Scottish Crown Estate draft strategic management plan: consultation analysis

Appendix D: Wider Comments on the SEA

A respondent made a number of comments, as detailed below:

• Table 2 seeks to show the relationship between the Scottish Crown Estate Strategic Management Plan and other Plans, Policies and strategies but instead only summaries what these other plans, policies and strategies are with no reference to how the Strategic Management Plan will interact with them.
• Table 3: SEA objectives and assessment questions for each topic: The SEA Objectives for biodiversity, flora and fauna state 'and where appropriate enhance biodiversity'. We would argue that to enhance biodiversity it will be necessary in many instances to restore it first. In that case the Assessment Questions should include this in their scope and we suggest the questions be amended to:
  • Does the Plan promote the protection and where possible the restoration of designated and non-designated habitats and species?
  • Does the Plan promote the enhancement, connectivity and integration of natural, semi-natural and priority habitats?
• Population & human health: Add 'Will the Plan provide more opportunities for the public to experience and immerse themselves in nature?' Increasingly evidence shows us that there are immense mental and physical health benefits from immersion in the natural world.
• Water: Add 'Will the Plan contribute towards the restoration and enhancement of waterways?' Many waterways are degraded and this Plan should aim to restore waterways where possible.
• 2.3.7 – Preferred Objective/Priority/Policy (6) must have protection for biodiversity caveats in the plan. New marine developments will not necessarily be good for the environment and high carbon developments with community benefits may conflict with climate change targets. We would recommend a wider focus to protect and enhance biodiversity.
• 2.3.11 – Whatever model is in operation it must protect the biodiversity associated with the assets in question. This should be stated explicitly.
• 3.1.7 – Key pressures tables
  • There is no mention of impacts of windfarms (construction and operation and associated infrastructure) in the Biodiversity, Flora and Fauna section.
  • Aquaculture is mentioned but not the mechanisms by which it is a pressure to habitats and species.
  • Under Soil and Geodiversity no mention is made to the pressures caused by aquaculture on marine soils.
  • Under 'marine biodiversity' the impacts of climate change should also include the impacts of changes to the marine community as conditions become more suitable for some species than others therefore affecting the food-chain. An increase in severe weather may also have significant impacts on some marine biodiversity such as seabirds.
• Terrestrial biodiversity – The impacts of climate change are once again very narrowly defined. Climate change is having significant impacts on terrestrial biodiversity via synchronicity of prey and predator, impacts on habitats, extreme weather events and changing climatic patterns etc. We would suggest a more realistic assessment of these is included here using sources such as the State of Nature Report 2019 and IPBES report.
• Upland habitats have been, and continue to be, significantly impacted by sheep grazing.
• In 3.2.5 – the SEA states 'The Plan provides an opportunity to mitigate/positively impact coastal environmental processes and work for the mitigation of any negative effects.' However, the Plan does not specify measures for mitigating impacts to the marine environment.
• Chapter 5 Monitoring: We strongly believe that annual plan monitoring will need clear environmental targets, and this should be set out in the Strategic Management Plan based on recommendations from the SEA. His will ensure a level of consistency in sustainability across the assets.
• Currently, much emphasis is put on the 'Value Project' but little detail on what this actually is or how it will align social, economic and environmental 'value'. This is unhelpful at this stage due to the importance of this to achieving environmental and social wellbeing in particular. In the absence of this piece of work more information is required on how overall sustainability will be achieved and what will be monitored (i.e. environmental and social wellbeing targets) to assess this.
• 7.2 – Reference State of Nature 2019 and the IPBES report.
• 7.2.4 – There is no assessment of how Scotland is performing against the mentioned Scotland's Biodiversity Strategy and how the Plan will help.
• 7.2.17 – Can this Plan help and how?
• 7.4.7 – Can this Plan help and how?
• Maps: Why are proposed and candidate protected areas not included on the Biodiversity map when these sites are protected in the same way as a classified or designated site?

