Marine and coastal restoration plan: consultation analysis report

7. Plan Implementation and Review

This chapter presents the analysis of responses to Q16 to Q19, which asked respondents for their views on the overall approach and content of the plan, whether any actions or objectives are missing, and how the plan itself can be monitored and evaluated.

Among those answering Q16, just under two thirds (64%) felt the plan would support the acceleration of restoration in Scottish coasts and waters; 43% felt it would do this ‘a lot’, and 21% ‘a little’. A further 11% were neutral, 12% felt it would not provide support, and 13% were unsure.

The same proportion of both individuals and organisations felt the plan would support restoration, at 64% each, though organisations were marginally more likely than individuals to select ‘yes, a lot’ (44% compared to 40%, respectively). Opinion varied considerably by organisation type. Half (50%) of organisations in the restoration and fisheries sectors that answered felt the plan would support the acceleration of restoration, rising to all aquaculture organisations (80% ‘a lot’) and both the community groups who answered. The only group where support fell below 50% was among nature conservation organisations, of which 22% felt the plan would support restoration, 11% were neutral, 55% felt it would not, and 11% were unsure.

Two thirds (68%) of those answering Q17 agreed with the content of the plan; 38% indicated they ‘strongly agree’ and 30% that they ‘somewhat agree’. A further 8% were neutral, 16% disagreed to some extent, and 8% were unsure.

A very similar proportion of individuals and organisations agreed with the content of the plan, at 70% and 68%, respectively, though individuals were marginally more likely to agree strongly (42% compared to 36% of organisations). As at Q16, all aquaculture organisations and both the community groups who answered agreed, as did at least three fifths of most other respondent types. The only group where support fell below 50% was among nature conservation organisations, of which only 33% agreed with the plan's content, 11% were neutral, and 55% disagreed.

Q18: Are there any actions or objectives that you feel are missing and should be included and prioritised for the first Marine and Coastal Restoration Plan?

Seven in ten of all respondents answered Q18. While many comments highlighted additional considerations for the plan, several respondents used Q18 to elaborate on their closed-question answers at Q16 and Q17. In addition, a few respondents at Q1 made general comments on the plan, both positive and negative. To minimise repetition, those comments have been consolidated into the analysis presented below.

A few respondents made positive comments about the plan. Conversely, two more critical themes were raised, particularly among nature conservation and restoration organisations. These were the lack of consideration of passive restoration and pressure management in the plan, and that the plan could be more impactful and is unlikely to drive change.

“The proposed Marine and Coastal Restoration Plan and it's objectives are welcomed.” – Argyll and Bute Council

“Welcome this focus on costal and marine restoration in Scotland, and hope the implementation can be swift.” – Dumfries and Galloway Council

“SSEN Transmission strongly supports the Plan’s aim to accelerate marine restoration and regeneration across Scotland’s coasts and waters. The focus on active restoration, alongside proportionate management measures, represents a positive and necessary step towards reversing the historic decline of marine habitats and supporting resilient coastal communities. The Plan’s five-theme structure and commitment to an iterative, evidence-based approach are well aligned with our own ambitions for biodiversity net gain and nature recovery.” – SSEN Transmission

Passive restoration

While the plan’s focus on active restoration was acknowledged by some respondents, several felt the lack of consideration of passive restoration was a serious omission. Those raising this issue did so with differing degrees of concern. A few respondents expressed support for the plan and its aims and objectives, but noted the need for active restoration to work alongside passive restoration. However, some respondents were very critical, expressing the belief that the lack of inclusion of passive restoration would ultimately mean the plan is unsuccessful or has little impact, in particular that it will not help Scotland reach its target to halt biodiversity loss by 2030. A small number of respondents, comprising a few individuals and COAST, highlighted this criticism in response to multiple consultation questions.

