Facilitating marine nature restoration through legislation: consultation

Part 1 – Registration process for marine nature restoration projects

Overview

In this section we will set out proposals to introduce a registration process for marine nature restoration projects, instead of having to apply for a marine licence. We will start with a general introduction as to why we think such a process is needed, and how it would hopefully help projects overcome some of the challenges they are facing. Following that are a few subsections that set out more details on how a registration process could work, with questions on specific aspects of the proposals. Then at the end of the section there will be questions on the proposal as a whole and whether you think this should be taken forward, to ensure you have had a chance to look at the detail before answering.

Introduction

There is a growing interest around Scotland in undertaking nature restoration projects in the marine environment. Scotland is unique among the devolved nations in that the vast majority of restoration projects currently taking place in our waters are community-led.

Community groups and other restoration stakeholders have raised concerns over the last few years that the regulatory environment - the permissions they need to undertake restoration - is complex, difficult and costly to navigate. The proposals set out in this consultation were developed in response to these concerns, and address one aspect of that regulatory landscape in particular: marine licensing.

As we have set out in the general introduction to this consultation, we are conscious that marine licensing is only one part of a jigsaw of licences, permits and consents needed by restoration projects. The number of restoration projects taking place around Scotland is currently still quite small. While this new sector needs to grow to help meet outcomes in the Scottish Biodiversity Strategy, we do not think a total overhaul of the entire regulatory system is a proportionate approach at this stage.

Marine licensing is the main element we think we can reasonably address in the short to medium term, while maintaining environmental safeguards, and will enable the restoration sector to grow in the marine environment. There are existing powers to establish a registration process in the Marine Scotland Act 2010. Under Section 33 Scottish Ministers may by regulations provide that licensable marine activities which fall below a specific threshold of environmental impact do not need a marine licence but are instead to be registered. Our intention is use this model to provide for a tailored registration process for marine restoration activity. A registration process would not just cover activities which are currently marine licensable activities, but also restoration activities which currently do not require a marine licence.

The purpose of this consultation is to understand whether a registration process for restoration projects is desirable and workable. In particular, if it would simplify rather than add complexity, and whether it would better support restoration projects while maintaining environmental safeguards.

Outline of the proposal

What are we proposing?

We are exploring whether it is feasible to establish a registration process for restoration projects that fall under a threshold of environmental impact. For those projects under the threshold this would replace the marine licensing process (where applicable) for their restoration activity or activities.

Currently projects may have to apply for a marine licence, or licences, if they undertake any construction like an artificial reef, or use a boat to deposit something on the seabed, for example oysters or bags of seagrass seeds. This applies no matter how big or small the project is, and whether or not it is likely to have a negative environmental impact. To avoid the costs and time involved in a marine licence application, some projects choose to instead undertake activity by hand, wading in from the shore, which can hinder their ability to develop and scale up. It also means we do not have very good oversight of where restoration is happening.

With a registration process, a threshold of likely environmental impact would be set out via secondary legislation. Projects that go over the threshold will still need to apply for a marine licence, but projects under the threshold(s) could instead register their activity, through a simpler process. At the moment, we are only consulting on the powers which would allow us to develop this approach. So while we do set out our current thinking about how a threshold of environmental impact might be set, this would be subject to a separate consultation process in future.

How would a registration process work?

A restoration project would need to be registered and provide information like the location and extent of their project, what restoration activity is being undertaken with what methods, and whether biosecurity measures are in place. A project would have to be registered before putting anything physically ‘in the water’, which is similar to when they would have to apply for a marine licence.

We intend that this would be a mandatory self-declaration process. It will be the responsibility of restoration projects to ensure they are under the threshold to be able to register. There would be no application or decision from Scottish Ministers or a other public body to ‘approve’ the registration. However, carrying out restoration activities over the threshold of likely environmental impact without a marine licence (i.e. registering a project which should instead be subject to marine licensing) would be an offence and subject to penalties.

We would develop the detail of the threshold in secondary legislation, and work closely with restoration groups, nature conservation bodies and other marine users to ensure this is set at a level that is easy to understand, but also meaningful in terms of preventing environmental harm. We would make guidance available to help projects understand when they might be over the threshold. We set this out in more detail under ‘Threshold(s) of environmental impact’ further on in this document.

