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

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3. COMMENTS ON SPATIAL OPTIONS FOR DEVELOPMENT

Overview

3.1 This section of the report sets out the responses to Questions 4, 5 and 12 of the consultation. These questions focused on the spatial options for development within the draft Plan. Question 4 sought views on whether any options should be removed from the plan, and Question 5 explored whether there were any options that consultees felt should be added. Question 12 asked for views on possible regional prioritisation within the Plan.

3.2 These three questions generated a significant proportion of the total number of responses to the consultation. This is very useful, given that the draft Plan was developed with the specific aim of encouraging a much fuller exploration and discussion of the spatial options for offshore wind energy development in the short, medium and longer term.

3.3 Given the extent of the responses to these questions, the following section have been set out in relation to each of the regions within the draft Plan. Views for each region incorporate specific comments on the short term sites.

3.4 In addition to formal consultation responses, a series of regional events were held in a number of locations throughout the country, to ensure that local views were accurately gauged as part of the consultation process. The key points raised in each of the workshops have been brought together with the formal written responses to provide a more comprehensive evaluation of views in each area.

Question 4: Should any options be removed from the Draft Plan?

Overview of responses

3.5 In summary, many consultees gave a definitive answer to this question, highlighting a specific site that they felt should be removed. This included a particularly large number of comments on the proposals at Kintyre, Wigtown Bay, Solway Firth and, to a lesser extent in terms of numbers, the Argyll Array.

3.6 Comments on one or more of the regional medium term options were also made by many respondents, including suggestions to remove specific option areas in the West, South West, East and North.

3.7 The graph on the next page illustrates the broad distribution of responses between the regions included in the Plan:

Figure 5

Figure 5

3.8 Some consultees believed no options should be removed from the draft Plan. This included the Royal Yachting Association, Scottish Boating Alliance, Future Electric, SSER, The Highland Council, and Historic Scotland. Others reserved their views on this until a later stage. For example, the Argyll Renewables Communities felt that options should not be removed at this point, but that further information arising at a later date may indicate that they should. Similarly, the Highland Council suggested options might be removed at the plan review stage based on monitoring of the short term options. Others felt that, more generally, there is insufficient information available at this stage to comment on this.

3.9 Building on the responses to Questions 1, 2 and 3 discussed in the previous section, some consultees, specifically those from the industry but also several individuals and other organisations, said that whilst no options should be removed, the Scottish Government should consider how they are presented. In particular, industry consultees including Scottish Renewables suggested that regional level recommendations would be more appropriate than site specific options. They were concerned that the SEA may have prejudged the findings of project level EIA and proposed that site specific references should be removed throughout the plan and its assessment. As an alternative to the option based approach, it was suggested that the Plan should focus on the regional level and express capacity for development in terms of MW or GW. It was also suggested by several industry consultees that it is premature to identify medium term development options at this stage, calling instead for further consideration of higher level strategic options.

3.10 With regard to EIA, some consultees noted the limitations of the process, implying the difficulty of relying on this level of assessment to address issues. In particular, Scottish Environment LINK expressed concern about the quality of individual project EIAs, noting evaluation work that highlighted many inadequacies in a sample of projects. They felt it was imperative that EIAs are properly scrutinised, especially in the early stages of the development of the marine renewables industry. It also contended that as five of the ten short term sites had already proceeded to scoping, it was too late for the SEA process to influence these projects.

3.11 Some consultees suggested that key criteria for selection of the options should be established and used to define which areas should be retained or excluded. This included The Scottish Fishermen's Federation which considered there to be a need for more equitable weighting to be used in defining options. The Federation was also unconvinced that leaving mitigation to the project level would be effective as "by then it will be too late." This was supported by other consultees representing the fishing sector, who requested that the options be revisited on the basis of enhanced data on fishing activities and significance within the plan area.

3.12 A number of other consultees suggested that all options should be deferred until further information was available, including data and evidence provided in response to Question 2 of the consultation. Many called for more thorough analysis of existing offshore developments before granting additional consents.

3.13 Several respondents suggested that all options with lower wind speeds should be removed. Others were of the view that all options within 8km of the shore should be removed from the plan, as a result of their significant visual effects.

3.14 It was noted that Bell Rock should be removed from the plan given the site constraints arising from radar and the withdrawal of its prospective developer. It was also suggested by some consultees that the plan as a whole would benefit from further consideration of airport and radar installations.

Regional analysis

3.15 The following paragraphs set out views on specific regions referring, where relevant, to the short and medium term option areas within them.

North Region

3.16 Only ten of the responses to the consultation focused specifically on the North region, from the following organisations:

Aquatera
Chamber of Shipping
Historic Scotland
Ministry of Defence
Northern Lighthouse Board
Orkney Islands Council
Royal Society for the Protection of Birds
Scottish Environment Protection Agency
Shetland Islands Council
Sportscotland

3.17 The issues raised in this Region are summarised below:

Support for further development

3.18 Orkney Islands Council expressed disappointment that development around the islands appeared to have been discounted within the Draft Plan. The importance of the renewables industry to the Islands' economy was emphasised, including the aspiration to replace the benefits of North Sea Oil with those from greener forms of energy. It was noted that whilst marine energy is advancing in the area, offshore wind is regarded as an important part of the energy mix and should not be excluded. Small scale development across different technologies would together build a critical mass.

3.19 As a result, it was suggested that offshore wind in this location should not be ruled out in the short and medium term. The Plan should acknowledge the importance of the industry to Orkney and be sufficiently flexible to allow scope for limited development of near shore turbines to be considered further as part of the overall vision for renewables.

3.20 This view was further supported by a small number of other consultees, with one asking that communities with a large stake in renewables that appear to have been ruled out of the Draft Plan are not further alienated. Linking questions 4 and 5 of the consultation with this specific region, it was suggested that the SEA to date did not provide sufficient certainty to identify, or indeed to rule out, development areas.

3.21 Shetland Islands Council suggested that the Plan would benefit from further consideration of the Shetland Marine Spatial Plan. This provides further information on the marine environment. It was also recognised that much of the identified development options could be hindered by the limitations of current technology, given the significant water depths. As a result, the Council suggested that wave energy is preferable as water depth is not a constraint but a benefit.

Figure 6: Mapping of Views on North Region

Figure 6: Mapping of Views on North Region

3.22 Detailed comments on the environmental assessment were also provided by Shetland Islands Council.

  • It suggested that the 250m buffer zones around developments for marine mammals was too limited.
  • It was noted that two of the options are in areas identified as having wave energy potential. A question was therefore raised about whether 'zoning for wind' would preclude other developments, and it was suggested that the exclusivity process makes this unworkable.
  • As in other areas, Shetland Islands Council asked for further consideration of landward infrastructure to be undertaken to allow the full extent of development impacts to be understood.
  • The Council asked whether any Government support would be available for the marine renewable sector to undertake necessary environmental surveys to the required level for EIA.
  • Further work on fishing was requested, including possibility of permanent loss of fishing grounds and the need for further evidence on benefits such as the creation of artificial reefs.
  • Consideration of the overall carbon footprint and payback, given that the marine environment is a carbon sink and part of the carbon cycle.
  • The need to include horse mussel beds in table 5.4 of the Environmental Report, given their UKBAP priority habitat status.

3.23 Shetland Islands Council also noted that cultural heritage on the islands could be impacted by development. Further detail on this was provided by Historic Scotland which noted that project level assessment will be needed to focus on:

  • The impact of area N1 on Sule Skerry Lighthouse and the Heart of Neolithic Orkney World Heritage Site;
  • The impact of area N2 on the wider setting of the World Heritage Site and a number of other sites including the setting of castles, fortifications and churches of the north coast of the mainland;
  • Impacts of N4, N5, N6, N7 and N8 on the particular sensitivities of the Shetland coastline including numerous scheduled sites. Recognition of the impact of the sites on two designated wrecks was welcomed.

Consultation and governance

3.24 The Council commented on the consultation process and suggested that the consultation events in the region would have been more beneficial if they had taken place earlier in the consultation period. This was broadly supported by a small number of other consultees who questioned the effectiveness of the consultation and suggested it had a central focus. A public workshop was held in Lerwick on 11 August 2010, as part of the consultation process. Queries were raised about the purpose of the consultation and what the Scottish Government was seeking to achieve from it. It was felt that more specific proposals (location, technology, size, etc.) were needed before substantive comment can be made. It was also felt that a 2 year review of the SEA and the Plan might lead to consultation fatigue.

3.25 Governance issues were also raised and discussed at the Lerwick workshop. Clarification was sought on the roles of the Scottish Government, the Crown Estate, local government and developers and questions were raised about the relationships between development and authorities in Scottish Territorial Waters and UK Waters. There was some discussion about the detail of licences required to develop sites, roles of the Scottish Government and local government. The need to ensure terrestrial and marine plans are linked was also emphasised.

3.26 Workshop participants asked whether developers will sell all the power generated by developments to the grid or if some would be available for purchase by islanders. There was discussion on the proposed interconnector from Shetland to mainland Scotland in the Lerwick public workshop. This included questions on funding, timing and the route of potential connections, and scope for linking into a new European grid.

3.27 Questions were raised in the workshop about the assumptions that have been made in the SEA about the type of technology to be deployed. It was noted that Shetland's seas will require different turbine infrastructure due to wave heights, wind strength and very deep waters. There was some criticism of MaRS, focusing on its reliance on appropriate information. As in other regions, in Lerwick it was suggested that the Plan would benefit from being informed by overseas experience and research.

Environmental issues

3.28 With regard to visual impact, at the Lerwick event it was suggested computer simulations may be the best way to inform the public about potential visual impact. It was felt that the visual impact of offshore wind is significantly less than onshore developments, and that offshore proposals could avoid adverse effects on specific valued onshore habitats. However, there was also an overall feeling that marine renewables would be preferable to offshore wind in the area. People also expressed concerns about noise, vibration and safety of offshore wind turbines.

3.29 The RSPB raised concerns about potential impact on resident or breeding birds in the area, noting that this should be addressed in the finalised plan. Concern was specifically noted in relation to areas N1 and N3, given their potential impacts on the high numbers of seabirds nesting on Sule Skerry and Sule Stack SPA, and as a result there was surprise about the relative low weighting of predicted impacts in this area. Similarly, it was noted that the finalised plan should consider impacts of N4 and N5 on seabirds on the Isle of Foula SPA. More generally, the RSPB was concerned about Shetland being surrounded by offshore wind development, given its potential to impact on breeding, wintering and migrant seabirds, waders, water birds and passerines. Key challenges for the SPAs in the area were raised, requiring further consideration within the Plan's Habitats Regulations Appraisal ( HRA).

3.30 It was noted at the Lerwick workshop that fish displacement should be covered in the SEA. Questions were asked about what biodiversity studies are taking place or are planned to fill current data gaps, and how gaps can be identified and filled.

Technical issues

3.31 Navigation emerged as a key issue in this area from the full range of respondents. Specifically, the Chamber of Shipping and Northern Lighthouse Board welcomed the removal of N2 and N3 on the basis of the potential impact on vessels using the Pentland Firth and Fair Isle Channels. However, the Chamber of Shipping suggested that other shipping routes in close proximity to development should be considered further. The Northern Lighthouse Board felt that the importance of Lerwick was understated within the Draft Plan (section 3.4.6) and that reference should also be made to Sullom Voe. The logistics for shipping in this area was also noted as an issue in the workshop held in Peterhead.

3.32 The high level of recreational sailing activity in the area was highlighted by Shetland Islands Council, including boats sailing to Norway and Holland and annual racing. It was proposed that reliance on mapped areas was insufficient to demonstrate the impacts on these types of activity.

3.33 A number of other environmental and technical issues were raised by sector representatives.

  • SEPA noted that, depending on the scale and footprint of projects, development in area N1 could downgrade the water body's Water Framework Directive Status. As a result, its development would need to be justified on the base of a lack of other alternatives.
  • The MoD noted that the MoD air defence radar at Saxa Vord has not been considered and may be a constraining factor particularly for sites in the vicinity of the Shetland Islands.
  • Sportscotland raised concerns about the impact of N2 on surf beaches on the North Coast.
  • The Scottish Canoe Association noted that kayaking could be particularly affected by development of the sites near Foula, and asked for further opportunities to comment at a later stage.

