Scottish seabird conservation action plan: consultation analysis

5 Key actions (Q3)

5.1 The action plan set out a series of priority actions grouped under six headings:

• Ensuring plentiful food supplies
• Restoring and improving seabird habitats
• Maximising resilience and survival
• Building the evidence
• Celebrating Scotland’s seabirds
• Making a global contribution.

5.2 The actions were intended to build on action already being taken and included new actions that could be pursued collaboratively with other stakeholders to address the various pressures identified.

5.3 Question 3 asked respondents if the action plan had captured the key actions needed to deliver the stated vision, aim and objectives.

Question 3: Have we captured the key actions needed to deliver the vision, aim and objectives and are there any missing? Please give us your views. [Yes / No / Unsure]

If no, please provide detail.

5.4 Table 5.1 shows that that there was a lack of consensus on this question. Overall, 44% of respondents (28 out of 63) said that the key actions needed to deliver the vision, aim and objectives were captured in the action plan, 33% (21 out of 63) said they were not, and 22% (14 out of 63) said they were unsure. Individuals were more likely than organisations to say that the key actions were captured: around half of individuals (24 out of 45) said ‘yes’, compared to 4 out 18 organisations. By contrast, most organisations (11 out of 18) said ‘no’ (i.e. the key actions were not captured). Note that all but one of the environment and nature organisations (8 out of 9) answered ‘no’. Note also, that there was no consensus among fishing sector organisations on this question, with one saying ‘yes’, two saying ‘no’, and one expressing uncertainty.

Percentages may not total 100% due to rounding.

5.5 The RSPB campaign response did not include a response to the closed part of Question 3. The campaign text did, however, identify additional key actions required in the action plan. These views are discussed in the qualitative analysis below.

5.6 Altogether, 79 respondents – 19 organisations and 60 individuals – made comments at Question 3. It is worth noting that more respondents provided comments than answered the closed question.

5.7 Comments made at Question 3 were often lengthy and detailed, particularly where the respondent answered ‘no’ to the closed question. The summary presented here cannot fully reflect the level of detail in these comments, but the main recurring points are reported.

5.8 Most often, respondents commented on the specific actions listed under each of the six headings set out in the action plan (see again paragraph 5.1). Some also made comments of a more general nature. These general views are summarised first in the sections below. Suggested additional actions that did not relate to any of the six headings are summarised at the end of this chapter.

5.9 It should be noted that, 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 plan was not specific or ambitious enough. Thus, there was not always a clear distinction in the qualitative views of those who answered the closed question in different ways.

General views

5.10 Respondents who answered ‘yes’ at Question 3 largely thought the key actions were adequately covered, and they welcomed the range of actions listed. Some in this group suggested the action plan should be updated regularly, given the rapid changes occurring in the natural environment, and as more evidence becomes available about the efficacy and deliverability of each action. At the same time, as noted above, some who answered ‘yes’ thought the actions listed in the plan should be more specific and ambitious.

5.11 Respondents who answered ‘unsure’ at Question 3 made two general points. First, they thought it would be helpful to prioritise the actions listed and set out a more detailed timetable for each one; respondents said this would be particularly helpful to the energy sector and enable this sector to support the most critical actions. Second, there was a concern, voiced by one individual, that the action plan should not become a ‘paper exercise’. This respondent wanted the Scottish Government to be ‘courageous’ in addressing the issues set out in the action plan.

5.12 Environment and nature organisations and many individual respondents who answered ‘no’ often did so because they wanted the action plan to demonstrate greater ambition and a stronger commitment to addressing the decline in seabird populations. This group often suggested specific changes to the wording of certain actions, stating that the language used in relation to some of the actions was ‘too vague’ and created uncertainty about whether they would be delivered or have any impact. Some highlighted actions they thought needed to be strengthened, or they suggested additional actions. Some in this group also wanted the action plan to state clearly who (which organisation(s)) would be responsible and accountable for the delivery of certain actions.

5.13 Among the (two) fishing sector organisations that answered ‘no’ at Question 3, there was a view that the action plan did not address the biggest threats to seabirds – which they saw as marine renewables development, the oil and gas industry, and climate change. These respondents argued that the plan focused too much on restricting and monitoring fishing.

