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

6 Site selection (Q8–Q11)

Summary of key points:

• The draft site selection guidelines stated that HPMA site identification will be based on ‘functions and resources of significance to Scotland’s seas’. Each of the seven functions and resources proposed was supported by between 21% and 31% of respondents. For each item, support was higher among organisations than individuals.
• Respondents who supported the introduction of HPMAs were most likely to highlight ‘blue carbon’, ‘essential fish habitats’ and ‘other ecosystem services’ as being key objectives for marine conservation. Comments from respondents who opposed the introduction of HPMAs often focused on definitional issues and the lack of evidence available on individual functions and resources. Some queried the relevance of the individual functions and resources for marine conservation or site selection.
• The guidelines stated that the site selection process will be underpinned by four general principles. Each of the principles was supported by between 32% and 58% of respondents. Support was highest for ‘use of robust evidence base’ – this was seen as critical and was the only principle that attracted overall majority support.
• A five-stage site selection process was proposed. One in six respondents (16%) said they supported this process. Among organisation types, views varied significantly: while 80% of environmental organisations expressed support, all fish selling and processing organisations (100%), and almost all fishing organisations (94%) were opposed.
• In relation to all the questions on the site selection guidelines, recurring themes – both among those who supported and those who opposed HPMAs – related to the importance of robust evidence, concerns about the timescales for designating HPMAs, the importance of community and stakeholder engagement, and the need to take account of socio-economic as well as environmental factors. There was a range of views on the ‘weight’ to be attached to different perspectives and factors in the site selection process.

6.1 The consultation paper sought views on draft guidelines, prepared by NatureScot and the Joint Nature Conservation Committee (JNCC), for the identification and selection of individual HPMA sites. The guidelines are intended to complement the policy framework developed by the Scottish Government, and the proposed site selection process is intended to ensure the sites chosen as HPMAs provide for:

• Balanced representation of the ecology of Scotland’s seas and their geographical spread from the coast to the deep sea
• Ecosystem recovery and biodiversity enhancement, including protection of blue carbon and essential fish habitats
• The recovery of Priority Marine Features (PMFs)
• Coverage of at least 10% of Scotland’s seas.

6.2 The draft site selection guidelines set out a five-stage process for developing HPMA proposals. Proposals that pass all five stages will then progress to a network level assessment. This will consider the relative merits of all HPMA options and combinations with a view to optimising ecological, social and cultural benefits in the final choice of sites. The guidelines stated that site identification will be based on ‘functions and resources of significance to Scotland’s seas’, and that the site selection process will rely on general principles and take account of socio-economic as well as environmental factors.

6.3 The consultation asked four questions on the draft site selection guidelines.

Question 8: What is your view of the proposal that HPMA site identification should be based upon the “functions and resources of significance to Scotland’s seas”, as listed below and set out in Annex B of the draft Site Selection Guidelines? [Strongly support / Support / Neutral / Oppose / Strongly oppose]

• Blue carbon
• Essential fish habitats
• Strengthening the Scottish MPA network
• Protection from storms and sea level rise
• Research and education
• Enjoyment and appreciation
• Other important ecosystem services

Please explain your answer in the text box, including any suggested changes to the list.

Question 9: What is your view of the general principles that are intended to inform the approach to HPMA selection, as listed below and set out in section 4.1 of the draft Site Selection Guidelines? [Strongly support / Support / Neutral / Oppose / Strongly oppose]

• Use of robust evidence base
• HPMA scale and the use of functional ecosystem units
• Ensuring added value
• Delivering ecosystem recovery

Please explain your answer in the text box, including any suggested changes to the list.

Question 10: What is your view of the proposed five-stage site selection process, found in sections 4.2 and 4.3 as well as figure 2 and Annex A of the draft Site Selection Guidelines? [Strongly support / Support / Neutral / Oppose / Strongly oppose]

Please explain your answer in the text box.

Question 11: Do you have any further comments on the draft Site Selection Guidelines, which have not been covered by your answers to the previous questions?