“There is a presumption in the consultation questions that respondents support active restoration being the sole focus of the restoration plan. This makes it extremely difficult to respond and provide meaningful comment to these questions, as we do not support the overall proposal that the restoration plan focuses primarily on active restoration. We do not consider that this will deliver restoration in the most timely and effective manner at scale, nor meet the stated targets to halt biodiversity loss by 2030.” - Community of Arran Seabed Trust (COAST)

“Passive restoration and removal of pressures should not be dismissed as being dealt with in other areas of Scottish Marine Policy, and the Scottish Biodiversity Strategy does not differentiate between active and passive restoration, both must be prioritised equally… If the Scottish Government is to produce a genuine strategy to restore our seas, they should not consider active restoration in a silo, and acknowledge that active restoration is a very small part of restoration efforts.” - Mossy Earth - Wilder Firths Hub

“Habitats and species have declined for a reason, if the pressures that caused this initial decline are not addressed, active restoration will not have a significant role in helping the Scottish Government reach its national and international obligations.” - Seawilding

At Q18, some respondents reflected on how active restoration might work effectively alongside passive restoration, and vice versa, suggesting that some form of pressure management may be necessary to ensure the success of active restoration sites. A few respondents at Q18 and other questions highlighted some of the pressures on the marine environment that they felt needed to be managed, for example, resulting from the impact of trawlers and dredgers.

“I acknowledge that the scope of this document is on Active Restoration, and involves deliberate human interventions to restore habitat, species or ecological functions where natural recovery is too slow or impossible without help. However, I think that there should be a focus on removing or reducing human pressures so that marine ecosystems can also start to recover naturally. This approach would then further benefit from Active Restoration interventions, thereby, hopefully, accelerating recovery of Scotland’s marine environment.” – Individual

“We acknowledge the distinction between active and passive restoration, and that passive restoration, or pressure management, is covered by a wide suite of strategies and policies. However, there may be scope in the plan to deliver a more integrated approach between the two approaches, rather than this plan looking at active restoration in relative isolation. The work of COAST can be viewed as an example where passive management has been successful in restoring seabed habitats.” - Clyde Marine Planning Partnership

“Consideration and clarification over whether there will be any attempt to manage activities which could damage the seabed in areas where restoration work has been undertaken would be very welcome. If restored areas are damaged by other users of the sea, that is likely to create conflict and damage morale of those undertaking the enhancement work.” – Crown Estate Scotland

Concerns about a lack of detail in the plan

A few respondents at Q18, all but one of whom were organisations, questioned the scope of the plan or expressed the view that it could be more impactful if more detail is included. On the former, singular comments included that the plan could go beyond native oyster and seagrass habitats, that it would benefit from examples of coastal habitats that will be considered for inclusion, and a suggestion that terrestrial planning projects would be better suited to a different plan, given the differences between the marine and terrestrial consenting processes.

“The definitions and scope of the Plan are not entirely clear and would benefit from examples of coastal habitats that will be considered for inclusion, or if these areas are not to be included, links/signposting to where these issues will be addressed.” – Aberdeenshire Council

On the lack of detail, respondents felt the plan lacked the ambition or urgency needed to facilitate large-scale restoration, with a few respondents specifically reiterating the importance of simplifying the regulatory environment (see Theme 2 / Chapter 3).

“The Plan as laid out will do little to help meet the objective of halting biodiversity loss by 2030 or the SBS objective to accelerate restoration and regeneration. The actions proposed are largely things that the restoration community are already doing and have been doing for some time - identifying suitable locations for restoration, monitoring, building the evidence base, navigating the regulation etc. At best this Plan will provide some coordination and coherence for the restoration community but this is at the expense of delivering real impact through measures that could address the very real barrier of regulation.” – Scottish Environment SE LINK

“There are significant gaps in the Plan with respect to actions: much of the Plan is simply aspirational and does not specify what actions would consist of. While SIFT agrees with many of these aspirations - we ‘somewhat agree’ to Question 17 - the omissions highlighted still remain... SIFT also has a significant concern regarding the scale of proposed restoration. Little detail has been provided in the Plan about how restoration will be sufficiently large to ensure that the wider nature and climate crises will be addressed. The plan appears to lack ambition in this respect and ultimately led to SIFT giving a neutral response to Question 16: any acceleration of restoration efforts will only be to small-scale, active projects.” - The Sustainable Inshore Fisheries Trust

At Q1, a few respondents commented on the need to ensure the plan does not distract from restoration activities, reflecting the urgency of the situation.

