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Review of Integration Among plans for the Coast in Scotland: Analysis of the SCF Coastal Plans Inventory

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REVIEW OF INTEGRATION AMONG PLANS FOR THE COAST IN SCOTLAND: Analysis of the SCF Coastal Plans Inventory

CHAPTER 7 RESULTS OF CASE STUDY REVIEWS
CASE STUDY ONE: CROMARTY FIRTH

Introduction

7.1 The Cromarty Firth, within Highland, is covered by the longest established ICZM initiative. The Cromarty Firth Liaison Group (CFLG) was set up in 1992. The area has a considerable industrial heritage, especially at Invergordon and Nigg, mostly set up with the establishment of the oil industry in the North Sea. However, the area also has significant nature conservation interests as well as the continuation of the pre-oil agriculture and fishing industry. The establishment of the group was motivated by the Cromarty Firth Port Authority's consultations with the other regulatory bodies over the implications of the proposed SPA (Special Protection Areas) under the 1992 Habitats Directive. However, the CFLG has now merged with the Moray Firth Partnership (MFP), and is likely to take on the local delivery element of ICZM for the Cromarty Firth as part of the MFP. Their management structures will merge.

7.2 The CFLG is comprised of 10 members on a Management Group, four of whom are represented on a Steering Group. It is the only ICZM forum in Scotland that has completed one cycle of the coastal management cycle as found in Olsen (1999), as they have commissioned an evaluation and review of their Management Strategy and Action Plan by Cordah in 2001. The case study examined 18 documents covering 12 of the 21 categories. Known omissions from the 'ideal' system include a local waste management strategy and subject plans.

Completeness

7.3 The Cromarty Firth is at the advantage of being wholly within the administrative boundaries of the statutory bodies and does not fall between two catchments. Thus there is a consistency in action and allows one representative for each body on the forum.

7.4 The ICZM plan for the Cromarty Firth, published in 1998, is in two parts, the Management Strategy and the Action Plan. The Management Strategy details the long-term proposals for the area, and the Action Plan details short to medium term tasks to be undertaken. The Action Plan is coming to the end of its implementation period.

7.5 The plans examined ranged from a localised level to the Highland Council area. Of the Rank 1 plans, all are present for this area (though the Shoreline Protection Strategy could not be obtained). Four Local Plans cover the Firth, meaning that development planning is detailed at the local level. All statutory plans, which include the port management plans and development plans, are present, though the Local Plans are out-of-date. Most of the other plans have been published relatively recently, from 1997 to 2001.

7.6 Achieving full development plan coverage has taken some time. The current adopted Local Plans date from as early as 1985, and the most recent Local Plan dates from 1992, covering the period up to 1996. The previous Structure Plan ran from 1990 to 1998, with a new plan adopted in 2001. A new Local Plan covering the whole of the Firth is due to be published in Spring 2002, and this will supersede the current Local Plans and bring the development plan coverage of the area up-to-date. Also, this new document may to a certain extent make a review of the current ICZM plan necessary.

7.7 Several other plans have not given a time scale for review and update. The ICZM Action Plan gives time scales attached to the actions suggested, and at this stage the plan is coming to the end of its implementation period. The intended review period is not clear for many documents. Most of the statutory plans give a date for review, though not all.

7.8 There is an apparent lack of community participation in many plans. That is not to say that there is no participation by the public, just that the plans do not always document if there have been efforts to take the public's views into account. Community Councils are a statutory consultee in the consultations on Structure and Local Plans and have also been included in the development of the ICZM plans. It is noted that the new Local Plan is being developed, and at this stage public contributions have been canvassed through workshops, so there is evidence that any previous lack of community involvement may be changing. The CFLG has also stated that it is noted that the wider business community, in particular small to medium sized organisations, have not been fully involved in the ICZM planning process, which they are looking to rectify.