We propose that there would be a mechanism post-registration enabling Scottish Ministers to intervene if they had or were made aware of concerns about a project. This could cover a range of scenarios. For example: if they became aware that a project was not operating according to the information provided at registration, was causing environmental harm (even unintentionally), should have applied for a marine licence or licences, or poses a significant navigational, human health or biosecurity risk.

Projects that go over the threshold would not need to register as they would be required to apply for a marine licence if they undertake marine licensable activity. We expect that many projects may start out small and grow over time, and the registration should allow for registrations to be updated by projects. If a project expands over time to the point of going above the threshold of environmental impact, they would have to apply for the necessary marine licence or licences at that point. We would set out in more detail and consult on how the link between the registration and marine licensing processes would work in the secondary legislation.

What is restoration?

Restoration activity takes place in many different ways. Generally a distinction is made between ‘active’ restoration: (re)creating new or lost habitats and reintroducing species; and ‘passive’ restoration which can include pressure removal like cleaning up marine litter or improving water quality. The proposals in this consultation are aimed at ‘active’ restoration projects, which typically undertake things like native oyster restoration and seagrass planting. We anticipate further species and habitats will have potential for restoration as methods and technologies evolve.

The reason these legislative proposals are targeted at restoration projects making ‘active’ interventions is that these generally may require marine licences (and other permits), and would benefit from easing the administrative burden resulting from this. This is not to suggest that ‘passive’ restoration is not in itself a very beneficial approach to restoring and protecting the marine environment.

Potential impacts of restoration on the environment

While the aim of marine nature restoration is to benefit the environment, there is the potential for unintended consequences. As these are typically projects that actively cause changes in the marine environment, there is a risk of negative environmental impact as well as positive effects. We need to strike a balance between enabling restoration to take place and making sure the marine environment is not harmed in the process.

A registration process would enable us to have a better overview of where restoration is taking place while also reducing the regulatory burden. It recognises that while the intentions behind restoration are good, we need to guard against negative side-effects, which is why we propose the use of a threshold of environmental impact to ensure we can maintain appropriate environmental safeguards.

Protecting restored areas

In Part 2 of this consultation, we set out proposals to extend existing Marine Conservation Order (MCO) provisions so they can be applied for the protection of habitats and species that are undergoing or have undergone restoration. Marine Conservation Orders are comprehensive and flexible tools which can be used to restrict potentially damaging activity to protect particular habitats or species in particular locations. The full detail of this proposal is set out in Part 2. However, it is worth noting here that while we envisage that MCOs could be applied on the basis of information submitted as part of the registration process or through marine licensing, this would not be an automatic process. Registering would not ‘entitle’ a restoration project to protection through an MCO. All MCOs are, and will remain including for restoration, a tool applied by Scottish Ministers if considered necessary, subject to public consultation, and based on advice from NatureScot.

How would a registration process make things easier?

All restoration projects that fall under the environmental threshold would have to be registered. If the project includes activities that are marine licensable activities, the registration process would replace the requirement to apply for a marine licence, and the project would also not have to conduct a pre-application consultation and comply with public notice requirements. This would, for example, enable such projects to carry out an activity from a vessel - especially small-scale activities to trial or test methods and viability of their siting and approach – providing the threshold of environmental impact was not reached.

This approach would mean that restoration projects which do not involve marine licensable activities – for example because they place oysters or seagrass by hand rather than using a vessel – will also need to register. This will help improve our oversight of where restoration activities are happening, while ensuring that there is not a significant regulatory burden on such projects.

Non-legislative measures to support restoration

Exploring legislative solutions is not the only route through which we are looking into how we can better support communities and groups interested in undertaking restoration in their local area. As noted in the general introduction to the consultation, the Scottish Biodiversity Strategy Delivery Plan already includes a commitment to develop a plan for coastal and marine restoration through prioritisation of habitats and locations.

Scottish Government and bodies like NatureScot are continually working to provide and improve guidance and information available to groups interested in restoration, on how to undertake restoration and how to comply with regulatory requirements. Restoration is also a relatively new and pioneering sector to us as regulators, and we will learn more and improve awareness of regulatory requirements as the sector matures.

