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

2 Description of the responses and respondents

2.1 This chapter provides information about the respondents to the consultation and the responses submitted.

Number of responses received and number included in the analysis

2.2 The consultation received a total of 4,594 submissions. These comprised:

• 2,129 responses submitted through Citizen Space
• 378 responses submitted by email or post
• 26 responses submitted by post as part of a Shetland-based campaign (this will be referred to as the Shetland postal campaign)
• 2,061 responses submitted as part of a Scottish Environment LINK campaign.

2.3 Responses received by email were entered into a database and, following quality assurance checks, were added to the database of responses received through Citizen Space. In addition, 43 of the 2,061 Scottish Environment LINK campaign responses were identified as ‘personalised’ responses. These were also added to the consultation database. The remaining 2,018 Scottish Environment LINK responses were ‘standard campaign responses’ which were not substantively edited by the respondent. These responses and the Shetland postal campaign responses were not entered into the consultation database, and so are not included in the tables throughout this report. However, the views expressed in these responses were included in the analysis as discussed below (see the discussion of campaign responses.)

2.4 A total of 92 responses were removed from the analysis for the following reasons:

• 30 responses were entirely blank
• 53 responses were found to be duplicate or multiple different responses submitted by 50 different respondents^[6]
• 9 submissions were identified as consultation-related correspondence, which did not contain a consultation response.^[7]

2.5 In cases where the respondent submitted a duplicate response, one response was removed and one retained for the analysis. In cases where the respondent submitted multiple different responses, the responses were combined into a single amalgamated response.^[8]

2.6 Thus, the analysis presented in this report was based on 4,502 responses. This comprised 2,458 substantive responses and 2,044 standard campaign responses of various types. See Tables 2.1 and 2.2 below.

* A total of 43 substantive (i.e. personalised) responses were identified among the Scottish Environment LINK campaign responses. However, two of these were submitted by one individual. These two responses were combined into a single amalgamated response, resulting in a total of 42 substantive responses from 42 individuals.

About the respondents (substantive responses only)

2.7 Substantive responses were received from 289 organisations and 2,169 individuals (see Table 2.3).

Organisational respondents

2.8 The response form for this consultation invited respondents (individuals and organisations) to select – from a list provided – the ‘sector’ to which they or their organisation was best aligned.

2.9 This list and self-selection process was used as the starting point for a categorisation that could be used to describe the organisational respondents to the consultation. However, not all organisations answered this question and, among those that did, there were differences in the way respondents had classified themselves. As a result, further work was done to create a set of categories that could be applied more consistently across all organisational respondents. Table 2.4 (below) presents details of the 12 main types of organisations that responded to the consultation, based on this re-categorisation.

2.10 Table 2.4 shows that the two largest categories of organisational respondents were fishing organisations / groups and community organisations / groups – each accounting for around a fifth (18%) of all organisational respondents. Fishing organisations / groups included those directly involved in fishing, fishing boat owners / operators, and their membership and representative bodies. Community groups included community councils, community development trusts, and their representative bodies.

2.11 The next largest organisational groups comprised (i) environmental organisations (11%), (ii) organisations / groups involved in the recreation, tourism and culture sectors (11%); and aquaculture organisations / groups (10%). Environmental organisations included those with a focus on environmental protection and nature conservation, as well as those with a broader interest in achieving ‘sustainable’ marine environments. Respondents from the recreation, tourism and culture sectors included sailing, angling, diving and sporting clubs and organisations, as well as hospitality organisations. Aquaculture organisations / groups included those involved in finfish, shellfish and seaweed aquaculture, and their representative bodies.

2.12 The remaining organisations comprised public sector bodies including regulators and local authorities (7%); organisations in the business / private sector (7%); energy providers (4%), fish selling and processing organisations (4%); organisations involved in the management of shipping, ports and harbours (3%), political groups (2%); and a small group of ‘other organisation types’ which did not fit into any of the other categories. This final category included academic organisations.

2.13 A complete list of organisational respondents is provided at Annex 2 of this report.

A simplified classification of organisations

2.14 To reduce the size of the tables in the report, a simplified classification of organisations was developed and agreed with the Scottish Government. This classification comprised eight (rather than 12) categories. (See Table 2.5 below.)

2.15 This 8-group classification is used throughout the remainder of this report – except in Annex 1 where the original 12-group categorisation (see Table 2.4) has been retained.

Individual respondents

2.16 Information about ‘sector alignment’ was also available for more than three-quarters of individuals. This information, together with statements included elsewhere in people’s responses, indicated that a large proportion of individual respondents were involved in the fishing or aquaculture sectors – as owners, contractors or employees – or as family members, neighbours or friends of people involved in this sector. Individual respondents also often highlighted their geographical location – with many saying they lived in coastal or island communities and were submitting a response as a ‘concerned member of the community’. Less than 2% of individual respondents identified themselves as being part of an ‘environmental organisation’, although individuals sometimes indicated their interest in environmental issues within their response.