North East Region

3.34 Eight responses focused specifically on regional issues in the North East, including from the following organisations:

Chamber of Shipping
Highlands and Islands Airports Ltd.
Ministry of Defence
Moray Firth Inshore Fisheries Group
Moray Firth Partnership
Royal Society for the Protection of Birds
Scottish and Southern Energy Renewables
Scottish Natural Heritage

3.35 The issues raised in this Region are summarised over the page:

Figure 7: Mapping of Views on North East Region

Figure 7: Mapping of Views on North East Region

Technical issues

3.36 A public workshop was held in Peterhead on 12 August 2010, as part of the consultation process. Key issues raised in the workshop primarily related to fishing. Whilst stakeholders with industry interests such as Peterhead port were generally supportive of development in the region, they were also aware that it will involve trade-offs. This could include loss of fishing grounds, impacts on fish stocks, exclusions or disruption during construction or installation of cabling. Moving development further offshore would not overcome these issues, given the current distribution of fishing activity.

3.37 It was noted at the workshop that laying cables on the seabed may benefit developers financially, but would increase impacts on fishermen. Participants suggested that the Scottish Government consult cable companies further, who could share further information on this matter.

3.38 Participants in the workshop event felt that large quantities of turbines could have significant effects on the region's fishing industry and therefore also impact on food security and employment. It was suggested that more detailed information is required, particularly on smaller vessels, as many of the options within the draft Plan coincide with heavily fished areas. The need for further consultation with the fishing industry was emphasised, to provide a clearer picture of the current baseline. It was suggested that the Plan as a whole should recognise the importance of different activities in different regions, with impacts on fishing communities in the North East being given particular recognition. As in Lerwick, grid connections were also raised, in particular the opportunities for offshore grid connections with Norway.

3.39 Reinforcing this emphasis on fishing issues in the North East region, in an individual response the Moray Firth Inshore Fisheries Group raised numerous concerns about the plan as a whole. They emphasised the importance of fishing interests being fully consulted, and suggested that the Draft Plan only considers the needs of the wind energy development sector as it stands. Concerns noted included the lack of a number of key elements including consideration of other technologies and areas, cumulative effects, cabling, test sites, onshore links and infrastructure.

3.40 The Group noted that there should be no presumption that fishing will be excluded from wind farms or cable runs, noting general restrictions during construction and operations. The safety of fishing vessels must be the overriding consideration, and there are options such as using fewer, larger turbines with greater spacing between them to allow access. The Group therefore called for a presumption in favour of continued access and navigation corridors to help fishing industry in transit between ports and fishing grounds. Concern was raised about the potential fuel cost of diversion and the time implications given restrictions on numbers of days at sea. The need for larger scale mapping to accurately assess the importance of options for fish stocks was also raised.

3.41 The Chamber of Shipping supported this, noting that there is a need for careful consideration of development in relation to shipping and fishing in the Moray Firth to avoid conflict between them. Recognition of ports was welcomed.

3.42 The MoD raised a number of specific issues requiring further consideration:

  • Although the location of Kinloss and Lossiemouth bases has been identified in the plan, the presence of air traffic control radars has not. This may therefore be a constraining factor to development.
  • RAF Buchan has been identified in the SEA, but the nearby Hill of Dudwick Meteorological Weather Radar has not. This may be a constraining factor.
  • Siting and design of development in NE1 will need to be considered in relation to the use of nearby RAF Tain Air Weapon Range to ensure military aviation is not obstructed or inhibited.
  • NE1 and NE2 are in proximity to MOD Danger areas used for aircraft operations. This will need to be taken into account in siting and design.

Environmental issues

3.43 The Fisheries Group stated that there is a need to view the Plan within its wider context including the MSFD and development impact on good environmental status for marine waters by 2020. This was considered to be particularly relevant to changes to benthic ecosystem and commercial fish and shellfish species due to energy inputs from wind farm operations. It was also proposed that the SEA explores more on sediment disturbance and links with toxic algal blooms, with consequences for commercial fishing operations.

3.44 The RSPB questioned some of the conclusions of the assessment in relation to Natura impacts and noted the proximity of area NE3 to Fowlsheugh SPA, and NE1 to the Moray Firth SAC. Further information on cumulative effects and medium term options was also requested.

Socio-economic issues

3.45 The need to consider the socio-economic (as well as environmental) impact of development in the medium term areas on important fishing areas was raised.

3.46 The Moray Firth Partnership commented on the overall approach to the SEA and Draft Plan. They raised the need for more economic information to be built in, such as the role of the Moray Firth Dolphins in generating tourism income. Broader points on the need to reconcile environmental impacts against clearer targets for renewable generation were also made.

Short Term Options - Beatrice

3.47 Amplifying some of this issues raised by other stakeholders at the regional level, Scottish and Southern Energy Renewables ( SSER) noted that the detail included in the SEA on spawning and nursery grounds is incomplete, and suggested that the scoping report for the project should be referred to as a more accurate source of information.

3.48 Highlands and Islands Airports Limited ( HIAL) recorded an interim objection to this option, as a result of its potential impact on Instrument Approach Procedures to Runway 31 at Wick Airport. It was also noted, however, that this impact could be avoided by repositioning the development further south west, and that HIAL are in discussion with SSE on the matter.

East Region

3.49 16 responses focused on the proposals for the East Region, including from the following organisations:

Chamber of Shipping
Civil Aviation Authority
Fife Council
Forth and Tay Wind Developers Group
Fred Olsen Renewables
Historic Scotland
Ministry of Defence
National Trust for Scotland
Neart na Goaithe Offshore Windfarm Ltd
North Berwick Environmental Trust
Northern Lighthouse Board
Royal Society for the Protection of Birds
Scottish Borders Council
Scottish Environment Protection Agency
Seagreen
Sportscotland

3.50 The issues raised in this Region are summarised over the page:

Figure 8: Mapping of Views on East Region

Figure 8: Mapping of Views on East Region

Level of detail

3.51 The Forth and Tay Wind Developers Group provided a detailed response that brought together various issues in the region. Overall, they were supportive of the commitment to the SEA, Habitats Regulations Appraisal ( HRA) and Plan and appreciated the time committed to achieving the outputs to date. They were content that the Draft Plan could form the basis for emerging development of the sector, in the short term.

3.52 However, the Developers Group also provided comments on how the SEA could be strengthened. This primarily included clarification of the boundary between the SEA and issues which are more easily and properly tackled at the project level through EIA. Concern was noted that the SEA may be prejudging EIA level considerations and suggesting mitigation that is not appropriate. This included particular anxiety about the removal of options from the Draft Plan on the basis of the HRA findings.

3.53 As with other developers, it was proposed that the site specific approach was replaced with regional assessment to provide a high level perspective and focus on significant effects from a national perspective. Further consideration of more strategic level options was recommended and it was also suggested that the SEA categories were revisited to achieve a closer fit with those used in EIA. Individual developers, including Seagreen, reinforced this view. A further developer requested that the demonstration project at Musselburgh Bay should be included in the plan as a short term option.

Environmental Issues

3.54 The RSPB welcomed the consideration of impacts on migratory birds in this region, noting significant movements taking place across the area and seeking additional reference to passage of birds across the North Sea from Scandinavia and further afield. The RSPB stated that the finalised plan should ensure impacts on birds are minimised, including in relation to barnacle, bean and light-bellied brent geese, ducks, waders and passerines, many of which being of relevance to Natura sites in and outwith Scotland. It was also stated that the final plan should note potential for adverse effects on prey species, arising from any impacts on spawning grounds and nursery areas for fish species.

3.55 North Berwick Environmental Trust raised concerns about visual and seascape impacts, and the potential effects arising from large scale construction on communities in the area.

3.56 A detailed response was provided by a surf business in Dunbar, seeking clarification of the likely impacts on this activity, and therefore associated businesses. Concern was raised about the scale of development proposed and its potential impact on the swell size. This was known to be more limited than that from the Atlantic serving comparable surfing areas in the west of Scotland, suggesting relative sensitivity in this region. It was noted that in other areas (Cornwall) the surfing community have been consulted before progressing with marine renewables projects.

Technical issues

3.57 Shipping emerged as a key issue in this region. The Chamber of Shipping expressed disappointment that the short term options sit alongside the Round 3 Zone and noted that cumulative impacts on shipping in this area would be significant as a result of rerouting requirements and associated time and financial costs to businesses. This was considered likely to have a long term impact on the viability of trade and employment, with specific impacts for Forth Ports, and risks to growth more generally. Access to the Firth of Forth was also raised in the Peterhead public workshop.

3.58 The Civil Aviation Authority questioned how radar issues have been avoided in this region, given the military and civil radars that exist here.

3.59 To support the consultation process, public workshop events were held in Edinburgh and Dundee. Attendance at the Dundee event was limited to just two, but the discussion nevertheless highlighted some interesting issues. Issues around onshore elements of the developments and the planning process were raised. People also asked how information gaps would be filled. The Statoil demonstration project off Peterhead was raised.

Short Term Options - Bell Rock

3.60 Several consultees noted that Bell Rock is no longer being pursued as an option as a result of insurmountable radar driven constraints. Notwithstanding this, SEPA noted that development at Bell Rock had the potential to downgrade the area's Water Framework Directive status, depending on its scale and footprint.

Short Term Options - Inch Cape

3.61 The Chamber of Shipping proposed that this site, along with Neart na Gaoithe, be reconsidered as a result of its potential implications, individually and cumulatively, for navigation.

3.62 Seaenergy Renewables questioned why the assessment had concluded that development in this area would have a moderate impact on seascapes, given that it lies more than 13km from the coast. Presentation of the findings for the site in the Environmental Report appendices was also queried.

Short Term Options - Neart na Gaoithe

3.63 The prospective developer (Neart na Gaoithe Offshore Windfarm Ltd.) provided a response to the plan as a whole which echoed many of the overarching issues raised by other developers. To support the general consensus amongst industry representatives that the plan should not be site specific, it was noted that the estimated generating capacity of this site has changed. They suggested that this region would be more appropriately referred to as 'Forth and Tay' with site specific references being removed to ensure future proofing. Suggestions were also made by the developer about how presentation of information could be improved.

3.64 The developer noted that the SEA assessment findings varied from those being undertaken at the site level. This included information on shipping and doubts about the accuracy of the conclusions in relation to fish stocks, given the lack of certainty about the site layout at this stage. However, the Chamber of Shipping proposed that this site, along with Inch Cape, be reconsidered as a result of its potential implications, individually and cumulatively, for navigation.

Short Term Options - Forth Array

3.65 Scottish Borders Council noted that it has responded to a request for a scoping opinion for this site, and that no major objections were raised, given that it lies some 17km from the shore. The need to assess the cumulative effect of this development with the medium term option, E1, was noted.

3.66 Sportscotland raised concerns about the impact of this development on beaches and surfing, whilst noting its significant distance from shore.

3.67 The developer, Fred Olsen Renewables, explained the collaboration that is underway in the region to assess cumulative impacts. Similar broader concerns to those of other developers were raised on the Plan more generally, including its overly detailed approach, the potential implications of the HRA and potential for the process to generate delays and uncertainty. Further information on how data gaps will be filled was sought, but it was felt that the SEA had identified sufficient baseline information to inform the development of a strategic level plan.

Medium Term Options

3.68 Specific concerns were also raised by developers about the medium term option (E1) and the need to assess cumulative impacts with the Round 3 Firth of Forth zone.

3.69 Similarly, the Northern Lighthouse Board noted option E1 with concern, given the likelihood of significant cumulative impacts and safety issues when this was viewed in relation to onshore developments and the Round 3 zone. It suggested that there is limited scope for further development in this area. Clarification was also provided on the importance of ports on the Forth.

3.70 Further technical constraints were raised by the MoD, which noted that option E1 includes Navy Exercise areas which may be relevant factor in siting and design of wind farms in this zone. The MoD also advised that, in conjunction with short term areas this option will block key maritime and strategic defence navigational access to the Firth of Forth. Accordingly, it was suggested that an east-west corridor for maritime navigation will need to be retained through this zone should development progress.

3.71 Fife Council's response suggested that it was content with overall scale and pace of change proposed in the plan, and the assessment conclusions.

3.72 Scottish Borders Council stated that they had expressed no major objections in relation to the Forth Array given its distance from shore, but expressed concern about area E1. This was a result of its proximity to the sensitive Berwickshire Coast AGLV (apparently 6km from shore). At this point, the full extent of this concern could not be defined by the Council, given the uncertainties about the scale of development or turbines, but it was noted that further more detailed consultation will be required at the appropriate stage. Scottish Borders Council noted more generally that although there is general support for renewables, within the area there is growing concern about the number of proposals and as a result the medium term options is likely to generate significant concerns. It was also noted that the cumulative impact of area E1 and the Forth Array should be assessed.

