Seas off St Kilda Special Protection Area: business and regulatory impact assessment
An assessment of the business and regulatory impacts of classifying the seas off St Kilda Special Protection Area.
Options
Option 1: Do nothing
This option is not predicted to create any additional costs to the sectors and groups outlined above.
However failure to classify the “most suitable territories” as SPAs would leave the Scottish Government exposed to a high risk of EU infraction proceedings, which may result in substantial one off and recurring fines.
In addition it should be noted that the societal cost of not classifying could be both large and irreversible relative to the current condition of the marine environment. The absence of management measures to conserve the identified features may produce future economic and social costs in terms of increased marine habitat and biodiversity degradation. The option to not classify holds the potential to undermine the overall ecological coherence of the Scottish SPA Network. This potentially large and irreversible societal cost avoided is presented within the benefits section of the ‘do classify’ scenario (option 2) to avoid double counting the same impact.
Option 2: Classify site as a Special Protection Area
Option 2 involves the formal classification of the Seas off St. Kilda site. Classification would provide recognition and protection to the natural features of the site while also contributing to the wider Scottish and UK SPA network. Requisite management would be required to maintain the status of the site.
- Sectors and groups affected
The following sectors have been identified as present (or possibly present in the future) within the Seas off St. Kilda site and potentially interact with one or more of the features:
- Commercial fisheries
- Military
- Shipping
- Public Sector
Affected sectors may be impacted to a greater or lesser degree by classification depending on which scenario is pursued and which management option is preferred.
Benefits
Option 1: Do nothing
No additional benefits are expected to arise from this policy option.
Option 2: Classify site as a Special Protection Area
The extent and quality of habitat and available food around Scotland’s coast supports huge numbers of different species of seabirds. Few countries can match this and we have an international responsibility to protect what we have around Scotland. Therefore the appropriate action is to protect and maintain Scotland’s seabird and water bird populations and meet the requirements of the EU Birds Directive.
SPAs are created to meet international commitments under the EU Wild Birds Directive, which promotes the conservation of wild birds. SPAs are managed to safeguard the birds and avoid significant disturbance and deterioration of their habitats. This means that proposed activities likely to affect a SPA are assessed for their potential to cause such disturbance or deterioration. The relevant consenting authority must ensure beyond reasonable scientific doubt that any impact is not significant before permitting the activity.
While it may not be possible with current levels of research to monetise benefits with a satisfactory degree of rigour, it is clear that many of the benefits relate to aspects of our lives that we take for granted and for which it is good practice and common sense to maintain through protection measures such as SPAs.
Contribution to an Ecologically Coherent network
Scotland's seas support a huge diversity of marine life and habitats, with around 6,500 species of plants and animals, with plenty more no doubt to be found in the undiscovered deeps of the north and west of Scotland. Our seas account for 61% of UK waters and remain at the forefront of our food and energy needs, through fishing, aquaculture, oil and gas, and new industries such as renewables, as well as recreation activities and ecotourism. This SPA is a contribution to a wider network of Marine Protected Areas designed to conserve and regenerate our seas. This in turn will help ensure that ecosystem goods and services continue to support current and future generations. It is likely that an ecologically coherent network of marine protected areas is likely to provide greater benefit than the sum of its individual components.
Ecosystem Services Benefits
Ecosystems are very complex, and it is thought that the more complex an ecosystem is the more resilient it is to change. Therefore, if it is damaged or if a species or habitat is removed from that ecosystem, the chances of survival for those services reduce as the ecosystem becomes weaker. However, by conserving or allowing the species and habitats that make up that ecosystem to recover, we can be more confident of the continuation of the long term benefits the marine environment provides.
Non-Use Values
Non-use value of the natural environment is the benefit people get simply from being aware of a diverse and sustainable marine environment even if they do not themselves use it. We take for granted many of the things we read about or watch, such as bright colourful fish, reefs and strange shaped deep sea curiosities, to lose them would be a loss to future generations that will not be able to experience them. It is challenging to put a precise value on this, but the high quality experience derived from Scotland’s seas can be better preserved through measures such as SPAs.