6.4 This chapter looks at respondents’ views on each question in turn. The following points should be noted about the analysis presented here:

• There was a great deal of overlap in the comments offered at each question. As far as possible, points are noted at the most appropriate question and are not covered in detail at multiple questions.
• Around a third of those commenting did not offer any specific views on the site selection process. Instead, they repeated overall views on the proposed introduction of HPMAs. This was particularly the case for those who opposed the introduction HPMAs. These views are presented in Chapter 4 and are not repeated here in any detail.
• Across this set of questions, comments suggested that some of those who selected ‘oppose’ did so because they were opposed to the introduction of HPMAs in general, rather than because they were specifically opposed to individual aspects of the draft site selection process. Some said the proposed site selection process was ‘irrelevant’, as they did not want the policy to be introduced at all. Therefore, given this approach, caution should be taken in interpreting the responses to the closed questions.
• By and large, the points made by those who selected ‘neutral’ at the closed questions in this section were not substantively different to the points made by those who selected ‘support’ or ‘oppose’; thus, their views are not presented separately.

The functions and resources forming the basis of site selection (Q8)

6.5 The draft guidelines stated that HPMA site selection would be based on the conservation of marine ecosystems and driven by the presence of a set of ‘functions and resources’ identified as being of significance to Scotland’s seas, as follows:

• Blue carbon
• Essential fish habitats (including prey species)
• Strengthening the Scottish MPA network
• Protection from storms and sea level rise
• Research and education
• Enjoyment and appreciation
• Other important ecosystem services.

6.6 Question 8 asked for views on this list of functions and resources. The question comprised seven separate tick-box questions. Of the total 2,458 respondents who submitted substantive responses, 1,704 (69%) answered at least one of the tick-box questions.

6.7 Table 6.1 below and Tables A1.24 to A1.30 in Annex 1 show the following main points based on the substantive responses:

• Each of the seven items were supported by between 21% and 31% of respondents. Levels of opposition were higher, ranging from 51% to 67% across the list.
• Respondents who expressed opposition were more likely to say they were ‘strongly opposed’ (rather than simply ‘opposed’). The proportion of respondents who were ‘strongly opposed’ ranged from 47% to 57% for each function or resource. By contrast, those who expressed ‘strong support’ ranged from 12% to 18% across the seven items.
• Individuals were more likely than organisations to oppose each of the seven items. In every case, individuals were at least 10% more likely than organisations to express opposition. In relation to blue carbon and essential fish habitats, individuals were 20% more likely than organisations to be opposed.
• Among the organisational respondents, environmental organisations and energy providers were most likely to support each of the seven items. These two groups gave the highest levels of support to blue carbon, essential fish habitats, and research and education. (See Tables A1.24 to A1.30 in Annex 1 for details.)
• Fish selling and processing organisations and fishing organisations were most likely to express opposition in relation to all seven items. In addition, opposition was unanimous, or nearly unanimous, among one or both of these groups in relation to blue carbon, essential fish habitats, and strengthening the Scottish MPA network. (See Tables A1.24 to A1.30 in Annex 1 for details.)

Percentages may not total 100% due to rounding.

The table combines those who selected ‘strongly support’ OR ‘support’ into a single category (Support). It also combines those who selected ‘strongly oppose’ OR ‘oppose’ into a single category (Oppose). See Tables A1.24 to A1.30 in Annex 1 for a full breakdown of the responses using the 5 original response categories.

6.8 The sections below present an overview of the comments received from respondents on (i) the use of the proposed list of functions and resources as a whole in identifying possible HPMA sites (ii) the use of individual functions or resources, and (iii) additions and revisions to the list of functions and resources.

Views on the list of functions and resources of significance to Scotland’s seas

6.9 As noted above, some respondents commented at a general level on the list of functions and resources included in the draft site selection guidelines. Some, environmental organisations and individuals in particular, offered general support, saying, for example, that all the functions and resources were ‘important’, or ‘relevant and reasonable’.

