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SNH Priority Marine Features Guidance
Supporting information for application of this guidance is available on the SNH website.
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Table Of Contents Page PURPOSE ........................................................................................................................... 2
1. INTRODUCTION ............................................................................................................. 2
2. COMPLEMENTARY GUIDANCE .................................................................................... 3 3. THE ROLE OF SNH ........................................................................................................ 3 4. SOURCES OF INFORMATION ....................................................................................... 3
5. PROVIDING PROPORTIONATE ADVICE ON PMFS ..................................................... 4 6. HANDLING PMF CASEWORK ....................................................................................... 4 6.1 Key assessment stages .............................................................................................. 5 6.1.1 Question 2a - Which PMF(s) may be impacted?......................................................... 6 6.1.2 Question 2b - How is/are the PMF(s) potentially impacted? ....................................... 6
6.1.3 Question 2c - What’s the magnitude of change to the PMF? ...................................... 6 6.1.4 Question 2d – What is the significance of the impacts? .............................................. 6 6.2 Requests for additional information or survey ......................................................... 7
7. CONDITIONS & MODIFICATIONS ................................................................................. 7 8. RESPONSE TYPES & SNH POSITION .......................................................................... 8 ANNEX 1 – PMF CASEWORK CHECKLIST ...................................................................... 9 ANNEX 2 – PMF CASEWORK FLOWCHART AND POSSIBLE OUTCOMES ................ 13
PURPOSE
This note provides SNH staff with guidance on handling development proposals with potential to impact Priority Marine Features (PMFs). In particular:
Identifying proposals that may have significant impact on the national status of PMFs in the ‘wider seas’. A ‘significant impact on national status’ is equivalent to an issue of national interest (SNH National Interest Guidance), and hence could trigger an objection.
Identifying proposals that do not have a significant impact on the national status of PMFs but still cause effects that merit ‘advice only’ comments.
While the detail of the guidance is targeted at development casework, the principles may also be applied when giving advice on the potential for other proposals or activities to affect PMFs.
1. INTRODUCTION
The PMF list and background information are available on the SNH website. The list was formally adopted by Scottish Ministers in July 2014. Some PMFs are already protected features of designated sites or are protected under species legislation (e.g. cetaceans, basking sharks). This guidance addresses the policy requirement to conserve PMFs as ‘wider seas’ biodiversity as established through:
The Scottish Government Strategy for Marine Nature Conservation
The Scottish Biodiversity Strategy 2020 Challenge
Scotland’s National Marine Plan (NMP) – see policy below.
NMP Policy
GEN 9 Natural heritage: Development and use of the marine environment must:
(a) Comply with legal requirements for protected areas and protected species.
(b) Not result in significant impact on the national status of Priority Marine Features.
(c) Protect and, where appropriate, enhance the health of the marine area.
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In most casework involving PMFs, SNH will be providing advice to regulators and developers. Usually the regulator will be Marine Scotland Licensing Operations Team (MS LOT), but we also provide advice to other regulators (SEPA, Planning Authorities, the Department for Energy and Climate Change (DECC) and Transport Scotland).
This guidance will be reviewed in the context of:
The progress of Regional Marine Planning.
Advancement of working-relations with Marine Scotland Science and regulators.
The development of standing advice to regulators and planners.
2. COMPLEMENTARY GUIDANCE
Some PMFs also receive legal protection, for example as European Protected Species or as protected features of a marine protected area1. This guidance does not duplicate or replace existing guidance on these matters, and should be used only to assess impacts not addressed through existing protection measures. Further supporting information is provided on the SNH website regarding the provision of advice on PMFs as wider seas biodiversity alongside their protection through species legislation or as features of designated sites.
One of the objectives for this guidance is to aid application of the National Interest Guidance. It also complements, but does not replace or duplicate, our guidance on Development Management and the Natural Heritage and the Application of Balancing Duties.
Our advice may also be guided by other relevant policies within the NMP, Regional Marine Plans (once they are developed) or sectoral plans (statutory or non-statutory). Staff should familiarise themselves with relevant marine plans and ensure that any advice is provided within the context of these policies.
