Marine and coastal restoration plan: consultation analysis report

8. Impact Assessments

In Scotland, public bodies including the Scottish Government are required to assess, consult on and monitor the likely impacts of their plans, programmes and strategies. The final section of the consultation asked respondents for their views, evidence and lived experience to inform impact assessments for the plan. An Environmental Report and Partial Business and Regulatory Impact Report (BRIA) were prepared ahead of the consultation.

This chapter presents the analysis of comments made by respondents about the Environmental Report and the Partial BRIA, as well as on potential impacts on island communities, equalities and children’s rights and wellbeing.

Strategic Environmental Assessment (SEA)

Q20: Do you think that the SEA Environmental Report is an accurate representation of the potential impacts (positive or negative) on the environment resulting from the objectives and actions proposed in this plan?

Among those answering the closed-question element of Q20, 43% agreed that the SEA Environmental Report is an accurate representation of potential impacts, 10% did not, 40% were unsure, and 8% selected ‘other’.

Three in ten of all respondents commented at Q20. Positive comments about the SEA Environmental Report were most prevalent. This included two statutory consultees, Historic Environment Scotland and NatureScot, who agreed with the report's findings. Respondents felt the report accurately identifies the key potential environmental impacts of the draft plan, particularly the overall net positive effects of scaling up active restoration. These included benefits such as biodiversity enhancement, improved water quality, and climate mitigation through carbon-sequestering habitats like seagrass and saltmarsh.

Respondents described the SEA as balanced and appropriately scoped, noting that it includes relevant mitigation and enhancement measures. Others emphasised that the SEA aligns well with the strategic direction of the plan and provides a foundation for future action. While most respondents supported the SEA’s overall positive conclusions, one organisation felt that the report may overemphasise negative impacts:

“It picks up the positive aspects, but probably overplays some of the negatives in the interest of 'balance'. This need not be a balanced position. The oceans are in trouble, we did the damage, and we need to fix it.” - Orkney Renewable Energy Forum

Some respondents suggested other factors they felt should be considered in the SEA Environmental Report; however, there was little consistency across these comments, with most points being made by one or two respondents. Two respondents called for a broader scope to include socio-economic impacts, with respondents noting that ecological, social, and economic outcomes are interdependent. A concern was raised about the lack of practical measures in the plan, suggesting that without clear implementation pathways, the SEA’s conclusions may not translate into meaningful environmental outcomes, or that the plan would not contribute to the delivery of the Scottish Biodiversity Strategy.

In line with calls throughout the consultation to consider pressure management and passive restoration, a few respondents advocated for stronger safeguards to prevent unintended ecological harm, such as habitat displacement or cumulative impacts from overlapping activities, including fishing, tourism, and aquaculture. Community of Arran Seabed Trust (COAST) expressed the view that the SEA should have included a reasonable alternative to active restoration, such as pressure management or passive restoration, as the primary focus. It was noted that the presumption in favour of active restoration had not been tested through a strategic assessment process, which limited the scope of the SEA.

A few respondents suggested additional content they felt was currently missing from the SEA Environmental Report. One suggestion was the need for stronger consideration of ecological risks, such as inappropriate restoration practices, non-native species introductions, and genetic homogenisation. This respondent emphasised the importance of adaptive monitoring to identify unintended consequences early and ensure restoration efforts remain ecologically sound.

A detailed response from one individual emphasised critical gaps from an island perspective, calling for the SEA to be island-proofed through the use of an Island Community Impact Assessment. Specific issues included the absence of island-specific impact assessments, inadequate treatment of marine litter, understated displacement effects, and a lack of monitoring infrastructure. The respondent also highlighted that community-led restoration is insufficiently recognised.

Other comments included:

• Suggesting that assessments like SEA and Socio-economic Impact Assessment (SEIA) would be more meaningful if conducted at the project level or for groups of similar projects in similar areas.
• Commenting that Scotland’s inshore waters are highly varied, making broad-scale assessments less informative and that more locally based assessments could be more effective.
• Concern that assessments risk being procedural rather than genuinely informative at this stage.
• One individual left a detailed comment suggesting additional considerations for the SEA. These included calls for more robust biosecurity measures, particularly in relation to INNS, for the SEA to more explicitly consider how public marine assets are managed in the public interest and a concern about the risk of commercialisation or reduced public access.
• In their response to the SEA, Historic Environment Scotland noted they agreed with the finding of the SEA that no significant effects on the historic environment have been predicted as a result of active restoration projects. However, they noted there could be potential adverse effects relating to material assets, for example, the breaching of coastal defences to allow flooding for restoration, which could also be of cultural significance.

Business Regulatory Impact Assessment (BRIA)

Q21: Do you think that the partial BRIA is an accurate representation of the potential costs, benefits and risks on the public, private or third sector, and regulators, associated with the objectives and actions proposed in this draft plan?

