Proposed Fisheries Management Measures within Scottish Inshore Marine Protected Areas (MPAs) and proposed Priority Marine Feature (PMF) Management Areas - Partial Business and Regulatory Impact Assessment (BRIA)

4. Engagement and information gathering

4.1 Engagement approach

The development of the MPA network in Scottish waters has been in progress since the early 2000s and has involved a large degree of stakeholder engagement. While the MPA network is science-led in advice, engagement has been sought throughout the process from those stakeholders who hold an interest or who may be affected by MPAs and the proposed fisheries management measures. Stakeholder insight is and continues to be sought in providing information used to support the development of options for potential management measures for MPAs and proposed PMF management areas in their activity area.

In July 2018, a prioritisation process was undertaken by Marine Directorate (formerly Marine Scotland) and NatureScot (formerly Scottish Natural Heritage), which identified 11 PMFs which are most vulnerable to physical disturbance from mobile bottom-contacting fishing gear.

A screening and scoping exercise for a Strategic Environmental Assessment (SEA) was carried out and in 2018, a public consultation was completed to seek views on the scoping report^[8], the advice provided by NatureScot on each PMF, and the management approach that would be assessed.

The PMF protection and MPA management processes were combined at the sustainability appraisal level due to the similarities between them (i.e. both bringing forward fisheries management measures for habitats and species). A draft Strategic Environmental Assessment (SEA) and Socio-Economic Impacts Assessment (SEIA) for each project were prepared in 2019. The assessments were brought together in a single sustainability appraisal.

At a workshop in 2019, concerns were raised by fisheries stakeholders about the scope of the PMF measures. A commitment was made to undertake local fisheries engagement ahead of the public consultation on the proposed measures. The aim was to develop an alternative option that still met the requirements of NMP policies including general policy 9b but with a lower economic impact on fisheries, whilst improving vessel safety (e.g. through opening up sheltered winter fishing areas). This local engagement took place from December 2019 - March 2020 and December 2021 - January 2022.

The COVID-19 pandemic created a delay in developing this work. This delay meant that the work was taken back to the SEA scoping stage, where MPA and PMF management measures were combined under one SEA and SEIA. This simplified the process for stakeholders and allowed better calculation of cumulative effects.

Eunomia Research and Consulting Ltd, in association with ABP Marine Environmental Research Limited and eftec, was commissioned by the Scottish Government Marine Directorate to design and deliver social impact research for MPAs and PMFs in Scottish Waters. This was undertaken in line with new guidance, developed with stakeholders in 2022.

The current research was intended to gather possible social impacts from the proposed fisheries management measures on local communities and identify issues and concerns. It is based on public and stakeholder engagement events: open-to-the-public drop-in events and invitation-only workshops conducted in June 2023, and an online workshop in August 2023.

Scottish Government officials visited seven mainland and island locations around the Scottish coast regarding the potential implications of the proposed fisheries management measures. The locations selected for engagement were fishing communities: Peterhead, Lerwick, Ullapool, Stornoway (including a linked online event for Barra), Oban and Troon. These were selected to represent Moray Firth, the Northern Isles, north coast, Western Isles, west coast and Clyde, respectively. The selection of locations aimed to ensure coverage of different SMRs, proposed PMF management areas and designation types.

In each location a drop-in event was held, with a stakeholder workshop on the following day. Over all the locations, 82 people participated in workshops, more than 200 people attended the drop-in sessions, and 205 people completed a survey which was distributed at the events and online. Attendance was sought from a wide range of stakeholders, because the proposed fisheries management measures being discussed have the potential to directly impact on fishers and affect their livelihood. Information on the sites or areas being considered and the potential fishing gear restrictions was provided at all events and provided the focus for the discussions. The findings are set out in the Social Impacts Research for Marine Protected Areas and Priority Marine Features Management in Scottish Waters, document.

