4 Key issues
This section provides an overview of the comments made by respondents to the consultation.
4.1 General views
4.1.1 The majority of respondents across the range of sectors agreed, or agreed in principle, with the proposed policies. Many asked for clarification of the wording used in most of the policies and, in particular, definitions of the terms used. Many also requested additional wording, to clarify the intention of the policy and/or provide what they considered to be the necessary level of detail.
4.1.2 The majority of respondents supported seaweed cultivation, but added provisos about appropriate siting and control of activities. Those opposed were primarily concerned about environmental and economic effects. Several felt that the policies should apply to all scales of seaweed cultivation or, indeed, to all forms of aquaculture.
4.2 Key issues
Further consultation with stakeholders
4.2.1 Some respondents felt that there had been little consultation outside the aquaculture sector during the development of the draft SPS. They felt that additional consultation with sectors such as the fishing sector, yachting organisations and the tourism sector should be undertaken. They also considered that consultation should be undertaken with environmental and wider community stakeholders, not just with "traditional interests".
Other marine users
4.2.2 The majority of respondents agreed that other marine users and activities should be considered in the siting of seaweed farms. Respondents from a range of sectors felt that, in addition to aquaculture and shipping, the consideration of "other users" in the policies should include fishing, recreation and tourism.
4.2.3 Some sectors raised concerns that increased growth in the seaweed cultivation sector could impact on existing marine activities, particularly fishing, recreation and navigation. Concerns were raised about the potential effects of seaweed cultivation, in particular, on the ability of the fishing industry to continue to gain access to and navigate fishing grounds, particularly in Orkney.
Proposed size scales for cultivation
4.2.4 Answers regarding the size scales used were evenly split: half thought that they were appropriate and half did not. Many questioned how the size scales outlined in the Consultation Document had been determined and asked what this could mean in the future when different types of cultivation technology are likely to be used. Other respondents expressed concerns over issues such as how cumulative impacts would be assessed and managed.
4.2.5 Many respondents raised concerns about the size scale categories and the degree of significant environmental effect that has been attributed to each (particularly shellfish scale). Many felt that the size limits quoted were inappropriate and not reflective of current shellfish practices. Some suggested alternative criteria based on their experience of aquaculture developments. Several suggested that scale be defined by area and/or biomass production rather than number and length of lines, which would facilitate future changes in equipment.
4.2.6 Several respondents considered that shellfish (small) scale has more potential for significant environmental effects than was identified in the Consultation Document. The majority of respondents were supportive of medium-scale development, subject to regulatory consideration, a key proviso. Concerns were raised regarding extensive or large-scale cultivation, particularly relating to possible negative effects on the environment and other marine users ( e.g. the recreation and fishing sectors; navigational safety).
4.2.7 Most respondents supported the policy of siting seaweed farms away from sources of pollution, including sewage outfalls, although clarification of terms was requested.
4.2.8 The majority of respondents agreed that seaweed farming equipment should be fit for purpose to prevent damage from adverse weather conditions.
4.2.9 Respondents called for additional research to underpin the policies, fill information gaps and reduce uncertainties, both for developers and decision-making bodies. This need was identified, in particular, to support the development of guidance and/or Code of Practice for wild harvesting.
4.2.10 Research was also considered important in the consideration of "local provenance" in seaweed cultivation and the potential effects of cultivation on the marine environment ( e.g. wild seaweed stocks, etc).
Guidance and regulation
4.2.11 The majority of respondents supported proposed guidance, such as a Code of Practice, on wild harvesting activities. Many felt that this sector will expand in the future and that control is essential to avoid overexploitation of wild seaweed stocks. Several respondents noted that there was current and existing work that can be used to underpin the development of guidance, and provided examples. Some respondents suggested that guidance would also be beneficial for seaweed cultivation, e.g. when considering the impact of cultivation on other marine users.
4.2.12 Several respondents felt that guidance, or the introduction of a Code of Practice, would not be sufficient, and that the Scottish Government should introduce regulation of seaweed harvesting instead of, or as well as, guidance. There was little consensus regarding the form that regulation should take: planning consent, marine licensing and use of General Binding Rules were all suggested.
Provenance/ cultivated species
4.2.13 The majority of respondents supported the inclusion of policy on the use of native species and local provenance, and many saw this as being essential to minimising the risk of introducing invasive non-native species. However, some sought clarification on what would be considered "local" or "native", and suggested guidance on how this could be implemented in practice.
4.2.14 Some felt that this policy could be commercially restrictive and suggested flexibility, particularly in light of the way climate change can affect distribution of species. The use of "native" and "nearby" stock was suggested by some, provided there were no adverse effects on local stock or the environment.
4.2.15 Some referred to existing legislation and Codes of Practice on non-native species, with respondents both in support of and against the policy noting a need for evidence and further research to be undertaken in this area. It was suggested that the possible ecological and environmental impacts of farming new species should be "at the heart" of the consenting process.
4.2.16 Amendment of the 1997 Act was supported by most of the respondents across a range of sectors, although views varied on whether species should be named. Some suggested species for inclusion, while others felt that this should remain open to provide flexibility as the industry grows and that defining species in legislation could be unnecessarily restrictive.
4.2.17 More than half of the respondents considered that seaweed cultivation should be consented through town and country planning, in line with other forms of aquaculture. There was less support for marine licensing, or combinations of the two. Several felt that none of the options were appropriate.
4.2.18 There were suggestions that small-scale, inshore developments be consented through planning, and larger (medium and extensive), offshore and deep water development consented through marine licensing.
4.2.19 There was general support for consistency and improved clarity in the regulatory regime, and for the recognition of seaweed cultivation as a form of aquaculture.
4.2.20 Respondents identified a need for expertise in considering environmental issues in the consenting process, particularly from those with knowledge of environmental issues in coastal and marine environments ( i.e. Marine Scotland, Local Authorities). There was disagreement about whether planning authorities or Marine Scotland would be best placed to provide the necessary expertise to support decision-making.
4.2.21 The importance of links between terrestrial and marine planning, co-ordination between Local Authorities and Marine Scotland, the role of Marine Scotland in the consenting process, and a request for a wider consultation on consenting options were also discussed. The context of the SPS was also noted by several respondents, specifically the importance of links between the SPS and the emerging National and Regional Marine Plans, as well as the National Planning Framework and the revised Scottish Planning Policy.
4.2.22 Several respondents suggested that seaweed cultivation, at some or all size scales, should be subject to environmental impact assessment ( EIA) as part of the consenting process.
4.2.23 Several respondents noted that, should consenting be through planning, a marine licence would still be required. A few noted that responsibilities could be transferred to Regional Marine Planning Partnerships when they are established.
4.2.24 There was general support for IMTA; those who opposed the policies did not agree with the IMTA concept. Respondents did, however, raise several concerns, most of which focused on the environmental and economic implications of this type of development.
4.2.25 Several respondents questioned the need for policy 9. There were also queries about whether the basis of the policy was still justified, and calls for amendment of the original policy, e.g. species of finfish; geographic application.
4.2.26 Several respondents considered that the BRIA's assessment of potential costs and benefits should have included equal emphasis on seaweed cultivation and harvesting in the wild. Some noted that the cost of the consenting process for wild seaweed harvesting in the future should have been reflected in the BRIA.
4.2.27 Several respondents felt additional consultation and cost analysis assessment was required, particularly in relation to the potential for socio-economic impacts on other marine users ( e.g. fishing, tourism, etc.).
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