Scottish seabird conservation action plan: consultation analysis

3 The action plan (Q1)

3.1 As noted in Chapter 1, this consultation sought views on a Scottish Seabird Conservation Action Plan. The action plan described the declining numbers of seabirds in Scotland, the challenges facing seabird populations, and the need for urgent action to address this situation. It set out a vision for Scotland’s seabird populations as follows:

‘By 2045, Scotland’s seabird colonies are thriving and showing improved resilience to climate change with increases in abundance and breeding success since Seabirds Count (2023). This is the result of a co-ordinated national effort to manage our seas and coasts with seabirds in mind and through partnership delivery of priority seabird conservation actions to build resilience and support adaptation to climate change.’

3.2 The action plan then set out the partnership working and actions required to achieve this vision.

3.3 The first question in the consultation asked if respondents supported the implementation of the action plan.

Question 1: Do you support the implementation of the Scottish Seabird Conservation Action Plan? Please give us your views. [Yes / No / Unsure]

Please explain your answer.

3.4 Table 3.1 below shows that, overall, 94% of respondents (99 out of 105) said they supported the action plan, 1% (1 out of 105) said they did not support it, and 5% (5 out of 105) said they were unsure. Among organisations, 16 out of 18 respondents said they supported the action plan, one said they did not support it, and one said they were unsure. Among individuals, 83 out of 87 respondents said they supported the action plan, and 4 out of 87 said they were unsure.

Percentages may not total 100% due to rounding.

3.5 In addition, all 5,264 respondents who submitted responses as part of the RSPB answered ‘Yes’ to Question 1 – that is, they supported implementation of the Scottish Seabird Conservation Action Plan.

3.6 Altogether, 87 respondents – 18 organisations and 69 individuals – commented at Question 1. Those who answered ‘yes’ explained their reasons for supporting the action plan and, in some cases, highlighted areas where they thought the action plan could be strengthened. Those who answered ‘no’ or ‘unsure’ discussed reservations or concerns, although some in this group also made suggestions for strengthening the action plan. All these views are discussed further below.

Views supporting implementation of the action plan

3.7 Respondents – both organisations and individuals – who supported implementation of the action plan welcomed it and highlighted the importance of having a published, evidence-based, targeted and achievable plan. Some in this group described the action plan as ‘essential’, ‘critical’ and ‘vital’ and they noted that the decline in seabirds may be seen as a reflection of the degraded state of Scotland’s seas. These respondents repeatedly highlighted:

• The national and international importance of Scotland’s seabird populations
• The ‘catastrophic’ and ‘alarming’ levels of decline in seabird species in recent years
• The urgency of the action required to reverse the decline in these populations.

3.8 Respondents thought that the action plan would provide a clear, co-ordinated and accountable framework to support the recovery of seabird species. They thought it was helpful that the action plan would be led by the Scottish Government and would involve international collaboration. They also praised what they saw as a comprehensive assessment of the vulnerabilities of individual seabird species and the action plan’s focus on addressing the range of pressures facing seabirds.

3.9 Individual respondents often described the enjoyment they got from watching – and hearing – seabirds around Scotland’s coasts. Some voiced sorrow, concern or dismay about the decline in seabird populations in recent years. This group not only highlighted the importance of protecting and supporting biodiversity and ecosystems, but also saw healthy seabird populations as economically, culturally and socially valuable. Some noted the positive impact that seabirds have on sustainable tourism and economic growth in coastal and island communities.

