Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report

13 RECREATION AND TOURISM

Chapter summary

• Some respondents considered this chapter of the Draft NMP is not clear on the intended extent of the marine planning policies, for example, whether these policies are intended to address only development and activity requiring consent and/ or licence.
• There were requests for more data to be referenced throughout the chapter and for more research to be undertaken; for example, research to identify key areas for activities or to ascertain how different sectors interact and the relative benefits of any interaction. There were some concerns over the potential for conflict between different sectors.
• A number of respondents referred to coastal walking with some requests for this to link to the National Planning Framework 3 for a National Network of Long Distance Paths and Trails; along with greater recognition of the social and economic benefits of a coastal path. There were some concerns that new coastal developments might compromise the integrity of coastal access paths.
• There were references to the National Tourism Plan / Strategy and for this to feed into future land use and marine planning; allied to this there were calls for a consistent application across Local Authorities.
• There were calls for the need to ensure the sustainable development of this sector; and the need to balance the economic benefits of tourism and recreation against the need to protect habitats and species, or the environment more generally.

13.1 The Draft NMP noted that Scotland's marine and coastal areas support a range of recreational, sporting and visitor activities; activities that offer a significant contribution to the Scottish economy. The Scottish Government has identified tourism as a growth sector and the Draft NMP acknowledged the need for marine planning to support economic growth by ensuring that access to coastal and intertidal areas is protected and supported.

13.2 Interactions with other users are rarely in conflict, although there may be some environmental impacts from recreation and tourism, for example, habitat damage and loss or disturbance / noise. Climate change could have positive and negative impacts on recreation and tourism.

13.3 The Draft NMP outlined seven marine planning policies in relation to recreation and tourism and also commented on the future of this sector.

Comments on Recreation and Tourism, Chapter 12

13.4 Respondents were asked:

Question 26: Do you have any comments on Recreation and Tourism, Chapter 12?

13.5 Fifty-eight respondents provided commentary at Q26 and the profile of these is shown in table 13.1 below. The table below shows that comments were made by all sub-groups, although the greatest number of comments came from respondents in Local Authorities and the environment/ conservation and recreation/ tourism sectors.

Table 13.1 Question 26: Do you have any comments on Recreation and Tourism?

Respondent group
Individuals (16)	7
Academic / scientific (7)	4
Aquaculture (5)	2
Energy (12)	5
Environment / conservation (9)	6
Fisheries (13)	3
Historic / Heritage (5)	3
Industry / transport (9)	1
Local Authority (15)	10
Local coastal partnership (7)	3
Local group (5)	1
Other public sector (10)	5
Recreation / Tourism (7)	7
Other (4)	1
Total (124)	58

13.6 While a number of themes emerged, most appeared in fewer than 12 responses. A significant number of respondents welcomed some or all of the information provided in this chapter; some noting overall support, while some welcomed specific objectives and/ or planning policies for this sector. There was also support for the recreation/ tourism sector and its importance to the Scottish economy.

13.7 That said, there were small number of comments that the chapter is not clear on the intended extent of the marine planning policies. For example, whether these policies are intended to address only development and activity requiring consent and/ or licence, or whether this would extend to the planning and management of an activity beyond the consenting regime; or whether there is any limit within the Marine Planning Act on what the NMP policies can address.

13.8 There were a number of comments made about the need to reference more data throughout the chapter to illustrate some of the points being made or for more data to be collected in support of this chapter. For example, there was support from a number of respondents for Marine Scotland to undertake research into participation levels and key areas of activity. One respondent in the environment / conservation sector noted:

"We would be pleased to see the Scottish Government undertake more research to gather data on marine recreation participation and its economic and environmental impacts and benefits where there are gaps in the data."

13.9 There were also some requests to conduct research into marine recreation participation and facilities in order to identify key areas for activities to ensure their inclusion in the marine planning process. Another respondent noted the need for research into the interactions between recreation and tourism and other industries to obtain a better understanding of the ways in which they interact and the relative benefits of this interaction.

