July 2005
ISBN 0 7559 2633 1(Web only publication)
This document is also available in pdf format (196k)
Contents
Section 1: Introduction
Section 2: Summary of responses to consultation
Section 1: Introduction
This is a summary report on the consultation carried out by the Scottish Executive on behalf of the Scottish Coastal Forum for their publication of "A Strategy for Scotland's Coast and Inshore Waters". The strategy is part of the on-going debate on marine and maritime policy, and has particular regard for the development of Integrated Coastal Zone Management ( ICZM).
The consultation period ran from 29 September to 17 December 2004 and a copy of the consultation and strategy were placed on the Scottish Executive's website. The Executive consulted a wide range of organisations (553 in total) and a total of 53 responses were received. A range of topics have been considered including ICZM, leadership, the role of the Scottish Coastal Forum, local partnerships, local government, statutory plans, funding, stakeholder engagement, marine spatial planning, monitoring and research, marine protected areas and sectoral management.
Consultations are designed to invite opinion from not only organisations and individuals with an interest in the area of consultation, but also a wider public audience. The consultation paper was therefore distributed directly to a wide range of potential respondents. The responses have now been passed to the Scottish Coastal Forum who will now undertake further analysis and take them into consideration as they aim to refine the strategy, and continue to provide advice on good practice within Integrated Coastal Zone Management.
It is standard Scottish Executive practice for responses to consultations to be summarised and for summaries to be made publicly available. Individual responses are also made available in the Scottish Executive's library, unless a respondent has specifically sought confidentiality.
A copy of this Summary Report will be available on the Scottish Coastal forums website, www.scotland.gov.uk/environment/coastalforum .. from July 2005. Copies of all the responses are available to view at the Scottish Executive's library at K Spur, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD.
Water Division
Scottish Executive Environment and Rural Affairs Department
July 2005
Section 2: Summary of responses to consultation53 responses were received from a variety of organisations. Most responses welcomed the strategy as a useful contribution to the on-going debate about marine and maritime policy.
Co-ordination of legislation
Several responses stated that better co-ordination between government consultations and initiatives and a more joined-up approach is required. These included Scottish Fishermen's Federation, Shetland Islands Council, The Crown Estate, Scottish Natural Heritage ( SNH), Marine Conservation Society, and Moray Firth Partnership. The National Trust for Scotland criticised the strategy as a missed opportunity to outline clearly what guidance and legislation exists in coastal areas now and in the future.
West Lothian Council said a national strategic framework must be created. Highlands and Islands Enterprise said a top-down approach to simplify the existing legislation would be invaluable. Aberdeenshire Council think that the issue of complex legislation and regulations needs addressed. RSPB Scotland, Scottish Environment LINK, Marine Conservation Society suggested a SMART (Specific, Measurable, Achievable, Realistic, and Time-bound) approach. RSPB Scotland and Scottish Environment LINK want a lead body and Marine Act. Hebridean Marine National Park Partnership also said it is time for a marine Act and streamlined and user-friendly legislation with a lead marine body. Scottish Natural Heritage suggested an overall Maritime Strategy, East Lothian Council welcomed a National Planning Framework and Marine Conservation Society advocate new framework legislation and a lead body.
Highlands and Islands Enterprise are concerned that the scale of the problem and the nature of the stakeholders is such that a monolithic structure will not work, and that efforts to achieve it may actually distract legislators and the agencies responsible for delivery from achievable ends. Ayrshire Joint Structure Plan and Transportation Committee says that without a coherent strategic planning, regulatory and management system in place it is extremely difficult to prioritise or co-ordinate the needs of different sectors and make decisions to guide long term investment in these areas.
Integration
Fife Council said there is a fundamental need for a more integrated and strategic approach to the management of coastal resources. East Lothian Council welcome integrated strategy. Scottish Natural Heritage said the key EC recommendation objective of identifying mechanisms for co-ordination and control of those acting in the coastal zone needs addressed, taking into account the character of different parts of the coast.
Integration of the various sectors in the coastal zone was seen as important by several respondees. Argyll and Bute Council said there is a need for the Scottish Executive to provide the necessary support to ensure synergy between interests. Fife Council said the current sectoral approach and its compartmentalised regulatory regime are detrimental to the principles of sustainable development and that horizontal integration is supported. They also support the principle of vertical integration. Forth Estuary Forum endorsed the objectives 4.1.4 To integrate the coastal management between the local, regional and national level, and 4.1.5 To integrate the many sectoral strategies and objectives relating to the coastal zone. Highland and Islands Enterprise said that rationalisation and coordination of individual sectors and areas, both internally and with each other, will incrementally produce a stronger structure. West Lothian Council said a tiered hierarchy (para 3.3) of policy and delivery has to apply. Ayrshire Joint Structure Plan and Transportation Committee says there is support for a hierarchy of marine planning from national to a local level. This would not add new planning tiers but enable the different aspects of marine planning to be addressed at an appropriate level.
Integrated Coastal Zone Management ( ICZM)
Several comments were made about ICZM in general.
The National Trust for Scotland said ICZM should be taken seriously in Scotland, not just because the EU has recommended that member states should address this issue, but because of a genuine recognition of the value of Scotland's coastal zone including its beauty, its importance for biodiversity, and its economic value. Scottish Water said it is imperative that government commitment to ICZM is forthcoming, and Highland Council recognises the importance of practical development of ICZM.
Forth Estuary Forum agreed with objective 4.5.4 to improve the understanding of Integrated Coastal Zone Management, its principles, goals and objectives to a wide audience throughout Scotland. The Highland Council believe that raising public awareness and understanding of the value of Scotland's coast and inshore waters is key to safeguarding this resource. They agree with the proposals to generate a better understanding of the socio-economic value of the coast, for example, by delivering promotional material and maximising the sustainable use of the coasts. However, they would suggest that this is more of a short-term priority rather than a medium one as stated in the report. Hebridean Marine National Park Partnership think the importance of the marine environment and its relationship within earth systems could be incorporated within the schools curriculum.
CBI Scotland said care must be taken to ensure that the ICZM strategy does not conflict with other public policy objectives, in particular growing the economy. The strategy document notes the dual objectives of establishing sustainable levels of economic activity while protecting the coastal environment, and they are concerned that the latter will be afforded greater priority at the expense of legitimate economic and employment considerations.
FRS Marine Laboratory said that regional coastal plans should be flexible should new information become available, for example environmental information. Suitable indicators and targeted monitoring should be in their remit, and ICZM plans should be assessed against achieving their objectives. Shetland Islands Council said inherent in the development and implementation of any strategy is the requirement to identify clear goals and targets that are achievable within realistic timescales. There will be a need to monitor progress both in delivery of proposed actions and whether the aims and objectives are being achieved. SEPA also considers that there is a need to monitor progress of ICZM and agrees with the SCF proposals to relate ICZM to indicators. Development of indicators should link to and complement those that may be developed to measure progress of River Basin Management Planning, achievement of WFD objectives and other relevant indicators. Natural Environment Research Council say the intention to monitor the outcomes of all the aims and objectives on an ongoing basis is particularly welcome. Argyll and Bute Council think the proposal that actions will be monitored to determine progress will have resource implications for Councils. Forth Estuary Forum thought there should be clear reporting on the achievement of ICZM in Scotland. Ayrshire Joint Structure Plan and Transportation Committee welcomes the reference to Strategic Environmental Assessment in section 2.9 but feels, given its relevance across sectors, that this process should be referred to throughout the Strategy as it would be required when developing an ICZM plan.
Solway Firth Partnership acknowledge that the strategy sets out a general time frame for implementation for each of the recommended actions to deliver the identified objectives, and think that this perhaps needs to more specific, with an indication of the resources need for implementation. Argyll and Bute Council think it is unclear from the actions proposed as to what is meant by short, medium and long term timescales. This is an important point as this may well have an impact on existing resources, both financial and staff. Shetland Islands Council think there is a need to attach dates to the indicative timescales.
The Crown Estate consider that greater emphasis should be placed on ICZM to enable local issues and community needs to feed into central government. Local input will make the maximum use of local knowledge and expertise and deliver some of the key ICZM policy drivers, specifically highlighting the environmental, social and economic benefits of better management of the coast. Kate Johnson thinks the implementation sections of the strategy are disappointingly general in nature with no strategy for building the capacity of the small vulnerable communities that categorise Scotland's coast to participate in the process to assist their social and economic needs. Highlands and Islands Enterprise say of specific concern is the inadequate recognition of the role for the business sector and for communities in which they are based. Whilst the consultation document acknowledges the links between marine and coastal environments and coastal communities, there is some concern that decisions about the former might be taken without the adequate involvement of the latter. In these circumstances, there is a perceived threat that national priorities will take precedence in constructing a strategic framework in which those most closely associated with the marine and coastal environment will have no greater say than others for whom it is only a peripheral concern.
Argyll and Bute Council has recently launched the Loch Fyne and Loch Etive ICZM Project. This project was reliant upon funding being secured from partner organisations and Europe in order to allow a project officer to be employed to implement the project. The project is seen as the first step in securing a more co-ordinated approach to ensure that this important economic resource is managed in a sustainable manner.
Scottish Environment LINK recognise the strategy states at 1.2 that 'planning and management systems need to address the significant inter-relationships between the use of the sea and use of the land and rivers adjacent'. However, they believe there is insufficient analysis of terrestrial issues. Reference is made to activities on land, for example coastal erosion and defence, but a more holistic view of the coastal zone should become a cross cutting theme emphasising the unique character of the areas where land meets sea. These ecosystems must be fully considered rather than simply focussing on human activities on or near to the shore. The National Trust for Scotland also think there is inadequate coverage of terrestrial issues. Reference is made to activities on land, but this is mostly about tourism, coastal erosion, the cultural heritage and coastal defence. More emphasis is needed on farming and forestry, as these are the most widespread land use types in the coastal zone. Highlands and Islands Enterprise also think several sectors illustrate an imbalance between the marine environment and the terrestrial coastal zone with too much emphasis on the sea. They found no reference to coastal quarries; on significant coastal developments that are predicated on good access to the sea (of specific concern for the Cromarty Firth); or the issue of transmission cables on land that have direct links to coastal and marine energy developments.
Scottish Water also believes that there is a tendency within the strategy to focus on the marine environment, and feels that it would be appropriate to pay equal attention to onshore maritime issues such as local planning and development matters, particularly as the intention is to support a diversified economy around Scotland's coasts. Attempts to diversify will have to consider the long term sustainable management of onshore developments, in order that infrastructure investment is not targeted at unsustainable activities. Scottish Water also say that sustainable development is mentioned only briefly in the strategy, and as a public sector body with a duty to give due regard to the principles of sustainable development, Scottish Water feels that it should feature more prominently in each area of the strategy.
Leadership
Fife Council agree with the strategy that ICZM requires strong political support and leadership at all levels of government, and that this can be achieved through the provision of additional resources, policy direction and authority. West Lothian Council stated that the role of national leadership must not be underestimated, be it, for example, for biodiversity, water quality or sea level rise. The Scottish Executive must oversee, lead and champion the delivery of ICZM across Scotland and provide the policy and funding support necessary (paras 4.3). Shetland Islands Council say the Scottish Executive should take the lead at a national level and develop national policies and priorities but ensure that they are applicable at the local level. Highland Council believes that it is essential for the Executive to take a stronger, more pro-active lead in implementing ICZM, with leadership also by government at regional and local levels working with and through key statutory bodies such as the Crown Estate, Scottish Environment Protection Agency ( SEPA) and SNH. Moray Firth Partnership also agree that it is important that all of the key agencies and local authorities be given a clear steer by the Scottish Executive, to incorporate ICZM into their own plans and activities, and to work in co-operation with others to achieve the mutual goals of ICZM, at local as well as national levels. Local coastal partnerships could provide leadership at the local / regional scale.
Scottish Coastal Forum
Aberdeenshire Council supports the proposal that the Scottish Coastal Forum is retained as the Strategic link for ICZM in Scotland. West Lothian Council said the role of the Scottish Coastal Forum needs to be reviewed, both in its national remit and in its relationship with bodies such as Scottish Natural Heritage, SEPA and Scottish Water, to genuinely provide a strategic coordinating role that is not duplicating the roles of other agencies. Highland and Islands Enterprise raised several questions about the Forum's future role, about it's structure and remit, how it would be constituted and resourced, what powers it may have, and how it would engage with the Scottish Executive. The Crown Estate also considered the SCF's future role, asking will it focus on steering the local Coastal Fora, will it assist in developing the objectives of the Water Framework Directive, or will it commission more research into ICZM matter in Scotland?
