Effectiveness Of Plan Policy And Progress Towards Securing Objectives
Evaluation of policies will help determine their effects, progress being made towards securing the Plan’s objectives and the relationship between policies and objectives. The process of understanding how a policy has been used and what effect it has had will help to determine whether or not policies are delivering as required. It will also help inform where policies could be improved in future plans.
In relation to the requirements for review, the legislation refers to ‘objectives for which the plan was prepared’. These strategic objectives are outlined in Annex B of the Plan and are a combination of the EU MSFD descriptors and the HLMOs. Within the Plan these are arranged around the sustainability principles.
The approach taken to evaluate the effectiveness of policies and progress towards securing objectives is two-fold: assessing monitoring programmes and other available data and information for their relevance to evaluation, and gathering feedback from public authorities and relevant interests. The following sections reflect this approach. Part 1 outlines the use of data monitoring and other information sources. Part 2 reflects feedback received from stakeholders engaged in the review process in response to questioning about policy effectiveness, and how well they consider policies to be delivering the strategic objectives.
Using data monitoring and other information sources to consider policy effectiveness
The strategic objectives of the Plan are identified as the EU MSFD descriptors and the HLMOs. The presentation of HLMOs in the MPS are arranged under the headings of the five guiding principles of sustainability to reflect a commitment to achieving sustainable use of marine resources. These also provide a structure to the Plan. This section focuses on considering data and information in relation to these themes:
- EU MSFD: Good Environmental Status ( GES) Descriptors,
- Achieving a sustainable marine economy,
- Ensuring a strong, healthy and just society,
- Living within environmental limits,
- Promoting good governance,
- Using sound science responsibly.
EU Marine Strategy Framework Directive: Good Environmental Status Descriptors
The aim of the EU MSFD, (Directive 2008/56/ EC) is to achieve GES by 2020. The MSFD identifies 11 descriptors which cover aspects of marine ecosystem structure and function, as well as effects of human activities. The MSFD requires targets and indicators to be defined for each descriptor, a monitoring programme to collect data to measure progress, and a programme of measures to cause the positive changes to the environment to achieve the targets. Although a target of 2020 was set by the EU, the Directive operated on continuous 6 yearly cycles.
These descriptors and the concept of GES have been adopted both in the UK MPS and are contained as strategic objectives of the Plan.
The Plan identifies the descriptors (Annex B) and targets associated with the MSFD as part of Scotland’s wider seas approach to marine nature conservation. It states that development and use of the marine environment must not compromise the achievement or maintenance of GES for UK waters (Plan section 4.58). As such these strategic objectives form part of the ecosystem approach adopted by the Plan.
It is important to note that the scale of assessment for MSFD is the North East Atlantic, with two sub-regions applicable to Scotland - North Sea and Celtic Seas. Assessments are currently being undertaken at the sub-regional scale.
The UK 2018 assessment of GES is being completed. This assessment will be published for consultation in mid-2018, and will include a range of indicator assessments to demonstrate progress towards GES.
Although the scale of assessments is larger than Scotland’s seas, monitoring of Scotland’s seas forms a substantial and important part of the UK assessment and will be reflected in the outcomes.
During 2017, the OSPAR Commission completed an “intermediate assessment” of the status of the North East Atlantic ( IA 2017). This assessment served both the need for OSPAR to assess the environmental status of the North-East Atlantic, but also enabled development of common indicators for Contracting Parties to use for MSFD purposes.
The resulting assessments cover 9 of the 11 descriptors (except commercial fish and hydrographic processes) and are based on 42 indicators (21 for human induced pressures, and 21 for biodiversity status). ( http://marine.gov.scot/information/ospar-intermediate-assessment-2017).