6.10 More commonly, however, respondents (both organisations and individuals) made generally critical comments, describing the set of functions and resources as ‘unfounded’, ‘vague’ or ‘nonsense’, or saying that there was not enough evidence on the functions and resources and how they would be affected by HPMA designation. Others called for more detail and further ‘unpacking’ of the functions and resources, or greater clarity on the approach to assessment and weighting.

6.11 Additionally, environmental organisations drew attention to ‘well-established globally accepted’ guidance and criteria for MPA site selection, and to the selection criteria for Scotland’s current MPA network. They suggested that these could be used for HPMA selection.

6.12 Some respondents also suggested that protection should focus on, for example, (i) areas of high biodiversity or supporting rare or threatened species or (ii) areas that are particularly damaged or vulnerable. Those responding to the consultation as part of the Scottish Environment LINK campaign called for the chosen sites to include ‘both healthy and degraded areas, and species and habitats that represent the full range of Scotland’s natural marine biodiversity’.

6.13 Some respondents (particularly individuals) said that action should be taken to address known environmental problems such as marine pollution (these comments were brief and it was not clear if they applied in the context of HPMA selection or to protecting the marine environment more generally).

Views on individual functions and resources

6.14 Respondents offered a wide range of comments on each of the seven functions and resources that it was proposed would form the basis of site identification. The main points are summarised here.

6.15 Those broadly supportive of the introduction of HPMAs thought all the functions and resources were relevant or important but were particularly likely to highlight blue carbon, essential fish habitats and other ecosystem services as being key to the objectives of marine conservation and ecosystem recovery. On the issue of strengthening the MPA network, respondents in this group endorsed this aim and generally called for HPMA sites to be outwith, and additional to, existing MPA sites. They also noted the importance of clarity of definitions and concepts – and taking account of socio-economic impacts as well as environmental factors.

6.16 Those broadly opposed to HPMAs offered criticisms or queried the relevance of each of the proposed functions and resources. Key views in the responses across the seven functions and resources related to:

• A perceived lack of evidence to support the use of functions or resources – particularly in relation to blue carbon, essential fish habitats, strengthening of the HPMA network and other ecosystem services
• A perceived lack of specificity and a need for well-defined (and better defined) terms and concepts
• Doubt about the relevance of individual functions or resources as site selection criteria – particularly in relation to (i) protection from storms and sea level rise, (ii) research and education, and (iii) enjoyment and appreciation
• Scepticism about the need to strengthen the MPA network, and a preference for any new HPMAs to be located within or overlapping with existing MPA boundaries
• Concern about a perceived lack of attention paid to socio-economic impacts in the site identification process.

6.17 The comments made indicated varied levels of familiarity with and understanding of the proposed criteria and how they would be applied to the site selection process, as well as varied views on the inclusion of the criteria for site identification purposes.

6.18 Further information on the main points raised in relation to each individual function or resource is provided in Annex 7.

Suggested additions and changes to the list of functions and resources

6.19 Question 8 specifically asked respondents to suggest any changes to the list of functions and resources that would be used in site identification. The main suggestions put forward by respondents included the following:

• Food security, low-carbon food production and nutritional health
• The presence of key species
• The presence of historic sites such as shipwrecks
• The provision of functions protecting against climate change.

6.20 Respondents (environmental organisations in particular) also suggested that the overarching aim for HPMAs should be presented as ‘ecosystem protection, recovery and enhancement’ or ‘supporting recovery and enhancement of biodiversity’ and that this should be reflected in the site identification criteria. Some respondents also suggested that selection should be based on evidence of ecosystem damage, and should focus on the most damaged areas rather than on preserving sites currently in good condition.

6.21 Additionally, there was also a very widespread view that the lack of reference to the sustainability of communities, or the socio-economic or cultural impacts of HPMAs at the site identification stage was a ‘massive oversight’. Respondents of all types argued for consideration of community impacts at an early stage in site identification, and emphasised the need for community engagement and input throughout the process. See also the discussion at Question 10 (paragraph 6.49).