Scottish Natural Heritage thought that the SCF should have an important coordinating role, but that its future role is unclear bearing in mind recommendations in the Biodiversity Strategy Marine Implementation Plan, and elsewhere, for new coastal bodies. Without a clear steer to SCF from Ministers and the Executive that it should continue to act in an advisory capacity to government, the Forum risks losing involvement and interest of key groups. It would be helpful if the Executive could take the opportunity in its ICZM strategy to clarify and reinforce the role of SCF as an influential national maritime stakeholder body.
Forth Estuary Forum said local coastal partnerships are in discussion with the SCF in order to clarify their relationship as the basis for the delivery of many important objectives of the above Strategy. Of particular interest to the local coastal partnerships is a paragraph on Page 32 of the Strategy that states 'The partnerships need to be more effective in influencing plans, policies and behaviour of stakeholders. SCF should be re-tasked to go beyond its present co-ordination and clearing house role to be the contact point and lead organisation for national scale influencing'. Forth Estuary Forum agree with this statement.
SEPA said the Forum's strategy should be compatible with, and complementary to, the River Basin Management Planning ( RBMP) framework, and that the SCF should be represented on advisory groups.
Local Partnerships
Moray Firth Partnership ( MFP) state that whilst they are pleased that the strategy recognises coastal partnerships as an existing and useful mechanism, the MFP is disappointed by the lack of clarity and focus within the SCF Strategy as to the role of the coastal partnerships in implementing the strategy. They believe their potential role to be significant. The partnerships are an established mechanism operating across a significant part of the Scottish coastline in terms of ICZM issues. They have over 10 years experience in developing and implementing ICZM through a strategic approach, and have the potential to play a critical role in the future implementation of ICZM at a regional scale. However, to be truly successful and sustainable, this will require greater recognition and stability than has previously been possible. The explicit recognition, by the Scottish Executive, of the role of coastal partnerships as the appropriate mechanism for ICZM will be essential to this.
There is currently no other statutory or non-statutory mechanism operating at a local or regional scale, which provides an appropriate framework for integrating coastal management. The partnerships are based on a voluntary principle, which requires to be evaluated in terms of future needs. They are neutral and inclusive, with the ability to focus the relevant key interests as and when required by issues that arise. This is a unique position, and has many strengths for ICZM. The partnership do, however, suffer from a lack of adequate recognition at national level, lack of clearly ascribed remit and lack of sustainable funding. To date, coastal partnerships have been established in response to areas of particular need, and where the coverage of local institutions did not adequately match this need, eg. the main Firths. This does not apply to the whole coastline of Scotland, however, and there is a need to assess the most appropriate way of providing complete coverage of the coastline.
Forth Estuary Forum state that the local coastal partnerships are working together more strongly in order to deliver ICZM, to develop 'national' projects, apply jointly for funding, and disseminate good practice. The national strategy will form the basis for their operations in the future and the collective local coastal partnerships consider themselves to be a lead partner in the implementation of the Strategy. The local coastal partnerships, including the Forth Estuary Forum, have an excellent record of local stakeholder participation, community involvement, managing local projects and providing excellent cost effectiveness. It is felt that these achievements should be recognised nationally and built upon through the delivery of the national strategy. No other existing collective group of organisations can provide this level of local working with a national view.
They also attached a proposal to formally affiliate the existing local coastal partnerships into a national body, the Scottish Coastal Partnerships. Objectives for the national body might include co-ordinating national responses to strategy documents; to engage in discussion with SEPA in the delivery of the Water Framework Directive community consultation; to develop funding applications to build a National Coastal Litter Campaign based on the work of the Forth Estuary Forum; and to link together research and data.
A concern is the lack of support that is presently received by the local coastal partnerships centrally from national organisations in particular the Scottish Coastal Forum. Without adequate mechanisms for central support and coordination, the implementation of the strategy will be fragmented and inefficient. Central support is also essential for monitoring and evaluation purposes.
Solway Firth Partnership think local coastal partnerships have been key in the delivery of ICZM in Scotland, but the strategy provides a limited account of examples of how they have achieved this. As such an analysis would further highlight examples of past and current good practice providing models that could be built on in the future. But the strategy highlighted the existence of locally specific strategies and management plans developed by partnerships e.g. Solway Firth Strategy. It is felt that such strategies and plans are an extremely valuable resource with regard to implementing ICZM at a local level and should be recognised more in the context of a national strategy. Particularly as they have themselves been through a comprehensive period of public consultation.
National Trust for Scotland acknowledged that local coastal management partnerships are an existing element of the network of organisations which, to date, have enabled local level progress on ICZM. The strategy document discusses these partnerships in Section 3.1 and highlights recent research which found that they have been effective in progressing ICZM and recommends that they continue to be supported as the preferred ICZM delivery method. The specific recommendation on local coastal partnerships in Section 4.3.4 is weak and a more strategic view should be taken of these partnerships, reflecting their crucial role in acting as a focus for action at local level.
RSPB Scotland and Scottish Environment LINK acknowledged that the existence of partnerships has greatly facilitated the development of the Scottish Coastal Strategy and joined-up thinking on coastal issues. However, in spite of having been operating successfully for over 5 years, few of these partnerships have been able to attract any longer term funding with the result that they are unable to attract full time staff and that much effort has to be diverted towards fundraising. For Integrated Coastal Zone Management to be delivered effectively, these partnerships urgently need a clear remit, strong leadership and funding security. The strategy must clearly outline how these groups will be provided with the support and security they require to help Scotland deliver ICZM.
The Crown Estate state that coastal management groups in Scotland are key in implementing ICZM in the UK. Their ability to engage with communities and stakeholders, to exchange information and bring disparate groups together to discuss common issues and concerns, provides a vital link between policy makers, industry and local communities. The Crown Estate are acutely aware of the difficulty that these bodies have in securing medium to long term funding and, since The Crown Estate regularly supports such organisations, they have recently commissioned Southampton Institute to research the funding of coastal partnerships (in the UK) and to contrast the expectations of funders with those of the Partnerships/Fora.
West Lothian Council think that Forth Estuary Forum's strength is to be recognised as a potential delivery mechanism in the context of ICZM and legislation such as the Water Environment and Water Services (Scotland) Act 2002 and issues such as sea level rise. The partnership approach of the Forth Estuary Forum has illustrated the strengths of the voluntary partnership approach, but there are financial implications for operating such a mechanism and without sustained core funding the subsequent pressures on the administrative team deflects it's priorities on to continuous fund raising needs.
Ayrshire Joint Structure Plan and Transportation Committee think the Firth of Clyde Forum is an example of a useful voluntary coastal partnership, and the Forum is currently about to get involved in developing a pilot marine spatial plan for the Firth. However whilst these voluntary partnerships provide a valuable forum for different stakeholders to discuss marine issues they cannot be a substitute for elected authorities, which must maintain ultimate control over the both land and marine planning system.
The Highland Council believes that local coastal partnerships have a useful role to play in raising awareness of the need for co-ordinated management and in helping to deliver ICZM and other community initiatives. However this will often be a supporting role - supporting or complementing actions by the statutory bodies - rather than a leadership role. Partnerships can of course take many different forms and each may have a different balance of interests within it. Some may be able to engender a higher level of commitment from local communities, statutory bodies, and business interests than others. However experience generally shows that ICZM can rarely be delivered on a sustainable basis by voluntary means alone.
Shetland Islands Council think one possible means of achieving stakeholder engagement is through a series of local fora charged with taking coastal and inshore management forward on some statutory footing under national guidance. Aberdeenshire Council consider that, given the weight being placed on coastal forums that either they are provided with adequate resources directly or that local authorities are provided with sufficient finance to assist with core funding targeted at the coastal forums within their area of responsibility.
Highland and Island Enterprise thought that the role of local partnerships is important, but also remain to be convinced that the current delivery mechanisms are strong enough, with short term project funding being commonplace, representing an inadequate means of delivery for strategic actions. More clarity is required into how these partnerships might evolve and help to deliver at a local level. The working relationship of the local to the strategic also needs further clarification. Hebridean Marine National Park Partnership said much ground work has been done by several local organisations and their knowledge should be tapped and utilized.
SEPA supports the findings of the recent research project on local partnerships and agrees that effective partnerships require a coherent set of objectives and support to ensure effective functioning. Natural Environment Research Council think "linking the partnerships' objectives to a coherent set of national objectives" (page 32) is needed not only "to give them direction" but (i) to avoid duplication, (ii) to provide national or even broader-scale information at national or UK level, and (iii) to encourage partnerships to look beyond their locality for wider sources of risk. Scottish Water think that clear direction, guidance and support to partnerships from SCF/Scottish Executive on national objectives are imperative.
Scottish Natural Heritage think the voluntary partnerships will evolve beyond current structures, and that it is crucial that the Executive recommends a clear way forward for them, in terms of their role and funding. They suggest that a stable fund for core running costs of these groups should be made available centrally (fulfilling the EU recommendation point on finance for ICZM). This would provide the stability required to allow staff to concentrate on key tasks, and groups would then seek contributions from their member organisations to fund priority projects.
Local Authorities
Ayrshire Joint Structure Plan and Transportation Committee showed strong support for the proposal that local authorities have the responsibility to prepare coastal plans, as they are in the best position to have an understanding of the local issues and have a democratic legitimacy to operate at this level. However, there are concerns related to the workload in developing a separate coastal plan, alongside Local and Structure Plans. There is also the potential for overlap between the Local Plan and the coastal plan, which may cause confusion. It is important that there is a clear delineation of the responsibilities and areas of the two plans.
Carlisle City Council thought coastal policy statements would be within Local plans, and say they are aware of the need to include a coastal zone development policy in the draft District Local Plan Review.
West Lothian Council said the joint working of local authorities, to meet national objectives, requires a more formal basis than voluntary partnerships, where key players may decide not to participate. Aberdeenshire Council considers it vital that the Executive gives priority to addressing the issue of complex legislation and regulations covering the coastal area with specific attention being made to inshore waters. This should be actioned as a priority and the outcome clarified in guidance notes, which make it clear what the responsibilities of local government will be within the ICZM regime and how this will be funded.
Shetland Islands Council recognize "The need to adhere more rigorously to coastal planning guidance and prevent development in vulnerable areas". They strongly agree with this statement, the Shetland Local Plan has several policies to this effect, and any new development in coastal areas should comply with this. It should be the local authority role to manage the implementation of the national priorities at the local level. There is a need for greater communication between the local authority and the Executive so that the Executive are more favourable to local issues and priorities. Any funding based on "Cost/benefit analysis", where an element is cost per head of population, fails to be workable in remote, sparsely populated areas. A more flexible approach to funding is required where the local priorities should dovetail with the national priorities.
Argyll and Bute Council recognise that the strategy asks that local authorities prepare coastal policy statements covering the inshore waters within 12 miles of terrestrial boundaries for inclusion in Structure and District-wide plans, and think that the Scottish Executive needs to be made aware of the fact that preparing coastal policy statements will have substantial resource implications for rural Councils who generally lack the capacity to carry out this type of work both in terms of staff and finance. It is unclear if there has been any assessment as to the implications of this and other action on Councils. It is imperative that such work is undertaken to determine the impact and to ensure that the necessary level of resources are made available.
Fife Council say it is accepted that local authorities are appropriately placed in terms of their functions as planning authorities and as leaders of the community planning process to perform a central role in coastal planning at the local level. The capacity to perform this role is however regarded as a major potential constraint factor in a context of expanding local authority functions and responsibilities and the need to prioritise limited resources of staff and funding for their delivery.