Although the IA 2017 assessments were conducted at a scale much larger than Scottish waters the process developed a number of new methodologies and indicators which will be useful to assess the state of Scotland’s seas. In addition, Scottish data was included in many of the OSPAR indicator assessments. Therefore, many of the highlights and key messages from the IA 2017 are relevant to Scotland and have been included on Scotland’s marine data and information portal Marine Scotland information http://marine.gov.scot/ and Marine Scotland Maps ( NMPI) http://marine.gov.scot/maps/nmpi.
The key messages from the OSPAR intermediate assessment show that there are improvements in many aspects of the North East Atlantic ecosystem arising from:
- expansion of the Marine protected Area network,
- decreasing discharges and concentrations of radioactive, hazardous substances and nutrient pollution from both land based and offshore installations,
- signs of improvement in fish communities.
However problems still exist or are increasing and include:
- localised impact of hazardous substances and eutrophication remain,
- problems are apparent for marine bird populations,
- benthic habitats impacted by bottom fisheries,
- a growing recognition that marine litter is a problem.
Many of these messages are likely to be true for Scottish waters as well as the North-East Atlantic as a whole.
In summary, it is not possible at the present time to definitively report on GES either at the sub-regional scale or UK-level and thereby derive information on Scotland’s progress towards its strategic objectives. However, both the IA 2017 and emerging UK assessments will provide information from new monitoring and assessment process which will inform marine planning.
Consideration of some MSFD indicator assessments at a Scottish Waters scale may be useful in both understanding and communicating the state of Scotland’s seas and helping inform management action through national and regional marine planning. Such work could be considered as part of a refresh of the assessments conducted under Scotland’s Marine Atlas http://www.scotland.gov.uk/Topics/marine/science/atlas and would provide further information on the extent to which the Plan’s strategic objectives are being achieved.
Achieving a sustainable marine economy
Marine Scotland is also making progress in developing its socio-economic evidence base for monitoring and reporting on the Plan’s contribution to (a) achieving a sustainable marine economy and (b) ensuring a strong, healthy and just society through the Marine Scotland Maps NMPi. Further work is on-going to produce a marine economic statistics report that would bring together official statistical evidence to inform indicators for monitoring progress across the economic sectors covered in the Plan. The main considerations for the socio-economic outcomes of the Plan and proposals for indicators for future monitoring are presented below.
The Purpose of the Scottish Government is to focus government and public services on creating a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth. The adoption of the HLMOs 1-4 as strategic objectives of the Plan sets out how this is envisaged to be achieved in Scottish waters.
- Infrastructure is in place to support and promote safe, profitable and efficient marine businesses. ( HLMO 1),
- The marine environment and its resources are used to maximise sustainable activity, prosperity and opportunities for all, now and in the future. ( HLMO 2),
- Marine businesses are taking long term strategic decisions and managing risks effectively. They are competitive and operating efficiently. ( HLMO 3),
- Marine businesses are acting in a way, which respects environmental limits and is socially responsible. This is rewarded in the market place. ( HLMO 4).
In 2015, Scotland’s marine economy generated directly £5.1 billion in GVA and employed 79,000 people.  It accounted for 4.1% of total Scottish GVA and 3.1% of total employment. Scotland’s marine economy is diverse, and it split into five broad sectors as follows:
- Fish-related activities: fishing; aquaculture; and, fish processing,
- Transport-related activities: boat building, repair and maintenance; construction of water projects and water transport services; sea and coastal passenger transport; and, sea and coastal freight water transport.
- Oil and gas services: exploration services and test drilling,
- Offshore renewable energy: wind, wave and tidal energy,
- Marine recreation and tourism.
An overview of key sectors making up Scotland’s Marine Economy is presented below.
Figure 5: Overview Of Scotland’s Marine Economy (£ Billion), 2015*
*Data currently not available for marine renewables and cables sectors
Marine Scotland is working to develop its evidence base for monitoring trends in these sectors of the marine economy and for future assessments of the marine environment. This will provide evidence for on-going monitoring and for future reviews of the impacts of the Plan on achieving a sustainable marine economy.
