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scottish-highly-protected-marine-areas-consultation-questions March 2023.._

Argyll and Bute Council · 22 March 2023
Back to Planning, Protective Services and Licensing Committee — 22 March 2023 and its agenda

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Page 1

3. Consultation Questions
3.1. Why your views matter
The Scottish Government is committed to realising our vision of the marine
environment being clean, healthy, safe, productive, diverse and managed to meet
the long term needs of nature and people. Your responses will help to shape and
inform how we do this.
Respondents should take into consideration the information provided in this
document alongside any other knowledge or personal experiences that could be
relevant. All opinions are welcome.
You are invited to answer all the questions. However, if you are unable to answer
any question then please feel free to skip and move on to the next.
The questions are asked in relation to specific documents: (i) Policy Framework: (ii)
Site Selection Guidelines; (iii) Initial Sustainability Appraisal; (iv) Partial Island
Communities Impact Assessment (ICIA) Screening Report; and (v) Partial Business
and Regulatory Impact Assessment (BRIA). 
We recommend reading the full suite of documents before starting to submit
your responses. 
Appendix A

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3.2. Policy Framework
1. What is your view of the aims and purpose of Highly Protected Marine Areas as
set out in sections 2 and 3 of the draft Policy Framework?
Strongly support   Support  Neutral  Oppose  Strongly oppose
Please explain your answer in the text box:
2. What is your view of the effectiveness of the proposed approaches to manage
the activities listed below, as set out in section 6 of the draft Policy Framework,
in order to achieve the aims and purpose of HPMAs?
Activity Strongly
support
Support Neutral Oppose Strongly
oppose
1 Commercial fishing (of any
kind)
2 Recreational fishing (of any
kind)
3 All other recreational
activities
4 Finfish aquaculture
5 Shellfish aquaculture
6 Seaweed harvesting
7 Oil and gas sector
8 Renewable energy
9 Carbon capture, utilisation
and storage

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Activity Strongly
support
Support Neutral Oppose Strongly
oppose
10 Subsea cables
11 Aggregate extraction
12 Ports and harbours
13 Shipping and ferries
14 Military and defence
15 Hydrogen production
16 Space Ports
Please explain your answer in the text box and if you think we have missed any
activities, please suggest them here:
3. What is your view of the proposed additional powers set out in section 8.3.2 of
the draft Policy Framework: “Allow for activities to be prohibited from the point of
designation to afford high levels of protection.”
Strongly support   Support  Neutral  Oppose  Strongly oppose

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Please explain your answer in the text box:
4. What is your view of the proposed additional powers set out in section 8.3.3 of
the draft Policy Framework: “Establish processes to permit certain limited
activities within a HPMA on a case-by-case basis for specified reasons.”
Strongly support    Support   Neutral  Oppose  Strongly oppose
Please explain your answer in the text box:
5. What is your view of the proposed additional powers set out in section 8.3.4 of
the draft Policy Framework: “Activities which are not permitted in a HPMA but are
justified in specified cases of emergency or force majeure.”
Strongly support    Support   Neutral  Oppose  Strongly oppose
Please explain your answer in the text box:

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6. What is your view of the proposed additional powers set out in section 8.3.5 of
the draft Policy Framework: “Measures for activities allowed and carefully
managed in HPMAs.”
Strongly support    Support   Neutral  Oppose  Strongly oppose
Please explain your answer in the text box:
7. Do you have any further comments on the draft Policy Framework, which have
not been covered by your answers to the previous questions?
Please add your response in the text box:

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3.3. Site Selection Guidelines
8. What is your view of the proposal that HPMA site identification should be based
upon the “functions and resources of significance to Scotland’s seas,” as listed
below and set out in Annex B of the draft Site Selection Guidelines?
Function and
Resources
Strongly
support
Support Neutral Oppose Strongly
oppose
1 Blue Carbon
2 Essential Fish Habitats
3 Strengthening the
Scottish MPA network
4 Protection from storms
and sea level rise
5 Research and
education
6 Enjoyment and
appreciation
7 Other important
ecosystem services
Please explain your answer in the text box, including any suggested changes to the
list:

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9. What is your view of the general principles that are intended to inform the
approach to HPMA selection, as listed below and set out in section 4.1 of the
draft Site Selection Guidelines?
General principle Strongly
support
Support Neutral Oppose Strongly
oppose
1 Use of a robust
evidence base
2 HPMA scale and the
use of functional
ecosystem units
3 Ensuring added value
4 Delivering ecosystem
recovery
Please explain your answer in the text box, including any suggested changes to the
list:
10. What is your view of the proposed five-stage site selection process, found in
sections 4.2 and 4.3 as well as figure 2 and Annex A of the draft Site Selection
Guidelines?
Strongly support   Support  Neutral  Oppose  Strongly oppose

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Please explain your answer in the text box:
11. Do you have any further comments on the draft Site Selection Guidelines, which
have not been covered by your answers to the previous questions?
3.4. Initial Sustainability Appraisal
12. What is your view of the Strategic Environmental Report, summarised within
sections 3 and 4 of the Sustainability Appraisal, as an accurate representation of
the potential impacts, issues and considerations raised by the introduction of the
draft Policy Framework and Site Selection Guidelines?
Strongly support   Support  Neutral  Oppose  Strongly oppose

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Please explain your answer in the text box:
13. What is your view of the Socio-Economic Impact Assessment, summarised within
sections 3 and 4 of the Sustainability Appraisal, as an accurate representation of
the potential impacts, issues and considerations raised by the introduction of the
draft Policy Framework and Site Selection Guidelines?
Strongly support    Support   Neutral  Oppose  Strongly oppose
Please explain your answer in the text box:
3.5. Partial Island Communities Impact Assessment (ICIA) Screening Report
14. What is your view of the partial ICIA screening report as an accurate
representation of potential impacts, raised by the implementation of the draft
Policy Framework and Site Selection Guidelines?
Strongly support   Support  Neutral  Oppose  Strongly oppose

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Please explain your answer in the text box:
15. Do you think that the implementation of the draft Policy Framework and Site
Selection Guidelines will have any significantly differential impacts – positive
and/or negative - on island communities?
Yes  No  Not sure
Please explain your answer in the text box, including any additional impacts that
have not been identified in the partial ICIA screening report:
3.6. Partial Business and Regulatory Impact Assessment (BRIA)
16. What is your view of the partial BRIA as an accurate representation of the
potential impacts, issues and considerations raised by the implementation of the
draft Policy Framework and Site Selection Guidelines?
Strongly support   Support  Neutral  Oppose  Strongly oppose

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Please explain your answer in the text box:
17. Do you think that the implementation of the draft Policy Framework and Site
Selection Guidelines will have any financial, regulatory or resource impacts –
positive and/or negative - for you and/or your business?
Yes   No   Not sure
18. If you answered “yes” to the previous question, please specify which of the
proposals/actions you refer to and why you believe this would result in financial,
regulatory or resource impacts for your business.

Page 12

3.7. Our Commitment
19. Do you have any further thoughts on the Scottish Government’s commitment to
introduce HPMAs to at least 10% of Scottish waters?