What is the Clyde Regional Marine Plan?

The draft Clyde Regional Marine Plan (CRMP) has been prepared by the Clyde Marine Planning Partnership (CMPP) in accordance with The Delegation of Functions (Regional Marine Plan for the Scottish Marine Region for the Clyde) Direction 2017[1] on behalf of the Scottish Government. The CRMP will be the first of its kind in the Clyde Marine Region (the Region), and one of the first in Scotland. Once adopted by Scottish Ministers, the CRMP will become a statutory document. The CRMP must be in accordance with the Marine (Scotland) Act 2010[2], The UK Marine Policy Statement 2011[3], and Scotland’s National Marine Plan 2015[4]. Steps have been taken to ensure that the draft CRMP is compatible with the National Planning Framework 4[5] and the Local Development Plans for the Clyde Region.

Role of the Marine Directorate

The draft CRMP has to be approved by Marine Directorate (MD) in its entirety at each stage of development. There is a small staff team at MD that works on regional marine planning. The draft CRMP is a complex document that requires scrutinisation by the team and by other policy and legal colleagues at MD. Additionally, over the course of the development of the CRMP, regional marine plans (RMPs) were being developed by the Orkney Islands and the Shetland Islands. MD had to work on providing feedback for those draft plans alongside the draft CRMP. This has also contributed to the length of time it has taken for iterations of the draft CRMP to be returned to CMPP.

Role of the Clyde Marine Planning Partnership

The CMPP is made up of approximately 25 members. Every member is on the partnership as they have a stake in how the Region is managed, and for their knowledge and expertise that contributes to the drafting of the CRMP. All members have given significant time and efforts to the creation of the CRMP. When MD review the CRMP and return it to the CMPP with feedback, all the members have the opportunity to review the feedback, make comments/suggestions, and review any proposed new text written by the CMPP staff. This can be a lengthy process, meaning it has taken several months for the CMPP to make amendments to different iterations of the draft CRMP and return it to MD for checking. Partnership working has been a critical component in developing the CRMP, however members have had to accept a high level of compromise with regards to the text of the Plan in order to progress development.

Development of the Clyde Regional Marine Plan

The first draft of the CRMP was produced in September 2018. A range of workshops and meetings with members of the CMPP, a public dialogue and a 12-week pre-consultation took place between 2018 and 2020. All of the findings from the workshops and events contributed to an updated draft of the CRMP that was submitted to MD for comment in July 2020. Since then, there have been multiple iterations of the draft CRMP that have been submitted to MD, and returned with comments, as can be seen in the ‘Version Control’ table on p2 on the CRMP Consultation Draft.

The Covid-19 Pandemic had a role in the delay of MD returning the draft CRMP to CMPP. CMPP submitted it to MD in June 2020 and received it back in May 2021. However, this was the first time the draft CRMP had been submitted in full and there was significant feedback to be considered by the members. Feedback was separated by chapters/policy area. Broader comments that applied across the whole document included addressing proportionality, space competition and operationalisation, and minor comments such as name changes or reference updates. The draft CRMP was sent back to MD in December 2021 with all comments addressed.  

