Open letter submitted to the Scottish Government regarding HPMAs
Consultation Response: Highly Protected Marine Areas: policy framework
The Scottish Seaweed Industry Association (SSIA) is the voice of Scotland’s seaweed industry, dedicated to the growth and development of the sector. We are committed to the sustainability of the industry by promoting research, collaboration, and advocacy.
We represent over 40 members and organisations that deliver investment, jobs, social benefits, and regenerative ocean practices.
Our members come from all sectors of the industry, ranging from seaweed harvesters to processors and distributors. We aim to lead and inform the sector in the growth of sustainable ocean operations.
The SSIA welcomes the opportunity to contribute towards the ongoing consultation process for the establishment of Highly Protected Marine Areas (HPMAs). Our industry plays an important role in Scotland's economy, providing sustainable and nutritious food, as well as a range of other products and services. We believe that the establishment of HPMAs will have a significant impact on our industry, and we would like to express our concerns and make some recommendations for consideration.
While we acknowledge the importance of protecting our marine environment, we are concerned that the establishment of HPMAs will limit access to some of the most productive seaweed cultivation areas in Scotland. This could have a significant impact on the livelihoods of many seaweed industries and could also limit the availability of Scottish seaweed for a value-add products, including food, cosmetics, and pharmaceuticals.
We understand that the Scottish Government is committed to supporting sustainable industries and protecting the marine environment, and we believe that these goals can be achieved through a balanced approach. We would like to make the following recommendations for consideration:
Consultation with the seaweed industry: We urge the Scottish Government to engage in meaningful consultation with the seaweed industry before finalizing any plans for the establishment of HPMAs. This will ensure that the impact on the industry is fully considered and that any measures taken are appropriate and proportionate.
Identification of key seaweed operating areas: We recommend that the Scottish Government work with the seaweed industry to identify the most important seaweed cultivation areas and take steps to protect these areas. This could include the establishment of seaweed management plans that promote sustainable harvesting practices.
Research into the impact of HPMAs on seaweed production: We recommend that the Scottish Government undertake research into the potential impact of HPMAs on seaweed production and the wider industry. This research should be undertaken in consultation with the industry and should consider the economic, social, and environmental impact of any proposed measures.
Other considerations that are relevant to the industry:
1. Spatial Considerations – aquaculture sites and other marine operations are chosen with great care, research, and at great cost. Relocation can cause significant harm to a nascent industry.
2. Socio Economic Factors – the development of the seaweed sector currently receives support as part of the Government’s rural growth plan, limiting the sector could damage these plans.
3. Evidence Base – we believe that there is not sufficient scientific evidence to support excluding seaweed cultivation activities for restoration.
4. Relocation Compensation – we are concerned that HPMAs will act as Economic Exclusion Zones, forced upon rural communities and businesses.
5. Existing or new land activities – there are major coastal water quality issues around sewage outflow and farming effluence that are not being considered.
6. Anthropogenic impacts – we believe that restorative ocean farming can be a route for positive environmental stewardship.
7. Nature Positive – seaweed cultivation will play a vital role in Scotland’s journey to net zero. The Scottish Government’s clear ambition for the development of the sector has been outlined in the following report potential scale for the Scottish Seaweed sector.
1 - Spatial considerations
Seaweed operations, much like shellfish and fin-fish cultivation, must provide evidence of positive economic and environmental impacts whilst avoiding conflict with other marine users.
Seaweed farms should be located within 7nm from a landing site in order to be stabilised in sufficient time, making site selection a fundamental part of the process.
The SSIA have concerns that HPMAs could create new spatial squeezes for existing and new cultivators in our coastal communities, limiting the growth of an industry that Marine Scotland, Crown Estate Scotland, and the Scottish Government have included in their vision as part of a sustainable blue economy. In some instances, relocation may not be possible, therefore a full re-application will need to be undertaken with environmental studies and pre-application consultations, and could result in rejection.
2 - Socio Economic Factors
Many of our members are from rural coastal areas which are looking to seaweed cultivation for economic diversification, to reduce depopulation, and offer green jobs and green tourism. In many areas, seaweed farms utilise local fishing and existing aquaculture vessels (for example mussel farm workboats) to help run a seaweed farm. Marine Scotland has also granted £472,000 to seaweed projects in the last year alone.
