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Draft Plan for Offshore Wind Energy in Scottish Territorial Waters: Analysis of Consultation Responses

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2. COMMENTS ON THE SELECTION OF OPTIONS 1

Overview

2.1 This section of the report focuses on the first three questions included in the offshore wind Draft Plan for consultees. These questions aim to explore the information and process that was used to identify the options for development, which were subsequently environmentally assessed and used to form the basis of the Draft Plan where appropriate. The responses to each of the questions are explored in turn.

Question 1: Does the mapping of exclusion zones, environmental issues, and technical issues provide a reasonable basis for modelling the options?

2.2 The development of the Draft Plan was informed by detailed consideration of a range of options for development. The options were identified using The Crown Estate's Marine Resource System ( MaRS), a tool for layering environmental and technical information which was used to ascertain where development may or may not be sustainable as a result of the baseline conditions. Question 1 invited views on whether the mapping used to identify the options for the SEA was considered to be reasonable. 60 consultees responded to this question, including the following organisations. The graph below sets out the overall distribution of views:

Aberdeen City Council
Argyll and Bute Council
Argyll Renewables Communities
Chamber of Shipping
Civil Aviation Authority
Comhairle nan Eilean Siar
Dumfries and Galloway Council
Fife Council
Galloway and Upper Nithsdale Liberal Democrats Constituency Party
Galloway Static Gear Fisherman's Association
Highlands and Islands Enterprise
Historic Scotland
Institute of Ecology and Environmental Management
Maritime and Coastguard Agency
Ministerie van Verkeer en Waterstaat
Moray Firth Partnership
National Federation of Fishermen's Organisations
NATS En-Route Ltd ( NERL)
North Berwick Environmental Trust
Royal Yachting Association Scotland
Scottish Boating Alliance
Scottish Natural Heritage
Scottish Renewables / Renewable UK
ScottishPower Renewables
Seaenergy Renewables Limited
Small Isles and Mull Inshore Fisheries Group
SSE Renewables
The Highland Council
The Village at Machrihanish Dunes/ KDCL
Tiree Community Development Trust
VisitScotland
West of Four Fisheries Management Group
Whale and Dolphin Conservation Society

Figure 3

Figure 3

First Step in the Process

2.3 The majority of respondents to this question viewed the MaRS mapping as a reasonable starting point for identifying the options. 27 respondents provided a positive response, of whom 19 provided additional comments. There was a general consensus amongst those who commented that the options should be considered a first step, acknowledging that more work is needed before sites can be designated for development.

2.4 The Royal Yachting Association Scotland ( RYAS) felt that the mapping was a good way of identifying options, providing that the data limitations and sensitivity weightings were borne in mind. RYAS also felt that the datasets used had improved significantly as a result of consultation with stakeholders during the pre-consultation workshop process.

2.5 The Highland Council felt that the mapping provided a reasonable indication of where development could come forward and where onshore development may be required. Aberdeen City Council was generally supportive of the approach, although it was acknowledged that options could change given data gaps and uncertainties at this stage, and the need to explore scope for mitigation of impacts.

2.6 Comhairle nan Eilean Siar (Western Isles Council) was also broadly supportive of the approach to layering static zones and constraints, noting that MaRS had been well used by Marine Scotland in regional locational guidance. However, it also acknowledged that this could be difficult for industries including fishing and the mobile and static gear sectors and that a finer grain of analysis was required to better reflect interests. It suggested further work with the industry to map existing activity, assess impacts and identify mitigation. The Institute of Ecology and Environmental Management ( IEEM) and VisitScotland also considered it to provide a good basis upon which more detailed assessment could be based.

Limitations of MaRS

2.7 At least 23 consultees felt that approach was not robust, primarily due to concerns about the basis of the data used. The Moray Firth Partnership agreed this approach was reasonable at a strategic level, but noted that further consideration of cumulative impacts was required to provide a fuller picture. A similar view was provided by the Argyll Renewables Communities, which emphasised the need for further consideration of impacts on communities: an issue which is not readily mapped.