3.731 The Institute for Ecology and Environmental Managers ( IEEM) recommended that the medium term option (E1) be removed from the plan. This is in an area with a large number of sensitive coastal sites, and impacts would arise individually and cumulatively with the four short term options, which could affect the integrity of designated sites with high conservation value.

3.74 Historic Scotland noted the potential for the development in this region to impact on the setting of Bell Rock, and referred to the large number of sensitive coastal sites in this region which could be impacted by sites individually and cumulatively with the other options including E1. As a result, they agreed that project level assessment will be required to consider these impacts further and identify mitigation where appropriate.

3.75 The National Trust noted that the scenic value of St. Abbs Head is important for visitors and the local economy, and questioned whether the Forth Array will be close enough to the shore to be visible. Impacts on seabirds was also raised as a concern, particularly in light of recent decreases in the population, and impacts on other species including grey seals, migrant birds, cetaceans and elasmobranchs (sharks, rays and skate).

South West Region

3.76 Just under half of all the responses to the consultation (47%) were made up of clear objections to the Wigtown Bay and Solway Firth scheme. Overall, 200 individual responses specifically indicating opposition to Wigtown Bay were received and this is supplemented with an ongoing petition with more than 800 signatures at the time of writing. 205 responses reflect opposition to Solway Firth (Robin Rigg Extension) and 77 further responses consider development in the South West more generally, often incorporating views on the specific short term options.

3.77 Most of the responses came from individuals. In addition, the following organisations and businesses provided comments specifically relating to this region:

Annandale and Eskdale Area Committee (Dumfries and Galloway Council)
Association of Wigtown Booksellers
Chamber of Shipping
Colvend and Southwick Community Council
Cree Valley Community Council
Discover Scotland
Douglas Hall Fisheries
Drummore Bowling Club
Dumfries and Galloway Council
E. ON
Galloway and Upper Nithsdale Liberal Democrats Constituency Party
Galloway Fisheries Trust
Galloway Static Gear Fisherman's Association
Garlieston Community Council
Gatehouse of Fleet Community Council
Gillespie Leisure Limited
Historic Scotland
Isle of Whithorn Community Council
Keep Wigtown Bay Natural
Kirkmaiden Community Council
Manx Fish Producers
Maritime and Coastguard Agency
Ministry of Defence
Monreith and District Action Group
National Federation of Fishermen's Organisations
Newton Stewart Sub-Aqua Club
Ochtrelure and Belmont Community Council
Portpatrick Community Council
Royal Society for the Protection of Birds
Rusko Holidays
Scottish Natural Heritage
Solway Coast AONB
Solway Firth Offshore Wind Developer Group
Solway Firth Partnership
South Rhins Community Development Trust
Stewartry Area Committee (Dumfries and Galloway Council)
The Kipp Estate
The National Trust for Scotland
The Whithorn Trust
West of Scotland Seafish Training Association Ltd
Wigtown and District Community Council
Wigtown Bay Local Nature Reserve Advisory Management Committee
Wigtown Bay Wildfowlers Club

3.78 Public workshop events were held in Dumfries and Wigtown on 6 August 2010, as part of the consultation process. Officials also attended the Stewartry Area Committee meeting in September 2010.

3.79 The diagram on the next page summarises key issues raised in the South West Region.

Figure 9: Mapping of Views on South West Region

Figure 9: Mapping of Views on South West Region

3.80 Many of those who commented on the specific short term schemes in this region also made broader comments. Others focused on a regional perspective or commented only on the medium term options.

Views on the Consultation Process

3.81 At the outset of the Dumfries consultation event, people expressed concerns about the consultation period and the deadline for responses, and there was a strong feeling that the development of the Plan was being hurried as a result of its underlying political impetus. These concerns were also raised in Wigtown, with the 150-200 people who attended the event voting for a 16 week extension to the consultation period. Whilst this could not be granted, a 6 week extension was subsequently notified by way of a compromise.

3.82 At the Wigtown event, there were additional concerns about the timing of the consultation during the summer. It was suggested that the Scottish Government should have consulted on the options when the Crown Estate announced exclusivity agreement for the 10 short term sites. There was significant concern that local issues were not being raised as consultation appeared to be mainly focused on regional and national representatives. People felt that the Scottish Government needed to liaise with councils, community councils and local people to get to local issues. People were concerned that Ministers would pay more attention to organised bodies, and it was suggested that they should visit the local area to see the potential impacts.

3.83 Within the formal written responses, general views similarly focused on the planning process as well as its content, with several consultees raising concerns about the consultation period and suggesting that it was a prior assumption that the 10 sites would proceed, regardless of consultee views.

3.82 The Solway Firth Partnership suggested that stakeholders in England had not been consulted and complained that the local consultation was undertaken too late in the process, and did not adequately answer local people's questions. They also complained about lack of hard copy information or accessible maps.

3.83 Some consultees, however, considered the SEA to have been robust, and a useful starting point for regional planning.

Scale of development within the South West

3.84 For the region as a whole, there was consensus that the overall scale of development was unacceptable when considered in relation to the area's special characteristics and its associated capacity to absorb change in a sustainable way. This was particularly the case when on and offshore wind energy developments were considered together. There were many views that the scale of development overall would undermine some of the essential qualities of the Solway coast, including its wild and isolated character. Visual and seascape impacts were the most significant concern, forming a key theme within the local consultation workshops and an issue shared by the vast majority of individual respondents.

3.85 Dumfries and Galloway Council made a broad, but also detailed response to the consultation. This noted that the area has already made a substantial contribution to renewable energy targets, and that there is a need to recognise the cumulative effects from both on and offshore development collectively. This view was strongly supported by people attending the local consultation workshops. At the Dumfries workshop, for example, people called for a much fuller assessment of cumulative effects of on and offshore developments and the need to ensure a process is in place to tackle these combined effects. The most significant concern of Dumfries and Galloway Council related to the impact this would have on the economy, particularly tourism. This response was fully endorsed by the Council's area committees.

3.86 Many consultees made close links between the area's environmental quality and its current and future opportunities for economic development, employment and regeneration. For example, the Solway Firth Partnership noted that a biosphere reserve in the area and possibilities around national park status could be significantly undermined by development of the proposed scale. Initiatives for wildlife tourism such as local RSPB reserves were mentioned by several consultees for the same reason.

Impacts on communities

3.87 Impacts on communities was a strong theme within the public consultation workshops in the area, with concerns about negative impacts not being compensated with any local economic benefits. People felt disengaged from the process, and were concerned that the low numbers of people living in the area made them easy to overlook. People were also very concerned about impacts on the wellbeing of local communities, including from noise, loss of tourism jobs and income, and energy costs. There was a strong feeling that the Scottish Government needs to consider people as much as the environment. Potential impacts on people's health were raised as well as more specific impacts including noise, and it was felt that the Government had a duty of care to communities.

Environmental issues

3.88 The Solway Firth Partnership felt that the assessment of impacts in the region had numerous knowledge gaps, particularly in relation to impacts on key species including birds, sharks, skates, rays and commercial fish species. They contended that there has been inadequate consideration of effects on European Protected Species, cetaceans, otters, turtles which all occur in the area. There were calls for closer links with marine planning and scepticism about the process amongst local people, as all 10 sites were incorporated into the Draft Plan. The Solway Firth Partnership was concerned that the Final Plan will be automatically transposed into regional marine plans, and stated that it must remain a draft until considered part of marine spatial planning process.

3.89 Wigtown and District Community Council was opposed to the Plan as a whole, as a result of the 'excessive' level of development and concerns that offshore wind arrays would effectively cordon off the south coast from North West England, the Isle of Man and Ireland. Impacts on the coast, navigation, fishing (particularly angling and salmon migration and impacts on fish in the Cree and the Bladnoch) and recreational boating were all raised as concerns. Low flying activities were also noted. Similarly, there were concerns about effects on biodiversity, including key species and habitats and local nature reserves.

3.90 Industry representatives with interests in this area were generally supportive of the Draft Plan. Developers agreed that whilst impacts were inevitable, mitigation could be provided to reduce this to an acceptable level. Pointers on the HRA were provided, including the need to cover disturbance of marine mammals, seal breeding colonies, foraging seabirds and their habitats, barriers and disturbance on migrating mammals fish and seabirds, and spawning and nursery grounds of Biodiversity Action Plan ( BAP) fish species. As with other regions, it was stressed by the industry respondents that plan level assessment should not prejudge EIA level assessment. It was also noted that collaborative working on cumulative effects is a requirement of The Crown Estate.

3.91 In addition to general concerns on visual and landscape effects from all of the sites and in particular the two short term sites within the region, further views were raised by some specific interests. This included the National Trust for Scotland which noted that further development in the Rockcliffe area could degrade an outstanding seascape, and that a number of other properties have outstanding coastal aspects which could be affected by the development. The Solway Coast AONB noted the potential for significant effects, looking into and out of the AONB and stated this would be exacerbated by additional effects from onshore developments. The Solway Firth Partnership questioned why the short term options had been included in the plan despite their potential for negative impacts on NSAs. They contended that insufficient attention has been paid to impacts on the AONB, views from the Lake District National Park, and the setting of the Hadrian's Wall AONB.

3.92 The RSPB provided detailed comments relating to the area as a whole. It noted the need for mitigation of potentially significant effects identified in the SEA. Concern was raised that impacts on birds from sites SW2 and SW6 had been ruled out as a result of their distance from designated sites. Instead it was noted that the Solway and Wigtown Bay are major flyways with internationally important numbers of birds passing through. It was noted at the Dumfries public consultation workshop that it is crucial to carry out migratory bird surveys at the right time of year, and that wind turbines are known to be dangerous to birds.

Economy

3.93 Tourism, linking with visual impacts, was also raised by the community council particularly in relation to the Wigtown Bay development and it was emphasised that the area is reliant on the tourism sector. Specific issues were raised about the potential for proposals to impact on Kirkmabreck Quay - an essential facility for sustainable timber transport and export. With regard to the community, the community council explained the importance of retired people moving to the area for maintaining services, and the social fabric of the region. There was concern that impacts on the scenic quality of the area could affect this adversely, and undermine fragile housing markets.

3.94 A detailed response focusing on wildfowling in the region as a whole was received. This highlighted important areas and potential impacts on this activity and associated tourism.

3.95 Several people remarked about the profits from the development 'going to Denmark' or were concerned that the impacts would be on Scotland, but that the energy would feed into the national grid and supply English homes. Many individuals stressed they had no issues with offshore wind in principle, but believed the siting of the short term developments was misconceived. Energy efficiency was raised as a preferable response to the climate change agenda.

3.96 Most of the respondents expected that economic benefits of the development to the Dumfries and Galloway area would be very limited. Partly, this appears to be based on views that the benefits of Robin Rigg have only been realised in Cumbria. The Galloway and Upper Nithsdale Liberal Democrats Constituency Party supported this view and noted that the potential loss of tourism employment and income would not be offset by any compensatory gain from the development. Many people anticipated with regret that construction, turbine making and maintenance would use labour sourced from elsewhere.

Other Technical Issues

3.97 Several consultees raised concerns about busy shipping routes in this area and the potential safety implications of development. It was suggested that AIS data has led to a significant underestimation of activity in the area. Specific issues were raised in relation to the short and medium term options, as described in more detail below. This included concerns about impacts of option SW1 on the Belfast and Larne to Loch Ryan Ferry Crossing.

3.98 Grid connection issues were also raised at the local events. For example, at the Wigtown workshop, the public noted the disincentive arising from the national grid feed-in tariff and there was concern that there was insufficient capacity to service the proposed developments. People were also worried about secondary effects arising from pylons, given the cost of underground cabling. It was felt that the plan should have considered this and other infrastructure issues in more detail.

Fishing

3.99 Key responses relating to fishing in the region were received from:

  • Scottish Sea Angling Conservation Network
  • Galloway Static Gear Fishermans Association
  • Manx Fish Producers
  • Galloway Fisheries Trust
  • Urr District Salmon Fisheries Board
  • River Eden and District Fisheries Association
  • Solway Firth Partnership

3.100 Concern was expressed by interests in this sector about a lack of earlier involvement in the plan and the need for further research was stressed. There were mixed views on the assessment, but on the whole this group were unconvinced that the approach had covered their interests to a sufficient degree of detail and accuracy. Some felt that this was a more significant issue for this region than others within the Plan. The broad effect of removing fishing grounds in terms of displacement and more intensive fishing in the remaining areas was raised. Specific views on short and medium term sites were also raised, as described in more detail below. On a more positive note there were offers of assistance with future assessment, information gathering and monitoring and willingness to be involved in the process as it moves forward. Detailed supplementary information was provided by several of the fishing sector consultees, which will be taken into account as the plan is finalised.

