Highly Protected Marine Areas (HPMAs): consultation analysis - final report

Analysis report on the responses to the consultation on Scottish Highly Protected Marine Areas (HPMAs) which ran from 12 December 2022 to 17 April 2023.

Annex 7: Views on individual functions and resources as a basis for site selection (Q8)

This annex presents further detail on respondents’ views on the functions and resources that would form the basis of site selection, as set out in the draft site selection guidelines.

The draft site selection guidelines presented a list of seven functions and resources identified as being of significance to Scotland’s seas that would be used in identifying potential HPMA sites. Question 8 asked for views on the functions and resources used in site identification.

Question 8: What is your view of the proposal that HPMA site identification should be based upon the “functions and resources of significance to Scotland’s seas”, as listed below and set out in Annex B of the draft Site Selection Guidelines? [Strongly support / Support / Neutral / Oppose / Strongly oppose]

  • Blue carbon
  • Essential fish habitats
  • Strengthening the Scottish MPA network
  • Protection from storms and sea level rise
  • Research and education
  • Enjoyment and appreciation
  • Other important ecosystem services

Please explain your answer in the text box, including any suggested changes to the list.

Chapter 5 presents a high-level overview of the comments from respondents in response to this question. This annex presents a more detailed summary of the comments on each of the individual functions and resources.

Blue carbon

Those who supported the inclusion of ‘blue carbon’ argued that carbon storage was a key component in climate change mitigation, and that marine sites fulfilling this function should be protected from potentially damaging activities. Some said this was the most important function or resource in identifying HPMA sites. It was also argued that taking steps to protect blue carbon sites would enhance the environmental quality of Scotland’s seas more generally by increasing biodiversity and creating the foundations for stable ecosystems.

However, some broadly supportive respondents nevertheless raised issues related to definitions and evidence, saying, for example:

  • That there was a need to be clear about terminology, with some arguing for the protection of blue carbon ecosystems rather than the protection of blue carbon, as currently worded, and
  • That this was a new area of science with methodologies still being developed and that this should be recognised in any decision-making process.

Environmental organisations in particular highlighted the role of cetaceans (whales, dolphins etc.) in blue carbon storage and the importance of protecting these species within any environmental measures.

Those who disagreed with the inclusion of blue carbon generally argued that there was insufficient knowledge and understanding of blue carbon for this to be used as part of the decision-making process. Respondents in the fishing and aquaculture sectors were particularly likely to offer views of this type, stating repeatedly that there was no evidence on where blue carbon is, what it is, or how it is affected by fishing, aquaculture or other activities. This group also argued that sustainable fishing and aquaculture practices would have minimal or no impact on blue carbon sites. Such respondents also pointed out perceived contradictions in (i) taking steps to restrict low-impact fishing activity in order to protect blue carbon while also allowing the construction of windfarms and associated cabling infrastructure which disturb the seabed, and (ii) restricting aquaculture activities when shellfish beds have the potential to act as blue carbon stores.

It was common for individuals to say that they did not know what ‘blue carbon’ was or to describe it as a ‘woolly’, ‘poorly understood’ or ‘unproven’ concept.

Essential fish habitats

Some respondents – environmental organisations and some individuals in particular – used their comment to express broad support for the inclusion of ‘essential fish habitats’; some expressed strong support and said that this criterion should be the priority in site identification. Some welcomed the ecosystem- and habitat-based rather than species-specific approach.

However, it was also common for respondents in this group to stress the importance of the criterion being clearly defined and / or being explicitly phrased to include the protection of all marine life (e.g. fish, forage fish, shellfish, seabirds, cetaceans) given the varying and important roles of different species in maintaining healthy ecosystems. There was also some concern about whether the available evidence base would allow the identification and effective monitoring of essential habitats.

Those who indicated opposition to or reservations about this item included fishing and aquaculture organisations and individuals. Their comments focused on two main issues:

  • They argued that essential fish habitats are already protected under the current MPA arrangements, and that these should be assessed before determining the need for further protection.
  • They said that evidence on the location and current state of habitats and how protection would be addressed by HPMAs had not been presented, and / or that current knowledge and modelling on habitats and species behaviours was not adequate for making decisions about the introduction of HPMAs.

Additionally, some in this group said the term ‘essential fish habitats’ was vague and needed to be clarified – echoing the views of respondents who expressed support for its inclusion. In addition, in contrast to the views discussed above, some thought that conservation efforts should be focused on specific habitats and species to be successful.

Strengthening the MPA network

Those broadly supportive of including ‘strengthening the MPA network’ as a site identification criterion thought the creation of HPMAs would:

  • Expand and add to existing protected areas in Scotland’s waters
  • Provide increased protection of key locations within existing MPAs
  • Fill gaps and increase connectivity between sites in the existing MPA network
  • Complement the existing MPA network and its focus on protecting particular identified features by delivering broader ecological protection and recovery.