3. THE ROLE OF SNH
We should provide the regulator with clear advice on:
whether the proposed activity and/or development will have an impact on PMFs;
whether the proposal may have a significant impact on the national status of any PMFs; and
any options for mitigation.
The JNCC provides advice for beyond 12 nm from the shore. The PMF list contains features listed for territorial (<12nm) or offshore (>12nm) waters only, or both. We must liaise with JNCC over proposals which could affect PMFs beyond 12 nm, copy JNCC into relevant correspondence and ensure our advice is aligned or any differences clearly justified. It may be appropriate to provide joint advice in some cases.
4. SOURCES OF INFORMATION
We should direct developers and regulators to sources of information on the presence, abundance and/or extent of PMFs. These are detailed as Supporting Information on the SNH website. For SNH staff the key internal resource is geo.View; for external access our data is periodically updated to National Marine Plan interactive (NMPi). In cases subject to statutory Environmental Impact Assessment (EIA), much of this information should also have been included and interpreted within an Environmental Statement (ES).
1 The term ‘marine protected area’ refers to all types of site within the network, including SACs and marine SPAs.
MPAs designated under the Marine (Scotland) Act 2010 are explicitly prefixed as Nature Conservation (NC) MPAs.
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5. PROVIDING PROPORTIONATE ADVICE ON PMFS
It is important that our advice regarding PMFs is proportionate to the likely impacts.
Work is on-going to identify those case-types for which it can be readily determined that there will be no impacts, or insignificant impacts only, on PMFs as wider-seas biodiversity interests. This is likely to be the case for many small-scale proposals requiring a marine licence. In due course we expect to either (a) not be consulted on these cases, by way of establishing agreements with regulators, or (b) triage out these cases via our internal Swift Sift process.
For some small-scale developments it will be necessary to examine additional details to determine if there is a potential for impacts upon PMFs. Further work will examine the potential for a simple filtering tool to help case-officers in reaching this decision quickly and consistently. In due course this should help limit the number of cases for which full application of this guidance is necessary, and aid scoping out of trivial issues at the pre-application stage.
In the interim, case officers should make informed judgements (with support from Coastal and Marine Ecosystems & Use Unit (CMEU) advisers as appropriate) about cases for which there is intuitively no potential for impacts on PMFs.
6. HANDLING PMF CASEWORK
There are no legally prescribed tests for assessing impacts upon PMFs, but a checklist is available (Annex 1) to help you reach conclusions and to ensure that a structured audit trail is kept. Case officers should complete the checklist for all casework with potential to impact PMFs in order to ensure consistency of approach.
The recommended approach provides a stepwise assessment. The checklist allows transparent justification of the decisions reached according to available information and, where necessary, expert judgement.
A partially completed checklist (Section 1: Proposal details) accompanying any requests for advice from specialist advisers provides a concise proposal summary and encourages advisers to follow a standard approach.
The checklist should record our confidence in the judgements made, stating whether real (qualitative/quantitative) or modelled data (including statistical confidence where available), or indicators, proxies or other expert opinion have been used.
Depending on the complexity of the case, input may be required from several specialist advisers. The following box provides some taxon-specific considerations for advisers in applying the following steps. After the provision of advice from different advisers, the case officer may wish to compile the information in to a single checklist.
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6.1 Key assessment stages
The PMF checklist (Annex 1: Sections 2a-2d) poses 4 key questions to guide the assessment of potential impacts upon PMFs. These questions relate closely to the questions within the NIG checklist, and the text can be transferred to it for presentation to the SNH National Interest Panel if and when this is required. The checklist does not prejudge whether there are issues of national interest/significant impacts on national status.
These questions focus upon using the available evidence to come to a conclusion on the magnitude of any change (including cumulative impacts) and its significance:
2a) Which PMF(s) may be impacted? Also note available information about the PMF(s) at the location of the proposal.
2b) How is/are the PMF(s) potentially impacted?
2c) What’s the magnitude of change?
2d) What is the significance of the impacts?
Applying these steps should allow you to describe the risk of impacts to PMFs, including the scale of impacts and consideration of cumulative or incremental impacts with other projects. It is important to record whether there are likely to be impacts and whether they may have a significant impact on the national status of any PMFs. We may also provide advice on proposals that may impact PMFs without having a ‘significant impact on national status’.