The Scottish Marine Environmental Enhancement Fund (SMEEF) supports restoration projects across Scotland through grants from private sector donations and public sector funding. SMEEF also provides information and resources to help restoration projects and raise awareness of what is involved in undertaking restoration.

These are all important support mechanisms which will continue to be developed alongside any legislative measures.

Proposal details and questions

Definitions of marine nature restoration and who would be able to make use of a registration process

A key question surrounding the implementation of a registration process is who would be able (or not) to use such a process. As a general principle, we want to prevent creating a regulatory loophole for commercial operations to carry out for-profit activities under the guise of ‘restoration’. However, we are conscious that some restoration projects operate, or may wish to in future, a mixed model of non and for-profit activities to generate self-sustaining funding. We want to support innovative models to fully realise the potential of restoration projects to provide jobs and generate income in coastal and island communities. There is therefore a need to explore where to draw the line in legislation between what can be registered and what should remain subject to the licensing requirements as they currently exist.

We would also need to be able to define what we mean by marine restoration. There are several definitions of marine restoration in the public domain which could form a basis for framing a definition of marine restoration and what activities projects can register, with further details being provided in secondary legislation.

The Society for Ecological Restoration (SER) characterises restoration as an “intentional activity that initiates or accelerates the recovery of an ecosystem with respect to its health, integrity and sustainability” and describes it as “the process of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed. Restoration seeks to initiate or accelerate ecosystem recovery.”

NatureScot considers the term “restoration” to be applicable to projects entailing a high level of intervention. Such as those rebuilding a habitat or reintroducing an ecosystem engineering species to assist with enhancing a habitat into a location from which it has been extirpated and where re-establishment could not occur without assistance.

Outwith Scotland, Natural England states in their Marine and Coastal Habitat Restoration Principles that the “primary aim of restoration is to (re)create natural habitats and functions and enhance resilient habitat features or biotopes within a land and seascape. Requirements for repeated interventions and management should be minimised where possible by restoring underpinning natural processes and allowing them to function freely”.

Our preferred model for framing a definition in primary legislation is a combination of the NatureScot and Natural England definition of restoration as involving high level intervention and habitat (re)creation outlined for framing, while further detail would be provided in secondary legislation.

Question 1

Do you think the example definitions provided are a suitable basis to frame a definition of marine nature restoration for the purpose of this legislation?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 2

Are there any other considerations or examples we should consider in formulating a definition for marine nature restoration?

Please provide examples and any information which you think would be useful to support your views.

What is being registered?

In addition to a general definition of marine nature restoration, we will need to specify what is being registered. In marine licencing, the key legal concept is ‘activity’ that is licensed, i.e. the depositing of something from a vessel onto the seabed, undertaking works or removing articles from the seabed. This can mean that a restoration project will require more than one marine licence, to cover different activities which are being undertaken. For the purposes of the registration process, we are instead proposing to use restoration ‘project’ as the key entity to which the registration applies.

This would mean that, provided they are under the threshold and thus do not need a marine licence or licences, activities being undertaken would be registered as a whole project rather than having to register for each individual activity undertaken. We would still expect that the registration would provide information on where restoration is being done, what habitat or species are being restored and what methods or materials are being used, but the registration can be entered and maintained for the project as a whole.

Registered restoration projects could range from very small areas focusing on restoring a single habitat or species, to much larger projects for restoring multiple habitats/species and a variety of methods. This potential for wide variation in projects means we do not think it would be appropriate for Scottish Ministers to implement (if considered necessary) a Marine Conservation Order to the project itself – this would need to be more targeted to the specific habitats or species under restoration as part of the project. More detail is provided on this in Part 2.

A description would be needed in legislation of what constitutes a marine nature restoration ‘project’. We want to gather views on how this could be done. There are several possible concepts that a definition of restoration projects could be anchored to for the purposes of this legislation, either individually or in combination. For example:

• Primary intent of the project: to benefit or restore the marine environment
• Commercial basis: use of the registration process could be restricted to not-for-profit activities
• Use of restored ‘assets’: restoration projects typically do not ‘own’ the features (habitat/flora/fauna) they restore (for example a seagrass meadow) and have no rights over the feature (for example to harvest the seagrass).