3.101 These industry views were supported by those attending the Dumfries public workshop. In particular, there was concern that the Plan and the SEA had identified only limited effects on fishing from development in the region. It was reported that there is a lot of activity originating from Maryport, and noted that many of these vessels would be smaller than 10m and therefore excluded from the broad analysis. It was noted with concern that the Wigtown Bay site was located in the middle of vessel routes, with any development requiring navigational assessment. People also asked whether liaison was being undertaken with the fishing industry, and it was noted that further information is available to better inform the plan.

3.102 Key considerations included impacts on migratory fish routes, nursery grounds, and spawning grounds. Effects during construction and operation were noted. Impacts on salmon and sea trout and their passage to and from rivers were raised as key concerns. Some consultees were particularly concerned that a valuable cockle fishery and shellfish aquaculture were not taken into account. The sector strongly recommended further research on issues including the impact of high voltage cabling on salmon and sea trout and migratory fish generally.

3.103 Fishing sector consultees in this region wish to see more scientific evidence that noise and vibration from installation and operation of wind farms will not deter migrating salmon, lamprey and eels from migrating through the Solway. Until such evidence is produced, at least one of the consultees will maintain a strong objection to proposals. Some recognition was, however, given to further assessments including EIA and HRA and the extent to which these would address some of the issues raised. It was suggested that there is a need for more robust research before development (and possibly the plan) proceed, and it was noted that this is moving forward in collaboration with developers of the short term times. It was also suggested that an amended SEA should be published.

3.104 Fishing was noted to be a major economic driver for the region as a whole. The Solway Firth Partnership emphasised the importance of small vessels and static fishing gear and the need for consultation with fishing interests in the Isle of Man and Cumbria.

Broader energy policy

3.105 Many people commenting on development in this region, including the short term options, raised broader questions about energy policy and suggested that wave and tidal would be preferable. Some suggested other alternatives including nuclear energy. Many referred to a potential tidal barrage for the Solway. Broader energy issues, such as subsidies, were also repeatedly raised by consultees in the three local public events.

3.106 At the Dumfries public consultation workshop, there were questions as to whether any marine renewable development (wave and tidal) would be possible in the Solway, and people asked why there are no Saltire Prize areas in the region. People also viewed alternatives such as improved energy efficiency as being more preferable to offshore wind. People did not consider wind farms to be a sustainable option, raised questions about subsidies for the industry, demand for the electricity generated, and the economic viability of projects in an area with low wind speed. There was significant concern that the developer would go for the cheapest and easiest option, which is most likely that closest to shore in shallower water.

3.107 Several consultees questioned the efficiency of Robin Rigg and wind more generally. Many suggested that the Solway as a whole has insufficient wind to sustain an efficient development. Numerous people requested that monitoring data from Robin Rigg be considered before further development proceeds.

Short term options: Wigtown Bay

3.108 The overwhelming majority of all responses to the consultation in this region, together with discussions at the local consultation workshops, reflected strong opposition to the proposed short term option of Wigtown Bay. The majority of those opposing the development were individuals (some 150 formal responses, plus the continuing growing number of petition responses at the time of writing). A large number simply stated that the project should be removed from the plan. A very small number suggested that it could become a medium term project. Only two respondents (except the prospective developer interests in the area) supported the project. The most frequently raised issue was landscapes, seascape and visual effects of the development. The diagram below provides further detail of the issues raised in relation to this specific option area.

3.109 Supportive responses were received from the regional wind developer group, although, as with regional industry groups for other areas, they questioned how far the SEA should go towards defining project level impacts and mitigation. The need for, or appropriateness of, some of the project level mitigation proposals was questioned. It was noted that The Crown Estate requires joint regional working to explore the cumulative effects of developments on a regional basis.

3.110 In terms of organisations, detailed responses were received from Dumfries and Galloway Council (incorporating views from its area committees), the Solway Firth Partnership, several community councils (Isle of Whithorn, Gatehouse of Fleet) and the Keep Wigtown Bay Natural Campaign. Local MSPs raised specific concerns about the development, referring to its scale, proximity to the shore, visual and landscape impacts and its implications for tourism. These organisations and key representatives had little confidence that any mitigation of the scheme's predicted effects would reduce its impacts significantly. Concerns were also widely raised about impacts on biodiversity, population and health.

Figure 10: Mapping of Views on Wigtown Bay

Figure 10: Mapping of Views on Wigtown Bay

3.111 As with general comments about the approach to the Plan as a whole, and regional views, many consultees raised issues with the length and approach to consultation for the plan. Many wished to have seen more detail on the specific projects in the area. Many felt more time was needed to allow for further assessment and evaluation of the findings and some called for a public local inquiry of the development. Concerns were raised about the advertising of the consultation and its public events. The Galloway and Upper Nithsdale Liberal Democrats Constituency Party felt that the consultation period had been unrealistic to allow for regional consultation effects, and that this reinforced their view that the Plan had undertaken insufficient consideration of regional impacts.

Landscape, Seascape and Visual Effects

3.112 Most responses focusing on this site were primarily concerned about visual, landscapes and seascape impacts of the development. Views varied on secondary impacts from this. Many people were concerned with the quality of life of residents, with many others focusing on the potential for secondary impacts on tourism. Most people were unconvinced that mitigation measures would reduce these effects, and most strongly proposed that the option be removed from the plan, rather than suggesting that it could be laid out differently or positioned in a way that its impacts could be reduced.

3.113 The proximity of the proposed development to the coast was a key concern. Indeed, many consultees noted that the plan should be regarded as a plan for inshore, as opposed to offshore, wind energy. At the Wigtown workshop, people felt that locations further offshore would be preferably. The community emphasised that it was not averse to wind energy development as such, but that the proposed short term sites are too close to shore.

3.114 In many cases, the likely effects of the development on views and vistas from the coast were noted, including from the Dumfries and Galloway Coast to Cumbria, the Isle of Man and Northern Ireland. Views across Brighouse Bay were also repeatedly noted as a key concern. SNH stated concern about the inclusion of the site given its proximity to the shore, the likelihood of significant seascape and visual impacts (being greater than as stated in the Environmental Report) and the lack of scope to mitigate these effects given the nature of the proposal.

3.115 Views on landscape and visual effects also related to some nationally designated areas including the Fleet Valley National Scenic Area ( NSA). Significantly, SNH noted that it is likely to raise issues about the proximity of the development to the coast and potential impacts on the NSA at scoping for the project. SNH was also unconvinced that mitigation will be effective in this case. Lighting was raised as an issue and it was noted that the project assessment will need to focus on how the Fleet Valley NSA is experienced. Lighting impacts on the dark skies status of the Galloway Forest Park were also raised in the Wigtown consultation event and by some individuals. Other visual issues included effects arising from the movement of the blades at different speeds, which could not be readily mitigated. More detailed visual issues included the likely backlighting of the turbines at sunrise and sunset.

3.116 Several consultees noted that the Environmental Report had recorded the landscape and visual effects as significant, and strongly questioned why this was not considered to be sufficient grounds to warrant removal of the proposal for Wigtown Bay from the draft Plan.

PETITION

Keep Wigtown Bay Natural produced an online petition opposing the Wigtown Bay development and it was published online in August 2010. At the time of writing (10/12/10) 812 people had signed the petition.

Cumulative effects

3.117 Compounding this, cumulative impacts were raised as an issue by many consultees. Many were concerned about the combined effects of offshore development with the larger scale developments and smaller scale installations on land in the vicinity of the coast. Several suggested that the area was at saturation point in term of pressure for small scale wind, and therefore did not welcome the likelihood of the development in addition to these issues.

3.118 Views were also raised about the methodology used for the landscape and visual impact assessment, with several people seeking clarification of detailed points within the SNH guidance.

Tourism and recreation

3.119 Tourism related concerns were very widespread and focused on visual impacts (explored above) and more general visitor perceptions and enjoyment of the area. Some responses were received from local businesses, including those running accommodation. All were concerned about impacts arising as a result of the visual and seascape effects of the development. Reinforcing this, local people noted the critical importance of tourism to the local economy at the Dumfries workshop, and questioned how this would be assessed. There was concern that the significant negative effects of development of the sites in the Solway on tourism had not been recognised within the Draft Plan or its SEA.

3.120 Other recreation issues were raised, with concerns about sailing and watersports and wildfowling, as noted above. Local interests were concerned about any possible restriction of local diving opportunities (Newtown Stewart Sub-Aqua Club) during both construction and operation, and it was suggested that this could be mitigated by siting the development further offshore. Discover Scotland expressed concerns about the project and suggested that are preferable areas where tourism impacts would be much less significant.

Impacts on communities

3.121 The impacts of development on people and communities was raised by individual respondents and also widely debated within the local public consultation workshops. Impacts of concern included lighting, noise, general disturbance and shadow flicker. There was a broad feeling that whilst the communities would experience the impacts of the development, they had not been fully engaged in the process and expected to receive little, or more often, no economic benefits. Impacts on property values, business viability and house prices were also concerns.

Fishing

3.122 Issues were raised about the impact of this specific development on fishing by several key organisations including: Galloway Static Gear Fisherman's Association; NFFO and Manx Fish Producers. This clearly demonstrated that fishing interests extend much more widely than the Dumfries and Galloway area, and include those operating from Cumbria and the Isle of Man.

3.123 Key impacts on fishing and fish stocks were expected to include loss of habitats, noise and vibration effects on adjoining areas, cable impacts, and displacement of activity to less suitable or profitable areas. Fishing interests reported that the area is regularly fished for nephrops, skate and plaice by vessels operating from Maryport, providing an important source of income. The area is also regularly fished by the local scallop fleet in winter. The project overlaps with trawling sites and could impact on static line fishing. Hand gathering of cockles, mussels, razorfish and other species were also expected to be affected, together with local and tourist small boat fishing. Impacts on these activities were expected to be substantial.

3.124 Safety concerns about loss of sheltered fishing areas were raised. It was noted that strong tidal flows and seabed hazards limit alternatives in this region.

3.125 Impacts on migratory fish were also a concern. Consultees pointed out that three salmon rivers run into the Bay. Cree Valley Community Council noted the importance of the Rivers Dee, Fleet, Cree and Bladnoch for salmon and sea trout rivers, and noted the extensive work being undertaken by the Galloway Fisheries Trust to maintain and improve conditions for all fish species using the Bay. At the Dumfries local consultation workshop it was reported that eleven important salmon rivers drain into the Solway. Whilst it was recognised that there is ongoing research in this area, people felt the Plan should consider this further. The importance of the area for Smelt (nursery and spawning ground) was emphasised by several individuals and organisations.

3.126 Impacts on recreational sea angling were noted, and it was suggested that any reduction or loss of this activity will have economic impacts, relating to the area's broader tourism product.

Other environmental issues

3.127 The RSPB provided detailed responses to the plan as a whole including references to this development. It noted that the SEA should recognise the Wigtown Bay (Cree Estuary) SSSI which is internationally important for migratory waterfowl and the largest Local Nature Reserve ( LNR) in the UK. Significant issues were raised in relation to whooper swan, pink-footed geese (both of international importance) and pintail and curlew, and the common scoter (nationally important), Manx shearwater and diver species. They also noted that increasing numbers of barnacle geese are now using the Bay in winter, and that the area is used by nationally important breeding gannets from Scare Rocks and auks from their Mull of Galloway reserve, as well as Manx shearwaters in summer. These concerns were also reflected in the comments of the local LNR management committee, who also provided comments on the importance of the area for birds, potential connections with the Crook of Baldoon, and associated effects on important fish species in the area. Concerns included impacts on passage through the area, feeding areas and the risk of bird strike. Links with plans for a biosphere reserve were also noted.

3.128 Several other consultees raised further environmental concerns. Impacts on biodiversity were raised by many people and organisations. In particular potential conflicts with seabirds, migrating geese, and effects on associated local nature designations were noted. The importance of the estuary and bay, and migratory routes was stressed. Linking with this, impacts on wildlife tourism were also raised. There was wide agreement that a Habitats Regulations Appraisal of the plan was essential. Vibration impact on porpoises, dolphins and basking sharks were also a concern. Cree Valley Community Council raised concerns about impacts of development on birds, including geese and swans, ospreys, seagulls, wading birds and ducks that feed in Wigtown Bay. They also noted potential for sediment transportation and disturbance of the seabed, with consequences for shellfish, crustaceans and bottom feeding fish, and potential destruction of fish feeding and nursery grounds. Also with regard to sediment, the issue of radioactive particles within sediment was raised at the Wigtown workshop event.

