Offshore Marine Protected Areas - fisheries management measures: SG response

3. Consultation Documents Reviewed

A number of documents were provided for comment and feedback. These were:

Sustainability Appraisal (SA)

Socio-Economic Impact Assessment (SEIA)

Strategic Environmental Assessment (SEA)

Business and Regulatory Impact Assessment (BRIA)

Island Communities Impact Assessment (ICIA)

Fisheries Assessment (per site)

3.1 Sustainability Appraisal (SA)

The Sustainability Appraisal (SA) is an assessment of environmental, social, and economic effects. Drafted by marine consultants ABPmer on behalf of the Scottish Government, the SA provides a high-level overview of the cumulative impacts of the proposed fisheries management measures. It is comprised of the high-level findings of the Strategic Environmental Assessment Report (SEA) and the Socio-Economic Impact Assessment (SEIA).

A number of respondents criticised the SA for its perceived imbalance, focusing on costs to fisheries while underrepresenting the long-term benefits of ecosystem recovery. Officials acknowledge there is a lack of robust quantitative evidence available to fully capture these long-term benefits, and as a result, have had to rely more heavily on qualitative data to inform the appraisal.

Further discussion on the SEA and SEIA, which informed this document, is provided in sections 3.2 and 3.3.

3.2 Socio-Economic Impact Assessment (SEIA)

The Scottish Government acknowledges the wide range of views shared in response to the Socio-Economic Impact Assessment (SEIA), and we are grateful to all who contributed detailed feedback. We recognise the concerns raised by industry and others regarding how the SEIA presents and analyses potential socio-economic effects. We note that some respondents felt the assessment over-relied on fleet-wide turnover figures and therefore may not have fully reflected the disproportionate impacts on specific sectors and geographic areas, including remote coastal communities.

SG Response

In response to concerns relating to the scale of the assessment, we would like to clarify that while headline figures are presented at a national level for context, the assessment also includes more granular analysis. This covers regional and sectoral impacts, including home and landing ports, gear types and fleet segment impacts from measures at individual sites and also as a result of the full suite of measures. However, due to the large volume and technical nature of the report, we understand that some of this detail may not have been easily accessible. We will consider how to present future assessments in a more user-friendly format to ensure key findings are more readily understood. A number of these impacts are presented in a supporting document to the SEIA which is available online here: (Appendix C Site Assessment Table).

With regard to long-term benefits, we acknowledge that these are more challenging to quantify but are nonetheless an important consideration. Healthy ecosystems provide services such as improved fish stock resilience, carbon storage, and climate regulation. These benefits are expected to grow over time and deliver broad societal value. We will continue to explore how such long-term effects can be better reflected in future assessments.

3.3 Strategic Environmental Assessment (SEA)

We welcome the feedback provided on the Strategic Environmental Assessment (SEA) and appreciate the range of perspectives shared. The SEA is an important tool to help understand and assess the potential environmental impacts. The SEA focuses solely on environmental effects only, and did not assess the socio-economic impacts, which were covered separately in the SEIA.

We note some respondents expressed concern that the SEA did not fully reflect the risks of Option 2 (full site restrictions), particularly due to displacement effects for fishing activity. Others felt that the SEA did not adequately capture the environmental benefits arising from spill-over effects or long-term improvements to marine biodiversity.

SG Response

Where there were high levels of scientific uncertainty, particularly around these broader effects, a more qualitative assessment was undertaken. Ongoing monitoring can assist to reduce scientific uncertainty. It is noted that the management measures and other factors may result in changes to fishing activity in the future and this will be monitored and considered on an ongoing basis. While the impacts from non-UK vessels, and potential effects on offshore ecosystems are more difficult to quantify at this time, these issues have been noted and will continue to inform our broader marine planning work.

Conversely, some respondents highlighted that the SEA could have better captured the positive environmental outcomes of full-site protection under Option 2, including enhanced spillover effects and potential contributions to achieving Good Environmental Status. These benefits were considered in the SEA, though we acknowledge that more detailed modelling of such long-term effects may be appropriate as better data becomes available.

Overall, we note that a number of respondents found the SEA to be a useful and well-structured assessment that adds value to the evidence base. The SEA has provided a baseline against which future changes can be measured, and we will consider how to improve accessibility and transparency in future assessment reporting. We will continue to work with stakeholders to ensure that environmental, conservation and other outcomes are robustly monitored, understood, and acted upon through an adaptive management approach.