7.9 With regard to accessibility of plans, the port documents are mainly controlled documents so are not widely available. Development plans are public documents and are available to view from the Council. Some other plans are available free on request. For the Cromarty area, only the NHZ plan is available on the Internet. With regard to their technical content, some plans could be more comprehensible to a lay audience, particularly in the introduction, as many are unclear on the reasons for the plan, the aims, and the assumed audience.

Quality and Best Practice

7.10 There does not appear to be any examples of non-compliance with current legislation. However, full implementation of NPPG 13 has not been achieved; the classification of the coast has not been undertaken in local development plans. This could be considered to be a potential hindrance to the completeness of the system. It is difficult to assess whether other policies of NPPG13 are taken up and are consistent with other plans. The SAC plan cross-references its proposed actions with those suggested in the ICZM plans, to avoid duplication of effort.

7.11 Some documents show good examples of vision, with the draft Natural Heritage Zone plan discussing what the environment should look like in 2025 if it is managed sustainably. Most plans have some sort of aims set out at the start. Most at least have short-term (2-5 year) goals.

7.12 The CFLG has undertaken an evaluation of the implementation of its strategy and has concluded that where a project in the action plan was required to fulfil statutory obligations, it has generally been completed, but there has been limited uptake on the actions where there was no legislative driver. It was noted that there has been a lack of uptake of the Strategy in other plans. However, because of the more consultative approach to conflict resolution, it is felt that this does not necessarily demonstrate a lack of commitment or a disregard of the activities and role of the CFLG.

7.13 There is not a great deal of cross-referencing between the many plans for the Cromarty Firth. However, most of the plans do contain similar types of policies aimed at improving the quality of the environment and developing the economy and community of the area. Some documents are better than others at recommending more definitive actions for improvement. It is noted that, in contrast, the evolution of development plans has led to more general policies rather than detailed actions. It appears however, that policies are generally becoming more compatible with ICZM, with the environment achieving a higher status over the years and community and social improvements having a higher profile.

7.14 The Evaluation and Review report concludes that there was little investigation as to whether the CFLG had influenced the policies and proposals of the participating partners. To a certain degree this is demonstrated in the plans for the area, with little evidence that organisations have had a lot of regard to other plans, other than when they have had to through legislation. However, that is not to say that current plans are contradicting each other, and the standard of policies is considered to be moving towards sustainability and ICZM thinking.

7.15 The CFLG feels that the other ICZM fora have perhaps now overtaken them in their approach to ICZM, but they were the pioneers. The CFLG's structure has not assisted in implementation as they feel they do not have the same backing, being comprised of a small group of policy makers. This is one of the reasons for the merger with the MFP to ensure the long-term stability of ICZM in the Cromarty Firth.

Consensus

7.16 The plans show a range of methods employed to obtain views on the plans. The port plans do not appear to have required any outside consultation apart from the bodies specified in the implementing legislation. The statutory development plans are required by legislation to obtain the views of the public through allowing them to comment on the draft plan, though it is not clear if other bodies were actively involved in the writing of the plan. The ICZM plan demonstrates some innovation in its development by setting up topic groups to develop the policies used later in the plan. The proposed Local Plan which has yet to be published shows the next stage in developing consensus by holding open public meetings before the plan is written. Future plans are likely to require further public involvement to ensure that they are not just a top-down plan imposed on a community.

7.17 The ICZM plan takes a more participatory approach in its development, with representatives from different sectors inputting into the plan preparation, so conflicts are resolved at early stage. Very few of the other plans use this inclusive approach. The ICZM action plan makes sure that the different sectors represented are included in the projects being proposed. The ICZM plan shows shared responsibility, but as it is voluntary, it does not mean that this is actually followed through. It is noted that as there is no unifying coastal policy within the Highland Structure Plan, then it is difficult to determine if the ICZM plan is influencing the policies of the Structure Plan.

Conclusions

7.18 With the longest standing coastal forum and the earliest produced management strategy, plans for the Cromarty Firth should be expected to show a high degree of integration. To a certain extent this has been found, and the Cromarty Firth has certainly benefited from the work of the CFLG. There are areas which remain incomplete, and are likely to be due to certain key issues: the lack of implementation of NPPG13, the time taken to revise development plans and the historic lack of community participation in some plans.

