Publication - Consultation analysis

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report

Published: 2 May 2014
Part of:
Marine and fisheries

Planning Scotland’s Seas: Scotland’s National Marine Plan was published for consultation in July 2013. Independent analysis of all written responses to the consultation has been undertaken and is presented in this report.

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report


Chapter summary

  • Most comments in relation to this chapter came in the form of requests for additional information such as more guidance on reserved matters or how Regional Marine Partnerships should interact with this sector.

16.1 The Draft NMP explained that Scotland's seas and coasts are important for military training exercises, test and evaluation facilities and are critical for operational reasons. The Royal Navy Army and the Royal Air Force need to be able to deploy and develop a flexible and broad range of capabilities, have exclusive use of certain areas at particular times of the year, be able to use exemptions in planning law for the purposes of national security and retain the statutory right to close areas in internal waters and create by-laws for complete closures and exclusions.

16.2 However, the activities undertaken by the Ministry of Defence ( MOD) and their presence in Scottish waters means it interacts with a range of other marine users including the fishing industry, shipping and recreational boating activity. Furthermore, while the MOD is committed to the protection of the natural and historic environment, some defence related activities including noise, pollution or the introduction of non-native species, may pose risks to the marine environment.

16.3 The Draft NMP introduced three marine planning policies which allow the MOD to maintain operational effectiveness in Scottish waters used by the armed services by managing activity and development, to establish bye-laws for exclusions and closures of sea areas, and to establish a code of conduct of managing fishing and military activities. The Draft NMP also noted that while climate change is likely to affect MOD-owned facilities and assets and its operations in Scottish waters, appropriate adaptation measures will be brought forward to address these challenges.

Comments on Defence, Chapter 15

16.4 The consultation posed two questions in relation to defence.

Question 33: Do you have any comments on Defence, Chapter 15?

Question 34: Are there alternative planning policies that you think should be included in this chapter?

16.5 Twenty-four respondents provided commentary and the profile of these is shown in table 16.1. The table shows the greatest number of comments came from respondents in the energy and Local Authority sectors.

Table 16.1 Question 33: Do you have any comments on Defence?

Respondent group
Individuals (16) 1
Academic / scientific (7) 3
Aquaculture (5) -
Energy (12) 5
Environment / conservation (9) 2
Fisheries (13) 1
Historic / Heritage (5) 2
Industry / transport (9) -
Local Authority (15) 5
Local coastal partnership (7) 1
Local group (5) -
Other public sector (10) 4
Recreation / Tourism (7) -
Other (4) -
Total (124) 24

16.6 Two respondents in the historic/ heritage sector noted their support for the MOD's commitment to the protection of the natural and historic environment.

16.7 Many of the other comments made were in relation to specific sections in this chapter, and mostly made by only one respondent; often asking for more detailed information on a specific subject. The bullet points below outline the information requested. The commentary in parenthesis denotes the chapter section where respondents would like to see this information provided.

  • Reference to aquaculture development (interactions with other users);
  • More definition and guidance in relation to oil and gas, CCS and marine renewables (interactions with other users);
  • Greater emphasis on the impact of anthropogenic noise on marine mammals and support effective management of this (living within environmental limits);
  • Explanation that the MOD has developed an electronic charting system that is used to minimise the environmental impact of all MOD activities in relation to environmental legislation (living within environmental limits);
  • Reference to the MOD having responsibility to minimise greenhouse gas emissions (living within environmental limits);
  • More reference to the codes of conduct applied by the MOD to manage potential environmental impacts (codes of conduct);
  • Reference that the MOD is subject to duties such as the Habitat regulations (codes of conduct);
  • Clarification regarding permanent infrastructure compatibility;
  • More information on the potentially wide ranging and challenging issues of climate change and reference to the findings of the research conducted by the Hadley Centre;
  • More guidance on reserved matters;
  • Greater consideration of the impacts of sub-surface munitions testing on CCS facilities;
  • Greater recognition of appropriate mitigation approaches such as navigation marking and / or greater use of design considerations;
  • Guidance on how Regional Marine Plans should interact with this sector;
  • Greater reference to the cumulative use of the marine environment for military exercises.

16.8 Two respondents asked specific questions:

  • Whether water discharge into harbours by military vessels is allowed, coupled with concerns over policy implementation in relation to invasive species;
  • Why there was no recommendation for military vessels to use electricity supplies when in port.

16.9 Finally, two respondents within the environment / conservation sector asked for the MOD to conduct a full Strategic Environmental Assessment of its marine exercise activities and more information on the environmental responsibilities of the MOD. A respondent in the academic / scientific sector noted the importance of the MOD adhering to extant codes of conduct and being included in discussion on the management of Scotland's seas. A respondent within the energy sector commented that the assumption that the development of the new marine renewable infrastructure will interfere with defence navigation and MOD activity is incorrect. An individual requested an end to using Cape Wrath for MOD activities.

Alternative policies

16.10 Only five respondents responded to Q34, four of which confirmed there were no alternative planning policies to be included in the chapter on Defence. The other comment, from an energy organisation, noted the NMP needs to provide information on a hierarchy of considerations for instances where there are potential planning conflicts in the marine environment, given that military activities are not devolved to Scotland.