National Marine Plan 2 - planning position statement: consultation analysis

Implementation

Questions 10, 11 and 12 looked at the proposals under the Implementation section:

Question 10: What are your views on the proposed policy ideas under the Implementation section?

Question 11: If you agree that NMP2 should include prioritisation, which outcome do you prefer i.e. space for a specific use given priority, space for nature given priority? Should additional outcomes also be considered? Please include any supporting information in your response

Question 12: What are your views on policy ideas suggested in relation to 'Community Informed Decision-Making'?

These questions had a response rate of 83%, 80% and 76% respectively.

For clarity, respondents were asked to consider the role of the decision maker and the potential introduction of prioritisation when responding to these questions.

Overview

In general, there was support for the inclusion of planning policies on implementation, such as proposals to consider socio-economic impacts or spatial data in decision-making and adoption of the mitigation hierarchy.

There was also general support for the inclusion of an implementation-specific HLO, with respondents recognising the importance for better tracking of plan use and for delivery.

Many stakeholders commented that alignment with the approach in NPF4 (significant weight to climate and nature crisis) is beneficial, as it avoids confusion and potential contradictions between future marine, and existing terrestrial planning frameworks. There was some support for the proposal to consider nature and climate policies first.

The majority of respondents expressed support for community-informed decision-making.

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 Aquaculture respondents generally encouraged meaningful sector-specific consultation throughout the process, highlighting that implementation measures need to be “practical, proportionate, and aligned with sector realities”.

With regards to prioritisation, representatives from this sector requested prioritisation of existing sites and equal priority for energy and food security.

Aquaculture respondents were mostly supportive of community-informed decision-making, but believed clearer definitions of key terms such as “communities” would be required.

Respondents also believed that clearer guidance would be helpful on what community-informed decision-making would look like, which must be appropriate and proportionate to the scale and type of development. This was a sentiment shared by other stakeholders, who believed the term needed to be clearer to avoid misinterpretation.

Fishing sector

Fisheries respondents acknowledged the need for clear and effective implementation but were concerned that the proposed policies “lacked transparency, failed to protect fisheries from competing interests, and did not provide an equitable prioritisation framework”.

Fisheries representatives requested prioritisation of existing fisheries and equal priority for energy and food security. There were also requests from fishers that any prioritisation within the NMP2 does not negatively impact fishers and that fishing must be given equal priority to offshore wind and nature conservation in marine planning.

Some fish producer organisations advocated for legal protection and safeguarding of fishing and mandatory financial compensation for fishers displaced by offshore wind development.

Representatives of the industry also called for early engagement with fishers in marine decisions, with some asking for mandatory consultation with fishers in marine decisions.

Renewables sector

Developers were supportive of implementation policies, stating that decision makers should apply all relevant policies consistently, underpinned by decision-making that is effective, transparent, equitable, and predictable.

This sectors representatives generally called for prioritisation of net zero targets and action on climate mitigation, with offshore wind developers strongly supporting prioritisation of space through the Sectoral Marine Plan (SMP).

An offshore wind developer also suggested that, if a development area has been assessed within the option areas within the SMP-OWE, the starting assumption should be that the location is generally suitable for the type of development, and should not need to be revisited in the consenting of individual projects.

Developers indicated support for pre-application engagement with regards to community-informed decision-making.

Environmental groups

ENGOs generally welcomed the emphasis on a “transparent, consistent and science based decision-making framework” within the implementation section and believed it to be a positive step. However, some respondents raised concerns with the apparent weakening of environmental protection, stressing the importance and emphasis on the prevention of environmental damage.

ENGOs requested prioritisation of space for nature and prioritisation of ecosystem-based management.

Respondents from ENGOs welcomed the concept of community-informed decision-making, acknowledging the “valuable knowledge” that local communities have about their local marine areas, which, when combined with scientific evidence, can help ensure decisions are “aligned with the realities” of the local environment and would support the local economy.

Public Sector (including Marine Planning Partnerships)

Regional Marine Planning Partnerships shared the opinion that implementation should be a “key consideration at all stages of policy development” with implementation guidance needed to support use the plan.

Government agencies were supportive of an implementation HLO and the policies that would support it, welcoming the “ambition for implementation to be considered alongside policy development”, including the interdependencies and relationships with other policies.

Generally, public sector representatives recognised the need for prioritisation in NMP2 and recommended alignment with NPF4, specifically ‘significant weight to the climate and nature crises’ in decision-making.

Notable additions

Other ideas presented by a small number of stakeholders for achieving prioritisation included prioritisation of projects which have the least impact, or those that demonstrate a nature positive contribution, while there were requests for prioritisation of shipping by those in the transport industry.

There were suggestions for alternative priority outcomes including co-existence and sustainable development, or climate and net-zero targets, or socio-economic sustainability and community resilience.

National Developments

Many developers also suggested the adoption of Critical National Priority infrastructure (projects to help meet net zero targets) in NMP2 (as a form of prioritisation) and raised the need for acceptability of some impacts from development (e.g. visual impacts from offshore wind farms) to achieve net zero.

Other marine plans

Historic Environment Scotland noted that the sectoral marine plans were consulted on as guides to relevant consenting bodies, but stated that they should not be considered as pre-determining decision-making processes.

With regards to community-informed decision making, there was notable suggestions that this could be effectively achieved via regional marine planning. This aligned with a wider expectation that NMP2 set the future direction for other marine plans (sectoral and regional).

Guidance

Many stakeholders raised the need for implementation guidance to be available at plan adoption, asked for clear definitions of terms throughout the NMP2 and clarity on approaches to monitoring.

There were calls for transparency in decision-making including how views expressed by communities or existing users are considered (or weighted) in decision-making, proportionate requirements for engagement and the need for engagement to be accessible and participatory.

Consensus

There was overwhelming support for the inclusion of planning policies on implementation, however the nature of those policies was subject to a variation of differing views.

While there were very clear differences in choice of priority, there was a prevailing theme observed throughout the PPS responses regarding a need for prioritisation in our marine space to ease conflict.

With regards to community-informed decision-making, this was heavily supported by many of the respondents, however it is evident that some concerns remain around the interpretation of this term and a belief that the term could easily be misinterpreted. Calls for clearer guidance were notable, and a sentiment shared across all sectors was the need for any policy to enable decision-making that was appropriate and proportionate to the scale and type of development.