7.19 The CFLG is to be praised for being the first group to go through the whole management cycle from plan preparation to evaluation, and has already started to build upon these findings. The merge with the Moray Firth Partnership appears to give the group a firmer standing for future development.

CASE STUDY TWO: ORKNEY ISLANDS

Introduction

7.20 Orkney has no formal ICZM Forum or other Initiative. However a report was published by Orkney Islands Council (OIC) in 1998 (updating a 1989 document, which was not reviewed) to discuss the baseline environment and potential benefits of an ICZM strategy for Scapa Flow. This document represents a 'proto' ICZM plan, though only covers a small area of the archipelago.

7.21 The case study examined 12 documents covering 8 of the 21 categories in the database. These included; Local Plans; Structure Plans; Archaeological Assessment and Plan; Biodiversity Action Plan; Guidelines (NPPG13); Landscape Character Assessment; Subject Plans; and Oil Spill Contingency Plan.

7.22 It is understood that the OIC intends introducing a Fishery Management Plan in the near future. No Local Agenda 21 Plan has been prepared and no nature conservation documents ware available at the review. Neither were there any tourism or other sectoral plans available for review although it is more than likely that they exist in some form. The same is probably the case with Port Waste Plans.

Completeness

7.23 Whilst the primary 'Rank1' Documents, the Structure Plan and the Local Area Plan, are in place, the initial review would suggest that from an ICZM perspective there are gaps in coverage. The Scapa Flow study is a very useful document in giving information on the 'environment' at the time of the report, but is limited in its scope as a management strategy and also in its geographic coverage. The absence of other 'Rank 1' documents (wider ICZM initiative and Shoreline Management Plans) may not be significant since the whole of Orkney could be described as being under the coastal influence and thus coastal issues would be integrated into the economy and social fabric of the islands. The area has the advantage that it is wholly within the administrative jurisdiction of the OIC. The Council is involved in some capacity or other in all of the documents reviewed and is therefore the key to integration in this region.

7.24 With the exception of the Orkney Structure Plan 1993, which was reviewed for the purposes of comparison, all of the documents reviewed are current and date from 1997 at the earliest. Geographical cover is complete for the key plans that deal with the whole of the archipelago. Cover varies for some of the more specific studies and plans, for example the misleadingly titled 'Report on a Coastal Zone Assessment [archaeology] Survey of Orkney' which covers only some of the Orcadian islands.

7.25 Whilst not all of the documentation relating to Orkney was available for review, there is no evidence from the case study of failure on the part of any organisation to comply with statutory obligation.

Quality and Best Practice

7.26 Some of the documents reviewed were incomplete in that they lacked certain maps or other illustrations that would indicate the legibility of the plans/strategies. On the whole the reading suggested that most of the documents are 'user friendly'.

7.27 It is difficult to comment on the quality of the documents but individually each document appears to fulfil its objective and the fact that the statutory plans are subject to rigorous review and analysis before adoption is a further assurance that their coverage is adequate.

7.28 All of the documents reviewed subscribe (or state that they subscribe) to the broad principles of ICZM as articulated by the EU Programme, although do not refer to the EU documentation. However, overall the impression is that the planning process is dealing primarily with the short term. Until the production of the new Structure Plan and the draft NHZ plan, there was little evidence of a long-term strategic view being taken to either development/conservation or to integration. Few of the documents reviewed look beyond the 10-year horizon and even those that do venture that far end up focusing on short-term action. Overall there would seem to be an absence of 'vision' in the documents apart from the structure plan.

7.29 This may be expected, since the statutory plans in particular are obliged to be practical and to be grounded in reality and this forces a short-term view. In the case of Orkney the lack of a 'consistent' voluntary coastal/integrated management initiative means that there is no vehicle for visionary statements and no forum for discussion of future scenarios. The Scapa Flow report however has taken on some of the key principles of ICZM, and notes some best practice issues, and thus sets up a good basis that could be developed.