3.10 Organisations expressed a range of additional views, and in some cases highlighted aspects of the action plan that they thought required strengthening. Recurring themes in the responses from this group included:

• The importance of funding: Some organisations commented that the implementation of the action plan will require adequate, targeted funding. Some wanted clarity about how the action plan would be funded and it was suggested that a short- and long-term funding and investment plan would be required. Some noted the inadequacy of existing funding for research and monitoring of seabird populations. There was also a concern expressed by some environment and nature organisations that funding for seabird conservation should not become overly reliant on compensation paid by offshore windfarm developments, as such developments contributed to the decline in seabirds.
• The need for SMART objectives^[6]: It was suggested that some priority actions in the action plan were vague and lacked timescales. Respondents wanted to see more specific actions (or targets) linked to timeframes. There was also a view that the action plan should set out a clear governance structure and specify a designated lead organisation for each action. A related suggestion was that seabird populations and species most at risk should be prioritised for action, and that a detailed delivery plan – with timescales – should be produced in relation to these.
• The need to manage conflict: While it was noted that the restoration of Scotland’s seabird populations will have a range of benefits for communities and fisheries, there was also a recognition that measures set out in the action plan would require buy-in and compromise from other sectors – particularly the energy and fishing sectors. It was suggested that careful consideration should be given to how best to maximise benefits and identify and manage conflicts.

3.11 Some organisational respondents also said they welcomed the focus in the action plan on the ongoing need for monitoring data. This was seen to be crucial for measuring progress. Some respondents also identified potential gaps in current monitoring data – such comments are covered in Chapter 6.

3.12 It was also common for respondents – including those who took part in the RSPB campaign – to say they wanted the scope of the action plan to be extended to include two additional seabird species – the common gull (red-listed) and black-headed gull (amber-listed) both of which, it was suggested, had suffered major decline in Scotland.

Support with caveats

3.13 Some organisations in the fishing sector indicated that they supported implementation of the action plan (or they supported ‘reasonable and proportionate measures to aid conservation’) but also highlighted concerns. Specifically, there was a call for ‘scientific rigour’ to be applied to the conservation of seabirds – ensuring that actions are based on evidence while avoiding the desire to simply do ‘something’ or ‘anything’ to support the recovery of seabird populations.

3.14 There was a view that the action plan should acknowledge that, despite any actions that may be taken to support the recovery of seabird populations, climate change may be creating an environment that is no longer capable of supporting previously documented population levels. There was also a concern that the fishing sector may be expected to ‘pay’ for impacts that are caused by issues not of their making (i.e. climate change and avian flu), or to compensate for damage caused by other sectors (the offshore wind sector, in particular).

Views not in support of implementation

3.15 One organisation did not support the implementation of the action plan. This respondent, from the fishing sector, argued that the action plan placed too much weight on the management of fishing activities, as compared with other sectors (such as the oil and gas sector and offshore renewables sector) which, in their view, had a greater impact on seabird populations.

3.16 This respondent also cited two studies / reports that found an association between warming sea temperatures (due to climate change) and disruption to seabird food sources – and suggested that the impacts of climate change were more significant than any impacts from fishing.

3.17 They further pointed out that EU and Scottish policies, including the EU Common Fisheries Policy Article 2) and the Scottish National Marine Plan (2015) require marine activities to balance the need for economic and environmental sustainability.

3.18 This respondent stated that they would be fully supportive of an action plan to address seabird population decline, but that the actions in such a plan should focus on the primary factors that are causing the decline.

Other views

3.19 Three of the five respondents who answered ‘unsure’ at Question 1 went on to provide comments. One individual said they supported implementation of the action plan but felt it should be strengthened, and that its scope should be extended to include the common gull and black-headed gull. A second individual, who identified himself as a fisherman from the Solway coast area, said he has not seen any significant recent reduction in seabird numbers in that area.

3.20 The one organisational respondent in this group (from the fishing sector) stated that they supported implementation of the action plan ‘in part’. This respondent welcomed the proposed collaborative partnership approach set out in the action plan but felt this could be strengthened in the sections on ‘maximising resilience and survival’ and ‘building the evidence’. Specifically, this respondent suggested there should be a focus on co-design and facilitation of stakeholder-led approaches. The point was made that those who are actively working to identify, develop and implement practical solutions such as bycatch reduction in the fishing sector should be involved and supported.