Publication - Impact assessment

Ythan Estuary, Sands of Forvie and Meikle Loch (extension) Special Protection Area: BRIA

Business and Regulatory Impact Assessment (BRIA) of classifying the Ythan Estuary, Sands of Forvie and Meikle Loch (extension) Special Protection Area.

22 page PDF

458.4 kB

22 page PDF

458.4 kB

Contents
Ythan Estuary, Sands of Forvie and Meikle Loch (extension) Special Protection Area: BRIA
Consultation

22 page PDF

458.4 kB

Consultation

Within Government

Consultation has been undertaken with policy colleagues within Marine Scotland, including aquaculture, nature conservation, marine renewables, fisheries and fresh water fisheries, and with Transport Scotland.

Historic Environment Scotland and the Scottish Environmental Protection Agency have also been consulted. Meetings were held with policy officials within these public bodies to discuss the development of these SPAs. We have also been working with Defra and other UK Departments on the join up between the Scottish MPA network, which includes SPAs, and the wider UK contribution to the OSPAR MPA network.

Public Consultation

A full public consultation took place in Autumn 2016. Further consultation took place in Autumn 2018 on at Network Assessment for the proposed set of sites and the SEA. An update to the SEA was consulted on in the summer of 2019.

Business

Routine updates are provided to the Marine Strategy Forum and are supplemented with

bilateral meetings across sectors including the fishing industry, environmental NGOs, tourism and recreation, nature conservation, renewable energy, aquaculture, ports and harbours, defence and local community groups.

A National Workshop attended by a wide range of stakeholders was held in March 2016 to present the proposals and gather feedback on the proposed consultation package.[3]

Options

Option 1: Do nothing

Option 1 is the 'Do nothing' option; this is the baseline scenario. Under this option, the proposed Ythan Estuary site is not classified. Accordingly, no additional management measures would be required.

Option 2: Classify site as a Special Protection Area

Option 2 involves the formal classification of the Ythan Estuary site. Classification would provide recognition and protection to the natural features of the site while also contributing to the wider Scottish and UK SPA network. Requisite management would be required to maintain the status of the site.

Sectors and groups affected

The following sectors have been identified as present (or possibly present in the future) within the Ythan Estuary site and potentially interact with one or more of the features:

  • Coastal defence and flood protection
  • Commercial fisheries (GVA)
  • Ports and harbours
  • Telecom cables
  • Public Sector

Affected sectors may be impacted to a greater or lesser degree by classification depending on which scenario is pursued and which management option is preferred.

Benefits

Option 1: Do nothing

No additional benefits are expected to arise from this policy option.

Option 2: Classify site as a Special Protection Area

The extent and quality of habitat and available food around Scotland's coast supports huge numbers of different species of seabirds. Few countries can match this and we have an international responsibility to protect what we have around Scotland. Therefore the appropriate action is to protect and maintain Scotland's seabird and water bird populations and meet the requirements of the EU Wild Birds Directive.

SPAs are created to meet international commitments under the EU Wild Birds Directive, which promotes the conservation of wild birds. SPAs are managed to safeguard the birds and avoid significant disturbance and deterioration of their habitats. This means that proposed activities likely to affect an SPA are assessed for their potential to cause such disturbance or deterioration. The relevant consenting authority must ensure beyond reasonable scientific doubt that any impact is not significant before permitting the activity.

While it may not be possible with current levels of research to monetise benefits with a satisfactory degree of rigour, it is clear that many of the benefits relate to aspects of our lives that we take for granted and for which it is good practice and common sense to maintain through protection measures such as SPAs.

Contribution to an Ecologically Coherent network

Scotland's seas support a huge diversity of marine life and habitats, with around 6,500 species of plants and animals, with plenty more no doubt to be found in the undiscovered deeps of the north and west of Scotland. Our seas account for 61% of UK waters and remain at the forefront of our food and energy needs, through fishing, aquaculture, oil and gas, and new industries such as renewables, as well as recreation activities and ecotourism. This SPA is a contribution to a wider network of Marine Protected Areas designed to conserve and regenerate our seas. This in turn will help ensure that ecosystem goods and services continue to support current and future generations. It is likely that an ecologically coherent network of marine protected areas is likely to provide greater benefit than the sum of its individual components.

