Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Consultation Analysis and Modifications Report.
The Pentland Firth and Orkney Waters Marine Spatial Plan is a pilot process undertaken by a working group consisting of Marine Scotland, Orkney Islands Council and Highland Council in advance of statutory regional marine planning. This report presents an
25. Sectoral Policies
25.1 Summary of responses received
25.1.1 This section deals with responses received in relation to the questions 'Do you have any comments on the format of the sectoral policies?' and 'Do you have any comments on Table 4?'.
25.1.2 This table describes the responses received in relation to the format of the sectoral policies.
| Stakeholder | Count |
|---|---|
| Commercial | 1 |
| Fisheries and aquaculture | 2 |
| Individual | 1 |
| Non-governmental organisation | 1 |
| Public sector | 3 |
| Recreation | 1 |
| TOTAL | 9 |
25.1.3 This table describes the responses received in relation to the format of Table 4.
| Stakeholder | Count |
|---|---|
| Commercial | 1 |
| Fisheries and aquaculture | 1 |
| Individual | 1 |
| Non-governmental organisation | 1 |
| Public sector | 3 |
| Recreation | 0 |
| TOTAL | 7 |
25.2 Main themes
25.2.1 Two aquaculture stakeholders provided the same comment on the sectoral policies. Both considered that the sectoral policy for aquaculture would not meet the aim of paragraph 320 (now 319), which notes that the policies provide a consistent framework to ensure the Plan delivers sustainable development through the identification of policies that deliver economic, social and environmental benefits for each sector.
25.2.2 These stakeholders expressed the view that they felt fish farming (aquaculture) was not supported in the same way as other sectors. They noted that all other users appear to have to be treated as having the same 'rights' to develop or use the sea. Their opinion was that fish farming could be considered to be a very efficient use of the marine space owing to the economic value and the very small areas used for this purpose. They felt because of this planning documents such as the Plan should have wording that promotes this specific use and development over others. It was suggested that establishing the economic value that is produced for every hectare of sea used for fish farming could be a tool that was used to prioritise this use over others.
25.2.3 These stakeholders felt that using economic value figures such as these could support the idea that areas thought to be suitable for fish farming should be protected from other forms of development. They felt this would fit with the objective for fish farming as stated in the Scottish Planning Policy.
25.2.4 Comments from other stakeholders included concerns that central government would override local preferences or other policies less politically leading. Another stakeholder felt the policies did not appropriately reflect the marine activities of the region and were too vague. This stakeholder also felt that not specifically mentioning protecting or minimising environmental impacts was a major oversight as one of the Guiding Principles of the Plan is 'an ecosystems approach to the management of human activities, climate change adaptation and mitigation'.
25.2.5 For Table 4 respondents provided comments in relation to where they felt changes or corrections were needed. One stakeholder reiterated comments made about Table 2 and noted most readers would likely not use the table.
Table 25.1 Sectoral Policy format and Table 4 - Table of suggested modifications
| No. | Suggested modification | Action taken | Reason |
|---|---|---|---|
| 240 | Policy Format - should this read 'Sectoral Policy Format' | None. | It is clear from the section title that sectoral policies are being referred to. |
| 241 | Why do we need the words "high level". Surely targets are targets whether high, low or whatever. | None. | High level is a term referred to in the UK Marine Policy Statement. |
| 242 | We suggest that the 'pressures' section should address (in relation to the specific sector) pressures on the particular sector ( e.g. economic pressures) and potential pressures (on marine ecosystems) caused by that sector ( e.g. impact of aquaculture on benthic habitats). This is why we suggest this section should be called 'issues' rather than 'pressures'. | None. | 'Pressures' is considered an appropriate term in the context of this marine plan. |
| 243 | Given the economic value of fish farming, and given the very small areas used for this purpose, would it not be reasonable to find a form of words in planning documents such as this that actually promote this specific use and development over others. Establishing the economic value that is produced for every hectare of sea used for fish farming could be a useful tool in seeking the prioritisation of this use over others. Equally, figures like this could help support the idea, referred to extensively in the SSPO response to the 'Planning Issues and Options' consultation in 2013, that areas of the sea thought suitable for fish farming should be protected from other forms of development. These ideas would fit much better with the overall objective of planning for fish farming as stated in SPP (2014). | None. | A balanced approach to the social, economic and environmental factors influencing sectoral development has been taken within the Plan. |
| 244 | The way policies for fish farming are worded is prejudicial compared to the wording used for other uses/development types. | None. | As the Plan is non-statutory, it is appropriate that the aquaculture policy signposts to the relevant statutory Local Development Plans and appropriate planning guidance. |
| 245 | We found the Sectoral policies were too vague and require additional detail. With the exceptions of policies 1, 5, and 8, there is no mention of protecting or minimising environmental impacts - a major oversight considering one of the Guiding Principles of the PFOW is 'an ecosystems approach to the management of human activities, climate change adaptation and mitigation'. | None. | The suite of General Policies including 1A, 1C, 4A, 4B, 4C, 4D, 4E, 5A, 6, 8A and 9 address the protection of the environment. |
| 246 | 'local sustainable development' requires further definition. | None. | Sustainable development is defined in Information Box 1. |
| 247 | Recreation, sport, leisure and tourism has a clear contribution to "Support management of the marine environment, marine development….. etc" with the installation of the marinas and the proposed development of Marine Tourism. | None. | The Objective 4 specifically relates to climate change as opposed the general management of the marine environment. |
| 248 | The majority of readers are likely to move past this table and therefore we advise that it would be of most use in a supporting document/ evidence base, rather in the plan itself. | None. | Table 4 provides a clear and concise diagram illustrating how the Plan policies contribute either directly, indirectly or have no clear contribution to the Plan objectives. |
| 249 | Table 4's title and key are not clear. Is a 'contribution' considered to be positive or negative to the objective? If positive then further explanation needs to be provided for justifying why sectors such as oil and gas or marine aggregates contribute positively to, for example the objective to '...protect and enhance the biological.... functioning of the marine and coastal environment.' | None. | Table 4 identifies where a sectoral policy contributes towards a Plan objective by addressing a potentially positive or adverse effects. |
| 250 |
|
None. None. None. None. |
The policies as drafted make no obvious contribution towards objective 2. The policy as drafted make no obvious contribution towards objective 6. The policy as drafted make no obvious contribution towards objective 9. An indirect contribution has been identified as the policy signposts to the relevant local development plan policy. |
| 251 | Inshore commercial fisheries are highly supportive in terms of contributing to a low carbon economy. Low food miles for local consumption, low fuel use. | None. | Noted. |
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