7.30 The Local Plan is currently under review, and the only section of the new plan available was a preliminary draft of Chapter 6 on Coasts. Initial reading of the Coasts section suggests that it will rely heavily on Structure Plan policy. Both documents support the establishment of a coastal forum for Orkney.

Consensus

7.31 The Orkney suite of plans exhibits a high degree of consensus. This is hardly surprising given that the OIC are responsible for, or have participated in, almost all of the studies and plans that were reviewed. At the core, all parties appear to subscribe to the concept of sustainable development, and to the principle of public and cross sectoral participation, however, if the sampling of reports and studies is typical, the effort toward sustainable development is driven in the main by the environmental side of the balance sheet. There is little evidence of the involvement of the private/development sectors in the formulation of the plans.

7.32 If the difficulty in accessing the various documents and plans encountered by the study team is an indication of their general (public) availability, there would seem to be an opportunity for increasing dissemination of information using the latest technology. This could have the added advantage of increasing the participation and involvement of the community at large.

7.33 The documents reviewed had little documented on the consultation process (public or technical), however, it is acknowledged that extensive consultation was undertaken for the new Structure Plan. The system of public consultation in the past has not embraced participation and was based on securing public acceptance of plans prepared in advance by the Authorities; this is now changing.

Conclusions

7.34 In Orkney, within the limitations of the documents reviewed, there appears to be a high level of integration between existing plans and management strategies. This would appear to be due to having a small and close knit community, and the importance of the coasts to the economic well being of the islands.

7.35 The absence of documents focused on a strategic vision for Orkney means that co-ordination falls to the OIC and to the Structure Plan. This appears to work well for Orkney but might be considered a gap in the integrated management process in general. For example, there is surprisingly little reference in the documents reviewed, apart from the new Structure Plan, to the position of Orkney in respect of its geographic neighbours or the wider economic context.

7.36 There is little evidence in the documents reviewed of voluntary ICZM initiatives having any influence on plans or strategies, though the profile of integration and the importance of the coastal environment may have been raised by the Scapa Flow report. There would appear to be a need for some sort of collaboration between different sectors and it is noted that the new development plans support the establishing of an ICZM forum.

CASE STUDY THREE: ABERDEEN AND ABERDEENSHIRE

Introduction

7.37 The Focus on Firths project saw the successful establishment of a number of local Fora along the Scottish Coast. A fundamental role of the fora being to aid integration where there are perhaps complex administrational arrangements and issues with regards to management of the coastal zone. However, fora do not cover the entire Scottish coastline.

7.38 The Aberdeen and Aberdeenshire case study area corresponds with the Aberdeenshire Council local authority boundary up until Fraserburgh, where the Moray Firth Partnership boundary lies and includes the City of Aberdeen. Unlike some of the other areas in Scotland without a forum, this case study area has two local authorities within its boundaries, each with land use planning responsibilities in the coastal zone. The level of integration being achieved is therefore of significant interest due to the different administrations and interest groups and the absence of a forum to facilitate the ICZM debate. The area also does not have an ICZM plan or strategy, prepared by a voluntary partnership, for the management of the coast.

7.39 The case study area also has an interesting mix of uses and types of coast, with highly developed coast alongside large swathes of undeveloped coast of local and national nature and heritage value. Aberdeenshire does not have any isolated coasts as defined in NPPG 13.

Completeness

7.40 As discussed in Chapter Three there are a number of plans that have varying degrees of influence on the coastal zone and the area has at least one of each of the plan types applicable to its area.

7.41 Aberdeenshire has three draft development plans. This includes the two local plans, Aberdeenshire Local Plan Draft 2000 and Aberdeen City Finalised Local Plan 1999 and the new structure plan, North East Scotland Together 2001. Additional statutory documents include a full set of up to date Port Emergency, Waste Management and Oil Spill Contingency Plans for Aberdeen Harbour, Peterhead Bay Harbour and Peterhead Harbour. It appears that where statutory plans are required in this area that they have been prepared.