General principles intended to inform the site selection process (Q9)

6.22 The draft guideline document sets out four general principles that would be followed in the HPMA site selection process, as follows:

• Use of a robust evidence base
• HPMA scale and the use of functional ecosystem units
• Ensuring added value
• Delivering ecosystem recovery.

6.23 The draft site selection guidelines stated that these principles build on those used to identify MPA sites and would apply to all stages of the HPMA selection process.

6.24 Question 9 asked for views on the principles. The question was made up of four separate tick-box questions. Of the total 2,458 respondents who submitted substantive responses, 1,360 (55%) answered one or more of the tick-box questions at Question 9.

6.25 Table 6.2 below and Tables A1.31 to A1.34 in Annex 1 show the following main points based on the substantive responses:

• Each of the four principles was supported by between 32% and 58% of respondents. Each was opposed by between 34% and 45% of respondents. The proportion of respondents who said their views were ‘neutral’ ranged from 8% for ‘use of robust evidence’ to 27% for ‘ensuring added value’.
• Support was highest for ‘use of robust evidence base’ – this was the only principle that attracted majority support. Overall, 58% of all respondents supported the use of this principle, although support was notably higher among organisations (77%) than individuals (55%). Respondents were also more likely to select ‘strongly support’ than ‘support’ for this principle.
• Organisations were more likely than individuals to support each of the four principles, and, by contrast, individuals were more likely than organisations to oppose all four principles.
• Among organisations, all but business / private sector organisations and fish processing and selling organisations expressed majority support for ‘use of robust evidence base’ as a site selection principle. Support was highest among shipping, ports and harbours (100%), political groups (100%) and environmental organisations (96%). (See Tables A1.31 to A1.34 in Annex 1 for details.)
• There was no consensus in views in relation to the other three principles, with support ranging from 32% to 43% and opposition ranging from 35% to 45%. In relation to each of these principles, support was highest among environmental organisations (90% or above). Other organisation types expressing relatively high levels of support across these principles (75% or above) included recreation, tourism and culture organisations and energy providers. (See Tables A1.31 to A1.34 in Annex 1 for details.)

Percentages may not total 100% due to rounding.

The table combines those who selected ‘strongly support’ OR ‘support’ into a single category (Support). It also combines those who selected ‘strongly oppose’ OR ‘oppose’ into a single category (Oppose). See Tables A1.31 to A1.34 in Annex 1 for a full breakdown of the responses using the 5 original response categories.

6.26 In addition, 2,018 Scottish Environment LINK campaign respondents said that they ‘support the general principles for selecting where HPMAs will be located and what they will protect’.

6.27 The following sections present an analysis of the comments made by respondents who provided substantive responses. General comments are covered first, before presenting views on each individual principle. It should be noted that, as with the functions and resources considered at Question 8, the comments from respondents – individuals in particular – indicated varying levels of familiarity with and understanding of the proposed principles and related concepts addressed in this question.

General comments

6.28 Those commenting on the principles in a general way offered contrasting views. On the one hand, some respondents provided an overall positive assessment of the principles, describing them as ‘strong pillars for the selection process’ or ‘strong principles consistent with an ecosystem approach’. On the other hand, other respondents described them as a ‘relatively arbitrary’ set of principles, or said, for example, that they ‘sound good but don’t mean much’.

Use of a robust evidence base

6.29 As shown in Table 6.2, the use of a robust evidence base was the only one of the four principles which attracted majority support overall, both from organisations and individuals. There was broad agreement among respondents of all types that a robust evidence base was critical for making important decisions on the designation of HPMAs.

6.30 Respondents largely agreed that the evidence base for site selection needed to be:

• Comprehensive, and open to public scrutiny
• Local rather than national or ‘generic’, with specific opposition to using modelled data, and concerns about the lack of sufficiently detailed data to assess impacts at community level
• Inclusive in taking account of local knowledge and information and the experience of those who live by and work on the sea as well as expert scientific evidence
• Holistic in including socio-economic, ecological and environmental evidence.

