Planning Scotland's Seas: Priority Marine Features - Analysis of Consultation Responses

4 ADDITIONAL COMMENTS

4.1 The second question on the consultation allowed respondents the opportunity to make additional comments which they felt were pertinent to the exercise. Question 2 of the consultation asked:

Q2. Are there other issues that have not been highlighted in this consultation that you would like to mention?

4.2 Twenty-two consultation responses added additional comments at this stage. Table 4.1 below shows the profile of those responding.

Table 4.1 Question 2

4.3 Four respondents added comments which were broadly supportive of the process - one recreation/tourism organisation agreed that the process seemed logical, robust and objective, whilst two other recreation/tourism organisations welcomed having a single list. A local authority added specific support for a six yearly review process, as proposed for new Marine Protected Areas.

4.4 Six responses made some form of suggested amendment or improvement to the PMF list and process. Two environment/conservation organisations stated that it is important to ensure threatened or declining species which were not included in the PMF list were not ignored altogether, citing those at risk from climate change as a key example. Aligned with this, an individual added that the PMF list needs to bear in mind species which will migrate to Scottish waters on the basis of climate change.

4.5 Another environment/conservation organisation suggested that the outputs from the MPA network need to be fed back into the PMF list, stating:

"In the absence of more evidence that the developing MPA network will be coherent for representative marine biodiversity features (in addition to those that are rare, threatened and declining), we remain to be convinced that the existing network of marine Special Areas of Conservation will provide sufficient area-based protection measures to represent the full range of rock reef habitats in Scottish waters. It may be that, as understanding develops, further additional examples of representative habitat-types will be identified that should be added to the PMF list to drive conservation action both inside and outside MPAs."

4.6 Similarly, a local authority stated that they felt there was a need for the NMP to define the status of PMFs and what weight should be attributed to them in decision making.

4.7 Another local authority stated that in terms of management of the PMFs, there is a need to ensure balance so that all activities having the potential to have a significant impact on PMFs can be considered at licencing stage.

Points of Clarification

4.8 The majority of comments received in relation to the second question on the consultation document related to desired points of clarification. The most notable point of clarification related to the purpose and/or intention of the list and the status of protection, highlighted in five separate consultation responses. As one local authority put it:

"The reference [1] to 'Marine Scotland guidance on safeguarding Priority Marine Features' links to the current consultation paper on PMFs. This document outlines the purpose of PMFs and the process of identifying PMFs, it does not provide guidance on how they should be safeguarded in regional marine plans. The Scottish Government should provide this guidance within the National Marine Plan, or separately, with a hook to this guidance within the National Marine Plan."

4.9 Three responses mentioned a lack of clarity on the benefits of inclusion of some PMFs ( e.g. Natura 2000 species and marine animals) which are already protected for example by European legislation - however the development of a single list was welcomed by some.

4.10 Other points of clarification included:

• Clarification on the licensing process;
• Clarification on how PMFs relate to MPA and whether management measures will be extended to areas outside of the MPA;
• Clarification on how the three pillar approach should be addressed in marine plans;
• Clarification on the regulatory status of PMFs;
• Clarification on the process of features being added to or removed from the list;
• Clarification on the risks/pressures to PMFs;
• Clarification on whether PMFs are already in force or in draft;
• More information required on implications on fisheries and angling on account of commercial and recreational species.