7.42 The area also has a range of non-statutory cross-sectoral documents, such as Nature Conservation plans, the Aberdeenshire Landscape Character plans, Coastal Protection Studies and Good Practice Guides. These plans deal with specific topics and coverage is related to each individual plan.

7.43 Accompanying these is a raft of new environmental and sustainability plans in response to both the City Council and Aberdeenshire Council's statutory obligations to prepare LA21 and also LBAPs. Aberdeenshire also has a number of recent plans tackling the sustainability issue including Aberdeen Futures and Aberdeen City Environmental Strategy 2001. The City and Aberdeenshire Council have prepared the majority of these plans. These documents are all saying the right thing, the degree to which they are implemented will be interesting to see.

7.44 The plans deal with the coast as a part of their overall remit or focus on specific topics as opposed to the coast as a whole. One of the gaps in plan coverage is an up to date ICZM document (or an ICZM group) that can focus and facilitate the ICZM debate. The current Structure Plan states that both Councils would support the preparation of ICZM plan (in line also with NPPG 13), and it is noted that the previous Grampian Structure Plan 1995 also made this commitment. As the Structure Plan is recent it is perhaps too early for this policy to be implemented but the support for developing ICZM is there. It is unclear as to how high a priority this is on the Council's agenda.

7.45 In general the plans for this area are user friendly, particularly the raft of environmental and sustainability plans. The Community Plan, (Aberdeen Futures), the LA21 Strategies and the BAPs are very readable, accessible and illustrative. The Internet is also a good resource for accessing plans. Aberdeen City and Aberdeenshire Council have made the majority of their plans available through this means. It is the non-statutory plans that are not so readily accessible to the public.

7.46 Participation is a fundamental part of ICZM. The statutory requirements for participation have been achieved in the development plan process and in most of the remaining documentation reviewed, the importance placed on community and stakeholder participation is evident. The environmental and sustainability plans such as the LA21 strategies and the Aberdeen Community Plan appear to have embraced the concept fully. The evidence includes, for example, accounts of Planning for Real days. The Aberdeen Beach Project is a good example of joint working between departments in the council and also with the wider community.

7.47 The 1986 ICZM plan for Banff & Buchan shows that participation was a key part of plan preparation. A working group was also established to facilitate the overall debate. The large number of representations made by interest groups and the community are included in the plan. These would be useful for monitoring purposes to see if concerns had been tackled through the polices in the plan. There is no evidence as to whether this has in fact taken place. Although this plan is in need of updating the principles of ICZM are reflected in its content.

Quality and Best Practice

7.48 Generally speaking the structure and local plans seem to be consistent, and have been over a period of time. Each contains policies that also link to national and UK guidance. Each contains policies for the coastal zone and associated policies for the conservation of natural heritage, planning for tourism etc. Conflicts will arise close to the coast when there is pressure for development (particularly around Aberdeen) where policies for economic development are conflicting with policies for the environment.

7.49 The environmental and sustainability reports do appear to have good consistency and cross group-working arrangements and are taking a more holistic view of issues in their economic, social and environmental context in a participatory manner. It is the 'stand alone' documents (majority of which are non-statutory) dealing with specific issues and topics that do not integrate as well within the hierarchy. This is the nature of subject or topic plans and it would be unrealistic to expect them to integrate with all other documents, though at least cross-referencing would be expected.

7.50 A good example of integration appears to be the 'proto' ICZM plan for Banff & Buchan (1986) which shows a strong bottom up management structure that was locked into the development plan process. The ICZM working group lobbied the District Council and had the findings of the ICZM plans integrated with the District Local Plan polices at the time.

