Planning Scotland's Seas: Possible Nature Conservation Marine Protected Areas. Consultation Analysis Report

7 Sustainability Appraisal

7.1 The consultation document explains that Nature Conservation MPAs are being identified using a science-led approach with provision for Scottish Ministers to have regard 'to any social or economic consequences of designation' during their considerations.

7.2 A Strategic Environmental Assessment and a Socioeconomic Assessment have been combined to form an overall Sustainability Appraisal. The Sustainability Appraisal informs the scientific recommendations with the social, economic and wider environmental considerations, while keeping sight of the overall benefits of the network.

7.3 The consultation set out potential costs for the sectors that may be affected: Aquaculture - finfish, Aquaculture - shellfish, Commercial fisheries, Energy generation, Military activities, Oil and gas, Port and harbours and Telecom cables.

7.4 Respondents were asked: 'Do you have any comments on the Sustainability Appraisal of the MPA network as a whole?' and 66 replied; this included 19 individuals and 47 organisations across most organisation groups.

7.5 In addition, one of the large campaigns included comment on the Sustainability Appraisal; 2,615 network campaign submissions included the following:

I do have a comment on the Sustainability Appraisal. I believe the Sustainability Appraisal does not fully account for the socioeconomic benefits that could arise from the proposed MPA network. For example, a recent study revealed that recreational diving and angling in 20 of the proposed MPAs in Scotland is valued at between £67 million and £117 million per year. In addition, divers and anglers questioned said they would make a one-off payment collectively worth between £142-£255 million to see these sites protected and damaging activities stopped. Similar studies are needed to demonstrate the benefits of the Scottish MPAs to other user groups.

7.6 Respondents from the mobile fishing group made a number of points. One main point was that the Sustainability Appraisal does not understand the specific circumstances of island communities. "The blunt measures of national economics do not reflect the sustainability of isles economies. The unsubsidised independent businesses of the numerous small scale fishermen that make up the fishery in Orkney survive against significant adverse conditions."

7.7 A small number commented that existing static gear and dive fishery activities have not harmed protected features in many of the proposed MPAs, for example around Orkney; they felt this should be established as a baseline.

7.8 A mobile fishing respondent wanted "a clear economic evaluation not just in terms of GVA but also in terms of the socioeconomic benefits it brings to local communities". A lack of alternative jobs for fishermen was mentioned with a comment that "Sustainable communities are maintained by sustainable employment."

7.9 A small number of aquaculture respondents said that only costs that could be quantified easily had been included and that even though other costs were difficult to quantify, such as delays or inability to expand or develop a site, they still existed and should be taken into consideration.

7.10 Similarly, a small number of energy respondents felt that not all costs had been included, for example deep water surveys that may be required to "underpin mitigation to deliver the management measures".

7.11 The approach to displacement was seen as sensible, however, there was disappointment from the aquaculture sector that no alternative locations to the inshore or sea loch MPAs had been suggested "due to the overall number of proposed MPAs which affect the finfish aquaculture sector." The benefits to the local economy from salmon or other fish farms were stressed as were other benefits to local communities.

7.12 Uncertainty, around designation, timescales and management plans, was seen as potentially damaging or negatively affecting the viability of an energy project. There was also concern that development of the network might deter investors, that there could be an impact on renewable energy and climate change targets.

7.13 An energy respondent asked how the Government will balance environmental goals with its goals for climate change mitigation and energy security.

7.14 Both mobile fishing and energy respondents commented that the Strategic Environmental Assessment assumes displacement will not occur; these respondents felt this to be unrealistic.

7.15 While some environment/conservation respondents said that this may not occur in many areas, others from this group commented that: "The potential effects of displacement of fishing activity have not been robustly considered within the Sustainability Appraisal and Strategic Environmental Assessment". One said: "Perhaps more fundamentally, where fishing pressures are moved within an MPA (or indeed where exclusion of one form of fishing pressure allows a significant increase in a different fishing pressure), no explanation of how management measures would be implemented has been provided". A local authority also commented on displacement saying that displacement to other areas may result in pressures on biodiversity in those areas; they said this effect is uncertain and unquantified; consultation with local stakeholders and additional information will be required.

