has a major role to play in decarbonising Scotland's industry and achieving net zero greenhouse gas emissions, and that this should be further emphasised.
- A wider comment related to the Climate Change Plan was that while it is not that there needs to be consideration of the potential for investments that contribute to the achievement of the Plan, it was felt that there was little detail or guidance on how this could be achieved.
- The same respondent commented that in terms of the objectives for community-led regeneration, it would be helpful to highlight that investing in the restoration of peatland, native woodland and also blue carbon habitats could help to store carbon and contribute to climate change mitigation. And that increasing the resilience of habitats to allow natural adaptation to climate change, particularly at the coast, could help to provide wider benefits to communities such as flood and erosion protection.
- A respondent noted that restoring biodiversity (species and habitats) as well as ecosystem functions can play a key role in achieving Objective 6.