Publication - Consultation paper

National Marine Plan: Sustainability Appraisal Report

Published: 24 Jul 2013
Part of:
Marine and fisheries
ISBN:
9781782567677

This report summarises the findings from a Sustainability Appraisal (SA) of the draft National Marine Plan (NMP). SA of the draft plan is required by the Marine and Coastal Access Act 2009. The SA has considered the potential social, economic and enviro

172 page PDF

2.9 MB

172 page PDF

2.9 MB

Contents
National Marine Plan: Sustainability Appraisal Report
5.0 Sustainability Appraisal Results

172 page PDF

2.9 MB

5.0 Sustainability Appraisal Results

5.01 This results of the sustainability appraisal are provided in the detailed appraisal tables in Appendix 3. This section provides a summary of this information.

5.02 The potential effects of the sectoral objectives and policies on each of the SA topics are reported. Sections 5.1- 5.7 provide information on environmental effects. Effects on socio-economic interests are discussed in Section 5.8. The appraisal of alternatives and cumulative effects is discussed in Sections 5.9 and 5.10 respectively. This structure is intended to satisfy the request of the Consultation Authorities that the environmental information be easily accessible.

5.1 Biodiversity, Flora and Fauna

Will the draft Plan …

8

Avoid disturbance of key species as a result of marine activities?

9

Safeguard marine and coastal ecosystems and their interactions? [89]

5.1.1 As noted in Section 3, there are existing pressures on biodiversity (including flora and fauna) from many of the activities and uses of the marine environment. Climate change is also exerting pressure on biodiversity.

5.1.2 The objectives and policies of the draft NMP recognise and address the potential for effects on biodiversity, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.1.3 The NMP recognises its role in setting policy for the sea fisheries sector, within the context of the Common Fisheries Policy and the powers of the Scottish Government to put domestic management measures in place. Both objectives and policies recognise the pressures on biodiversity resulting from fishing and fishing practices:

  • The objectives aspire to sustainable harvesting using maximum sustainable yield. They are also directed to changing specific fishing practices, including maximising annual quota opportunities, monitoring total removals from the sea (rather than landings) and tackling the issue of discards. They recognise the need to manage fisheries in line with international and national environmental priorities.
  • The policies focus on managing fishing to ensure sustainability of fish stocks. They also identify the desired outcomes for sea fisheries of marine planning, e.g. protection of vulnerable stocks, improved protection of the seabed, and the need for other sectors (when planning their activities) to take into account the need to protect fish and shellfish stocks and sustain healthy fisheries. There is also an overall requirement for other sectors to consider the environmental impact on fishing generally.

5.1.4 Most of the policies are focused on the sustainability of the sea fisheries sector but, in doing so, they have positive implications for the sustainability of fish stocks as well.

5.1.5 Policy 3 identifies the need for protection of the seabed and the mitigation of impacts of fishing. We have therefore assumed that the term "sustainable" encompasses sustainable fishing gear issues and anticipate that the regional marine plans (with input from Inshore Fisheries Groups) will identify suitable regional/local policy regarding gear, using the national policies as a starting point.

5.1.6 The aspiration to maximise annual quota opportunities (Objective 2) should be viewed in the light of the aspiration to fish at maximum sustainable yield: the two should work together in the long-term to achieve sustainable fish stocks. In addition the cross-cutting general policies will assist both Scottish Government and regional marine plans in reducing the effect of fisheries on biodiversity in the long term.

5.1.7 It is anticipated that, in the long term, these policies and objectives (taken together with the cross-cutting general policies) will have positive implications for biodiversity.

Aquaculture

5.1.8 The aquaculture policies recognise the pressures on biodiversity resulting from aquaculture:

  • Locational policies, when developed, will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry.
  • Sustainable growth of the aquaculture industry is supported. As with sea fisheries, we have assumed that the term "sustainable" encompasses planning to avoid issues around sea lice, escapes, benthic habitat, nutrient enhancement, seals etc.
  • The policies recognise that aquaculture must be located appropriately and explicitly require that the following issues be addressed in planning and development:
    • wild salmon interests on the north and east coasts
    • nutrient enhancement
    • benthic impacts
    • wild salmon in general
    • control of seals
    • escapes (through requirements around equipment specification)
    • sea lice

5.1.9 The objective to support growth in aquaculture production has the potential for adverse effects. However, the objective notes that the support is for sustainable production. The cross-cutting general policies in the draft NMP, e.g. GEN11 and 12, also require that this growth be progressed sustainably, avoiding adverse effects on biodiversity. In addition, sectoral policy (Aquaculture 2) requires that Marine Scotland's future spatial aquaculture planning guidance be taken into consideration. We therefore anticipate that adverse effects on biodiversity will be prevented through application of this overall policy framework.

Wild Salmon and Migratory Fish

5.1.10 The policy on wild salmon and migratory fish requires that these interests be considered when progressing regional marine plans and making decisions at the project level. We have assumed that this includes working to avoid adverse effects (such as those identified in Section 3) and therefore anticipate that adverse effects on biodiversity will be prevented through application of this policy.

Oil and Gas

5.1.11 The policies and objectives support the continuing exploitation of oil and gas, but recognise that this must be at "minimum environmental cost". We have assumed that this will include, for example, avoidance of seismic disturbance of cetaceans, air and water pollution incidents, etc. Taken together with the general cross-cutting policies, we therefore anticipate that adverse effects on biodiversity will be prevented. However, it should be recognised that policies alone will not prevent pollution and that regulatory agencies will continue to encourage prevention of accidents and/or pollution incidents.

Carbon Capture and Storage

5.1.12 The policies focus on the re-use of existing infrastructure and the development of marine utility corridors, which would prevent further disruption of the marine environment, particularly the seabed. Assuming that pollution incidents/issues are avoided, these advantages should not be offset by contamination issues (which would have implications for biodiversity).

5.1.13 Objective CCS 5 explicitly recognises the need for an environmental assessment to allow early consideration of these issues in the deployment of CCS. Taken together with the general cross-cutting policies, we anticipate that adverse effects on biodiversity will be avoided.