2.8 Although Scottish Natural Heritage ( SNH) was involved in discussions on the use of MaRS within this process and did not object to its use or the methodology applied, it nevertheless expressed concerns about the use of MaRS, particularly arising from the assumptions adopted and the use of environmental data. Data sources and weightings were questioned, and it was suggested that greater recognition be given to the limitations of this tool, including data gaps and the consequent reliance on expert judgement to the outputs. SNH emphasised that MaRS is a decision support tool, not a decision-making tool, and therefore viewed it as an aid to identifying constraints that then require further evaluation in association with statutory consultees. In the meantime, SNH recommended restraint particularly in the north and north west until further constraints mapping has been undertaken and the Habitats Regulations Appraisal ( HRA) concluded. Further, more specific advice was offered on MaRS, and has subsequently been discussed with SNH.

2.9 Scottish Environment LINK was concerned that MaRS has a 'commercial bias' and suggested that it could only be useful for mapping protected sites. Shortcomings in terms of mapping areas of environmental sensitivity for species and habitats for which designated sites do not exist were emphasised. Exclusion of Nature Conservation Marine Protected Areas ( MPAs) that will be designated in the future was a particular concern. LINK suggested that the only additional (non- MaRS) data considered within the planning process related to fishing and shipping activity.

2.10 Similarly, Dumfries and Galloway Council had serious concerns about the mapping, based on the absence of information on salmon, vessel movements and socio-economic issues. Argyll and Bute Council found it difficult to interpret the maps provided, and were concerned that the technical constraints were not more fully described in the document. They also felt that the analysis was undermined by a lack of information on onshore developments and transmission networks.

2.11 Similar views were raised by individuals who suspected that the information may be 'faulty' or incomplete. Examples were noted where specific options had been included in the Draft Plan despite their perceived environmental shortcomings: notably the Argyll Array and Kintyre. Some felt that this illustrated the shortcomings of the option selection process. However, it should be noted that the MaRS modelling used to identify medium term sites was not used to outline the 10 short term sites.

Further information to inform the options

2.12 Numerous detailed suggestions for different datasets and weightings were made, and these are discussed in more detail in relation to Question 2.

2.13 Several consultees, including SEPA and Scottish Environment LINK, suggested that the approach would be more robust if it had been linked with marine planning, and / or if it better reflected other considerations including the grid and wave and tidal developments.

2.14 A more integrated view was supported by other consultees who provided considerable detail on the additional information that should be used to inform the identification of options for the Plan. For example, the Moray Firth Inshore Fisheries Group were concerned that marine energy outside of territorial waters had not been included, as well as wave and tidal development potential and test locations, cabling, navigation corridors, existing infrastructure and current marine energy suppliers, and areas that may become available as a result of technological or production advances. The group also recommended that no assumptions should be made about exclusions from wind farms or cable runs and that more mapped information should be gathered to inform the assessment findings on fishing. This view on assumptions was supported by The Crown Estate.

2.15 The Sea Mammal Research Unit ( SMRU) expressed concerns about the data used in the options mapping, and in particular that marine mammal and bird data had been confined to distribution of interests on land and designated sites and their marine extensions. As a result it suggested that coverage of highly mobile species was poor, even although data exist for this and could be deployed. Further detailed advice on how this could be remedied was provided, including for the HRA to take into account. The Whale and Dolphin Conservation Society stated that The Crown Estate considered MaRS to be inappropriate for recording species with no spatial protection such as cetaceans. The lack of designated sites for bottlenose dolphins was raised to illustrate this.

2.16 Others were concerned that environmental matters were too heavily weighted within the mapping, at the expense of issues which could be less easily mapped including social and cultural characteristics.

Transparency

2.17 Several responses focused on the accessibility of information on data used for the mapping and the presentation of mapping outputs. SLP Energy sought reassurance that the mapping has been fair, and that areas have not been viewed as more constrained simply because more information is available on its environmental character.

2.18 The Maritime and Coastguard Agency ( MCA) requested that mapped information be provided in a format that would allow it to be linked to nautical charts and publications, and other designations, thereby allowing for a more accurate assessment of maritime risk. Similarly, the National Federation of Fishermen's Organisations ( NFFO) asked for more detailed boundaries to allow for a fuller response. The limitations of the fishing data (from COWRIE) used in the mapping was noted. The NFFO was also surprised that fishing was given a lower weighting than other activities, and strongly argued with this decision.