Among those answering the closed-question part of Q21, 28% agreed the partial BRIA is an accurate representation of the impacts associated with the objectives and actions proposed in this draft plan, 15% did not, 48% were unsure, and 8% selected ‘other’.

A quarter of respondents left a comment at Q21. A small number commented positively on the partial BRIA, highlighting its value in capturing the potential benefits of the draft plan. These respondents welcomed the BRIA’s contribution to illustrating a pathway for quantifying economic benefits, particularly at the local level, with one organisation noting:

“This helps to show a route to quantification of economic benefit of projects - at first locally - and then more generically.” - Northbay Innovations Ltd

Respondents also appreciated the BRIA’s reflection of efficiency gains, especially for the private sector, through mechanisms such as opportunity maps, dedicated support posts, and a more coordinated regulatory approach. These were seen as likely to reduce staff time and streamline project development.

“The plan, if effectively implemented, has the potential to deliver tangible benefits to businesses. Specifically, the development of opportunity maps could significantly reduce the time and resources required to identify suitable restoration locations. These maps would also support biodiversity enhancement initiatives linked to development proposals.” – Cooke Scotland

Others noted the plan’s potential to support resilient supply chains and unlock third-party funding opportunities, which could reinforce its role in enabling both biodiversity restoration and sustainable development.

In contrast, a few respondents noted a range of concerns about the partial BRIA. There was little consistency within these mostly singular comments, with respondents expressing the view that:

• The BRIA lacked sufficient consideration of socio-economic and maritime impacts, particularly for small-scale and inshore fishers. Those in the fisheries sector were more likely to raise this point than other respondent types. For example, concerns were raised that even minor cost implications could significantly affect the viability of businesses operating on tight margins, especially within the under-10m fleet.
• The BRIA did not adequately reflect the economic benefits of restoration, such as job creation or the potential for growth in restoration-related industries.
• The costs of regulatory complexity were underestimated, and that clearer economic modelling could help attract private investment.
• There is a need for greater certainty in the BRIA’s projections and assumptions.
• The plan lacked practical measures, making it unlikely to deliver meaningful change, which in turn undermines the BRIA’s assumptions.
• Wider socio-economic impacts should be considered in the BRIA, including the displacement of existing marine activities and the need to assess both positive and negative effects beyond the immediate scope of individual projects.
• Greater consideration was needed of island contexts, including higher transport and infrastructure costs, limited capacity, and the need to account for the economic value of volunteer contributions in community-led restoration.
• Past negative experiences suggest that BRIAs have historically underestimated negative impacts on inshore fishing.
• There should be stronger representation and engagement with local stakeholders, including wildfowling clubs, community users, and coastal land managers, to ensure the BRIA reflects a broader range of perspectives.

In their response to Q22, Rebalance Earth Venture Limited expressed the view that the partial BRIA underestimates the cost of not taking action. It felt that the business-as-usual option is presented in the BRIA as “generating no additional direct costs or benefits, but in reality, inaction carries profound indirect impacts across the economy, from government to individual households.”.

“To frame [business-as-usual] as cost-neutral is misleading. Delayed or ineffective action will amplify climate and nature-related risks, driving higher public spending on disaster recovery, lowering tax receipts, stranding assets, and disrupting supply chains. Social costs also multiply, from lost livelihoods and reduced food security to increased mental health burdens… The BRIA should reflect this reality: the choice is not between marginal additional costs or no costs, but between rising systemic risks under BAU and the resilience, growth, and fiscal savings unlocked by restoration.” - Rebalance Earth Venture Limited

One individual left a detailed comment, expressing partial support for the BRIA but raising concerns that it does not sufficiently address key legal, economic, and national interest issues. They felt the plan should place a stronger emphasis on ensuring public investment benefits Scottish businesses and communities, include clearer legal safeguards around procurement and public value, and provide more robust scrutiny of public sector costs. They also felt risks such as community displacement had been overlooked and questioned the evidence base for some of the plan’s environmental claims.

Island communities

Q22: Do you think that objectives and actions proposed in this draft plan will have an impact that is significantly different (positive or negative) for some or all island communities than for other communities (including other island communities)?

Among those answering the closed-question element of Q22, almost half (47%) felt the plan would have a significantly different impact on some or all island communities. Of the remaining respondents, 17% felt it would not have a different impact, 30% were unsure, and 7% selected ‘other’.

Two fifths of all respondents left an open comment at Q22. The most common theme, mentioned by some respondents, was the distinct challenges faced by island communities compared to other communities, emphasising the need for tailored approaches to ensure fair participation and outcomes. Key concerns mentioned in this theme included islands having limited transport links, smaller populations, and reduced digital connectivity, which were seen as barriers to engaging with restoration initiatives. A few respondents noted that remote coastal areas face similar issues and should be considered alongside islands.