3.4 Business and Regulatory Impact Assessment (BRIA)

The purpose of the BRIA is to provide an initial understanding of the likely costs, benefits and wider implications of the proposed fisheries management measures for businesses and stakeholders. The assessment was informed by the analysis undertaken as part of the SEIA.

SG Response

We note the views shared by a number of respondents regarding the perceived difference in engagement between the development of zonal measures (Option 1) and full-site measures (Option 2). The zonal approach was indeed shaped over many years of engagement with fisheries and environmental stakeholders, including through workshops, bilateral meetings, and collaboration with Advisory Councils. While the full-site approach (Option 2) was introduced as required, later in the process, due to the need to assess a reasonable alternative. Further detail on this is provided in 5.5.

We acknowledge that concerns were raised regarding the potential for displacement of fishing activity under Option 2, and its disproportionate impacts on certain sectors, particularly the mobile demersal fleet. These issues were also considered in the Strategic Environmental Assessment and the Socio-Economic Impact Assessment. However, as noted in these assessments, there is significant uncertainty around the scale, location, and effects of displacement. To ensure these potential impacts were still considered, a qualitative assessment was undertaken.

As part of the wider package of assessments, the costs and benefits of the various options are assessed through different lenses, economic, environmental, and regulatory, but we agree that it is important for the combined outputs to present a clear and holistic picture. We will consider these comments carefully in future management work.

3.5 Island Communities Impact Assessment (ICIA)

An Island Communities Impact Assessment (ICIA) was carried out as an integral part of the wider impact assessment process. The ICIA plays a crucial role in ensuring that the specific needs and unique circumstances of island communities are meaningfully considered in the development of new policies.

Some respondents argued that a single, national-level assessment failed to capture the distinct impacts on individual islands. This was particularly emphasised in responses from Shetland, where the cultural, historical, and economic importance of the fishing industry were seen as overlooked.

Others noted that the ICIA focused too heavily on potential risks without adequately considering the potential long-term benefits of sustainable fisheries for island communities, or the environmental and social costs of inaction. A few respondents, while supportive of the environmental aims of the proposals, emphasised the need for financial support to help communities transition toward more sustainable practices.

SG Response

As part of the ICIA process, a formal screening assessment was carried out. This concluded that there were no differential impacts on island communities compared to those on the mainland. However, in recognition of the importance of understanding regional variation, further analysis was carried out through the Socio-Economic Impact Assessment (SEIA) to explore potential localised effects in more detail.

Within the SEIA, both regional and relative effects were explored, using home port and landing port data to identify where island and remote rural communities may be more significantly affected due to their geographic isolation and strong dependence on fishing-related activity. This included consideration of potential changes in fish landings, local processing activity (where applicable), and the implications for individuals and businesses reliant on those activities.

The ICIA and SEIA both examined both the potential impacts and opportunities for island communities, with a particular focus on identifying any disproportionate effects compared to mainland areas. While the ICIA primarily considered potential risks, we recognise the importance of more fully capturing the long-term environmental and social benefits of the proposed measures, including healthier fish stocks, more resilient ecosystems, and enhanced support for sustainable island livelihoods.

We also acknowledge calls for targeted support to accompany these measures. While not part of the ICIA itself, the Scottish Government remains committed to ongoing engagement with island communities and stakeholders as measures are implemented.

3.6 Fisheries Assessment (per site)

We note the feedback on the Draft Fisheries Assessments and are pleased that many respondents recognised the value of site-specific analysis, the clarity of methodology, and the careful consideration given to fishing gear types and their associated impacts. Some respondents felt that the assessments lacked sufficient consideration of the broader impacts of vessel displacement and the financial contributions required.

SG Response

We acknowledge the concerns raised regarding vessel displacement impacts, data timelines, and the broader context of spatial pressures from other marine sectors. These factors are inherently complex and often subject to high uncertainty. Where quantitative data was limited or not available, a more qualitative approach was taken to ensure these nuances were still reflected.

Wider considerations such as displacement effects and socio-economic impacts are not assessed within these assessments, which focus solely at the direct impacts of fishing activity on the designated features in the site. These wider impacts are instead captured in the Socio-economic Impact Assessment.

All comments received have been considered in finalising the assessments. These have been published alongside this document and are available online.