6.31 However, there was also a widespread view that good quality evidence on all aspects of the marine environment was not currently available, with respondents expressing scepticism about whether such an evidence base could be assembled in time to be used in the selection of HPMA sites by 2026. Respondents described the timeline as ‘challenging’ or ‘unrealistic’. A range of respondents (including fishing and aquaculture organisations, community groups and organisations, and a few individuals) suggested that a small number of pilot HPMAs might help provide evidence for the development of the HPMA programme.

6.32 Some respondents highlighted the reference in the consultation paper to the use of ‘best available’ evidence and a ‘preference for relying upon existing data’. Some expressed concern about this and were strongly of the view that new and detailed evidence was required. However, others (mainly environmental organisations and individuals) argued for the use of a ‘precautionary approach’ in the absence of complete knowledge, or said that ‘the absence of perfect knowledge’ should not be used as a barrier to HPMA implementation.

6.33 In their responses to this question, respondents repeatedly (i) pointed out the perceived lack of a clear evidence base for the introduction of the HPMA policy as a whole, or the absence of such evidence in the consultation documents, and (ii) argued that the principle of using a robust evidence base for site selection was undermined by the already stated commitment of designating at least 10% of Scotland’s seas as HPMAs.

HPMA scale and the use of functional ecosystem units

6.34 The comments made in relation to this principle were varied in nature. Some respondents – including environmental organisations – broadly welcomed the focus on functional ecosystems and favoured larger rather than smaller HPMAs as offering the most potential in terms of ecosystem protection and recovery, and research, education and enjoyment. However, other respondents were concerned about the designation of large inshore areas as HPMAs and the potential impact this would have on existing coastal activities. Some, individuals in particular, said they favoured a system based on a greater number of smaller sites which would allow greater scope for existing marine activities to continue.

6.35 The lack of stated parameters (e.g. in terms of size and number) for establishing HPMAs was seen as offering helpful flexibility by some respondents, while others thought that, alongside the stated 10% target, this introduced uncertainty and the risk of pressure and ‘spatial squeeze’ in coastal areas.

6.36 Comments on the relationship between existing MPAs and new HPMAs are covered in the discussion related to ‘strengthening the MPA network’ at Question 8 (see paragraphs 6.9 to 6.18 and Annex 7).

Ensuring added value

6.37 The draft site selection guidelines explained that HPMA sites were intended ‘to add clear value to the conservation and wider sustainable use of Scotland’s seas over and beyond existing marine conservation policies and management’. Comments in relation to the proposed principle of ensuring added value suggested that many respondents were uncertain either about the meaning of this principle or how it would be implemented in practice.

6.38 Respondents from a range of sectors referred to the principle as ‘vague’, and ‘poorly defined’, or said it was not clear if the ‘added value’ referred to ‘purely conservation objectives, wider objectives or both’. There were calls for a more precise definition to be provided.

6.39 Those offering fuller comments mainly argued that it was important that any assessment of ‘added value’ take account of socio-economic factors – and specifically the socio-economic value associated with fishing – as well as environmental factors. However, there was also a less common view put forward by environmental organisations that environmental and ecological value should take precedence in any assessment.

Delivering ecosystem recovery

6.40 Those commenting on ecosystem recovery as a principle for site selection were largely supportive of its inclusion. Environmental organisations and some individuals were particularly supportive of the principle arguing that this was essential to HPMA designation and should carry more weight or be at the forefront of site selection process. Some of those who supported this principle went on to raise the following caveats:

• They said the wording should be broadened to refer to ‘delivering ecosystem protection and recovery’ or ‘delivering ecosystem recovery and enhancement’.
• They said the principle should be further defined and quantified, and that baselines should be established for future research purposes.
• They argued that sustainable ecosystem recovery required local support, education, funding, and regulation.

