Scottish blue carbon action plan

3. Blue carbon habitats in the policy landscape

The protection and restoration of blue carbon habitats takes place within a wider policy landscape that has developed around nature conservation and environmental protection, as well as tackling climate change. While the recognition of the carbon storage benefits of these habitats may be a more recent development, the biodiversity value of blue carbon habitats is well understood and has been an important driver for policies for many years. Many blue carbon habitats therefore benefit from existing measures taken to conserve and restore nature. This demonstrates the win-win potential of nature-based solutions as efforts to tackle biodiversity loss benefit climate mitigation and vice-versa.

A number of high-level strategies and plans are already in place that coordinate and guide Scottish Government priorities, and set out upcoming developments across different policy areas, including:

• the Scottish Biodiversity Strategy (SBS) and Delivery Plan 2024 to 2030, which set out how Scotland will become nature positive by 2030 and restore and regenerate biodiversity by 2045
• the UK Marine Strategy, which sets out how the four governments of the UK will achieve and maintain good environmental status in the UK marine area
• Scotland’s Climate Change Plan 2018 to 2032, which sets out how Scotland will achieve net zero by 2045
• the Scottish National Adaptation Plan 2024 to 2029 (SNAP3), which sets out how Scotland will build resilience to climate change

This section provides a high level overview of the main policies relevant to blue carbon habitats and then outlines the upcoming policy developments. While these upcoming developments are commitments the Scottish Government has already made, work is being undertaken to ensure that the latest blue carbon evidence is integrated into the policy development process in line with objective 1 of this action plan. This is to ensure that the role of these habitats as natural carbon stores is given due consideration alongside their well-recognised biodiversity benefits.

When policies undergo development, they must have regard to the statutory guidance on Scotland’s Guiding Principles on the Environment, including as part of their impact assessments. This includes the application of the precautionary principle, prevention principle, ‘polluter pays’ approach, and rectification of environmental damage at source. As scientific understanding and evidence on blue carbon habitats has advanced, some recent Strategic Environmental Assessments for marine plans and policies, as well as Environmental Impact Assessments for marine and coastal developments and other impact assessments, have started to consider marine and coastal blue carbon stocks, often under the ‘climatic factors’ topic.^[8]

Key policies for blue carbon habitats

A number of important policies already apply to blue carbon habitats in some manner. These include:

• Marine Protected Areas (MPAs). Many blue carbon habitats are already designated as protected features because they are important parts of Scotland’s biodiversity, and so benefit from the conservation objectives and management advice from NatureScot (for inshore) and/or JNCC (for offshore). Competent authorities (including the Scottish Government) are required to undertake their functions in compliance with relevant legislation for MPAs, for example for permissions, consents, and licencing. Fisheries management measures may also restrict certain activities to prevent damage to protected features.
• Marine Planning. The National Marine Plan contains policies on climate change (General Policy 5) and on protecting the natural environment (General Policy 9), which apply to blue carbon habitats. Public authorities are required to take authorisation and enforcement decisions in accordance with the plan.
• Fisheries Management. While fisheries measures are not specifically aimed at protecting blue carbon habitats, restrictions for other purposes (such as protecting fish spawning grounds or avoiding conflict with other marine users) can help to manage pressures on blue carbon habitats present in those areas. There is ongoing consideration as to how to best integrate blue carbon into fisheries management, including recognition in upcoming fisheries management plans.
• River Basin Management Plans. These plans set out what the Scottish Government, the Scottish Environment Protection Agency, responsible authorities, and others will do to maximise the benefits of a healthy water environment for wildlife, people and businesses. They recognise the important role of a healthy natural environment in climate change mitigation.
• Coastal Change Adaptation. Several blue carbon habitats are recognised for their role for natural flood and coastal protection. Funding is provided to local authorities under the Scottish Government’s Coastal Change Adaptation Programme to support development of adaptation plans and undertake resilience and adaptation actions. The future coastal monitoring programme will provide wider information on blue carbon habitats, as outlined in SNAP3.
• Restoration and Enhancement Funding. Funds including the Scottish Marine Environment Enhancement Fund (SMEEF), the Nature Restoration Fund (NRF), and the Facility for Investment Ready Nature in Scotland (FIRNS) provide funding that supports blue carbon habitats. This includes direct support for restoration projects, such as the £2.4 million seagrass restoration programme provided via SMEEF in partnership with SSEN Distribution (see Box 2), and funding to support the development of investment-ready projects and market mechanisms by FIRNS, including work that has contributed to the UK Saltmarsh Code.

Blue carbon in key upcoming policy developments

MPA Fisheries Management Measures. Spatial protections are a key tool to protect features and contribute to passive restoration by helping to manage pressures on marine habitats.