7.16 Many of the environment/conservation respondents said that the Sustainability Appraisal was based on false assumptions and flawed information in relation to management costs. For example, upper estimates are based on complete closures of commercial fisheries but this option is seldom mentioned in management options papers. False assumptions on baselines were also a concern; the baseline referred to in documents was described as "neither accurate nor appropriate. In particular, it assumes that if no MPAs are designated, the current situation would continue and, as such, there would be no cost to any activity".

7.17 One environment/conservation respondent felt that the current proposals protect the status quo and are dependent on further discussion with the commercial fishing sector.

7.18 Another environment/conservation respondent, commenting on research into the value of recreational diving and angling in MPAs, asked if similar research had been undertaken with other user groups; this information is needed to account fully for the socioeconomic benefits from the proposed network.

7.19 Some environment/conservation respondents commented on a recent survey by Kenter et al (2013) saying that this is a useful starting point for evaluating the indirect and non-use value of MPAs and for illustrating the value of MPAs to diving and angling.

7.20 Respondents from this group, along with individuals, were concerned that only potential losses to the mobile fishing sector had been quantified and that the potential positive value in terms of tourism, static fishing, diving and sea angling had not been adequately quantified. A environment/conservation respondent said the Sustainability Appraisal "must therefore be understood as presenting a worst case scenario on the one hand (likely displacement of fishing activity is not included for instance) and a weak financial benefits case on the other."

7.21 Many of the mobile fishing group commented that the potential for displacement must be considered prior to designation: "There is a reason why vessels fish where they do, that is where the most productive grounds are and displacement is likely to have cost implications for the fleet. Issues to be considered when moving to other areas are higher fuel costs, gear conflict, fishing ground may already be in use for another purpose, quota issues; vessels may not have quota available for what can be caught in the area they are displaced to, all of which have to be taken into consideration".

7.22 Displacement for other activities was also addressed by a public sector respondent who commented on potential costs to operations. Again, uncertainty around management measures was not welcomed "Inconsistency in approach and unknown measures that may impact delivery of our project builds or services are of significant concern … as our customers must bear the financial cost."

7.23 There was a comment that the Sustainability Appraisal is incomplete as economic and environmental displacement effects need to be considered.

7.24 Environment/conservation respondents also commented that the value of marine wildlife tourism including seabird tourism has not been considered and that there have been limited efforts to value non-use benefits. Individuals and organisations from several groups said that the Sustainability Appraisal does not account fully for socioeconomic benefits that could arise from the network.

7.25 A local authority commented that there seems to be a focus on short term financial loss rather than long term economic and environmental benefits.

7.26 Differences in analysis methodology between the Sustainability Appraisal and Strategic Environmental Assessment were also mentioned with one environment/conservation respondent saying that this "does not provide a consistent knowledge base to fully inform the decision-making process".

7.27 Comments from industry/ transport respondents included concern that potential costs of relocation for commercial anchorages have not been considered, although they allowed that most are likely to be minimal. There was also a concern in this sector over a possible loss of investor confidence from potential extra responsibilities, assessments, costs and delays that may result from the designation of a site. A public sector respondent was concerned that costs for additional work that will be required of for example, energy companies, had not been considered saying that "many factors contribute to the sanctioning of a project, including the consideration of development costs in other parts of the world. If development is hindered this could have serious economic impacts on Scotland and the UK".

7.28 There were also comments that the drive to increase salmon farming conflicts with "maintaining a diverse ecosystem and that industry will destroy organisms that make up the biodiversity of the marine environment."

Summary - Sustainability Appraisal

A large number of campaign respondents said that the Sustainability Appraisal does not fully account for the socioeconomic benefits that could arise from the proposed MPA network.

There were comments, from standard responses, that not all costs and benefits had been included. Some felt it had been based on false assumptions and flawed information in relation to management costs.

Some commented that the Sustainability Appraisal is based on closure or restrictions to fishing and the management options don't always propose such action.

Some commented that the Strategic Environmental Assessment assumes displacement will not occur; this was seen as unrealistic. Others said that the potential effects of displacement of fishing activity have not been robustly considered.

There were also comments that, in relation to the importance of the fishing industry and especially small scale fishing, the Sustainability Appraisal does not understand the specific circumstances of island communities.