Ecosystem Services Benefits

Ecosystems are very complex, and it is thought that the more complex an ecosystem is the more resilient it is to change. Therefore, if it is damaged or if a species or habitat is removed from that ecosystem, the chances of survival for those services reduce as the ecosystem becomes weaker. However, by conserving or allowing the species and habitats that make up that ecosystem to recover, we can be more confident of the continuation of the long term benefits the marine environment provides.

Non-Use Values

Non-use value of the natural environment is the benefit people get simply from being aware of a diverse and sustainable marine environment even if they do not themselves use it. We take for granted many of the things we read about or watch, such as bright colourful fish, reefs and strange shaped deep sea curiosities, to lose them would be a loss to future generations that will not be able to experience them. It is challenging to put a precise value on this, but the high quality experience derived from Scotland's seas can be better preserved through measures such as SPAs.

It is expected that non-use value will be attained as a result of classification and the support of wider conservation objectives. Whilst ecosystem services benefits at an individual site level cannot be readily calculated, the one-off non-use value to Scottish households of marine conservation in Scottish waters generated by the additional 14 SPAs is estimated to be in the region of £74 million.[4] This figure uses valuation evidence across several sites with similar features and characteristics and highlights the significant positive non-use value that divers and anglers within the Scottish marine environment place on securing the quality of the marine resources they use as a result of protection against degradation.

Use Values

There could be a major transformative effect on inshore habitat and a significantly enhanced flow of environmental goods and services. We know the inherent capacity of the system and the flora and fauna that it could support. Achieving that could see the expansion of recreational activities such as diving, sea-angling, and other tourism alongside sustainable methods of fishing.

Research by Kenter et al[5] has been used to estimate the use benefits to divers and anglers specifically, as a result of classifications safeguarding the total recreational value of the sites. The additional increase in recreational value as result of implementing management measures for the 14 new SPAs has an estimated total present value of £2.1-6.2 million over the 20 year assessment period.[6]

In addition there is likely to be increased activity for businesses in the marine wildlife and tourism sector. This includes those directly involved (e.g. operating boat trips) and those benefiting indirectly (e.g. accommodation providers). The scale of this increase across the sites cannot be quantified, but it can be expected to be some increment of the existing value of these activities. Given the marine wildlife tourism market is currently estimated to be worth £100's of millions per year, an increment of this could be expected to be worth in the region of £10 million per year across the network to the Scottish wildlife tourism market.[7]

Summary of Benefits

The uncertainties in each of the benefits assessed result in a large range of estimated values. Based on the available evidence, the combined total present value of the benefits for the new network (based on the additional benefits of the 14 new sites) is tentatively estimated to be between in the region of £80 million over the 20 year assessment period. This is comprised of a one-off non-use value attained at classification to Scottish households of marine conservation in Scottish waters generated by the additional 14 SPAs of £74 million and an additional use value as result of implementing management measures for the 14 new SPAs of £2.1-£6.2 million.

For a qualitative summary of anticipated benefits to ecosystem services in this particular site see appendix A.

Costs

Option 1: Do nothing

This option is not predicted to create any additional costs to the sectors and groups outlined above.

However failure to classify the "most suitable territories" as SPAs would leave the Scottish Government exposed to a high risk of EC infraction proceedings, which may result in substantial one off and recurring fines.

In addition it should be noted that the societal cost of not classifying could be both large and irreversible relative to the current condition of the marine environment. The absence of management measures to conserve the identified features may produce future economic and social costs in terms of increased marine habitat and biodiversity degradation. The option to not classify holds the potential to undermine the overall ecological coherence of the Scottish SPA Network. This potentially large and irreversible societal cost avoided is presented within the benefits section of the 'do classify' scenario (option 2) to avoid double counting the same impact.