6.41 Those respondents expressing stronger reservations about the use of the principle in site selection questioned the extent of and evidence for current ecosystem damage and degradation and thus the need for recovery, and / or the assumption that recovery required the removal of all human activities.

Proposed five-stage site selection process (Q10)

6.42 The draft guidelines proposed a site selection process that involved five stages:

• Stage 1: Identification of possible HPMA sites based on functions and resources of significance to Scotland’s seas
• Stage 2: Consideration of the contribution of potential sites to the overarching aims of HPMAs
• Stage 3: Defining the appropriate scale of the proposed HPMA site
• Stage 4: Reviewing the current use of sites and setting out the management of existing activities under HPMA arrangements
• Stage 5: People, Planet and Prosperity – an assessment of the wider potential benefits of HPMA designation.

6.43 It was anticipated that progression through the stages would be iterative rather than linear – particularly in relation to stages 3 and 4 – and that the process would be underpinned by robust evidence, stakeholder engagement and public consultation.

6.44 Question 10 asked for views on the process. Table 6.3 below and Table A1.35 in Annex 1 show the following main points based on the substantive responses:

• Overall, around one in six respondents (16%) said they supported the proposed process (7% said they supported it strongly), while around two-thirds (69%) said they opposed it (60% said they opposed it strongly). One in seven (15%) selected ‘neutral’.
• Organisations were more likely to express support for the process (25%) than individuals (15%); conversely, organisations (60%) were less likely than individuals to say they opposed the process (70%).
• Among organisations, support for the proposed process was highest among environmental organisations (80%). Levels of opposition were highest among fish selling and processing organisations (100%) and fishing organisations (94%). Around two-thirds of community organisations and groups and aquaculture organisations (69% in both cases) also opposed the proposed process. Other organisational groups (recreation, tourism and culture organisations; public sector bodies; and organisations in the ‘other organisation types’ category) had mixed views.

Percentages may not total 100% due to rounding.

The table combines those who selected ‘strongly support’ OR ‘support’ into a single category (Support). It also combines those who selected ‘strongly oppose’ OR ‘oppose’ into a single category (Oppose). See Table A1.35 in Annex 1 for a full breakdown of the responses using the 5 original response categories.

6.45 Those commenting at Question 10 often repeated comments made at earlier questions on site selection. The comments which focused specifically on the five-stage process are summarised in the section bellow.

6.46 Those offering broadly positive views on the site selection process described it as clear, comprehensive, sound, logical, or well thought out. Individuals were particularly likely to give such straightforward comments, while organisations were more likely to qualify their overall views on the process. Amongst organisations, some welcomed the references to socio-economic impacts, the involvement of stakeholders and the non-linear pathway. Public sector and regulatory bodies were particularly likely to comment positively on the process describing it as sensible, providing clarity, and ‘address[ing] all relevant matters’.

6.47 However, it was more common for respondents to offer broad support for the process while also raising concerns or seeking clarification and reassurances on issues such as the evidence base that would support the process; the need for clarity and transparency in the process; community and stakeholder involvement; and consideration of socio-economic issues. The main points made by these respondents were often similar to those raised by others who offered an overall negative assessment of the process, as discussed below (see paragraph 6.49).

6.48 In a few cases respondents who were opposed to the introduction of HPMAs nevertheless indicated a degree of support for the draft site selection process as they thought this would provide an acceptable way for proposals to be considered / contested should the policy proceed.

6.49 Those who offered broadly negative comments on the site selection process included respondents – mainly individuals – who described it as vague, bureaucratic or incomprehensible. Organisations generally provided fuller reasons for their opposition to or reservations about the process, focusing on the following three main interlinked issues in their comments: (i) consideration of socio-economic and cultural impacts, (ii) stakeholder and community engagement and input, and (iii) methodology. Views on each of these are summarised below.

