I have a response to Mike Rumbles’s question about what works well at the moment. There has been a much greater focus in recent years on pre-application discussion. That has been very helpful for us and we have embraced it. We now try to put a lot of our resource into that pre-app discussion with industry partners.
The key with the pre-app discussion is to identify, at the very early stage, what the constraints might be on the sites—we hope that developers will consider more than one site—so we can steer developers away from sites where we think there are likely to be the most environmental problems.
That ties in with what Mark Harvey said about how, ideally, we would like to see better strategic planning from the outset. If we identify where the most suitable locations are, we do not have to say that a site is really bad at the individual application stage, because we have already gone through that process.
Useful work is being done. Marine Scotland has been doing good work on heat mapping, and once it is out there and in the public domain, I think that it will be helpful. Some form of better strategic planning that helps steer developers to good sites will really help.
The pre-app phase has been good, and we think that it will lead to a decrease in the number of applications coming into the system that we have big problems with and have to raise an objection to.
On issues that we feel are still problematic, Mike Rumbles mentioned monitoring. SNH does not have a role in post-consent monitoring, but there are issues with it.
The ECCLR Committee report referred to the evidence of damage, particularly within marine protected areas or to priority marine features. Our role in relation to MPAs is on site condition monitoring—monitoring the condition of the features within protected areas. We do that on quite a long cycle, because of the resourcing costs: marine monitoring is very expensive and we do not have a lot of resource to monitor those sites regularly. We deliberately select stations for the survey points for monitoring that are away from things such as fish farms, because otherwise the results would not be representative of the site as a whole. It is very unlikely that our routine site condition monitoring on that lengthy cycle will pick up issues relating to change and damage to features from a fish farm.
There is something there about better use of the routine monitoring that other partners, such as SEPA, are carrying out and linking that to a better understanding of the impacts on sensitive features, such as maerl beds, which were mentioned in the Environment, Climate Change and Land Reform Committee’s report. That would give us a better understanding of the long-term impacts, likely recovery rates and how much we can say about damage to a wider area from the direct footprint of fish cages. There is probably quite a lot there that we need to come back to.