2.19 A more transparent approach with explicit acknowledgement of data gaps was called for to address this issue. Terminology was also discussed, for example, SeaEnergy Renewables suggested that the terms 'environmental' and 'technical' could be clarified, and that 'biological' and 'human environment' would be more consistent with EIA, thereby assisting developers. Some consultees, including Scottish Renewables, asked for more explanation of the weightings used within the analysis.

2.20 The Highland Council sought further explanation of exclusion areas. It noted that whilst some significant constraints may not merit exclusion status, in practical terms they could preclude some developments. It recommended that areas should only be excluded on the basis of robust evidence, and that if there was any doubt, areas should be included in the Plan, with constraints clearly indicated. This could then steer further data collection. In a similar vein, other individuals and organisations questioned why features such as pipelines and cables were exclusions, but environmental issues had been treated as more flexible.

2.21 A broader point was raised about consistency by several consultees and in particular the fact that the analysis using MaRS only applied to the selection of medium term options, and that the criteria used for short term options had not been made explicit. Scottish Environment LINK for example felt that it would be useful to understand the decision making process that had led to these areas being recommended. SNH viewed this as a regrettable situation.

Concern about local level analysis

2.22 Industry representatives, including the Forth and Tay and Solway Firth Wind Developers Group, SSE Renewables and Future Electric were concerned about trying to achieve too high a degree of certainty at this scale, suggesting the approach should be more strategic and less site specific. Partly, this was based on a view that it would be inappropriate to rule out areas that had not been included as options at this stage. Supporting industry views, both the Highland Council and Highlands and Islands Enterprise felt that the mapping was reasonable at a basic level, but suggested that areas should not be excluded at this stage without further investigation and additional information.

2.23 Several consultees suggested that it would be more useful to link or express the mapping of options in terms of generating capacity. Scottish Power Renewables ( SPR) felt that the approach taken was only feasible for the short term, and that further industry input on technical constraints would be required to better define longer term constraints. SPR was concerned about undue application of the precautionary approach when identifying options in the meantime.

2.24 Scottish Renewables discussed this further. Whilst the approach was considered to be reasonable at a simple level, it was suggested that it would be more appropriate for it to signpost suitable areas and avoid marking others as unsuitable. They suggested that developers would naturally avoid sensitive areas, and that the study should provide only general direction as to the spatial composition of development areas.

2.25 This contrasted with the views of some individuals who were concerned about 'adopting' sites on the basis of broad or partial information at the national level. Some people felt that the only option considered for the Plan was to progress development, and that this was not supported by the evidence provided.

Question 2. Do you have any further technical or environmental information you think we should take into account as we refine the Draft Plan?

2.26 A range of consultees provided further information in response to this question. This included industry representatives, environmental organisations and local authorities.

2.27 Some consultees commented on the availability and accessibility of information that had been referred to in the Draft Plan or its SEA. Building on responses to Question 1, this included advice on the use and presentation of mapped data. Some were concerned about too many layers or imprecise boundaries, and also focused on the weightings ascribed to different layers. These are discussed in more detail below.

Further technical and environmental information suggested by consultees

2.28 Virtually all of those who responded to this question suggested further information. This was wide ranging, and included the following:

1. Further reference to onshore development, including grid connections and support facilities.

2.29 The Highland Council and Fife Council recommended that clearer links are drawn with the National Renewables Infrastructure Plan ( N-RIP), and the former referred to relevant regional work set out in the Highland Renewable Energy Strategy ( HRES). It was noted that the options for development within the Draft Plan varied from those identified in HRES, and therefore suggested that it may be useful to check why this has arisen as a means of cross referencing the options in the Draft Plan and testing the evidence base.

2.30 Others focused on grid connections and capacity, and felt that a fuller picture would only emerge if these issues were taken into account more fully in the identification of options.

2.31 Argyll and Bute Council felt that the Draft Plan missed an opportunity to consider onshore infrastructure requirements, such as ports, harbours, workforce housing requirements, electricity convertor stations and other buildings and infrastructure. It was pointed out that without this information it was difficult to fully define cumulative effects of developments, particularly for option areas located close to shore.