• The assessment of socio-economic and cultural impacts: While respondents welcomed the consideration of socio-economic and cultural impacts within the site selection process, they often thought this was not given enough prominence. In particular it was noted that socio-economic considerations did not explicitly feature in the process until stage 4 which respondents thought was too late. There was a specific suggestion that a socio-economic assessment should be carried out at stage 1 with any proposals deemed as having an overall detrimental effect not proceeding further. There was also concern about the language used in the text and graphic in the guidelines which referred to ‘benefits’ rather than ‘impacts’ (thus emphasising the potential positive impacts and downplaying the consideration of negative impacts). Respondents also called for further detail on how socio-economic considerations would be assessed and weighted against other relevant factors.
• Stakeholder and community engagement and input: There were widespread calls for a more collaborative ‘bottom-up’ process that gave greater priority to the input of stakeholders and local communities and emphasised a commitment to a ‘just transition’. Clarity was sought about when and how stakeholders and communities would feed into the selection process, which stakeholders would be involved in advising Ministers on the sites that should go forward for public consultation, and the weight that would be attached to the views of different groups and stakeholders. Some said that the process should be guided by local communities, with appropriate time, resources and support provided to allow this to happen. There were also suggestions for regional approaches to the co-creation of site proposals and communities using the ‘third party’ process (outlined in section 5.1 of the draft site selection guidelines) to put forward their own proposals. There were also warnings that the process could give rise to conflicting views and divisions between different groups within communities. Respondents noted the need for mechanisms for dealing with such conflict and reaching compromise positions.
• Methodology: Clarity was sought on the methodology to be adopted at each stage in the process – in particular, respondents queried the proposed qualitative assessment of socio-economic impacts (at stage 4), given the reliance on quantitative data in relation to other aspects of the assessment and selection process. They called for more information on how different evidence and perspectives would be weighted in the process. For many this was about ensuring that community voices were heard throughout the process. However, there was also a specific concern, expressed by environmental organisations, that nature conservation objectives should remain the priority in site selection and not be overridden by socio-economic interests and powerful commercial interests in particular.

6.50 Additionally, respondents were doubtful that, if all the steps were followed (with necessary evidence gathered and considered, and appropriate stakeholder and community engagement undertaken), the process could be completed to allow site selection by 2026.

Other comments on the site selection guidelines (Q11)

6.51 A final question in this section, Question 11, asked respondents for any other comments on the draft site selection guidelines. This section summarises additional points raised at Question 11 (and at Questions 8 to 10) about the site selection process which have not been covered elsewhere in the sections above.

• A strategic approach to site selection: A range of respondents including both environmental and fishing / aquaculture organisations said the selection process had to be part of an overall coherent approach to marine management, biodiversity and conservation. As such it would be important that the site selection process considered the effect of designation on adjacent areas and the potential for displacement and how that will be managed, and that there was clarity about the contribution of potential sites to wider ecosystem recovery and enhancement.
• Relationship with the overall policy aims for HPMAs: Respondents frequently expressed concern that the stated commitment to designating 10% of Scotland’s seas as HPMA would be a main driver in the site selection process, over-riding any evidence-based approach that might be put in place. Additionally, in a few cases, respondents queried what would happen if the selection process resulted in less than 10% of seas being designated as HPMAs.
• Ensuring alignment with other government policies: Respondents noted the importance of site selection taking account of other current policies. For example, some in the fisheries and aquaculture sectors highlighted the commitment to ‘incentivise the use of lower impact gears’ included in the 2020 UK Fisheries Act, while the risk of HPMA designation impeding renewable energy development and hampering the achievement of Scottish Government net zero targets was noted by an energy provider.
• Excluding areas from the site selection process: There was a common suggestion that fishing and aquaculture and some leisure activities should be classed as activities that it is not feasible to relocate and that the presence of such activities should provide a basis for excluding areas from the HPMA selection process. It was also suggested that there should be an initial stage in the site selection process which defined and scoped out areas to be excluded from designation.

6.52 Finally, some respondents said that it was difficult to comment, in the abstract, on site selection processes without knowing the specific sites under consideration.