Marine Scotland is also developing specific indicators for monitoring the Plan’s impact. These indicators will include the following:
- economic contribution and profitability for the key marine economy sectors listed above ( HLMO 1 & 3);
- infrastructure development for the marine economy ( HLMO 1);
- patterns of employment in marine economic sectors ( HLMO 1 & 2);
- diversity of Scotland’s marine economy ( HLMO 2);
- performance of key sectors against relevant environmental limits and trends for key economic activities ( HLMO 4).
Ensuring a Strong, Healthy and Just Society
The HLMOs (5-10) for ensuring a strong, healthy and just society set out how it is envisaged that the marine environment will be appreciated and used to the benefit of communities and wider society. By providing healthy food and space for a wide range of recreational activities, Scotland’s marine environment can contribute to longer and healthier lives. Provision of jobs and their role in maintaining populations in coastal and island regions can contribute towards building strong, resilient and supportive communities.
The spread of some marine economy sectors like aquaculture and fishing to remote rural and island communities contributes to reducing regional inequalities in economic performance and in Scottish society. For example, in island communities of Shetland, Orkney and Western Isles, the marine economy accounts for 28%, 18% and 13% of gross value added, respectively. The Scottish Annual Business Survey data for 2014 shows that marine economy labour productivity ( GVA per worker) in these three islands is higher when compared to that of other sectors in the same locations.
The Plan seeks to ensure that:
- People appreciate the diversity of the marine environment, its seascapes, its natural and cultural heritage and its resources and act responsibly ( HLMO 5);
- The use of the marine environment is benefiting society as a whole, contributing to resilient and cohesive communities that can adapt to coastal erosion and flood risk, as well as contributing to physical and mental wellbeing ( HLMO 6);
- The coast, seas, oceans and their resources are safe to use ( HLMO 7);
- The marine environment plays an important role in mitigating climate change ( HLMO 8);
- There is equitable access for those who want to use and enjoy the coast, seas and their wide range of resources and assets, and recognition that for some island and peripheral communities the sea plays a significant role in their community ( HLMO 9); and,
- Use of the marine environment will recognise, and integrate with, defence priorities, including the strengthening of international peace and stability and the defence of the United Kingdom and its interests ( HLMO 10).
Marine Scotland will develop specific indicators for monitoring various impacts of the Plan, including those relating to HLMOs 1-5. These indicators will include the following:
- the geographic distribution of marine economic activities and employment, and the relative importance in coastal and island communities;
- the level and patterns of engagement with Scotland’s marine environment for recreation and tourism or cultural purposes ( HLMO5 & HLMO 9);
- levels and patterns in the cleanliness and safety of Scotland’s marine environment ( HLMO 7);
- contributions of the marine environment to Scotland’s total energy generation ( HLMO 8); and,
- the extent to which Scotland’s marine environment is contributing to activities of the UK defence industry ( HLMO 10).
Living within environmental limits
In relation to this theme, the Plan contains the following strategic objectives
- Biodiversity is protected, conserved and, where appropriate, recovered, and loss has been halted. ( HLMO 11)
- Healthy marine and coastal habitats occur across their natural range and are able to support strong, biodiverse biological communities and the functioning of healthy, resilient and adaptable marine ecosystems. ( HLMO 12)
- Our oceans support viable populations of representative, rare, vulnerable and valued species. ( HLMO 13)
Marine Scotland and its partners undertake a very wide range of marine environment monitoring in order to undertake assessments of the state of Scotland’s seas and inform marine management. Most of this monitoring is undertaken according to a set of strategies and coordinated at a UK or Scottish level. At the UK level, the UK Marine Monitoring and Assessment Strategy ( UKMMAS) provides a coordination framework for marine monitoring across the key themes of “ Clean and Safe”, “Healthy and Biologically Diverse”, “Productive” and “Ocean Processes” ( http://marine.gov.scot/information/ospar-intermediate-assessment-2017).