The following summary outlines the key findings from the stakeholder engagement sessions. It reflects the views and perceptions shared by participants and is intended as a summary of qualitative feedback rather than evidence-based analysis. A number of the issues raised have been explored in greater detail within the inshore socio-economic impact assessment, which provides a data-driven evaluation.

The fishing industry was widely perceived to be in decline, particularly in Troon, Peterhead, Ullapool, and the Western Isles, due to factors such as recent and anticipated marine protection measures, quota restrictions, workforce shortages, Brexit, the Covid-19 pandemic, incursions by foreign vessels, and reduced access to fishing grounds caused by wind farm development. Fishing remains integral to the social and economic fabric of coastal and island communities, supporting a range of occupations, sustaining local incomes, and contributing to cultural identity—particularly where it is closely linked to Gaelic heritage and a strong sense of place.

Participants expressed frustration at limited involvement in policy development and perceived a lack of trust between the fishing community and government, though there was a clear willingness to engage in co-developing sustainable management measures. Fishers viewed proposed measures as likely to reduce incomes, deter investment, and exacerbate existing challenges such as depopulation and loss of local services, with benefits to other sectors seen as uncertain. Divergent views were expressed on environmental outcomes, with conservation organisations highlighting the need for stronger protections, while fishers cautioned against unintended negative effects such as increased pressure on unprotected areas. Overall, participants called for greater transparency, locally informed decision-making, and improved collaboration to ensure that future measures balance environmental objectives with the social and economic wellbeing of coastal communities.

Extensive engagement with a full range of stakeholders has been undertaken in the development of the proposed fisheries management measures. Since 2022 Scottish Government officials have met with fisheries and environmental and conservation stakeholders separately 120 times in a range of different forums to discuss MPAs and MPA related issues.

Engagement was held on the development of the proposed PMF management areas which included extensive gathering of industry fishing activity data leading to reductions in some of the management areas shared with stakeholders initially in 2018. This led to the development of alternative options and further reductions were able to be made in 46 of 90 proposed management areas.

We have engaged further on other sites which stakeholders and their organisations have presented alternatives or amendments to including Clyde Sea Sill NCMPA, Fetlar to Haroldswick NCMPA, Sound of Arisaig SAC, Inner Hebrides and the Minches SAC, Sea of the Hebrides NCMPA, Solway Firth SPA and Berwickshire and North Northumberland Coast SAC. If able to meet the conservation objectives of the site and work within the limitations of policy, including compliance and enforcement amendments were made.

4.2 Future engagement

Further engagement is planned regarding the SPAs to establish a project with tangle netters to gather data on seabird bycatch. This will help increase our knowledge and evidence base to determine if any concessions can be made for those specific nets within these sites or areas, which have strict restrictions on set nets. Engagement is planned with Western Isles, Coll and Tiree and Orkney.

Engagement activities are also scheduled in relation to the public consultation. The Marine Directorate and NatureScot will conduct a series of virtual and in-person workshops, drop-in sessions, and online meetings. These sessions will take place both before and during the consultation period.

4.3 Internal Scottish Government engagement/engagement with wider Public Sector

The Scottish Government has discussed its proposals with the following internal groups during the development of the policy:

• Sea Fisheries and Marine Conservation Division
• Marine Planning and Policy
• Marine Analytical Unit
• Marine Economy and Communities
• Marine Operational Delivery
• Marine Directorate Science, Evidence, Digital and Data
• Aquaculture and Recreational Fisheries

Statutory Nature Conservation Body, NatureScot has been consulted on these proposals, with conservation advice helping to inform the basis of the proposed measures for consultation.

Management proposals were developed between 2017 and 2024 with stakeholders. Scientific and conservation advice was provided by NatureScot on the sensitivity of the protected features at each site, the 11 PMFs and advice on management options. JNCC provided scientific and conservation advice on the SPAs that overlap with the offshore regions.