Question 3

Do you think registration should be based on the restoration ‘project’, rather than each individual ‘activity’?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 4

Please share any considerations you have in relation to tying the registration process to a ‘restoration project’ rather than each individual activity.

Please provide examples and any information which you think would be useful to support your views.

Threshold(s) of environmental impact

Setting a meaningful and workable threshold of environmental impact would be key to making a registration process viable. The detail of the threshold would be specified in secondary legislation and developed in further consultation with stakeholders. At this stage we want to gather views on how this could be done, as it is important that it will be possible to develop a meaningful threshold which maintains environmental safeguards without adding unnecessary complexity.

There are several approaches possible:

1. a threshold based on a single criterion, for all restoration projects;

2. a set of thresholds, or a ‘checklist’ of multiple criteria that address different elements of environmental concern, that applies to all restoration projects;

3. several thresholds for different types of restoration project. For example based on target species such as a threshold for native oyster restoration, and a different threshold for seagrass planting.

Thresholds of environmental impact under the proposed approaches could be set across a range of factors, and should be informed by best available evidence and advice from NatureScot. As noted, this would be subject to further consultation as part of developing secondary legislation.

Examples of environmental risk factors that could be considered include:

• scale of the restoration activity, for example up to a specified number of hectares or depth which is a simple but crude measure of environmental impact; and/or
• proximity or potential to affect sensitive/designated sites and priority marine features; and/or
• biosecurity, for example risk of unintended release of invasive non-native species (INNS), or transfer of pathogens and parasites; and/or
• restoration method, for example if using mechanised planting.

We think a threshold should be developed based on a few core principles:

• it should be meaningful in terms of reducing the risk of negative environmental impacts;
• it should be easy enough to understand for non-expert audiences looking to undertake restoration; and
• it should not simply replicate criteria for marine licensable activities and/or thresholds for pre-application consultation (PAC)

As noted, secondary legislation would also include further detail on how projects transition from registration to the marine licensing process if they develop over time and go above the threshold.

Question 5

Please share any reflections you have on how we could set appropriate threshold(s) of environmental impact.

Please provide examples and any information which you think would be useful to support your views.

In addition to the considerations above, we want to gather views on how we could consider and minimise navigational risks under a registration process. One way of achieving this could be that elements of a restoration project that could present a navigational risk, such as placing moorings, anchors or below surface mooring lines (for example through propellor entanglement) etc. should not be covered by the registration process. They would instead require a marine licence as under the current process. The detail of this would be set out in secondary legislation.

Question 6

Do you agree with the principle that placement of moorings/anchors, lines or other objects that may present a navigational risk (for example through propeller entanglement) should not qualify for registration, and should remain subject to current marine licencing laws, even if they are part of a restoration project?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 7

Please share any reflections you have on how we can minimise navigational risks under a registration process.

Please provide examples and any information which you think would be useful to support your views.

Administration of the process

As noted in previous sections, detail on how a registration process would be administered would be articulated in secondary legislation. However, we do think it would be desirable for Scottish Ministers to have the power to delegate administration of the process to an existing public body, for example a Statutory Nature Conservation Body like NatureScot. This would enable the registration process to tie in with other forms of advice, guidance and support that such bodies may already be providing to restoration projects.

Question 8

Do you agree Scottish Ministers should have the option to devolve the administration of a registration process to another public body?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Nature of the process

Based on discussions with restoration groups we currently think a registration process would work best as a self-declaration process, allowing projects that fall under the threshold of environmental impact to notify Scottish Government/the administrator via registering.

The alternative would be an approval/application process, however we do not want to effectively replicate the marine licensing process in a different format. At this stage, we want to gauge whether there is a preference to one model or the other.

Under a self-assessment process it would be the responsibility of the applicant to make sure their project is under the threshold of environmental impact. We would make available guidance to support this assessment, and would aim to make any environmental threshold easy enough to understand for non-experts.

