The National Marine Plan recognises projects with existing leases, many of which have already submitted planning applications, are ‘planned development at the licensing stage’ and Renewables Policy 1 contains a presumption in favour of adopted Plan Options. This must be recognised in the MPA network.
We believe it would be inappropriate and misleading to remove the SPA/SAC/SSSI/NC MPA label and refer to all sites as an MPA.
Nature Conservation MPAs are not SPAs or SACs and this distinction must be clear throughout
It is very important that potential data bias is recognised and the economic consequences are properly factored into designation and management decisions
We would encourage Marine Scotland to carry out further analysis quantifying the potential socio-economic costs of individual proposed designations and the proposed network as a whole specifically with regard to the potential effects on project delay, restrictions or failure to proceed.
If the network is determined to be ‘ecologically coherent’ following adoption of the NC MPAs, no further amendments must occur to the network out with the statutory review process.