4.4 UK/Devolved Administrations

UK or other Devolved Administrations were kept up to date with the development of measures including those that extend into the offshore area, but the Scottish Government has engaged with the Marine Management Organisation (MMO) in more detail as two sites with proposed fisheries management measures are cross border sites. The measures proposed are only being implemented in the Scottish area, so engagement was for awareness purposes only.

4.5 Wider Public Sector

The Scottish Government has engaged with Local Authorities across Scotland and plans further engagement.

The Scottish Government has also engaged with two Inshore Fisheries and Conservation Authorities (IFCAs). Similar to the engagement with MMO, this was in relation to cross border sites and was for awareness purposes only.

4.6 International

Marine Directorate officials will provide notifications to the Specialised Committee on Fisheries via the required notification process on the implementation of fisheries management measures within MPAs in the Scottish offshore region. This is for the three SPAs with an offshore component:

• Seas of Foula
• Seas off St Kilda
• Outer Firth of Forth and St Andrews Bay Complex

Non-UK vessels do not have access to the 0–6 NM zone, and the UK-EU Trade and Cooperation Agreement removed historic access rights to the 6–12 NM area for EU vessels around Scotland.

This policy of implementing fisheries management measures within MPAs in the Scottish inshore region aligns with the EU’s ecosystem-based approach^[9] and is not expected to impact access to EU markets for people, goods and services.

The Marine Directorate will continue to engage EU and other States that will be affected by the proposed measures.

4.7 Business/Third Sector engagement

Further to our public engagement, during the intervening years opportunities have been taken to engage with businesses and relevant external organisations.

There has been regular engagement with external stakeholders mostly attending in-person or virtual meetings and stakeholder workshops on economic and social impacts relating to implementation of fisheries management measures. We have engaged extensively with fisheries business as part of the development of this policy. This is part of our wider stakeholder engagement which is outlined in detail previously within this section.

Due to the location and level of restriction that these proposed fisheries management measures will place on site or proposed management area users, particularly the commercial fishing sector, we would envisage that stakeholders most likely to be impacted by their implementation would include the commercial fisheries sector. We would not rule out the possibility of other sectors such as Military and Defence, Oil and Gas, Seabed Mining, Shipping, Aquaculture (Finfish, Shellfish and Seaweed), Recreational Angling and Boating, Environmental Groups, Tourism and Wider Communities and Business, could be affected these proposed fisheries management measures. These cost and impacts are discussed further in the SEIA sections 4, 6, 7 and 8.

We will hold a series of in-person public events across the country, including in island and coastal communities, throughout the consultation period. In addition, several online sessions will be hosted to discuss the consultation process. Details and dates for all in-person and online events will be announced in due course.

Stakeholders who have engaged with Officials throughout the development process of the fisheries management measures being proposed which are detailed below:

Businesses

• Amity Fish Company
• Barratlantic Ltd
• Cooke Aquaculture - member company of Salmon Scotland
• Fish Industry Training Association
• Hebridean Adventures
• Kallin Shellfish Ltd
• Kitesurf Scotland
• Mowi
• Organic Sea Harvest - member company of Salmon Scotland
• Peterhead Fish Market
• Spes Bona Superior Seafood
• Ullapool Charters Ltd
• Fisherman in region of Troon
• Fisherman in region of Barra
• Fisherman in region of Peterhead
• Fisherman in region of Stornoway

Some of these stakeholders attended the in-person and/or workshops on Social Impacts of the proposed fisheries management measures in 2024.

Many will have been involved in wider engagement over the last 10 years while developing measures, through a variety of meetings, open-to-the-public drop-in events, invitation-only workshops and online workshops.