3.129 Cultural heritage issues included impacts on St. Ninian's landing and on local cultural diversity more generally, with references to artists, including the Glasgow Boys. Historic Scotland noted that there are several important coastal sites that could be affected by the project. This includes impacts on setting of scheduled coastal fortifications, chambered cairns and early church sites. They suggested this could be explored further at the project level.

3.130 Concerns about coastal erosion and the impacts of development on waves were raised.

3.131 Some consultees raised issues about munitions in the area. Several were concerned that munitions have migrated from Beaufort's Dyke and been washed up on shore. Given uncertainties, it was suggested that mapping of this was not feasible. Other technical constraints were raised including proximity to Dundrenan Range and two major gas pipelines. Low flight training and Ministry of Defence activity were also raised as possible constraints.

Shipping and navigation

3.132 In terms of shipping and navigation, it was noted that the data used in the SEA ( AIS) does not cover small fishing vessels. This was considered to be a significant issue. Potential problems for navigation were raised, including effects on the safety of small boats such as those of recreation users. The importance of this for tourism and the local economy was emphasised. Cree Valley Community Council explained that the development could restrict entry to harbours at the Isle of Whithorn, Kirkcudbright, Creetown and Carty Port. It was noted that access to Portmacadam / Gatehouse of Fleet has already been denied by a bypass road below the harbour. Furthermore, restriction of access to the sheltered anchorage behind Murrays Isles would also be made more difficult. These views were also confirmed by the wider public attending the local workshops. At the Dumfries workshop, for example, the need for a full navigational assessment was noted.

3.133 Small cruising yachts criss-cross the whole area of Wigtown Bay and indeed the whole of the Solway, visiting harbours, bays, inlets and anchorages throughout the season, many of them based locally or visiting from Cumbria, the Isle of Man and Ireland or further afield. People called for the importance of the area for recreational boating to be recognised within the Plan and its SEA.

Short term options: Solway Firth

3.134 Most of the issues raised in the case of Wigtown Bay were equally applicable to the proposal for the Solway Firth option. A significant share of responses focusing on this project came from campaigns, form letters and petitions. This included a series of letters from local people, and a group of responses from visitors to the area. The total number of people objecting was almost identical to those campaigning against Wigtown Bay, at 205 (as compared to 200).

3.135 Unsurprisingly, given that the project is effectively an extension of the existing Robin Rigg site, cumulative effects were a dominant issue for this site. Several respondents were concerned about turbines extending across the Firth. Points raised above about publishing and making use of evidence from the Robin Rigg development were strongly reinforced within responses relating to this specific site.

3.136 The same concerns about these impacts and their relationship with local people and visitors was raised. The majority of consultees (a significant number) felt the project was too large in terms of scale, numbers and potential size of turbines, and too close to shore. Impacts on the special qualities of the East Stewartry National Scenic Area ( NSA) were a focus here. In addition, cumulative impacts on the Colvend coast were repeatedly raised.

3.137 Concerns about the yield from the site due to low wind speeds were possibly even greater for this project than for Wigtown Bay. Many people were concerned about efficiency and subsidy of the project.

3.138 At the Wigtown public workshop, local people expressed concern that Dumfries and Galloway Council had objected to the Robin Rigg development, but that this had not triggered a public local inquiry, and it was expected that this might happen again. At the meeting, initial confirmation was given that the new marine planning and licensing process would overcome this issue. However, subsequently, as noted at the meeting of the Stewartry Area Committee, Marine Scotland officials explained that this issue would be reivsited, and that the process will need further examination and explanation.

3.139 In addition, the following issues were raised specifically in relation to this project:

  • Impacts on coastal paths were noted by several people.
  • It was suggested that economists should aim to establish the economic value of the area's coastline, to get a more accurate idea of impacts.
  • The site was noted to be an important fishing ground for plaice, skate, turbot, brill and cod.
  • Concerns about navigation from Maryport were also emphasised (as with Wigtown Bay) and in addition impacts on Whitehaven were also noted.

3.140 At the Dumfries public consultation workshop, it was strongly recommended by the group that the lessons learned from Robin Rigg should firstly be established, before any thought is given to an extension or other development in the area.

Medium term options

3.141 Several consultees objected to all of the sites in the wider South West region. Many were concerned about the impact of these sites on the Machars peninsula and the Mull of Galloway. The overall scale of development in the area was repeatedly raised and considered unacceptable. The impacts most frequently identified from the medium term sites related primarily to landscape and visual effects, together with secondary effects on communities and the region's tourism industry. Some suggested that developments would only be acceptable if they were at least 10km from shore.

3.142 Many comments were made about the potential for medium term development in and around Luce Bay. Luce Bay lies to the west of Wigtown Bay and would be potentially most directly affected by the SW3 and SW5 option areas. Some viewed it to be a preferable location when compared with Wigtown Bay, whilst others stressed its environmental importance and did not support it as an option. Several consultees noted that Luce Bay should be regarded as a danger area as a result of the live bombing range and unexploded ordnance drifting from Beaufort's Dyke. Radar issues were also raised.

3.143 Reflecting concerns raised more generally by others in relation to Questions 1 to 3, the Galloway and Upper Nithsdale Liberal Democrats Constituency Party pointed out that the medium term options in the draft Plan had been identified using criteria that had not been applied in the selection of short term sites. This was viewed as inconsistent and it was suggested that the short term sites were being fast tracked on the basis of commercial interests. A more sound evidence base for the Plan was called for, and it was proposed that an intermediate stage, considering environmental and economic impacts, was needed. This should explore the combined effects of Robin Rigg and the two further short term sites and onshore developments to provide a clearer picture of regional scale cumulative effects, which they expected to be significant.

3.144 A consultee suggested that siting of offshore wind in general should be in remote areas which are not visible to tourists and road users. Distance from land was considered to be important. Alternative sites within the region were suggested, including along the M74, on the top of high buildings in cities, on MoD land which is already in accessible (Dundrennan range), on forested land and west of Ailsa Craig.

3.145 One person supported development in the wider area, as a result of its contribution to climate change and energy suitability. It was argued that impacts on tourism may be overstated, given that there is little evidence on adverse impacts on this sector.

3.146 The Table below summarises specific views raised in relation to each of the region's medium term options.

Option

Comments

SW1

  • Some considered SW1 to be acceptable.
  • The Maritime and Coastguard Agency suggested removing this option.
  • Option designated Navy exercise areas supporting military activities and is therefore a concern. Maintaining ongoing military training should be seen as a constraining factor and considered further.
  • The DETI (Northern Ireland) noted that this site is on the traffic corridor between Belfast and Larne and Loch Ryan, a very significant economic and transport corridor. Development would need proper scrutiny and assessment.
  • Northern Ireland Environment Agency noted that the site lies 34km from the Antrim Coast and Glens AONB, and that minor negative effects had been identified.

SW2

  • Visual, tourism and community impacts were raised.
  • This is the area of the largest nephrops fishery in the Irish Sea.
  • Removal of the site was supported and it was noted that munitions may have drifted into this and other areas.
  • The Northern Lighthouse Board welcomed the withdrawal of the area given its implications for shipping in the North Channel.
  • Concerns about impacts on sea angling were also raised.
  • RSPB raised issues about assessment conclusions that impacts were unlikely, noting the paucity of data and the importance of the area as a whole as a major flyway.

SW3

  • Visual, tourism and community impacts were raised.
  • The Maritime and Coastguard Agency suggested this option be removed from the plan.
  • There was concern about the lack of a shipping slot allowing vessels clear passage through SW3 from the North of the Isle of Man. Similarly, the Northern Lighthouse Board noted with concern the potential impact of the option on traffic between North West England and Northern Ireland.
  • The area is important for nephrops and demersal fish.
  • Sea angling concerns and diving concerns were raised, and viewed as sufficient to warrant removal of the option from the Plan. Impacts on the seabed and on rare fish species and associate impacts on tourism were also noted.
  • Impacts on the South Rhins, designated as a Regional Scenic Area were noted.

SW4

  • Visual, tourism and community impacts were raised.
  • The Chamber of Shipping raised concerns about the impact of this site on traffic between North West England and Northern Ireland.
  • This area is important for nephrops, scallops and demersal fish.
  • Sea angling concerns were also raised.

SW5

  • Visual, tourism and community impacts.
  • This area is important for nephrops, scallops and demersal fish.
  • Sea angling concerns were also raised.

SW6

  • Some consultees considered this option to be acceptable.
  • Diving interests expressed concerns and sought its removal from the Plan.
  • RSPB raised issues about assessment conclusions that impacts were unlikely, noting the importance of the area as a whole as a major flyway.

West Region

Overview

3.147 A total of 355 responses focused on issues in the West region, including a large share focusing on Kintyre (297), some addressing the Argyll Array (26), and some focusing on Islay (7). Others discussed development in the region more generally, including the medium term options and often linking this with concerns about the two short term sites. The majority of responses relating to the region as a whole were from individuals, including some campaign responses from visitors to Kintyre and the members of Machrihanish Golf Club. As well as individuals, the following organisations and businesses responded in relation to the West region:

Argyll and Bute Council
Campbeltown Community Council
Campbeltown Loch Berthing Company
Chamber of Shipping
Clyde Fishermen's Association
Highlands and Islands Airports Ltd.
Historic Scotland
Infratil
Kintyre Civic Society
Kintyre Offshore Wind Farm Action Group
Machrihanish Golf Club
Manx Fish Producers
Maritime and Coastguard Agency
Ministry of Defence
Northern Lighthouse Board
Riders of the West
Royal Society for the Protection of Birds
Scottish Canoe Association
Scottish Environment Protection Agency
Scottish Natural Heritage
Scottish Power Renewables
Small Isles and Mull Inshore Fisheries Group
Sportscotland
Scottish and Southern Energy Renewables
The Village at Machrihanish Dunes / Kintyre Development Company Limited
Tiree Community Development Trust
Visitscotland
West Coast Offshore Wind Developer Group

3.148 The overall issues raised in relation to this region are shown in Figure 11 below.

Regional scale and pace of development

3.149 A public consultation workshop was held in Campbeltown on 9 August 2010, as part of the consultation process. Overall, consultees were concerned that the whole exercise seems to be industry led. As in the South West region, the pace of development was questioned. Some people suggested that it may be better to go ahead with just one area, rather than ten sites at once. It was also proposed that the Plan and projects should not be taken forward ahead of the National Marine Plan and designation of Marine Protected Areas. Further comments were provided as detailed below.

3.150 In addition, a public workshop was held in Oban on 10 August. More specific comments raised in the workshop are also set out below.

3.151 Argyll and Bute Council provided detailed comments on the Draft Plan and its SEA. It concluded on the basis of the information provided, that the short term option at Kintyre should be removed from the plan. Instead, the Council proposed progressing the medium term option to the south of the Mull of Kintyre (W4) in the short term. This idea was also supported by some of those who attended the public consultation workshop in Campbeltown. Further key issues raised by Argyll and Bute Council included the need to consider cumulative effects arising from the onshore elements of developments and the grid (also raised at the public workshop in Oban), and to give much greater consideration to the socio-economic aspects and impacts of the Plan.

Figure 11: Mapping of Views on West Region

Figure 11: Mapping of Views on West Region

Community views

3.152 People attending the Campbeltown public workshop felt that developments should be refused consent if local communities oppose them. Also in common with the South West, people were concerned that the limited number of local residents within this rural area could mean their views are overlooked. A further view that was shared with other communities in Argyll and also in the South West, was that the Plan appears to have been formed primarily on the basis of environmental information, with insufficient regard given to local people. It was emphasised that development impacts would be greatest from the projects located closest to the shore, specifically the Kintyre proposal, as discussed in more detail below. One consultee suggested that uninhabited islands and remote promontories in this region and the North West would be better alternative locations.

Industry Perspective

3.153 The West Coast Offshore Wind Developer Group welcomed the Plan and consultation on it. However, concerns were raised about the level of detail within the assessment, the inevitable uncertainties about the project level at this stage, and issues around timing and the HRA. The Group felt that it would be useful to explain how ad hoc proposals are covered by the SEA. It was also suggested that better alignment of assessment and mitigation across UK boundaries would be welcomed. Very detailed comments were provided in relation to Table 9.1 of the Environmental Report.