Management measures for fishing activities for inshore sites and for PMFs in key biodiversity locations outside of the MPA network are due to be consulted on in late 2025 and offshore measures will be put in place in the autumn. While final details will be established following consultation, these measures will contribute to protection for blue carbon habitats that are vulnerable to fishing activities, including seagrass, kelp, and different types of seabed sediment, such as burrowed mud, sandflats, and mudflats. Draft measures are linked to the conservation objectives associated with protected features. A wide range of scientific evidence and advice has informed the preparation of draft management measures. Whilst protecting biodiversity has been the main driver for these measures, consideration of natural carbon storage has been integrated into this process over time as evidence on blue carbon has developed. Recognising that the MPA network has developed over decades and scientific understanding of blue carbon is a more recent development, separate work is also being undertaken to assess how well existing and proposed management measures protect blue carbon (actions 8 and 12 of this action plan).

National Marine Plan 2 (NMP2). Marine planning is an important tool for managing the wide variety of activities in Scotland’s seas and ensuring that important natural habitats, including blue carbon habitats, are taken into consideration. This contributes to both passive restoration by managing pressures, and to active restoration by identifying space for restoration.

As NMP2 is developed, opportunities to integrate consideration of blue carbon are being pursued. Building on the first National Marine Plan, the NMP2 will support the sustainable development of Scotland’s seas, protect the marine environment, and deliver for coastal communities. The NMP2 Planning Position Statement includes consideration of alignment with the NPF4 to give significant weight to the climate and nature crises. The statement also sets out that NMP2 could include a policy that requires proposals for activities or developments to demonstrate climate change mitigation and adaptation in their design and/or siting. NMP2 could also support opportunity mapping for restoration, enhancement, or nature-based solutions for climate mitigation and adaptation and set out a requirement to consider this evidence in decision-making.

Restoration Funding and Private Finance. Funding for enhancement and restoration projects is a critical part of active restoration of nature.

A Saltmarsh Carbon Code is under development at a UK level and is being coordinated by the UK Centre for Ecology and Hydrology, including input from the SBCF. A pilot code is due to be produced in 2025.^[9] The Saltmarsh Code will provide a means to support private investment into saltmarsh restoration by providing a rigorous framework for saltmarsh restoration projects, helping to unlock carbon finance and support biodiversity.

This is part of a wider programme of work being undertaken within the Scottish Government and in collaboration with the UK Government and other partners to support responsible, values-led investment in natural capital. This includes the development of high-integrity voluntary carbon markets and of opportunities to invest in biodiversity as well. The Scottish Government’s Natural Capital Market Framework sets out the principles for this and provides guidance and links to tools and resources. To date, developments in this area have been focused primarily on terrestrial opportunities, particularly in woodlands and peatlands. The extension of such mechanisms to marine habitats is still being explored, and some unique challenges need to be addressed to apply market mechanisms to the marine environment. The SBCF will continue to engage with this work to provide evidence to ensure that blue carbon aspects are appropriately incorporated.

SMEEF also provides a mechanism to channel private finance into restoration of Scotland’s marine and coastal environment (see Box 2, below, on the seagrass planting programme) and NRF provides public funding for restoration projects, including for blue carbon habitats. Enhancement and restoration projects will continue to be supported and will be guided and informed by the latest scientific advice (including from the actions in this plan).

Marine and Coastal Restoration Plan. To accelerate ecosystem restoration and regeneration, a Marine and Coastal Restoration Plan is under development and due to be published by the Scottish Government before the end of 2025. Restoring natural ecosystems can provide a range of ecological, social, and economic benefits, including increased biodiversity and contributions to natural carbon storage.

The Marine and Coastal Restoration plan will identify actions to help prioritise habitats and locations suitable for restoration, maximise ecological benefits and social and economic opportunities, support community-led restoration and enable investment in restoration efforts. Blue carbon habitats, particularly saltmarsh and seagrass, are an important aspect of the Scottish Government’s approach to restoration.

Box 2: Seagrass planting programme

£2.4 million in funding has been provided by the company SSEN Distribution and will be managed by SMEEF to support seagrass restoration projects. This is Scotland’s largest ever and most comprehensive seagrass planting programme. Launched in 2024/2025, it will aim to restore 14 hectares over the next 3 years. Grants under this programme have been provided to:

• Mossy Earth’s Wilder Firths project
• Kintyre Coastal Network’s East Kintyre Biosphere
• Wester Ross Fisheries Trust’s seagrass planting project
• University of the Highlands and Islands – Restoring Shetland’s Marlie Meadows project