Renewable Energy

5.1.14 The policies and objectives for renewable energy recognise the need for development in this sector to be sustainable. For the purposes of this assessment, we have assumed that "sustainable" therefore includes avoidance of unacceptable adverse effects on biodiversity ( e.g. obstacles to migration; noise disturbance during construction and operation; collision risk for birds, fish and cetaceans; benthic effects of anchoring; etc.). Taken together with the general cross-cutting policies, we therefore anticipate that adverse effects of biodiversity will be avoided.

5.1.15 This framework will also apply to the objectives for growth of this sector.

Recreation and Tourism

5.1.16 The policies and objectives for recreation and tourism recognise the need for development in this sector to be sustainable. We have assumed that "sustainable" will include management of such issues as disturbance of wildlife, trampling effects, benthic impacts, etc. This, taken together with the cross-cutting policies, should offset the growth aspirations expressed in the objectives, in particular, and result in the avoidance of adverse effects on biodiversity. This will be strengthened through the policies' identification of the need to avoid unacceptable impacts on sensitive or important habitats and species, and for compliance with codes of practice on invasive non-native species.

Transport

5.1.17 The policies and objectives explicitly recognise the need to reduce emissions to air, including greenhouse gases, by supporting fuel efficiency and making shore-based electricity available. They also focus on ensuring that this sector is able to adapt to the consequences of climate change.

5.1.18 Any development of port and harbour facilities (Transport 4) would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on biodiversity would be avoided. This will rely on biodiversity issues (particularly those relating to Natura sites) being integrated into project planning and design.

Telecommunications

5.1.19 The policies and objectives, taken together, should work to avoid adverse effects on biodiversity including, for example, further loss, damage or disturbance of benthic habitat through additional cable laying.

Defence

5.1.20 The objectives and policies will not affect biodiversity. (Although operational activities may have some adverse effects, these are outwith the scope of this SA.)

Aggregates

5.1.21 The policies explicitly recognise the need for environmental issues to be considered in consenting and licensing, and emphasise sediment transport and coastal process issues. Taken together with the general cross-cutting policies, we anticipate that adverse effects on biodiversity will not be significant in the long-term.

5.2 Water

Will the draft Plan …

10

Avoid pollution of the coastal and marine water environment?

11

Maintain and/or improve the ecological status of Scottish waters?

5.2.1 There are existing pressures on the coastal and marine water environment (including biodiversity) from many of the activities and uses of the marine environment. These include historical contamination of sediments; diffuse pollution (including eutrophication); oil spills; and marine litter. Climate change is also exerting pressure on water through, e.g. increases in sea temperature etc.

5.2.2 The objectives and policies of the draft NMP recognise and address the potential for effects on the water environment, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

5.2.3 Note: a key objective for the assessment of water quality is "Maintain and/or improve the ecological status of Scottish waters". This has been interpreted in the SA as the ability of Scottish waters to support marine biodiversity, and is therefore discussed in Section 5.1 (biodiversity) to avoid double counting.

Sea fisheries

5.2.4 The key issue for the fisheries sector in regard to water quality is accidental spills e.g. oil, as noted in Section 3.3.

5.2.5 Fisheries Objective 9 explicitly recognises the need to support international and national environmental priorities, which includes water quality. For the purposes of this assessment we have assumed that this includes compliance with MARPOL (Annex I of the International Convention for the Prevention of Pollution from Ships, 1973, as modified).

5.2.6 Fisheries Policy 4 focuses on protecting the environmental quality that underpins sea fisheries, and includes considering potential environmental effects on fishing grounds resulting from uses of the marine environment, so overall is positive for water quality.

5.2.7 It is anticipated that, in the long term, these policies and objectives (taken together with the cross-cutting general policies) will have positive implications for water.

Aquaculture

5.2.8 Objective 2 is focused on increases in sustainable production, which has the potential for adverse effects on water quality ( e.g. nutrient release). The cross-cutting policies ( GEN11 and GEN18) will be key here, as will the spatial planning exercise for aquaculture referred to in Objective 4 and Policy 2. We therefore anticipate that adverse effects on water quality will be prevented through application of this overall policy framework.

5.2.9 The aquaculture policies recognise the pressures on water quality resulting from aquaculture:

  • Locational policies, when developed, will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry.
  • Sustainable growth of the aquaculture industry is supported. As with sea fisheries, we have assumed that the term "sustainable" encompasses planning to avoid issues around nutrient enhancement, use of therapeutant, etc.
  • The policies recognise that aquaculture must be located appropriately; for the purposes of this assessment, we have assumed that "appropriately" will include water quality interests, including assimilative capacity.

Wild Salmon and Migratory Fish

5.2.10 As for biodiversity, the policy on wild salmon and migratory fish requires that these interests be considered when progressing regional marine plans and making decisions at the project level. We have assumed that this includes working to avoid adverse effects, and therefore anticipate that adverse effects on water quality will be prevented through application of this policy.

Oil and Gas

5.2.11 The policies and objectives support the continuing exploitation of oil and gas, but recognise that this must be at "minimum environmental cost". The policies, in particular, recognise the need for use of best available technology and practices to reduce risk of spills, etc. As for biodiversity, we have assumed that this will result in the reduction of water pollution incidents. Taken together with the general cross-cutting policies, we therefore anticipate that adverse effects on water quality will be prevented.

5.2.12 ACOPS (2011) reported discharges from oil and gas installations and vessels operating in UK waters, as noted in Section 3.3. It should therefore be recognised that policies alone will not prevent pollution, and Marine Scotland will work alongside other agencies to encourage prevention of accidents and/or pollution incidents.

Carbon Capture and Storage

5.2.13 The policies focus on the re-use of existing infrastructure and the development of marine utility corridors, which would prevent further disruption of the marine environment, particularly the seabed. Assuming that pollution incidents/issues are avoided, these advantages should not be offset by contamination issues (which would have implications for water quality).

5.2.14 Objective CCS 5 explicitly recognises the need for an environmental assessment to allow early consideration of these issues in the deployment of CCS. Taken together with the general cross-cutting policies, we anticipate that adverse effects on water quality will be avoided.