Option 2: Classify site as a Special Protection Area

Costs have been evaluated based on the implementation of potential management measures. Where feasible costs have been quantified, where this has not been possible costs are stated qualitatively. All quantified costs have been discounted in line with HM Treasury guidance using a discount rate of 3.5%. Discounting reflects the fact that individuals prefer present consumption over future consumption.

Coastal defence and flood protection

There are two coast protection and flood defence structures (2 x artificial protection (dykes)) which overlap the Ythan Estuary SPA boundary or within the 10km buffer. Therefore, management costs may be incurred under the assumption structures will require maintenance or construction works once every 20 years (starting in 2024).

Seasonal controls will be applied to construction activity, where necessary, to minimise impacts to protected features. It has been assumed that these seasonal restrictions can be accommodated without imposing any additional cost on the construction programme.

Economic Costs on the Activity of Classification of the Site as a SPA
  Lower Estimate Intermediate Estimate Upper Estimate
Assumptions for cost impacts
  • Additional assessment to support planning application (maintenance or construction works).
  • Additional assessment to support planning application (maintenance or construction works).
  • Additional assessment to support planning application (maintenance or construction works).
Description of one-off costs
  • Additional assessment to support planning application (maintenance or construction works) - £5.2k per application. Applications estimated for two developments to be submitted in 2024.
  • Additional assessment to support planning application (maintenance or construction works) - £5.2k per application. Applications estimated for two developments to be submitted in 2024.
  • Additional assessment to support planning application (maintenance or construction works) - £5.2k per application. Applications estimated for two developments to be submitted in 2024.
Description of recurring costs
  • None.
  • None.
  • None.
Description of non-quantified costs
  • Seasonal controls applied to construction activity.
  • Seasonal controls applied to construction activity.
  • Seasonal controls applied to construction activity.
Quantified Costs on the Activity of Classification of the Site as an SPA (£million)
Total costs (2015–2034) 0.010 0.010 0.010
Average annual costs 0.001 0.001 0.001
Present value of total costs (2015–2034) 0.008 0.008 0.008

Commercial Fisheries:

According to ICES rectangle landings statistics, pots, lines, dredges, nephrops trawls, whitefish trawls, nephrops trawls and other gears (under-15m vessels) operate within the Ythan site's marine extension. There were no VMS data recorded within the proposed marine extension between 2009 and 2013. The value of catches from the site's area was £15,000 (under-15m vessels, indicated from ICES rectangle landings data) (annual average for 2009–2013, 2015 prices).

Management measures for the scenarios have been developed based on the sensitivity and vulnerability of the features to the pressures caused by different gear types and SNH recommendations.

Uprated ScotMap data (under-15m vessels) indicate that the annual average earnings from the Ythan site's marine extension was £34,000 for the period 2007-2011, with pots contributing the highest value. The coverage for ScotMap interviews in the region was 92% (total value of reported landings from the Fisheries Information Network for those vessels included in the ScotMap value analysis expressed as a percentage of the total reported landings for all vessels <15m; the spatial representation of the value of fishing is more robust in regions where coverage is higher. VMS data indicate that there are no foreign vessels fishing within the site's marine extension.

Economic Costs on the Activity of Classification of the Site as a SPA
  Lower Estimate Intermediate Estimate Upper Estimate
Assumptions for cost impacts
  • No change to existing
  • 10% reduction in pelagic gear effort across the site
  • 25% reduction in pelagic gear effort across the site
Description of one-off costs
  • None
  • None
  • None
Description of recurring costs
  • None
  • Loss of >15m fishing income (annual values, £ k):
  • None.
  • Loss of <15m fishing income (annual values, £ k):
  • All affected gears (fewer than 5 vessels; value not presented).
  • Loss of >15m fishing income (annual values, £ k):
  • None.
  • Loss of <15m fishing income (annual values, £ k):
  • All affected gears (fewer than 5 vessels; value not presented).
Description of non-quantified costs
  • None
  • Displacement impacts (additional fishing pressure on other areas, potential conflict with other vessels, additional steaming time/fuel costs, gear development and adaptation costs, and additional quota costs).
  • Displacement impacts (additional fishing pressure on other areas, potential conflict with other vessels, additional steaming time/fuel costs, gear development and adaptation costs, and additional quota costs).

