Highly Protected Marine Areas (HPMAs): consultation analysis - final report

Annex 3: Campaign responses

This annex provides information about the two campaigns which provided templates or suggested text to be used in responding to the consultation. Copies of these campaign texts are provided below. Information is also provided on how the text has been allocated to individual consultation questions for the purposes of analysis.

Scottish Environment LINK^[15] campaign

This campaign provided a template response which individuals could submit to the consultation via a website. The response did not follow the structure of the consultation questionnaire. Table A3.1 provides details of how the content of the response has been allocated to the consultation questions for the purposes of the analysis. A total of 2,018 standard and 43 non-standard responses were received.

To: HPMA mailbox

Subject: Campaign to Create ocean recovery zones for Scotland’s seas

[Respondent name, postcode and email address goes here.]

Dear Minister,

I support the Scottish Government’s proposals to designate at least 10% of Scotland’s seas as Highly Protected Marine Areas (HPMAs). Evidence shows that such strict levels of protection can create ocean recovery zones, helping ecosystems recover and providing benefits to society including increased fish and shellfish populations and opportunities for sustainable fishing (1). Urgently restoring ocean health is vital if we are to reverse the interlinked climate and nature emergencies, safeguard our marine environment and secure resources for future generations.

I support the prohibition of all activities that remove or damage natural marine resources, or that dump materials and pollutants in the sea, within HPMAs and adjacent waters. I support access for recreation and cultural heritage within HPMAs as long as activities are well-regulated and low impact.

I support the general principles for selecting where HPMAs will be located and what they will protect. The chosen sites should include both healthy and degraded areas, and species and habitats that represent the full range of Scotland’s natural marine biodiversity. HPMAs should focus on providing site-based protection outwith the existing marine protected area network.

HPMAs must not simply be oases in a marine desert. Activities that damage marine species and habitats must also be better managed throughout Scotland’s seas, to prevent further degradation, for HPMAs to provide their full potential benefit to both people and ocean. (1)

Yours sincerely,

[Respondent’s name]

Table A3.1: Allocation of ‘Scottish Environment LINK’ campaign text to the consultation questions

Consultation text

I support the Scottish Government’s proposals to designate at least 10% of Scotland’s seas as Highly Protected Marine Areas (HPMAs). Evidence shows that such strict levels of protection can create ocean recovery zones, helping ecosystems recover and providing benefits to society, including increased fish and shellfish populations and opportunities for sustainable fishing (1). Urgently restoring ocean health is vital if we are to reverse the interlinked climate and nature emergencies, safeguard our marine environment, and secure resources for future generations.

Related consultation questions: Q1

Consultation text

I support the prohibition of all activities that remove or damage natural marine resources or that dump materials and pollutants in the sea within Highly Protected Marine Areas (HPMAs) and adjacent waters. I support access for recreation and cultural heritage within HPMAs as long as activities are well-regulated and low impact.

Related consultation questions: Q2

Consultation text

I support the general principles for selecting where HPMAs will be located and what they will protect. The chosen sites should include both healthy and degraded areas, and species and habitats that represent the full range of Scotland’s natural marine biodiversity. HPMAs should focus on providing site-based protection outwith the existing marine protected area network.

Related consultation questions: Q9 / 11

Consultation text

HPMAs must not simply be oases in a marine desert. Activities that damage marine species and habitats must also be better managed throughout Scotland’s seas, to prevent further degradation, for HPMAs to provide their full potential benefit to both people and the ocean.

Related consultation questions: Q7

Shetland postal campaign

This campaign provided a template letter which individuals could sign and send to the Scottish Government. The letter did not follow the structure of the consultation questionnaire. Table A3.2 provides details of how the content of the letter has been allocated to the consultation questions for the purposes of the analysis. The originator of the campaign is not known. Twenty-six (26) standard responses were received.

HPMA Policy Team

The Scottish Government

Area 1B North

Victoria Quay Edinburgh

To whom it may concern,

Please consider this correspondence as an individual response to the Highly Protected Marine Area public consultation currently being run by the Scottish Government, and closing on 20^th March 2023. I am submitting my response in this format, as opposed to the overly complicated online 'Citizen Space' portal, due to technical inability on my part — and trust that this response will please be accepted and duly considered in the same manner.

I am utterly opposed to the concept of HPMAs — with the associated consultation documents providing no scientific evidence as to the need for, or potential effectiveness of, banning fishing/aquaculture activity through HPMAs. Instead, these proposals seem to be driven by politics and pledges in the Bute House Agreement, rather than driven by any environmental or conservation imperatives.

