National Marine Plan 2 - planning position statement: consultation analysis

Nature

Questions four and five asked for views on the Nature section in the PPS:

Question 4: What are your views on the policy ideas proposed under the Nature section?

Question 5: Considering the definition of ‘Nature Positive’ included in the Scottish Biodiversity Strategy (SBS), what are your views on how this could be implemented by different sectors and types of development and use?

Question 4 received a response rate of 89%, while question 5 had a response rate of 84%.

Overview

Respondents found the proposed policies aligned well with biodiversity goals but required “clearer definitions” and “practical guidance” to ensure effective implementation.

In general, there was support for the principle of nature positive development but detail around how such a planning policy could be implemented, by different sectors, was raised as a concern.

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

Respondents from the aquaculture sector agreed with proposals for NMP2 to be aligned with NPF4, highlighting that future planning policies must include “clear mitigation strategies to offset negative impacts on existing operators” and be supported by practical guidance for implementation, further noting that “enhancement in one area might have unforeseen impacts on other parts of the ecosystem”.

Although supportive of the ambition, some respondents in the aquaculture sector stated that due to the limitations faced by the salmon farming sector in implementing nature inclusive design, supplementary measures will “need to be implemented to contribute to meeting the goal”.

Additional engagement with stakeholders was encouraged to explore how outcomes could be achieved across different sectors.

Fishing sector

There was commonality across the fishing and aquaculture sectors in their responses, with both stating that nature positive measures would need to be scientifically justified, applied fairly and without disproportionate financial burden.

The current definition of nature positive was thought to be “too vague and could be used as a blanket justification for restricting fishing activities”.

Renewables sector

Developers broadly sought to encourage a level of flexibility to be employed, noting that nature positive measures were not always possible at the development site and may be most effectively delivered at a strategic level. They also suggested that clear definitions of ‘good practice’ would be imperative for all industries and sectors.

It was highlighted that nature inclusive design may not be applicable in all situations, therefore flexibility would be needed when assessing approaches that may not deliver directly at the site of operations or construction.

Environmental groups

ENGOs highlighted the need to take an holistic approach to protecting the seabed and all that it supports, not just the features within designations.

ENGOs, whilst supporting nature positive approaches, felt that the focus should be on prevention of further damage and loss over recovery and restoration efforts. In line with other respondents, they agreed that “clear, enforceable guidelines and consistent monitoring” were essential to ensure developments contributed positively to the marine environment.

Public Sector (including Marine Planning Partnerships)

Government agencies were supportive of the proposed policy ideas for marine protection and enhancement and welcomed the potential requirement to consider mapped opportunities for restoration, enhancement, or nature-based solutions for climate mitigation and adaptation.

Notable additions

Respondents with interests in the tourism industry were supportive of proposed policy ideas and keen to develop nature positive initiatives.

Developers supported alignment with the Nature section within NPF4 and welcomed the development of a restoration plan for Scotland's seas. Additionally, they were “supportive of policies that protect and preserve restoration sites” and welcomed the streamlining and simplifying of the licensing process, particularly for restoration activities. There were also supportive of the idea of nature-inclusive design so long as expectations were “realistic, workable and proportionate”.

Clarity and monitoring

Community-led groups encouraged measures to be “supported by robust monitoring, enforcement, and community involvement” and to align economic activity with reversing biodiversity loss.

Marine planning partnerships highlighted the need for robust guidance and clear definitions to avoid mis-interpretation of nature positive.

Developers cited the acknowledgement towards further guidance and examples was welcomed, while they emphasised support for “using a mitigation hierarchy to ensure impacts remained below significant levels”.

Challenge to meet intentions

Respondents for ENGOs asked that the current policies in the NMP are maintained, and raised concerns that proposals were seen as a regression of environmental protections. This was a sentiment echoed by respondents from different sectors, including fisheries and those with tourism industry interests.

Some developers queried whether a single development, or use, would itself be considered nature positive, or whether it would contribute to a wider nature positive target or goal. This was echoed by some in the aquaculture sector who reflected that perhaps “single interventions associated with a development are unlikely to result in changes to the [biodiversity] curve”.

Consensus

In general, there was support for improving implementation of the planning policy and broad support for nature-based solutions, while the protection of Priority Marine Features (PMFs) was regarded as essential.

However, many respondents felt that clear, enforceable guidelines, definitions and consistent monitoring were essential to ensure developments contributed positively to the marine environment.