Marine and coastal restoration plan: consultation analysis report

2. Theme 1 – Restoration opportunities and priorities

This chapter presents the analysis of responses to Q1 to Q3, which address Theme 1 of the plan: “Restoration opportunities and priorities”. This theme, which contains four objectives, focuses on improving understanding of where restoration could happen and what is in need of restoration most urgently. Respondents were asked how they would prioritise the objectives in Theme 1 and whether each action set out under this theme should be included in this plan, reserved for the future, or not included. Respondents were then asked if they had any further information they would like to share on the objectives or actions in Theme 1. This set of three questions was repeated for each of the five themes covered in Chapters 2 to 6 of this report.

At least 80% of those answering felt each objective in Theme 1 is important to some extent. Respondents considered the objective “Promote the importance of a place-based approach and baseline surveys” as most important, with 61% of those answering indicating this is ‘very important’. While 80% felt the objective “Establish a rolling programme of opportunity maps” is important to some extent, 41% indicated this was ‘very important’.

At least two thirds of those who answered felt that each of the actions in Theme 1 should be included in this plan, ranging from 83% who supported including “Set out priorities at national scale, while supporting regional partnerships and other local coalitions to identify regional priorities” to 67% who supported “Explore appetite for more localised and/or regional opportunity maps”. The only exception was the slightly lower level of agreement of 62% for the action “Review and update priorities using the criteria once established to ensure action is targeted where it is most urgently needed”.

Q3: Is there any further information you would like to share with us on the objectives or actions in this theme? This could include your reasons for selecting the answers to the previous two questions, or any further reflections on the overall content of the theme.

Four fifths of all respondents answered Q3. While most comments focused on Theme 1’s objectives and actions, some left general comments on this theme or used Q3 as their first opportunity to comment on the plan overall. These latter comments have been included in the analysis of responses to Q16, Q17 and Q18 in Chapter 7, which asked respondents for their views on the overall approach and content of the plan.

“We recognise the importance of all the actions outlined under this theme and agree that, in an ideal world, every element - comprehensive mapping, detailed baseline surveys, and full ecosystem-scale prioritisation - would be included from the outset.” – Individual

A recurring theme, raised by several respondents at Q3, was the lack of consideration for passive restoration or pressure management in the plan. A few of these comments related to Theme 1, with those points noted at the end of this chapter. Some respondents, particularly nature conservation organisations, made more general points about passive restoration in response to this and other consultation questions. These perspectives are detailed in Chapter 7 as part of the analysis of Q18, which focuses on views about what is missing from the plan.

Establish a rolling programme of opportunity maps

Several respondents commented on a programme of opportunity maps. When considering the need to “Develop opportunity maps for habitats and species, taking into account restoration priorities”, there was a broad consensus on the potential value of this approach. However, respondents also highlighted a range of suggestions and concerns that they felt should be considered to ensure opportunity maps are effective.

Positive comments on the creation of opportunity maps reflected that they could help support the coordination of restoration activity. Respondents felt that opportunity maps could be useful tools in helping community groups and restoration organisations identify areas with restoration potential, determine which areas have the most restoration potential, support funding opportunities, ensure that activities are aligned with priorities and government strategy, and identify any potential areas of conflict with other marine users. It was also suggested that having official opportunity maps could help to encourage long-term investment in restoration activities from potential funders.

However, some respondents stressed the need to ensure that opportunity maps are neither prescriptive nor restrictive, either to restoration activities or other marine activities. Respondents cautioned that if these maps are interpreted as definitive or are based on incomplete or outdated data, they could inadvertently limit restoration opportunities or be misused in planning decisions. The risk of oversimplifying complex ecological systems was also noted, particularly if modelling is incorrect or not complemented by adequate on-the-ground evidence gathering or local expertise. There was also a concern that maps might not adequately reflect the connectivity and co-benefits of multiple species and habitats, potentially leading to fragmented or poorly targeted restoration efforts.

