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

  • Only a small number of respondents expressed either positive or negative views on the Sustainability Appraisal ( SA) document, with similar numbers being favourable and unfavourable.
  • Respondents tended to focus on the SA issues of relevance and / or interest to themselves. There were some comments of the need for recognition of the incompatibility of some activities and the need for mitigation. A key issue was the growth of aquaculture.
  • Some respondents found the policies, models and assertions within the SA contradictory and confusing; and liable to give rise to conflicts between competing stakeholders.
  • There were references to the use of the word 'sustainable' and the interchangeable use of the terms 'sustainable development' and 'sustainable economic growth'.
  • There are some concerns that the SA does not address the duty to, where appropriate, enhance the health of the [Scottish marine] area.

20.1 The Scottish Government has produced an additional report which summarises the findings from a Sustainability Appraisal ( SA) of the Draft NMP as required by the Marine and Coastal Access Act 2009. There is an environmental component of the SA which is also required under Directive 2001/42/ EC and the Environmental Assessment (Scotland) Act 2005.

20.2 The SA identifies the likely socio-economic and environmental impacts of plans and policies, and alternatives to them. Taking place at an early stage in the plan preparation process, it ensures that decision-making is informed by relevant environmental and socio-economic information. The SA provides opportunities for the public to consider this information and use it to inform their views on the Draft NMP or policy.

20.3 The SA is a strategic-level appraisal of national-level planning policies and sectoral objectives and policies, which broadly assesses their expected effects. A series of key questions ('sustainability appraisal objectives') is used to structure the assessment. Information about the existing marine environment has been used to inform the appraisal and define these appraisal objectives. The appraisal identifies the individual and collective effects of the Draft NMP's policies and objectives on: the economy (including other users of the sea); communities, population and human health; and environmental features.

20.4 Respondents were asked:

Question 40: Do you have any views/ comments on the Sustainability Appraisal carried out for the NMP?

20.5 Table 20.1 shows that thirty-three of the 124 respondents gave a response to this question. The most frequent respondent types were the environment / conservation, public sector, energy, fisheries and recreation / tourism groups.

Table 20.1 Question 40: Do you have any views/ comments on the Sustainability Appraisal carried out for the NMP?

Respondent group Commented
Individuals (16) 2
Academic / scientific (7) 1
Aquaculture (5) -
Energy (12) 4
Environment / conservation (9) 6
Fisheries (13) 4
Historic / Heritage (5) -
Industry / transport (9) 2
Local Authority (15) 2
Local coastal partnership (7) 1
Local group (5) 1
Other public sector (10) 5
Recreation / Tourism (7) 4
Other (4) 1
Total (124) 33

20.6 Only a very small minority of respondents expressed either positive or negative views about the Sustainability Appraisal ( SA) document as a whole. Similar numbers commented favourably and unfavourably.

20.7 Most respondents answered the question in terms of a general summing up of their standpoints on the specific Sustainability Appraisal issues that were directly of interest to themselves or their organisation.

20.8 The most frequently discussed issue was the impact of aquaculture, with seven respondents (including three environment / conservation bodies and two recreation / tourism organisations) expressing fears about the potential growth of the industry.

20.9 Particular problems with the growth of aquaculture as reported in the SA were pinpointed as follows:

  • Aquaculture expansion targets not being fully assessed for environmental carrying capacity, or mitigation measures set out for environmental impacts ( e.g. protection of wild salmon);
  • Conflicts with other industries ( e.g. scallop divers, creel fishermen);
  • Conflicts with communities will increase;
  • Lack of reference to the potential impact of aquaculture on recreational activities.

20.10 One (public sector) respondent was generally supportive of aquaculture expansion, but only in designated areas where water quality can be monitored.

20.11 Three energy sector respondents desired more recognition for the beneficial impacts of the renewables industry within the SA. The beneficial impacts claimed, but not acknowledged within the SA, included:

  • Habitat creation due to developments having a positive impact on biodiversity, rather than merely avoiding adverse effects on biodiversity;
  • Meeting UK CO 2 emission reduction targets/ role in climate change mitigation;
  • Prevention of adverse effects on air quality;
  • Marine renewables survey work leading to discoveries about the historic marine environment.

20.12 However, one respondent saw the potential for increased community conflicts over renewables developments in the model designated in the document ( i.e. a balance between economic and environmental focus. Two respondents considered there was a lack of consideration given to safeguarding existing jobs from any adverse impact of new renewables-related activities.

20.13 Four respondents, including two recreation and tourism organisations, pushed for more recognition of the importance of environment-related activities and environment-related tourism such as wildlife watching and angling.

20.14 Five respondents stated they found the policies, models and assertions within the SA frequently contradictory and confusing in nature, and liable to give rise to conflicts between competing stakeholders. In particular three environment/ conservation respondents saw a contradiction with the assertion at 5.1.11 that continued Oil and Gas exploration is to be supported at minimum environmental cost to biodiversity, because the carbon emissions are regarded as threatening.

20.15 Four respondents, including two fisheries organisations, raised concerns over the defining of 'sustainable'. In particular the interchanged usage of the terms 'sustainable development' and 'sustainable economic growth' were seen as a cause of future misunderstandings, problems and conflicts.

20.16 Three respondents thought more recognition should be given to the incompatibility of various activities, i.e. a recognition that co-existence of some activities would require some mitigation. For instance, one public sector body commented that the placing of new fish farm developments should have the location of Water Waste Treatment Works and systems discharges taken into account.

20.17 Three environment/ conservation respondents considered that the SA failed to address the Marine (Scotland) Act 2010 duty to, where appropriate, enhance the health of the [Scottish marine] area whereas the Draft NMP sets out the positive effects of these.

20.18 Two respondents referred to the SA as a whole as confusing, and two others queried whether the SA had made any difference or improvements to the Draft NMP. An individual and an academic/ scientific contributor pointed out that monitoring work needs to be ongoing as changes take place over time.

20.19 Single respondents made the following points:

  • Environmentally and economically focused plans and policies need to work in balance with each other;
  • For developments, there needs to be a weighing of overall costs against overall benefits;
  • The alternatives assessed could have included a hybrid approach to high level policy-based strategic planning versus high level spatial planning. A third option, which could have been assessed would be high level policy-based strategic planning with some limited spatial planning at a national scale ( e.g. for safe navigation);
  • Policies relating to the sustainability of the sea fisheries sector will have positive implications for the sustainability of fish stocks as well;
  • Recognition should be given to human wellbeing, in terms of activities impacting landscapes and ways of life;
  • Little mention is given to sport and recreation.