A self-assessment process would not involve waiting times for a registration to be ‘approved’. We propose that there would need to be a way for Scottish Ministers to intervene post-registration if there were concerns about a project – see questions 15 - 17. However, the registration itself would be ‘automatic’ once an applicant submitted the required information. However, we understand that a self-assessment process could generate a degree of uncertainty about whether projects meet the registration requirements, as the person or group registering would have to work out for themselves whether they were over the threshold of environmental impact or not.

An approval/application based process would give the administrator of the registration – whether that were Scottish Government or a body to which the administration is delegated – greater control over who could register what. It would enable the administrator to assess whether a project was under the threshold of environmental impact and whether the information provided as part of their application was correct. In an approval/application process it would also be possible to attach tailored conditions to the registration, for example around what methods can be used for the restoration, siting of the project or monitoring requirements. The use of conditions is a common approach used in granting licences and permits. An application/approvals process could provide projects with more certainty about whether they are under or over the threshold. However, this would also make the process more involved, it might require a fee to cover the greater amount of resource needed to administer the register, and would make the process similar to applying for a marine licence. As this approach would apply to all restoration projects under the threshold it would potentially make the regime more onerous on the sector as a whole.

Question 9

Should a registration process be based on a self-declaration/self-assessment model or would you prefer an ‘approval/application’ based process?

Self-declaration/self-assessment

Approval/application

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 10

If you answered ‘approval/applications process’ for question 9, should the administrator of a registration process be able to apply conditions to the registration?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 11

Please share any considerations or concerns you have on the nature of the registration process and whether it should be based on self-assessment or approval/application.

Please provide examples and any information which you think would be useful to support your views.

Information provided in the registration and publication of the register

As part of the registration process, we propose that restoration projects would have to provide essential items of information, details to be determined in secondary legislation.

This information would at a minimum need to include the location and extent of the restoration project, the target habitats and/or species, details of the activity or activities being undertaken, what methods are used, and a contact address (email or postal) for enquiries about the project. We are exploring whether it would also be desirable to request information on how the project has considered aspects like biosecurity, monitoring of impact (positive and negative), navigational risk, and considerations about interactions with other sea users.

The purpose of gathering this information is two-fold. First, it would enable Scottish Ministers (or the administrator of the registration process) to check the information provided for a registered project as part of a post-registration intervention if concerns were raised about a project’s activity. For example Scottish Ministers might want to verify, if a concern is raised, whether a project is in fact under the environmental threshold. The information provided in the registration process and held in the register would be the first port of call to compare what was registered to what is happening in reality. We also think Scottish Ministers would need to be able to ask for the provision of additional information for this purpose.

Secondly, gathering and holding this information would improve oversight of where restoration activity is happening. This would help Scottish Government to better understand how restoration is contributing towards meeting our environmental targets and commitments. It would also allow Scottish Ministers to make decisions about whether a Marine Conservation Order (MCO) might be appropriate to protect habitats or species which are undergoing or have undergone restoration, as set out in Part 2 of this consultation.

We anticipate that the administrator of the registration process would need powers to share this information with other relevant public bodies, especially if they also have a regulatory role that touches on restoration work. This could include Scottish Environmental Protection Agency (SEPA), Fish Health Inspectorate, Marine Directorate Licensing and Operations Team, Crown Estate Scotland and NatureScot.

We also propose that at least some of this information would be made publicly available, to provide transparency and ensure that local communities, including other users of the sea, are aware of where projects are taking place. We are conscious that there may be issues around publishing data on the location of sensitive habitats and species. We would not intend to publish all information provided as part of the registration process, but basic information like location, type of restoration being undertaken and how to contact the project. The detail of this would be set in secondary legislation, but we want to gauge whether there are any particular sensitivities around making (some of) this information available.

Question 12

What are the key types of information you think projects should be required to provide as part of their registration? Please select all that apply.

Location

Activity being undertaken

Methods

Biosecurity

Monitoring

Navigational risk

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 13

Do you think the register should be made publicly available? By publicly available we mean published online.

Yes, all information

Yes, but only some information

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 14

Please share any concerns or considerations you may have with regards to providing information in the registration process and/or making information on the register publicly available.

Please provide examples and any information which you think would be useful to support your views.