7.51 Generally speaking the coast lacks an overall integration vision. The coastal policies contained in key documents (structure and local plans), focus on development planning and development control. These land-use planning documents are limited in terms of what they can do for the coast, except perhaps for providing a context for an ICZM plan. As key documents in ICZM, the plans give their support to initiatives that might in fact realise the vision that is regarded as lacking at present. The Structure Plan advocates that where appropriate local authorities and other agencies should work together to prepare coastal protection studies and input to coastal management plans where they are needed. The Aberdeen City Local Plan also gives support through saying it will promote the setting up of a coastal forum, as recommended in NPPG 13, in conjunction with Aberdeenshire Council.

7.52 Some plans for the area do have vision for parts of the coast. Nature Conservation and Nature Reserve plans have a vision for short stretches of coast, with plans detailing how the coastal environment will be managed and how the plans will be implemented. These are effective management tools and due to the designated status of the area they cover, the conflict with economic development is not a problem. The LA21 strategies again have a longer-term vision for areas that include the coast. For each of the key actions in the LA21 plan, the targets for implementation of key actions are clearly stated and the key partner responsible for implementation - the vision for the future is there. The biodiversity action plans deal with parts of the coast and importantly bench marks the situation in the coastal zone at the time of writing and where they want to be in the future.

7.53 Very often the vision in the plans above is focused on the environment. There is a lack of a holistic vision that joins up these individual actions, one that integrates the environmental with the social and economic aspirations relating to the coastal zone.

7.54 On the subject of good practice, the Moray Coastal LBAP (a part of the BAP for the North East) is a useful document for ICZM that could be duplicated elsewhere. The document gives good details on the state of the coast, the factors affecting it, principle objectives and the key actions to be taken. The key actions include, the development of a coastal strategy, promotion of integrated management to resolve conflicting management interests, assessing the trends in coastal pressures and plan current and future vegetation and erosion control. This is a locally driven process that fits in with national and international programmes designed to enhance biodiversity globally. There is a BAP steering group with a large representation of local interests, a bottom up approach with one of the primary aims being to provide a focal point for information exchange, raising the profile of the biodiversity issue, community involvement and partnership development. The BAPs for the North East of Scotland are ongoing and there is an opportunity if deemed necessary to prepare something similar for areas of Aberdeenshire.

7.55 Aberdeen City Council is producing a Climate Change Action Plan that includes research into the impacts of sea level rise, potential increases in flooding, storms and coastal erosion. The action plan will look at implications of developing along the coast in areas at risk. The Climate Change Action Group preparing the plan is working with other organisations and agencies in the formulation of the plan. When the plan is adopted, the group will take it to other outside interests for example the business community and the general community to raise awareness.

7.56 Many of the plans have also engaged what is currently regarded as best practice. One example being that all the policies in the Structure Plan have undergone a sustainability appraisal routine.

7.57 Overall when we talk of quality it is important to remain objective in the absence of an ICZM document. It is unlikely that any of the existing plans would deliver an integrated distillation of good practice and vision for the coast. The policy documents that have been reviewed deal with coastal issues alongside many different policy areas and in many instances are cross referencing one another and integrating to a certain extent.

Consensus

7.58 Generally there appears to be a consensus amongst polices and the message coming through is consistent. There appears to be a great sense of commitment to sustainability and achievement of the objectives of the LA21 actions. The common concern for nature conservation, landscape, recreation and tourism and protection and diverse environment is coming through. There is a consensus that the principles of integration, community involvement, cross group working groups and environmental education are vital to the planning process. The main conflicts are arising where the pressure for economic development is highest.

7.59 There also appears to be consensus that a coastal forum should be established as supported in the structure and local plans. The Aberdeen Bay Coastal Protection Study report also recommends co-operation between interested parties within Aberdeen Bay and that this is continued through an Aberdeen Bay Coastal Group. How high this is on the agenda is difficult to say.

Conclusions

7.60 Statutory development plans play an important part in coastal management but cannot deal with all of the issues. The authorities have recognised this fact and appear to be in the process of supporting initiatives to encourage the necessary alternatives.

7.61 It would be useful for the coast to have more references in the LA21 and biodiversity action plans to raise public awareness and improve the profile.

7.62 The local authorities need to continue support for other plans that will have an influence on coastal planning in the future e.g. LA21's, BAPs, River Basin Management plans.