Each of these “Evidence Groups” coordinates the ongoing monitoring, assessment and data reporting of monitoring type. Monitoring is conducted according to the principles of the Scottish environmental monitoring strategy http://www.gov.scot/Publications/2011/12/05085553/0 with some monitoring types being subject to specific monitoring strategies such as the Scottish MPA network http://www.gov.scot/Topics/marine/marine-environment/mpanetwork/MPAmonitoring, with some Scottish level coordination provided by e.g. the Scottish Marine Monitoring Coordination Group ( SMMCG).
An extensive range of environmental monitoring is undertaken in Scotland’s seas. Key monitoring themes focus on:
- Fish and shellfish stock health – Co-managed offshore stocks
- Fish and shellfish stock health – Nationally managed inshore shellfish stocks
- Clean and Safe Seas
- Biodiversity - MPA Condition
- Biodiversity - Cetaceans
- Biodiversity - Seabirds
- Impact of Aquaculture
- Prevailing Conditions – Oceanography
Using Marine Scotland Maps NMPi and the Marine Scotland Information portal: http://marine.gov.scot/ an evidence base is being developed to bring monitoring results into the public domain.
Policies to protect and enhance natural heritage
HLMOs 14-18 are implemented by a range of policies across the Plan but most notably by General Policy 9 Natural Heritage which states that development and use of the marine environment must:
- (a) Comply with legal requirements for protected areas and protected species.
- (b) Not result in significant impact on the national status of Priority Marine Features ( PMF).
- (c) Protect and, where appropriate, enhance the health of the marine area.
A number of work streams are underway which have associated reporting mechanisms which will, in the future, provide data and information of relevance in assessing the progress towards achieving HLMOs. These include a Report to Scottish Parliament on the status of the MPA network which will be submitted in 2018. In addition to this, there is a commitment under the Programme for Government to carry out a review of the level of protection given to the most vulnerable PMFs, particularly those in coastal waters. A scoping report on this will be published in 2018 for consultation.
A new research programme of work has been initiated to build on recent findings into the value of our blue carbon resource, which is estimated to be more effective at carbon capture and storage than the terrestrial environment. The focus will involve measuring the ability of various habitats to sequester carbon, understanding how it is stored for the long term, and building an evidence base on the effects that human activities may have on these processes. Once the research projects are complete the expectation is that we will be better informed on how the marine environment can benefit the Scottish Climate Change Adaptation Programme, and how the Plan can assist in delivering potential benefits through protection of ecosystems and further development of climate change policies.
Further information on the current research Programme can be found on Marine Scotland’s Blue Carbon topic sheet: http://www.gov.scot/Topics/marine/Publications/TopicSheets/tslist/BlueCarbon
Promoting good governance
The HLMOs 14–18 characterise the way in which governance of marine environment is envisaged, while a number of policies throughout the Plan, most notably General Policies 15-18 intend to deliver these. In general, the framework of marine planning in Scotland supports these objectives by promoting engagement at national and regional levels and by encouraging integration of marine, land and water management mechanisms.
Regional marine planning
Marine planning is being implemented at a local level through Scottish Marine Region to take account of local circumstances. Within 11 SMRs (designated by order out to 12 nautical miles) marine planning will be undertaken by MPPs comprising of relavant local authorities and representatives of marine interests. Marine Planning Partnerships have been established in Shetland and Clyde Regions with others to follow in due course (starting with Orkney Islands). Regional plans have to comply with national policy. The Plan also sets specific regional policies for the purpose of steering regional marine planning.
Both the established MPPs are in the early stages of regional plan development and therefore their experience has not been directly captured in this review. However, it is expected that as regional marine planning develops the process will be iterative in terms of exchange of information on policy effectiveness and progress of objectives from a national to regional level and vice versa.
