NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.


Proposed key objective of NPF4: To support the sustainable growth of the finfish and shellfish sectors to ensure that the aquaculture industry is diverse, competitive and economically viable and that new development is guided to coastal locations that best suit industry needs with due regard to the marine environment.

An alternative wording of the key objective was proposed in order to both take account of other planning considerations and ensure support for small scale start-up businesses. It was suggested the objective should read:

'To support the sustainable growth of the finfish and shellfish sectors to ensure that the aquaculture industry is diverse and competitive. New development is guided to appropriate locations with due regard to the marine environment, carrying capacity and novel technologies, such as closed-containment and non-chemical sea lice treatments for finfish aquaculture.'

The need for NPF4 to ensure alignment of terrestrial planning processes with the National Marine Plan and subsequent regional marine plans was also highlighted. Specifically, it was argued NPF4 should reference:

  • The need for aquaculture to take full and considered account of Scotland's network of marine protected areas including national nature conservation marine protected areas.
  • The suite of proposed marine Special Protection Areas and marine Special Areas of Conservation.

Sustainable development of the aquaculture sector was suggested to require implementation of higher standards of environmental regulation to safeguard marine protected species and habitats, including priority marine features.

It was suggested that there is currently a lack of explicit guidance on aquaculture despite the size of the salmon farming industry and the controversial nature of some developments. Lack of guidance was argued to create uncertainty for both policy makers and developers. Specific suggestions included:

  • Clarification of responsibility for each aspect of the aquaculture assessment process. A need for clarity on where different agencies' responsibilities lie in relation to sea lice, fish health, disease management areas and interactions with wild fish populations was highlighted.
  • Clear guidance on issues associated with a move of fish farm sites out of enclosed lochs into open coastal waters.
  • Updating Circular 1/2015 to reflect changes in marine and coastal development and planning, potential changes in foreshore and seabed ownership and control and to better acknowledge the advent of marine planning.

The work of the Regulators Technical Working Group to look at providing better spatial planning advice was supported.

Creation of a National Aquaculture Technology and Innovation Hub was proposed as a National Development. It would create the UK's leading innovation community for sustainable aquatic food production and lead development of new technologies and systems required to support growth in the production of aquatic food for human consumption, while reducing the impact on natural resources.

Finfish aquaculture

It was argued that current policy that presumes 'against further marine finfish farm developments on the north and east coasts to safeguard migratory fish species' implicitly accepts that further finfish farm development is not compatible with safeguarding migratory fish. However, conservation of these species on the west coast and islands is not addressed and it was proposed that future policy must be science-led to identify areas of opportunity and constraint around the entirety of Scotland's coastline.

An enquiry into the effects of commercial fish-farming and designated places for aquaculture was also suggested.

It was argued that NPF4 should make direct reference to working with SEPA via the guidance of the Finfish Aquaculture Sector Plan and to the revised regulatory framework for this sector. It should also reference the outputs of the Rural Economy and Connectivity Committee 9th Report on Salmon Farming in Scotland, which informed the plan and regulatory framework.



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