2.32 SNH considered that the failure to address cabling connection activities within the Plan was a major omission, and recommended that the impact of this aspect was given further consideration. It also recommended further consideration of onshore activities associated with offshore construction, but acknowledged a need for further thinking on how this could be achieved.

2. Further information on other aspirations for energy generation.

2.33 Some consultees felt that the options mapping should take into account test and demonstration sites, with one asking for clarification of the levels of generation that classified sites as such. Several also asked for fuller analysis of wind speeds in relation to the options.

2.34 References were also made to links with aspirations for wave and tidal energy generation, particularly by those that viewed this as a reasonable alternative to offshore wind energy development generally. For example, Keep Wigtown Bay Natural felt that there should be further consideration of tidal opportunities in the Solway as a broader alternative to the Plan.

2.35 Comhairle nan Eilean Siar suggested that information gathered for the Saltire Prize Regional Location guidance would be helpful. SSE Renewables asked for reference to be made to the UK wide plan for future leasing of offshore wind and oil and gas, and gas storage, cables for exporting energy, Round 3 sites and landfall connections for the zones around the Firth of Forth and Moray Firth.

2.36 Several consultees suggested that a more generalised approach to identifying options would be preferable, for example defining the energy generation capacity of regions instead of going as far as identifying spatial options. Some felt that the options and therefore the Plan would benefit from further exploration of the carbon footprint of manufacture, erection and operation of wind farms, to provide a fuller picture of the net benefits of development. Specific questions were asked about whether information on the output levels and timing of Robin Rigg might provide a more accurate view of the generating capacity of offshore wind.

3. Further socio-economic information.

2.37 A range of additional socio-economic information was raised by consultees, who recommended that it is incorporated into the selection or analysis of options. Some of this information related to specific regions and developments. For example, the Tiree Community Development Trust referred to socio-economic impact assessment work planned for the three short term sites in Argyll and noted that further baseline surveys were required to better reflect the characteristics of west coast communities that could be affected by proposals within the Plan. Several consultees felt that the vulnerability or fragility of communities cannot be mapped and does not therefore feature within MaRS, but was nevertheless an issue that should be considered within the options appraisal.

2.38 Several organisations suggested a need for further information on recreation. Data on surfing, coastal access areas and paths and sea angling were all raised. Several consultees commented that there is a need for more mapped information on tourism to be built into the options.

4. Further information on fishing

2.39 The fishing sector as a whole was concerned about the data used in the MaRS options analysis, and the weightings applied to it.

2.40 The SFF noted that it was willing to share information of fishing at a finer grain than had been used in the assessment, if it would lead to a review of the short term options within the Plan. The NFFO felt that the Plan is likely to have been misinformed as a result of the deficiencies of the fishing data used. It supported further assessments and requested further involvement. They suggested that the Cumbria Sea Fisheries Committee and Irish Sea Marine Conservation Project may be able to provide further information on fishing activity.

2.41 The West of Four Fisheries Management Group ( WOFFMG) sought more information on commercial fishing, and for it to be given highest priority. The Small Isles and Mull Inshore Fisheries Group found it difficult to comment as they were unclear about the data that had been used to evaluate the impact of the plan on commercial fishing. However, the distribution of the options proposed suggested a lack of fishing data, and the group was concerned that fishing had not been treated as a material asset within MaRS. Consideration of gross value of landings was considered to be too broad and weighted in favour of larger vessels with higher gross revenue, at the expense of smaller vessels that more directly support rural communities. They agreed with the SFF that a finer resolution of data was required, and that the weighting valuing recreation over fishing was wrong.

2.42 The Scottish Sea Angling Conservation Network was concerned that they had not previously been involved in the research, and noted that many of the options were close to sensitive areas. Detailed supplementary information was provided in its response.

2.43 The Dutch Government suggested that the assessment could be more specific about cabling requirements and its environmental effects. They reported having further information on cumulative effects, and the effects of construction on fish larvae and the wider food chain.

2.44 Other consultees noted the need to consider aquaculture licenses to gain a more complete picture of commercial activities.

5. Further information on shipping and navigation.

2.45 Some consultees referred to national level information on shipping, whilst others provided specific information about their region.