Depending on the feature and the pressure(s), impacts may arise from proposals of any scale (i.e. an impact does not necessarily need to be widespread to merit the provision of SNH advice). This is more likely where the impact magnitude is large, if a given region or locality is known to support a disproportionately large or valuable portion of this PMF in Scotland, or where trend data shows the population is threatened and/or declining.
Taxon-specific considerations for PMF casework
This is not an exhaustive list; advisers may wish to consider other factors.
Benthic habitats and low-mobility species
- Extent, quality (condition or age/size profile) and fragmentation of habitats / species
aggregations may be important considerations.
- Ecosystem services / functional value of habitats (e.g. carbon sink, wave
attenuation/coastal defence, supporting biodiversity, nursery habitat, etc).
- Where a PMF habitat is comprised of multiple component biotopes, consider differing
ecology and trends of each component.
Fish (and crustaceans) - Consider habitat associations. Species with very specific requirements (e.g. sandeels,
spawning herring) may be more sensitive to change. Consider habitat quality and
extent.
- Review function of location as potential spawning and/or nursery ground. Consider
ground extent, availability and specificity of species requirements.
- For diadromous species, also consider known / likely migratory routes and feeding
areas.
Marine mammals - Likely functional link between the site and regular/seasonal use of the site by the PMF?
- For constrained channels, are alternative routes available for passage?
- Use available information on foraging range, locations & behaviour.
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The checklist also guides consideration of any requests for additional data or information (Section 3 of checklist), and potential conditions and recommendations (Section 4 of checklist).
6.1.1 Question 2a - Which PMF(s) may be impacted?
This section should name the PMFs which will be assessed further.
Record any information about the PMF at the location being considered. This may include:
Condition / quality, i.e. patchiness; structural complexity of habitats; species richness/diversity within habitats.
Abundance of species aggregation / extent of habitat.
Specific biotopes present for habitat features.
Particular life stages for mobile species.
6.1.2 Question 2b - How is/are the PMF(s) potentially impacted?
Record the sensitivity of features. Sensitivity is a combination of the capacity to (a) tolerate a pressure (resistance) and (b) recover from a pressure (resilience). FEAST and MarLIN provide online sensitivity tools which help us to determine the sensitivity of features to physical, chemical and biological pressures. The sensitivity assessments are based on defined pressures where possible (referred to as benchmarks), providing consistency across the range of different features. Note if the magnitude of the pressure exceeds the benchmark and, where required, seek specialist advice; this will need to be considered further in the next step of the assessment.
6.1.3 Question 2c - What’s the magnitude of change to the PMF?
This section combines the feature information (2a) and feature sensitivity (2b) with an understanding of the magnitude of pressures associated with the proposed activity. You should consider the intensity, spatial extent, patchiness, duration and frequency of relevant pressures and note if the applicant has provided sufficient information to understand these. This part of the appraisal should allow you to identify, quantitatively where possible, the magnitude of change to the PMF(s).
It is also important to consider if there are likely to be any cumulative impacts either in combination with other proposals and/or existing developments/activities.
6.1.4 Question 2d – What is the significance of the impacts?
This step guides you to determine the significance of impacts, considering the above assessment of magnitude of change (2c) against aspects of policy, spatial context and other factors that influence how we regard the relative conservation importance of different features.
The checklist subsequently asks you to record whether:
(i) there is a significant impact on the national status of any PMF/PMFs, (ii) there is an impact on PMF(s) but without significant impact on national status, or (iii) there are no impacts or insignificant impacts only.
Considerations include:
Policies, objectives and/or targets relevant to the PMF, at the national, regional and local level. In due course, more detailed and regionally-specific policies regarding PMFs may emerge from Regional Marine Plans and Local Development Plans.
Factors influencing relative conservation importance, generally and specifically within the area in which it may be impacted. For example:
- Functional role e.g. key predator or prey interactions; supporting habitat for other biodiversity / commercial species; carbon storage; wave attenuation/coastal protection; supporting key life stages of mobile species.
- Proportional importance in the UK/wider context i.e. do Scottish territorial waters contain a significant proportion of the UK/wider resource?