The representation of multiple marine interests in MPP structure and governance is deliberate and is intended to ensure fair and equal participation in the plan decision making processes. Lessons learned from the establishment of the Shetland and Clyde partnerships will influence implementation of future partnerships and provide evidence as to how this level of participation and engagement in marine plans works. Engagement of public and wider interests will be undertaken by consultation at early stages of the regional plan development to enable a range of views to be reflected.
Local development planning and other management frameworks
The Marine (Scotland) Act 2010 recognises the importance of alignment between marine and terrestrial frameworks through the requirement for RMPs to be compatible with development plans for adjoining areas. This is mirrored in Town & Country Planning (Development Planning) (Scotland) Regulations 2008 as amended http://www.legislation.gov.uk/ssi/2008/426/contents/made. Policy consistency between marine and terrestrial plans is important for the activities and industries which span the terrestrial/marine interface. The Plan seeks to make these legal obligations explicit within plan led decision processes by the inclusion of policies in the Plan requiring alignment between marine plans and relevant statutory and non statutory plans.
As a key agency, Marine Scotland regularly responds to Local Authority consultation. It uses the Plan and its policies to encourage inclusion of Plan policy in local and strategic development plans and to encourage alignment of terrestrial and marine frameworks. As the cycle of renewal of development plans continues there is evidence that reflection of marine policy is beginning to emerge albeit not consistently.
With regards to other management frameworks and plans, some public authorities have indicated work areas where change had been implemented or where progress is being made. Crown Estate leasing for renewable energy development and the development of planning guidance, amendments of standing advice from statutory advisors and the representation of River Basin Management Coordinators on MPPs refers to the latter.
Further integration of River Basin Management Plans and flood management into marine planning were highlighted in responses as areas where progression was underway but which could be enhanced by closer working between Marine Scotland and relevant bodies.
This could equally apply to working with Local Authorities to make further progress on integrating marine policy across all relevant public authorities.
Using sound science responsibly
HLMOs 19, 20 and 21 set out how the Plan will take account of using sound science responsibly by:
- Our understanding of the marine environment continues to develop through new scientific and socio-economic research and data collection. ( HLMO 19)
- Sound evidence and monitoring underpins effective marine management and policy development. ( HLMO 20)
- The precautionary principle is applied consistently in accordance with the UK Government and Devolved Administrations’ sustainable development policy. ( HLMO 21)
The primary source of evidence to support the Plan is ‘ Scotland’s Marine Atlas’ http://www.scotland.gov.uk/Topics/marine/science/atlas with associated information and data layers available on Marine Scotland Information ( http://marine.gov.scot/ and MS Maps NMPi ( http://maps.marine.gov.scot) The portals act as central repositories for all spatial data currently available to Marine Scotland and are freely available to assist statutory authorities implement the Plan.
Although data and assessments in the Marine Atlas reflect those that were current at the time of developing the Plan, new evidence and data of the types underpinning the Atlas assessments are continually being sourced and made available on MS Maps NMPi. Content of NMPi is also regularly reviewed for currency and scope and displayed by a tool with improved functionality, under the direction of The Scotland’s Seas Data and Assessment Group which includes Marine Scotland, SEPA, SNH, Joint Nature Conservation Committee ( JNCC) and Marine Alliance for Science and Technology for Scotland ( MASTS) representatives.
As new spatial data types become available, Marine Scotland has, where possible, made data sets available in an INSPIRE compliant and downloadable format via the MS Maps NMPi portal. Since the Plan came into force, Marine Scotland has sourced or created 439 new marine data layers and made them available on NMPi. Data have also been kept current during this period with 261 data layers being updated. The total number of data sets on NMPi is 940 layers (approx). Many of these will enable new assessments of the state of Scotland’s seas to be undertaken and determine whether new management action is needed. This demonstrates an active evidence gathering and dissemination process supporting marine planning in Scotland.
