The sheer number of key policies and decisions being shelved until after the 2014 independence referendum - on all sorts of pretexts – is way beyond coincidence.
Due for publication this year, 2012, a two year delay in the publication of the National Marine Plan has now been announced.
Whatever Scotland chooses in the autumn of 2014, it is condemned to suffer the damage of a prolonged period of limbo until then with an irresponsible and politically manipulative suppression of urgently needed policies and decisions.
And in this political context, delay on any such matter can only mean that Scotland will not agree with it when it comes.
But we’ll have voted by then. Scotland will either be independent with a government that will thumb its nose at critics externally and internally; or it will be on its knees, run down by a Scottish Government – a situation that will, of course, be Westminster’s fault.
In the case of the delay to the National Marine Plan, the proposed upside-down scenario of actual decisions taken on marine energy developments – and implementation in progress – before the publication of the marine plan that is supposed to guide them is identical to that proposed by Transport Minister, Keith Brown.
He announced the same schedule for the issuing of the west coast ferries contract; but, in the face of widespread protest and strike threats, retreated from that equally indefensible position into putting the whole sequential chain into a new timeline that will not see a new ferries contract in place until 2016.
The concerns today of the environmental groups
Environmental groups have now expressed serious concern about the sector-led planning that threatens to sideline Scotland’s marine environment and the national sustainability agenda.
Members of Scottish Environment LINK – an umbrella group for Scotland’s environmental organisations – argue that delays to finalising a National Marine Plan will favour short-termist, large-scale development without ensuring due consideration of wider environmental impacts and the interests of broader marine activities.
The two year delay to the publication of the Scottish Government’s National Marine Plan means that an overarching marine plan, originally scheduled to be finalised in 2012, will now remain on the bureaucratic shelf until its publication at the end of 2014.
Meanwhile sectoral plans, such as those for the offshore renewable industries, are due to be signed off long before.
The National Marine Plan should provide forward-looking guidance to businesses wishing to develop the marine environment and ensure that marine activities develop alongside each other sustainably, much like the terrestrial planning system. Meanwhile, however, activities such as the aquaculture and renewable industries are developing at a rapid pace without such a coordinated approach.
Members of LINK’s marine taskforce believes this delay not only risks Scotland’s natural and historic marine environment and resources, but also creates uncertainty for businesses within the wider marine sector.
Scottish Environment LINK is calling on Marine Scotland and the Scottish Government to provide assurances that the National Marine Plan is a priority and will be progressed as a matter of urgency.
Furthermore, LINK’s marine taskforce also asks the Scottish Government to ensure that sectoral plans will be revised in light of the National Marine Plan where necessary.
Comments from Scottish Environmental LINK partner organisations
Calum Duncan of Marine Conservation Society (and taskforce convenor) says: ‘Unfortunately, this has the appearance of the tail wagging the dog – in this case development plans leading the national plan.
‘Both the environment sector and marine industries are very much in favour of the sustainable use of our seas, but without an overarching national marine plan in place, we remain in bureaucratic limbo and risk developing beyond environmental limits.’
Kara Bryson of RSPB Scotland says: ‘Developers need certainty that they’re not going into the most sensitive parts of our marine environment .Without a National Marine Plan to coordinate and inform investment, the environmental credentials of energy companies are at reputational risk. Protection of the marine environment is central to planning and without adequate coordination in place, this could have serious implications for the energy market as well as our natural heritage.’
Sarah Dolman of Whale and Dolphin Conservation Society says: ‘The National Marine Plan cannot be shelved for another year and a half. Some of the biggest marine renewable projects in the world are being planned for Scotland’s seas right now, and we currently don’t even have a planning system in place to coordinate them in our already busy waters. This lack of joined-up planning wouldn’t be tolerated on land. Many marine species are vulnerable and we urgently require careful and cohesive management to ensure all developments at sea are environmentally sustainable.’
Alex Kinninmonth of Scottish Wildlife Trust says: ‘Without a National Marine Plan in place, smaller businesses are unable to plan ahead. Meanwhile large-scale developments are being progressed via sectoral plans drafted in a strategic planning vacuum. The current two-speed approach risks creating an uneven playing field for the marine sector as a whole.’
The Scottish Government issued a pre-consultation draft of the National Marine Plan in March 2011 with the aim to deliver the final marine plan during Spring/Summer 2012. A formal consultation on a revised draft is now planned Summer 2013, with publication anticipated at the end of 2014.
Marine sector interests covered by the pre-consultation draft National Marine Plan included offshore energy (wind, tidal and wave), fishing (static, inshore and offshore), aquaculture (predominantly salmon and shellfish), shipping (cargo), tourism and recreation. The full list can be found here in the pre-consultation draft plan.
‘Blue Seas – Green Energy: A Sectoral Marine Plan for Offshore Wind Energy in Scottish Territorial Waters’ was published in March 2011 and is currently being revised An updated version is now expected Spring 2013.
The Scottish Government is currently inviting comments on planning and guidance documents it will use to help develop draft sectoral plans for wave and tidal energy in Scottish territorial waters. A public consultation for these sectoral marine plans is expected in February 2013 and published Summer 2013.
Marine Protected Areas will be a critical tool to help protect and recover Scotland’s marine environment. The National Marine Plan will have a role to guide developers to ensure these sites are considered across the wider marine area. However, it is anticipated these sites will be in place nearly a year before the National Marine Plan is published.
On 17 March 2011, the Scottish Government provided consent to the Sound of Islay tidal stream array, the largest consented tidal array in the world.