Renewable Energy

5.2.15 The policies and objectives for renewable energy recognise the need for development in this sector to be sustainable. For the purposes of this assessment, we have assumed that "sustainable" therefore includes avoidance of unacceptable adverse effects on water quality ( e.g. spills during construction/installation). Taken together with the general cross-cutting policies, we therefore anticipate that adverse effects on water quality will be avoided.

Recreation and Tourism

5.2.16 The policies and objectives for recreation and tourism recognise the need for development in this sector to be sustainable. We have assumed that "sustainable" will include management of such issues as increased water abstraction and increased volumes of effluent discharges ( e.g. sewage) resulting from increases in numbers of visitors. This, taken together with the cross-cutting policies, should offset any negative aspects of the growth aspirations expressed in the objectives, in particular, and result in the avoidance of adverse effects on water quality. This will be strengthened by the sustainable development approach recommended for regional marine planning in Policy 2. In addition, the policies' identification of the need to avoid unacceptable impacts on sensitive or important habitats and species will provide positive support for water quality, given that these habitats and species are reliant on good water quality.

Transport

5.2.17 The policies and objectives emphasise the need to maintain navigational safety and thereby prevent collisions and consequent oil spills (as discussed in Section 3.3), which has benefits for water quality.

5.2.18 Any development of port and harbour facilities (Objectives 2 and 3 and Transport 4) would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on water quality would be avoided. This will rely on water quality issues being integrated into project planning and design.

Telecommunications

5.2.19 The policies and objectives, taken together, should work to avoid adverse effects on water quality including, for example, increases in local water turbidity and/or smothering by preventing unnecessary additional cable laying.

Defence

5.2.20 The objectives and policies do not incur change from existing defence activities and uses of the marine environment, and therefore will not further affect water quality.

Aggregates

5.2.21 Policy 2 explicitly recognises the need for environmental issues to be considered in consenting and licensing. Taken together with the general cross-cutting policies, we anticipate that adverse effects on water quality from aggregate extraction ( e.g. increased local turbidity and/or smothering) will not be significant in the long-term.

5.3 Air Quality

Will the draft Plan …

12

Avoid adversely impacting on air quality, with particular regard to known existing concentrations of transport and industrial related pollution close to the coast?

5.3.1 There are some pressures on the coastal and marine water environment (including air quality) from some of the activities and uses of the marine environment. Pressures include: emissions of NOx, SOx and particulates from shipping and other vessels; possible effects on human health in residential areas adjacent to ports and harbours; and emission of pollutants from infrastructure development and/or marine activities.

5.3.2 The cross-cutting policies ( GEN15) of the draft NMP recognise and address the potential for effects on air quality, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.3.3 Fishing vessels give rise to atmospheric emissions as a result of fuel use. Emissions of sulphur dioxide and nitrous oxides are controlled.

Aquaculture

5.3.4 As with sea fisheries, atmospheric emissions from vessels supporting aquaculture operations are regulated.

Wild Salmon and Migratory Fish

5.3.5 Wild salmon and migratory fish are not known to affect air quality.

Oil and Gas

5.3.6 Oil and gas installations give rise to atmospheric emissions at the local level.

Carbon Capture and Storage

5.3.7 It is not envisaged that the carbon capture and storage sector will give rise to atmospheric emissions, so marine air quality is unlikely to be adversely affected by this sector.

Renewable Energy

5.3.8 As with sea fisheries and aquaculture, atmospheric emissions from vessels supporting renewable energy operations are regulated.

Recreation and Tourism

5.3.9 As with sea fisheries and aquaculture, atmospheric emissions from recreational and/or tourism-related vessels are regulated.

Transport

5.3.10 As with sea fisheries and aquaculture, atmospheric emissions from vessels are regulated.

5.3.11 However, there is one AQMA in Scotland adjacent to a port, in Aberdeen (see Section 3). Aberdeen City Council is monitoring the situation.

5.3.12 Any development of port and harbour facilities (Objectives 2 and 3 and Transport 4) would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on air quality could be avoided. This will rely on air quality issues being integrated into project planning and design.

5.3.13 In addition, Objective 6 requires that the sector considers air quality implications as part of its consideration of climate change mitigation and adaptation.

Telecommunications

5.3.14 As with the other sectors, atmospheric emissions from cable-laying vessels are regulated. In consequence, this sector is not known to adversely affect air quality.

Defence

5.3.15 As noted earlier, atmospheric emissions from vessels supporting renewable energy operations are regulated.

Aggregates

5.3.16 As noted earlier, atmospheric emissions from vessels supporting renewable energy operations are regulated .

Overall

5.3.17 Vessel movements around the UK give rise to atmospheric emissions including SOx, NOx and particulates. It is difficult to identify vessels from one particular sector as being responsible, as it is likely that all contribute, despite emissions being controlled. The mapping of air quality for the UK shows that there are concentrations of certain pollutants in and around key shipping transport routes around the Scottish coast. Areas with higher concentrations of SO 2, NO x and/or particulates include the Firth of Forth, Firth of Clyde, Irish Sea, routes around the west of Eilean nan Siar, and routes between Orkney and Shetland.

5.3.18 None of the sector-specific polices or objectives deals directly with air quality. However, cross-cutting policy GEN15 requires that air quality is taken into consideration when progressing development and use of the marine environment.

5.4 Seascape/Landscape

Will the draft Plan …

17

Ensure that the value and special qualities of designated landscapes is protected?

18

Recognise and respect the value of wider (non-designated) landscapes and seascapes?

19

Encourage sectors to take into account the relative sensitivities of different seascapes?

5.4.1 There are existing pressures on the coastal and marine water environment (including landscape and seascape) from many of the activities and uses of the marine environment. These include aquaculture; offshore wind; and development in sensitive seascapes/landscapes. The effects of climate change may also exert indirect effects on landscape through, for example, increased erosion of coastal features. There is also a need for seascape sensitivity to be recognised generally.

5.4.2 The objectives and policies of the draft NMP recognise and address the potential for effects on landscape and seascape, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.4.3 Sea fisheries are not known to directly affect landscape/seascape interests. Indirect effects may occur through marine litter arising from fisheries; work to control marine litter is being progressed through the Marine Litter Strategy.