- Distribution and status e.g. rare, declined, threat of decline.
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Relevant spatial context for framing the assessment of impacts, including recognition that the interpretation of ‘national’ or ‘regional’ scale may differ between PMFs. In particular:
- If the feature being assessed is identified as a PMF within both Scottish territorial waters and offshore (>12 nm), then consideration at a ‘national’ scale should include offshore waters. For example, the burrowed mud PMF is listed as a PMF across the whole of Scotland’s seas and is widely distributed within both inshore waters and the offshore continental shelf. Consequently, it is likely that, to determine a significant impact on the national status of burrowed mud would require an impact upon a very large extent of habitat, or on an area of very high quality or functional importance.
- If the feature has a very limited distribution (e.g. Limaria beds largely restricted to west-coast territorial waters), this should be accounted for in any assessment of significant impacts on national status of a PMF. It is therefore possible that a relatively small-scale change to Limaria beds would have significant impact on national status.
- When assessing impacts on cetaceans it is important to consider the management units for cetaceans as defined by the Inter-Agency Marine Mammal Working Group (IAMMWG), providing a geographic-scale for population level impact assessments2. A CMEU adviser should be consulted for further advice on the relationship between management units and the regional/national scales, and subsequent implications for assessing impacts. For seals it may also be appropriate to consider the Seal Management Areas; CMEU specialists can advise further.
- The default position for benthic habitats and species should be to regard ‘regional’ as equating to the area covered by the relevant Regional Marine Plan (RMP) (i.e. the Scottish Marine Region).
- Some fish populations are known to have geographically distinct spawning stocks (e.g. herring: Buchan / Orkney-Shetland stocks) or sub-populations (e.g. Moray Firth cod). It would be appropriate to adjust the definition of ‘regional’ to match these areas for assessing impacts on relevant fish PMFs. A CMEU adviser should be consulted.
If there is insufficient information to reach a judgement on impacts, use Section 3 in the checklist to guide these considerations.
6.2 Requests for additional information or survey
Many locations will lack good spatial information on PMFs; specialist advisers may therefore consider the likelihood of occurrence of PMFs based on the physical environment, predictive modelling and any other indicators/proxies of likely PMF presence or quality/condition. Only request that the developer conducts targeted surveys when there is a risk that a proposal may significantly impact national status of a PMF (section 3 of the checklist provides a space for detailed recording of this justification). CMEU specialists can also advise on survey design, including for subsea cables and pipelines and for marine renewables developments (https://beta.snh.scot/sites/default/files/2017-06/B925810.pdf).
7. CONDITIONS & MODIFICATIONS
Section 4 in the checklist guides users to consider if mitigation or modifications are required (to avoid an outright objection) or recommended (advice only). If there is a risk of significant impact on national status of PMFs but uncertainties cannot be resolved by additional survey or information, consider an adaptive management approach with phased development and/or monitoring. This can allow impacts to be measured to inform further mitigation or phased consenting stages.
2 Basking sharks are also PMFs; considering their wide-ranging nature, they should be considered according to similar
principles as those applied to cetaceans. However, there is not a defined ‘management unit’ or geographic context for population-level impacts, nor is there a robust population estimate.
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8. RESPONSE TYPES & SNH POSITION
Section 5 of the checklist guides the selection of a response type and SNH position that should be used in our consultation response, referring to possible outcomes shown in suggested wording provided on the SNH website. These reflect the style and approach within the SNH Development Management Guidance.
SNH will only object3 to proposals that may have significant impact on the national status of PMFs.
Proposals that will impact PMFs but without significant impact on their national status may still be relevant for giving ‘advice only’ positions, including recommended mitigation or modifications if appropriate.
3 With some regulators we may establish an agreed alternative to using an ‘objection’.
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ANNEX 1 – PMF CASEWORK CHECKLIST
Any advice provided to other SNH staff must be clear, simple to use, and proportionate. Advice regarding impacts upon Priority Marine Features (PMFs) from a single development may require input from several specialist advisors, thus potentially requiring more than one completed checklist. PMF advice may be categorised according to the taxonomic grouping of PMFs and their corresponding adviser. Please indicate the taxonomic grouping addressed.