Organisation

• Aberdeen Fish Producers Organisation (AFPO)
• Association of Shetland Community Councils
• Castlebay Community Council
• Clyde Fishermen’s Association (CFA)
• CNE Councillor/Local Council
• Communities Inshore Fisheries Alliance (CIFA)
• Councillor for Barra
• Hooktone Ltd
• Local Council Offices (Comhairle nan Eilean Siar)
• Lochbroom Community Council
• Mallaig and Northwest Fishermen’s Association (MNWFA)
• North and East Coast Regional Inshore Fisheries Group (NECRIFG)
• North East of Scotland Fishermen's Organisation Ltd.
• Northwest Coast Regional Inshore Fisheries Group (NWCRIFG)
• Oban Community Council
• Orkney Fisheries Association (OFA)
• Outer Hebrides Regional Inshore Fisheries Group (OHRIFG)
• Peterhead Community Council
• Ross, Sutherland, Skye and Lochalsh Fisherman’s Association (RSSLFA)
• Scottish Fishermen’s Federation (SFF)
• Scottish Fishermen’s Organisation (SFO)
• Scottish White Fish Producers Association (SWFPA)
• Shetland Council
• Shetland Fishermen’s Association (SFA)
• Shetland Regional Inshore Fisheries Group (SRIFG)
• Shetland Shellfish Management Organisation (SSMO)
• Shetland University of the Highlands and Islands (UHI)
• Southwest Coast Regional Inshore Fisheries Group (SWCRIFG)
• Stornoway Community Council
• The Oban Community Harbour Development Association
• Troon Community Council
• West of Scotland Fish Producers Organisation
• Western Isles Fishermen's Association (WIFA)

Some of these stakeholders attended the in-person and/or workshops on Social Impacts of the proposed fisheries management measures in 2024.

Many will have been involved in wider engagement over the last 10 years while developing measures, through a variety of meetings, open-to-the-public drop-in events, invitation-only workshops and online workshops.

Third Sector Organisation

• Fairlie Coastal Trust - member of CCN
• Friends of Loch Etive
• Friends of the Sound of Jura - member of CCN
• Little Loch Broom Marine Life - member of CCN
• Marine Concern
• Scottish Association for Marine Science (SAMS)
• Sea Change, Wester Ross - member of CCN/Marine Conservation
• South Skye Seas initiative
• Blue Marine Foundation
• Coastal Communities Network (CCN) and associated members
• Community of Arran Seabed Trust (COAST)
• Flora and Fauna International
• Open Seas
• Our Seas (and associated members)
• Royal Society for the Protection of Birds (RSPB)
• Scottish Islands Federation (SIF)
• SE Link (and associated members)
• Sustainable Inshore Fisheries Trust (SIFT)

Some of these stakeholders attended the in-person and/or workshops on Social Impacts of the proposed fisheries management measures in 2024.

Many will have been involved in wider engagement over the last 10 years while developing measures, through a variety of meetings, open-to-the-public drop-in events, invitation-only workshops and online workshops.

We would expect the majority of the above listed stakeholders to respond to the public consultation on proposed fisheries management measures when this is launched.

4.8 Public consultation

During the last 10 years, we have developed these proposed fisheries management measures in accordance with the principles of fairness and engagement, underpinned by robust scientific evidence. The Scottish Government has engaged extensively with the fishing industry, communities, eNGOs and local decision makers throughout the process of developing fisheries management measures to minimise the impact on the catching sector and other fishing businesses. Scientific and conservation management advice was provided by NatureScot on the sensitivity of protected features at each site and for the 11 PMFs.

The SEA has been undertaken in line with The Environmental Assessment of Plans and Programmes Regulations 2004 which require that certain public plans, programmes and strategies be assessed for their potential effects on the environment. In addition, a SEIA has also been completed to explore the potential social and economic effects of the proposed management measures. These assessments have been undertaken by external contractors ABPmer Ltd and eftec Ltd and have been used to inform and produce a Sustainability Appraisal. These assessments will be included within the public consultation. All documents will be finalised following confirmation of the fisheries management measures to be taken forward. This section will be updated following the public consultation.

A formal 16 week consultation will be undertaken.

4.9 Other stakeholders

Subject to the outcomes of the public consultation, additional stakeholder engagement may be undertaken.