Requirements for new evidence are assessed continually and priorities identified in accordance with existing strategies such as:
- the Scottish Marine Science Strategy 2010-2015 http://www.scotland.gov.uk/Publications/2011/03/02092716/0
- the UK Marine Science Strategy 2010-2025 https://www.gov.uk/government/publications/uk-marine-science-strategy-2010-to-2025
- sectoral strategies such as the Aquaculture Science and Research Strategy http://www.scotland.gov.uk/Publications/2014/07/4459 and
- research frameworks such as the Scottish Offshore Renewables Research Framework ( SpORRAn) http://www.gov.scot/Topics/marine/marineenergy/mre/research
Prioritisation and commissioning of new evidence is often through a joined-up and collaborative process involving industry, academia, and other national and international bodies. Examples of these include Marine Alliance for Science and Technology for Scotland ( MASTS) the UK Marine Management Organisation ( MMO) the International Council for Exploration of the Sea ( ICES) and the OSPAR Commission.
Stakeholder evidence as a measure of policy effectiveness
The review process, which involved engagement with a range of marine interests, indicates that overall the Plan is perceived as a valuable document which pulls together the appropriate policies and practices relating to marine planning. In general the HLMOs and policies are considered to be comprehensive and still relevant. The whole process of developing the Plan is reported as positive; building long-standing and effective stakeholder relationships has led to a collective understanding of each other’s sectors and issues. However, issues were raised, including new and emerging policies, developments and initiatives, which the next Plan would be expected to address.
A number of those who participated in the review suggested it was too early to report on the effects of the Plan as internal policies of public authorities were still being aligned with the Plan and put into practice. The fact that the Plan has only been in effect a relatively short time was also thought to make it difficult to assign change directly to it. Others thought the Plan will not fully be delivered until RMPs are in place to apply national policy and objectives to local issues. Nevertheless, the review was considered timely and was regarded as an opportunity to refocus on the purpose of the Plan and the responsibility on public authorities to implement it.
Effectiveness of policies in relation to decision or policy making
Relevant public authorities, industries and sectors were asked to provide information or evidence which illustrated how useful, or otherwise, the Plan is to decision making or policy development. They were asked for examples of specific policies which are helpful to their decision making, or which cause difficulties. They were also asked which policies contribute, or are counterproductive, to meeting strategic or sector objectives of the Plan.
A number of policies and general aspects of the Plan were identified as being particularly effective or useful to decision making. The following refers to some key areas identified:
- New policies given statutory status by the Plan, such as those in relation to cables (Chapter 14) and PMFs (General Policy 9, natural heritage) had been helpful in influencing and underpinning decision making. These are examples of new policies introduced for the first time by the Plan and have therefore provided new direction to decision makers. The PMF policies have been central to action taken in Loch Carron to protect features of importance following damage by fishing activity.
- Sea Fisheries policy 3, which requires fishing mitigation plans to be developed, had resulted in the provision of information which had influenced decisions. It had also encouraged discussion between different interests.
- Marine litter and invasive non-native species have been given a focus within decision making. Both areas have become prominent in recent years in response to increasing awareness and evidence regarding their impacts. Inclusion of policies within the planning process highlights them as issues central to decision processes.
- The Plan has informed leasing approaches for commercial scale energy and has helped ensure policies of public authorities are aligned with those of Scottish Government. The Plan recognises marine renewable energy ‘plan options’ i.e. areas identified in sectoral plans as strategic development zones in which commercial scale operations should be sited. This has informed Crown Estate’s leasing approaches.
- The objectives of the Plan have influenced business delivery planning.
In addition to these specific points, feedback highlighted that value was attached to the encouragement the Plan gives to different sectors and groups to work together within a marine planning framework. The information it provides about other marine users and how compatible, or otherwise, different activities may be was also considered helpful by various marine interests.
The statutory basis for taking terrestrial/marine interactions into account within LDPs was highlighted as beneficial. Previously this had mostly been influenced by advice from statutory advisors via consultation processes and had not been undertaken routinely. It was also highlighted that where the Plan’s policies extend beyond LDP policies in relation to the coast, value is added to decision making in coastal areas.