Aquaculture

5.4.4 Objective 2 is focused on increases in sustainable production, which has the potential for adverse effects on landscape, particularly if production increases result in additional aquaculture facilities. We have assumed that the definition of "sustainable growth" includes consideration of seascape/landscape issues, and therefore anticipate that adverse effects on seascape/landscape will be prevented through application of this overall policy framework.

5.4.5 The aquaculture policies recognise the pressures on seascape/landscape resulting from aquaculture:

  • Locational policies, when developed, will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry.
  • Sustainable growth of the aquaculture industry is supported. As with sea fisheries, we have assumed that the term "sustainable" encompasses planning to avoid adverse effects on seascape/landscape.
  • The policies recognise that aquaculture must be located appropriately; for the purposes of this assessment, we have assumed that "appropriately" will include seascape/landscape interests.
  • In addition, Policy 4 requires that siting and design guidance should be taken into account in planning and decision-making

Wild Salmon and Migratory Fish

5.4.6 Wild salmon and migratory fish activities are not known to affect landscape/seascape interests.

Oil and Gas

5.4.7 Oil and gas installations may affect seascape by their presence, but are generally out of sight of land and/or tourism/recreation interests. Should this situation change, for example, by siting installations closer to shore or in the vicinity of sensitive landscapes ( e.g. St Kilda), then the cross-cutting policies would come into play to manage adverse effects.

Carbon Capture and Storage

5.4.8 The policies focus on the re-use of existing infrastructure and the development of marine utility corridors, which would reduce the need for new infrastructure and thus prevent any further disruption of seascape and/or landscape character, where this may already be present. Objective CCS 5 explicitly recognises the need for an environmental assessment to allow early consideration of these issues in the deployment of CCS. Taken together with the general cross-cutting policies, we anticipate that adverse effects on seascape and/or landscape will be avoided.

Renewable Energy

5.4.9 Offshore renewable energy arrays have the potential for adverse effects on seascape/landscape, the significance of which will depend on the nature of the seascape/landscape in question and on the characteristics of the renewable energy devices being deployed. The policies and objectives for renewable energy recognise the need for development in this sector to be sustainable. For the purposes of this assessment, we have assumed that "sustainable" will therefore include management of unacceptable adverse effects on seascape/landscape. Taken together with the general cross-cutting policies, we therefore anticipate that it will be possible to avoid adverse effects on the most sensitive landscapes and seascapes ( e.g. National Scenic Areas, National Parks).

Recreation and Tourism

5.4.10 The policies and objectives for recreation and tourism recognise the need for development in this sector to be sustainable. We have assumed that "sustainable" will include management of such issues as increased recreational pressure, appropriate siting of tourism and recreational infrastructure, etc. In addition, Policy 1 identifies the need to protect the qualities important to recreational users, which include seascape and landscape. This, taken together with the cross-cutting policies, should offset the negative aspects of the growth aspirations expressed in the objectives, in particular, and result in the avoidance of adverse effects on seascape/landscape. This will be strengthened by the sustainable development approach recommended for regional marine planning in Policy 2.

Transport

5.4.11 Any development of port and harbour facilities (Objectives 2 and 3 and Transport 4) would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on seascape/landscape would be avoided. This will rely on seascape/landscape issues being integrated into project planning and design.

Telecommunications

5.4.12 As with carbon capture and storage, the policies focus on the development of marine utility corridors, which would reduce the need for new infrastructure and thus prevent any further disruption of seascape and/or landscape character, where this may already be present.

Defence

5.4.13 Defence is not known to affect landscape/seascape interests.

Aggregates

5.4.14 Aggregate extraction in the marine environment is not known to affect landscape/seascape interests.

5.5 Historic Environment

Will the draft Plan …

15

Improve understanding and knowledge about the marine historic environment?

16

Protect the site and setting of marine and coastal historic environment features?

5.5.1 There are existing pressures on the historic environment from many of the activities and uses of the marine environment. The effects of climate change may also exert indirect effects on the historic environment through, for example, increased erosion of coastal features. Pressures include: development that results in loss of and/or damage to historic environment features, including effects on their setting; coastal erosion, with consequent loss of archaeological interests; and potential effects on underwater archaeological features from development involving anchoring, e.g. offshore wind, wave and tidal arrays, aquaculture, and recreational boating. Data gaps, particularly in regard to underwater archaeological features, remain to be resolved.

5.5.2 The objectives and policies of the draft NMP recognise and address the potential for effects on the historic environment, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.5.3 Sea fisheries are known to affect historic environment interests, particularly scallop dredging. Policy 3 ensures protection of the seabed and this will therefore include heritage features.

Aquaculture

5.5.4 Objective 2 is focused on increases in sustainable production, which has the potential for adverse effects on the historic environment, particularly if production increases result in additional aquaculture facilities. We have assumed that the definition of "sustainable growth" includes consideration of historic environment issues, and therefore anticipate that adverse effects on the historic environment will be prevented through application of this overall policy framework.

5.5.5 The aquaculture policies recognise the pressures on the historic environment resulting from aquaculture:

  • Locational policies, when developed (we assume by regional marine plans), will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry.
  • Sustainable growth of the aquaculture industry is supported. As with sea fisheries, we have assumed that the term "sustainable" encompasses planning to avoid adverse effects on the historic environment.
  • The policies recognise that aquaculture must be located appropriately; for the purposes of this assessment, we have assumed that "appropriately" will include the historic environment.

Wild Salmon and Migratory Fish

5.5.6 Wild salmon and migratory fish activities are not known to affect historic environment interests.

Oil and Gas

5.5.7 Oil and gas installations may affect historic environment interests, depending on their location.

5.5.8 Should oil and gas installations be sited closer to shore or in the vicinity of sensitive cultural landscapes ( e.g. St Kilda), then the cross-cutting policies ( GEN13) would come into play to manage adverse effects.

Carbon Capture and Storage

5.5.9 The policies focus on the re-use of existing infrastructure and the development of marine utility corridors, which would reduce the need for new infrastructure and thus prevent any further disruption of the historic environment, where this may already be present. Objective CCS 5 explicitly recognises the need for an environmental assessment to allow early consideration of these issues in the deployment of CCS. Taken together with the general cross-cutting policies, we anticipate that adverse effects on the historic environment will be avoided.