However, respondents in this group stressed the need for effective management of both MPAs and HPMAs.

Those indicating opposition to the use of this criterion generally argued that:

  • MPAs already provide good levels of environmental protection, and there is no evidence they need strengthening.
  • MPAs provide good levels of protection, and their marine conservation role could be further enhanced without the creation of HPMAs – the development of the Welsh MPA network was cited as an example of how this could be done.
  • Efforts should be put into ensuring the success of existing MPA sites before developing new levels of protection.
  • Consideration of the need for HPMAs should await further information from the ongoing review of Scotland’s MPA network – recent reports were said to have shown positive results, with the network review due in 2024.

In a few cases, respondents (including environmental organisations, businesses, and some individuals) argued that current MPA sites were not well managed and queried how the introduction of HPMAs would strengthen the network.

Respondents also offered a range of comments on the relationship between existing MPAs and the newly proposed HPMAs.

Those who were broadly supportive of the introduction of HPMAs generally favoured HPMAs being located in new areas rather than within or overlapping with existing MPAs. This view was also expressed by those who took part in the Scottish Environment LINK campaign which argued that ‘HPMAs should focus on providing site-based protection outwith the existing marine protected area network’. Respondents in this group argued that HPMAs should not be used to deliver on existing MPA conservation objectives, with some suggesting that any significant overlap with existing sites should require the identification of an alternative MPA elsewhere.

In contrast, other respondents favoured locating HPMAs within, overlapping with or adjacent to MPAs, arguing that this approach:

  • Could allow MPAs to act as helpful buffers around HPMAs
  • Made sense as MPAs contained areas that were already identified as requiring protective measures
  • Would limit the reduction in areas available for commercial fishing and other activities.

There was also some concern that existing MPA sites may be favoured to become HPMAs without full consideration of community impacts, and that this could lead to a concentration of HPMAs in the Outer and Inner Hebrides.

Protection from storms and sea level rise

Some respondents – mainly environmental organisations and individuals – were positive about the inclusion of ‘protection from storms and sea level rise’ as a site identification criterion, noting, for example, the beneficial role of some marine habitats in reducing coastal erosion. However, alongside this, there was widespread doubt or scepticism among other respondents about how and to what extent the creation of HPMAs in Scottish waters could contribute to addressing such issues and mitigate weather- and climate-related challenges.

Research and education

Those supporting the inclusion of ‘research and education’ as a basis for site identification said that monitoring and evaluation in HPMAs would allow the study of natural ecosystems, and be important to long-term site success, and that research and education provided opportunities for engaging with local communities.

Those offering more qualified support said that, while research and education were important, they were unclear how this could be a factor in site identification and selection, or they did not think that this should be a key criterion.

Those expressing greater reservations or opposition queried the justification for inclusion of research and education as a factor in site identification. They said that ample research and education opportunities exist under current arrangements, and that any benefits associated with research and education activities would be outweighed by wider negative community impacts.

Enjoyment and appreciation

Those indicating support for the inclusion of ‘enjoyment and appreciation’ did not often explain their views. Some did, though, call for consideration of this resource to take account of enjoyment and appreciation linked to low-impact recreational activities such as fishing, windsurfing / kiting and marine tourism – all activities which these respondents thought should be allowed to continue in HPMAs.

Others expressing opposition to or reservations about the inclusion of enjoyment and appreciation argued that this:

  • Was lacking in clarity, and was subjective and difficult to measure
  • Could not be justified against the likely negative social and economic impacts of HPMA designation for local communities – there was concern that the inclusion of enjoyment and appreciation suggested that potentially damaging tourism was being prioritised over low-impact fishing, and that the interest of non-local stakeholders would be prioritised over the interests and needs of coastal communities
  • Should not be weighted highly in the assessment process and / or should not be favoured over conservation and climate change objectives.

Some respondents acknowledged that enhanced enjoyment and appreciation could potentially result from the creation of HPMAs but were unsure how this could be used in the site identification process.

Other important ecosystem services

Those expressing varying degrees of support for ‘other ecosystem services’ as a criterion for identifying possible HPMA sites included environmental organisations and individuals. These respondents welcomed the recognition of the links between the marine environment and human wellbeing in particular, although some argued that this should be considered a potential benefit of HPMA designation rather than a basis for identification and selection. Some respondents in this group highlighted the marine food chain and the role of seagrass, algae and shellfish in filtering and regulating water quality as important ecosystem services.

Most often, those expressing opposition to or reservation about the inclusion of other ecosystem services queried the concept, describing it as undefined, and potentially applying to all coastal areas. Respondents said that this could result in inconsistent decisions about HPMA designation. In other cases, respondents in this group commented on the issue of wellbeing, stating that they did not see any wellbeing advantage associated with potential HPMAs compared to other marine areas, or arguing that, while wellbeing was important, it was generally linked to economic prosperity which would be put at risk by HPMA sites.


Email: HPMA@gov.scot

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