13.10 A number of respondents, primarily within Local Coastal Partnerships and the recreation/ tourism sectors, commented on the chapter section on coastal walking. There were requests from some respondents for a link to the National Planning Framework for a National Network of Long Distance Paths and Trails and the need for greater recognition of the social and economic benefits of a coastal path. One respondent in the recreation/ tourism sector noted the opportunities to create a network of long distance walking and cycling routes including links by canals, which could be also extended into marine areas.

"[We] would wish to reiterate the spirit of our response to the NPF3 i.e. the importance of integrating terrestrial and land-based planning and in particular for both to take account of the spatial importance of tourism."

13.11 Two Local Authorities also noted that the coastal walking section needs to state that new coastal developments should not compromise the integrity of coastal access paths. Two respondents in the recreation/ tourism sector noted the need for the NMP to make reference to access rights in general. Two Local Authorities also noted the need for the national priorities to be referenced in relation to coastal path networks and "blue "recreational routes because of their significant economic potential.

13.12 A respondent in the recreation/ tourism sector noted concerns over the impact of salmon farming upon recreational angling and the potential for conflict between the two sectors. They suggested a spatial approach that would restrict the siting of fish farms adjacent to sea trout spawning areas. This concern was amplified because while salmon farming is governed by land use planning, there is no third party right of appeal against decisions.

13.13 There were also a number of references to the National Tourism Plan/ Strategy and the need for the National Tourism Development Framework to be used to inform future land use and marine based plans and for a greater emphasis to be placed upon this.

13.14 There were also some calls - primarily from respondents within the recreation/ tourism sector for strategic marine and land use planning across Local Authority boundaries to help grow this sector and to link into local development plans. They emphasised the importance of integrating marine and land based planning in order to pay heed to tourism in and across Scotland and the need for joined up working across local boundaries and different stakeholder organisations.

13.15 While there was general support for the recreation/ tourism chapter, there were a number of qualifying statements made by some respondents. Some respondents noted the need to ensure the sustainable development of the marine recreation and tourism sector. There were also some comments that the economic benefits of recreation and tourism need to be balanced against the need to protect habitats and species or the need for a balance between the natural environment and the development of tourism and recreation.

13.16 A small number of respondents, primarily in the fisheries sector, noted that recreation and tourism activities may need to be subject to controls as part of an integrated marine and coastal management strategy. Two respondents from recreation/ tourism noted the need for policy to recognise the difference between recreation and tourism; there were also a small number of comments about the potential for conflict between recreational users and other users of the marine environment.

13.17 There was a degree of support for codes of conduct or good practice guidance to be introduced to reflect existing guidance and codes of conduct as well as any new guidance that is introduced. One or two respondents noted the Draft NMP does not make it clear where the responsibility lies for their implementation.

13.18 Three individuals noted concerns over the damage caused by offshore renewable developments and the damaging impact this can have on tourism.

Alternative planning policies

13.19 Respondents were asked:

Question 27: Are there alternative planning policies that you think should be included in this chapter?

13.20 Only seven respondents provided any comment here. Additional planning policies respondents would like to see included were:

• Sustaining vibrant coastal communities where tourism is key to an area's social and economic future;
• A policy that acknowledges the need to maintain or enhance the wildlife and/or wilderness qualities which attract so many people to Scotland's coasts;
• Either an extension of Recreation and Tourism Policy 4 or a new policy added to provide that marine recreation and tourism activity should not unacceptably impact upon heritage assets;
• Scottish Planning Policy states that local development plans should safeguard access rights and enhanced opportunities for access linked to wider networks. A complementary policy should be provided by the NMP;
• Health and wellbeing benefits to be explicitly recognised through a sectoral objective in Chapter 12;
• Adherence to requirements of Bathing Water legislation;
• To improve education and understanding of the marine environment for recreational users, including how to enjoy it responsibly in accordance with the Marine Wildlife Watching Code and the Scottish Outdoor Access Code.

13.21 A respondent suggested a similar policy to Recreation and Tourism Policy 4 should be included in the chapters on aquaculture, renewables and transport.