Renewable Energy

5.5.10 Offshore renewable energy arrays have the potential for adverse effects on the historic environment ( e.g. anchoring effects on underwater archaeology; effects on setting of historic environment features such as A-listed lighthouses), the significance of which will depend on the characteristics of the renewable energy devices being deployed and the nature of the historic environment features that may be affected. The policies and objectives for renewable energy recognise the need for development in this sector to be sustainable. For the purposes of this assessment, we have assumed that "sustainable" will therefore include management of adverse effects on the historic environment. Taken together with the general cross-cutting policies, we therefore anticipate that adverse effects on the historic environment will be avoided.

Recreation and Tourism

5.5.11 The policies and objectives for recreation and tourism recognise the need for development in this sector to be sustainable. We have assumed that "sustainable" will include management of such issues as increased recreational pressure, appropriate siting of tourism and recreational infrastructure, etc. In addition, Policy 1 identifies the need to protect the qualities important to recreational users, which may include historic environment features. This, taken together with the cross-cutting policies, should offset any negative aspects of the growth aspirations expressed in the objectives, in particular, and result in the avoidance of adverse effects on the historic environment. This will be strengthened by the sustainable development approach recommended for regional marine planning in Policy 2.

Transport

5.5.12 Any development of port and harbour facilities (Objectives 2 and 3 and Transport 4) would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on the historic environment would be avoided. This will rely on historic environment issues being integrated into project planning and design.

Telecommunications

5.5.13 As with carbon capture and storage, the policies focus on the development of marine utility corridors, which would reduce the need for new infrastructure and thus prevent any further disruption of the historic environment, where this may already be present.

Defence

5.5.14 Defence is not known to affect historic environment interests.

Aggregates

5.5.15 Aggregate extraction in the marine environment may affect historic environment interests, depending on its location. Extraction would be progressed in light of the general cross-cutting policies, and we therefore anticipate that adverse effects of such development on the historic environment would be avoided.

5.6 Climatic Factors

Will the draft Plan …

13

Reduce greenhouse gas emissions from vessels and other marine activities?

14

Contribute to adaptation to climate change?

5.6.1 There are existing pressures on the coastal and marine water environment from climate change through, e.g. increases in sea temperature etc.

5.6.2 The objectives and policies of the draft NMP recognise and address the need to integrate climate change issues into the sustainable development and use of the marine environment, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.6.3 The key issue for the fisheries sector, in regard to climatic factors, is the emission of greenhouse gases ( GHG) as a result of fuel consumption. The sector is already aware of the need to reduce both fuel consumption and GHG emissions.

5.6.4 The objectives and policies together are working towards sustainable fishing practices and management, to ensure the sustainability of fish stocks ( e.g. Policy 1). Other measures are also being utilised, e.g. cod recovery plans. Sustainable fish stocks in Scottish waters may reduce steaming distances to fishing grounds, which would reduce GHG emissions. However, this may be offset by increased sea temperatures and the potential for traditional catch species to move further north, thereby increasing steaming distances and fuel consumption.

5.6.5 The draft NMP requires consideration of sea fisheries when considering other marine development, and the issues of displacement and fuel use are explicitly recognised in Policy 4. This should assist in managing additional pressures for increased fuel consumption and GHG emissions.

5.6.6 Fisheries Objective 9 explicitly recognises the need to support international and national environmental priorities, which includes GHG emissions.

Aquaculture

5.6.7 Objective 2 is focused on increases in sustainable production, which has the potential for increases in GHG emissions if additional support vessel movements are involved and/or if facilities are located further offshore. The significance of this is currently unclear; however, the aquaculture policies recognise the pressures on climatic factors resulting from aquaculture:

  • Locational policies, when developed (we assume by regional marine plans), will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry.
  • Sustainable growth of the aquaculture industry is supported. As with sea fisheries, we have assumed that the term "sustainable" encompasses consideration of increased fuel use, etc.
  • The policies recognise that aquaculture must be located appropriately; for the purposes of this assessment, we have assumed that "appropriately" will include consideration of distance from shore.
  • Policy 12 requires that aquaculture equipment be fit for purpose for the site conditions, subject to future climate change.
  • In addition, GEN19 requires that developers and users of the marine environment should seek to minimise emissions of greenhouse gases and should have regard to possible future climate conditions.

Wild Salmon and Migratory Fish

5.6.8 The wild salmon and migratory fish sector is not known to affect GHG emissions (any emissions resulting from travel by recreational fishers are captured under "tourism and recreation").

5.6.9 Climate change may exert pressures on wild salmon and migratory fish while they are in the marine component of their life cycles, and may thus contribute to the existing trend in population decline of Atlantic salmon by affecting survival at sea, for example. The policies for this sector are intended to manage additional pressures on wild salmon and migratory fish from other sectors and, in addition, the draft NMP seeks to integrate climatic factor consideration into sustainable development and use, including marine planning and decision-making that affects the marine environment.

Oil and Gas

5.6.10 The policies and objectives support the continuing exploitation of oil and gas, but recognise that this must be at "minimum environmental cost". We therefore do not anticipate a change in GHG emissions from that which already occurs ( i.e. no change from the baseline).

Carbon Capture and Storage

5.6.11 This sector focuses on carbon capture and storage, and we do not anticipate any additional GHG emissions in consequence. For the purposes of this assessment, we have assumed that infrastructure re-use will take the need for adaptation measures into consideration.

5.6.12 However, Objective CCS 5 explicitly recognises the need for an environmental assessment to allow early consideration of environmental issues in the deployment of CCS. Should this assessment identify climatic factors as a significant issue, this matter will be revisited.

Renewable Energy

5.6.13 The policies and objectives for renewable energy recognise the need for development in this sector to be sustainable. This sector will require vessel movements to the array sites, during both construction and operational stages, which has the potential for increases in GHG emissions. The significance of this is unclear.

Recreation and Tourism

5.6.14 The policies and objectives for recreation and tourism recognise the need for development in this sector to be sustainable. We have assumed that "sustainable" will include management of such issues as transport; however, this is unlikely to reduce GHG emissions from visitors travelling by private car. Policy GEN18 may assist in integrating such issues into marine planning and decision-making affecting the marine environment.

