Scottish seabird conservation action plan: consultation analysis

Executive summary

1. The Scottish Government carried out a public consultation on a Scottish Seabird Conservation Action Plan between 11 December 2024 and 5 March 2025. The draft action plan covered 22 species of seabirds. It identified the pressures on Scotland’s seabird populations while they are in Scottish waters and set out actions in relation to the following areas: (i) ensuring plentiful food supplies, (ii) restoring and improving seabird habitats, (iii) maximising resilience and survival, (iv) building the evidence base, (v) celebrating Scotland’s seabirds and (vi) making a global contribution.

2. The consultation contained four questions. Question 1 asked respondents about their overall support for implementation of the action plan. Question 2 asked whether the action plan identified all the key pressures on Scotland’s seabird populations. Question 3 invited views on the proposed actions, and Question 4 asked how progress on the action plan should be monitored.

Consultation respondents

3. The consultation received 107 substantive responses – 20 from organisations and 87 from individuals. In addition, a further 5,264 responses were submitted as part of a campaign organised by RSPB (Royal Society for the Protection of Birds). Thus, the analysis was based on 5,371 responses in total.

4. Organisational respondents included environment and nature organisations (9), organisations in the fishing sector (4), and organisations in the renewable energy sector (4). The remaining organisations (3) comprised an academic organisation, a non-UK government department and a recreational organisation.

Views on the action plan (Question 1)

5. Among those who submitted substantive responses, 94% said they supported implementation of the action plan. In addition, all those who submitted RSPB campaign responses supported implementation of the action plan.

6. Respondents who supported the action plan described it as ‘essential’. They praised what they saw as a comprehensive assessment of the vulnerabilities of individual seabird species and thought that the action plan would provide a clear, co-ordinated and accountable framework to support their recovery.

7. However, some in this group highlighted aspects of the plan that they thought required strengthening. Specifically, these respondents emphasised the importance of adequate funding for implementation, the need for SMART objectives^[1], and the need to manage conflicts – particularly with the energy and fishing sectors. There was also a common view that the scope of the plan should be extended to include two additional seabird species – the common gull (red-listed) and black-headed gull (amber-listed).

8. Other respondents expressed caveats to their support for the action plan. In particular, some from the fishing sector and some individuals thought the action plan gave too much weight to pressures related to fishing activities compared with other causes of seabird population decline (e.g. related to the oil and gas sector, offshore renewables sector, and climate change). Respondents who did not support the action plan, or who answered ‘unsure’ at Question 1, made similar points.

Views on the pressures on seabirds (Question 2)

9. Among those who submitted substantive responses, 85% said they thought the action plan had identified the key pressures on seabirds in Scotland. In addition, respondents who submitted an RSPB campaign response agreed that the key pressures were identified.

10. Respondents noted the interrelated nature of the pressures on seabird populations, and the fact that pressures would vary over time and across locations. They also suggested that more evidence was needed to better understand the identified pressures and their impacts. Those commenting on specific pressures often focused on three main issues: climate change; offshore wind and other renewable energy technologies; and fishing and / or fish-farming. In particular, respondents noted the impact of climate change on the other main pressures identified in the action plan. Some respondents discussed their views on the weight given to various pressures in the action plan.

Views on the key actions (Question 3)

11. There was a lack of consensus among respondents about whether the action plan had captured the key actions needed to deliver on its vision, aim and objectives. Overall, 44% of respondents said it did, 33% said it did not, and 22% said they were unsure. Among organisations, however, all but one of the environment and nature organisations (8 out of 9) answered ‘no’ to this question. The RSPB campaign response did not include a response to the closed part of Question 3, but did identify additional actions required in the action plan.

12. Regardless of whether respondents answered ‘yes’, ‘no’ or ‘unsure’ at Question 3, there was a great deal of overlap in the comments they made. For example, some respondents answered ‘yes’, but went on to say that they wanted the action plan to be more specific or ambitious in terms of its priority actions, while many who answered ‘no’ did so because they thought the action plan was not specific or ambitious enough.

13. Comments made at Question 3 were often lengthy and detailed, particularly where the respondent answered ‘no’ to the closed question. In most cases, respondents focused their comments on the specific actions listed under the six main areas for action.

• In relation to ensuring plentiful food supplies: Respondents wanted to see (i) more specific and ambitious actions and a clear commitment to restore and enhance fish habitats, (ii) expansion, monitoring and enforcement of designated Marine Protection Areas (MPAs), and (iii) continued protection of sandeel.
• In relation to restoring and improving seabird habitats: Respondents welcomed the progress that had been made in recent years to eradicate invasive non-native species (INNS) on some seabird islands and they thought further action was needed to enhance and / or create new seabird habitats. There was also a widespread view that the action plan should state a firm commitment to ensuring that biosecurity plans are required for new developments on and around seabird islands where there is a risk of introducing seabird predators.
• In relation to maximising resilience and survival: Respondents wanted to see (i) a clear commitment to roll out the use of Remote Electronic Monitoring (REM) on fishing vessels to address the problem of seabird bycatch, (ii) better monitoring and enforcement of the protected seabird site network, and (iii) a commitment that offshore wind developments will only be progressed if they help deliver nature positive outcomes.
• In relation to building the evidence: Respondents welcomed the action plan’s focus on addressing current evidence gaps. There was a recurring view that additional funding was needed to develop the evidence base.
• In relation to celebrating Scotland’s seabirds: There were a range of comments relating to the importance of raising awareness and educating members of the public to avoid disturbance of seabird colonies during breeding / nesting seasons.
• In relation to making a global contribution: Respondents welcomed the focus in the action plan on international collaboration and wanted to see Scotland playing a leading role in this area.

14. Across all the areas of action, respondents often called for stronger action and clearer commitments; the prioritisation of actions; and greater coordination across different sectors and greater collaboration between stakeholders

15. Respondents welcomed the recognition in the action plan that significant funding would be required to implement the actions listed. It was suggested that a costing exercise should be undertaken to provide a clearer understanding of the likely levels of investment needed. Some respondents cautioned against becoming too heavily reliant on funding received through strategic compensation from offshore wind developments as they thought this funding stream may not be sufficient to address the challenges.

Monitoring progress and success (Question 4)

16. Respondents recognised the importance of monitoring the progress and success of the action plan, as this would allow the actions to be properly directed and adapted, and the action plan to be reviewed and revised. They agreed that seabird population data would provide an important measure of progress and success. However, some respondents identified shortcomings or gaps in the proposed evidence sources for monitoring the action plan, and called for improved data on seabird populations, and improved monitoring and research in relation to the pressures affecting seabird populations.

17. More generally, in relation to monitoring progress and success, respondents highlighted the importance of (i) providing adequate oversight of the action plan, (ii) producing published annual reviews, (iii) engaging and collaborating with stakeholders and (iv) and improved funding for monitoring and research activities related to seabird conservation.