Commercial fisheries costs are presented below in terms of Gross Value Added (GVA). GVA more accurately reflects the wider value of the sector to the local area and economy beyond the market value of the landed catch. Stating costs purely in terms of landed value would overstate the true economic cost of not fishing. If fishermen are prevented from catching fish they forgo the landed value of those fish but subsequently forgo the payment of intermediate costs such as fuel (it is assumed that no fishing activity is displaced). Costs are also presented in terms of the reduction in full-time equivalent (FTE) employment. It is also possible that effort not continuing in the area could be transferred to other locations resulting in no or reduced loss of income.

Quantified Costs on the Activity of Classification of the Site as a SPA (£Million)
Total change in GVA (2015–2034) 0.000 <0.001 <0.001
Average annual change to GVA 0.000 <0.001 <0.001
Present value of total change in GVA (2015–2034) 0.000 <0.001 <0.001
Direct and Indirect reduction in Employment 0.0 jobs 0.0 jobs 0.0 jobs

These estimates represent a worst-case scenario, based on the assumption of zero displacement of fishing activity. In reality, it is likely that some commercial fishing activity will be displaced to other grounds and hence it is likely that the impacts on employment are likely to be lower than those estimated. A Marine Scotland study on fisheries displacement in relation to the 2015 Nature Conservation MPA classifications[8] indicated that a significant proportion of fishing effort affected by the classifications was likely to relocate elsewhere. In reality, vessels are likely to react to any management measures in place in order to maintain profitability (i.e. by changing target species/gear type) but this could add to their costs (i.e. the extra fuel cost associated with fishing elsewhere). This uncertainty surrounding the change in behaviour is the reasoning behind not attempting to quantify this cost impact. Other non-quantified costs include: potential conflict with other fishing vessels, environmental consequences of targeting new areas, longer steaming times and increased fuel costs, changes in costs and earnings, gear development and adaptation costs, and additional quota costs.

Ports and Harbours

There is one major port/harbour (Aberdeen) located within the Ythan Estuary SPA boundary or within the 5km buffer. Therefore, management costs may be incurred under the assumption that major ports/harbours will undertake development every 5 years (starting in 2018) within the assessment period (2015-2034). In addition, there are four minor ports/harbours (Collieston, Newburgh, Port Erroll and Whinnyfold) located within the YES SPA boundary or within the 1km buffer; however, all four minor ports/harbours overlap with existing SPAs for which no costs impacts are anticipated in this assessment.

There are no open disposal sites located within the Ythan Estuary SPA boundary or within the 5/1km buffer.

Economic Costs on the Activity of Classification of the Site as an SPA
  Lower Estimate Intermediate Estimate Upper Estimate
Assumptions for cost impacts
  • Additional assessment of new port/harbour developments in or adjacent to SPA to support licence applications.
  • Additional assessment of new port/harbour developments in or adjacent to SPA to support licence applications.
  • Additional assessment of new port/harbour developments in or adjacent to SPA to support licence applications; and Additional monitoring of development project (major ports/harbours only).
Description of one-off costs
  • Additional assessment of new port/harbour developments – £7.1k per application. Assessment estimated for one major port (Aberdeen) to be submitted in 2018, 2023, 2028 and 2033.
  • Additional assessment of new port/harbour developments – £7.1k per application. Assessment estimated for one major port (Aberdeen) to be submitted in 2018, 2023, 2028 and 2033.
  • Additional assessment of new port/harbour developments – £7.1k per application. Assessment estimated for one major port (Aberdeen) to be submitted in 2018, 2023, 2028 and 2033; and Additional monitoring of major port development – £30k per development. Monitoring estimated for one major port (Aberdeen) to be conducted in 2019, 2024, 2029 and 2034.
Description of recurring costs
  • None.
  • None.
  • None.
Description of non-quantified costs
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
Quantified Costs on the Activity of Classification of the Site as an SPA (£Million)
Total costs (2015–2034) 0.028 0.028 0.148
Average annual costs 0.001 0.001 0.007
Present value of total costs (2015–2034) 0.020 0.020 0.102

It should be noted that additional cost impacts could also arise as a result of consenting delays. The cost impacts and uncertainty associated with SPA classification may impact on potential investment opportunities.