2.46 The Maritime and Coastguard Agency ( MCA) suggested that the guidance on Offshore Renewable Energy Installations and wider maritime and MPA information needs to be brought together to provide a fuller assessment of the options.

2.47 Dumfries and Galloway Council provided further information on shipping in order to demonstrate why, in their view, Wigtown Bay should be removed from the Plan.

6. Aviation information

2.48 The Civil Aviation Authority provided further detailed information on aviation issues, covering terminology, distances and buffer zones. It was noted that these issues will be addressed at the project level, but also suggested that further consideration could be given to the cumulative impacts of options on aviation at the plan level, including accumulation with onshore wind turbines. Further information on the relationship between options in the south west and their interaction with aviation to and from the Isle of Man and Northern Ireland was requested.

2.49 Reliance on British Wind Energy Association ( BWEA) data within the assessment was criticised by air industry representatives and suggestions were made on additional information, including North Sea helicopter routes and longer distance flight paths

7. Other technical issues

2.50 The MoD provided specific information on their activities and potential for interference with air traffic and air defence radar systems. It was noted that Practise and Exercise Areas ( PEXA) had been shown as a technical issue within the analysis, and confirmed that there may be some scope to accommodate development in these areas, depending on case by case circumstances. The approach of using buffer zones around radar facilities was not supported, as the MoD uses actual radar coverage data and line of site assessments to provide a clearer picture of potential impacts. It was noted that the assessment does not cover precision approach radar systems at military aerodromes, Ministry air traffic control facilities which are not located at aerodromes and air defence and meteorological radar sites.

2.51 Localised hazards were also noted, included the need to identify the risk of live ammunition shells next to Dundrennan MoD range.

8. More detailed environmental information.

2.52 Many of the respondents focused on additional, or more detailed environmental information that could be built into the assessment of options.

2.53 This included further bathymetric information and bird data, including the location of gannet colonies, breeding grounds and fishing grounds. E. ON suggested including further information on the disturbance of marine mammals, seal breeding colonies, foraging seabirds and their habitats, barriers and disturbance to migrating mammals, fish and birds, spawning and nursery grounds of Biodiversity Action Plan ( BAP) species.

2.54 Several consultees also noted the importance of taking into account impacts on proposed Marine Protected Areas, including Environment LINK (see below).

2.55 The need for a Habitats Regulations Appraisal ( HRA) was raised by some consultees at this stage, including Scottish Natural Heritage ( SNH). Advice included the need to consider possible Special Protection Areas ( SPAs) within the assessment, as well as those which are more formally proposed. SNH also suggested that further consideration be given to mobile species (birds and marine mammals), and that this is explored as an integral part of the HRA. It was noted that SNH is currently compiling a list of Priority Marine Features ( PMFs) for inshore waters, whilst the Joint Nature Conservancy Council ( JNCC) is compiling a list for offshore areas (beyond 12nm), and that these should be considered further when they become available.

2.56 Some specialist respondents focused on bats. It was noted that they are at risk of turbine strike, and that Swedish studies have demonstrated that bat activity can extend 10km offshore. As a result, further survey work was suggested to provide a more accurate estimation of mortality. It was also noted that this is most pertinent to the South West Region where the most at risk of the Scottish bat populations exist - noctules, Leisler's bat, soprano and common pipistrelle.

2.57 A good number of consultees asked for further information on marine mammals to be built into the process. Suggestions included referring to SNH's 2009 information on basking shark hotspots, and providing further data on cetaceans generally, and specifically in the Solway Firth. The Whale and Dolphin Conservation Society noted the urgent need for research to fill data gaps and provided a full list of additional references. The importance of satisfying the Habitats Directive requirements was noted, and particular concerns about pile driving were raised.

2.58 Landscape information was also raised by several consultees, with consultees suggesting that the assessment would benefit from more up to date landscape / seascape and visual impact methods. Some consultees suggested the use of further information including non-designated landscape, key views, sensitive areas close to shore, scenery that has important links with local tourism, and the setting of the coastal historic environment. Further regional level landscape character information was provided by some consultees, for example additional evidence from Dumfries and Galloway council of particular relevance to the Wigtown Bay proposal.