“What matters most is putting in place processes that can be refined over time rather than waiting for a fully polished framework. Restoration must be treated as a continuous cycle: implement, learn, refine, and scale. Embedding iteration ensures resilience, builds confidence, and avoids delay while waiting for “perfect” solutions. This approach will keep momentum, allow for adaptation as new evidence emerges, and create the foundations for scalable, long-term restoration.” - Rebalance Earth Venture Limited

“There is a risk that effort will focus on the easy tasks such as 'survey' and 'plan' and shy away from the harder items that involve 'doing'. In the light of the catastrophic changes in the marine estate this needs to be resisted, and bold action is needed. Now.” - Orkney Renewable Energy Forum

Missing actions or objectives

Many of the remaining comments at Q18 raised or reiterated points related to the plan’s themes, which have already been covered earlier in this report. These included small numbers of comments on priorities, improving the regulatory environment, funding, collaboration with local communities, ensuring that the plan does not detrimentally impact the activities of other marine users or have negative socio-economic impacts on those groups, and enhancing the restoration supply chain. The remainder of this section outlines additional points highlighted by respondents as being missing from the plan.

A few respondents called for the plan to demonstrate stronger or more explicit links with other strategies and policies. Those mentioned at Q18 included: NMP2, Biodiversity Net Gain policies, Scotland’s National Adaptation Plan, the proposed Scottish Marine Recovery Fund (MRF), Marine Planning Partnerships, regional marine plans and coastal partnerships. Local authority-led shoreline management planning and offshore wind development were also mentioned. Scottish Renewables noted a lack of reference to National Planning Framework 4 (NPF4), noting that “Clarity is needed on whether the Scottish Government will consistently apply the biodiversity enhancement requirements in Policy 3 of the NPF4 to consenting applications for offshore wind projects and associated grid connections”. Three respondents highlighted the need to consider strategic compensation policies:

“It’s important to acknowledge the growing role of restoration in strategic compensation for Offshore Renewable Energy (ORE) impacts in Scotland. Similar initiatives are emerging under this banner, particularly for protected species like seabirds. We are concerned that restoration and compensation policies may begin to compete, potentially limiting the number of viable projects available to meet the UK’s biodiversity and nature recovery goals. Using restoration to offset ORE impacts could undermine broader conservation objectives. We urge the government to address this potential conflict and focus on reducing impacts at the source, rather than relying on compensation as a default solution.” - West of Scotland & Orkney Fish Producers Organisations

“Our members recommend that the role of environmental compensation measures in contributing to restoration should be given greater attention in the final version of this plan. This includes identifying restoration priorities and considering the practical aspects of allocating and deploying strategic compensation measures.” – Scottish Renewables

A few respondents called for each of the following to be considered or included in the plan:

• In addition to the awareness raising workshops under Theme 2, there were calls for using information campaigns and filmmaking to educate the public and marine users about the need for restoration and its benefits
• Bold and effective leadership of restoration efforts to build wide support, in addition to the plan’s perceived focus on bottom-up, community-led projects
• Link the need for restoration more directly to climate change risk and sea-level rise, pollution and degradation, and the role of nature in making coastal systems more resilient, and for the plan’s action to include direct links to climate action
• Greater consideration of pilot projects
• Carbon emissions and capture via the marine environment
• The need to work with Historic Environment Scotland if cultural sites on the coast and in the marine environment are affected by restoration projects
• Consideration of a framework for Marine Net Gain (MNG), which the respondents felt could create “predictable demand signals, mainstream marine restoration into development, and unlock sustained private investment.”
• Include marine litter removal as a restoration activity eligible for funds and support

“It would be good to see greater support from Government and statutory agencies. The success of the plan currently appears to rest squarely on the shoulders of community groups and although this is critical, so is a greater level of support from the Government and statutory agencies.” – National Trust for Scotland

“Another missing element is the need to expand pilots of marine restoration. Demonstrator projects are essential to test approaches, generate evidence, and build confidence among regulators, investors, and communities.” - Rebalance Earth Venture Limited

One individual left a detailed comment calling for multiple additional actions, including legal Safeguards for Coastal Restoration Zones, taking advantage of regulatory flexibilities that have resulted from the UK leaving the European Union, restoring and developing traditional marine skills such as boatbuilding and rope-making, ensuring financial transparency and anti-lobbying protections for all public funds distributed through SMEEF and other restoration grants, and to consider how faith-informed environmental ethics can contribute meaningfully to restoration.

Q19: Noting that we will develop a monitoring and evaluation approach for implementation and review of the plan, do you have any comments you wish us to consider at this stage?

Just over half of all respondents answered Q19. However, some respondents reiterated aspects of monitoring and evaluating restoration in a way that made it unclear whether they were referring to monitoring restoration projects or to the plan itself. As many of these issues have been addressed in the analysis of comments related to Theme 5 (Chapter 6), the analysis below focuses on comments about the effectiveness of the plan itself.

