Scottish seabird conservation action plan: consultation analysis

4 Key pressures on seabirds in Scotland (Q2)

4.1 The action plan outlined a series of pressures on seabirds in Scotland. These pressures include climate change, and a range of other pressures grouped under three main themes of ‘threats to plentiful food supply’, ‘threats to safe breeding and foraging habitats’, and ‘threats to mortality’, as follows:

• Threats to plentiful food supply: reduction in prey availability
• Threats to safe breeding and foraging habitats: invasive non-native species; disturbance; habitat loss
• Threats to mortality: bycatch, collision, displacement and barrier effects; disease; pollution; intentional taking and destruction.

4.2 Climate change is noted as being relevant to each of the three themes.

4.3 These threats were described in fuller detail in the vulnerability report which accompanied the action plan. Question 2 asked respondents if all the key pressures had been identified.

Question 2: Do you agree that the key pressures to seabirds in Scotland are identified? Please give us your views. [Yes / No / Unsure]

If no, please provide detail.

4.4 Table 4.1 shows that, overall, 85% of respondents (88 out of 104) thought the key pressures to seabirds in Scotland were identified in the action plan, 12% (12 out of 104) thought they were not, and 4% (4 out of 104) said they were unsure. Among organisations, 11 out of 18 respondents said they agreed, five said they disagreed, and two said they were unsure. Among individuals, 77 out of 86 respondents agreed that key pressures were identified, seven disagreed, and two said they were unsure.

Percentages may not total 100% due to rounding.

4.5 In addition, all 5,264 respondents who submitted responses as part of the RSPB campaign answered ‘Yes’ at Question 2 – that is, they agreed that the key pressures to seabirds in Scotland were identified in the action plan.

4.6 A follow-up question asked respondents who answered ‘no’ to provide further details. Altogether, 35 respondents – 16 organisations and 19 individuals – provided comments at Question 2. Note that the RSPB campaign response did NOT include comments relevant to this question.

4.7 Although this question was aimed at those who answered ‘no’, more than half of those who commented had answered ‘yes’ or ‘unsure’ at the closed question. In a few cases, respondents who answered ‘yes’ used their comments to state their explicit agreement with the pressures identified in the action plan or vulnerability report and / or to endorse the presence of specific pressures such as those related to plastic pollution or avian flu. However, other respondents who answered ‘yes’ went on to qualify their answer in some way. These respondents often commented on similar issues to those who answered ‘no’ and ‘unsure’, and the views of all respondents – irrespective of how they answered the closed question – are included in the analysis presented below.

4.8 Respondents commented in two main ways at Queston 2: offering comments of a general nature or offering comments on the specific pressures included in the action plan. Both types of comment are covered below. It should be noted that, by and large, respondents who commented on the specific pressures, did not identify new pressures for inclusion in the action plan; rather, their comments discussed the emphasis on, or prioritisation awarded to, different pressures in the action plan, or the interpretation and presentation of different pressures.

General views on the identified pressures

4.9 Respondents – particularly those who answered ‘yes’ at the closed question – often offered comments of a general nature about the identified pressures. Some offered general endorsement of the pressures identified, while others made a range of points about the need to properly understand and account for the nature of the pressures in order to determine and prioritise actions and facilitate partnership working. The points made are summarised as follows:

• The pressures identified were interlinked and cumulative in nature, and this needed to be considered in the action plan – respondents particularly noted the links between climate change and the other pressures included in the action plan (e.g. reduction in food availability and habitat loss).
• The importance and impact of the pressures identified would vary over time and space and across seabird species.
• Further research and monitoring and analysis was required – this would build the evidence and help develop a common understanding of the nature and extent of the pressures on seabird populations.
• There was no ‘value system’ applied and no prioritisation in the presentation of the identified pressures in the action plan.

4.10 One respondent (an individual) thought that it was necessary to read the action plan and vulnerability report together to get a full picture of the identified pressures.

Views on specific identified pressures

4.11 Respondents who commented more specifically on the identified pressures most often focused on pressures related to three main issues: climate change, offshore wind, and fishing and / or fish-farming. The views expressed on these are summarised below. Two subsequent sections then present points made in relation to missing pressures and the description of pressures.

Climate change

4.12 Environmental organisations, in particular, endorsed the prominence given to climate change in the action plan. They highlighted the significance of the threat presented by climate change and stressed the importance of recognising its impact on the other main pressures identified in the action plan.

Offshore wind and other renewable energy technologies

4.13 Some respondents – mainly environmental organisations and some fishing organisations and individuals – thought that the threat presented by offshore wind (and other renewable energy technologies) was not given sufficient weight in the action plan. They highlighted threats in the form of habitat loss, disturbance, and collisions. These respondents recognised the role of offshore wind in mitigating climate change but stressed that this had to be developed in an environmentally sensitive way. One respondent noted that, while renewables were presented as a mitigation in the context of climate change, they were not properly accounted for as a pressure in their own right. Respondents thought the threats posed – by turbines, and the marine traffic related to their construction and maintenance – needed to be better understood, and that the action plan needed to more fairly set out the risks and how these might be mitigated.

Fishing and fish-farming

4.14 Environmental and nature organisations and some individuals highlighted the impact of two threats linked to fishing and fish-farming: (i) reduction in availability of prey as a result of bycatch, landing obligations, and overfishing; and (ii) pollution, including plastic pollution resulting from discarded fishing gear, and toxins resulting from fish-farms which put pressure on marine ecosystems and habitats. With regard to the former, some respondents endorsed the action already taken to regulate fishing activities and particularly welcomed the ban on sandeel fishing in Scottish waters introduced in 2024.

4.15 However, fishing organisations expressed the view that the threat presented by the fishing sector had been overstated or misrepresented in the vulnerability report and action plan. These respondents thought the assessment process had not taken full or appropriate account of all the factors and relevant evidence in assessing the impact of fishing on the availability of prey; they also pointed to knowledge gaps in this area and questioned the quality of the data on which the assessment was based. Respondents in this group thought that the action plan overemphasised the risks presented by fishing while underemphasising the risks presented by climate change, offshore wind, and pollution. One respondent noted their ongoing work with other stakeholders to investigate and mitigate fishing-related threats to seabirds.

Missing pressures

4.16 As noted above, respondents did not, for the most part, identify missing or additional threats or pressures that should be included in the action plan. Those that did highlighted the following, all of which were mentioned by one or two respondents only:

• Lack of knowledge of marine issues
• Adverse weather
• Native predators, including larger seabird species
• The increasing use of drones
• Development of land used as breeding grounds by seabirds
• Human persecution of gulls.

4.17 In addition, it was suggested that the lack of enforcement of Marine Protection Areas (MPAs) risked creating or increasing pressures by not mitigating identified threats or supporting ecosystem regeneration.

The description of pressures

4.18 One academic organisation offered a series of detailed suggestions about the description and presentation of some pressure included in the action plan. These included:

• Recognising the overlap between climate change and other pressures, and reformulating some pressures to focus more specifically on non-climate related aspects – for example, ‘fisheries reduction in food availability’, ‘habitat loss from fishing and other human activities’
• Changing the reference to ‘reduction in prey availability’ to ‘reduction in high quality prey availability’
• Downgrading the importance attached to litter by rephrasing as ‘oil, chemicals and litter’.

Other comments

4.19 Other comments made by respondents at Question 2 related to the overall approach and scope of the action plan; the actions (already taken or planned) set out in the plan; and other issues relevant to the effective implementation and monitoring of the plan. These are not covered in any detail here but are addressed in other relevant chapters of the report.