It is expected that non-use value will be attained as a result of classification and the support of wider conservation objectives. Whilst ecosystem services benefits at an individual site level cannot be readily calculated, the one-off non-use value to Scottish households of marine conservation in Scottish waters generated by the additional 14 SPAs is estimated to be in the region of £74 million.[4] This figure uses valuation evidence across several sites with similar features and characteristics and highlights the significant positive non-use value that divers and anglers within the Scottish marine environment place on securing the quality of the marine resources they use as a result of protection against degradation.
Use Values
There could be a major transformative effect on inshore habitat and a significantly enhanced flow of environmental goods and services. We know the inherent capacity of the system and the flora and fauna that it could support. Achieving that could see the expansion of recreational activities such as diving, sea-angling, and other tourism alongside sustainable methods of fishing.
Research by Kenter et al[5] has been used to estimate the use benefits to divers and anglers specifically, as a result of classifications safeguarding the total recreational value of the sites. The additional increase in recreational value as result of implementing management measures for the 14 new SPAs has an estimated total present value of £2.1-6.2 million over the 20 year assessment period.[6]
In addition there is likely to be increased activity for businesses in the marine wildlife and tourism sector. This includes those directly involved (e.g. operating boat trips) and those benefiting indirectly (e.g. accommodation providers). The scale of this increase across the proposed sites cannot be quantified, but it can be expected to be some increment of the existing value of these activities. Given the marine wildlife tourism market is currently estimated to be worth £100’s of millions per year, an increment of this could be expected to be worth in the region of £10 million per year across the network to the Scottish wildlife tourism market.[7]
Summary of Benefits
The uncertainties in each of the benefits assessed result in a large range of estimated values. Based on the available evidence, the combined total present value of the benefits for the new network (based on the additional benefits of the 14 new SPAs and 4 MPAs combined) is tentatively estimated to be between £130 million and £240 million over the 20 year assessment period.[8]
For a qualitative summary of anticipated benefits to ecosystem services in this particular site see appendix A.
Costs
Option 1: Do nothing
This option is not predicted to create any additional costs to the sectors and groups outlined above.
However failure to classify the “most suitable territories” as SPAs would leave the Scottish Government exposed to a high risk of EC infraction proceedings, which may result in substantial one off and recurring fines.
In addition it should be noted that the societal cost of not classifying could be both large and irreversible relative to the current condition of the marine environment. The absence of management measures to conserve the identified features may produce future economic and social costs in terms of increased marine habitat and biodiversity degradation. The option to not classify holds the potential to undermine the overall ecological coherence of the Scottish SPA Network. This potentially large and irreversible societal cost avoided is presented within the benefits section of the ‘do classify’ scenario (option 2) to avoid double counting the same impact.
Option 2: Classify site as a Special Protection Area
Costs have been evaluated based on the implementation of potential management measures. Where feasible costs have been quantified, where this has not been possible costs are stated qualitatively. All quantified costs have been discounted in line with HM Treasury guidance using a discount rate of 3.5%. Discounting reflects the fact that individuals prefer present consumption over future consumption.
Commercial Fisheries:
According to VMS-based estimates and ICES rectangle landings statistics, pelagic trawls, lines, whitefish trawls, pots and other gears (over-15m) and pots and other gears (under-15m vessels) operate within the Seas off St Kilda SPA. The value of catches from the SPA area was £5,406,000 (over-15m vessels) and £3,000 (under-15m vessels, indicated from ICES rectangle landings data) (annual average for 2009–2013, 2015 prices). Landings from the over-15m vessels are predominantly into Peterhead (31% by value), Lerwick (17%) and Egersound (17%). For the over-15m fleet, pelagic and whitefish trawls operate across the north-west half and in the south-east corner, lines operate across the north and pots operate in the east part of the SPA.
Management measures for the scenarios have been developed based on the sensitivity and vulnerability of the features to the pressures caused by different gear types and SNH recommendations.
Uprated ScotMap data (under-15m vessels) indicate that the annual average earnings from the Seas off St Kilda SPA was £44,000 for the period 2007-2011, with pots contributing the highest value. The ScotMap data only covers the south-east section of the site; there is no under-15m fishing reported in the more westerly ICES rectangles. The coverage for ScotMap interviews in the region was around 87% (total value of reported landings from the Fisheries Information Network for those vessels included in the ScotMap value analysis expressed as a percentage of the total reported landings for all vessels <15m); the spatial representation of the value of fishing is more robust in regions where coverage is higher.