East Lothian Council say the action of reviewing the timing of local and structural plans with a view to incorporating other coastal related plans into the process may be desirable but it will need careful consideration to avoid holding up the development plan process. See objective 4.2.4 "Establish a baseline level of spatial planning policy guidance for the whole of Scotland's inshore zone by 2010" and 4.2.5 "Encourage Local Authorities to develop…an enhanced coastal planning framework which, in appropriate areas, provides detailed guidance for the development and sustainable use of inshore waters". This could have considerable resource implications for local authorities and will require 'skilling up'. This additional responsibility should be properly resourced. The Highland Council supports the proposal to develop a comprehensive consents procedure to help integrate planning, development and policy in the coastal area. While it is agreed that local and structure Plans should take account of coastal related plans, it is not clear in the document (paragraph 4.1.4) how it is possible to review the timing of these statutory plans to incorporate coastal-related plans into the process. On 4.1.4, SEPA questions the need to review timing of local and structural plans to incorporate other coastal related plans and whether this is feasible or necessary. SEPA considers it more important to engage stakeholders and partnerships and to have input of coastal issues into production of plans.
Highland and Islands Enterprise asked the question how are local authorities to be resourced to allow the implementation of marine spatial planning? They thought logically the next step might be to examine local authority planning powers for the near-shore marine environment. Ayrshire Joint Structure Plan and Transportation Committee supports the proposal 4.2.4 for a revised version of NPPG 13 to explicitly include the inshore marine area out to 12 nautical miles. West Lothian Council say it is noted that since the publication of the strategy, NPPG7 - Planning and Flooding, has been superseded by more up-to-date guidance in the form of SPP7 - Planning and Flooding.
British Ports Association think that for a document that discusses co-operative action at length, there is very little reference to what is happening in England and co-operation with the English authorities. They believe that this should be an important part of future policy making. Government Office for the North West think that in considering examples of ICZM good practice, there appear to be no examples from England (nor from Wales, nor Northern Ireland). Reference to these could have been useful.
Fife Council think in relation to training and capacity building, it is considered that many skills are held by local authorities which could be directly relevant to or transferable to coastal planning. Significantly new elements would, however, be introduced notably reflecting the contrasts between land use and marine activities. There is currently considered to be a significant lack of expertise in such matters and it would be essential that expanded local authority functions were matched by the training and expertise needed to deliver them. The involvement of the Scottish Coastal Forum, the Royal Town Planning Institute and the Scottish Executive in investigating improvements in ICZM training is considered appropriate. To contribute to raising the profile and understanding of coastal issues in Scotland, involvement in this could also be extended to other professional bodies in Scotland such as the Institution of Civil Engineers ( ICE) and the Chartered Institution of Water and Environmental Management ( CIWEM).
SEPA states that on 4.2.6, the action to improve and disseminate training has primarily been restricted to those Agencies with a planning remit. This should be extended to involve other sectors in ICZM who may also require training.
Statutory Plans
SEPA considers that although voluntary provisions for delivering the strategy may be effective, in the long term the principle of ICZM will require a statutory basis, with a clear associated partnership through which the public and stakeholders can participate.
Hebridean Marine National Park Partnership said that building on the numerous voluntary agreements that have been developed around our coast and encouraging local stakeholder ownership is a start, but these voluntary agreements require a statutory underpinning to protect them and prevent vessels foreign to these areas destroying both the agreements and the ecosystems which in turn will affect the small rural communities around our coasts. Solway Firth Partnership questions the statement in the 2002 ITAD and BMT Cordah research that partnerships should not be given powers of statute over the coastal zone.
The Highland Council welcomes the proposals to establish a planning system which combines Scotland's inshore marine area with the terrestrial planning system. However, the document states that statutory coastal plans should be prepared by local authorities (short term) before legislation is provided (medium term). We suggest that a commitment should be made by the Executive to provide legislation before local authorities prepare statutory coastal plans or policy statements for inclusion in the Development Plan, in order that the approach assists rather than hinders the Executive's proposals to streamline the development plan process.
It agrees that NPPG 13 should be revised to explicitly include the inshore marine area and provide a baseline level of spatial planning policy guidance. It also supports the role of voluntary coastal partnerships and non-statutory plans within the marine and terrestrial area where these fill an obvious gap in statutory provision. Highland Council and its predecessor have been active in preparing non-statutory plans for aquaculture and supporting various coastal partnerships and coastal management initiatives. The Council is currently working to develop a new type of integrated coastal plan via the Interreg 3B Atlantic Coast project in Wester Ross. It believe that all forms of coastal and marine development should be subject to local planning control within the 12 mile limit.
British Ports Association said that while one of the longer term proposed actions of the strategy is the preparation of either statutory or non-statutory coastal plans, they believe the case has yet to be proved for statutory plans, particularly bearing in mind ports' flexibility and their responding to the market. There is little doubt that coastal management is highly complex because of the large number of participants involved, sometimes with conflicting objectives. BPA do not see how statutory plans would necessarily resolve this, nor do they see how they will necessarily complement marine spatial planning. Associated British Ports Ayr & Troon echoed this.
Marine Conservation Society say a national Scottish body should have statutory responsibility for the preparation, implementation and evaluation of a marine strategy and spatial plan(s); powers to decide national priorities, co-ordinate sectoral activities, review policy, oversee enforcement of agreed activities, allocate budget, work with UK bodies on reserved issues, collect and exchange information and ensure the active involvement of stakeholders at all levels.
Funding
West Lothian Council said that, regarding local partnerships, there are financial implications for operating such a mechanism and without sustained core funding the subsequent pressures on the administrative team deflects it priorities on to continuous fund raising needs. There are financial implications of delivering national priorities at the local level and this must be taken into account.
The Crown Estate are acutely aware of the difficulty that these bodies have in securing medium to long term funding. Related to this point is the issue of SNH cutting back its financial support for coastal partnerships and Fora. Without this core funding there is the worry that these organisations may collapse. They seek clarification as to whether the SCF and/or Scottish Executive have a strategy for supporting these organisations in the future.
Forth Estuary Forum said their main concern with the strategy is the level of resources needed for the implementation of the objectives that will be implemented by the local coastal partnerships. The funding of the Forth Estuary Forum presently tends to be short-term funding that is largely project based. This type of funding leads to a lack of job security and therefore high staff turnover. This means that expertise is lost from the organisation. Lack of long term core funding leads to a lack of security within the organisation. A large proportion of time is spent by Forth Estuary Forum staff in fundraising, which would be better spent developing and implementing projects. They believe that the funding situation at the Forth Estuary Forum is reflected in the other local coastal partnerships. Therefore the objectives in the strategy that have been identified as being implemented by the local coastal partnerships will have to be costed accurately and funded externally. They would also strongly support the provision of resources to ensure an adequate level of central support to the local coastal partnerships. Moray Firth Partnership also suffer from a lack of sustainable funding.
A national representative body for local partnerships could address several issues: lack of resources including unrestricted, core, project and long term funding; sustainable balance between funding sources; duplication of fundraising effort and potential competition for resources; duplication of project officer time in particular in the development of resources; limited ability to attract funding from national organisations due to local remit; and lack of staff time to make large funding applications particularly to European sources.
Forth Estuary Forum visualise the next stage of the development of the national strategy as being when the strategy objectives will be expanded into more specific actions and resources applied to them. They would welcome the opportunity to engage further in the development of these objectives and to secure the role of the Forth Estuary Forum along with the local coastal partnerships in the implementation of these objectives. Solway Firth Partnership said that while the strategy sets out a general time frame for implementation for each of the recommended actions to deliver the identified objectives, this perhaps needs to more specific, with an indication of the resources needed for implementation, particularly in light of resourcing issues associated with local coastal partnerships.
Argyll and Bute Council said that there is a need for the Scottish Executive to make a long term commitment to the provision of the necessary financial resources available to local authorities, particularly in a large rural authority such as Argyll and Bute where the coastline is longer than that of France and where the statutory provision of ICZM plans could potentially have a huge impact on existing Council resources.
Hebridean Marine National Park Partnership said that funding to those government agencies tasked with enforcing existing marine legislation is extremely limited, leaving them at best stretched to capacity. These extremely low levels of resources coupled with a lack of political will to apply current and existing legislation is a matter of great concern for the environment and future sectoral activities that would wish to utilise the seas resources. Also, government implies that local groups and stakeholders should be encouraged yet little assistance is given, financial or otherwise. The Highland Council believes it is vital that the Scottish Executive makes provision for additional resources, legislation and policy direction - it should be an Executive priority to work with the relevant authorities and provide funding and technical support for practical ICZM projects and initiatives which can help to achieve the long term objectives of the SCF strategy.
Scottish Natural Heritage said the EC Recommendation on ICZM requires strategies to identify sources of durable funding for ICZM, and this is clearly something that the Executive will need to address in the final ICZM strategy.
SEPA is identified to contribute to objectives within the strategy, and although SEPA is keen to play its part in achieving these, they acknowledge that, for many proposed actions, extra resources will be needed, as these represent additional work not currently planned or budgeted for.
Stakeholder Engagement
SEPA say it is the action to be taken by all stakeholders to achieve the identified objectives that is of key importance. COAST said that any future marine environment management structure must include all stakeholders, particularly community organisations. There must be a body not dominated by fishermen who can make decisions to ensure sustainable fishing. Scottish Fishermen's Federation endorses the commitment to improve stakeholder participation in management.
Fife Council say the emphasis by the strategy upon effective stakeholder participation at appropriate geographical and administrative levels (Section 4.6) is fully supported as being essential to ICZM whilst the action points identified within this Section are considered to be appropriate. Mechanisms to enable engagement with local community interests should in particular be established, appropriately through the community planning process as led and facilitated by local authorities.
The Highland Council is pleased to see that stakeholder participation is a key theme of the strategy. Public participation is a fundamental component of the terrestrial planning system and it is just as important in developing management arrangements for the inshore marine area. This is particularly relevant at this stage in the development of ICZM where ideas for a marine spatial planning system are starting to be tested on the ground in real areas with real communities.
Shetland Islands Council think it is imperative that all stakeholders are involved in management of the coastal environment otherwise the process will quickly lose impetus and cohesiveness. One possible means of achieving this is through a series of local fora charged with taking coastal and inshore management forward on some statutory footing under national guidance.
Forth Estuary Forum say that the local coastal partnerships have an excellent record of local stakeholder participation. Scottish Natural Heritage say there is likely to be a need for local stakeholder involvement (this is already becoming clear in discussions with SEPA on the coastal aspects of river basin management planning), and that this highlights a need for groups like the local coastal partnerships to be maintained, even if they may require a new remit or status. Some stretches of Scotland's coast are not covered by existing partnerships, and some consideration is needed into how local stakeholders will be engaged in these areas (whether through establishing formal partnerships or less formal arrangements).
Moray Firth Partnership are pleased to see the important role of the local coastal partnerships reflected in the actions in section 4.6. This is the primary focus of their work, and they have significant experience of implementing a wide range of processes for enabling partnership working, stakeholder and community participation. They have co-ordinated strategic partnerships, topic focussed partnerships and wider community consultations. One current, and very successful, example is their work to bring together all of the stakeholders involved with inshore and associated river fisheries in the Moray Firth. It is difficult to think of another body locally that would have the required neutrality to undertake this difficult work. However, this facilitation work is not always easy to fund, and consideration must be given to how to sustain the partnerships to carry out this important role. Moray Firth Partnership have also played an important role in collating and providing access to information and data on the Moray Firth.
The Royal Yachting Association is already committed to a planning and environmental strategy for sustainable boating, Boating for Life, (see Ref. 5) in which the fundamental aim is to work with stakeholders towards the sustainable use of the UK's coasts and inland waters. These sustainable principles include the protection of the marine environment and the maintenance of employment. In Scotland, the RYA, through RYA Scotland, represents all aspects of boating and is keen to work with the local authorities and fish farm developers to assist the complementary development of aquaculture and recreational boating, so that the interests of each industry are safeguarded.
Association of Salmon Fishery Boards say that the concept of stakeholder/community participation in the management of Scotland's coast is now well established. However, the issue of Forum Fatigue remains a critical one. It should not always be assumed (particularly in remote rural communities) that the people who engage in such participative events are truly representative of the key interests in these areas. Equally, it is possible that the person representing a stakeholder group may not be representing the views of his/her constituents. Furthermore, there are now so many stakeholder involvement processes that stakeholder representative bodies are finding it increasingly hard to service all these various committees and meetings, let alone members of the general public. This issue is now recognized in many consultative processes and there seems to be an inability to resist creating an ever greater proliferation of groups/forums/management committees etc. This puts particular pressure on those involved in commercial activities where the primary aim must be earning a living. An interested stakeholder representative on an average Scottish West Coast sea-loch could be involved in up to a dozen separate groups or initiatives none of which have much contact with the other. Whilst such processes may superficially discharge consultation responsibilities they do also put great pressure on hard-pressed groups and organisations. A rationalization and better co-ordination of these processes and meetings conducted in language ordinary people can understand is vital to the success of engaging the public, stakeholder groups and commercial enterprises.
