ESS response to UK Marine Strategy Consultation

 
 

20 August 2025

ESS: UK Marine Strategy assessment and consultation lack the rigour and transparency necessary to enable independent evaluation of the state of the UK seas

 

Environmental Standards Scotland (ESS) has responded to the UK Marine Strategy (UKMS) Part One Update 2025 consultation that sought views on the UK’s updated assessment of progress towards Good Environmental Status (GES) for UK seas.

 

In their current form, ESS has concluded that the assessment and consultation process lack the rigour and transparency necessary to enable independent assessment of the state of UK seas, and to evaluate whether genuine progress towards GES is being made.

The Marine Strategy Regulations 2010 set out specific duties on UK Government and Devolved Administrations in relation to reviewing and updating the Part One assessment. Consequently, ESS has written to the Scottish Cabinet Secretary for Climate Action and Energy, to put on record its concerns about the assessment and consultation. These concerns include:

 

  • a lack of explanation and identification of the different assessment methodology and presentation of results between the current and previous assessments

 

  • a lack of clarity in how sub-assessments are aggregated to determine whether GES has been met at the UKMS subregion level

 

  • poor justification for changes to the assessment methodology and presentation of results that appear to state incorrectly that the approach aligns with the EU in relation to threshold values for GES

 

  • delays to publishing some ‘detailed assessments’ underpinning the assessment of GES, meaning that they were not available for close to 50% of the consultation period

The letter sets out what steps must now be taken, in ESS’ view, to facilitate effective scrutiny of whether the assessment provides an accurate reflection of the state of UK seas and whether there has been progress made towards achieving GES. These steps include the publication of all underlying data and methodology associated with the assessment and a detailed explanation of why the reporting methodology has changed.

Mark Roberts, CEO of ESS said: “The assessment comes at a critical time for Scotland’s seas. It coincides with proposals for statutory nature targets under the Natural Environment (Scotland) Bill and the backdrop of continuing pressures from human activity and climate change. However, in its current form, the published assessment and the associated consultation fall significantly short of the standards that we expect from public authorities.

 

“Our response to the consultation outlines key actions that we hope will now be taken to allow thorough scrutiny of whether Part One of the assessment accurately represents the condition of UK seas.”

 

The Office of Environmental Protection (OEP) that covers England and Northern Ireland, has also responded to the consultation and shares ESS’ concerns.

Helen Venn, Chief Regulatory Officer for the OEP, said: “In our response to the consultation we have identified shortcomings in the updated Part One that, in our view, should not be a feature of an assessment of such importance. We consider these can and should be rectified, so the final assessment can drive the management of UK seas to deliver commitments for environmental protection.”

 

ENDS

 

Notes to editors:

 

You can read ESS’ letter to the Scottish Cabinet Secretary for Climate Action and Energy, and consultation response, here.

 

You can read OEP’s response to the consultation here.

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