5.6.15 Policy 4 seeks to prevent damage from recreation and tourism to those environmental features which are either already vulnerable to climate change ( e.g. maerl) or those which assist in mitigating climate change ( e.g. salt marsh, kelp beds).

Transport

5.6.16 GHG emissions from shipping have been identified as a pressure. Work is already underway to reduce GHG emissions, e.g. through increasing engine efficiency, improved vessel design, amendments to existing management practices, etc.

5.6.17 Objective 6 recognises the need to reduce GHG emissions from vessels in port through increasing the availability of shore-based electricity and supporting efficiencies in fleet management and technology advances. Policy 5 requires port and harbour operators to consider, and where appropriate implement, measures to ensure that their facilities remain resilient to climate change. Where proposals for marine development may displace vessels from their existing routes, resulting in longer journeys and increased GHG emissions, Policy 6 requires that this be taken into consideration as part of decision-making. Taken together, these policies and objectives (along with GEN18) will ensure that the climate change implications of and for marine transport will be considered in planning and decision-making.

Telecommunications

5.6.18 The policies and objectives, taken together, should work to avoid adverse effects on GHG emissions, for example, by preventing unnecessary additional cable laying.

Defence

5.6.19 The objectives and policies do not incur change from existing defence activities and uses of the marine environment, and therefore will not affect GHG emissions or adaptation measures.

Aggregates

5.6.20 Aggregate extraction activities (other than emissions from vessels) are not considered to have significant effects on climatic factors.

5.7 Marine Sediments

Will the draft Plan …

20

Avoid exacerbating coastal erosion?

21

Maintain the integrity of coastal processes?

22

Maintain and protect the character and integrity of the seabed?

5.7.1 There are existing pressures on coastal processes and marine sediment transport from some activities and uses of the coastal and marine environments. The effects of climate change may also exert indirect effects through, for example, increased erosion of coastal features.

5.7.2 The objectives and policies of the draft NMP recognise and address the potential for effects on marine sediments and coastal processes, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.7.3 Policies to improve seabed protection and/or to restore ecosystems have positive implications for marine sediments, in terms of maintaining the character and integrity of the seabed. In addition, Fisheries Objective 9 explicitly recognises the need to support international and national environmental priorities, which includes seabed integrity.

Aquaculture

5.7.4 As with biodiversity, significant growth in aquaculture has the potential to have negative effects on coastal and marine sediments, e.g. through anchoring. In addition, work to identify areas which are potentially suitable for new fish farm development and sensitive areas which are unlikely to be appropriate for such development is likely to assist in avoiding sensitive habitats and species which are a key feature of the seabed. Policies GEN11 and 12 should assist in balancing significant adverse effects, ensuring that these issues are taken into account in regional marine planning and project decision-making.

Wild Salmon and Migratory Fish

5.7.5 The policies and objectives for this sector are unlikely to have an effect on marine sediments.

Oil and Gas

5.7.6 The policies and objectives support the continuing exploitation of oil and gas, but recognise that this must be at "minimum environmental cost". We therefore expect that this will include avoiding adverse effects on marine sediments. The maximisation of recovery, for example, has potential for adverse effect on marine sediments, so this and the cross-cutting policies in Chapter 4 should act to avoid and/or reduce negative effects, e.g. policies GEN11, GEN12, and GEN18. Marine sediments will also be a consideration when deciding to remove or retain decommissioned assets, as it is uncertain as to how much oil and gas infrastructure changes marine sediment patterns of movement and therefore what the effects would be.

Carbon Capture and Storage

5.7.7 The reuse of existing infrastructure and the employment of utility corridors will be positive for marine sediments, as this will reduce the amount of sea bed under development. It is uncertain as to how much oil and gas infrastructure changes marine sediment patterns of movement.

Renewable Energy

5.7.8 The effects of renewable energy policies on marine sediments are mixed. On the one hand, policy to support renewable energy development in Scotland's seas has the potential for negative effects as it supports new development in the marine environment which could affect the character and integrity of the seabed. However, the cross-cutting policies in Chapter 4 will apply to the Sectoral Marine Plan process, and the SEA of these sectoral plans will identify any adverse effects and measures for their mitigation.

Recreation and Tourism

5.7.9 Policies to support the growth of tourism have the potential for negative effects, but these will be mitigated by planning and consenting decision-makers using the cross-cutting policies in Chapter 4. It is therefore expected that the overall environmental effects of these policies will be neutral.

Transport

5.7.10 Increased port activity, including recreation/tourism, may have negative effects on marine sediments if growth results in a need for new capital dredging. The policies in Chapter 4 will work to mitigate adverse effects, e.g. GEN11, GEN12 and GEN18.

Telecommunications

5.7.11 The telecommunications policies have positive implications for marine sediments, as they mainly seek to reduce disturbance to the seabed by focusing activity in fewer locations. When it comes to landfall, there may be coastal process and/or erosion issues, but use of the Chapter 4 policies (invoked by Policy 4, for example) should assist in preventing coastal erosion and/or its exacerbation.

Defence

5.7.12 No effects from defence policies are anticipated on marine sediments.

Aggregates

5.7.13 Aggregates policy specifically encompasses consideration of environmental issues and therefore is positive in its protection of marine sediments, particularly as it specifies: "including that sediment removal will not significantly adversely interfere with coastal processes and thus alter local rates of coastal erosion which could exacerbate the predicted effects of a changing climate".

5.8 Socio-Economic Factors

Will the draft Plan …

1

Support the development of a sustainable marine economy?

2

Contribute to the growth of any marine industry without detriment to another?

3

Safeguard and/or create jobs that support new or existing communities?

4

Remove or avoid barriers to new marine enterprise opportunities? [90]

5

Maintain or improve the accessibility and connectivity of remote island and coastal communities?

6

Promote access to the coastal and marine resource for tourism and recreation?

7

Contribute to the resilience and cohesion of coastal and island communities?

5.8.1 There are existing pressures on the socio-economic component of the coastal and marine water environment. These include: employment, particularly in remote coastal and island communities; potential for conflict both within and between different marine sectors; competition for space; barriers to new marine enterprise opportunities; and connectivity, particularly of remote coastal and island communities.