“It must be perfectly possible for sites to be taken forward even if they are outside the scope of the opportunity areas within the existing maps (so long as a good case can still be made for them). Local authorities or project opponents should not be able to challenge the siting of the project simply on the basis of it sitting outside the areas marked out on an opportunity map.” – Sunbird

“It is important to stress that spatial mapping should be used as a guide to inform restoration opportunities (as stated in the consultation) and not as a prescriptive tool that restricts other marine activities. It is important that mapping takes into account existing marine uses and recognises that suitable areas for marine development are already limited.” – Scottish Sea Farms

Some respondents called for opportunity mapping to be aligned with, or integrated into, broader work being undertaken as part of National Marine Plan 2 (NMP2) and Regional Marine Plans (RMP), to ensure a coherent approach with other marine planning policies. More generally, respondents advocated for transparency over the purpose, methodology, and limitations of opportunity maps. It was emphasised that maps should inform, but not override, local development decisions, and their impact on policy and planning should be closely monitored. For example, Salmon Scotland noted that “Following adoption, the plan could monitor the effect opportunity maps have in influencing local authority decisions, policy objectives in [Local Development Plans (LDP) / RMP], and supplementary guidance”.

“As the draft restoration plan notes, the policy landscape in this space is busy - and the proposals under this plan raise concerns that siloed planning exercises (including opportunity maps) are being created through different workstreams - when ideally, to minimise complexity and conflict, this should be brought together under one place in NMP2 and in turn, regional marine plans. This would also provide the perfect opportunity to outline the overall restoration priorities for Scotland’s seas as a whole, reducing the risk that this is only carried out for selected habitats/species in a piecemeal approach.” - The Sustainable Inshore Fisheries Trust

Comments about the second action, to “Gather and incorporate further data to refine opportunity maps and develop new layers”, were made by some respondents. These respondents typically advocated for opportunity maps to be regularly reviewed, updated as new data becomes available, and for the mapping process to remain flexible to accommodate new information and evolving priorities.

Some respondents suggested information or features they felt should be considered when developing opportunity maps. These included:

• Integrating aquaculture and restoration data to capture areas with strong larval supply, settlement potential, and ongoing management capacity
• Incorporating indicators of community interest and support, as it was felt that this could “help direct resources to areas with strong grassroots momentum”
• That maps should also highlight risks to restoration, such as invasive species, and consider other modelling about other species and activities in an area
• For mapping tools and data layers to be publicly accessible, easy for non-specialists to use, and have features that allow users to explore different data sets and contribute local insights
• Including the anchorage locations and the routes taken by recreational boaters
• That maps should be edited to exempt all Statutory Harbour Areas
• For maps to be in a similar format to the National Marine Plan Interactive (NMPi), “where different data layers such as Marine Protected Areas (MPAs) and climate change modelling can be toggled on/off”
• The use of drone mapping

“1. The spatial resolution of the maps should be sufficient to allow for individual site scoping. The resolution of the mapping should be relevant to the size of the restoration project… 2. Such maps should be integrated with existing [Marine Spatial Planning] (MSP) data layers to understand existing designations, uses, and active pressures in areas that meet ecological criteria for restoration. 3. The environmental parameters used to create the maps (such as temperature, salinity, benthic substrate, etc.) should be clearly accessible. The threshold values for individual species (such as the salinity tolerance of native oysters) should ideally be tunable within the mapping platform...” - The Scottish Association for Marine Science

A small number of respondents commented specifically on the draft opportunity map included in the draft plan, which they found unclear, confusing, and misleading, particularly regarding opportunities around Orkney and Shetland.

When commenting on opportunity maps, a few respondents indirectly reflected on the action to “Explore appetite for more localised and/or regional opportunity maps”. National-scale maps were seen as helpful in stimulating discussion and identifying broad areas of potential for restoration. However, respondents often commented that detailed, localised mapping is necessary for effective project implementation. In addition to community involvement, a few respondents noted that aligning maps with Scotland’s Regional Marine Planning Partnerships would be a good way to refine and apply opportunity maps at the local or regional scale (similar to the point about alignment with NMP2 above).

