Aquaculture and the Fourth National Planning Framework – SPICe Spotlight

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The Fourth National Planning Framework (NPF4) was published on 10 November 2021. The National Planning Framework is a strategic document outlining how “the Scottish Government’s approach to planning and development will contribute to achieving a clean and sustainable Scotland”. zero by 2045”. General information on the national planning framework can be found in a previous blog. This blog examines national aquaculture planning policies. Other blogs on NPF4 related topics can be found in the SPICe hub.

This blog examines aquaculture policies in the fourth national planning framework. He explores policy planning for aquaculture in the context of the recent reviewlooked biodiversity planning policies for aquacultureand highlights other work in progress compared to the sector.

The Scottish aquaculture sector

Aquaculture – the practice of raising aquatic animals or plants – is a major industry in Scotland. Fish and shellfish (mussels and oysters) are farmed in Scotland, with salmon farming being the most common by far. Seaweed is also cultivated, but to a limited extent.

Scotland is one of the world’s top three producers of farmed Atlantic salmon (after Norway and Chile, but it should be noted that both countries produce far more than Scotland), and farmed salmon is both Scotland’s and the UK’s largest food export by value.

The figure below shows the growth of the salmon farming sector from 1999 to 2020.

Figure 1: Salmon farming in tonnes since 1999
Source: https://www.gov.scot/publications/scottish-fish-farm-production-survey-2020/documents/

Recent Industry Review

The regulation of salmon farming in the context of this growth has become a concern, particularly with regard to environmental, animal welfare and community impacts. In Session 5 there was an in-depth review of the salmon farming industry in the Scottish Parliament. The Committee on the Environment, Climate Change and Agrarian Reform has carried out an investigation into the environmental impacts of salmon farming, commission the Association of Marine Science of Scotland (SAMS) to review the evidence on this topic. The ECCLR committee reported its findings to the Rural Economy and Connectivity Committee (REC), which carried out a wider inquiry into salmon farming in Scotland in 2018 and a shorter follow-up survey at the end of 2020. Committees agreed ‘status quo is not an option’.

Aquaculture, planning and MFN4

The role of the planning system in aquaculture was considered as part of the REC Committee investigation.

In its final report following the Committee’s two investigations, the REC Committee highlighted the evidence received regarding the planning system, noting that witnesses had raised the need for “a more strategic approach to the siting of salmon farms”. .

In December 2020, the then-Secretary to the Cabinet told the Session 5 Rural Economy and Connectivity Committee that, with respect to aquaculture:

“The Fourth National Planning Framework will reflect the Scottish Government’s aim to support sustainable growth and it will help direct new development to locations that will best meet the needs of industry, with due regard to the marine environment. “.

Setting up a new fish or shellfish farm or expanding an existing one requires planning permission through the local authority planning system, in addition to a number of licenses and consents obtained from different public authorities (for example, a seabed lease from Crown Estate Scotlanda marine license to install equipment from Marine Scotland and a SEPA Controlled Activities Regulation license)

High-level policies on aquaculture are defined within national planning policies, Scottish Planning Policy (published 2014)and now as part of the draft fourth national planning framework (NPF4; the SPP has been combined with the national planning framework in the NPF4).

In addition, although building permits for fish farming are issued through the local authority planning system, a more detailed policy is set out in the National Marine Plan – it is the framework for managing activities in the Scottish marine area. Regional Marine Plans are intended to do the same but for Scottish marine regions.

In draft MFN4, the content of aquaculture planning policies does not differ significantly from those previously defined in Scottish planning policy, although there are some changes.

The draft NPF4 no longer emphasizes that local development plans should ‘make positive provision for the development of aquaculture’, as stated in Scottish planning policy. However, NPF4 continues to be clear on the Scottish Government’s support for aquaculture, stating that “the planning and licensing system should support the prosperity of the fish, shellfish and seaweed sectors”, including guiding developments to the most appropriate sites.

While Scottish planning policy has stressed the need to direct developments “to coastal locations which best meet the needs of industry with due regard to the marine environment”, NPF4 states that:

“Local development plans should direct new aquaculture development to sites that reflect industry needs and consider environmental impact, including cumulative impacts that arise from other existing and planned aquaculture developments in the area, and broader marine planning.” (emphasis in original)

Furthermore, NPF4 is perhaps less ambiguous on the role of the National Marine Plan and the Regional Marine Plans.

In the Scottish Planning Policy, the National Marine Plan has been listed as a “key document”, while NPF4 explicitly states that:

“Proposals for aquaculture development should be supported where they are comply with the local development plan, the national marine plan and, where applicable, the appropriate regional marine plan.” (emphasis in original)

However, marine planning is an emerging field compared to land-based local authority planning systems that have been in place in one form or another for decades. Planning partnerships to develop regional marine plans have so far been established in Shetland, Orkney and the Clyde across all eleven marine areas. No statutory regional marine plan has yet been approved by Scottish Ministers.

The National Marine Plan was last updated in 2015, before scrutiny of aquaculture by parliamentary committees. The 2018 Triennial Review of the National Marine Plan did not result in a revision due to uncertainties surrounding EU exit and noted that:

“Aquaculture policies and objectives were raised in a number of responses. In particular, it was suggested that the reflection of industry production targets in one objective was in conflict with the approach taken for other sectors, and therefore arguably at odds with environmental policies and the principles of sustainability of the Plan. Although the application of Plan policies applies to decision-making to ensure sustainability, future iterations of the Plan will provide an opportunity to examine this issue further.

the NMP was re-examined in 2021and a decision has yet to be taken by Ministers as to whether the NPM will be amended, replaced or remain unchanged.

Aquaculture and biodiversity planning policies

A curious aspect of NPF4 in relation to aquaculture is the exemption of farmed fish or shellfish from management policies associated with the enhancement of biodiversity. Policy 3 on Nature Crisis states, among other things, that:

“Development proposals for national, major and EIA development or development for which proper assessment is required should only be supported if it can be demonstrated that the proposal keep and improve biodiversityincluding the natural networks within and near the site, so that they are in a demonstrably better condition than without intervention, including through future management. Applications for the development of farmed finfish or shellfish are excluded from this requirement..” (first emphasis in original, second emphasis added)

Similarly, in terms of local development, the NPF4 notes:

“Local development proposals should only be supported if they include appropriate measures to improve biodiversityin proportion to the nature and scale of the development. Applications for development of individual households, development of farmed fish or shellfish… are excluded from this requirement.” (first emphasis in original, second emphasis added).

There is no explanation included in NPF4 as to why the development of farmed fish and shellfish should be excluded from the biodiversity enhancement requirement.

Other regulatory changes for the aquaculture sector

As indicated above, the planning system is only part of the regulatory framework for aquaculture. The Aquaculture Regulatory Review has fueled regulatory reform, including several changes and work programs beyond the planning regime:

Other changes are also planned following a ongoing external review of salmon aquaculture regulatory processes.

Anna Brand, Principal Investigator

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