5.8.2 The objectives and policies of the draft NMP recognise and address the need to integrate socio-economic issues into sustainable development and use of the marine environment, while recognising that the NMP will work in conjunction with the overall legislative and policy framework for the marine environment outlined in Section 2.

Sea fisheries

5.8.3 The key issue for the fisheries sector is the sustainability of the fishing industry in the long-term.

5.8.4 The objectives and policies together are working towards sustainable fishing practices and management, to ensure the sustainability of fish stocks ( e.g. Policy 1). The potential for conflict between fisheries and other marine sectors is recognised, particularly in terms of competition for space, and the policies require that fisheries interests are taken into account in planning and decision-making, including engagement with fishers at the local level. This is likely to involve trade-offs between the sectors, which will be negative for some and positive for others. The key here is that these trade-offs would result from considered discussion and review, rather than through imposition.

5.8.5 Long-term sustainability of the sea fisheries industry is considered likely to maintain levels of employment and thus contribute to community cohesion and resilience.

Aquaculture

5.8.6 The objectives and policies, taken together, support the sustainable development of aquaculture, including increases in production and diversification of the industry. Locational policies, when developed, will be informed by Marine Scotland's spatial planning guidance which will be progressed on the basis of a sustainable aquaculture industry. The requirement for regional marine plans and terrestrial land use plans to identify potentially suitable areas for aquaculture should assist in reducing conflict between the sectors and/or managing uncertainty in the aquaculture and other marine sectors. Again, as with sea fisheries, there are likely to be trade-offs between the sectors, with both positive and negative implications.

5.8.7 As with sea fisheries, long-term sustainability of the aquaculture industry is considered likely to maintain levels of employment and thus contribute to community cohesion and resilience.

Wild Salmon and Migratory Fish

5.8.8 As with aquaculture, the objectives and policies, taken together, support the sustainable development of the wild salmon and migratory fish sector. In particular, there is a requirement for other sectors to recognise their potential adverse effects on wild salmon and other migratory species. This may result in mitigation and monitoring requirements, which may have negative implications for other sectors but is considered to be positive for the wild salmon and migratory fish sector.

5.8.9 As with other sectors, long-term sustainability of the aquaculture industry is considered likely to maintain levels of employment and thus contribute to community cohesion and resilience.

Oil and Gas

5.8.10 The policies and objectives support the continuing exploitation of oil and gas, recognising the challenges that the future may bring, e.g. decommissioning, development in more testing environments. Taken together, these policies and objectives will be positive in terms of supporting employment in this sector, with consequent benefits for community cohesion and resilience.

Carbon Capture and Storage

5.8.11 The objectives and policies focus on encouraging the development of this sector in a sustainable manner, and have positive implications for employment and community resilience, particularly in terms of skills transfer from the oil and gas sector. There is unlikely to be significant conflict with other sectors, e.g. in terms of competition for space, given the emphasis on re-use of existing infrastructure.

Renewable Energy

5.8.12 The policies and objectives for renewable energy encourage sustainable development of this sector. The policy link to the sectoral plans for offshore wind, wave and tidal energy will help to reduce uncertainty and thereby manage potential conflicts between sectors, e.g. in terms of competition for space, as will the requirement of Policy 9 to engage with existing users of the area.

5.8.13 There are positive implications for employment, which is likely to contribute to community resilience and cohesion. Policies GEN4 and GEN9 encourage engagement with local communities in the planning and development process.

Recreation and Tourism

5.8.14 The policies and objectives for coastal and marine recreation and tourism recognise the need for development of this sector to be sustainable. They also recognise the potential for conflict between this sector and other sectors, e.g. in terms of competition for space, effects on environmental quality etc. Accordingly, mechanisms for inclusion of coastal and marine recreation and tourism interests in planning and decision-making are included in the policies, in particular.

5.8.15 Sustainable development of this sector should contribute to employment in coastal and island communities. There may be negative implications for other sectors. Overall, assuming that trade-offs can be appropriately managed, there are positive implications for employment in coastal and islands communities, and therefore for community resilience and cohesion.

Transport

5.8.16 The objectives and policies provide protection to shipping ( e.g. navigational safety, protection of shipping routes) and to ports and harbours ( e.g. protection of access). They also provide mechanisms for ensuring that ports and harbours take note of the interests of other sectors, and vice versa.

5.8.17 Taken together, the objectives and policies support the sustainable development of both marine shipping and the port and harbour sectors. There may be trade-offs for other sectors, in terms of competition for space.

5.8.18 Air quality issues associated with such development will be taken into consideration in planning and decision-making (Objective 6), and this should avoid adverse effects on adjacent residential populations in the future.

Telecommunications

5.8.19 The policies and objectives, taken together, should work to support this sector and reduce conflict between this and other sectors.

Defence

5.8.20 The objectives and policies do not incur change from existing defence activities and uses of the marine environment, and therefore will not change socio-economic factors.

Aggregates

5.8.21 The policies and objectives work to protect this resource so that it is available for future need. This may involve trade-offs for other sectors, in terms of competition for space.

5.9 Assessment of alternatives

5.9.1 As noted in paragraph 2.2.14, three tiers of alternatives to the draft NMP were identified as the planning process progressed:

  • Do nothing
  • Use of alternative approaches:
    • A high level strategic plan
    • A high level spatial plan
  • Use of alternative priorities
    • An economically-focused plan
    • An environmentally-focused plan

5.9.2 These alternatives have been assessed against the SA objectives and the detailed results are set out in Appendix 4. In summary, the assessment shows that:

  • Do nothing: Under the "do nothing" approach, environmental, economic and social policies and initiatives would not benefit from the integration and coordination that the NMP would provide, and this would result in a lack of direct benefits for the economy, communities, population and human health. The same would apply to environment, as without the NMP there would be a lesser degree of integration between environmental and economic considerations, and planners and decision-makers would need to rely on the comprehensive range of existing environmental protection legislation and policy in isolation [91] .
  • High-level strategic plan: This option supports development of individual marine economic sectors, within environmental and social constraints. It provides some guidance on factors to consider in identifying preferred locations for different types of development (with a focus on marine renewables) but in the main sets out policy considerations (environmental, social and economic) which need to be recognised by regional marine plans and project decision-makers. This option is largely positive across the three topics of environment, economy, communities, population and human health through the emphasis on economic development of the individual marine sectors and the inclusion of the mitigating policies [92] .
  • High-level spatial plan: This option provides a clear indication of the locations where certain marine economic activities can take place, including where different activities are compatible within the same locations. Key aspects of this approach include:
    • Availability and gathering of sufficient information to ensure sound decision making within the plan preparation process.
    • Weighting of environmental and economic considerations against each other to identify the best use of different areas.
    • Identifying the carrying capacity of different marine environments.
    • Understanding of market influences on different marine industries.

