National Marine Plan 2 (NMP2) Strategic Environmental Assessment (SEA) Scoping Report: Consultation Analysis

4. Analysis

Responses were analysed to identify prevalent theme and subtheme, arising within the comment.

Responses received from organisations were split according to type. A break-down is shown below:

• academia (2)
• business/private sector organisations (10)
• community organisations (5)
• public sector bodies including regulators and local authorities (12)
• representative bodies and charities (12)

Most responses in the businesses/private sector category were from organisations with their main interest in the renewables sector.

Respondents did not always respond to all six questions in the consultation.

4.1 Overarching themes identified from feedback on SEA Scoping Report

The Scoping Report suggested that due to the nature and scale of NMP2 and the potential for likely significant effects to occur across all topics that all SEA environmental topics be scoped into the assessment.

Around half of respondents agreed to scoping in all environmental topics from the SEA legislation, with many suggesting specific environmental components for consideration, such as: the interaction between sectors, consideration of entire ecosystems, and sustainable access to marine areas. Useful feedback on the SEA objectives used in the assessment of the 2015 National Marine Plan was provided. The need for greater emphasis on the global climate emergency and support for the transition to net zero was highlighted, and it was clear that respondents wanted to see greater emphasis on halting loss and proactively recovering biodiversity in the marine environment.

Respondents were supportive of the proposed approach to the SEA and the identification of key environmental issues under each topic to be used in the assessment and to inform the SEA objectives.

However, several respondents felt that commentary on the SEA framework was challenging because the updated SEA objectives for the NMP2 were not available in the scoping report. Furthermore, there should be clearer consideration of the relationship between topic areas, and how effects in one topic could have implications in another. A common theme presented during the analysis was the need for interactions between marine users, specifically between sectors, to be considered.

Responses from the consultation, and updated list of environmental issues, will be used to inform the SEA objectives for the NMP2. These objectives will be shared for review with the NMP2 steering group before the assessment begins. The intent for the SEA process to work in parallel with the NMP2 development was welcomed by Consultation Authorities.

4.2 Overarching themes identified from feedback on NMP2

A number of common points on proposals for the new NMP2 itself were observed during the analysis:

• Respondents expressed a desire for NMP2 to be used as the clear framework for decision-making when considering colocation and capacity for multi-use areas.
• NMP2 needs to be ambitious and have an important role in setting priorities where there is the potential for competing priorities.
• Prioritisation of key topics within the marine environment would help in delivering strategic aims of the Scottish Government.
• NMP2 should be used as an opportunity to provide guidance on spatial policies that are likely to be needed at the local, regional, and national level.
• NMP2 should help ensure increased synergy between marine and terrestrial planning to ensure consistency between policy frameworks.

4.3 Analysis by question

Question one asked: “Do you have any comments on either the environmental topic areas or assessment methodology proposed?”

Seventeen responses from a range of private and public sector organisations showed clear favour for the inclusion of all proposed topic areas, with some responses providing additional issues to further strengthen the topic areas, for example “the consideration of interactions between multiple issues and addressing cumulative effects, particularly where issues impact on whole ecosystems such as climate change. These have been noted and will be shared with the contractors.

The remaining respondents did not object to the environmental topic areas, but rather some thought they could be updated to better reflect the role that oceans can play in delivering climate change mitigation and biodiversity recovery. Eight respondents agreed that the methodology to be used was appropriate. Three respondents, ranging through Academia and Representative Bodies and Charities, were not in favour of the methodology, all highlighting suggested issues for inclusion within the topics or requesting greater clarity on the process. While the remainder of responses were neutral or left blank.

Question two asked “What are your views on the broad policy framework and is there any further information that you feel should be considered?”

Nineteen respondents agreed with the proposed SEA framework, with suggestions proposed for ensuring a strong alignment between NPF4 (National Planning Framework 4) and NMP2 in cross-cutting policy areas and recommendations to include the Nature Conservation (Scotland) Act 2004 and fisheries management measures.

The remaining respondents did not explicitly object to the SEA framework but rather had suggestions for further policies and considerations to be taken into account. All the proposals for the assessment will be considered and, where appropriate, shared with the contractor undertaking the SEA. The proposed SEA assessment methodology will be shared with the NMP2 steering group for review.

Question three asked “Is there any further information or data that you feel should be considered as part of the environmental evidence base for the assessment?”

As set out in the Scoping Report, Scotland’s Marine Assessment 2020 (SMA2020) will provide the broad evidence base for SEA by providing an information on the state of Scotland’s seas and of the main activities and pressures. As also highlighted in the scoping report, where required, additional and updated data and information will be taken into account and used as part of the environmental baseline.

While many respondents agreed to the SMA2020 being used as the primary evidence base, six disagreed and over three quarters of respondents provided suggestions for additional evidence. These have been collated and, will be considered by the contractor undertaking the SEA. The NMP2 steering group has been asked to provide any additional sources of evidence for inclusion in the assessments.

Question four asked: “What are your views on the early work set out in the report to identify key environmental issues that will be used to inform the development of SEA Objectives for assessment (SEA Objectives - Section 3, Table 1)?”

There were 41 responses to this part consultation, with around half of respondents agreeing that the environment issues identified should be used to inform the SEA objectives. A number of suggestions were made for inclusion, such as “adopting an ecosystem-level assessment of species and habitats and their interactions” and highlighting the “need for a spatial management approach in the NMP2, and assessment on an area basis”. These have been noted and will be shared with the contractors.

Question five asked: “What are your views on the SEA Objectives used to assess National Marine Plan (2015), (SEA Objectives – Section 3, Table 2)?”

There were 39 responses to this part of the consultation. While several respondents considered the SEA objectives used to assess the current National Marine Plan published in 2015 to be minimal, many were supportive of them being used as a starting point to develop updated SEA objectives for assessment of NMP2 and welcomed that they would be updated and modified in accordance with feedback from this consultation. The SEA objectives to assess the potential environmental impacts from the proposals in NMP2 will be shared with the NMP2 steering group for review before the assessment begins.

Question six was an open question asking: “Do you have any further comments on the SEA scoping report?” giving responders the opportunity to provide any relevant comments about the SEA scoping report in general.

There were 37 responses to this part of the consultation. Responses were wide-ranging, many focusing on proposals for the plan and will be useful as we take the next steps in the NMP2 process. We have collated all responses and will share with the contractors, for consideration. Please refer to Section 4.2 ‘Overarching themes from the feedback on NMP2’.