A positive transition

Lucie Skates looks at implementing a proportionate approach to the future of marine advice in Wales 

The Welsh National Marine Plan (WNMP) 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 to deliver sustainable outcomes in a consistent and efficient way that minimises burdens. 

As a principal advisor on the environment, Natural Resources Wales (NRW) has been working closely with the Welsh government to provide evidence supporting the development of the WNMP. Now the plan has been adopted, we have a key role in implementing the policies through our regulatory, evidence and advisory work. NRW is improving its ways of working within a new organisational structure, identifying opportunities to improve the management of marine resources under the WNMP planning framework.

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.


We face several challenges in applying a proportionate approach when carrying out or advising on impact assessments, or identifying opportunities for restoration or enhancement. Some are longstanding, for instance the high level of uncertainty in the marine environment in terms of distribution of key receptors. Others are more recent – for example balancing new requirements and duties, such as those introduced by the Environment (Wales) Act (2016) and the Wellbeing of Future Generations Act (2015), with existing legislation. 

Although some of these challenges were being partially addressed in existing projects or workstreams, we felt there would be considerable benefits in taking a fresh look at some of the 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 seen as implying their advice is disproportionate. It was vital that the principles were developed collaboratively with marine colleagues and that this was as much about articulating the good work we are already doing, along with any 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 colleagues. We outlined our principles and what we wanted to achieve with them, and were also able to set the wider context by talking through the proportionate EIA strategy.

A recommendations report helped hone our thinking, the final principles were agreed, and we use them when formulating advice and guidance, and as we work to identify opportunities to improve management of marine resources under the planning framework. 

The progress we have made during the past 12 months was noted by the Minister for Environment, Energy and Rural Affairs, Lesley Griffiths, who said: “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.” 

Dr Lucie Skates is Natural Resource Wales lead specialist advisor on marine plan implementation.

For the extended version of this article with references, go to bit.ly/2YIyjzY


Picture Credit | iStock
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