In summary - 3 Year Review of Scotland’s National Marine Plan


Marine Scotland recently published its three year review of implementation of Scotland’s National Marine Plan. The review is a statutory requirement exploring the effects of plan policies, the effectiveness of plan policies and progress in securing plan objectives

The review evaluated implementation of the plan policies by decision-makers and also sought to assess the effectiveness of policies using available data and through a stakeholder questionnaire.

Here Stephen Hull, Director, a recognised authority in marine planning provides a summary of what the review tells us in terms of the challenges of implementing marine plans. 

One size does not fit all
Marine Scotland’s Licensing Operations Team (MS LOT) is responsible for marine licensing in Scottish waters. It is the principal decision-maker for authorisation decisions under the plan and has established procedures for taking account of plan policies in decision-making. The review highlights issues of proportionality in applying plan policies, particularly for smaller marine licence applications. This is similar to experiences in England suggesting that further consideration needs to be given by regulators to ensuring proportionality in the application of plan policies in line with the requirements of better regulation. 

Measuring effectiveness is not easy
The review notes that there is currently limited data to measure the effectiveness of plan policies. Evidence of progress towards the achievement of environmental objectives is expected to come from MSFD reporting obligations. The review notes that Marine Scotland will develop specific indicators for monitoring progress against economic and social objectives. 

Experience with developing similar indicators for English marine plans suggests that the development of such indicators is challenging because of the difficulty in attributing change to marine plans which are only one of a number of drivers of such change. 

Making use of plan policies
Although the review indicates that implementation of plan policies outside of Marine Scotland is patchy and further work to raise awareness is required. Stakeholder evidence indicated that a number of policies have been particularly useful in decision-making. 

These included new policies in relation to cables, priority marine features, mitigation plans for impacts to commercial fishing activities, marine litter, invasive non-native species and commercial scale energy projects. 

Stakeholders also highlighted a number of challenges that plan policies posed to decision-making, particularly around the lack of clarity and strength in socio-economic policies. This issue has arisen in relation to a number of other marine plans. While a presumption in favour of development might seem attractive, environmental requirements under the EIA Directive and Birds & Habitats Directives mean that any such presumption must always be predicated on development projects progressing through the consenting process. Nevertheless, marine plan policies that are supportive of economic development activities can do much to legitimise development needs and create a favourable climate for project level decisions. Where such policies are being promoted within a plan, the plan makers should ensure focused data collection and engagement with stakeholders around these policies to seek to build consensus as far as possible. 

The review highlights some of the challenges associated with implementing marine plans and in quantifying the contribution that marine plan policies are making to marine objectives. This is particularly the case where there are multiple policy, technological and economic drivers affecting achievement of those objectives, such as for marine renewable energy development.

However, we must recognise that marine planning is still in its infancy and the beneficial effects of marine plans are anticipated to occur over decadal time scales. Therefore a lack of quantifiable evidence at this stage should not be seen as a sign of failure. 

Perhaps most encouragingly the review notes that stakeholders are broadly supportive of marine planning and are already identifying positive outcomes from the Plan. Further iterations of the national Plan and establishment of regional marine plans can ensure that marine planning makes increasingly positive contribution to sustainable development in Scottish seas.

The detailed review can be accessed at

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Stephen Hull

Business Development

(Policy and Planning)

+44 (0) 2380 711 849


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