Ensuring plentiful food supplies

5.14 There were several recurring themes in the comments relating to the actions listed under ‘ensuring plentiful food supplies’. These were expressed both by organisations and individuals. Respondents repeatedly called for:

• A stronger commitment to action: Respondents said they thought the actions in this section should be made more specific and ambitious. In particular, they wanted to see a clear commitment to restore and enhance fish habitats, rather than simply to ‘explore opportunities’ to do so.
• Expansion, monitoring and enforcement of designated Marine Protection Areas (MPAs): Respondents saw a well-managed MPA network as crucial in protecting seabird foraging areas. There were frequent calls for these areas to be enlarged, monitored and enforced. In addition, there was a recurring view that the action plan should include a clear commitment to ban all forms of bottom towed fishing and dredging (not just hydraulic dredging) within MPAs. There were also views (made by one or two respondents in each case) that there should be an increase in the numbers of No Take Zones (NTZ) within existing MPAs, and that action should be taken to protect seabird prey habitats located on the edge of MPAs (for example, sandbanks) and to manage the fishing of other forage fish (not only sandeel) that are important in seabird diets.
• Continued protection of sandeel: Respondents often endorsed the action already taken to close fishing for sandeel in Scottish waters. One respondent highlighted evidence showing positive impacts from the ban on commercial sandeel fishing on the east coast of England. Respondents often expressed concern about ongoing pressure from the European Union to reopen North Sea sandeel fisheries, and repeatedly called for the UK and Scottish Governments to resist this pressure. There were also questions about whether the current ban on sandeel fishing was being monitored and effectively enforced.

5.15 One respondent from the fishing sector suggested that action should be taken to monitor the impacts on forage fish of predators other than seabirds, given the potential negative impacts of competition from other predators on seabird consumption rates. This same respondent also thought there should be no action taken to prevent fishing for forage fish other than sandeel.

5.16 Another fishing sector organisation emphasised the importance of involving all stakeholders (including those working in the fishing sector) in actions aimed at restoring and enhancing fish habitats in order to avoid ‘scattered and unregulated’ approaches. There was also a suggestion that current methodologies used to identify essential fish habitats should be reviewed as these were seen to have limitations.

5.17 In addition, one respondent from the ‘other organisation types’ category cited research that found no long-term decline in sandeel stocks in Scottish waters. This respondent argued that the current ban on sandeel fisheries was, therefore, ‘questionable and disproportionate’.

5.18 Additional actions under the heading ‘ensuring plentiful food supplies’ were suggested by environment and nature organisations and some individuals. These included: (i) action to improve monitoring of forage fish species, and (ii) taking a leading role in international discussions, rather than merely ‘contributing’ to these discussions.

Restoring and improving seabird habitats

5.19 Regarding the actions listed under ‘restoring and improving seabird habitats’, there were several recurring themes in the views expressed by organisations and individuals. These are summarised below.

• Seabird predator eradication: Respondents welcomed the progress that has been made in recent years to develop biosecurity plans, put in place biosecurity measures, and eradicate invasive non-native species (INNS) on some islands. There were views that (i) any predator control measures should be based on solid evidence, and (ii) where such measures were needed, predators should be removed and re-homed, rather than exterminated.
• Restoration and creation of new habitats: Respondents also thought action was needed to enhance and / or create new seabird habitats. They suggested this could be done by, for example, providing nesting boxes or burrows where there is evidence that insufficient natural breeding areas are restricting productivity, or creating new soft-coast habitats for ground nesting birds. The creation of man-made nesting areas may allow anti-predator provisions to be put in place at the same time.
• ‘Biosecurity for Scotland’ programme: The proposed action to continue to support the work of the ‘Biosecurity for Scotland’ programme was seen to be inadequate (one respondent said ‘pointless’), given that this programme will finish in March 2026. Respondents wanted to see a commitment to identify the means of continuing this work beyond March 2026.
• Requirement for biosecurity plans: Respondents wanted this action to state a firm commitment to include standard conditions in statutory regulatory permissions requiring biosecurity plans for new developments / proposals on and around seabird islands where there is a risk of introducing seabird predators. Related to this, it was suggested that provisions in the Wildlife and Natural Environment (Scotland) Act 2022 could be better enforced to reduce accidental predator introductions and recover the costs of dealing with incursions. There was also a suggestion that action should not be limited to new developments and proposals but should extend to major works undertaken in relation to existing developments.