There were a few more versions of the draft CRMP produced over the course of 2022 and 2023, with necessary amendments being made following feedback from MD and comments from CMPP members. MD submitted advice to the Cabinet Secretary regarding regional marine planning following a gateway review of the 3 draft regional marine plans (Clyde, Orkney Islands, and Shetland Islands) and CMPP staff were notified of this in July 2023. The results of the gateway review were received in November 2023. The feedback received was from the legal department at MD. The main critique was that certain policies were creating obligations that went beyond the remit of regional marine planning. Other feedback was received on issues such as the role of consenting authorities and ensuring the CRMP does not overstep, lack of clarity of certain policies and objectives, and the application of policies. Given the number of changes required for the draft CRMP and considerations around the development of NMP2, MD provided CMPP with two options for how to progress with the progress of regional marine planning within the Region. Option 1 was to pause development of the draft CRMP until the NMP2 is adopted, or to undertake a review and refresh of the current draft to incorporate the feedback received. The CMPP had a full discussion about the feedback at the Members Meeting in the December. Members were concerned that MD were requesting significant text amendments several years into drafting that hadn’t been raised before. It was also raised that the feedback was suggesting amendments that would significantly change the policy text and members stressed that CMPP needed to consider the role of the decision makers when amending language. Members agreed that they needed more information before deciding about how to progress. MD offered to host a meeting with members to discuss the feedback and answer questions. CMPP accepted this offer. This meeting took place in January 2024. A further CMPP meeting took place in February 2024. It was decided to continue with plan development and to amend policy text first before making any other changes to the rest of the CRMP; this was to be carried out alongside regular meetings with MD staff before making the next iteration of corrections. Unfortunately, due to staffing pressures at MD and prioritising the Orkney Islands and the Shetland Islands RMPs, the stepwise approach to plan corrections could not be carried out within a reasonable time frame. However, MD staff were able to respond to the policy text amendments in August 2024, with broad approval and the proviso that amendments would have to be checked by the legal department. A fully revised plan incorporating all the corrections was submitted to MD in November 2024.

In 2025, 2 more versions of the draft CRMP were produced, following feedback from MD and discussion with CMPP members. The feedback received required some further amendments to existing policies, and other minor changes to items including diagrams, formatting, and definitions. Learnings from the Orkney Islands RMP and Shetland Islands RMP also helped inform feedback from MD on the draft CRMP, as both draft plans were close to adoption. In 2026, CMPP produced a further draft of the Plan and submitted to MD for checking in May. Some further amendments were required until the final draft version was approved for statutory consultation in October 2026.

Policy Text in the Clyde Regional Marine Plan

The purpose of the policies is to guide, including but not limited to, developers, public authorities, decision makers, consenting authorities, and regulators to make decisions on sustainable development and/or use within, or that affect, the Region. There have been several iterations of the policy text, and policy colleagues at MD have worked with the CMPP staff and members to produce the current text. Significant changes were made to the policies in 2024 after receiving instruction from MD on where amendments were necessary according to legal feedback. The CMPP accepted that the wording must be in accordance with NMP and other relevant legislation, but have done what it can to retain ambitious policy language. Currently the text must be in line with the existing NMP, however NMP2 is currently being developed. Once NMP2 is adopted, the CMPP will be able to revise the CRMP and can work to strengthen policy language where possible.

Recommendation Text in the Clyde Regional Marine Plan

Recommendations for marine users/local management are included throughout the Plan to inform the general management of all activities within the Region, including those which are not managed through planning or licensing, such as marine and coastal sport, recreation and tourism. They provide considerations and best practice information relating to the chapter and will also support delivery of the objectives. Implementation of these recommendations by marine users at the local level has a significant role in driving protection and enhancement of the marine and coastal environment and ensuring sustainable activities take place. The recommendations are not enforceable and will not be subject to monitoring and reporting obligations under the Marine (Scotland) Act 2010.

Action Plan

An Action Plan has been developed alongside the draft CRMP to inform and prioritise future work of the CMPP that is in line with the CRMP’s objectives. Post adoption of the draft Plan, the CMPP will work to update the draft Action Plan, providing another avenue for CMPP to undertake work that will ensure sustainable management and use of the Region. Delivery of the Action Plan will serve to provide further guidance on Plan policy topics, support ongoing adaptive management of marine-related issues, inform future iterations of the Plan and support implementation of the Plan. The draft document can be found on the CMPP’s website.

[1] The Delegation of Functions (Regional Marine Plan for the Scottish Marine Region for the Clyde) Direction 2017 (http://bit.ly/4o1DV2n)

[2] Marine (Scotland) Act 2010 (https://bit.ly/47cDj44)

[3] UK Marine Policy Statement 2010 (https://bit.ly/36gcr0V).

[4] Scotland’s National Marine Plan 2015 (https://bit.ly/3aAoTvN).

[5] National Planning Framework 4 (https://bit.ly/3NalPhT)