7.63 It might be the case that if there was a national strategy, as is the case with BAPs, ICZM would be equally successful at being transposed to the local level. In some cases it appears that national backing has brought about local action. The national strategy could deliver results such as guidelines on coastal initiatives or standards on content and scope of management strategies.

CASE STUDY FOUR: FIRTH OF CLYDE

Introduction

7.64 The Firth of Clyde, on the west coast of Scotland, extends from the upper tidal limit of the river Clyde to the tip of the Mull of Kintyre in the west and Loch Ryan in the south, and is covered by an ICZM forum, the Firth of Clyde Forum (FCF), established in 1994. The Firth is acknowledged to have representations of probably all sectors and interests in the coastal zone, mainly due to its size. There was considerable heavy manufacturing interests in the north of the Firth, but this has declined in recent times, leaving a legacy of vacant land and economic down turn. The area also has significant nature conservation, tourism, fishery and transport interest, and the coast is significantly urbanised.

7.65 The FCF has a wide range of members and has published an Integrated Management Strategy and Action Plan in July 2000. The case study examined 32 documents covering 13 of the 21 plan categories. Known omissions from the 'ideal' system include a local waste management strategy and separate fishing strategies (outwith the development plans).

Completeness

7.66 The Firth of Clyde covers a wide area and encompasses many administrative boundaries. There are eight local authorities and four structure planning authorities. The coverage of other organisations is more regional, partly because the area was within the single administrations of the old Strathclyde Regional Council and River Purification Boards.

7.67 Most plans therefore cover a substantial area. The FCF's ICZM plan is the only one that covers the whole Firth. Due to having joint structure planning authorities, Structure Plans are mostly strategic. BAPs are varied, some being prepared for a local authority, some for the wider structure plan authority - authorities are pooling together where there are similar habitats (e.g. Renfrewshire and Inverclyde), or where existing administrative co-ordination is in place (e.g. the three Ayrshire councils). LCAs and NHZ plans are prepared for the wider, regional level. Most local authorities are replacing local plans with a single plan for the authority area. LA21 strategies are prepared at the local authority level. Oil spill, port waste and port emergency plans, though specific to a harbour, group areas together for reporting. Of the Rank 1 plans, all are present, though only one small area has a shoreline management plan, which was not available to review. The plans examined have been produced since 1994, and most from 1998.

7.68 The statutory development plans are under review in most councils, with most producing a draft or adopted plan in the last two years. The only area that is still to be updated is the Local Plan for Argyll and Bute, which will be published in draft, after the new Structure Plan is approved. However, it is disappointing to see that even though all plans studied have been published after the FCF was set up, and considering a good number were published after the Management Strategy was produced, that there is not much direct reference made to either.

7.69 Regarding the ICZM plan, the action plan has not yet been fully implemented, and there has yet to be a review and evaluation. This is likely to change with the recruitment of new staff and an application for European funding has been submitted to progress areas identified in the plan. To date there have been limited resources to undertake actions and to motivate participants to implement actions. However, the Management Strategy shows a good example of setting out long-term principles but having short-term (up to 18 months) and far more practical and realistic actions. The actions from the "Phase 1" plan hope to set up the mechanisms to improve communication, links and for later information gathering. The recently appointed project officer has also begun developing "Phase 2".

7.70 As with other case studies, the Clyde also demonstrates an apparent lack of community participation in the preparation of some documents; this was conceded as a difficulty by the FCF. An exception is in LA21 plans which demonstrate the most effort made in community consultation, as many are undertaken as part of community planning activity. Also, it should be noted that Community Councils and the regulatory authorities are statutory consultees in development planning.

7.71 The Clyde also shows a high level of accessibility to plans. Most development plans, LBAPs, LA21, NHZ and the ICZM plans are available on the Internet, and although there may be a charge for a paper copy, they are available to view from council offices and some libraries. The LCA may be available to view locally, but is mostly only available from SNH Publications to purchase or on loan. Port documents are mostly controlled documents and not generally available. These documents are also the most technical, and could improve on the presentation for a lay person, when considered that they may be used in the preparation of other plans. This could assist achieve further integration.