Post-registration intervention and offences/penalties

As noted previously, we think that Scottish Ministers would need powers to intervene post-registration if there were concerns about a registered project. While restoration is undertaken with aim of restoring the marine environment, there is a risk of unintended and unforeseen consequences, especially as our marine environment changes and adapts in response to climate change and other pressures. While the registration process should be light-touch, there would need to be safeguards in place to ensure Scottish Ministers could still fulfil their duties to have due regard to environmental protection, human health and legitimate uses of the sea.

Scenarios in which Ministers or the administrator might wish to intervene could include:

• a project has registered but is undertaking restoration in a different location;
• a project is at risk of damaging the marine environment; or
• the project poses a navigational or other risk to human health.

To allow Scottish Ministers to intervene in such unforeseen circumstances we propose that Scottish Ministers should be provided with a broad power and discretion to intervene for any reason.

We also propose that Scottish Ministers would be able to amend, update or remove a registered project, for example if a project has ceased to exist without notifying the administrator.

Question 15

Do you agree Scottish Ministers should have a broad post-registration power to intervene and amend/update/remove projects from the register?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 16

Please share any comments you may have on instances where Scottish Ministers should be able to intervene post-registration.

Please provide examples and any information which you think would be useful to support your views.

Offences

We think Scottish Ministers would need powers to create offences, in order to deter misuse of the registration process.

Detail on the offences would be set out in secondary legislation. We consider the basic premise to be that registration would be mandatory, unless projects secure a marine licence for the associated activity or activities instead. In other words, it would be an offence to undertake restoration without either registering a project or obtaining a marine licence (if licensable activity is undertaken). There may be instances where projects know they will develop in a way that would take them over the environmental threshold fairly quickly, and may wish to apply for a marine licence from the start rather than register. We intend that this would be possible.

The Marine (Scotland) Act 2010 already sets a framework and upper limits to powers to create offences. For example under Section 33 Scottish Ministers are able to create offences in secondary legislation. These include the ability to provide that such offences be triable summarily or on indictment, and provide that offences would be punishable (on summary conviction) by a fine not exceeding £50,000 or (on conviction by indictment) a fine, imprisonment for a period not exceeding 2 years, or both. We consider these existing powers provide an appropriate model of powers and upper limits on the offences. This means penalties set in secondary legislation could be lower but cannot exceed these limits.

There are a number of scenarios which might arise in future and we want to ensure that there would be futureproof mechanisms in place to handle these. The main instances of non-compliance that would need to be dealt with are most likely to be scenarios where:

Scenario A

A restoration project is undertaking activity but has not registered.

Projects will have to register at the point of physically undertaking restoration, and Scottish Ministers will wish to specify that doing so without registering would be an offence (unless the project has secured a marine licence or licences instead).

Scenario B

A restoration project has registered but their activity is above the threshold of environmental impact.

This could mean that the project is undertaking a marine licensable activity (or activities) without a licence, in which case it could be dealt with through the existing mechanisms for dealing with non-compliance in marine licensing.

Scenario C

False information has knowingly been provided for a registered project.

This could coincide with any of the above scenarios, however Scottish Ministers may wish to specify additional offences to act as a strong deterrent to not misuse the process.

Question 17

Do you agree Scottish Ministers should be able to create offences and penalties in relation to the registration process?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 18

Do you agree with the limits we propose as a model for the framework and upper limits on offences and penalties?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Concluding questions for Part 1

In the preceding sections we have outlined how a registration process could work, and discussed some of the considerations that would need to be explored further as part of developing secondary legislation. Having considered these, we want to know if you are supportive of the proposals outlined in this part of the consultation.

Question 19

Do you support bringing forward legislation to enable Scottish Ministers to develop a registration process for marine nature restoration projects?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 20

Do you think a registration process would help to reduce the administrative burden on restoration projects?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 21

Do you think a registration process would help encourage more restoration projects to come forward and/or scale up?

Yes

No

Unsure

Other – Please explain

If you selected ‘Other’ then please use this space to expand on your answer.

Question 22

Please share any further considerations you have about the proposals as a whole.

Please provide examples and any information which you think would be useful to support your views.