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

  • Very few issues were raised by more than one respondent to this chapter.
  • There were requests to include reference to the recent Crown Estate study conducted to identify aggregate deposits in Scottish waters.

17.1 The Draft NMP noted that marine aggregate extraction removes sand and gravel from the seabed for use as construction aggregate or for land reclamation or beach replenishment. Historically the industry has been very small in Scotland due to an adequate land supply and lack of suitable and easily accessible marine resources. While aggregate extraction in Scotland has taken place at two sites in Scottish waters, there are currently no licences for marine aggregate extraction although there is potential for further activity if it becomes viable under different economic conditions.

Comments on Aggregates, Chapter 16

Question 35: Do you have any comments on Aggregates, Chapter 16?

Question 36: Are there alternative planning policies that you think should be included in this chapter?

17.2 Twenty-five respondents provided commentary to question 35.

Table 17.1 Question 35: Do you have any comments on Aggregates?

Respondent group
Individuals (16) 2
Academic / scientific (7) 1
Aquaculture (5) -
Energy (12) 2
Environment / conservation (9) 5
Fisheries (13) -
Historic / Heritage (5) 2
Industry / transport (9) 3
Local Authority (15) 4
Local coastal partnership (7) 1
Local group (5) 1
Other public sector (10) 3
Recreation / Tourism (7) -
Other (4) 1
Total (124) 25

17.3 While a number of themes emerged, only three received comment from more than one respondent. The greatest number of respondents (six) welcomed some or all of this chapter. Four respondents referred to the recent Crown Estate study conducted to identify aggregate deposits in Scottish waters and noted this would be a useful reference within this chapter. Two energy companies noted that energy developments sites that have been identified for development by the Scottish Government should be given protection from aggregate developments that would adversely impact on renewable developments.

17.4 Other issues raised by only one respondent included:

  • The need to protect maerl beds;
  • Marine and estuarine dredging need to take into account priority species and habitats and its impact on the overall biodiversity of Scottish seas and the seabed;
  • Policies demonstrating best practice mitigation need to be promoted;
  • The need for a formal reporting system;
  • The need for the Scottish Government to consult with industry and explore future demands and opportunities to meet demands from land use consented operations;
  • If mineral extraction is allowed there should be a bonding requirement undertaken by an independent expert to ensure any land based facilities are fully restored;
  • This chapter fails to mention Glensanda Harbour or its importance;
  • It would be useful to develop a glossary to support the final NMP;
  • Aggregates extraction can damage the sea bed in the same way as trawlers and dredgers, and should be discouraged;
  • Support for the general objective laid out in this chapter, although concerns that large scale aggregate extraction from seabed has the potential to alter or destroy important sites of geodiversity interest, particularly small scale relict features;
  • Interaction with the water industry is low risk in spatial terms, although care should be taken to avoid any dredging and dumping impacts in the vicinity of material assets or discharges belonging to the water industry;
  • It is important not to generalise the importance and relevance of the aggregate industry as a whole;
  • Consideration should be given to establishing suitable marine policy provisions to allow mineral safeguarding to be considered under the marine planning process.

Alternative policies

17.5 Respondents were also asked to say whether there were any alternative planning policies that should be included in this chapter; only four respondents made any comment. Responses included;

  • The introduction of a third Aggregates Policy so that the operation of Glensanda Harbour and its approaches are protected from development that could compromise its future operation and expansion;
  • Sustainability and commercial fishing;
  • A policy promoting the use of consented reserves in preference to offshore extraction.

17.6 One respondent also made suggestions for changes in wording to two existing policies:

  • (Aggregates 1) Consenting and licensing authorities should consider the impacts of other development or activity on areas defined as being of potential marine aggregate resource, including whether the development/activity would inhibit future aggregate or mineral exploitation. Where there is an interaction, consideration should be given to appropriate steps to safeguard marine mineral resources;
  • (Aggregates 2) Consenting and licensing authorities should ensure all the necessary environmental issues are considered and safeguards are in place when determining whether any proposed dredging is in accordance with the principles of sustainable development and considered to be environmentally acceptable.