1. PROPOSAL DETAILS
Casework Management System Ref.
File Ref.
1a. Proposal title:
1b. Details of proposed operation (inc. location, timing, methods):
2. ASSESSMENT See section 6.1 of the guidance for further information on completing these steps. Also use Information Sources (section 4 of guidance), as well as the Environmental Statement and expert knowledge. The following has been extracted and modified from the National Interest Guidance (NIG) Checklist. Questions 2a-2d relate closely to the NIG checklist; when required, answers can therefore be copied to a completed checklist for provision to the SNH National Interest Panel. A ‘significant impact on the national status’ of a PMF (as per National Marine Plan Policy GEN 9) is equivalent to an ‘issue of national interest’ (as per the NIG), and hence could trigger an objection. If insufficient information is available to answer the questions below, either with regard to the proposal details or the PMF(s), consider next steps further at section 3.
2a. Which PMFs may be impacted? Also note available information about the PMF(s) at the location of the proposal.
This section should name the PMFs which will be assessed further. Record any information about the PMF at the location being considered. This may include:
Condition / quality, i.e. patchiness; structural complexity of habitats; species richness/diversity within habitats.
Abundance of species aggregation / extent of habitat.
Specific biotopes present for habitat features.
Particular life stages for mobile species.
2b. How is/are the PMF(s) potentially impacted? Consider the sensitivity of features, combining (a) the resistance to (tolerance of) a pressure and (b) the resilience (recovery) from a pressure. The FEAST online sensitivity tool is available on the Scottish Government website at:
Benthic habitats and low-mobility species
☐
Cetaceans, seals, otters and basking sharks
☐
Fish (& crustaceans) ☐
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http://www.scotland.gov.uk/Topics/marine/marine-environment/FEAST-Intro and a public user guide is available at: www.marine.scotland.gov.uk/FEAST/Help.aspx.
2c. What’s the magnitude of change to the PMF(s)? Combines the feature information (2a) and feature sensitivity (2b) with an understanding of the magnitude of pressures associated with the proposed activity. You should consider the intensity, spatial extent, patchiness, duration and frequency of relevant pressures and note if the applicant has provided sufficient information to understand these. This part of the appraisal should allow you to identify, quantitatively where possible, the magnitude of change to the PMF(s). Consider if there are likely to be any cumulative impacts when this proposal is considered in combination with other proposals and/or existing developments/activities.
2d. What is the significance of the impacts? Determine the significance of impacts, considering the above assessment of magnitude of change (2c) against aspects of policy, spatial context and other factors that influence how we regard the relative conservation importance of different features. Considerations include (See Section 6.1.4 of the guidance for further information):
Policies, objectives and/or targets relevant to the PMF
Factors influencing relative conservation importance, generally and specifically within the area in which it may be impacted, such functional role of a species or habitat, proportional importance in the UK/wider context or the distribution and status of the feature.
Relevant spatial scales for framing the assessment of the significance of any impacts, including recognition that the interpretation of ‘national’ or ‘regional’ scale may differ between PMFs.
Assess any impacts with respect to the relevant national and/or regional scale and any relevant policies etc.: This should include consideration of any key points of relevance to national status noted in 2b and 2c, for example:
The PMF may generally be considered to be threatened and/or declining but the proposal will impact a good quality example.
The PMF (or component) may be restricted in distribution and any impacts would therefore be more significant than for a more widely distributed PMF.
Achievement of a relevant policy would be compromised as a result of impacts associated with the proposal (e.g. impacts on a PMF that would be contrary to a Regional Marine Plan Policy).
Record one of the following: i. There is a significant impact on the national status of a PMF/PMFs.
[This could include significant impacts at a national scale and/or regional scale (see further detail on scales in section 6.1.4 of guidance). Note that localised impacts may still raise issues at national and/or regional scales (i.e. an impact does not necessarily need to be widespread to impact national status).]
ii. There is an impact on PMF(s) but without significant impact on national status. iii. There are no impacts or insignificant impacts only.
Also record confidence in judgement reached e.g. direct/indirect evidence, use of expert judgement.
If there is insufficient information to complete the assessment, proceed to section 3. If conditions or modifications are required or recommended, proceed to section 4.