Marine Spatial Planning ( MSP)
British Ports Association acknowledge that the Strategy is clearly directed towards using MSP as a basis for coastal management in the future. So far as they can see, this is without going through a pilot scheme to test MSP concepts. In England a pilot scheme to test MSP in the Irish Sea will shortly get underway and in the absence of anything similar in Scotland, the results of the pilot should be carefully noted. The problem is that MSP means different things to different people. For example, their experience in talking to some groups is that MSP is another way of introducing a strict statutory planning regime for the coast which, in an inflexible way, identifies particular areas for particular types of development. Others, including ourselves, would see the value of MSP as possibly providing greater certainty with some indication of where development is likely to take place, but strictly on the basis that these are indications rather than pre-set objectives. Certainly before they commit to MSP as the basis for coastal management in the future, they would appreciate further discussion about its use and implications. Associated British Ports Ayr & Troon echoed this, and would welcome a Scottish trial exercise to ensure that all involved organisations and institutions have a common understanding of what it means and will involve, in terms of definition, use and implications. A major concern over the use of MSP is that it will result in the creation of a national ports' policy by the back door. This is unacceptable to an industry, which exists in a commercial world where the demands of the market dictate the development of business.
Ayrshire Joint Structure Plan and Transportation Committee say a criticism of the strategy is that it does not sufficiently distinguish between ICZM and marine spatial planning. It is noted that marine spatial planning is part of the process of ICZM but there is not enough of an explanation as to what the thinking behind ICZM is and what the process can also involve. It is not clarified as to whether marine spatial planning is meant to go further out to sea than ICZM or in fact the boundaries are interchangeable. There is a need for further discussion on the roles, objectives and mechanisms for spatial planning in the coastal zone.
Also, marine areas based on local authority boundaries may not fully reflect marine ecosystems or other possible sea regions, but the extent of the land based influence on the coastal zone would seem to make this the most appropriate scale to prepare plans at. Marine areas based solely on marine rather than terrestrial boundaries would run the risk of being difficult to interact with terrestrial planning and create jurisdictional difficulties. A wider regional overview could be provided on the basis of Structure Plan areas and above this, in Ayrshire, the Firth of Clyde Forum could provide a steer on some marine environment issues. Ayrshire Joint Structure Plan and Transportation Committee thinks it is important that local authorities maintain the responsibility for planning within their areas and in order for marine spatial planning to integrate with terrestrial planning, local authorities should lead on development of marine spatial plans and be charged with the implementation and regulation of these.
SEPA supports the principle of coastal spatial planning, and says the acceptability of a new system of coastal spatial planning will depend to some extent on a simplification of other regulatory measures or frameworks, such that applicants are presented with a simpler system than at present. On 4.2.4, SEPA has recently closed a public consultation process through which four possible models of river basin planning sub-basins structures were proposed for Scotland. They think the water body units determined for this process drawn up logically on features and water body types represent sensible management units for the coast. SEPA considers these to be the most appropriate units for sub-dividing the coast and inshore waters for management purposes.
Scottish Natural Heritage think that in evolving the Executive's ICZM strategy further work will be required to identify suitable management units, based on both environmental and socio-economic characteristics. There will be a need for discussion with stakeholder groups on the delimitation of boundaries for management units. However, it is worth noting that coastal/marine boundaries are already starting to be defined (eg, Area Advisory Groups for river basin management planning, under the Water Framework Directive; or inshore fisheries work), and it would be useful to coordinate these processes.
Scottish Fishermen's Federation notes that section 2.2 lists Marine Spatial Planning ( MSP) as a `key costal management tool ... for moving towards sustainable fisheries'. But whilst Marine Spatial Planning exists as a concept, very little information has been published with regards to the definition, or potential practical application, of this system. If MSP is to be considered seriously as a possible tool in marine environment management, considerable work must be done in modeling this system. Once detailed modeling has been completed, it may be appropriate to instigate trials at the Regional Seas scale to determine the suitability of implementing MSP in Scottish/ UK waters.
Argyll and Bute Council also think it would be helpful if a clear definition were provided as to what constitutes marine spatial planning as there seems to be a variety of views on this i.e. does it imply some form of zoning?
FRS Marine Laboratory see the strategy as requiring a sub-section explaining the roles of spatial planning and how it interacts with coastal forums to encompass issues from all interested sectors i.e. spatial planning can be used as a mechanism to identify where conflicts of interest may occur and perhaps help resolve them.
RSPB Scotland welcome the strategy adding to the increasing recognition of the need for marine spatial planning (Goal 4.2.1 Establish an integrated system of spatial planning for Scotland's inshore marine area). They believe that only this will achieve effective management of our seas, and better protection for our coasts and those livelihoods dependent upon it. They strongly support the strategy's aims and objectives to develop and use spatial planning, for example Action 4.2.4 Prepare a revised version of NPPG13 (Coastal Planning) to explicitly include the inshore marine area out to 12 nautical miles by 2007. They are pleased that the strategy states "any system of spatial planning in the marine environment should incorporate the best features of the terrestrial system, but also take account of the special characteristics of the marine environment and the needs of the marine users." They urge that the strategy clearly shows how it will link with the SSMEI pilot projects which offer the opportunity to test marine spatial planning, such as the Sound of Mull pilot management scheme. Scottish Environment LINK echoed this.
Marine Conservation Society think there must be effective marine spatial planning including a hierarchy of plans and policies for Scotland's inshore seas managing the vast range of marine activities and the regulation of proposals for change. MSP is a key tool to implement the ecosystem-based approach to management. Hebridean Marine National Park Partnership also think marine spatial planning is essential and integral to the future of Scottish seas.
Shetland Islands Council think marine spatial planning would assist in the management of the various competing interests in the coastal and inshore environment and allow a more integrated approach. Marine spatial planning could certainly contribute to the delivery of sustainable management through a plan-led framework for coastal/inshore activities. However the current level of coastal development in some areas may work against a truly effective spatial planning regime.
If spatial planning is taken forward there would be a need to develop a legislative framework, either along the lines of the Town and Country Planning system or through a more radical approach through a statutory process for Integrated Coastal Zone Management. Locally tailored framework plans could evolve from the national level and it is worth noting that a number of local authorities are currently developing marine framework plans based on the concept of spatial planning albeit outwith any legislative framework. The inclusion of a marine spatial planning pilot project within the Scottish Sustainable Marine Environment Initiative is a welcome step. It is contended that marine spatial planning is critical to the delivery of improved regulation, management and protection of the coastal and inshore environment by addressing the multiple, cumulative and conflicting uses of it. Inherent in this approach is the recognition that there will be a need to introduce new, and perhaps radical, legislation. However this would offer the opportunity to realise most, if not all, of the aims of this Strategy, including improved and cohesive regulation, involvement of all stakeholders and attainment of conservation objectives, including water quality. Strategic Environmental Assessment could more readily be applied to a marine spatial planning framework.
East Lothian Council say that moving towards an increased spatial planning role for local authorities for inshore waters around their area is welcomed, particularly as there appears to be increasing demand for seaward uses which can effect those on land as well as increasing use of the inshore area for recreational purposes. Hopefully this will lead to an increased opportunity for local people to have an input into decisions that effect them in the same way as is possible through the well understood town and country planning system.
Highlands & Island Enterprise ask how are local authorities to be resourced to allow the implementation of marine spatial planning? Such a recommendation has significant resource implications for the Highland Council specifically.
Scottish Natural Heritage strongly support the strategy's recommendation that an integrated system of marine spatial planning is required for Scotland's inshore marine area, but feel that more detail could be provided on how this should be implemented. Evidence from other countries suggests that, to be effective, a system of marine spatial planning should address both `development' and `activities' (such as fishing, recreation and transport) in the sea. This point is mentioned in the strategy as a lesson from elsewhere (section 3.3), but could be clarified in the recommendations on spatial planning in 4.2. The strategy should also clarify the need for a two-tier approach to marine spatial planning: a national level policy statement which would identify the overall priorities for marine spatial planning (incorporating concepts like sustainable development and ecosystem approach); together with area map-based plans which identify resource distribution and sensitivities, and (taking into account national principles) use a collaborative approach to allocate activities to preferred locations.
It may be premature for the strategy to state (section 4.2.3) that local authorities should play the leading role in marine spatial planning, as there are other options (a new agency, or appropriately authorised partnership group, etc) which require to be investigated. The strategy could have described some alternative options or scenarios for issues such as the possible lead body; extent of coverage (inshore/offshore); operation of consents; together with resulting implications for the roles of others, such as consenting bodies, local coastal partnerships, etc.
Moray Firth Partnership think MSP will require to be considered in the context of ICZM, of which it is a key component. The role of the voluntary coastal partnerships requires investigation, and if this is to become a statutory process, as for instance in Norway, its relationship to the partnerships must be clearly defined. It may be useful to trial this in existing coastal partnership areas, especially those which relate to several local authority areas. The Moray Firth Partnership has links to marine spatial planning in the West of Norway, and would welcome consideration of the lessons of this system.
British Geological Survey, as a research centre of the Natural Environment Research Council, would like to emphasise that it believes the issues could best be addressed by having a spatial framework in which to develop sustainable use and management of the coast and inshore waters. BGS's experience, and that of reviews such as the Irish Sea Pilot project, shows that a spatial framework would be best supported by a detailed seabed geological map. In the coastal zone around Scotland, there is a paucity of good seabed marine landscape and geological data at present. It is vital that a programme of new data collection (based on multibeam swath mapping) is supported. Similar projects are now underway in an increasing number of countries such as Ireland, Norway and Canada. The Proudman Oceanographic Laboratory recognise that some concerns depend on a much wider spatial view than coastal cells (for example). While coastal cells should be defined, and although there is natural emphasis on waters within 12 nautical miles, various aspects are "driven" from outside. For example: rising sea levels are global; coastal flooding (page 25) relates to (tides and) wind-driven surges on scales of 100s of kilometres. Scotland is thus far from standing alone; e.g. caesium-137 from Sellafield has been carried all around Scotland into the North Sea and beyond.
The Royal Town Planning Institute in Scotland ( RTPI) appreciate the reference to the Institute's role in developing the debate about MSP in 4.2.6, and confirm that the Institute at a UK level has agreed to set up a MSP Task Group to look not only at their views on MSP systems across the UK but also at the implications for education and professional activity by our members. They take the suggestion of para 4.2.1 to reflect the Scottish Coastal Forum's preference for extension of the terrestrial planning system to the inshore waters, and think that this would happen within the limited confines of the fish farm regime in 2006 with the commencement of section 24 of the WEWSA 2003. RTPI would not go so far until there has been some appraisal of all the options and there has been some testing of the experiences of the marine fish farm regime.
While scale and administration are clearly important issues as the strategy addresses in 4.2.4, there are much thornier issues of range of control and the resolution of responsibilities between UK administrations to be resolved. Royal Town Planning Institute for Scotland are concerned that there should not be a headlong rush into the issue as it is clear that there are some fundamental concepts about spatial planning systems which need to be explored. The matters which are now emerging for closer debate include the need to apply a spatial policy framework in the marine environment equivalent to the statutory Development Plan and relate the appropriate regulatory regimes to it; the need to consider how a MSP system will work proactively to promote opportunities for sustainable development and not just to be an added environmental protection tool; and that these issues will raise the need for much more research into how a spatial planning system can be developed in relation to the panoply of existing regimes which is compatible with governmental competencies and truly integrated policy. They are currently talking to consultants who have been commissioned by Defra about this.
Scottish Fishermen's Federation think the present consultation considers the issue of coastal and inshore marine environmental management in a Scottish context only - an approach directly at odds with the widely supported Regional Seas Approach recommended by the recent Irish Sea Pilot. Several studies conclude that Regional Seas provide an appropriate scale at which to assess marine biological resources, and both the physical and chemical processes that these depend upon. The Regional Seas Approach is thought to offer the lowest effective management scale for UK waters. Division of areas on the scale of Regional Seas provides the added bonus of compatibility with areas defined for EU (fisheries) Regional Advisory Councils. Members of the Federation believe it vital to create consistent borders for the management of marine fisheries and the broader marine environment.