No landings based GVA calculation is required for this site since the management measures are only concerned with one-off costs of implementing by-catch mitigation measures.
| Lower Estimate | Intermediate Estimate | Upper Estimate | |
|---|---|---|---|
| Assumptions for cost impacts |
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| Description of one-off costs |
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|
|
| Description of recurring costs |
|
|
|
| Description of non-quantified costs |
|
|
|
| Total costs (2015–2034) | 0.012 | 0.012 | 0.012 |
|---|---|---|---|
| Average annual costs | 0.001 | 0.001 | 0.001 |
| Present value of total costs (2015–2034) | 0.012 | 0.012 | 0.012 |
Military
2 military practice areas (Hebrides (D701A) and Hebrides (D701C); both firing danger areas) overlap with the Seas off St Kilda SPA.
The features which overlap with military activities have not been described as vulnerable to MoD activities in this SPA. It is assumed that management relating to MoD activity will be coordinated through the MoD’s Maritime Environmental Sustainability Appraisal Tool (MESAT) which the MoD uses to assist in meeting its environmental obligations. This process will include operational guidance to reduce significant impacts of military activities on SPAs. It is assumed that the MoD will incur additional costs in adjusting MESAT and other MoD environmental assessment tools in order to consider whether its activities will impact on the conservation objectives of SPAs and also incur additional costs in adjusting electronic charts to consider SPAs. However, these costs will be incurred at national level and hence no site-specific cost assessments have been made.
Shipping
AIS data for vessels carrying hazardous cargoes, assumed to be all vessels >300GRT, transiting the Seas off St Kilda SPA boundary have been assessed to consider the establishment of a voluntary ‘Area To Be Avoided’ (ATBA). A potential cost is anticipated due to the additional steaming distance to avoid transiting the SPA boundary. Cost of additional time to complete the extended transect are based on an estimated hourly cost of tankers (£1,215 per hour).
| Lower Estimate | Intermediate Estimate | Upper Estimate | |
|---|---|---|---|
| Assumptions for cost impacts |
|
|
|
| Description of one-off costs |
|
|
|
| Description of recurring costs |
|
|
|
| Description of non-quantified costs |
|
|
|
| Total costs (2015–2034) | 0.000 | 0.000 | 1.843 |
|---|---|---|---|
| Average annual costs | 0.000 | 0.000 | 0.092 |
| Present value of total costs (2015–2034) | 0.000 | 0.000 | 1.330 |
Public Sector:
The decision to classify the Seas off St. Kilda site as a SPA, would result in costs being incurred by the public sector in the following areas:
- Preparation of Marine Management Schemes
- Preparation of Statutory Instruments
- Development of voluntary instruments
- Site monitoring
- Compliance and enforcement
- Promotion of public understanding
- Regulatory and advisory costs associated with licensing decisions
Some of these costs will accrue at the national level and as such have not been disaggregated to site level.
| Lower Estimate | Intermediate Estimate | Upper Estimate | |
|---|---|---|---|
| Preparation of Marine Management Schemes | 0.025 | 0.000 | 0.000 |
| Preparation of Statutory Instruments | 0.005 | 0.005 | 0.005 |
| Development of voluntary measures | 0.000 | 0.000 | 0.000 |
| Site monitoring | 0.000 | 0.000 | 0.000 |
| Regulatory and advisory costs associated with licensing decisions | 0.000 | 0.000 | 0.000 |
| Total Quantified Public Sector Costs | 0.005 | 0.005 | 0.005 |
Total Costs
Total quantified costs are presented in present value terms. Commercial fisheries costs are presented in terms of GVA.
| Sector | Lower Estimate | Intermediate Estimate | Upper Estimate |
|---|---|---|---|
| Commercial Fisheries | 0.012 | 0.012 | 0.012 |
| Military | See National Costs | See National Costs | See National Costs |
| Shipping | 0.000 | 0.000 | 1.330 |
| Public Sector | 0.005 | 0.005 | 0.005 |
| Total Present Value of Costs | 0.017 | 0.017 | 1.347 |
| Scenario Sector/Group |
Low | Intermediate | Upper |
|---|---|---|---|
| Commercial fisheries |
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|
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Contact
Email: Marine_Conservation@gov.scot
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