Scottish Highly Protected Marine Areas (HPMAs) consultation: Scottish Government response

Our response to the public consultation on the proposal to designate 10% of Scottish seas as Highly Protected Marine Areas (HPMAs) by 2026.

Annex A: Suggestions and alternative approaches for HPMAs from consultation responses

There were a vast number of comments, suggestions, ideas and alternative approaches within the consultation responses and the list below provides some examples separated into themes.


A number of different models were suggested to improve the process:

  • Local Coastal Authorities should be established (following the Local Harbour Authority model), to resolve conflict and engage with the local communities
  • Make any legislation "enabling" to allow local authorities to configure the best fit for local fisher folk. Make the implementation "local", not "national". Make the restrictions on the basis of scale to enable all small companies, boats, communities to thrive.
  • The Clyde Fishermen’s Trust ‘A Vision - The Clyde Fishery’ should be considered as a modern, carbon conscious and community empowered model.
  • Allowing designated routes for cables between sea infrastructure and the shore to safeguard community’s reliance on under-sea communication and power cables and additionally providing navigational safety.
  • Local communities should be able to designate their own, small, HPMAs to suit their needs such as “no-take” nurseries. Such areas could be policed more effectively locally.
  • A community Well Being Assessment is required, focussing on social, economic and environmental impacts.
  • The use of Regulating Orders for all inshore shellfish fisheries.
  • Safeguarding the designated shellfish water status.


  • Suggestion to establish a group of marine experts and representatives of local coastal communities to consider what, if any, new restrictions are required and examine evidence of how successful such restrictions have been elsewhere.
  • The importance of cetaceans in the considerations for further protection was highlighted, indicating their value in different ways. Some examples below:
    • Cetaceans contribute to ocean mixing and releasing nutrients (via migration, feeding, defecating), which in turn stimulates enhanced primary production (thus absorbing carbon dioxide and producing oxygen) and contributing to mitigating climate change.
    • Whales live a long time and act as living carbon stores, when they die the carbon sinks to the seafloor where it can remain for thousands of years – carbon stocks.
    • Evidence showing the potential for successful recovery of cetaceans if major threats such as such as entanglement and ship-strikes are managed well.
    • Scotland is of international importance for cetaceans and basking sharks, and many areas of critical habitat need protection, including essential fish habitats (to support feeding, breeding and calving).
  • Monitoring plans should include further investigation of cetacean prey dependencies and updating feeding ecology.

Alternative Solutions

  • Preference for several smaller, legislated “no take zones” over HPMAs.
  • Use existing measures within the existing MPA structure and the introduction of Priority Marine Features management outside the MPAs.
  • A pilot scheme trialling two highly protected marine sites (e.g. one inshore and one offshore) to measure their effectiveness and scope what is required for a full HPMA network and that would balance needs of fishing and other stakeholders.
  • Focus on protection from impacts from bottom contact trawling/dredging whilst allowing low impact methods to continue.
  • The reintroduction of the three mile limit.
  • Consider closed system fish farms to reduce the release of food, excrement, disease, chemicals, farm escapes etc.
  • Investigate low-impact artisanal fishing at sustainable levels, as part of the economic gain from any proposals: if activities are sustainable (e.g. once stocks reach a certain threshold), then they could continue.
  • Prioritise stricter more general protection for the marine environment (e.g. contaminates, pollution, plastics sewage) as this would benefit all stakeholders more.
  • An ecosystem-based approach to marine management should include effort- and fishing technique-based management as well as spatial management where necessary (similar to Norwegian model).
  • Use existing MPA sites as ‘buffer zones’ to only permit low-impact activity, such as potting, creeling, diving and hand lining, alongside strict protection (no take areas) as could offer an opportunity to support lower-impact commercial industries, whilst also supporting ecosystem recovery.
  • Ensure all marine tourism operators are WISE Scheme certified (or similar) to be able to operate and have a requirement to publish their environment and biodiversity policies.
  • Additional considerations for further protection:
    • Areas with high levels of biodiversity
    • Habitats in deep water which are particularly vulnerable to impacts
    • Habitats supporting connectivity, particularly for migratory species
    • Essential fish habitats in freshwater for diadromous fish
    • Coastal areas where there are terrestrial land-use impacts
  • Blanket bans on human activities should be considered carefully, and instead distinctions should be made in the management of what could be considered high and low-impact activities.



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