“Whilst I agree that improved site suitability mapping is necessary for many of the target restoration species, we lack data to produce very detailed site suitability maps. Instead of creating a detailed national map, it may be beneficial to focus on creating localised maps with all available information when specific groups/government bodies specify that they are interested in starting a restoration project in their area.” – Individual

Respondents felt that local knowledge and stakeholder engagement are essential to ensuring that opportunity maps are accurate, practical, and take a place-based approach. A few called for existing evidence and data from local projects and delivery organisations to be collected and utilised to develop maps as detailed as possible.

“SE LINK members would recommend that community groups should be involved in the mapping work as there has been some progress on this already. For example, the Community Led Marine Management Roundtable run by the Coastal Communities Network, Fauna & Flora and Esmee Fairbairn Foundation discussed at a recent meeting in June, mapping current or planned activities in Scotland. The Protected Areas Foundation is also currently mapping designated sites across the UK, along with the community groups working in that area.” – Scottish Environment SE LINK

Develop criteria for priority habitats and species

In addition to a small number of comments at Q3 which stressed the need for a clear strategic framework to guide restoration, several respondents reflected on this objective and the action: “Set out priorities at national scale, while supporting regional partnerships and other local coalitions to identify regional priorities”.

In general, respondents emphasised the importance of establishing clear priorities, with a few also noting that clear targets are necessary to evaluate whether those priorities had been achieved. However, there was little consistency in comments about priorities. A few respondents noted that there is sufficient existing data to develop priorities, and a few others emphasised the need to balance local, regional, and national priorities, with the latter two incorporating local priorities.

“We support the emphasis on identifying and prioritising opportunities for marine and coastal restoration. Clear national priorities will help guide investment and effort.” – Solway Firth Partnership

“Balancing national, regional and local priorities is of key importance in relation to the prioritisation of habitats and species for restoration. A one-size-fits-all approach, which mandates the restoration of habitats and species at a national level, will inevitably disenfranchise community interests and values, as well as place-based knowledge. There is a requirement for flexibility and local discretion with regard to any such prioritisation.” – Cooke Scotland

“Direction is urgently needed on what the priorities for marine restoration are and where it should go. The plan provides the opportunity to set the strategic direction, allowing maximum conservation benefit to be derived from restoration activities and helping to ensure that funding is used most effectively.” – Crown Estate Scotland

Orkney Islands Council called for the plan to include more detail about the process for setting and publishing any priority criteria:

“The background to objective 2 states that “a key objective for this plan is to develop a set of criteria to help us identify what the key priorities should be”. This is a vague statement, and it is unclear when these criteria will be published, and whether it will be within a review of this plan or separately. This is a major omission from this version of the plan.” – Orkney Islands Council

Only a small number commented on the action to “Review and update priorities using the criteria once established to ensure action is targeted where it is most urgently needed”, noting this must be included in the plan, and that there is a need to be flexible and open to ongoing change based on changing environmental priorities and feedback from projects.

Beyond this, several respondents suggested a range of factors they felt needed to be considered when prioritising areas for restoration. These included:

• Cost and benefit considerations
• Levels of risk and likelihood of success
• Whether exploratory or baseline surveys have been undertaken, and the extent of “restoration readiness” of a site, i.e. whether the supply chain has the capacity to support the activities
• Wider ecosystem functionality and environmental requirements, e.g. water quality, biodiversity uplift. One individual called for consideration of whether locations can “act as a catalyst for natural regeneration”
• Socio-economic potential, for restoration to provide raw materials, community projects, and jobs
• Local knowledge, for example, Scottish Seaweed Industry Association noted that “fishers, seaweed farmers, community groups hold ecological memory of past abundance that should shape mapping and baselines.”