5.20 The action to establish a ‘Task and Finish Group’ received little comment from respondents. However, one organisation and one individual argued that there was no need for a ‘task group’ to develop a programme of work in relation to INNS eradication. Instead, the action should be to establish a permanent, dedicated and skilled unit of responders who would be able tackle biosecurity incursions quickly when they occur. It was suggested that this unit could be supported by groups of volunteers when needed.

5.21 Respondents from energy sector organisations made the following additional points in relation to the actions in this section:

• There should be an action to address human disturbance at breeding colonies. This is mentioned under the heading ‘celebrating Scotland’s seabirds’ as an area to ‘explore’ but, given the evidence that disturbance at colonies is a significant pressure on seabird habitats, there should also be a clear commitment in this section of the action plan to address this.
• Further work is required to identify shared goals between the actions identified in this plan and potential project-specific and strategic compensation measures relating to the offshore wind industry. These shared goals need to be clearly recognised within the action plan.

Maximising resilience and survival

5.22 The actions listed under ‘maximising resilience and survival’ attracted considerable comment. For the most part, these comments were aimed at strengthening actions relating to reducing seabird bycatch, improving monitoring and enforcement of protected seabird sites, and regulating offshore wind developments. Respondents who submitted their views through the RSPB campaign – and a range of other respondents – addressed each of these issues in their comments, as follows:

• Reducing seabird bycatch: To end seabird bycatch, there needs to be a clear commitment to roll out the use of Remote Electronic Monitoring (REM) with cameras on all fishing vessels, with longliners seen as a priority, alongside effective bycatch mitigation.
• Monitoring and enforcement of a protected seabird site network: In addition to capturing all the important sites for seabirds, a protected seabird site network must also be well managed and effectively monitored and enforced.
• Regulating offshore wind developments: There should be a clear commitment that offshore wind will only be progressed in a manner that helps deliver nature positive outcomes, and that this should include the development of robust policies requiring strategic compensation and biodiversity enhancement.

5.23 Additional comments made in relation to each of these three issues are summarised here.

Minimising seabird bycatch

5.24 In general, respondents who wanted to strengthen the action plan thought it was crucial to address the problem of seabird bycatch.

5.25 Several respondents questioned why creels would be excluded from actions taken to manage static gear fisheries. Some acknowledged that creel fishing has a lower impact on seabirds than other types of fishing, but nevertheless they thought that any action to reduce bycatch should include creels, as well as gillnets and longlines. In addition, they thought that action to reduce bycatch should not be limited to seabird MPAs but should also apply in all Marine Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and other types of Marine Protection Areas. Other respondents questioned why the action plan did not include action to address the hazards posed by set net and midwater trawl fisheries (identified in the vulnerability report accompanying the action plan).

5.26 Occasionally, respondents addressed the issue of bycatch / entanglement of seabirds in aquaculture infrastructure and suggested that there should be a commitment to increasing effort on this issue. Actions in this area could include conducting further research into the origin of seabirds caught in aquaculture infrastructure and seeking to ‘significantly reduce’ rather than simply ‘minimising’ incidents of bycatch.

5.27 In contrast to these views, some individuals working in the fishing sector said that they would oppose the introduction of a ban on gillnetting specifically, as this offers diversification opportunities to fishermen at certain times of year and has no serious impact on seabird numbers.

5.28 Fishing sector organisations thought the plan should:

• Place greater emphasis on working collaboratively with the sector to understand the extent and significance of seabird bycatch, to improve monitoring, and to develop mitigation strategies. It was suggested that top-down regulatory approaches and disproportionate approaches should be avoided.
• Include provision for outreach and extension support which would help promote the uptake of proven mitigation solutions and the sharing of good practice by the fishing sector.

Protected seabird site network

5.29 At noted above, respondents repeatedly called for the protected seabird site network to be well managed, effectively monitored and enforced. This should include tailored fisheries management measures at all sites. There were suggestions that the plan should include actions to support carbon sequestration in protected areas, and that future review of the action plan should take account of the forthcoming Blue Carbon Action Plan.