Government Office for the North West recognise that the EC has encouraged consideration of a Regional Seas Approach to Integrated Coastal Zone Management ( ICZM). The Strategy appears to make no reference to this, and there may be potential for its consideration in an Irish Sea context, potentially involving Scotland, NW England, Wales, the Isle of Man, Northern Ireland and the Republic of Ireland.
Hebridean Marine National Park Partnership think in keeping with the findings of the recent Review of Marine Nature Conservation Irish Sea Pilot, regional sea management is the best way forward in managing the seas. The Scottish Executive must therefore work with other countries in the UK, the EU and outside the EU, such as Norway to secure the future of offshore seas. Due to the dynamics of coastal currents and the movement of species throughout political boundaries it is essential that effective pressure is brought upon other Countries whose actions adversely affect our own shores and industries. The industrial fishing for sand eels, sprat, herring and Norway Pout is scandalous, and has a direct effect on our ecosystems and food chain. Norway's continuance of whaling minkie has an adverse affect on our whale watching industry as it is probably the same whale population which traverse international borders.
Monitoring, Data and Research
RSPB Scotland say monitoring and evaluation is key to the continuous development of a workable, effective coastal strategy and that a list of ICZM process indicators should be developed that link to other national and international reporting systems. Scottish Environment LINK echoed this. RSPB Scotland say the UK and Scotland have a range of international commitments and domestic policies that include targets for environmental improvement. However, it is not always clear how effective the various actions taken by the Government or its bodies are in achieving these particular conservation aims, if at all. The setting of environmental indicators, to inform decision-making and help measure and report on changes in environmental status and progress towards conservation goals and objectives, are now the norm for most Governments.
A new RSPB report, "A Review of Marine Environmental Indicators", has reviewed marine environmental indicators and identifies those best suited to give an overview of marine ecosystem health and the sustainability of human activities. Traditionally most environmental indicators describe the quality of a particular aspect of the environment. However, a clear message that emerges from examining the different approaches to selecting indicators is that it is preferable to reflect and report on the whole ecosystem, and its structure and function. Therefore a 'suite' of indicators rather than a single one will be needed to adequately report on marine ecosystem health, structure and function.
Shetland Islands Council think that Goal 4.7 (Research, monitoring, and data and information) should be the first goal as this underpins all the other laudable objectives. There is a need for a stocktake of existing knowledge and information in order to identify gaps or areas of limited detail and then prioritise the action required to rectify the situation. This work would also provide a baseline against which progress can be measured. A lot of information already exists but it is held by a number of diverse organisations and there is a need to pull this together into, for example, a single database that is accessible by all interested and relevant stakeholders and organisations.
Argyll and Bute Council think in the development of ICZM plans it is imperative that the necessary data relating to the coast and inshore waters is made available as good data and information is crucial in the decision making process. The Scottish Executive should ensure that there is sharing of information between different agencies and partners to assist in the process and that the data is held in a format that everyone can access. There should be an agreed format/template for the collection and storage of this data.
SEPA say that to ensure effective inter-operability of data there needs to be a clear understanding of how interchanged data is to be used and interrogated in the future. It should be recognised that the first task is to establish what questions a data repository should answer. The making of the repository will be the second task. SEPA expected specific mention of agencies active in research and monitoring, such as SEPA, Scottish Natural Heritage ( SNH), Fisheries Research Strategies ( FRS), as contributing to objective actions. SEPA's environmental monitoring will be prioritised by their report "Pressures and Impacts on Scotland's Water Environment".
The WFD requires SEPA and other responsible organisations in Scotland to develop new monitoring and classification systems by December 2006 which will include coastal and inshore waters. The classification system will be underpinned by a range of biological quality elements, supported by measurements of physico-chemistry, hydrology and morphology. SEPA's WFD monitoring system will be risk-driven, focusing monitoring resources on those water bodies identified as being at risk of failing to meet their WFD objectives. An already effective liaison between FRS and SEPA will be improved, through more detailed annual co-operation on monitoring plans. SEPA and FRS have started on preparation of a common marine monitoring plan also to involve SNH.
Natural Environment Research Council think it should be noted that not even the UK as a whole claims to lead research on all aspects of marine science, and certainly within the UK different research laboratories have their specialisms. Thus, the Scottish Association for Marine Science ( SAMS) leads for aquaculture and sea-lochs, for example, but POL (in England) for shelf-sea modeling and predictions of coastal flooding. Hence in respect of 4.5.3, 4.5.4, 4.7.5, 8.2.4 first bullet, and 8.4.6 last bullet, care is needed to avoid duplication and to co-operate with work in the rest of the UK ( e.g.NERC Research Centres, Defra/ EA-sponsored work). In parts the document seems to assume that things are already fully understood when they are not; this is reflected in the lack of mention before page 28 of research needs. The mechanism at 8.2.4 fifth bullet is not just a matter of awareness but lack of understanding, as at 8.2.3 first bullet and 8.4.3 first bullet.
Monitoring is mentioned in various places, with a particular section 8.12.7. There is scope for consideration of the space- and time-scales needed for monitoring in relation to the natural scales of relevant phenomena and the ability (or otherwise) to use models to "interpolate" between measurements. Regarding 8.2.7, sixth bullet, sea level rise, wind strength and direction should indeed be monitored, but there is not much that Scotland can do to change them, so measuring them will hardly help to monitor progress.
Natural Environment Research Council Section say that for section 4.7 data, The British Oceanographic Data Centre ( BODC) surely plays some role here as the NERC designated data centre for UK marine research data, recognised as such also by IACMST. In fact BODC receives and distributes data from FRS Aberdeen. However, the relation with SEPA should be considered. In England, the Environment Agency ( EA) manages its own data, separately from BODC. Scottish bodies should certainly engage fully with IACMST (end of page 28) in view of the above comments about scales of some phenomena and research specialisms.
Ian Burrett suggests that regarding monitoring, who is better placed than a volunteer committee made up of sea anglers reporting back to relative government departments on their observation of sea stocks and algael blooms? With internet sea angling chatrooms and forums etc. they could collate, up to date information on a weekly basis if necessary.
Scottish Natural Heritage say section 4.2.6 refers to the merits of GIS but there should be an additional action for a strategic plan for acquisition of datasets, with special reference to remote sensing. Also, the Executive's Scottish Sustainable Marine Environment Initiative will test different management models, and there should be some mention of how the results of such pilots might be assessed and used to inform future policy development.
Fife Council said that the need for co-ordinated research, data and information management activities, and monitoring / evaluation of Scotland's Coasts and Inshore waters across Scotland (Section 4.7) is agreed. Local authorities should be in a position to assist in data sharing and collaborative working across a range of topics such as built and natural heritage, land use, contaminated land and shoreline management. The Highland Council agrees with the proposals to promote collaborative working and endorses the sharing of information across all sectors. East Lothian Council agree with 4.2.2 Rationale which states "Good performance of management of the coastal zone will be reflected in a broad spectrum of indicators", and goes on to mention e.g. high water quality, healthy fish stocks etc. Forth Estuary Forum say that affiliating the local partnerships would help to link together research, sources of information and data particularly through websites. The National Trust for Scotland recognise the importance of monitoring and evaluation. Hebridean Marine National Park Partnership think research and monitoring should be conducted by truly independent bodies and be consistent with the habitats and species concerned, all too often incorrect methods lead to misleading and/or invalid results.
Marine Conservation Society say data sharing has particular relevance related to seismic testing. Seismic testing is undertaken by different oil & gas companies repeatedly over the same area of sea, due to no obligation from the government to share seismic data. This results in a web of noise which is known to impact on cetacean. Seismic testing is licensed outside of oil & gas licensing rounds and Strategic Environmental Assessments and without any strategic overview. The extent of the problem in Scottish waters therefore needs to be reviewed and action taken ( e.g. insistence on seismic data sharing by the O & G industry, by the Scottish Executive). Also, fisheries research services should have increased resources to enable them to support the development of inshore fisheries management and the monitoring of the condition of inshore fisheries.
Natural Processes
Structures and Lighting Department, South Ayrshire Council, also acknowledge that our understanding of coastal processes needs to be improved. The Highland Council is pleased to note that the Executive plans to improve research into understanding dynamic coastal processes and how the marine and terrestrial environments interact. This will help to better inform the decision-making process for suitable development locations, particularly with predictive modelling and monitoring techniques. FRS Marine Laboratory think that where it is stated that there is a need to work with natural processes, there should be an awareness that such an approach will undoubtedly result in unpopular decisions having to be made. For example, perhaps leaving some coasts to erode naturally rather than using hard protection measures.
Moray Firth Partnership would like to see recognition of the role of the local partnerships in section 4.5 The Partnership has played an important role in providing access to information on coastal processes, in bringing together key partners in developing integrated thinking on management in relation to these processes, and in identifying and promoting the need for further research. They would cite 4 examples: support for the co-ordination of management guidelines for the Moray Firth SAC; the work undertaken in the Cromarty Firth to produce a pilot data system for enabling wider public access to environmental data sources on the Firth; forthcoming work to assist with stakeholder consultation in relation to the proposed Talisman wind energy development in the Beatrice oilfield; and our proposed scientific conference on the Moray Firth.
Water Quality
On water quality, sportscotland think that references to the importance of water quality should be linked to the importance of this for sport and recreation interests eg "surfers against sewage".
On 2.13, Scottish Water feels that the wording in Paragraph 4 ("Although only a tiny percentage…") is confusing and does not adequately represent the issue. Through improvements in wastewater treatment driven by the Urban Wastewater Treatment Directive, the environmental impact of sewage discharges has been greatly reduced since 2000. The provision of full treatment for all of Scotland's large population centres at the start of this decade allied to the ongoing commitments to meet the 2005 deadline for provision of full treatment to the remaining significant population centres will address all the major sewage-related concerns with respect to coastal pollution.
On 8.12, Scottish Water questions the source and quality of information relating to pollution and sewage related impacts. Whilst section 8.12.3 states that 0.5-0.7% of the coastline was classified as "seriously polluted" (1996-2000), SEPA's 2003 National Water Quality Classification Report identified that the percentage of Scotland's coastline classed as "seriously polluted" has halved from 0.4% in 1999 to 0.2% in 2003, and that the percentage classed as "unsatisfactory" fell from 2.3% to 1.1% over the same period. Furthermore, SEPA commented that the improvements in quality are primarily due to "substantial" improvements in sewage treatment delivered by Scottish Water through its Quality and Standards investment programmes. Moreover, SEPA indicate that the existing programme to be delivered in accordance with the 2005 deadline for the Urban Wastewater Treatment Directive will ensure that its 2006 targeted level of improvement to coastal water quality will be exceeded.
It is important that strategies such as this draw attention to the work being done under existing drivers to improve water quality ( UWWTD, bathing waters, shellfish waters etc) in order that effort is not duplicated.
Shetland Islands Council say that whilst Scotland has, in general, a good quality of coastal water (section 2.13), there is no room for complacency. There is a need to continually build on this existing level of quality to ensure that all aspects of the coastal environment, whether exploitative or not, remain sustainable in the long term. The implementation of the Water Framework Directive, through the Water Environment and Water Services (Scotland) Act 2003, should ensure that this is the case. Highland and Islands Enterprise have specific concerns about the coverage relating to water quality as there have been important developments and key consultations this year which are not taken into account.
Sea Defences
Highland and Islands Enterprise think that the impacts of coastal erosion and the increased need for physical protection is one of the most significant issues that needs to be addressed at the strategic level. Global warming may increase the potential for flooding, but even without it many coastal areas are at risk from the sea. Nationally, it may be well understood that sea defences can only be selectively supported, but locally, there is little or no acceptance of the corollary to that policy which is that some areas will be sacrificed. The issues around prioritisation and long term impact should be addressed, probably by offering a proper strategic consultation process in advance of need.