A few respondents, particularly aquaculture organisations, highlighted specific areas, habitats or species they felt should be recognised as having restoration potential or considered as priorities. These included: estuarine systems; kelp forest regeneration; areas that are already well-defined as suitable for restoration; sites with the most degradation or loss of habitat, as these could offer the most significant biodiversity gain; considering cod as a key species in wider ecosystem restoration; and integration with other habitat restoration to create “mosaic benefits”. Conversely, Scottish Seabird Centre expressed a different view:

“Whilst there is a clear need to highlight those species that are facing immediate threats or extinction, there is a risk of overcomplicating this process with additional criteria/priorities. With 43% of Scotland’s species facing a decline in the last decade, and a 49% decline in seabirds between 1986 and 2019 (State of Nature Scotland, 2023), the focus of this plan should be encouraging action across all habitats and species, rather than limiting support to a narrow range of priorities.” – Scottish Seabird Centre

Regarding the element of the action focusing on supporting regional partnerships and other local coalitions, only a few respondents commented. These included calls to engage or partner with, for example, Regional Marine Planning Partnerships, regenerative aquaculture, The Berwickshire and Northumberland Marine Nature Partnership, and Local Coastal Partnerships. A small number requested that the plan provide more information about how these partnerships will be supported. Conversely, one restoration organisation felt that projects are already in contact with and supporting each other, and that “government facilitation of this may be too time-consuming and not something that should be prioritised”.

“It is also welcome to see that there would be encouragement for existing groups, for example, local coastal partnerships, Regional Land Use Partnerships, and local planning partnerships, to identify regional priorities for restoration, supported by more localised opportunity maps.”- Clyde Marine Planning Partnership

“It is important that Marine Planning Partnerships, or the most suitable group in the area to lead or advise on these projects e.g. Coastal Partnerships, are able to access national expertise to support them in this role, including input from national-level bodies including NatureScot and the Marine Directorate” – Orkney Islands Council

A few respondents, while acknowledging the value of historic information, expressed differing views on the extent to which it can be used to identify and prioritise sites:

“To help identify these areas, we need to look at historic records of what was being caught where, when and why, and seek to protect and restore these areas. There is evidence in place names, catch records, living memory etc. For example, we know that the Firth of Clyde was famous until recently for its diverse fishery and the Firth of Forth had 50 miles sq. of native oysters beds. These areas might bounce back if protected and allowed to regenerate passively, with active restoration being part of this.” - Seawilding

“Historical presence alone should not be a justification for restoration, it is important to understand the reasons for any loss of habitat and whether this can be addressed, rather than simply saying it was there before so we should put it there again.” - West of Scotland & Orkney Fish Producers Organisations

Support and enable landscape scale restoration

A range of mixed views were presented regarding this objective. On balance, respondents who commented were in favour of taking a landscape-scale or ecosystem-scale approach, noting the importance of considering the interconnectedness of land and sea. It was also felt that this approach will be necessary to scale up restoration efforts, and that there is value in having a wider focus than solely on specific habitats or species.

Conversely, a few respondents expressed the view that landscape-scale restoration can only be successful if pressure management is implemented or undertaken alongside passive restoration. This view is explored in more detail later in this section. Other points noted by different respondents included that while there is value in landscape-scale restoration smaller projects should still be able to access funding, and that there needs to be professional skills and capacity available to manage landscape-scale restoration projects.

“It is essential to prioritise ecosystem-scale projects. While smaller projects may have local value, they are unlikely to achieve the critical mass required for ecological take-off, that is, for restored habitats to become self-sustaining. Without reaching this threshold, such projects risk delivering only limited and short-term benefits, remaining dependent on continuous intervention, management, and further funding. By contrast, ecosystem-scale initiatives have the potential to deliver enduring ecological and socio-economic returns.” - Sunbird

“SAMS is supportive of the ambition to take an ecosystem and landscape approach to marine habitat restoration. However, this approach increases the complexity as well as the benefits, and it is possible to envisage scenarios where individual projects are delayed and impacted by this complexity, where benefits from rapid project implementation are lost. Special care will need to be taken regarding the importance of combining active and passive restoration within a seascape. Given this caveat, the benefits of considering connectivity, ecosystem diversity, and connections across the terrestrial and marine social-ecological systems espoused by this approach would be considerable.” - The Scottish Association for Marine Science

There were no specific suggestions at Q3 regarding the action to “Enable join-up between projects”, and only a few comments related to the action “Encourage landscape scale funding”. These singular comments included: a call to establish a dedicated Marine and Coastal Restoration Investment Fund, drawing on a combination of Crown Estate marine revenues, climate funding, and public-private partnerships; a suggestion to fund regional pilot projects involving multiple stakeholders to test landscape-scale benefits and mixed finance mechanisms; and a caution on the need to be realistic about whether there is sufficient funding available to fund landscape scale restoration.