5.30 It was also suggested that there is a need to identify any gaps in the current protected seabird site network. There was a call for an up-to-date SPA sufficiency review to be undertaken that goes beyond the 2018 Scottish Marine SPA network assessment, and for this work to incorporate findings related to the recent highly pathogenic avian influenza (HPAI) outbreaks and from the Seabirds Count Census.

Offshore wind developments

5.31 Respondents who wanted to strengthen the action plan thought offshore wind developments – while important for combatting climate change – should only be permitted where there will be minimal impact on key seabird feeding areas, and where those developments will help deliver nature positive outcomes. Some respondents noted that the current reform of the offshore marine energy compensatory process presented an opportunity to develop a strategic compensation framework that would channel significant funding into seabird conservation projects.

5.32 Respondents generally also welcomed the action to adopt strategic site selection for future marine renewable leasing rounds. However, it was noted that current sites, sites under construction or consented, and those currently being progressed would be unaffected by this action. It was suggested that the Scottish Government should ensure that the most damaging existing proposals are not consented. There was also a separate suggestion that the development of marine renewables should focus less on wind turbines and more on tidal technologies which were thought to have less impact on seabird populations.

5.33 Respondents from the energy sector argued that the delivery of offshore wind projects, including any marine recovery fund, and any monitoring or enhancement initiatives delivered by projects, should be considered as supporting the actions in the action plan. Some in this sector wished to see clarification about whether the actions in the action plan (i) would be implemented as project-specific or strategic compensation and (ii) would be seen as additional to any site management actions.

Other comments

5.34 Another recurring theme in the comments on this section of the action plan related to the issue of marine litter. Respondents generally welcomed an action addressing marine litter but wanted to see further detail about action that would be taken to address specific kinds of marine litter. Several respondents commented on entanglement in discarded and lost fishing gear as a cause of seabird mortality. This group wanted to see measures to support and encourage better fishing gear management and appropriate disposal through, for example, providing incentives and making it easier for fishers to dispose of gear at the end of its life. It was also suggested that implementation of the Scottish Government’s previously proposed deposit return scheme would help reduce the amount of plastic litter entering Scotland’s seas. There was also a call for lobbying – at UK level and internationally – to address the problem of plastic waste by, for example, banning the use non-compostable materials in packaging.

5.35 In contrast to these views, there were also occasional comments to suggest that there was a lack of evidence on the impacts of plastic pollution on seabird populations. Those who raised this point suggested that, instead, a greater focus was needed on addressing the effects on seabirds of oil pollution and chemical contaminants – oil pollution from the chronic and widespread release of fuel oil, as highlighted in the vulnerability report, was particularly mentioned.

5.36 Occasionally, respondents made other suggestions in relation to action required to maximise seabird resilience and survival. Some suggestions involved strengthening the actions listed, while others involved new actions. Comments from respondents included the following:

• The use of evidence-based solutions to reduce seabird collisions with offshore wind turbines had been overlooked in the action plan. For example, the use of coloured blades for offshore wind farms has been shown to reduce collisions in Norway.
• Any catalogue of marine enhancement measures should be updated periodically as new measures or evidence becomes available.
• Marine Protection Areas should be expanded to cover the northernmost ranges of key conservation species and their prey.
• All dredging / bottom trawling should be banned.

Building the evidence

5.37 Environment and nature organisations welcomed the action plan’s focus on improving knowledge and addressing current evidence gaps. Many said their organisations stood ready to assist with these actions. This group often made very specific suggestions about areas where further research is needed. At the same time, they also highlighted the logistical challenges of monitoring seabird populations. A recurring view was that there is a crucial need for additional funding to build and develop the evidence base.

5.38 Respondents from the energy sector said that their industry was in a good position to help in building the evidence and noted their willingness to assist in this way. There was a suggestion – put forward by other respondents as well as those in the energy sector – that some of the data currently collected through post-consent monitoring of offshore windfarm developments was not being used to its maximum potential, nor was it being appropriately considered within the consenting process. It was suggested that the results of post-consent monitoring should be fed back to government and shared with all interested parties.

5.39 The action to explore the use of remote electronic monitoring (REM) attracted comments from multiple respondents. Respondents saw the use of REM, particularly on longline vessels, as vital for demonstrating the outcomes of mitigation measures.

