On 28 January 2025, RTPI Scotland submitted a response to the Scottish Government's consultation on the National Marine Plan 2 Planning Position Statement. Read the response below or access the PDF here.
About the RTPI
The RTPI Champions the power of planning in creating sustainable, prosperous places and vibrant communities. We have over 27,000 members in the private, public, academic and voluntary sectors. Using our expertise and research we bring evidence and thought leadership to shape planning policies and thinking, putting the profession at the heart of society’s big debates. We set the standards of planning education and professional behaviour that provide our members, wherever they work in the world, a unique ability to meet complex economic, social environmental and cultural challenges.
Introductory Remarks
We welcome the opportunity to respond to this consultation on the planning position statement for National Marine Plan 2. Set out below are RTPI Scotland’s remarks on certain of the proposals set out in the consultation paper.
We recognise that this consultation is part of a wider engagement programme to create an updated National Marine Plan, the first version of which has been in place since 2015. We appreciate that this is an ongoing process, with which we are keen to engage. We would, therefore, be happy to discuss or clarify any aspect of our below submission and work with the Scottish Government in the future as the drafting of NMP2 progresses.
Alignment and Relationship with NPF4
We are broadly supportive of the proposed High-Level Objectives. We agree that reducing the number of objectives from 12 down to 5 will enhance the document’s usability, clarity and avoid duplication across the HLOs. We are also broadly supportive of the topics proposed to be captured in the HLOs and are pleased to see the proposal to give significant weight to the climate and nature crises, thereby aligning NMP2 with policies 1 and 2 of NPF4.
We are also pleased to see the proposals in the consultation paper for close alignment between NMP2 and NPF4 more generally, with a view to them acting as “companion documents”. There is a strong link between marine and terrestrial planning, with implications arising from development and decisions made in the marine environment on land, and vice versa. It is important to ensure that the plans put in place take a joined-up approach; complementing and supporting one another. This means approaches to the development of NMP2 must be taken forward hand in hand with land use planning documents and strategies, including the National Planning Framework 4. We are, therefore, pleased to see proposals in this consultation paper for closer alignment between the policies of NMP2 with NPF4, which we believe will help support a plan-led approach to development and conservation in the sea and on land.
Such close alignment should reduce the risk of conflicts arising between the two plans. However, we are conscious that not every eventuality can be anticipated at the plan preparation stage, and we therefore believe further clarity should be provided to assist decision-makers on which of NMP2 or NPF4 should be given primacy. Such clarity will be important to ensure a consistent approach is taken by decision-makers implementing the two companion documents.
Supplementary Guidance
We note that many of the policy proposals set out in the consultation paper are caveated on the basis that further supporting guidance, including clarity around definitions, will be required to support their practical application. The consultation paper does not set out the details of these additional support mechanisms. Consequently, the paper remains vague regarding how the HLOs and policy proposals will be implemented and applied to development proposals in practice.
Whilst we broadly support the overarching principles and objectives of the proposed HLOs and associated policies, the devil will be in the detail. NMP2’s practical application will be largely dependent upon the proposed wording of the policies as well as the availability and content of the associated guidance documents and agreed definitions. It will be important that the availability of these supporting mechanisms is appropriately timed so that it coincides with NMP2 coming into force. When such guidance is delayed, there is a risk of exacerbating uncertainties and associated negative repercussions that are the opposite intention of NMP2.
In addition to the above, we note that there are a number of guidance documents which have been prepared, and are currently being prepared, by the Scottish Government to support NPF4 policy implementation, including guidance on climate mitigation and adaptation (currently in draft form). As well as ensuring close alignment between the policies of NMP2 and NPF4, we also believe it will be important for there to be close alignment between the guidance that has been and will be produced to support the implementation of NPF4 and NMP2 policies. The supporting guidance will be vital to ensure consistent interpretation and implementation of policy. Consequently, their alignment will be key to ensuring a consistent approach is taken to the implementation of both NMP2 and NPF4 moving forwards.
Co-existence and Co-location
The consultation paper provides separate definitions for co-existence and co-location (with co-location recognised as a subset of co-existence). We acknowledge that promoting effective and harmonious co-existence is a policy of the current National Marine Plan and aligns with the EU Maritime Spatial Planning Directive 2014. However, it is unclear from the consultation paper what the proposed policy stance is on the co-location subset. Providing a separate definition indicates that it is important to make a clear distinction between these two terms. However, the consultation paper is unclear in what way co-location should be considered as distinct from co-existence. We believe further clarity on this point would be beneficial, including potentially through the use of case studies to show examples of both co-existence and co-location in practice.
Implementation and Monitoring
RTPI Scotland supports the introduction of a “Implementation” HLO and associated policies. All too often, plans are put in place without due regard given to their practical implementation which results in enhanced uncertainty and a lack of concerted focus on long-term delivery.
By embedding “implementation” into the plan itself, we believe this will place NMP2 on a strong footing to achieve its intended outcomes. Continued monitoring of NMP2 will be key to its successful implementation. We are, therefore, also pleased to see the consultation paper refer to the preparation of a monitoring and evaluation plan as well
as an implementation and resourcing plan to accompany NMP2. We strongly believe that for NMP2 to be delivered effectively, it’s policies must be supported by a clear implementation plan, monitoring/evaluation framework and resourcing strategy.
Notwithstanding the above, the consultation paper currently lacks detail on what these supporting documents will comprise, the timing of their preparation, and their intended outcomes. In particular, the resourcing plan is mentioned only once within the consultation paper, with no further details given as to its intended purpose and scope. Such a resourcing plan will have implications on the successful attainment of the “Implementation” HLO including, for example, policies associated with sound and evidence-based decision-making. It must, therefore, be embedded within the monitoring and evaluation process. Whilst we strongly support the inclusion of an evidence-based decision-making policy in NMP2 (which we note is also in the current NMP), we are acutely aware that such an approach will require access to specialised knowledge and skills which have been lost to many local authorities due to budgetary constraints. RTPI Scotland believes that any future resourcing strategy must include an assessment of the knowledge and skills that are required and available to effectively deliver on the outcomes of NMP2, as well as a strategy to ensure access to these knowledge and skills is available to decision-makers and statutory consultees. We note that progress is currently being made to provide mandatory elected member training in accordance with Section 45 of the Planning (Scotland) Act 2019. This includes options to include modules on specialised areas of planning. We believe including a marine planning module, including the intersection between marine and terrestrial planning and the interconnected relationship between NMP2 and NPF4, would be of great value to elected members in Scotland who are involved in decision-making affecting the marine environment.
We agree that monitoring and evaluation must be built into the design of NMP2’s policies and given due regard throughout its development and implementation to ensure an agile and adaptive approach is taken to Scotland’s marine and coastal areas. The consultation paper states that “the outcomes of evaluation will inform further action”. However, we believe that for the outputs of these supplementary plans (including a resourcing plan) to serve their intended purpose, they must include a clear action framework to address any shortcomings identified through the monitoring and evaluation process. This should include details of who is responsible for the actions, when the actions will be delivered and through what mechanisms, how the actions will be prioritised etc.