Telecom Cables

There is one telecom cable (Aberdeen to Ula) located within the Ythan Estuary boundary. Therefore, management measures associated with the replacement of telecom cables (additional assessment) during the assessment period could lead to cost impacts.

Economic Costs on the Activity of Classification of the Site as an SPA
  Lower Estimate Intermediate Estimate Upper Estimate
Assumptions for cost impacts
  • Additional assessment to inform marine licensing for telecom cable replacement.
  • Additional assessment to inform marine licensing for telecom cable replacement.
  • Additional assessment to inform marine licensing for telecom cable replacement.
Description of one-off costs
  • Additional assessment to inform marine licensing – £2.6k per licence application. Applications estimated for one telecom cable (Aberdeen to Ula) to be submitted in 2025.
  • Additional assessment to inform marine licensing – £2.6k per licence application. Applications estimated for one telecom cable (Aberdeen to Ula) to be submitted in 2025.
  • Additional assessment to inform marine licensing – £2.6k per licence application. Applications estimated for one telecom cable (Aberdeen to Ula) to be submitted in 2025.
Description of recurring costs
  • None.
  • None.
  • None.
Description of non-quantified costs
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
Quantified Costs on the Activity of Classification of the Site as an SPA (£Million)
Total costs (2014–2033) 0.003 0.003 0.003
Average annual costs <0.001 <0.001 <0.001
Present value of total costs (2014–2033) 0.002 0.002 0.002

It should be noted that additional cost impacts could also arise as a result of consenting delays. The cost impacts and uncertainty associated with SPA classification may impact on potential investment opportunities.

Public Sector:

The decision to classify the Ythan Estuary site as a SPA, would result in costs being incurred by the public sector in the following areas:

  • Preparation of Marine Management Schemes
  • Preparation of Statutory Instruments
  • Development of voluntary instruments
  • Site monitoring
  • Compliance and enforcement
  • Promotion of public understanding
  • Regulatory and advisory costs associated with licensing decisions

Some of these costs will accrue at the national level and as such have not been disaggregated to site level.

Site-specific Public Sector Costs (£Million, 2015-2034)
  Lower Estimate Intermediate Estimate Upper Estimate
Preparation of Marine Management Schemes 0.000 0.000 0.000
Preparation of Statutory Instruments 0.000 0.004 0.004
Development of voluntary measures 0.000 0.000 0.000
Site monitoring 0.000 0.000 0.000
Regulatory and advisory costs associated with licensing decisions 0.003 0.003 0.003
Total Quantified Public Sector Costs 0.003 0.007 0.007

Total Costs

Total quantified costs are presented in present value terms. Commercial fisheries costs are presented in terms of GVA.

Total Present Value of Quantified Costs (£Million, 2015-2034)
Sector Lower Estimate Intermediate Estimate Upper Estimate
Coast defence and flood protection 0.008 0.008 0.008
Ports and harbours 0.020 0.020 0.102
Telecom cables 0.002 0.002 0.002
Public Sector 0.003 0.007 0.007
Total Present Value of Costs 0.033 0.037 0.119
GVA Impacts (£million 2015-2034)
Commercial Fisheries 0.000 <0.001 <0.001
Total Non-Quantified Costs
Scenario Low Intermediate Upper
Sector/Group
Coast defence and flood protection
  • Seasonal controls applied to construction activity.
  • Seasonal controls applied to construction activity.
  • Seasonal controls applied to construction activity.
Commercial fisheries
  • None.
  • Displacement impacts.
  • Displacement impacts.
Ports and harbours
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
Telecom cables
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.
  • Costs of project delays during consenting; potential impact on investment opportunities.

Contact

Email: marine_conservation@gov.scot