3.154 The assessment of cumulative effects was considered confusing by the developer group, relating more to wildlife and other receptors than those stated in paragraph 8.6.2 of the Environmental Report. It was suggested that the topic of 'water' could be scoped out of the assessment, based on collaborative work undertaken on the West Coast. The developers also suggested that there was a need for a flexible approach to consideration of distance in relation to landscape and visual effects, and referred to recent guidance issued by JNCC and SNH during the consultation period, regarding seascape assessment. Further regional queries were raised by the Group including a request for an explanation as to why the tidal project in the Sound of Islay was predicted to have cumulative effects - this was viewed as an overly cautious conclusion at this stage, symptomatic of the uncertainties arising at a strategic level. This issue was also raised by the Crown Estate.

Environmental issues

3.155 The majority of the regional issues in the West focused on the area's scenic value, general visual and landscape effects of development, with particular emphasis on its tourism and recreation value. The issue was raised and debated at all of the public workshops in the region. For example, at the Oban public workshop, concerns were raised that only National Scenic Areas and World Heritage sites were taken into consideration in the visual impact assessment. Questions were raised as to what is seen as a reasonable distance between turbines and homes (with the suggestion of at least 15 km to the shore). It was noted that the Kintyre site would be visible from an Area of Outstanding Natural Beauty in Northern Ireland. Some participants suggested that a comprehensive seascape analysis would better inform projects, and highlighted that local authorities have information on sensitive landscapes along the coast to feed into such a review.

3.156 Detailed comments on the value of the area for birds were provided by the RSPB. It was emphasised that the West coast is particularly well used by species migrating from Iceland and Greenland to winter in the UK and Ireland. As a result, large numbers of birds pass through the area, including many species of qualifying interest to Natura sites in Scotland and further afield.

Tourism and Recreation

3.157 The importance of the area's scenic quality for international tourism interest in the area was emphasised by numerous consultees.

3.158 The Scottish Canoe Association was concerned about the impacts of development in this region on kayaking, given that this activity tends to move from island to island and the quality of experience is largely defined by seascape quality. As a result, it was proposed that the east coast would be a more suitable location overall. The Scottish Canoe Association had concerns about developments in the area that are close to land.

3.159 Surfers (Riders of the West) also submitted a detailed response which raised similar concerns about the proximity of the three short term developments in this region to the coast. They expressed concern about impacts on surfing and provided detailed information on current activities including an outline of the great importance of Machrihanish Bay for their activity, serving a wide catchment across central Scotland with significant numbers of surfers and making an important contribution to the tourism sector of the local economy.

3.160 This group provided additional information of relevance to this region, and the wider plan. Reference was made to guidance on the EIA of offshore renewables provided by Surfers Against Sewage in June 2009. Information on surfing areas nationally, and from other offshore wind projects in the UK was also provided, suggesting issues with damping of waves as shown by modelling. Their view was that the proposed scale of development was too great to avoid having such impacts. The Group emphasised the importance of further consultation with surfers and associated businesses to ensure the baseline is accurate and inform future decision making.

Fishing

3.161 Fishing was also a key issue in the West region. At the Oban public workshop, people questioned the extent to which this has been viewed as a constraint, and there were concerns that the data used in MaRS would be insufficiently detailed to capture current activity and areas of value. Gaps in knowledge of migratory fish and salmonids were raised, and the Scottish Government confirmed that further work on this is underway. The proposed development options could be on important migratory routes and people asked specific questions about the impact of the Sound of Islay demonstration project on these areas.

3.162 The Small Isles and Mull Inshore Fisheries Group had concerns about the coverage of fishing within the assessment, and considered the overall scale of development to be too great. Their view was that impacts and compensation had been insufficiently covered.

3.163 The Clyde Fishermen's Association provided a detailed response focusing of fishing. It emphasised the need for development to be sympathetic to this to avoid significant losses. Given the advancement of technology for floating turbines in deeper water, the Association concluded that no areas could be ruled out for renewables, with significant consequences for crab, lobster, scallop and nephrop fisheries. As a result, they called for the Scottish Government to make a decision on the scale of development that would be suitable. This should take into account a fuller assessment of the short and medium term options, with the additional scope for wave and tidal energy. Significant effects on businesses and communities were expected from this scale of development across the sector.

3.164 The Clyde Fishermen's Association also asked for better consultation, noting their lack of engagement in the process of identifying short term options. Displacement of fishing activity and the possible consequences for save navigation, merchant shipping, recreational boating were also noted. Comments in the SEA on the environmental benefits of excluding trawlers from areas were disputed, as this is known to not automatically improve environmental status as areas can stagnate or be inundated with invasive species that predate certain stocks. This uncertainty about potential benefits was also reflected by Scottish Environment LINK, in its more general response to the Draft Plan.

3.165 The Association also noted that the VMS tracking data will not reflect vessels that are less than 15m in length. Proper evaluation is required, given that the area of the short term sites is known to be used by such vessels. Lack of knowledge of fish stocks in the SEA, and the secondary effects which could arise from any expansion of fish farms in wind farm areas that are currently productive were also raised as concerns. They also questioned the level of detail that will be addressed within EIA at the project level, having not been party to any specifications for the short term sites to date. Overall the plan was not viewed as constituting a practical set of options from the perspective of the fishing sector and its associated communities.

Short Term Options - Kintyre

3.166 A total of 297 responses to the consultation focused on the Kintyre site. Excluding petitions, this was the site with the greatest number of single issue objections, accounting for more than a third of all responses (35%). A large share of these responses were from individuals, but there were also two campaigns in the area: one focusing on visitor views (having been distributed by an accommodation provider from the area) and another bringing together the views of the Machrihanish Golf Club members.

3.167 With the exception of the prospective developer ( SSE Renewables), only two letters of support for this development were received. The remainder were objections to the site. The figure over the page summaries the key points raised in relation to the project:

Figure 12: Mapping of Views on Kintyre

Figure 12: Mapping of Views on Kintyre

Landscape, seascape and visual effects

3.168 The majority of responses focusing on this scheme were concerned with its visual, landscape and seascape impacts. The scale of the proposed development and its location in relation to the coast were also noted in most responses. Questions and views on the likely turbine size and configuration were raised. Overall there was consensus that the development scale was substantial and that this, together with its proximity to the shore, would contribute to very significant adverse impacts on the existing scenic character of the area. These views were held by individuals, local businesses and organisations, and national stakeholders. This included Scottish Natural Heritage ( SNH) which pointed out that it had already raised concerns about the proximity of the project to shore, and its consequent seascape and visual impacts. SNH was very doubtful that these issues could be mitigated.

3.169 At the Campbeltown public workshop people questioned why options close to St. Kilda had been removed as a result of their visual impacts, but no similar steps had been taken for sites such as Kintyre, that were close to living communities. This echoed a similar view arising in Tiree. People also questioned how the proposal had got this far and asked on whose authority the developer had been able to progress the project.

3.170 The lack of formal designations of the natural and cultural heritage value of the area was noted. Some felt that the area should be designated as an AONB or NSA. The Northern Ireland Environment Agency ( NIEA) raised concerns about the impact of the Kintyre site on the Giants Causeway World Heritage Site, noting it was at a comparable distance to that identified in the case of NW3 and St. Kilda. They therefore questioned why this had prompted removal of the latter option, but not the former from the draft Plan. The NIEA also noted that the SEA had identified potential impacts of the development on the Antrim Coast and Glens AONB and the Causeway Coast AONB.

3.171 Particular characteristics and sensitivities of the visual amenity of the area were raised repeatedly, including its sunsets, vistas, and views of the islands. The iconic character of some of these views was emphasised and references were made to artists and others who have valued and celebrated its qualities. Key views noted included those of the Inner Hebrides (Islay and Jura), Rathlin, and the coast of Northern Ireland. Light pollution was also noted as an issue related to visual impacts.

3.172 There were concerns about the use of photomontages by SSER in its local consultation, with many people calling for more or better visualisations to allow for a fuller understanding of these likely impacts to be gained. Some, including Campbeltown Community Council, questioned the accuracy of those provided to date.

3.173 The majority of these responses also noted the close links between the area's scenic quality, and its appeal to visitors. Many people from much further afield who regularly visit the area also responded to the consultation, including those involved in the local campaign, but also a significant number of other individuals. Other, less immediate qualities were also raised, including the area's sense of isolation, tranquillity and wildness.

Tourism impacts

3.174 A significant number of responses were from tourism sector businesses, including accommodation providers. Many, including businesses and the community council, were pessimistic about visitor views on the development, expecting that it would become a disincentive to future visits. One consultee suggested that a survey had shown that 80% of visitors to the area would not return if the scheme went ahead. One accommodation provider had organised a substantial campaign response from recent clients who had stayed in her accommodation, significantly adding to the overall opposition to the scheme. Another respondent was considering investment in a tourism business locally, but suggested that this would no longer proceed, if the development was to go ahead. Some requested a fuller cost benefit analysis and surveys of tourists to be undertaken by an independent third party. Visitscotland supported the numerous individual responses on this point, noting that the project should be considered further given the sensitive setting of the project and its concerns about its proximity to shore and consequent visual impacts.

3.175 A significant number of responses focused on the impacts of the development on golfing in the area. This related partly to its impact on the enjoyment of existing users of the golf course, but also to the implications for future investment in golf and associated tourism development, planned for the Machrihanish Dunes project. This was viewed as being critical to wider aspirations for regeneration of the area. Views on this were raised by the developer of the project, but also widely supported by individuals, businesses and organisations. The golf course architect and existing club captain were clear about their opposition to the scheme, and supported by many others. Many people, including those attending the Campbeltown workshop, noted the special qualities of the view from, and experience of, the first tee.

3.176 As well as golf, surfing was a significant issue raised by many consultees. The impacts of development on wave height, direction, currents and movement of sediments were linked with this, as well as broader environmental concerns. The possibility of a 20% drop in surf was referred to. Baseline information on the important surfing beaches was provided, including Killegruer beach near Glenbarr, Machrihanish and the Gualdrons, and Southend beach at the southern tip of Kintyre. Of these the west coast beaches were considered to offer the best surfing opportunities. Impacts on surfing activity was expected to have a major impact on recreation and tourism. Doubts were expressed about whether effects could be mitigated. This issue was also raised at the Campbeltown workshop, where people felt that hydrological interactions and longshore drift should be considered in relation to the dunes at Machrihanish, and there was concern there will be negative effects on waves, affecting surfing.

3.177 Recreational sailing was raised as an issue by several consultees. Some explained that the area was crucial for sailors as it was on one of two routes around the Mull of Kintyre (the alternative being the Crinan Canal). Safety issues were raised, with those interested in sailing stating that the location of the development could force boats further west into more challenging seas. This would be a particular issue in the event of stormy weather. At the Oban public workshop, it was explained that theKintyre site could be an issue for recreational sailing and other small boats, because the area is used by these vessels, and any development will disrupt routes for shelter and safe anchorage. The site would push boats out much further (to Otter Rock) before they could come back into the coast. Tidal turbines at Sanda Sound may also be an issue for yachting and other small boat users, including small commercial vessels. This combined with the Kintyre site would make navigation round the Mull of Kintyre very difficult

3.178 Detail was provided by the Campbeltown Loch Berthing Company, which likened the development in this location to being "like placing bollards across a motorway." Comments were also raised on the quality of the cruising experience and the impact of interference with the wind on yachting. The Scottish Canoe Association was also opposed to the development, given its visual impacts, concern about safety issues in rough conditions, and use of Machrihanish beach for surf kayaking.

3.179 Other tourism and recreation activities and resources raised as being vulnerable to this potential development included the Kintyre trail, heritage sites, and birdwatching.

Environmental Issues

3.180 Coastal processes, and impacts on the shore were also raised by several consultees. The Gauldrons were a key concern. SEPA noted that development in this location could downgrade Water Framework Directive status, depending on the scale of development and its footprint. Morphological assessment would also be required. One consultee described their concern about further coastal erosion, having watched the erosion of Machrihanish Dunes over the past 20 to 30 years.

3.181 Issues arising from piling works and the stability of the seabed were also raised, including questions about the stability of the seabed, based on the disused undersea coal / shale workings under the site. This issue was also highlighted at the Campbeltown public workshop event.

3.182 Biodiversity was a concern shared by many consultees. Impacts on: migratory birds (whitefronted geese), fish (spawning fish, salmon runs, impacts of cabling on salmon), seals, dolphins, and sea mammals. As with visual amenity, wildlife was viewed as important in its own right but also an essential part of the area's appeal to visitors. The proximity of development to the shore was considered likely to exacerbate its impacts on biodiversity (as well as visual effects).

