2014 Consultation on the management of inshore Special Areas of Conservation and Marine Protected Areas - Consultation analysis report

23. Other Comments

23.1. General Comments

23.1.1. You Said

23.1.1.1. Several respondents included comments not directly related to the consultation questions. While these mainly related to background information on the organisation or individual, other points from these responses included specific issues or issues that apply to all of the areas under consultation.

23.1.1.2. Many respondents also restated or summarised points made at the various questions through the consultation.

23.1.1.3. Comments from environment / conservation respondents included:

• Support for MPAs.
• Disappointment with measures proposed as these are seen as being insufficient to provide the protection needed in the MPAs and SACs.
• That the proposals are not fit for purpose.
• The need for re-appraisal of some objectives and also of some protected features in order to ensure their conservation.
• Concern that proposals will not deliver site integrity.
• Support for environmentally sustainable fisheries.
• Support for precautionary approaches.
• Support for ecosystem approaches.
• The need to ensure an ecologically-coherent network.
• The need to consider cumulative impacts.
• The need for strategic planning and monitoring.
• That management approaches must be guided by scientific evidence and advice.
• The need for up to date, accurate data and economic, impact, cumulative and appropriate assessments.
• That 30% of Scottish seas should be 'no take' zones.
• That there is public support, especially on Arran, for the prohibition of dredging and bottom trawling within a 3-mile limit.
• The need for protection for particular species and habitats, particularly maerl, seagrass and the Common Skate.

23.1.1.4. A static fishing respondent commented that they had been excluded from workshops. This respondent felt that the proposed measures did not go far enough in order to "facilitate recovery of our inshore waters and the special features contained therein. The 'Band Aid' approach we believe is unlikely to produce any meaningful recovery of the marine environment". They also wanted to see re-instatement of the 3 mile limit on the West coast.

23.1.1.5. An inshore fisheries group wanted to see the review period for fisheries management measures set at no more than three years.

23.1.1.6. Comments from individuals included concern over the consultation process, described variously as: complicated; difficult to engage with; designed to discourage engagement; confusing; containing too many documents and that these were difficult to access and to interpret; badly publicised; forms that were not user-friendly; and badly conducted meetings. In addition there was concern that SNH had not attended one key meeting.

23.1.1.7. One individual outlined concerns over Atlantic salmon farms in some of the areas. This respondent saw these as negatively affecting the marine environment and questioned why they would be allowed near protected areas.

23.1.1.8. A public sector organisation said that any measures "must be underpinned by sound science and evidence to ensure that appropriate measures provide a clear environmental benefit" and asked that any measures required of them be "clearly evidenced and included in a future regulatory investment programme".

23.1.1.9. A recreation /tourism association commented:

• on the contribution made by boat owners to the economy;
• on the need to ensure freedom to anchor is not unduly limited;
• that numbers of leisure craft using anchorages is small and is, mainly, seasonally restricted;
• that some have no choice but to anchor due to weather and tides; and
• that the 'footprint' of cruising yachts is extremely light.

23.1.1.10. Several respondents thanked Marine Scotland for the chance to participate in the consultation and others looked forward to on-going engagement with Marine Scotland over the proposed management measures.

23.1.2. We Did

23.1.2.1. Marine Scotland have noted the concerns raised regarding the consultation process, and that most of these were generated from a single location.

23.1.2.2. It is unfortunate that no-one used the "comments and complaints" process set out in the Overview document. Had this been done we could have made changes during the consultation.

23.1.2.3. We acknowledge that the official publications should have had links between them, and back to the consultation hub page to make navigation for stakeholders easier.

23.1.2.4. For another consultation we have been trialling the use of "Citizen Space" which has been designed to improve the responder experience. The second management consultation will use this new platform and the normal routes in tandem. This gives responders a greater choice in how to respond. We will also publish the second consultation in a singular document.

23.1.2.5. The consultation public drop-in sessions were held at 14 locations throughout Scotland. The purpose of these sessions was to raise awareness of the public consultation and the proposed management measures. These sessions were advertised locally via radio and newspaper adverts and nationally in the 'Fishing News' paper.

23.1.2.6. Marine Scotland would welcome stakeholder views on how to improve public awareness of future consultation and related events.

23.1.2.7. The meeting that Scottish Natural Heritage did not attend was held in Mallaig on 16 January 2015. The weather was adverse and they were unable to travel from Perth and Inverness because of the conditions. These circumstances were outwith their control. Although Marine Scotland did make it we had a 7 hour journey home which is a good indication of the adverse conditions.