21 ADDITIONAL COMMENTS
21.1 A number of respondents took the opportunity to provide additional comments, many of which reiterated points made to earlier questions. A number provided background information on their organisation in order to provide context for their actual responses. Some also noted their willingness to be involved in future discussions around the development of the National Marine Plan.
21.2 Many of these respondents welcomed the opportunity to respond to this consultation and noted their general support for the Draft NMP; for example, for a framework for marine planning that will play a vital role in the planning, management and sustainable development of Scotland's marine resources. Many respondents were pleased with the general direction and approach adopted and/ or considered marine planning to be an integral part of the sustainable management of the marine environment. A few commented that while they are pleased with the approach taken in the Draft NMP, this is a high level document which provides little specific detail. For example, a public sector organisation requested more information on the forthcoming Regional Marine Plans, and the process for developing and implementing these.
21.3 Key themes raised included:
- This is a high level document which will need more detail to be provided in future iterations or to provide or signpost to other guidance;
- A need for links with other national bodies and effective co-ordination with other EU, UK, national, regional and local bodies to ensure effective planning and co-ordination. For example, a number of environment/ conservation bodies suggested that, as it is currently presented, the NMP does not conform with the duties of the Marine (Scotland) Act 2010;
- A need for consistency with other national planning frameworks and objectives; alignment between national and regional plans and links between land use and marine planning; and the hierarchy between different plans;
- Timescales for the implementation, monitoring and review of the NMP; with suggestions that this should match those outlined under land use planning;
- A need for further information in relation to how objectives that have the potential to conflict with each other will be managed; and a clear long term vision that can help balance competing sectors' priorities;
- The need for high quality data so that decisions taken can be based on good evidence; a need for all organisations involved in the development and implementation of the NMP to work to agreed high quality data management standards; regular updating of Scotland's Marine Atlas;
- More guidance to show how national strategic and sectoral objectives should be dealt with under regional planning;
- A list of definitions and their consistent application throughout the NMP; also that there is consistency with other relevant documentation;
- Sectoral objectives should focus on the role of the sector in the delivery of sustainable marine planning
- There is a need for objectives and policies relating to mitigation and adaptation to climate change;
- A need for direction on how cumulative effects will be addressed through marine planning and licensing;
- A need for recognition of geodiversity;
- An environment-specific sector chapter that more effectively integrates environmental issues within the NMP;
- Concerns over the compatibility of sectoral objectives;
- That environmental information required to be provided under Aarhus has not been provided in the Draft NMP.
21.4 Two respondents in the industry/ transport sector noted that the reference to the IMO Convention for Ballast Water Management should be removed as the UK has not signed up to this. Also, that the NMP should provide for the mapping and future safeguarding of key shipping routes.
21.5 A small number of respondents noted their dissatisfaction with the consultation process, because of a perceived lack of public consultation and poor marketing of the consultation events. Two respondents commented on bias in the structure of the Project Advisory Group, which was perceived to be comprised of organisations based in the north or highlands of Scotland.