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.

3 Overview of findings

3.1 This chapter presents a brief overview of the views expressed in response to the consultation. It outlines the main perspectives of respondents and highlights key themes and areas of agreement and disagreement in the responses.

Responses to the consultation

3.2 The consultation received a total of 4,502 responses. These comprised 2,458 personalised responses and 2,044 campaign responses.[9] Most of the campaign responses (99%) were prompted by a campaign organised by Scottish Environment LINK, an environmental organisation. The remaining campaign responses (1%) were submitted in response to a Shetland-based campaign.

3.3 The large response to this consultation indicated a high degree of interest in this topic, and a willingness to engage with the Scottish Government. It should be noted, however, that there were widespread criticisms about the consultation process, the consultation questions – which respondents found complex and difficult to understand – and the way that views had been sought on the proposals. These views were expressed mainly by respondents who were opposed to the proposals, but also by those who supported them.

Overall balance of opinion on HPMAs[10]

3.4 All those who submitted a campaign response and the vast majority (more than 95%) of those who submitted a substantive response expressed a clear view either in support of, or against, the introduction of HPMAs. There were two main groups:

  • 55% of respondents supported the introduction of HPMAs (note that a large majority of the respondents in this group submitted Scottish Environment LINK campaign responses)
  • 43% of respondents opposed the introduction of HPMAs (note that almost all the respondents in this group submitted a personalised response to the consultation).

3.5 The remaining 2% of respondents held neutral views – that is, they did not express clear support for, or opposition to, the introduction of HPMAs. This suggests highly polarised views among respondents, with one group very firmly in support of the introduction of HPMAs, one group firmly opposed, and very few holding neutral or ambivalent views.

3.6 However, this apparent polarisation masks a great deal of common ground shared by respondents in relation to the importance of protecting the marine environment and marine ecosystems – as well as agreement on many aspects of how that might be achieved.

3.7 The main arguments made both for and against the introduction of HPMAs are briefly summarised below. This is followed by a summary of the main areas of consensus about how policy on this topic should be developed.

Arguments in support of the introduction of HPMAs

3.8 Those who supported the introduction of HPMAs did so because they saw an urgent need to intervene to protect the habitats of species that are in decline and / or are critically endangered. This group also pointed to national and international evidence indicating that high levels of marine protection are effective in improving marine biodiversity. However, alongside their broad support for HPMAs, this group also expressed a range of caveats. Many of these related to the potential for HPMAs to have significant adverse impacts on local communities – and the need to mitigate these impacts by involving local communities in the process of developing HPMAs. They also expressed the view that HPMAs were likely to be ineffective unless they formed part of a coherent wider spatial management plan for Scotland’s seas.

Arguments against the introduction of HPMAs

3.9 Those who opposed the introduction of HPMAs often stated their commitment to marine conservation but did not think HPMAs provided an appropriate mechanism for addressing the issue. They gave a number of reasons for their views: (i) there was no scientific justification for establishing HPMAs, (ii) the proposal to set aside 10% of Scotland’s seas for HPMAs was both arbitrary and disproportionate, (iii) the policy would have unacceptable social and economic impacts on island and coastal communities, (iv) there had been inadequate engagement with stakeholders in developing the proposals, (v) HPMAs were inconsistent with a range of other Scottish Government and / or international policies, and (vi) the timescale for putting HPMAs in place (by 2026) was unrealistic and incompatible with good policy-making.

Areas of consensus in relation to future policy development

3.10 The main areas of consensus between those supporting and those opposing the introduction of HPMAs are set out below.

  • Communities must be directly involved in the process of identifying, developing and managing marine conservation measures. The process of involving communities will take time; it is highly unlikely this can be achieved within the timescale proposed by the Scottish Government for establishing HPMAs.
  • Any measures need to be clearly evidence-based, monitored and enforced.
  • There needs to be an appropriate balance struck between conservation needs and the needs of local communities. There needs to be a just transition.
  • Marine conservation measures, including HPMAs, need to sit within a coherent marine management plan. They should also be consistent with other related national and international legislation, policies, and strategies.
  • Blanket bans on human activities should be considered carefully, and distinctions should be made in the management of high and low-impact activities. In the fisheries sector, low-impact fishing should be incentivised and supported. High-impact fishing should be restricted and carefully managed.


Email: HPMA@gov.scot

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