Quality and Best Practice

7.72 There does not appear to be any non-compliance with legislation. However it is interesting to note how councils have implemented NPPG 13. Many authorities with a significant area of developed coast do not precisely refer to the classification text from the NPPG, but still have policies that provide protection from unacceptable development on the coast.

7.73 The ICZM plan was produced with the ICZM principles in mind and reference is made to them. As the principles had been published only a short time before, and the ICZM planning process to gain agreement between participants is so long, the document would not have been expected to fully comply with them. The only shortcoming is perhaps that of community participation.

7.74 It is perhaps the case that the statutory development plans now recognise how important the environment is and has developed good policies to deal with these issues. There are some very good examples of development plans in the Firth of Clyde area, which look to be making a good contribution to the regeneration of the area, even if they do not tackle the coasts as a separate topic. It is also interesting that issues such as tourism, aquaculture and minerals are now located in the environment section of development plans instead of in the economy section.

7.75 Many documents show good examples of long term visioning for the area. The NHZ plan discusses the future environment in 25 years time, and the LA21 plan for Renfrewshire also sets long term goals. The Structure Plans are required to plan at least mid term (5-10 years) and one includes targets to be met in the next 20 years. The LBAPs also plan long term, with some having short to mid-term actions for implementation. Other plans continue to plan in the short-term with no overall strategy for the long-term.

7.76 The ICZM plan and the LBAPs have identified the need for improved information access and sharing. For such a wide area, data collection looks to be a significant issue. It has also been noted elsewhere that the Water Framework Directive will create requirements for the clear demonstration of data management based on catchments (which includes the coastal area) and that this will make a tremendous impact in the future. It is not clear whether the actions for data collection may wait until the Directive is implemented.

Consensus

7.77 There is a range of mechanisms employed in plan preparations to obtain views and gather comments and much effort employed in the development plan process with some local plans having been preceded by "issues papers" to garner views before the draft plan is prepared. The ICZM plan made a conscious effort to engage participants in the plan preparation although outside of the usual players found this challenging. It can be concluded that some plans will only undertake the statutory requirement for consultation although a few show a willingness to engage the community in the development of the plan.

7.78 The ICZM plan achieved consensus by developing a consultative approach in developing general principles that can be agreed by all parties. Therefore conflicts are resolved at the plan preparation stage. As many sectors have been included as possible, so it is expected to be fairly representative, but the concern has been that a wider range of voluntary groups were not included. The FCF also report that it has been difficult to ensure that the strategy is implemented by the participants unless there is a particular interest or an individual commitment to an action. Statutory responsibilities are assumed to have been implemented, but there is a problem engaging a shared responsibility for the plan.

7.79 It is clear though that recent policy is becoming more consistent, in particular between the BAPs, ICZM plans and development plans. This may be a result of the setting up of the coastal forum, as well as directions from the government through planning guidance and legislation.

Conclusions

7.80 The policies and strategies relating to the Firth of Clyde area are considered to be in the most part consistent among each sector, and at least attempting to integrate between sectors, especially regarding the environment. In the case of statutory development plans however, there is competitiveness between authorities for resources and for attracting business, which means that policies on the economy across the whole Firth of Clyde are lacking integration. It is difficult to see how the best location for new businesses taking a wide scale view for the whole Firth can be resolved when each local authority could be competing for economic investment.

7.81 Another interesting point is that if coastal issues are mentioned, they are included in the environment or development strategy in local plans, and not under the other sections on economy, transport or community. ICZM plans could fulfil this co-ordinating role if priorities were changed. This is of particular relevance for the Clyde given its diversity and conflicts. If the organisations and individuals with an interest in the coast could see that the ICZM plan has a wider remit than the 'environment', then ICZM could start to have a bigger impact on planning for the coasts.

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Page updated: Monday, June 5, 2006