Promote the importance of a place-based approach and baseline surveys

Several respondents commented on this objective, expressing widespread support for adopting a place-based approach to restoration. Respondents were clear that understanding the specific needs of an area and the aims and concerns of local communities is vital to the success of restoration projects, as well as to ensuring that ecological, social, and economic opportunities are maximised. One respondent called for the wording of the objective to be strengthened to “Prioritise a place-based approach…”, as they felt restoration would be unsuccessful without this.

Comments often emphasised the importance of a participatory approach, engaging with local communities and involving them in decision-making, including the creation of opportunity maps and exploring what the community believes should be the focus and priorities of a project in their area. Respondents also noted the benefits of engaging communities, such as gaining buy-in for projects, building local awareness, inspiring young people to engage in environmental stewardship, and supporting the self-management of community-led projects. Conversely, Salmon Scotland cautioned that “currently, communities have a preference for hyper-localised initiatives”, and noted these may not always have the best conditions for success or struggle to attract sufficient funding. As such, they expressed the view that “strategic and regionally scaled enhancement efforts are more likely to deliver meaningful biodiversity outcomes and offer greater feasibility for long-term planning and policy compliance”.

“[We] are pleased to see acknowledgement of the importance of community-led initiatives. From the Trust’s experience, the community-led nature of these projects is often key to their gaining buy-in and support from local communities and affected user groups, and so finding ways in which the Government can support these projects will be key to the plan working. To that end we would like to see more about how the Government will not only promote but support the ‘place-based approach and baseline surveys’ and how the Government intends to incentivise the take-up of national priorities.” – National Trust for Scotland

While some respondents commented on the baseline surveys element of this objective, this was mainly in the context of what data and information local communities could provide. Respondents cited a community’s local and historical knowledge to guide surveys and map opportunities, and felt that local groups may have already collected valuable survey data. Beyond this, a few respondents commented on the need to collect data from communities at the development phase of a project, using public consultation, social surveys, interviews, and workshops to understand what a localised approach looks like. A few respondents noted concerns about the limitations of existing data sharing. Suggested improvements included: developing a publicly accessible national marine restoration portal, similar to Scottish Environmental Protection Agency’s (SEPA) River Basin Management Planning (RBMP) tools, to track outcomes; creating open-access regional data hubs to support transparency and knowledge sharing; and expanding NMPi to include information about broader habitat and species survey sites.

Related to this objective, some respondents used Q3 to emphasise the importance of considering or consulting all marine users when assessing restoration opportunities. These comments were particularly prevalent among organisations from the fisheries and aquaculture sectors. Respondents felt it was essential to consult with and understand the needs and views of different marine users, and to minimise any negative socio-economic impacts on these groups. They advocated for meaningful, open and transparent engagement and partnership working with, for example, fisheries, aquaculture, recreational marine users, and organisations that could be involved in the restoration supply chain. A small number of respondents, therefore, called for the Stakeholders Advisory Group to continue. More information on this theme is provided in Chapter 5 / Theme 4 – Supply chain and communities.

Other themes

As noted in the introduction to this chapter, several respondents referenced passive restoration or pressure management in some way as part of their response to Q3. General views on this issue are presented in Chapter 7. Only a small number of respondents reflected specifically on the relationship between passive restoration activities and theme one. These noted the need to consider pressure management in opportunity maps, and a view that landscape-scale restoration must prioritise pressure management and passive restoration, supplemented by active restoration.

“Overall, this theme fails to recognise that pressure management should be a main feature of opportunity mapping and prioritisation. An additional layer to the opportunity maps could highlight areas that would benefit significantly from the removal of pressures (such as poor water quality and pollution). This could signpost locations where pressure management and additional monitoring is needed before active restoration can ensue and have higher chances of success. It may also prevent investment in active restoration methods that may have limited success until pressures are removed, and passive restoration can take place.” – Scottish Seabird Centre