Shetland Islands Council say "Strategic planning of coastal and flood defences" is much needed in Shetland where much of the coastal defence work has been undertaken in the past by private landowners to varying standards. An audit of the coastal defences around Shetland was initiated by the Planning Service in 2003/04 but without specific information relating to the perceived impacts of climate change it is difficult to plan strategically for the future of these defences. The strategy states that there is "poor understanding of flooding/erosion trends (including climate change effects) and ineffective prediction and management of erosion and flooding events". This statement is true at a national level and even more relevant at the local or Shetland level where there is a lack of specific information relating to the effects of climate change and sea level rise. The research undertaken recently e.g. the Foresight Future Flooding Project in Scotland report (published Sept 2004) or the Review of Protection Offered by Flood Prevention Schemes UKCIP02 update (2003) highlight that there is little research undertaken at the national level that is applicable to Shetland. There is often no information that is relevant to Shetland included in such reports or when Shetland is mentioned the information is incorrect.
The report identifies that there is no single agency with responsibility for coastal protection and flood defence, with no dedicated budget for defence. It is pleasing to note that this has been highlighted as it is a major concern and the issue of responsibility needs resolving.
The Crown Estate acknowledge that mention is made to developing Shoreline Management Plans in Scotland. They would like to ensure that such SMPs are underpinned by local scientific knowledge and with due regard to the Habitats and Birds Directives. Further, they would encourage the identification of further sites for managed realignment in Scotland, as a tool for scientific research and as a method of educating the public of the issues relating to sea-level rise and coastal squeeze.
Fife Council say coastal defence (as referred to in Section 2.12 'Coastal Defence and Shoreline Management') was traditionally carried out by the Water and Drainage Departments of Regional Councils. However, investment in coastal defence infrastructure declined dramatically when the new unitary local authorities were created in 1996. Increased levels of sustainable revenue are required to deal with the backlog of maintenance as well as capital funding to replace defences that have reached the end of their design life.
Fife Council's Shoreline Management Plan ( SMP) has been in place since 1999 and is now due for review. However the resources available for monitoring the coastline are very limited and it is therefore proving difficult to implement the recommendations of the Plan. Increased monitoring and inspection of the Coast is required to keep the SMP up to date and relevant. There is also a general lack of information about coastal processes, existing assets, land ownership etc. The coast protection database is not up to date as a consequence. An asset database is required to establish ownership of (and therefore responsibility for) coastal assets. If available, this information could be used to inform the SMP process. Coastal defences in private ownership are a problem in terms of getting owners to maintain / repair existing defences. Similarly local authorities have extremely limited maintenance budgets which are insufficient to deal with either private or council-owned defences.
Conservation
RSPB Scotland state that Scotland's seas support over 8,000 species of birds, mammals, marine plants, invertebrates, fish and reptiles, which, together with the lower organisms, account for over 50% of our nation's total biodiversity. The Scottish Executive, in its Strategic Framework for Scotland's Marine Environment consultation document, is committed to "a clean, healthy, safe, productive and biologically diverse marine environment which, through sustainable management, will continue to support the interests of nature and people". The coastal strategy is a vital strand in allowing the Scottish Executive to deliver on that commitment, as well as its international obligation to halt the loss of biodiversity by 2010 made under the 1992 Convention on Biological Diversity. The strategy therefore must integrate the delivery of the Scottish Biodiversity Strategy, specifically the Marine Implementation Plan which covers "all offshore and inshore (coastal) waters around Scotland, as well as the intertidal interface between the land and sea", with the primary aim of "ensuring a productive and biologically diverse marine environment". It is clear, therefore, that biodiversity and nature conservation should be at the heart of the national strategy for our coasts. Scottish Environment LINK echoed this, saying there should be a duty of care on all bodies whose activities impact upon the marine environment, to protect, manage and enhance marine species, habitats and ecosystems.
The National Trust for Scotland also think nature conservation and biodiversity should be key components of a strategy for the coast and inshore waters. These areas are a serious omission from the document and need to be highlighted under Section 2 'Understanding the Challenges'. Whilst reference is made to biodiversity at 2.9 'Marine and Coastal Natural Heritage', this is by no means sufficient within such a strategy. A holistic view of the coastal zone should be apparent in the document, stressing that the unique character of this area type lies in the complexities of land meeting sea. Objectives for the natural environment are confined to Section 4.4 where it is relegated to the status of a component of the 'resources of our coast'. This results in a wholly inadequate focus on protection measures and an overemphasis on means of quantifying the resource value rather than implementing practical conservation. The Review of Marine Nature Conservation, referred to in Section 3.1, contains some excellent recommendations for measures that are urgently needed which have been entirely overlooked by this strategy.
David Ainsley observes that we have witnessed a worrying decline in our local marine environment over the years. Since the abolition of the 'three-mile limit' in 1984 (which allowed sustainable, eco-friendly creel fishing, but banned damaging scallop dredging) the seabed within the Firth of Lorn SAC now resembles a ploughed field over large areas. Much of the biodiversity on the 'protected' reefs has been lost, due to both siltation and by direct dredge damage. The relevant authorities have so far failed to control this activity despite their duties under the Habitats Directive.
There are duties under the Habitats Directive 1994 to designate areas for the protection of porpoises. This has still not been done. Within SAC's, Relevant Authorities are charged to adopt the precautionary principle using best available evidence. Sightings reported to Hebridean Whale and Dolphin Trust show that the Firth of Lorn, Sound of Mull and its western approaches are the most important areas for this species. Scottish Office circular 5/95 states that "all species which occur at a significant level within a SAC" are protected. It is clear from the above sightings records that porpoises occur here at a 'significant' level. Porpoises must be protected immediately within the Firth of Lorn SAC.
Furthermore, bottom-set multi-monofilament nets kill porpoises, seals and seabirds. The local fishermen have agreed not to use these in the Firth of Lorne SAC. Instead they use creels provided by an EU fund. A bye-law is now needed to prevent other fishermen coming into the area and using nets, to safeguard both local business and wildlife.
The problems of seabed pollution, effects on wild salmon and the use of therapeutic chemicals are well documented. Industrial fisheries provide the food source for fin-fish farms, but deprive the wildlife on which our industry relies of its food source, to the extent that seabirds are starving and failing to breed. Feeds based on vegetable oil must be developed as a matter of urgency.
Hebridean Marine National Park Partnership ( HMNPP) states that the EU Habitats Directive has provided a firm basis on which to build upon, it makes provision for maintaining and improving our natural heritage. HMNPP asks why does there appear to be apathy within many government agencies these include: SEPA, SEERAD, SNH and local government with its implementation? Local observations suggest that it is reluctance and or policy from above which is restricting the development and enforcement of the Habitats Directive. The structure of this Directive is in place to promote and protect biodiversity and transposed into English and Scottish law, why is it not being utilised in the marine and maritime environment? One comment constantly arising from government led consultations is "local stakeholder involvement", why is this not being taken seriously? Current ICZM initiatives are being undertaken by people who have shown an inability to comply with existing legislation, why are these same people entrusted to deliver the next stage of implementation where currently no or little legislation exists?
HMNPP think the 'Precautionary Principle' is of paramount importance. The key is that ecosystem integrity is maintained, underpinning the social and economic activities that rely upon it: the 'precautionary approach' should be invoked when in doubt over the possible impact of an activity on ecosystem integrity. Ecosystems form the heart of what is trying to be achieved: a successful, workable medium between the environment and human exploitation. Why is there reluctance by relevant authorities to invoke this basic requirement?
The Centre for Ecology and Hydrology, of the Natural Environment Research Council in particular welcomes the fact that the strategy recognises the international importance of seabird and marine mammal populations, and the need for management to ensure a good supply of their prey species.
Pollution
Ian Burrett says an area that needs acting on quickly is the amount of nitrates that are allowed to pollute the sea. He recently witnessed the death of 10,000 or more sandeel that died as a result of poisonous toxins left after an algae bloom. If the basic foodchain is under threat, what chance have other species got for recovery. The government seems to have the opinion that it is cheaper to pay fines to Europe than to clean up the sea. This must be addressed. The sea is just a large pond that can be managed, if the correct political will is created. Despite years of pollution, the rivers have more fish (albeit not Salmon and Sea Trout) in them than in living memory, so it can be achieved.
SEPA goes into detail about shellfish farming and the opportunity to separate it geographically from sewerage effluents so that the risk of contamination of farmed shellfish is minimised by a separation or "buffer" zone. This also reduces pressure on hard-pressed capital resources used to improve the sewerage infrastructure and the risk that priorities will be upset through the location of a shellfish farm close to established sewer outfalls. Also, larger scale finfish development cannot be considered environmentally benign, and has the capacity to affect the seabed through the deposition of faecal and pseudo-faecal solid matter, or by removal of fouling organisms and waste shells. However, field studies on the impact of shellfish farming are relatively scarce and there is a need for further monitoring around existing shellfish farms to gauge the need for regulatory intervention as the industry expands in both scale and extent. The Association of Salmon Fishery Boards also goes into detail about the effects of finfish aquaculture.
Marine Conservation Society think that regarding noise, drilling for oil and gas may have an impact on marine mammals e.g. those in the Moray Firth. An assessment of noise from industries such as oil and gas, and renewables in Scottish coastal waters should be undertaken and an action plan to mitigate this noise implemented. East Lothian Council says the section on power generation does not mention discharges from or de-commissioning of existing coastal power stations. Forth Estuary Forum wish to build a National Coastal Litter Campaign and rollout the recently produced beach litter education pack.
Marine Protected Areas
COAST think there must be the establishment of a comprehensive network of No Take Zones and Marine Protected Areas.
Fife Council say that regarding national parks, the SCF Strategy does refer to an example in Section 3 'Home Truths and Lessons from Elsewhere' and reference is also made to it in section 8.11.4 'Tourism and Recreation'. No reference is however included in Section 4.0 Responding to the Challenges whilst the strategy highlights the benefits of using existing networks as important (at section 2.14). Further clarification and discussion on the issue of national coastline parks and marine national parks would seem to be a key requirement in relation to the action point identified for the Scottish Executive (at 4.1.4) to 'review current management partnerships and assess need / demand for further groups'. Scottish Natural Heritage also think there should be further exploration of the potential role that Marine or Coastal National Parks might play as a delivery mechanism for management of some of Scotland's areas of highest maritime natural heritage interest.
Hebridean Marine National Park Partnership gives a case for Marine National Parks. They think the development of Marine National Parks, underpinned by a single Marine Act governed by a lead body with Ministerial responsibilities would protect local biodiversity, promote sustainable economy, encourage local stakeholdership and reduce the need for active policing. The numerous and current government initiatives are to be commended. However it is now time that some physical developments actually take place, for example Marine National Parks ( MNP's), A Marine Act and No Take Zones. In keeping with the aims of MNP's, areas should be identified where commercial development, including fishing and aquaculture can flourish on a sustainable basis. Good scientific principles should be adhered to and in the case of doubt regulations which contain the "Precautionary Principle" adopted.
The SSMEI has been welcomed but to actively exclude piloting a Marine National Park is a missed opportunity, especially as so much preparatory ground work has been accomplished.
Establishment of a Marine National Park would be the ideal opportunity to help trial ideas such as proper local management with full stakeholder input, and a system of marine spatial planning, developed within a coherent marine strategy, with measurable goals and timescales. The HMNPP would be happy to assist in the development of such ideas using information gained during two years of public consultation with those in the industry and those from remote rural locations. A network of Marine National Parks (National Parks are identifiable Worldwide, when administered correctly work both for the ecosystems and the economy) could be a suitable vehicle for delivering local stakeholder management of the coasts and seas. Each would have its own Authority comprising of a large proportion of local stakeholders coordinated by a central governing agency led by a Minister.
National Parks are renowned Worldwide. There is a plethora of evidence that Marine National Parks work and fishermen are known to preferentially target boundaries of Parks and "No Take Zones" for increased catch. Two of the aims under the National Park (Scotland) Act 2000 are to conserve and enhance the natural and cultural heritage of the area; and to promote sustainable use of the natural resources of the area. The benefits that could be achieved from these aims are positive from all perspectives. The creation of Marine National Parks would benefit people and businesses everywhere in Scotland. They would enable Scotland to truly fly a "green tourism flag" throughout world markets. MNP's could provide for areas with enhanced spawning grounds, small scale natural salmonid enrichment, lucrative sports fishing regions and actively encourage and tap into the world tourism markets for water sport and wildlife tour activities.