Policies which are considered challenging to the decision making process
A number of policies or general attributes of the policies were identified as being challenging to the decision making process. The following refers to key areas identified in feedback:
- policy wording in certain areas, for example the inclusion of ‘support’ or ‘should’, was not considered strong enough to directly influence decision making,
- the socio-economic policies need to be more explicit and more directive for use within regulatory processes,
- while some policies are helpful and lead to better decision making, their positioning within the Plan means they can be overlooked. One example is Sea Fisheries 3; this requires fisheries mitigation plans to be developed in relation to proposed development and use, but its location in the Sea Fisheries chapter means it may not be noticed by all users of the Plan,
- Aquaculture 4 places a presumption on locating shellfish farms in areas designated as shellfish waters if these have sufficient capacity to support such development. A number of these currently have downgraded water quality and so there is a concern that directing shellfish farms to those particular areas would be disadvantageous for the sector.
- General Policy 9 regarding PMFs is helpful but there is no sufficient process to track accumulation of multiple impacts and therefore assess impact on national status as required.
- the cumulative effects of sectoral policies within decision making processes was challenging to determine.
It was also suggested that the Plan could be made more effective by introducing clearer priorities, or by introducing primacy of policies. This would offer clearer direction to decision makers. This and the introduction of guidance to help interpret policies were suggested as necessary to reduce ambiguity and lead to consistent application of policies. In particular conflict between oil and gas objectives and policies to maximise recovery and the climate change objective to facilitate a transition to a low carbon economy was referred to. However it was suggested that such incompatibilities could be managed by taking a longer term vision for the Plan as this would allow development of policies over time and a progression towards longer term goals.
A key point raised was that voluntary measures may not be sufficient, or regulatory mechanisms are not available, to effectively implement policies such as those in relation to aspects of tourism and recreation. An assessment of whether policies rely on voluntary measures or whether regulatory mechanisms exist to implement them could determine how likely it is for a policy to deliver an outcome.
The legislative basis for effectiveness of the Plan was also raised. It was suggested that if activities which do not have their management delivered through licensing, e.g. fishing, and are therefore not captured by legislation as ‘authorisation and enforcement decision’, the relevant authorities must only ‘have regard’ to rather than make decisions in accordance with marine plans. It was queried that if the relevant legislation differentiates between licensable and non-licensable activities on different footings, then the intention of a fair and level planning framework could be undermined and hinder the potential to deliver policies and objectives.
Aquaculture policies and objectives were raised in a number of responses. In particular the reflection of industry production targets within an objective was suggested to be in conflict with the approach taken for other sectors, and consequently arguably at odds with the environmental policies and sustainability principles of the Plan. While application of the Plan’s policies apply to decision making to ensure sustainability, future iterations of the Plan will afford an opportunity to consider this issue further.
Policies which deliver strategic or sectoral objectives
Those engaged in the review process were asked to specifically consider the effectiveness, or otherwise of the policies in the Plan in achieving HLMOs and individual sector objectives. Relatively few specific examples were offered in response to this question, which may in part reflect that there is more of a focus on using policies to deliver outcomes than consideration of objectives, sectoral or strategic.
The following examples were provided
- The designation of the emergency MPA in Loch Carron through Plan Policy General 9(b) helped contributed to meeting the HLMO “living within environmental limits”
- Inconsistencies between aquaculture targets and the Plan’s environmental commitments were highlighted with specific reference to HLMOs 2, 4, 11, 15 and 20, general policies and sectoral policies relating to Wild Salmon and diadromous fish.
- Objectives relating to maximising oil and gas exploration and recovery of fossil fuel are considered to be in conflict with commitments to mitigating and adapting to climate change. This was seen to be contrary to general policy 5 and HLMO 2.
- The language applied in Plan policies and HLMO can result in challenges for decision makers in taking a clear direction from the Plan.
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