2.59 The Scottish Campaign for National Parks and some others suggested making use of SNH information that was used to inform the establishment of a coastal and marine national park in 2006.

2.60 With regard to cultural heritage, Historic Scotland noted that there are gaps in knowledge of submerged archaeology, and noted the approach had referred to zoned areas where there is a possibility of submerged prehistoric landscapes. This data was considered to be very coarse, requiring further refinement to assess significant effects, and it was noted that in England and Wales this work is being undertaken regionally, as opposed to leaving it to the project level. It was suggested that a co-ordinated programme in Scotland is required to address this, particularly around the Western and Northern Isles. The Northern Ireland Environment Agency ( NIEA) stated that account should also be taken of the Giants Causeway and Causeway Coast World Heritage Site in Northern Ireland.

2.61 Water quality was also raised as an issue that could be better reflected in the SEA through further baseline information, including the status of waters in relation the Water Framework Directive.

2.62 Scottish Environment LINK was concerned about data gaps at a strategic level, and sought adequate resources to fund the research required to match the proposed pace of development. This included research on wildlife baseline data, including monitoring of international studies and research. They proposed that SNH leads the preparation of GIS data on all known sensitive marine sites and features, drawing on knowledge held by environmental stakeholders. This should be made publicly available, updated as appropriate, and applied to decision making.

Broader comments

2.63 More generally, it was noted that environmental information is being gathered collaboratively at a regional level by developers assessing cumulative developments, under the terms of their agreement with the Crown Estate. Some consultees also suggested that trend information should be built into the baseline to ensure that it remains a relevant reference point for assessing the likely effects of medium and long term options.

2.64 Some consultees recognised that there may not be scope to integrate this information at a strategic level, but suggested that information should be flagged up at this stage for further consideration at the project level within Environmental Impact Assessment. This included numerous replies from prospective developers, who will have responsibility for gathering information at this level. The West Coast Offshore Wind Developer Group suggested that it may be possible to scope 'water' out of the assessment at the regional level, based on information gathered on the west coast. Others, such as fishing interests, disagreed with this view and stated that information needs to be gathered and evaluated at the plan level, to avoid taking forward unsustainable options. Scottish Renewables felt that the status of the options should be clarified to provide more certainty about the effect of classification

2.65 Some concerns were raised about the way information had been presented. For example, SeaEnergy Renewables were concerned that some specific leases (e.g. for wave at Portnahaven) had been named in the exclusion category, and suggested a more general reference to this to ensure that updates to agreements can be taken into account. Scottish Renewables felt that some of the mapping was unclear, and that the figures caused confusion by bringing together too many layers. Some also considered the presentation of information in Table 4.3. to be unclear.

2.66 Some consultees also asked how the data used in the study had been verified. Specific points were made about whether some datasets were up to date.

Question 3: Do you consider that the Draft Plan presents a practical set of options?

2.67 A total of 53 consultees responded to Question 3, including most of those who answered Question 1.

Options considered to be practical

2.68 Some consultees were content that the options were practical, including some organisations ( RYA Scotland, Scottish Boating Alliance, Tiree Community Development Trust, North Berwick Environmental Trust, Comhairle nan Eilean Siar and Fife Council) and several individuals. The Highland Council considered the options to be a good starting point, but noted that they should be updated to reflect further development of technology. Aberdeen City Council provided a similar view. Visitscotland were content with the options, providing that scenic value formed an equal part in their selection. Others felt that this question was difficult to answer, particularly in the light of their views on the breadth and depth of data used.

Options considered to be too detailed

2.69 Others suggested that the options were not appropriate for a national level plan. Instead they recommended consideration of higher level alternatives. This was particularly the view of industry respondents who were concerned that it was impractical and inappropriate to prejudge project level assessment at the national level. Scottish Renewables agreed that the nine remaining short term options should form the core of the Plan, and that other options would be needed in the future. However, it was felt that these would be better supported within a broader marine planning context and within future reviews of the Plan as a whole. Several consultees repeatedly referred to the importance of better links with marine spatial planning, within the context of the Marine (Scotland) Act.