A serious failing of the Wildlife and Countryside Act 1981 and its Sites of Scientific Interest ( SSSI's) is the failure to extend below Mean Low Water (England) and Mean Low Water Springs (Scotland). The same would occur if the potential Marine National Parks did not include and have influence over the land that affects them. HMNPP has received a strong indication from members of the public that a Marine National Park should include land and islands that occur within its boundaries. Agriculture, Forestry Commission and all potential sources of polluters should be accountable to the Park Authority and the coordinating lead marine body.
In Scotland the role of the Park Authority is laid down by the Act. However the 25 members (extract from the Act) must be of equal proportions i.e. eight members from the Scottish Executive, eight members from local council and eight members from the general public/stakeholders, the 25 th member should be an independent chairman. An apparent failing currently voiced of the Loch Lomond National Park is the low representation (only five) of local, general members.
Allan Wilson, Deputy Minister for the Environment in a press release indicated that his preference would be a National Coastline Park. What is a National Coastline Park? Would it have jurisdiction over marine activities and if so to what extent? It appears to present a cheap, unworkable alternative to the Governments obligation of achieving its manifesto goals. Small local communities have already expressed a very real fear of being overshadowed by larger more populated areas and therefore have no real say in what happens within their own area. A National Coastline Park would only confirm their fears and important individual local issues would become overlooked (possibly destroying the very ecosystems that they are intended to protect) by what could only be a monstrous or ineffective single National Park Authority. Over 50% of Scotland is sea; this is a massive area, a coastline length probably exceeded in Europe only by Norway and its extensive fjordic systems. The length of coastline within the Clyde Coastguard area alone exceeds that of France! A single Coastline Park Authority would be destined for disaster from its conception and would never gain local stakeholder involvement, already identified as essential for the success of any National Park or conservation area.
To date there has been no development, only talk through consultation after consultation. Something tangible is urgently required in the first instance even if mistakes are made, these can be improved upon and / or rectified. There are many organisations that have vast amounts of expertise and would be more than willing to assist in forming the first trial Marine National Park e.g.HMNPP, and other local groups, NGO's etc.
Marine Conservation Society think there should be adequate protection of marine species and habitats through a network of well-managed marine protected areas and a duty of care on all bodies working in the marine environment.
SEPA state that protected areas have been identified which are designated under European directives as requiring special protection: examples include bathing waters, shellfish waters and areas identified for the protection of birds and habitats. Establishing a register of protected areas will help to ensure that the management of the relevant water bodies is geared towards achieving the protected area objectives.
Loch Lomond and the Trossachs National Park note that the document makes no mention of the Loch Lomond and The Trossachs National Park. The Park has 63 km of marine coastline extending to the low water mark, around Loch Long, Loch Goil and the Holy Loch. This National Park should be listed in the table of designations in section 8.6.2. The Park Authority is also the planning authority and has responsibility for producing the local plan for the Park. They believe that the tables in sections 4.1.4 and 4.2.5 should refer to the Park Authority alongside the references to local authorities.
Water Framework Directive ( WFD)
SEPA writes at length on implementation of WFD. The WFD requires the use of a new planning system, River Basin Management Planning ( RBMP), to develop and set out activities to assess, monitor, protect, improve and manage the water environment. The Coastal Forum Strategy needs to be compatible with, and complementary to, the RBMP framework. The RBMP approach will seek to make best use of existing and efficient means of communication and engagement with stakeholders and communities. SEPA recognises the value and potential of coastal partnerships and intends to have coastal management groups, such as the Scottish Coastal Forum ( SCF), represented in the national and area advisory groups. A network of advisory groups will assist with the integration and co-ordination of sectoral interests. Forth Estuary Forum say a project for a national organization of local partnerships would be to engage in discussion with SEPA in the delivery of the Water Framework Directive community consultation.
RSPB Scotland state local and national coastal partnerships are crucial to the delivery of the Water Framework Directive, which establishes a framework for community action with the aim of improving water quality, protecting and enhancing the status of aquatic ecosystems and promoting sustainable water use. In Scotland, WFD is delivered through the Water Environment & Water Services (Scotland) Act 2003, which will allow public participation in River Basin Management Planning via national and area advisory groups. Local coastal partnerships have a major role to play in this process, due to their years of experience and expertise in local area management. It is therefore crucial that the national strategy provides local coastal partnerships the support and security they require to contribute to these processes. Activities and plans of existing catchment initiatives could prove to be a useful tool for identifying significant water management issues, and existing best practices could be used to establish an effective and workable programme of measures to improve water quality.
Ayrshire Joint Structure Plan and Transportation Committee think that the Water Framework Directive, which covers coastal waters out to 3 nautical miles, is underplayed in the Strategy despite relevance to the process. The Crown Estate also believe that there is not enough mention made of the Water Framework Directive ( WFD) and the changes this will have upon the management and use of Scottish rivers, estuaries and coastal waters. They hoped that this strategy would have addressed the topic in greater detail and highlighted the scope for the SCF, and the local firth based fora, in disseminating information and raising awareness of the Directive in Scotland. The Robert Gordon University writes about WFD objectives and how they are related to the strategy.
Climate Change
Scottish Natural Heritage think the strategy does not adequately address the maritime (especially coastal) implications of climate change. Although mentioned periodically in the strategy, nowhere is there significant coverage of this critical issue, nor is there much mention of the strategic approach that is required to plan for the likely changes. Section 1.2 Bullet 6 should be amended to refer to climate change, as storms and inland flooding may be at least as important as sea level rise in some coastal locations. Section 2.9 (natural heritage) identifies climate change as a key management issue, but this is not picked up in the mechanisms section that supposedly addresses these issues. In Section 2.12 (coastal defence) the need for data acquisition to plan for climate change should be added to the issues list. The `key ways forward' section does not really address the over-riding problem of lack of co-ordination, direction and funding in this field in Scotland. South Ayrshire Council also think that our understanding of the potential effect of climate change needs to be improved.
Fisheries
Shetland Islands Council is fully supportive of the devolvement of fisheries management to the local level (Section 2.2). Building on the experience of the Shetland Shellfish Regulating Order, the Islands are actively developing proposals in respect of managing all its inshore fisheries. Such an approach should address most of the main issues facing this aspect of coastal use. Fife Council provides detail on Fife's fisheries and it is the Council's view that local management would be the best way to achieve sustainability. The Strategy's identification of regional management committees for representation of fisheries interests at local level, and to develop proposals for inshore fisheries management related to an eco-systems based approach and marine spatial planning is considered potentially relevant to and supportive of the position in Fife. Scottish Fishermen's Federation writes at length on regional management committees. Marine Conservation Society writes about Inshore Fisheries Management Groups for managing inshore fisheries. FRS Marine Laboratory think coastal management forums should be encouraged and supported to help develop and reinstate environmentally sustainable fishing methods (small scale, labour intensive etc, etc.).
West of Scotland Fish Producers Organisation say the strategy does not reflect the true situation with fisheries, and they go into detail about quotas and their effect on the size of fleets. The main problems for the fishing industry are not as described in the Strategy, they are the incompetence of the EU and lack of support for our industry from the UK government.
Ian Burrett says 5 species have disappeared in south west Scotland's waters since 1988, and 10 that were abundant are now rarely caught. Quotas on cod stocks have failed to stop the decline so something more radical has to be considered. He vouches for the sea angling industry. He is concerned about the knock on effect of wiping out any particular species, with problems sometimes occuring decades later. COAST think there must be a body not dominated by fishermen who can make decisions to ensure sustainable fishing.
Hebridean Marine National Park Partnership think the Common Fisheries Policy plainly fails our marine environment. To ensure both the future of our threatened species and coastal communities utilising the seas resources, bold actions concerning the most destructive forms of mobile-gear fishing, dredging and pair-trawling, need to be made now. The use of mono and bi-filament nets account for unacceptable by-catch levels which regularly kill species protected under various forms of legislation e.g. dolphins, porpoise, seals and sea birds. Restriction to these destructive forms of fishing would allow for seabed rejuvenation and a reduction in by-catch. This would provide habitats for an explosion of fauna, and more mature stock to develop, providing marine resources which could then be maintained sustainably. In most cases this would not mean job losses but a slight displacement of activities. However compensation must be available to those incurring financial loss as a result of these actions. Full protection to our local fishing fleet must be given priority over vessels foreign to the regions. They also ask will the recommendations released within the recent Royal Commission on Environmental Pollution be addressed?
Kate Johnson thinks the commercial fisheries section on page 15 is unnecessarily downbeat and pessimistic about Scotland's fisheries. Offshore demersal fisheries are indeed in a bit of a mess but pelagic and coastal shellfish fisheries are stable and profitable. The Prime Minister's Strategy Unit report (Net Benefits May 2004) highlights the potential for significant growth in the shellfish fishery sector. 62% of Scotland's fishing employment is in the coastal zone and most in the inshore (0-6 miles). East Lothian Council remark that benthic trawling, known to cause extensive damage to marine biodiversity, is not mentioned as an issue.
Aquaculture
Shetland Islands Council say a number of the issues highlighted in this section have been addressed in Shetland as industry development has taken place under a local legislative umbrella (the Zetland County Council Act, 1974) that allows local management and policies to be applied. As such the intention of giving all Scottish Local Authorities similar local management control is supported whilst noting that this will not be a panacea for all the issues and concerns that surround the industry.
Scottish Quality Salmon write about the Strategic Framework for Scottish Aquaculture. SEPA write about zoning and the role of local authorities, and treatment of production wastes. FRS Marine Laboratory comments on management mechanisms, monitoring and planning for aquaculture. Association of Salmon Fishery Boards write in detail about the economics of aquaculture, spatial and management decisions regarding environmental impacts and problems for the West coast industry.
The Crown Estate writes about the fin-fish Location/Relocation Working Group and a marketing and branding campaign. Also, formal transfer of the planning function for marine aquaculture development to local authorities will clarify the planning arrangements and move the current voluntary scheme onto a proper statutory basis. It is hoped that this can be achieved as soon as practicable. Marine Conservation Society thinks expansion should be halted until planning can be extended to local authorities. They write about appropriate sites, labelling and best practise.
Hebridean Marine National Park Partnership think aquaculture has and is developing more and more environmentally friendly practices. There is no place for complacency and further actions still need to be addressed. Due to the fragile state of the aquaculture economy further assistance should be supplied by government and commercial retail outlets in ensuring that the industry becomes fully sustainable. The industry must explore and expand into different arenas such as farming herbivorous fish and utilise polyculture. The use of chemical treatments for targeting sea lice requires careful monitoring because other food web fauna, such as copepods are also affected.
Royal Yachting Association think that to aid navigation, finfish or shellfish farms should be clearly marked with buoys so they can be avoided. Information on the precise location and type of aquaculture developments should be disseminated to recreational boaters through appropriate means including Notices to Mariners and to editors of the relevant Pilots and sailing Directions. They provide a 'check list' to ensure that the available information and needs of recreational boating interests are adequately considered in the planning stage for new Aquaculture developments.
Oil and Gas
Marine Conservation Society believes that the section on oil & gas is a bit weak. Although it covers many of the key issues and MCS is pleased to see it cover the issues of infrastructure and decommissioning, it does not include any firm proposals. The SCF, in its terms of reference, was meant to "monitor developments in the oil & gas industry, exploration, production, decommissioning and disposal, especially near-shore" and we wonder whether the forum or officers have had the time and resources to do this. With the largest oil & gas find in over twenty years, recently having been discovered in the Moray Firth, MCS would have thought more research would have been undertaken and hoped that further liaison with the DTI, JNCC and the oil & gas industry might have occurred to inform this section.
Fife Council state that there is a significant amount of coal in rocks below the coastal areas of Scotland. In situ gassification has been suggested as a means of exploiting these deposits and could impact on Scotland's coastal areas.
Aggregate and Mineral Extraction
FRS Marine Laboratory think it must be recognized that should aggregate extraction become a significant industry in Scotland it will, as it is in England and Wales, be a well regulated marine industry. The fact that we have no current extraction industry is based more on economics rather than our "inability" to manage, regulate and monitor the industry.
SEPA states that in future, any proposals for marine aggregate extraction in estuarine or coastal waters (out to three nautical miles from territorial baselines) will require taking into account their potential effects on the ecological objectives of the River Basin Management Plans.