Targets and timescales

The most common theme at Q19 was the need for the plan to have targets associated with its objectives and outcomes, which could enable implementation and progress to be monitored. Respondents called for clear, unambiguous, realistic, proportionate, practical and measurable targets. Most of these comments were brief, but a few respondents were more critical of the lack of targets in the draft plan.

“The monitoring proposals are vague and risk becoming a box-ticking exercise rather than a genuine feedback mechanism. There’s no clear framework for how data will be used to adjust priorities, funding or regulatory action over time. Monitoring should be linked to measurable ecological and socio-economic outcomes, not just process milestones, and results must feed directly into decision-making. Without this, the plan risks drifting without accountability or evidence-based course correction.” – Thistle Wind Partners

“A plan is not a plan unless it is clear about what it intends to achieve and by when. This plan is not really a plan but rather a series of worthy but vague aspirations.” – Fish Legal

Some respondents highlighted specific measures they felt needed to be monitored, noting the need to consider social and economic impacts, as well as progress against plan milestones. A few left similarly worded responses noting that monitoring and evaluation should outline what scale and type of restoration has been delivered on the ground as a result of the plan, and how these have contributed to mitigating biodiversity loss by 2030. One individual recommended that monitoring elements should include measures of cross-sectoral partnerships, levels of community participation, and island-disaggregated metrics.

“Crucially, monitoring and evaluation should assess not only ecological outcomes but also how effectively the plan supports cross-sectoral collaboration, regulatory clarity, and strategic investment. For example, the plan could track how opportunity maps influence local authority decisions, including their integration into Local Development Plans, Regional Marine Plans and supplementary guidance. It should also evaluate whether these maps are being used appropriately – as indicative tools rather than prescriptive boundaries – and whether they are being interpreted alongside expert knowledge, robust data and peer-reviewed science. The plan should also monitor the effectiveness of engagement mechanisms, such as stakeholder workshops and guidance updates, to ensure that restoration practitioners, developers, regulators and communities are working together effectively. It should also assess whether funding mechanisms are supporting restoration at scale, matched to the notable timeframes and resources required over the long-term.” – Scottish Sea Farms

A few respondents stressed the importance of ensuring the plan is monitored in an open and transparent way. Two respondents emphasised the importance of public reporting on progress, and one individual provided a detailed response, also advocating for independent oversight with community representation, the use of open-access tools to facilitate public review, transparency regarding any digital tools used for monitoring, and mandatory safeguarding and equality audits.

Mixed views on timescales were expressed by a few respondents. While a few supported the proposed Plan review in five years, others felt this was too long given the rapidly evolving nature of the work and suggested including interim milestones to assess progress. A few stressed that the plan’s actions must be accompanied by clear timescales.

Other considerations

Several other points regarding monitoring and evaluation were raised by a few respondents. These included:

• The importance of involving communities in monitoring and evaluation, though in most cases, these comments appeared to relate to restoration projects in general
• Ensuring there is a dynamic review of the plan, including putting revised drafts out to consultation and feedback loops, which ensure future revisions to the plan are based on monitoring results
• One respondent called for the evaluation of the plan to assess its impact on Scotland-wide economic and social metrics

“Please allow for groups at the delivery end to participate in discussion around monitoring and evaluation, including plans on how to deliver this. You will then gain realism on the one hand, and also big aspiration too!” – Climate Hebrides CIC

“Feedback Loops for Adaptive Management – The evaluation system should not just measure but inform. If data shows that certain regulatory hurdles are blocking community-led projects or that costs are deterring uptake, then the Plan should require the Scottish Government to amend procedures accordingly. This is especially important post-Brexit, where we have the freedom to shape our own marine rules.” - Individual

“Within the plan, the opportunities, challenges and barriers to marine restoration are mostly explored through a lens focusing on community activities and bottom-up conservation measures. There are some objectives proposed in the plan which serve to benefit business as well as communities (such as improved communication between regulators and local authorities), but this must be stated as an objective within the final plan and not just an assumption. It is likely that the work from this plan will be carried through into the development of marine planning policy (i.e. NMP2). To this point, the aquaculture sector, and business more widely, must be involved more proactively in the development and monitoring of objectives/actions within this plan and working closely in their design to ensure benefits are fully realised by all stakeholders.” – Salmon Scotland

A few respondents were critical that the plan does not consider passive restoration. One individual specifically noted that the evaluation of the plan and active restoration must be done against and alongside assessing the impact of passive restoration projects.