Respondents also cautioned against a one-size-fits-all approach, emphasising the need to recognise that place-based differences should be considered to ensure restoration efforts are effective and inclusive across diverse settings. For example, a few noted that island communities or local authorities may have fewer resources but the same administrative demands as larger or mainland areas. It was felt that, without additional support, this could limit their ability to contribute meaningfully to the plan's intended outcomes.

Similarly, a few respondents commented on the potential variation of impacts across different locations, noting that the effects of the draft plan would not be uniform across all island or coastal communities. Some areas were identified as having greater vulnerability to environmental change, such as sea-level rise, or a greater potential to benefit from restoration due to their proximity to suitable sites or cohesive local networks. Respondents also highlighted that geographic isolation could limit access to support and funding, particularly where communities are distant from business hubs or workshop locations. This raised concerns about unequal opportunities to participate in or benefit from restoration efforts. Others noted that island projects may offer advantages in monitoring and community engagement, suggesting they could serve as benchmarks for wider implementation. However, there was caution that uneven investment across locations could create social tensions or disrupt existing economic activity if not carefully managed.

“Island communities face distinct challenges of remoteness, limited connectivity, and smaller, often ageing populations, but they are also uniquely positioned to benefit from marine and coastal restoration. Properly designed projects can create local jobs, build skills, and support economic diversification, helping retain younger people and strengthen resilience where alternatives are scarce. At the same time, these benefits will only be realised if interventions are sensitive to local context. Island economies are often highly dependent on marine resources, so poorly designed projects risk unintended disruption to existing livelihoods.” - Rebalance Earth Venture Limited

“If activities or plans are mandated without discussion at local levels, by individual islands, then one positive may become a negative. The ideal would be to start local discussion, then build them in regionally, I.e. Lewis or Barra then Outer Hebrides wide. So, an Islands Impact Assessment could involve multiple island discussion, rather than one island or island area” – Climate Hebrides CIC

A similar proportion of respondents commented on the potential negative impacts that island communities may face as a result of the plan. These responses focused on the risk of uneven benefit distribution, particularly where commercial initiatives are involved. A few respondents warned that such approaches could extract value from island settings without delivering lasting benefits to local people. To mitigate this, respondents stressed the importance of locally led projects and inclusive planning that reflects the diversity of island contexts, thus avoiding the creation of social or economic imbalances. A few called for robust island-proofing measures to prevent restoration inequality and ensure fair access to funding and decision-making. It was also noted that poorly targeted funding or shifting project goals could undermine trust and lead to unintended social or economic disruptions.

A few respondents noted that the impact of the plan would depend heavily on how it is implemented. They emphasised the need for implementation to be responsive to individual island contexts, with clear objectives and coordination across relevant policies. Respondents stressed the importance of clear objectives, transparent consultation, and alignment with existing marine policies to maximise positive outcomes. However, it was also recognised that effective implementation could deliver significant benefits, including improved policy visibility, sustainable funding, and employment opportunities, especially if previously identified island-specific needs are addressed.

“Critical requirement: Without explicit and mandatory island-proofing (ICIA for all plan elements), the plan will likely perpetuate and potentially worsen existing restoration inequality. However, with appropriate island-proofing -ring-fenced funding, infrastructure investment, cost differential recognition, OSPAR site establishment, and simplified access processes, the plan could be transformational for island restoration.” – Individual

A small number of respondents explicitly called on the Scottish Government to undertake an Islands Impact Assessment to inform the development of the proposed plan.

“The Fraser of Allander research institute undertook analysis of the Shetland economy (20211) which revealed that the combined economic output of: Fishing (£70.9m), Aquaculture (£243.79m), Fish processing (£125.04m) equated to 34.75% of the entire Shetland economy. This compares to <1% of the national economy for the same sectors combined. This extreme disparity is worthy of ICIA assessment since any marine restoration measures which negatively impact marine economic activities (as referenced in the draft plan) would have an order of magnitude greater economic impact than for the Scottish mainland context.” – Cooke Scotland

Equalities

Q23: Do you think that the objectives and actions proposed in this draft plan will have an impact (positive or negative) on protected characteristics, with particular regard to eliminating unlawful discrimination, advancing equality of opportunity and promoting good relations?

Among those answering the closed-question element of Q23, 21% felt the plan would impact protected characteristics, 25% did not, 46% were unsure, and 8% selected ‘other’.