3.183 The RSPB noted the potential for adverse impacts on birds including wintering birds in the adjacent Machrihanish Important Bird Area to the east of the site, and internationally important seabirds within the North Channel (part of the Rathlin Island SPA) that may be displaced through loss of breeding habitat, or be at risk of collision. Migration of a range of terrestrial qualifying species of SPAs, close to and at a distance from the site was also noted, including: whooper swans, Greenland white-fronted geese, pale-bellied brent geese and black-tailed godwit. Reference was also made to the presence of breeding black-throated diver in the region and uncertainty about its movements at sea. Similar uncertainty was noted in relation to corncrake, although it was noted that it was unlikely that they would pass through the area in large numbers to impact on SPAs for the species.

3.184 One consultee suggested that bird life and seabird records had not taken into account in the assessment. References were provided to sources of further information including local wildlife www.machrihanishbirds.org.uk

3.185 Campbeltown Community Council noted the importance of the natural environment for tourism, stating that some 200,000 seabirds use the seas in the area in summer and late autumn, and that the site is on a southerly migration route. They also suggested that the data on marine mammals in the area used in the assessment was inaccurate, with the observatory logging dolphin sitings regularly, as well as seals, basking sharks and minke whales. It viewed development in this location as potentially conflicting with the designation of the area in the future as a Marine Protection Area.

PETITION

A petition opposing the development has been set up by the Kintyre Offshore Windfarm Action Group. It asks Scottish Ministers to reject the proposed development. At the time of writing (10/12/10) the number of signatories was unclear.

Community Impacts

3.186 The project was considered likely to reduce the value and sale of properties and businesses in the area. General impacts on residential quality of life were also noted including construction noise and disturbance, and operational noise, shadow flicker (linked to stroke and epilepsy) and vibration. People were concerned about direct impacts of activities such as piling on the stability of their properties. Overall, there was consensus that the development was too close to the village to allow for mitigation of what was expected to be significant effects, a view also reported in the Campbeltown workshop. Radio and TV receptions were also a concern. Compensation for homeowners and businesses was sought. People were nevertheless concerned about broader impacts on the 'way of life' particularly in Machrihanish village.

3.187 Cumulative effects arising from on and offshore development were noted as a concern. Some felt that this had not been fully assessed in the SEA of the Draft Plan. Questions were also raised about the likely grid connections for the project and the associated environmental impacts.

3.188 One consultee felt that the employment generated by the scheme would be for a small number of specialists from outwith the area, offset by the loss of a large number of local jobs in the tourism sector. Several people felt that the site was at odds with regeneration aims in for the area and investment in infrastructure such as the marina. There appeared to be a common view that the employment and economic benefits would be achieved elsewhere, with local people only suffering adverse effects. Some attributed this to the current lack of local skills.

3.189 Campbeltown Community Council was unanimously opposed to the inclusion of the site within the plan, on the basis of its visual impact, proximity to shore, impacts on tourism, biodiversity, and environmental quality generally. The Kintyre Offshore Wind Farm Action Group also brought together many of the concerns raised by individuals and other organisations to provide a range of reasons for rejecting the proposal. It was also noted that a formal meeting of councillors, the MSP and community members had concluded with a majority opposing the development. Argyll and Bute Council noted significant concerns about the impacts of the development on landscape, economy and the community, and emphasised the importance of the scenic quality of the west coast of Kintyre for tourism. The Council was unconvinced that any mitigation measures would be effective. As a result, it suggested removing the site and replacing it with W4 in the short term.

3.190 Many local organisations, community representatives and individuals, implied or stated concerns that the site was a 'done deal' and would be included in the plan regardless of their views. People also asked for clarification as to why the site had been retained within the plan, despite the SEA having raised significant issues.

3.191 A number of people strongly suggested, as a result, that the site should either be removed from the plan or that its boundary should be moved further offshore to reduce its impacts. Argyll and Bute Council also objected to the site on this basis, and were supported by other organisations in doing so, including Campbeltown Community Council and numerous local individuals.

Fishing

3.192 Impacts on fishing were raised by numerous individuals and also the fishing sector itself. Clam beds, lobster fishing and prawn fishing were key concerns. Fishing interests point out that the development could add substantially (2 hours) to sea journeys for returning fishermen, with implications for costs and emissions. The Manx Fish Producers, had concerns about the implications of development in this site in addition to other areas of the South West for their fleet, arising from the loss of or disturbance to fishing grounds, displacement of activity to other areas and cabling.

Technical issues

3.193 Other technical issues included aviation, with the project being close to Campbeltown Airport, affecting aircraft radar. Highlands and Islands Airports Ltd. ( HIAL) noted that the site is within the safeguarded are of Campbeltown Airport, where the presence of turbines could prejudice safety by forming obstacles and affecting radar. HIAL is therefore already corresponding with SSER to reach a solution. The risk of munitions migrating on the seabed into this area was also noted by some consultees. Impacts on Ministry of Defence low flying exercises and exercises at sea were noted.

Other technologies

3.194 As with many other areas, other technologies, specifically wave and tidal were raised as preferences by a number of consultees. The efficiency of this type of energy generation and the likely lack of local benefits was also repeatedly emphasised, although this was perhaps a slightly lower level issue than was the case for those who opposed development in the Solway. At the Oban public workshop event, people asked that a comparison was made between the cost of wave and tidal energy and conventional power stations. It was noted that there may be areas where, for example, wave and wind power can co-exist, and suggest that the Scottish Government should ensure that infrastructure is in place to enable this. The use of floating wind turbines to access deeper water was also suggested. Questions were asked about where the turbines would be sourced from.

Industry Perspective

3.195 The developer ( SSER) recognised the environmental constraints for the area, and stated that EIA will address landscape and visual effects at the project level. SSER were concerned that the SEA was pre-empting the EIA process, and clarified that the scheme was 1.3km offshore, as opposed to 0.9km as stated, with the distance to Machrihanish from the nearest turbine being 3km. SSER was critical of some elements of the assessment, including the data on spawning and nursery grounds (Figures 5.6 and 5.8), comments on electromagnetic effects and the cumulative effects on marine mammals and birds of development with wave and tidal.

Short Term Options - Islay

3.196 Fewer responses focused on the Islay project.

3.197 The developer ( SSER) raised questions about the accuracy of some of the data used in relation to the assessment of site and directed Marine Scotland towards the scoping study undertaken for the project. It asserted that there will be no loss of feeding habitat arising from the development, as geese feed onshore, and corrected a reference to electromagnetic fields impacting on marine mammals within the SEA. It also proposed that further work was required to assess the cumulative effects arising from offshore wind, wave and tidal.

3.198 Concerns about the development raised in responses related mainly to its potential landscape and visual impacts, and effects on wildlife. Some respondents noted the particular landscape and seascape quality of the region as a whole, and suggested the removal of the Islay project along with other options as a result.

3.199 A public workshop was held in Islay on 22 September 2010 to further support the consultation process. People attending the event raised fundamental questions about the rights of the islanders to the seabed, questioning the authority of the Crown Estate to progress development and echoing the views expressed by the fishing sector representatives in Barra. Clarification of the licensing process was sought including the treatment of on and offshore issues together, and people were concerned that the community should have a role to play in the decision making process.

3.200 There was also extensive discussion focusing on the findings of the SEA process and the process of identifying and assessing options within the Plan. Concerns were expressed about the visibility of the turbines from sensitive areas on the west of Islay, potentially affecting both local communities and visitors. People were concerned about the impacts of construction and maintenance on the island, and reassurance was sought that this would be kept in balance. It was noted that other issues included grid access, construction bases and support infrastructure would emerge at a later stage in the process. The importance of further contact between the Islay Energy Trust and the wider community and the developer was emphasised and it was noted that this should also involve fishing and other sectoral interests. Further consideration of how local businesses and the community can benefit from development, or at least be compensated for its impacts was also considered to be a priority.

Short Term Options - Argyll Array

3.201 Twenty six responses were opposed to the proposal for the Argyll Array, with a number of detailed views coming forward from community organisations and individuals who live on Tiree. To support the consultation process, a public workshop was held on Tiree on 16 September 2010.

3.202 The diagram below sets out the key issues raised in relation to the Argyll Array development.

Figure 13: Mapping of Views on the Argyll Array

Figure 13: Mapping of Views on the Argyll Array

Community

3.203 The most prevalent concern raised by both formal written responses and discussed in the public workshop was the effect that development could have on the culture and quality of life of Tiree. Many questions were asked about the impacts of offshore development and its onshore components on the island's environmental quality, infrastructure and community. One individual summed up concerns by noting issues including helicopter flights, road widening, buildings on crofting land, housing for workers (one third of the current supply) and eloquently envisaging : "A vast energy factory will deface the island's natural beauty and change its peaceful community forever." Some felt that the economic benefits would be limited to a small number of people, and that change could particularly impact on the elderly, families and young people, for whom quality of life was in question. Whilst some issues such as property prices were raised, the majority of views were quire fundamental, going as far as considering future viability of Tiree's population. Whilst the development is potentially of regional significance, sitting within national plan, some consultees emphasised that the majority of the impacts of the development will be on the proximate community of Tiree, and this must be recognised and addressed as a priority. This view was strongly supported throughout the public workshop on the island.

3.204 The community attending the workshop in Tiree were concerned that they had been largely 'scoped out' of the EIA scoping report. There were strong views that development on land arising from the offshore array would need to be considered within the assessment, and disbelief that the island's culture and people had not been referenced. This was viewed as essential, so that potential for mitigation measures, like managing construction to provide regular quiet periods, could be brought into the process. As with consultees in the South West and in Kintyre, people were concerned that the limited number of people in the island would reduce the weight given to their views within the overall planning process.

3.205 Concern was raised in the Tiree public workshop that current government guidelines for noise are outdated. It was noted that many acoustics companies are no longer relying on guidance due to its currency, however noted that this is what is being used to inform assessments. Questions were raised about the implications of infrasound on human health.

3.206 The Tiree Community Development Trust felt that the assessment should consider communities as living entities, recognising that the island's community is fragile with a unique culture that is more worthy of protection than some aspects of the natural heritage that are designated and therefore more fully recognised in the assessment. Comparisons were also drawn to St. Kilda, and the greater level of protection offered to relics of past communities, compared to the way in which living communities such as Tiree were viewed. This view was supported by those living on the island, regular visitors and respondents more widely. Words such as 'special case', 'unique', 'distinct' 'pristine' 'magical' and 'fragile' were repeatedly used to describe the island and its community. The size of the island was also noted, with some stating that Tiree would be unable to tolerate a level of change that could be more acceptable to larger islands.

3.207 Many individual responses supported this, and viewed the proposal as the industrialisation of the island. It was emphasised that the island's infrastructure cannot sustain major development. The Tiree Community Development Trust asked that the assessment considers more important aspects of population and health than its current focus on recreational activity. Specifically, it suggested consideration of local health services, traffic and safety, potential failure of the local housing market, impacts on crofting and fishing, under resourcing of education and low water and sewerage system capacity as key issues affecting the island's community. Demographic change and its potential for secondary effects on services, the community and the environment, was a key issue.

3.208 Many respondents felt that the development would swamp Tiree, and therefore suggested that the community should become part of the decision making process, through working with the development and Argyll and Bute Council to develop a masterplan approach or a pilot study. One individual called for an integrated plan to address the environmental impact of the project, whilst another felt that project specific modelling was required to build a more accurate picture of its effects. There was consensus within the Tiree workshop and amongst those responding individually to the consultation that a socio-economic impact assessment was essential to balance the needs of the community with the environmental issues already addressed in the SEA. However concern was expressed that any such study is likely to be strategic and will need to be supplemented by similar local level studies. The community felt the analysis should focus on impacts on Tiree, as opposed to the wider Argyll and Bute area, and should be undertaken by an independent party.

3.209 Support was given to the communities 'buying in' to the process, becoming part owners as opposed to simply passive receptors of its impacts. Several noted that benefits in the form of community funding would not suffice, but much more meaningful involvement was required. Some were interested in how opportunities to harness some benefits from the development, such as local harbour improvements, support for services and possibly employment creation could be secured partnership working. One suggested that the community be afforded statutory stakeholder status to enable their full participation in the process.

3.210 At the Oban workshop, questions were raised as to whether there would be any compensation for those who are impacted most seriously, with particular reference to Tiree, and it was noted that there is a need to consider community compensation and / or benefit if the proposed developments go ahead.

3.211 Impacts on tourism were a key concern. This was viewed as a key part of the island's economy, but it was noted that visitors come to enjoy peace and quiet, exceptional land and seascapes, wildlife and culture. All of these were viewed as being in jeopardy as a result of the development. As one islander put it: "How many people will travel 4 hours in a ferry to spend their time and money at an industrialised work-site? Islanders have put a major investment into building up their holiday home businesses (2,500 beds). These businesses are currently sustainable and a vital source of income." Impacts on key characteristics including lack of pollution, tranquillity, dark skies and Hebridean island and Gaelic culture, were viewed by many as sufficient reason to remove the site from the plan.