5.40 A range of other points were made – in most cases by just one or two respondents:

• There was support for the proposal to establish a UK Seabird Scientific Advisory Board. Respondents saw this group as having a key role in identifying high impact research priorities, while also coordinating and harmonising research efforts across the UK.
• There should be improved access to and standardisation of available marine datasets. A database on the management and monitoring of MPAs in an accessible format would be particularly beneficial.
• The action plan should seek to increase the frequency of the national seabird census. It was suggested that more frequent censuses would result in a larger pool of people with the skills to do the work who are also familiar with the sites. The large intervals between censuses means that this expertise is currently being lost.
• The action to train more volunteers for seabird monitoring programmes was welcome but there is also a need to train professional staff in this work.
• The action plan should recognise the important contribution made by volunteers and citizen science projects. An action on the use of citizen science projects for collecting evidence should be explicitly included. Additional funding for citizen science projects would support their continued success.
• Actions to build the evidence should be more closely aligned with the full range of pressures on seabirds. These include not only wind farms and bycatch, but also climate change, disease and INNS.
• The proposed action to identify options, methodologies and recommendations for seabird re-establishment and reintroductions across Scotland should not be a priority, given that so many existing seabird colonies are in unfavourable condition.
• One respondent from the fishing sector suggested that funding should be made available to support innovation in developing mitigation options to minimise bird mortality and enable concepts to be commercialised.

Celebrating Scotland’s seabirds

5.41 There were a relatively small number of disparate comments made in relation to the actions on celebrating Scotland’s seabirds. Many of these focused on raising awareness and educating members of the public about the importance of avoiding disturbance of seabird colonies during breeding / nesting seasons. Various respondents said they supported actions to ban dogs at seabird colonies; to restrict the use of drones / remote photography equipment; to develop best practice codes for reducing light pollution around windfarms; to establish a seabird colony site managers network; and to provide advice / guidance to visitors and others about behaviour near seabirds. There was also endorsement of the importance of involving communities in looking after their local birds.

5.42 One respondent suggested that the action plan should explicitly state that its aim is to avoid significant disturbance to seabird colonies, rather than implying that all disturbance should be avoided. This respondent provided a definition (based on previous research) of what would constitute significant disturbance: an action that impacts on populations through (i) changed local distribution on a continuing basis, (ii) changed local abundance on a sustained basis, and / or (iii) a reduction in the ability of any group of birds to survive, breed or rear their young.

5.43 Some respondents specifically welcomed the action to improve perceptions of urban gulls but said that there was also a need for better waste collection and management systems in urban areas.

5.44 In relation to improving public and business attitudes and behaviours around marine and coastal litter, respondents suggested a need for better monitoring of fishing boats, awareness raising among fishermen about proper rubbish disposal, and action to ensure that all harbours in Scotland have facilities / procedures for rubbish disposal.

5.45 Finally, there was a suggestion that actions involving ‘working together’ should specify which organisations will be involved.

Making a global contribution

5.46 There was limited comment on this section of the action plan. Environment and nature organisations welcomed the focus on international collaboration. They argued that, as home to some of the largest populations of nesting seabirds in the world, Scotland should not simply ‘contribute’ to international discussions but should ‘play a leading role’ in all international forums that concern seabirds – including in relation to fisheries, marine protection, climate and nature conservation.

Other suggestions

5.47 Respondents made a small number of additional points, not necessarily related to any of the six main headings in the action plan.

• Some of the specific actions recommended in the NatureScot Research Report 1370 (on potential actions to support recovery of seabird populations in Scotland) should be included in the action plan.
• The action plan should be ‘future-proofed’ and include an action for how to deal with critical incidents and their long-term impacts on seabird food sources, migration routes and habitats – for example, in relation to disease, sewerage, industrial and plastic pollution, storm damage / flooding.

Funding

5.48 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. This type of exercise would also help identify appropriate funding streams for each action. It was noted that without a commitment to adequate funding, the action plan risks becoming nothing more than a wish list.

5.49 Some respondents cautioned against becoming too heavily reliant on funding received through strategic compensation from offshore wind developments. There was a concern that this funding stream may not be sufficient to address the challenges, as it is likely to be tightly regulated in terms of the activities it can fund. It was also noted that it would take time for this funding to come through, and that it may come through in waves as offshore developments progress – rather than being a steady source of funding. Respondents emphasised the need for actions to be delivered urgently, and therefore reliable funding is needed, without delay.