Lucie Skates looks at implementing a balanced approach to the future of marine advice in Wales
The Welsh National Marine Plan (WNMP) is the first marine plan for Wales, and represents the start of a new planning process for shaping Welsh seas to support a range of economic, social and environmental objectives.
A key aspect is the focus on proportionality, as the Welsh government wants the plan to deliver sustainable outcomes in a consistent and efficient way that minimises the burden on its users.
As a principal advisor on the environment and natural resources, Natural Resources Wales (NRW) has been working closely with the Welsh government to provide evidence and advice to support development of the WNMP. Now the plan has been adopted, we also have a key role in implementing the policies in the plan through our regulatory, evidence and advisory work.
For example, in our report Seascape and visual sensitivity to offshore wind farms in Wales we applied a proportionate approach by focusing on visual effects on National Parks and Areas of Outstanding Natural Beauty, and proactively sought to produce improved evidence that reflects the sensitivity of these receptors and the scale of impact.
In NRW, we are improving our ways of working within a new organisational structure, identifying opportunities to improve management of marine resources under the new planning framework of the WNMP.
We asked IEMA Fellows Josh Fothergill and Dr Rufus Howard to help develop a set of advisory principles to help guide our work by embedding a proportionate approach in our marine planning and development advice.
Marine advice
We aim to provide marine advice that will positively influence policy, planning, development and decision making, to ensure that the marine environment and natural resources of Wales are sustainably maintained, enhanced and used, both now and in future. Our advice will comply with relevant legislation and be:
- Proactive, and focused on enabling consideration of key environmental issues and opportunities at an early stage. We can do this at a strategic level by advising on plans and policies, and for individual projects, for example by developing guidance to help planners and developers consider more generic issues or environmental opportunities in the early stages of a plan or project.
- Clear, concise and mindful of the intended audience. We want to provide effective, focused advice that people can understand and act on. We are providing NRW staff with training and guidance on effective writing, and will work to develop and promote a common understanding of key terms.
- Constructive, timely and consistent. We want to consider the needs of the recipient of our advice, and if appropriate to be adaptive and work collaboratively with them. We are aiming for a consistent approach and advice that is clear about the adequacy of the information provided. Where there are gaps, we will be clear about what additional information is required.
- Based on sound science and the best available evidence. We rely on our objective expertise and scientific knowledge when formulating our advice. Where appropriate, we should be able to explain our reasoning and describe the process used to develop advice, including levels of confidence and the assumptions associated with any interpretation of the data or evidence.
- Proportionate to the risk of a plan, development or activity. We want to ensure that our advice is proportionate, and recognise that delivery of a proportionate approach in the context of the high degree of uncertainty in the marine environment will be a significant and challenging area of work.
A proportionate approach
We face several challenges in applying a proportionate approach in the Welsh marine area when carrying out or advising on impact assessments, or identifying opportunities for restoration or enhancement. Some are longstanding, such as the high level of uncertainty in the marine environment in terms of distribution of key receptors. Others are more recent – balancing new requirements and duties, such as those introduced by the Environment (Wales) Act (2016) and the Wellbeing of Future Generations Act (2015), with our existing environmental legislation.
Although some of these challenges were being partially addressed in existing projects or workstreams, we felt that there would be considerable benefits in taking a fresh look at some of these problems and integrating the work under a new theme of 'embedding a proportionate approach' with clear objectives and guiding principles.
Proportionality can be tricky to discuss. Telling people that you want to 'embed a proportionate approach' in their area of expertise could be interpreted as a criticism or an implication that their advice is currently disproportionate. It was therefore vital that the guiding principles for this approach were developed collaboratively with our marine colleagues and that this was as much about articulating the good work we are already doing as about potential changes or improvements to our approach.
Having Fothergill, Howard and marine expert Paul Salmon help us organise and facilitate our initial staff workshop was crucial to getting buy-in from our colleagues. In the workshop we established the broad outline of our principles and what we wanted to achieve with them. We were also able to set the wider context by talking through the Proportionate EIA Strategy.
A recommendations report then helped hone our thinking as we agreed the final principles. We now use the principles when formulating our advice and guidance, and as we continue working to identify opportunities to improve management of marine resources under the new planning framework.
Positive response
The progress we have made during the past 12 months was noted by Wales's Minister for Environment, Energy and Rural Affairs, Lesley Griffiths: “NRW has a pivotal role in supporting the transition to renewable energy. I want to see NRW build on this work to develop a positive approach to both enabling and delivering renewable energy development, on and offshore, in line with the Welsh government planning frameworks, including the marine plan [...] NRW has already made progress in developing proportionate consenting of energy applications.“
Dr Lucie Skates is lead specialist advisor on marine plan implementation at Natural Resource Wales.