A respondent made a number of comments on the non-technical summary:

• The 'Key Pressures' on the Historic Environment stated on p12 are somewhat limited with a focus on historic buildings. It is suggested that the following addition ( - both the wider historic environment landscape and specific assets ) is made after 'Land management and development can impact on the historic environment and cultural heritage'.
• On p14 the last item ' Asset Managers should give consideration at the earliest stages to appropriate siting and design of new infrastructure in collaboration with community bodies where appropriate. (soil and geodiversity)' should include cultural heritage in the brackets.
• On p15 the second item ' Investment decisions at asset level should consider opportunities for enhancing the environment for the wider community benefit. (landscape and visual)' should include cultural heritage in the brackets.
• The following comments relate to the main body of the Strategic Environmental Report:
• On p32 it is suggested that the SEA objectives for 'Cultural Heritage and the Historic Environment' should read 'To preserve and enhance the historic environment including historic buildings, archaeological sites and other culturally important features.'
• In Section 3.1.3 on p33 designated assets within the historic environment and undiscovered archaeological resources are specified but undesignated assets and the wider landscape of the historic environment are not included. This provides a partial, fragmentary and biased representation of the historic environment.
• On p37 the 'Key Pressures' on the Historic Environment stated are somewhat limited with a focus on historic buildings. It is suggested that the following addition (- both the wider historic environment landscape and specific assets) is made after 'Land management and development can impact on the historic environment and cultural heritage'.
• Under the heading '4.13 Cultural Heritage' on p43. In section 4.13.3 mention is made of the impact on listed buildings and scheduled monuments in the following sentence 'Impacts on listed buildings and scheduled monuments are managed through the relevant consenting processes and the planning process influences the potential impacts of development.' This omits to address the protection of know and undesignated assets through the National Planning Framework and Scottish Planning Policy.
• In section 4.13.4 it is again only designated assets which are mentioned.
• It is appreciated that the statement in section 4.13.6 which states that the impact on the historic environment (designated, undesignated and previously unknown) must be assessed 'in relation to specific work being undertaken'. Only then can the impact on the historic environment be measured - this is potentially contrary to the 'minor residual negative effects' stated in 4.13.3 and 'residual effects... low in scale' in 4.13.4.
• In section 4.17.3 on p51, first bullet point - the item 'Asset Managers should give consideration at the earliest stages to appropriate siting and design of new infrastructure in collaboration with community bodies where appropriate. (soil and geodiversity)' should include cultural heritage in the brackets. The third bullet point on p51 'Investment decisions at asset level should consider opportunities for enhancing the environment for the wider community benefit. (landscape and visual)' should also include cultural heritage in the brackets.
• In section 7.8.9 on p80 reference should be made to the Historic Environment Records (HERs) held by Local Authorities which are the primary resource for information on non-designated sites. It is suggested that the words 'to local communities' are removed from the final sentence of this section.
• In Figure 21 on p99 the key on the 'Glenlivet rural estate and historic environment designations' is a misleading and partial representation of known sites within the historic environment as it only includes designated sites. Information about undesignated sites (information contained in HERs held by the Local Authorities) should be included.

A respondent made the following comment:

• Appendix B: Supplementary Environmental Baseline: Cultural Heritage - We welcome the discourse here on the Cultural Heritage baseline. However, we would note that the reference to the "35 Crown Properties" under Terrestrial Historic Environment is not factually correct as these sites were disponed in 1999 to The Secretary of State for Scotland.
• A respondent made the following comments relating to Q14:
  • 4.2.2 – We would strongly suggest using more recent information such as the State of Nature 2019, which contains specific information on the current condition of Scotland's nature.
  • 4.2.3 – We acknowledge that this is the case but to actually promote and achieve 'environmental wellbeing' the Plan must be more ambitious setting out best practice principles such as net gain, it should also go beyond mitigation and look at how assets can contribute to environmental restoration and resilience.
  • 4.3.2 – Note that 'International and national level policies and strategies aim to restore, protect and enhance the environment.'
  • 4.6.5 – Environmental damage should also be acknowledged i.e. add 'Under the asset management theme there is potential for negative effects where a local community body as new manager of an asset loses interest or resources to manage that asset or where significant environmental damage occurs or where environmental damage occurs regularly/continuously.'
  • 4.7.1 – Direct impacts are also equally likely such as direct mortality of seabirds from collision.
  • 4.7.6 – Strongly agree with this
  • 4.8.4 – This could also potentially have damaging impacts on environmental wellbeing unless this is considered from the outset and potentially damaging impacts mitigated for.
  • 4.9.2 – Mitigation could also commit to restoration/enhancement of soils.
  • 4.12.3 – It would be appropriate to include the restoration of peatlands here.
  • 4.15.4 – Any management of assets for natural capital benefits must first and foremost ensure the long-term sustainability of the assets in question and all known interacting biodiversity. Taking ecosystems, food-webs, competition, habitat and environmental safeguards into consideration.