Queen of Sweden Historic Marine Protected Area - designation proposal: final business and regulatory impact assessment – 18 July 2025

Section 3: Costs, impacts and benefits

Costs

Costs to businesses

Option 1 (do nothing) – There would be no additional costs to industry.

Option 2 (designate the site as a Historic MPA) – Under this option, activities that might affect the preservation objectives for the Historic MPA will be considered through marine licensing or planning processes. However, as the area proposed for designation is very small and will in most instances be able to be avoided by developers and sea-users, it is not considered that designation will place a significant burden on marine stakeholders beyond some possible additional costs where assessment of archaeological impacts is required prior to consenting.

Costs to Government and Historic Environment Scotland

Costs to HES include costs in advising on designations, ongoing recording/monitoring work on designated sites, advising on the management of designated sites, and providing support to local stakeholders. Costs to Scottish Government include administration relating to designation orders and any subsequent administrative costs relating to management.

Option 1 (do nothing) – there are no costs to the Scottish Government.

Option 2 (designate the site as a Historic MPA) – The original survey of the Queen of Sweden cost £31k. As the MPA monitoring strategy follows a risk-based approach, ongoing monitoring costs for the site have not been identified at this stage and will be dependent on a range of factors including the type of monitoring required. There will be a small cost for HES to provide advice to the Scottish Government’s Marine Directorate on designations, marine licensing applications and to public authorities on functions they exercise.

Enforcement, sanctions and monitoring

Option 1 (do nothing) – No enforcement and monitoring framework is in place.

Option 2 (designate the site as a Historic MPA) – Periodic monitoring should be carried out by a contractor on behalf of HES, which would likely be a marine archaeology service contractor. HES will also explore other options such as citizen science and working with local dive groups. HES will continue to work with local communities, the police and other justice partners on enforcement. The 2010 Act also provides enforcement powers to Marine Enforcement Officers (MEOs), include boarding vessels and marine installations, entering and inspecting premises and vehicles, powers of search and seizure, forcing vessels to port, and requiring production of certain information. The Financial Memorandum for the 2010 Act envisaged a cost of enforcement action associated with MPAs of £12,000 per site per year (in 2010 prices). It envisaged that the Marine Directorate will take the lead role, closely working with HES and other justice partners on Historic MPAs. Given that the proposed Queen of Sweden Historic MPA is at such a small scale and is adjacent to the coast, this estimate is considered excessive in the circumstances – even more so when inflating to 2025 prices – and as such this cost remains unmonetised in this BRIA.

Net present costs

Due to the lack of reliable data regarding the potential costs and the uncertainty regarding the frequency in which they would be incurred, the net present costs have not been calculated.

Other impacts

No other impacts have been identified for the proposal within this BRIA.

Scottish firms’ international competitiveness

The proposal discussed within this BRIA will not impact Scottish businesses ability to compete internationally.

Benefits

The proposal discussed within this BRIA will not impact business processes.

Option 1 (do nothing) – There are no benefits as no statutory protection exists.

Option 2 (designate the site as a Historic MPA) – statutory protection as a Historic MPA does not limit responsible access. HES will be publishing information about the wreck which may be of interest to researchers and others, and help to promote understanding through ‘virtual’ access. It is possible that this may attract additional diving visitors to the site, although the economic value of this is difficult to quantify in a meaningful sense. This increase in marine tourism would be classed as ‘use values’, i.e. the benefits of using or visiting a particular asset or resource. While we make no attempt to estimate the specific use-value benefits of protecting the Queen of Sweden, we discuss estimated use and non-use values for other historic sites below.

Fujiwara, Cornwall and Dolan (2014) analysed and valued the wellbeing associated with visiting different types of heritage sites – a type of ‘use value’ estimation. They found that (for those who visited 3.4 heritage sites per year, the average number observed) different types of sites provide different (wellbeing) values to people. Visits to heritage sites in general were valued at £1,646 per person per year, while visits to historic industrial sites (such as an old factory, dockyard or mine) were valued at £1,096 per person per year, and visits to archaeological sites were valued at £847 per person per year. It should be noted that these figures are upper-bound estimates, and that there are barriers to visiting heritage sites. Some reported reasons for not visiting heritage sites include lack of time, lack of transport, costs, and poor health^[4].

While there are additional hurdles to ‘visiting’ a shipwreck like the Queen of Sweden, it is possible, e.g. as part of a diving group, to visit shipwrecks. Dives to visit wrecks (or reefs) are already taking place around Scotland’s coasts, with particular concentrations seen around Orkney and the Berwickshire coast. The 2016 Scottish Marine Tourism Survey had 168 respondents who mentioned taking part in (SCUBA) dives, with over 2,000 diving locations identified around Scotland^[5].

Any potential increase in marine tourism might also bring further benefits to the local community in the form of e.g. (terrestrial or coastal) tourism and hospitality.

The benefits of protecting our most important marine heritage assets are likely to extend beyond these ‘use values,’ and are commonly underestimated using traditional market valuation techniques. For example, a local community might assign importance to a certain asset that provides a distinctive characteristic to their local area. A natural capital approach attempts to account for this issue by using non-market valuation techniques – i.e. non-use values.

The UK Government’s Department for Culture, Media and Sport (then, the Department for Digital, Culture, Media and Sport), produced a rapid evidence assessment to gain a better understanding of valuation techniques and obtain reliable values across the arts, museums and heritage sectors^[6].

• One such study analyses visitors’ willingness to pay for various aspects when visiting the Roman archaeological site of Vindolanda, near Hadrian’s Wall. It was estimated that visitors would be willing to pay £14.60 per visit (£17.64 in 2025 prices) for continued excavation and research at the site – which can be broadly defined as a non-use value given the beneficiaries are not the visitors, but the discovery and existence of the cultural assets now and for future generations.
• Similarly, Danish citizens were willing to pay £8.96 more in annual income tax to ensure permanent protection of archaeological artefacts from Stone Age villages buried in the topsoil, or £12.17 to ‘reduce the destruction’ of these sites (£10.82 and £14.70 in 2025 prices, respectively). This is despite these Stone Age settlements not being visible or open to the public (similarly in many ways to the Queen of Sweden for a large proportion of the Scottish public).

In 2023, there were 2.54 million households in Scotland^[7]. If each household in Scotland was willing to pay e.g. between £10.82 and £17.64 annually for the protection of Queen of Sweden, it could be argued that this could accrue non-use benefits of between £27.5 million to £44.8 million annually. Due to the uncertainty of these estimates and their limited relevance to Queen of Sweden, they are not used as estimates for non-use benefits.

Small business impacts

As this marine historic asset is visited for recreational and tourism reasons (in particular recreational diving), it is possible that designation will help to promote the heritage value of the site, foster its understanding and enjoyment, and encourage responsible behaviour by divers and others.

Investment

The proposal discussed within this BRIA does not impact Scotland’s potential for global investment.

Workforce and Fair Work

The proposal discussed within this BRIA does not directly affect inclusive recruitment/job satisfaction.

Climate Change/Circular Economy

The proposal discussed within this BRIA does not impact on businesses ability to contribute to climate and circular economy targets.

Competition Assessment

The proposal discussed within this BRIA will not have any impact on competition.

Consumer Duty

The proposal discussed within this BRIA will not have any impact on Consumers.