2.70 Some suggested that focusing on what was perceived to be project level options was too limiting, calling into question the viability of development outwith these areas at a premature stage, and potentially stifling development of the sector. This included industry representatives and Comhairle nan Eilean Siar, who felt that the Plan should be more ambitious and take into account technological developments including demonstration projects that aim to unlock technology for wind in deeper waters.

2.71 Again, the issue of how the options collectively relate to national renewables targets was raised. People suggested that in the absence of MW based target, it was difficult to conclude whether or not the options presented were appropriate. Some questioned whether the options represented the maximum area that could feasibly be developed, or was based on a less comprehensive approach. Others felt that the Plan appeared to be aiming to fulfil an assumed target (50% generation) that was not underpinned by robust evidence.

2.72 Further consultees suggested that the options should be viewed alongside opportunities for other technologies including wave and tidal, as also noted in responses to Questions 1 and 2.

2.73 Comparisons were drawn with the UK wide offshore energy SEA, and it was suggested that the options could be explored at a more strategic level by comparing, for example, the effects of (1) not offering areas for leasing (2) proceeding with the leasing programme or (3) restricting areas offered for leasing temporally or spatially.

2.74 The RSPB also suggested an alternative approach, including exploration of the 'do nothing' option or consideration of the maximum level of development that could be achieved within the short and medium term areas. It was of the view that the SEA had only considered alternatives within the plan, and that further exploration of broader alternatives to the Plan as a whole would be useful. The RSPB also suggested that the thirty short and medium term options should be scored to allow for a fuller comparison of their performance.

2.75 Scottish Environment LINK felt that there had been inadequate consideration of alternatives in the SEA. They suggested that there is a requirement for SEA to explore the 'do nothing' alternative and for full explanation of how the assessment was undertaken and 'the reasons for not adopting the alternatives considered.' They, like the RSPB, were concerned that the SEA had focused on alternatives within the Plan, as opposed to alternatives to the Plan.

Information gaps

2.76 Some questioned the practicality of some or all of the options on the basis of a lack of robust information to underpin their assessment, as had been discussed in responses to Questions 1 and 2. This included the shipping and fishing sectors. The shipping sector suggested that without a fuller assessment of the interplay between STW developments, Round 3 and MPAs, it would not be possible to identify whether options were practical. Specific practical issues arising from medium term options in the Minches were raised to illustrate the difficulty the sector had in defining any of the options as feasible at this stage.

2.77 The SFF suggested that there had not be consideration of any option other than to progress development. Other fishing interests reinforced comments raised in response to Questions 1 and 2 by noting that the options could not be regarded as practical, unless they were informed by much more comprehensive data on commercial fishing, including activity by smaller vessels. The NFFO were clear that some of the options were impracticable from the commercial fishing perspective.

2.78 Logistics, including availability of port facilities, distance from option areas to the grid, cost of grid connections and potential for power loss over transmission distance to the end users were all raised. Comhairle nan Eilean Siar noted that the grid if often cited as a constraint to offshore wind energy and noted the expectation that a 900 MW interconnection between Lewis and the mainland will be in place soon. Some felt that the options were impractical as they did not reflect wind speeds, rendering some specific areas unjustifiable.

2.79 The need for the HRA to be undertaken to establish the suitability of the medium term options was also noted by some consultees.

Inappropriate options

2.80 Some respondents did not view specific options as practical because they included specific sites that they felt were inappropriate. This included several respondents focusing on their opposition to the short term sites at Wigtown Bay and Kintyre. Cumulative effects arising from groups of options, particularly in the West region were also raised to illustrate that the overall level of development proposed by the Plan was unlikely to be practical, given the need for a precautionary approach These are explored in the spatial and regional analysis provided in Section 3.

Practicality over sustainability?

2.81 Whilst some consultees considered the options as impractical, others felt that practicality appeared to have been prioritised over other considerations including their environmental and socio-economic impacts.

Conclusion

2.82 Several consultees gave considerable thought to the process of identifying options that form the basis of the Draft Plan. The diagram below maps the key issues identified in relation to Questions 1, 2 and 3. This shows that views ranged from comments on the role and status of the options, to practical suggestions on additional data sources.

Figure 4: Mapping of Key Issues Arising from Questions 1,2 and 3

Figure 4: Mapping of Key Issues Arising from Questions 1,2 and 3