HPMA – Highly Protected Marine Area Consultation

[NickB]

(from the latest CC minutes March 2023)

I would urge everyone to look at this and let us know your views and comment from the links on the document. Essentially the consultation sets out the proposed selection criteria, which will be used for HPMAs and the activities which will be restricted (fully or partially) within these areas. The proposal is that Scotland should align with the three most strictly protected categories. The consultation has been extended to 17th April so please have a look and comment, it is important, and will impact on you.

Proposed restrictions within the HPMA areas include (but are not limited to) a ban on: Fishing (commercial and recreational), collection of shellfish, seaweed harvesting, renewable energy developments, developments of new ports, harbours, ferry piers and marinas, subsea cables (exemption for ‘lifeline’ services to islands, hydrogen production and space ports). Subsistence use of the sea has been mentioned and likely falls under the category of ‘recreational fishing’.

The proposal includes a list of areas where HPMAs will not be located but focuses on large scale energy projects, ports, and defence, rather than on community-level uses of the sea. The definition of ‘port or harbour’ is unclear within the consultation documents. The proposal considers allowing some restricted activity to be allowed on a permit basis.

Things to note: The following areas have been proposed as a framework for considering whether an area should become an HPMA site: Blue Carbon, Essential Fish Habitats, Strengthening the Scottish MPA network, protection from storms and sea level rise, research and education, enjoyment and appreciation, other important ecosystem services. It is not clear if existing data which would be used to help select HMPA areas is granular enough to reflect direct and indirect local-level impacts in communities. While potential community benefits of HPMAs are listed, negative impacts at a community level are not.

It is proposed that the main criteria for site selection be the contributions that sites will make to the HPMA plan compared to other areas. The assessment does not consider cultural practices related to the sea and their contribution to health and wellbeing of local people, nor local food systems which contribute to food security. Impacts have been quantified in monetary terms. It is unclear which stakeholders were involved in this appraisal. Partial Island Communities Impact Assessment (ICIA) Screening Report – things to note; only part of the ICIA process has been carried out – the consultation is asking whether a full ICIA should be carried out.

This includes considering impacts for individuals, communities, and businesses to help inform which areas are selected for consideration as HPMAs.

www.gov.scot/publications/scottish-high ... ion-paper/

www.scottish-islands-federation.co.uk/d ... sultation/

The key stakeholders who have been consulted are a combination of industry-specific bodies and interest groups operating at a national or regional scale, with no clear representation from communities or bodies representing communities. It is not clear whether the ICIA has considered food security, cost of living, decarbonisation, development of transport networks, or cultural practice in an island-specific context. It is not clear whether the ICIA has considered the different impact the loss of jobs can have in small islands. Partial Business and Regulatory Impact Assessment (BRIA) – things to note; states that ‘A range of businesses will be affected by this legislation. We expect small, medium, and large businesses to be affected directly and indirectly in a number of different sectors. Since the selection site for HPMAs has not taken place yet, we cannot estimate the costs to businesses.’ It states that ‘HPMAs could also impose environmental costs, such as the concentrating of fishing efforts around the boundary of HPMAs and the displacement of fishing efforts to less managed areas where the stocks might also be vulnerable’.

At this stage no locations have been suggested but we are potentially an area, so we need to consider the impacts (positive and negative) that implementing an HPMA on a variety of areas may have in our islands.

While a ‘partial’ Island Community Impact Assessment has been undertaken as part of the consultation process, we note that the key stakeholders who have been consulted are a combination of industry-specific bodies and interest groups operating at a national or regional scale, with no representation from communities or bodies representing communities. We therefore think it is important to both encourage islanders to respond to this consultation to ensure that island voices are represented, as well as submitting a response on behalf of our community.

Concerns were raised at the meeting about how this would be policed if implemented, that it would do nothing other than turn folk against each other when people were reported. It was also raised that we are in a shipping area with numerous yachts sailing through our area all of whom are discharging raw sewage into the sea, which would impact the area. It was further noted that in the community there are still numerous properties with no septic tanks discharging directly into the sea. Concerns raised that the documents were too vague when applying the criteria and how they would be managed, and that HPMAs are to cover 10% of the water although the Scottish Government is looking to increase this further. Further concerns were raised that fishing is in decline so any measures would be negated by the above. Zim asked that word is spread, and people comment on the proposal. The CC will be doing a response, and suggestions were given by Luna.