National Marine Plan 2 - planning position statement: consultation analysis

High-level objectives

Questions one and two asked about the wording and policy focus for all five proposed high-level objectives:

Question 1: Do you agree with the updated wording for the high-level objectives (HLOs) and the focus they set out for policies in the NMP2? Please state which HLO(s) you are referring to in your response.

Question 2: Please add any additional comments on the HLOs in the space provided below.

These questions had a response rate of 97% and 77% respectively.

The draft high-level objectives (HLOs) shared in the PPS set the national ambition for marine planning. Much of the feedback on the HLOs received related to how the objectives could be implemented and is therefore of most relevance to design of planning policies.

Overview

54 respondents (primarily from ENGOs and fisheries) did not agree with the wording and/or focus of the HLOs, while 36 respondents (mainly from renewables and trade associations) agreed with the wording and/or focus of the HLOs. The remainder of responses did not specify a preference, or the question was left unanswered.

Although more than half of respondents did not agree with the proposed wording of the HLOs, support was shown for the proposed structure believing it was preferable to have “short, sharp HLOs with greater detail included in the policy sections” and that the reduction in number of HLOs reduced duplication across areas.

The proposal to include an implementation HLO was welcomed, with respondents broadly agreeing that an implementation HLO, or strong implementation guidance, would be imperative for monitoring and evaluating the effectiveness of the plan.

Although respondents were broadly in favour of an overall reduction in the amount of HLOs, there were respondents who referenced previous iterations of the HLOs, (as described in Annex A of the PPS), advocating for the inclusion of HLOs on Food Production and island and coastal communities.

Sector themes

Themes and general consensus from across the identified stakeholder groupings have been collated within this analysis, and suggest the following general sentiments:

Aquaculture sector

The feedback from this group appeared to demonstrate agreement with the emphasis on climate and nature, while also agreed with the HLO wording. However, it was noted that that sustainable food production should be national priority too, while it was felt that the HLOs should be equally weighted.

There was an indication that the sector felt environmental, social and economic factors need to be considered together.

Fishing sector

The sector feedback displayed disagreement with updated HLO wording. Feedback displayed a feeling of a need for greater consideration of the economic and social impacts on fishing communities, and that fishing should be a protected industry.

The sector responses were consistent that fishing is crucial to the economic wellbeing of islands and coastal communities.

Renewables sector

The responses demonstrated a feeling that offshore wind development should be prioritised. While there was agreement with the amount of HLOs, the responses sought strengthened wording, but agreed with the ‘significant weight’ being given to address climate change.

Environmental groups

Respondents suggested that HLOs need to take a whole ecosystem approach and as such sought strengthened wording to these.

There was requests for prioritisation of the environment over economic development, while a wish for more equitable access and community inclusion.

Public sector (including Marine Planning Partnerships)

A varied response from the sector, seeking more emphasis on tackling climate change and recovery/restoration.

Some suggested the reintroduction of the food production HLO, while others believed them to now better align with wider SG policies and the urgency of the climate and nature crises. Some also requested an additional HLO specifically supporting coastal and island communities.

Notable additions

Food production

Respondents from fisheries and aquaculture sectors questioned whether there should be an additional food production HLO to ensure marine food production was “factored in appropriately” when balancing environmental, economic, and social considerations in the sustainable development of the marine space.

Support for a food production HLO was considered essential by respondents to encourage responsible growth, investment, and innovation in marine food production. This viewpoint was held by respondents from across different sectors including: fishing, aquaculture, local authorities, community groups and charities. However, this view was not shared by many developers, believing food production to be “just one of many services and demands on the marine ecosystem”.

Coastal and island communities

Respondents from islands areas highlighted the need for a specific coastal and island communities HLO. They expressed concerns with current proposals appearing to focus more on access, recreation and tourism, rather than “sufficiently considering coastal industries and marine-based livelihoods”.

Several stakeholders, including Orkney Island Council and Shetland Marine Planning Partnership, strongly recommended that a HLO to ‘Support and enable thriving and resilience island and coastal communities’ be included in NMP2. There was also backing for NMP2 planning policy to support outcomes in the National Islands Plan.

Tourism

Some respondents raised the issue of sustainable development in relation to tourism, but only with minimal impact to the marine environment. They sought more focus on economy and employment opportunities in coastal and island communities, and ensuring safe, fair access while protecting and promoting valuable cultural assets.

Consensus

While stakeholders may have differed in opinion, it was clear that employing an iterative approach during the drafting of the new HLOs was thought of as valuable, and was appreciated by those who would be using it in the future.

In general, there was support for significant emphasis, or ‘significant weight’ to be given to the global climate and nature crises, which would align with the priorities set out in National Planning Framework 4 (NPF4). Although, some respondents believed ‘significant weight’ didn’t go far enough, considering climate change targets to be a key objective of the plan with projects which directly addressed climate change prioritised.

It was also highlighted that the climate and nature crises were equally important, and one should not be prioritised at the expense of another.