2.17 The detail on how individuals responded to the sector alignment question is not presented in this report because of the high degree of variability and inconsistency in the way the question was answered. However, the responses nevertheless provide an insight into the perspectives of individual respondents in relation to the proposal to introduce HPMAs and informs the qualitative analysis undertaken.

Campaign respondents

What is a campaign response?

2.18 A ‘campaign response’ is defined as a response to a consultation which is based on a template provided by a campaign organiser. The campaign organiser assists their members and supporters either by providing suggested responses to individual consultation questions or to the consultation overall, or by providing a commentary on the consultation and the consultation questions which people may draw on in drafting their own responses.

2.19 ‘Standard’ campaign responses are based on a ‘standard’ template, to which the respondent simply adds their name and submits the response (usually through a website) without amendment. ‘Non-standard’ campaign responses are responses based on the template, but where the respondent has personalised the response by adding additional substantive comments. Throughout the remainder of this report, ‘standard’ campaign responses are referred to, simply, as ‘campaign responses’. ‘Non-standard campaign responses’ are referred to – and reported – as substantive responses.

2.20 This consultation received responses from two campaigns. One was organised by Scottish Environment LINK, and a second smaller campaign was organised in Shetland. The organiser of the latter campaign was not known.

2.21 As noted in paragraph 2.3 above, campaign responses were included in the analysis, but are not included in the tables throughout this report.

Scottish Environment LINK campaign

2.22 The Scottish Environment LINK campaign was a web-based email campaign. This campaign:

• Expressed support for the Scottish Government’s proposals to designate at least 10% of Scotland’s seas as HPMAs
• Expressed support for the prohibition of certain types of activities within HPMAs and adjacent waters, while allowing access for certain other types of activities
• Expressed support for the general principles for HPMA site selection
• Called for better management of activities that damage marine species and habitats.

2.23 This campaign generated 2,018 responses. The campaign text is shown at Annex 3.

Shetland postal campaign

2.24 The Shetland postal campaign was based on a template letter to which respondents could add their names and contact details and send (by post) to the Scottish Government. This campaign:

• Expressed opposition to the concept of HPMAs, claiming it lacked a scientific basis
• Highlighted the potential for a disproportionately adverse impact on island and fishing communities
• Called for a greater recognition of the importance of fishing to food security
• Suggested that the intention to designate 10% of Scottish seas as HPMAs was ‘extreme’ and not consistent with proposals put forward by the UK Government for English waters
• Highlighted the challenges of restrictions on marine access already affecting fishing crews
• Reiterated the potential adverse socio-economic impacts of the policy on the fishing industry and fishing communities.

2.25 This campaign generated 26 responses. The campaign text is shown at Annex 3.

Overview of campaign responses

2.26 Table 2.6 provides a brief overview of each of the campaigns.

2.27 See Annex 3 for further details.

Campaign-like responses

2.28 In addition to the campaigns described above, two other forms of campaign-like activity were identified within the responses, as follows:

• Small clusters of identical or almost identical responses
• Responses using sections of common text or common phrasing, suggesting collaboration between organisations and individuals in preparing responses, or the sharing of responses within communities, groups, networks or social circles.

2.29 Responses of these types have been treated as substantive responses.

Response to the consultation

Response rates at individual questions (substantive responses only)

2.30 As noted above, there were 2,458 substantive responses to the consultation. However, not all respondents answered all the consultation questions and respondents’ comments at the open questions did not always address the specific consultation questions in the answers provided. This was so not only for those who submitted their responses by email without having completed a questionnaire, but also for those who submitted their responses using the online questionnaire provided.

2.31 It was not uncommon in this consultation for respondents to say that they did not understand certain questions, that they found it difficult to answer certain questions, and / or that they found the questionnaire irrelevant given their views on HPMAs.

2.32 The response rates for individual questions are shown in Annex 4. However, given the issues outlined above, the figures shown in Annex 4 cannot be taken as an accurate indication of the extent to which respondents addressed individual questions – although they do provide an indication of the extent to which respondents attempted to engage with the consultation.

2.33 Among organisations, the highest response rate (89%) was for the open part of Question 1 (which asked for views on the aims and purpose of HPMAs). The lowest response rate (50%) was for the open part of Question 12 (which asked for views on the Strategic Environmental Report).

2.34 Among individuals, the highest response rate (86%) was for the closed part of Question 1 (which asked for views on the aims and purpose of HPMAs). The lowest response rate (36%), as for organisations, was for the open part of Question 12.

2.35 Annex 4 provides further details.

Challenges with the consultation process

2.36 Many respondents – including those who submitted their responses by email, post and Citizen Space – said they found it difficult to engage with this consultation. Many were highly critical of the consultation documents and the consultation process itself. The reasons for this dissatisfaction are discussed in Annex 5 of this report.