The Crown Estate say there has been a considerable amount of work done on recolonisation of the seabed once dredging stops. Timescales for recovery vary depending on a number of factors, the most important being the intensity of dredging, the type of habitat and the physical conditions at the dredging site. More work is being done but on the presently available information, recovery times range somewhere between a few months to more than 10 years. All applications to extract marine aggregates are thoroughly checked for the potential to impact the coastline. The fundamental assumption underlying the current system is that, if the studies suggest any impact, then the application is refused. As well as the individual application the studies also look at in-combination effects with existing licences and other activities.
Marine Conservation Society writes at length on the impacts of marine aggregates extraction. The Scottish Executive would be most forward thinking if it's policy was to prevent the future development of the marine aggregate extraction industry in Scotland. Alternatives to aggregates should also be researched and recycling of existing building waste occur.
Power Generation
FRS Marine Laboratory states that whilst the development of renewable energy sources will pose new issues to Scotland, very few will in the long run be truly problematic. The main issue is unlikely to be the "environmental impacts" it is more likely to be resolving/minimizing conflicts of interest.
The Crown Estate state that since the publication of the strategy document the Scottish Executive has announced its strategy for a Strategic Environmental Assessment for the Scottish coastline. They welcome this comprehensive and systematic approach to the development of offshore renewables in Scotland. The SEA process will need to collect scientific data and information and identify data gaps therein, and they would hope that there will be an open and free interchange of data between this project and the other marine environmental initiatives presently operating in Scotland. Much of this work, especially the identification of data gaps, will also be of use in underpinning ICZM in Scotland. They also welcome the formalisation of the Energy Act (2004) and its creation of a Renewable Energy Zone beyond 12 nautical miles. They hope this will facilitate industry developments when the technology is suitably developed to allow the industry to operate in the `deep water' conditions further offshore.
On 2.6, Ayrshire Joint Structure Plan and Tranportation Committee supports a localised consents procedure for energy generation projects within 12 nautical miles. This will ensure an accountability to those likely to be affected by the proposal. However, as the number of forms of renewable energy installations increases, from not just wind power but to tidal and wave power, it is important that guidance is issued by the Scottish Executive to ensure that local planners are informed and able to make the correct decisions. As mentioned earlier it is slightly unclear why for energy generation installations the mechanism of ICZM is proposed rather than marine spatial planning, as is proposed for marine fish farming.
Argyll and Bute Council would also concur with the view expressed within the Strategy that there is a need for localised planning consent procedures for energy generating projects on the coast and installations in inshore waters within 12 nautical miles ensuring that communities affected most directly by development can have a say in what happens in their coastal and marine environment.
CBI Scotland state that regarding a localised consents procedure for projects in inshore waters within 12 nautical miles, they fully support the principle of local involvement but are worried that if it is taken too far it will threaten the Executive's ambitious targets for renewable energy generation. Serious deficiencies in the planning regime are already a source of great concern for the business community. They would not wish to see marine power generation schemes subject to the same planning difficulties and delays as many on-shore business and commercial developments suffer. It may, therefore, be sensible to continue to use the 1989 Electricity Generation Act, which does give local communities and authorities a genuine input.
Fife Council writes at length about potential for offshore developments and the potential for a power technology industry in Fife.
Marine Conservation Society disagrees with the following statement in the SCF strategy regarding wave and marine current technologies: "Once these technologies are proven - and they could be much less intrusive than both onshore and offshore wind turbines - a wide range of subsea locations around the coast may become feasible for energy generation." Marine current turbines and wave machines will be just as intrusive in the marine environment as wind turbines on land if not more so. The potential impact of marine current turbines and wave machines is an area which to date has received no research by government bodies. MCS recommend that the Scottish Executive, JNCC or SNH urgently commission a study into the potential impact of these technologies. In particular will marine current turbines adversely alter the very nature of tidal rapids - which are priority BAP habitats?
Natural Environment Research Council note some of 8.10.3-6 is out of date. The Renewables Atlas has been completed and published by DTI (8.10.3 first bullet, 8.10.5 third bullet, 8.10.6 end).
Ports and Marine Transportation
British Ports Association notes that towards the end of Section 8.9.2, the Strategy states that "Although national planning for ports has not been government policy for many years, the strategy should consider the existing port facilities within Scotland and make recommendations regarding development." They believe these two statements are in conflict; they simply do not see how governments can start to make recommendations concerning port development when it acknowledges in other parts of the Strategy that ports are market driven and need to be able to respond flexibly and quickly to market changes and demands. The proposed developments at Hunterston and Scapa Flow are examples of this. This section also seems to be in conflict with Section 2.7 where the list of priority elements of a coastal management framework in relation to ports and marine transport are all ones which they can fully support, for example, more efficient mechanisms for processing port development and re-development proposals.
Associated British Ports Ayr and Troon echoed this. They say a major concern of the use of marine spatial planning is that it will result in the creation of a national ports' policy by the back door. This is unacceptable to an industry, which exists in a commercial world where the demands of the market dictate the development of our business. Indeed, we believed that this market-driven aspect of our industry had been acknowledged elsewhere within the Strategy. The first bullet point in Section 2.7 explicitly states that a priority element of a coastal management framework to deal with ports is the flexibility "to allow ports to decide their own structures in response to their own markets". We suggest that the strategy revisits this aspect of its proposals.
They welcome the statement that "It is important that ports retain the flexibility to expand" as this is clearly fundamental to their business. They also welcome the acknowledgement that "assessing the need for land claim should be included as an option" but they have some concern that there is no credit given to ports which are already considering how to minimise any adverse environmental effects that may be caused by development proposals. There is no recognition that ports have long been working to provide compensation and mitigation measures as an integral part of development and expansion and they feel that this is an unfortunate oversight.
Fife Council writes at length about the Rosyth. The Crown Estate wrote that although ferries were mentioned in the document they were surprised that there was nothing describing the establishment of commuter ferry services in the Firth of Forth. As there has been a considerable amount of work undertaken on the feasibility of such infrastructure services they thought this area should have been discussed.
Recreation and Tourism
David Ainsley says the strategy rightly points out that wildlife tourism is a globally competitive market. The most important step to address is that tourists must have something to see! We have witnessed a worrying decline in our local marine environment over the years. Also, one of the most important attractions to wildlife tourists is the perception of wilderness. Fish farms should not be sited in areas of conservation and landscape importance.
The Crown Estate would like to see greater emphasis placed on the importance and significance of tourism and recreation at the coast because it helps to raise the profile of Scotland's hugely diverse marine landscapes and ecosystems. Hebridean Marine National Park Partnership say tourism is a growth industry on which many rural areas depend for revenue. This expansion requires careful monitoring, encouraging true eco-tourism and not mass tourism in vulnerable areas. Sportscotland make a number of points about wording in the strategy, and thinks there is a need for research into sport and recreation at the coast.
Scottish Water states that the seasonal nature of much of the tourism industry presents particular challenges in providing water and wastewater services, owing to the different demands on the infrastructure at key points throughout the year. Promoting new tourist development must be tied with considerations of the utility infrastructure, and steps taken to highlight the importance of liaison with the water industry when considering new developments. Moreover, the establishment of new areas for "national level" facilities in the marine environment must consider the potential impact of other drivers (recreational waters, bathing waters etc) that may subsequently apply. Scottish Water's funding regime (Scottish Executive owned Quality and Standards process) will require that investment is programmed many years ahead of the time when it is required to be delivered.
Royal Yachting Association consider that there is little recognition given in the paper to the important role of leisure boating on our coasts and the urgent need to provide and protect facilities for what is an ever growing, inclusive and diverse recreational activity. They go into detail about the recreational boating industry and are committed to a planning and environmental strategy for sustainable boating, Boating for Life, in which the fundamental aim is to work with stakeholders towards the sustainable use of the UK's coasts and inland waters. They also write about navigation, anchorages and moorings.
West Highland Anchorages and Moorings Association are very disappointed that there is virtually no mention of leisure boating in the strategy. Leisure boating is a multi-million pound business in Scotland, at least of the same scale as aquaculture, and should certainly feature in a significant way in any strategy for our coasts. While the Annex includes a section on Marine Aquaculture, the section on Tourism and Recreation has really nothing to say about leisure boating. This is a most unfortunate oversight and they hope some sensible input on boating can be included. Fife Council also think there is a lack of reference to recreational sailing in Section 8.11 Tourism and Recreation.
Sportscotland states that lack of facilities and recreational infrastructure, such as path networks, interpretation and access point to the sea, can be an issue. The development of path networks may be positively addressed through the implementation of the Land Reform (Scotland) Act. Shetland Islands Council notes that in regard to Recreation and Tourism (Section 2.8), the Strategy refers to a lack of facilities in relation to footpaths and cycleway routes but that proposed core-paths under the Land Reform (Scotland) Act 2003 will help address this. It should be noted that there is no requirement under this Act for the provision of interpretation. The 'core-paths' identified by the Council, as part of its duties under this legislation, may not include coastal routes. The Strategy assumes that the Land Reform (Scotland) Act will address the lack of infrastructure and this is wholly speculative. There may well be coastal routes that are core-paths but the lack of infrastructure will continue. Scotways writes about a list of access issues near the coast.
Solway Firth Partnership note that although landscape/seascape is mentioned in part in reference to a number of topics listed in the sector analysis, it is felt that this is one of Scotland's most valuable assets, and as such warrants inclusion as a separate sector with its own set of actions and identified appropriate management mechanisms.
East Lothian Council writes that there is no mention of conflicts between different recreational activities.
Marine and Coastal Natural Heritage
FRS Marine Laboratory feel there are a couple of misinterpretations in section 2.9, the polluter pays principle is pretty much central to regulating developments on the coast and SEA's are already in place for the oil and gas sector and are planned for renewables within the 12 nm zone. It should be noted that the Water Framework Directive as is transposed through the Water Environment Water Services (Scotland) Act will add a new dimension to the assessment of the impacts that coastal developments may have on the marine environment. Also, at section 8.6.3, the key issues should include the potential multiple use of coastal areas, i.e. aquaculture, fisheries, tourism and conservation. This will lead to a combination of threats and pressures which when seen individually are not an issue but when combined could result in real problems. Techniques are required for improved data gathering and assimilation in the near coastal areas, especially the 0-10 m water depth range. They also write about locational guidance.
Marine Conservation Society support under Annex 1 the bullet to 'Develop a suite of marine protected areas for Scotland building on current work in this field.' They are however disappointed that this point is omitted from the text of section 2.9 and to the seemingly low priority given to the marine and coastal natural heritage. In November this year the Nature Conservation (Scotland) Act came into force fully. Part 1 of the Act states that 'It is the duty of every public body and office-holder, in exercising any functions, to further the conservation of biodiversity so far as is consistent with the proper exercise of those functions.' Since the Act applies out to 12 nautical miles, marine biodiversity should be considered a strand throughout every section of the Scottish Coastal Forum Strategy for Scotland's Coasts and Seas.
Cultural Heritage and Archaeology
The Crown Estate state that this section mentions the potential impacts to coastal archaeological sites from natural and anthropogenic influences but does not consider the potential impacts on submerged archaeological landscapes / archaeology. There is a passing note of the Valletta Convention yet no discussion of the impacts that the convention will have on coastal development and offshore activities. Further, there is no mention of the work of the Joint Nautical Archaeological Policy Committee ( JNAPC) which is working to develop best practice with regard to marine archaeology and marine commercial activities.
Military
FRS Marine Laboratory state that no mention is made of the fact that the testing of military equipment in the marine environment, where ranges are managed by Qinetiq in particular, now requires a licence from the Scottish Ministers under the Food and Environment Protection Act 1985. Scottish Natural Heritage say the issue of grazing management is not mentioned. On some coastal MOD sites under-grazing is leading to reduction of conservation value through scrub or bracken encroachment.
Small changes in the way we perform everyday tasks can have huge impacts on Scotland's environment.
Walking short distances rather than using the car, or being careful not to overfill the kettle are just two positive steps we can all take.
This butterfly represents the beauty and fragility of Scotland's environment. The motif will be utilised extensively by the Scottish Executive and its partners in their efforts to persuade people they can do a little to change a lot.