Restricting future farms and relocating current farms puts the investment of the Scottish Government and other private investors at risk at a time when the nascent industry requires support.
Plans for HMPAs will limit the access of seaweed farmers to large areas of the ocean, which can reduce the available space for cultivation and decrease the productivity of seaweed farms. This can have negative effects on the socio-economic factors of seaweed cultivation by reducing the potential income and livelihoods of seaweed farmers and related industries.
3 - Evidence Base
The SSIA would like to know what evidence is being considered for areas that will be chosen to show they have been degraded by anthropogenic activity and over what timescale a baseline of good ecological condition can be shown to have existed there before. Any evidence that complete Economic Exclusion Zones will see the repair and rehabilitation of HPMA areas, who and how will this be proven, and what timescales are estimated for this recovery.
In the consultation paper the following statement was made: “wild seaweed harvesting predominantly takes place above mean low water springs (MLWS) and therefore would be outside of the boundaries of HPMAs” this is incorrect, as many licences stretch out to 100m below MLWS.
4 - Relocation and Compensation
Aquaculture forms an integral part of the fragile coastal economy and seaweed farming is increasingly being viewed as a socially acceptable form of aquaculture. The SSIA would like to see the evidence of expected negative economic impacts from the sites chosen for HPMAs and estimates on the number of aquaculture sites that will be forced to relocate.
The Consultation document discusses relocation. Considering the challenges applicants have with the current aquaculture licensing regime, the SSIA would like to know if Marine Scotland will be in a position to offer assistance in relocating and licensing existing seaweed farms.
As part of a Marine Scotland licence and Crown Estate Scotland lease, all aquaculture sites are required to have a costed decommissioning plan. With any closure enforced by HPMAs, the SSIA would like to know whether the compensation scheme will cover these decommissioning costs.
Most seaweed farming companies in Scotland are SMEs. The SSIA are concerned that compensatory money will not be distributed to local communities most affected by forced closure, but used to relocate farms elsewhere and take away the potential rural benefit.
5 - Existing or new land activities
The HPMA does not take into account the negative impact of existing or future land based activities such as Sewage, Sewage Treatment Works, Septic Tank or Agricultural direct or diffuse pollution (coastal or streams) which can cause serious water quality and therefore environmental impacts.
Excessive nutrient discharge from terrestrial sources of poor water that are known to have negative impacts on marine systems can cause problematic seaweed and microalgae blooms. HPMAs are not addressing this issue.
6 - Anthropogenic impacts
The SSIA are concerned that under the proposed plans for HPMAs, seaweed aquaculture is being labelled as ‘damaging’. The SSIA feel the HPMA proposal is dismissive of the positive role regenerative ocean farming will have on the marine environment.
Currently seaweed aquaculture in Scotland, the rest of the UK, and Northern Europe is less than two decades old. To date, there is limited research and information available regarding the potential positive benefits on marine biodiversity that seaweed farming has. The current proposal does not address this.
7 - Nature Positive
The HPMA plan does not take into account the possible positive actions to repair a damaged ecosystems that could be undertaken in partnership with the commercial sector. For example, several seaweed cultivation companies are actively involved in sea grass and native oyster restoration projects, marine waste clearance, and are built on an environmental ethos of net zero operations whilst providing sustainable employment to rural communities.
The current proposal under consultation assumes that human activity can only have neutral or negative impact on the marine environment. Research into the seaweed sector demonstrates negligible or positive impacts. A recent study in Sweden shows seaweed farming increases biodiversity, and an assumption of negative anthropogenic impacts will hinder the growth of the seaweed aquaculture industry and the Scottish aquaculture industry as a whole.
In summary, the SSIA agrees that proper stewardship of Scotland’s waters is required to support all of us who rely on it for our livelihoods and our way of life. Our seas have great potential to help us reach our carbon net-zero targets, to support us with our health, mental well-being, food, materials within the circular blue economy and tourism economy. For these reasons our seas need protecting, but as it stands the way HPMAs are proposed to be delivered will not achieve this.
We appreciate the opportunity to contribute to the consultation process and would be happy to provide any further information or support that may be required. We believe that a balanced approach, which takes into account the needs of both the marine environment and the seaweed industry, is essential to the success of any measures taken to protect Scotland's marine environment.