Many of Scotland's rural and island communities rely on the socio-economic benefits brought by local fishing and aquaculture industries, to which the prospect of HPMAs is the single greatest threat. HPMAs appear to be yet another central belt vote winner, allowing Scottish Ministers to burnish supposedly environmentally friendly credentials, at the sole expense of Scotland's already fragile remote/island areas and fishing communities that rely on producing high-quality and low carbon food from the sea.

I would prefer that any government effort to protect the environment should aim to be compatible with the production of this low-carbon and nutritious protein, rather than threaten its existence.

The Scottish Government's ill-conceived commitment to designate 10% of Scotland seas as Highly Protected Marine Areas by the year 2026 seems extreme and overly ambitious. In contrast, UK Government proposals put forward 5 potential HPMAs covering only 0.53% of English waters. Please note that plans for one of those areas, around Holy Island/Lindisfarne, have now had to be scrapped in the face of community protest at the sheer economic damage it would have caused to the island through the effect on its fishing crews. There are lessons to be learned there by the Scottish Government, if it has the wit to do so.

In particular, fishing crews already face a substantial and growing spatial challenge at sea, including a rapidly developed Marine Protected Area network — which already protects the environmental features that could be impacted by different types of fishing activity. Adding unnecessarily to this spatial squeeze through the introduction of unevidenced HPMAs will only destabilise the economic viability of vessels - with terrible economic consequences for the families, supply chain businesses and wider communities who rely on them and their crews for employment and income.

I believe that the Scottish fishing industry has proven in the past that they are not opposed to sensible conservation measures, recognising that strong fish stocks and healthy marine ecosystems are in their own interest — and in the wider interest of sustaining their fishing communities. However, nothing about these HPMA proposals are sensible and — for the sake of my whole community — I would urge the Scottish Government to abandon these reckless and unevidenced proposals.

I confirm that the Scottish Government has permission to publish this individual response.

Name:

Signed:

Email address:

Address:

Table A3.2: Allocation of Shetland postal campaign text to the consultation questions

Consultation text

I am utterly opposed to the concept of HPMAs – with the associated consultation providing no scientific evidence as to the need for, or potential effectiveness of, banning fishing/aquaculture activity through HPMAs. Instead, these proposals seem to be driven by politics and pledges in the Bute House Agreement, rather than driven by any environmental or conservation imperatives.

Related consultation questions: Q1

Consultation text

I believe that the Scottish fishing industry has proven in the past that they are not opposed to sensible conservation measures, recognizing that strong fish stocks and healthy marine ecosystems are in their own interest – and in the wider interest of sustaining their fishing communities. However, nothing about these HPMA proposals are sensible and — for the sake of my whole community — I would urge the Scottish Government to abandon these reckless and unevidenced proposals.

Related consultation questions: Q1

Consultation text

Many of Scotland’s rural and island communities rely on the socio-economic benefits brought by local fishing and agriculture industries, to which the prospect of HPMAs is the single greatest threat. HPMAs appear to be yet another central belt vote winner, allowing Scottish Ministers to burnish supposedly environmentally friendly credentials, at the sole expense of Scotland's already fragile remote/island areas and fishing communities that rely on producing high-quality and low carbon food from the sea.

Related consultation questions: Qs12-16 (impacts)

Consultation text

In particular, fishing crews already face a substantial and growing spatial challenge at sea, including a rapidly developed Marine Protected Area network – which already protects the environmental features that could be impacted by different types of fishing activity. Adding unnecessarily to this spatial squeeze through the introduction of unevidenced HPMAs will only destabilize the economic viability of vessels - with terrible economic consequences for the families, supply chain businesses and wider communities who rely on them and their crews for employment and income.

Related consultation questions: Qs12-16 (impacts)

Consultation text

I would prefer that any government effort to protect the environment should aim to be compatible with the production of this low-carbon and nutritious protein, rather than threaten its existence.

The Scottish Government’s ill-conceived commitment to designate 10% of Scotland seas as Highly Protected Marine Areas by the year 2026 seems extreme and overly ambitious. In contrast, UK Government proposals put forward 5 potential HPMAs covering only 0.53% of English waters. Please note that plans for one of those areas, around Holy Island/Lindisfarne, have now had to be scrapped in the face of community protest at the sheer economic damage it would have caused to the island through the effect on its fishing crews. There are lessons to be learned there by the Scottish Government if it has the wit to do so.

Related consultation questions: Q19 (recoded to ‘alternative arrangements’)