One in six respondents commented at Q23, though a few of these considered the plan’s effectiveness more generally, rather than any impact on protected characteristics. The most prevalent theme was that the objectives and actions in the plan could have a negative impact on protected characteristics, or that it does not sufficiently consider the potential for these negative impacts. Respondents highlighted that the plan does not consider how it might affect individuals based on gender, sexual orientation, religion or belief, and disability, particularly in terms of access, inclusion, and equal opportunity. The need for more meaningful engagement with Black and minority ethnic (BME) communities was also highlighted, with concerns that the conservation and environmental sectors remain disproportionately white and continue to underrepresent diverse voices.

The next most prominent theme, commented on by a few respondents, was about the impact the plan may have on opportunities and how this could be linked to protected characteristics. Respondents recognised the positive potential of the plan to create new jobs, volunteering roles, and skills development, particularly in coastal and island areas where economic alternatives may be limited. However, respondents also cautioned that these benefits would not be automatic. It was noted that some groups may face barriers to participation, and there is a risk that communities or groups of stakeholders without the time or resources to engage, particularly through volunteering, could feel excluded.

“This plan and the following works are an excellent opportunity for targeted training and engagement for a range of marginalised groups, and I hope this is taken into account moving forward as a social win.” - Individual

To maximise impact, the plan should ensure inclusive access to training and employment, so restoration supports both environmental recovery and wider social equality.” - Rebalance Earth Venture Limited

One individual left a very detailed comment, emphasising that the impact on protected characteristics would depend heavily on how the plan is implemented. This individual raised specific concerns about the protection of single-sex spaces, freedom of belief, and ensuring that equality measures do not inadvertently exclude or pressure individuals based on their views or identities. The response also highlighted the need to prioritise local communities in decision-making and ensure the realistic and proportionate inclusion of disabled people and older workers in physically demanding roles.

Children’s rights

Q24: Do you think that the objective and actions proposed in this draft plan will have an impact (positive or negative) on children’s rights and wellbeing?

Among those answering the closed-question element of Q24, 32% thought that the objective and actions proposed in this draft plan will have an impact on children’s rights and wellbeing, 23% did not, 37% were unsure, and 8% selected ‘other’.

One in five respondents left an open comment at Q24. The most prevalent theme, raised by some respondents, highlighted the potential for the plan to positively impact children’s rights and wellbeing by promoting environmental awareness, encouraging stewardship, and strengthening long-term protection of natural resources. These respondents emphasised the importance of cultivating environmental leadership among younger generations and providing opportunities for children to engage with nature in meaningful ways. Respondents noted that children in coastal and island communities could benefit from improved biodiversity, cleaner air and water, and greater access to nature, leading to better health and wellbeing outcomes.

“These benefits align with Article 24 (health) and Article 29 (education focused on respect for the natural environment) [of the UN Convention of the Rights of the Child].” - Individual

Respondents emphasised the importance of integrating environmental education, youth participation, and citizen science into restoration projects, ensuring that children are not only beneficiaries but also active contributors to a more sustainable future. Suggestions included designing family-friendly volunteering opportunities and creating youth leadership roles to strengthen engagement and learning.

Similarly, the next most common theme was the potential for the plan to positively impact children’s futures. A few respondents commented on the potential long-term benefits of marine restoration, noting that the plan could help secure a healthier, more sustainable environment for future generations. These included references to improved education and livelihood opportunities, as well as the reversal of biodiversity loss. Others emphasised that restoration efforts could reduce the risks of extreme weather events and environmental degradation, helping to safeguard children’s physical and mental wellbeing while lowering future social and economic costs.

“The actions flowing from a well-developed plan should benefit our children and grandchildren.” - Royal Yachting Association Scotland

Others reflected more generally on the principle that improving the environment should benefit everyone, including children, while also acknowledging that not all projects may deliver those outcomes equally. One individual expressed concern that the current plan may fall short of delivering a healthy environment for future generations.

Comments highlighting the positive impact the plan could have on health and wellbeing were mentioned by a few respondents. They emphasised the role of restoration in supporting both the physical and mental health of children and young people. Improved access to clean air, water, and natural spaces, particularly in coastal and island communities, was seen as contributing to healthier environments and more active lifestyles. Respondents noted that restoration could help alleviate eco-anxiety and feelings of hopelessness among children by providing them with a sense of agency and connection to the natural world. Others highlighted the potential therapeutic value of nature, suggesting that engaging with the environment could help address rising levels of anxiety and depression in young people.

“Restoring marine and coastal ecosystems directly supports children’s right to health by delivering essential ecosystem services, from improving water quality to increasing resilience against climate change and nature-related risks.” - Rebalance Earth Venture Limited

Conversely, a small number noted that restoration projects could have detrimental impacts on children and young people, which need to be considered and mitigated. For example, if a parent's livelihood is disrupted by a restoration project, it could have a detrimental socio-economic impact on the family, including the children.