The preferred option has not taken a spatial approach, but has set out the broad policy direction. The spatial approach does not bring particular benefits across the appraisal topic areas, and would require a high degree of information gathering and analysis (which is a key purpose and benefit of regional marine planning). It was also considered that a spatially directive national plan could conflict with the regional marine planning process. As a result, there would be negative implications for communities, as there would be reduced opportunities for local planning/ decision making. Nevertheless, the plan is informed by nationally significant spatial outputs from other planning processes ( e.g. Marine Protected Areas, draft plan options for offshore renewable energy)

  • Alternative priorities - economically focused plan: This option explores the possible measures which would achieve greatest economic benefit. Although this option has a strong economic focus, it is not strongly positive in relation to the economic objectives which seek to reflect sustainability, balancing different marine economic interests, job creation and avoiding barriers. This option does not place sufficient emphasis on protecting the environmental quality and ecosystem services which are critical in supporting a large proportion of marine economic activities. It also does not reflect the complex interactions between different marine economic activities or recognise how one area of activity can adversely affect another.
  • Alternative priorities - environmentally focused plan: This option prioritises protection of all aspects of the environment including habitats and species, water, air, cultural heritage and landscape/seascape. It is therefore strongly positive in relation to environmental objectives, but only partly positive in relation to the economic objectives as there are some tensions between the benefits for marine economic industries which rely on good environmental quality and those which do not. The impacts on communities, population and human health are partially linked to the environmental objectives, where positive effects for environmentally dependent marine industries support communities reliant on these.

5.10 Cumulative Effects

5.10.1 The Environmental Assessment (Scotland) Act 2005 requires that the cumulative environmental effects of the National Marine Plan are identified and evaluated.

5.10.2 Figures 2 and 3 set out the policy context within which the National Marine Plan ( NMP) is being progressed, including the Marine Policy Statement and Scottish Planning Policy ( SPP):

  • The Marine Policy Statement sets out UK-level marine policy, and the policy framework in the NMP delivers these policies within the Scottish context.
  • The NMP and the SPP, taken together, provide the overarching marine and terrestrial planning policy framework. This includes policy relating to activities where the two planning systems overlap, for example those which occur on and around the coast or in coastal waters, such as aquaculture.

5.10.3 Figures 2 and 3 also identify the plans and programmes for which the NMP acts as the overarching policy framework, including the sectoral marine plans for renewable energy and the Regional Marine Plans. The spatial elements of the marine and terrestrial planning systems will be provided by the spatial strategies set out in the sectoral and Regional Marine Plans and the National Planning Framework, alongside strategic and local development plans. These spatial strategies will be prepared in accord with the policy framework set out in the NMP and the SPP.

5.10.4 Given that the focus of the NMP is on policy, rather than proposals, this part of the assessment has focused on the cumulative effects of the NMP and the SPP. The cumulative effects of the spatial strategies will be assessed during the preparation of the relevant plans.

Scottish Planning Policy ( SPP)

5.10.5 The purpose of the SPP is to set out Scottish Ministers' policy for planning, and to influence development plans and development management. The Scottish Government is in the process of revising the SPP, and a draft revised SPP was published for consultation in April 2013.

5.10.6 The current policy review considers the policy as a whole and aims to ensure that planning contributes as fully as possible to sustainable economic growth, and to Scotland's transition to a low carbon economy. Bringing together and updating the existing SPP, the draft SPP includes a number of proposed policies:

  • Cross cutting/ overarching policies focusing on sustainable economic growth, sustainable development, engagement, climate change, place making and spatial strategies.
  • Policies relating to buildings: delivery of new homes, supporting business and employment, and valuing the historic environment.
  • Policies for the environment: valuing the natural environment, enhancing green infrastructure, sustainable resource extraction, and aquaculture.
  • Policies on movement: making best use of existing infrastructure and reducing the need to travel whilst supporting sustainable transport options.
  • Policies supporting development of utilities: delivering heat and electricity, digital communication, flood management and waste.

5.10.7 The draft SPP has been subject to strategic environmental assessment ( SEA), alongside the Main Issues Report for the National Planning Framework 3, and the results are set out in the Environmental Report. [93] These show that the draft SPP will have largely positive or neutral environmental effects. Although some types of development have the potential for adverse environmental effects, the draft policies address these by promoting a sustainable approach to planning and decision-making.

Cumulative Effects Assessment

5.10.8 The NMP and the SPP will work together to set out a framework of social, economic and environmental policies which identify the issues to be taken into account when developing spatial plans and which are to be applied in making decisions about projects and/or activities in the marine and terrestrial environments. These cross-cutting policies also apply to the sectoral and subject-specific policies in the two plans. A review of the draft NMP and draft SPP against the SA objectives demonstrates how the two policy frameworks will work together (Table 5).

5.10.9 Thus, for example, both the NMP and the SPP emphasise the importance of sustainable economic growth and sustainable development. Alone, policies encouraging economic growth have the potential to result in adverse social, community and environmental effects. However, these economic policies are balanced by the requirement for economic growth and development to be sustainable, and this is further elaborated by policies which protect social, community and environmental interests.

5.10.10 The cumulative effect of this overarching policy framework is that economic growth is supported, focusing on the right type of development in the right place. The cross-cutting and sector-specific policies of the two policy frameworks will work to avoid and, where appropriate, reduce the potential adverse effects of development on coastal and marine communities (including social effects) and on the coastal and marine environment.

5.10.11 In conclusion, the cumulative effects of the policy frameworks in the draft NMP and SPP are considered to be largely positive or neutral.


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