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Otherwise, proceed to section 5. 3. INSUFFICIENT INFORMATION: Consider justification for any request for additional information or data.
i. If PMF data or proposal details are insufficient to complete the assessment, detail the requirements here and justify based on an evaluation of risk.
ii. Include consideration of any advice given pre-application. iii. Additional data or information requests should only be made for proposals that may have a
significant impact on the national status of a PMF (see SNH Development Management guidance for exceptional circumstances).
If further information or survey is required and justified, proceed to section 5 and submit a holding objection. If conditions or modifications are required or recommended, proceed to section 4. If the proposal may have significant impact on national status but uncertainties cannot be resolved by additional survey or information, consider an adaptive management approach with phased development and/or monitoring, allowing impacts to be assessed to inform further mitigation or consenting decisions. If conditions or modifications are not necessary or feasible, proceed to section 5. 4. CONDITIONS AND RECOMMENDATIONS Provide text below that can be readily transferred to a response letter.
i. Detail conditions required to ensure that the proposal would not have significant impact on the national status of any PMFs.
ii. Detail mitigation or modifications recommended to ensure any impacts associated with the proposal would be minimised (i.e. for an ‘advice only’ position where impacts have been determined not to have significant impact on the national status of any PMFs).
5. RESPONSE 5a. Record the conclusion of the impact assessment in line with the possible conclusions shown in Annex 2 of the PMF guidance. Therefore, one of the eight options (the text in the pink boxes) should be recorded here. NB:
i. Objections4 can only be used where there is potential for proposals to have significant impact on the national status of PMFs. All other outcomes should be ‘advice only’.
4 With some regulators we may establish an agreed alternative to using an ‘objection’.
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ii. A holding objection may be used where further information is required to support an assessment, particularly where a risk-based evaluation suggests the potential for significant impacts in line with i. above.
iii. A conditioned objection may be used where modifications, mitigation or an adaptive management approach would ensure impacts are reduced to an acceptable level.
iv. ‘Advice only’ positions may make recommendations to minimise impacts to PMFs (i.e. where it has been determined that the proposal will not have significant impact on the national status of any PMFs).
5b. SNH Position summary (as entered in SNH Casework Management System) Note that an outright objection may need to be supplemented with a complete Balancing Duties proforma. Record the SNH position (the text in the blue boxes in Annex 2) associated with the conclusion reached (e.g. advice only, conditioned objection). [Suggested wording for use in response letters is available on the SNH intranet]
Appraised by
Date
Checked by
Date
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ANNEX 2 – PMF CASEWORK FLOWCHART AND POSSIBLE OUTCOMES
No
Yes
Yes
No
PMF conclusion 5: Significant impact on national status of PMF(s) that can be mitigated with conditions / modifications.
Could there be an impact upon the PMF(s)?
PMF conclusion 2: Potential for interaction with PMF(s), but insignificant impacts only. [It may still be appropriate to provide advice on recommended mitigation] SNH position A: Advice only
SNH position C: Conditioned objection
Proposal details
PMFs present / likely to be present
PMF conclusion 1: No potential for impact on PMF(s)
PMF conclusion 6: Significant and unavoidable impact on the national status of PMF(s). SNH position D: Outright objection
SNH position E: No comment
PMF conclusion 3: Insufficient information to determine impact on PMFs, but unlikely to have a significant impact on national status. [It may still be appropriate to provide advice on recommended mitigation]
SNH position A: Advice only
PMF conclusion 4: Insufficient information to complete impact assessment, but could potentially have a significant impact on national status of PMFs. SNH position B: Holding objection
Insufficient information
Can the impact be avoided or adequately reduced?
Insignificant impact(s) only
No impact
Could the proposal significantly impact national status of any PMFs?
No
Can the impact be avoided or reduced?
Yes
No
Yes PMF conclusion 7: Impact on the PMF(s), but without significant impacts on national status. We recommend that the impact(s) may be mitigated with conditions / modifications.
SNH position A: Advice only
PMF conclusion 8: Unavoidable impact on the PMF(s), but without significant impact on national status.
SNH position A: Advice only
Assessment conclusion
SNH position (corresponding with codes in
SNH Development Management Guidance)
Key