3.212 At the public workshop, it was reported that 60% to 70% of the island's tourism is based on watersports including surfing, wind surfing and kite surfing. Questions were asked about the impacts of the development on these activities, and consequently the island's tourism industry. Previous surveys addressing the impacts of wind farms on tourism were not considered to be relevant, given the much greater scale and density of turbines proposed off Tiree.

3.213 Impacts on surfing were raised by communities, businesses and organisations. Notably, Sportscotland expressed great concern about the impact of the development on the Tiree Wave Classic, calling for more information on the likely impacts on coastal processes and waves.

Cultural Heritage

3.214 Cultural heritage was raised as an issue by the Tiree Community Development Trust, in term of the community's living culture, but also in relation to onshore archaeology. Historic Scotland supported this view, noting that the proximity of the development to the southern tip of Tiree could suggest impacts on the setting of a number of coastal fortifications and early church sites. As a result, it was proposed that further work was undertaken at the project level in line with the recommendations within the Environmental Report on turbine locations and scheme design. Links were made with the cultural heritage of the island's people by many consultees, and raised in the public workshop on Tiree. It was noted that EC and UN legislation afford protection to minority groups. Participants also noted the increasing recognition of the value of historic sites on and around Tiree, and stated that the EIA should investigate and mitigate impacts on marine archaeology. There are 14 known wrecks around the island.

Landscape, seascape and visual impacts

3.215 Impacts on landscapes and seascapes were raised repeatedly, with the Tiree Community Development Trust noting the relative proximity to shore and larger size of the proposed turbines, as compared Skerryvore lighthouse. Individuals from the island were supported by those from further afield who valued Tiree and the broader West region for its scenic quality and expressed concern about the impacts arising from development of the scale proposed.

3.216 In terms of visual impacts, at the public workshop people noted that the turbines would be taller than the highest point on Tiree. People were disappointed that they had not had sight of photomontages for the project, and this was reinforced in a number of subsequent individual responses. Within this, there was concern that in selecting viewpoints, some of the most sensitive areas would be missed, and the community were considering preparing their own visualisations as a result. Some called for visualisations to be produced and discussed within a public forum - it was viewed as insufficient to rely on information from other sites of a less significant scale and density.

3.217 People questioned the methodology for visual and seascape assessment, and asked why Tiree did not fall within the category of a high sensitivity seascape. There was disagreement with the terms of the guidance in this respect, and people sought clarification of the methods and definitions used. Differences between objective landscape or seascape impact assessment and more subjective visual effects were discussed.

3.218 Linking with this, values such as tranquillity and the unspoiled character of Tiree were mentioned by several consultees. SNH, however, contended that at this stage the SEA may have overestimated the landscape and visual impacts of the Argyll Array, withholding fuller judgement until the scoping response for the project had been received and analysed. Regardless of views, the community called for further information to be provided by the developer at an earlier stage to allow for a more informed discussion.

3.219 The Tiree Community Development Trust asked for clarification as to why the short term options were closer to shore than the medium term options, and specifically for information on the constraints that limited the proximity of area W2 to shore.

Other environmental issues

3.220 The ecological qualities of the island were raised, and considered to be vulnerable to development of this scale in this location. Its status as a SSSI and importance for corncrake, migratory birds were raised. Underwater noise effects on basking shark, whale, dolphin and other marine wildlife were mentioned. Onshore impacts and implications for the machair was highlighted as a key concern requiring further assessment. Further information was provided, including data on basking sharks in the vicinity of the site. The RSPB stated that the SEA should consider potential impacts on wintering, breeding and migratory birds at an international scale, including species such as Greenland white-fronted geese. Cumulative impacts from the short and medium term options in this area were also a concern. At the public workshop evidence relating to Norfolk seals was raised and questions were asked about the extent to which candidate Natura were given the same level of protection as sites that had been designated.

Technical issues

3.221 Technical issues arising included to the possible constraint of the Argyll Array site's geology was noted. Questions were asked about impacts on air traffic control, and the potential effects of the development on the island's weather. Consultees sought reassurance that these matters had been adequately addressed by the SEA. Shadow flicker and light pollution were also raised.

3.222 Fishing was raised as a concern, with the Tiree Community Development Trust suggesting that this should be fully assessed, especially potential impacts on local fisheries. It emphasised that small boats with static gear are more closely fixed to operating port and local waters, and could therefore be more vulnerable to loss of income if development occurs in their area, as compared with more mobile, bigger boats. Opportunities for mitigation, including phasing to allow fisheries to move during construction, were raised.

3.223 As with other areas, quite fundamental questions about energy policy were raised by respondents who were focusing on development at Tiree. It was stressed that, if the development were to proceed, its impacts could call into question the sustainability and credibility of the Scottish Government energy policy overall. Some suggested that the policy was being implemented at too fast a pace to allow for full and proper consideration of its impacts.

3.224 As with Kintyre, many people noted and concurred with the conclusions of the SEA that the development was likely to have significant adverse effects, and therefore questioned why the project had nevertheless been taken forward within the Draft Plan. There was a degree of scepticism associated with the extent to which options within the Plan were genuinely open for debate. There was consensus that the development should only proceed if there was consensus amongst the islanders (one suggested a referendum), and full engagement in decision making.

3.225 Several individuals and the Tiree Community Development Trust noted the importance of assessing the aggregated impacts of the short and medium term options. It was noted that, should it proceed, the Argyll Array could become a centre or base for the construction of other options in the medium term, specifically areas W1, W2 and NW4. As a result its cumulative effects could be expected to be significant.

Consultation and Decision Making

3.226 Respondents seemed unconvinced that mitigation would either be taken forward for the scheme, or that it would be effective. One mentioned that acknowledgement by the developer to date had been targeted at the island's fishermen and not the community as a whole. The same respondent also expressed concern that there is a lack of a regulatory body to impose mitigation measures on developers. The proposal was considered to be of a density and impact ration which was incomparable to any other development in the UK or Europe. It was contended that such a development could only arise from a policy making process which excluded the proximate community from any representation in the formal consultation process.

3.227 Questions were asked about the consultation to date, specifically the extent to which the whole community and groups such as the crofters had been included. Local people were concerned about the limitations of consultation at both the plan and project level, and viewed further working with the developer as an essential requirement. Views on the methods for engagement in the Plan varied - some respondents felt that the questions asked too much of consultees, whilst others provided lengthy responses and welcome the open nature of the debate.

3.228 The approach to consultation on the Plan was also discussed in the Tiree workshop. People were concerned that decisions had already been made on the principle of the development, and clarification that no decisions had been made on any of the options was welcomed. The community felt they needed to be more fully aware of the on and offshore proposals and their impacts before they could provide a meaningful comment on them. There was also consensus that the community of Tiree should be regarded as a statutory consultee within the process, fuelled by frustration with current limitations on their inputs. People were also seeking further information on the decision making process at the project level, and the extent to which an objection by the local authority could initiate a public inquiry.

3.229 At the Tiree workshop, further clarification of the licensing process was requested and people asked about the extent to which decisions would focus on the project area, or take into account the wider area including Tiree. People were also seeking further information on where responsibility for approving onshore developments would lie.

3.230 Broader issues were raised in the Tiree workshop about the timing of phases of development within the Plan. It was suggested that areas with least environmental constraints should be prioritised in the short term. Comments on the scale of development were also raised, with people suggesting that it would be preferable to initially develop smaller sites around Scotland that feed more directly into local areas of consumption.

Industry Perspective

3.231 A different perspective was provided by Scottish Power Renewables, the prospective developer of the Argyll Array. Whilst the Draft Plan was welcomed, concern was expressed about the level of uncertainty arising from the assessment at this level, and in particular in relation to the medium term priorities, technical constraints and the future evolution of the supply chain. As a result, SPR suggested that the Plan should present options in a different way to the spatial approach within the draft. This would ensure that mitigation is not suggested at the SEA, where there remain uncertainties in the assessment findings. In contrast, however, communities suggested that the assessment at this stage was essential to ensure opportunities were built into the scheme 'from birth.'

Medium term options

Other Technical Issues

3.232 The Chamber of Shipping raised concerns about site W1 and its impacts on shipping passing through the Minch, and area W4 and its impact on vessels entering the IMO route in the North Channel. The Maritime and Coastguard Agency echoed concerns about area W1 and its potential to restrict access to the Minch and recommended its removal from the Plan. It also noted, however, that it may be possible for developers to show that, given gaps or restrictions in operations, risk can be sufficiently reduced to permit other areas in the region to progress. The Northern Lighthouse Board also raised the same navigational concerns about areas W1 and W4.

3.233 Conflict of interest arising from area W4 with investment in infrastructure and the new quay for shipping wind turbines, marine, other commercial activity was noted by one respondent. It was explained that the Council's CHORD economic regeneration programme and EU Sail West scheme could be undermined by any development that impacts on the accessibility of the marina. Impacts of development on recreational boating and the new quay was also emphasised as a concern, with the suggestion that the eastern boundary of W4 could be drawn back and the site extended further west.

3.234 Areas W1 and W4 were also raised as concerns by the MoD as potentially impeding naval operations in direct support of national defence requirements. It therefore requested their relocation or re-examination. W4 also emerged as a concern for aviation by Infratil, operator of Prestwick International Airport.

Other Environmental Issues

3.235 Historic Scotland provided comments on the medium term options in the area, including to note that the proximity of area W1 to the southern tip of Barra suggests that there may be impacts on the setting of coastal scheduled duns and Barra Head Lighthouse. As a result project level assessment and mitigation will be required. The location of W4 between islands and the mainland also suggested to Historic Scotland that there may be potential impacts on the inter relationships between South Arran, Sanda, Ailsa Craig, Kintyre and Ayrshire coast that need further consideration. Sightlines to, from and between these sites are important for a number of historic environment assets in the area. Recommend this is explored at project level. Some individuals also considered W4 to be located too close to the coast, generating significant visual and seascape impacts and resulting in loss of tourists to the area.

3.236 The RSPB provided detailed comments on the options in the region, expressing concern that these could exacerbate the effects identified for the Argyll Array, "with the a risk of cumulative potentially massive impacts on a range of species - particularly on populations of birds using the East Atlantic Flyway such as the whooper swan, Greenland white-fronted goose, Greenland barnacle goose, pale-bellied brent goose, golden plover, sanderling, turnstone, black-tailed godwite etc - as well as impacts on locally breeding birds such as corncrake (W1-W3) and locally breeding seabirds". Concern was also raised about cumulative impacts on birds attempting to travel through the Minch, including impacts on foraging trips of breeding seabirds from SPAs. The proposals were considered to potentially form a barrier across the Minch, resulting in displacement. It was recommended this is explored more fully in the HRA and reflected in the finalised Plan.

3.237 Several individuals also expressed concern about the impacts of some of the region's medium term options for a variety of reasons, most frequently visual impacts and tourism. Several of those who were focusing on other areas such as the South West, also mentioned general concern about development in this region, given its environmental quality and importance for tourism nationally. This included one respondent, for example, who raised concerns about the landscape and seascape impacts of areas W1, W3 and the area's short term options, and noted particular issues with W2 where views from Colonsay and wild land on Jura could be significantly affected.

North West Region

3.238 A smaller number of responses to the consultation focused on development in the North West Region, including 11 from the following organisations:

Chamber of Shipping
Comhairle nan Eilean Siar
Historic Scotland
Maritime and Coastguard Agency
Ministry of Defence
Mountaineering Council of Scotland
Northern Lighthouse Board
Royal Society for the Protection of Birds
Scottish Canoe Association
Scottish Environment Protection Agency
Scottish Natural Heritage

3.239 To support the consultation process, public workshops were held in Ullapool on 3 August, in Stornoway on 13 August and on Barra on 8 September 2010.

3.240 The key issues raised in this region are summarised in Figure 14 below.

Decision making

3.241 The Comhairle nan Eilean Siar (Western Isles Council) provided a detailed response relating to developing in the region as a whole. It proposed that the approach within the Plan was insufficiently flexible to allow development to progress at different speeds, and sought higher prioritisation of development in the area in the short term. It did not wish to see any options removed from the Plan and explained the importance of the renewables sector to the economic future of the Western Isles.

3.242 At the public workshop in Stornoway, concerns were raised that the local authority's views could be ignored. People at this event were also critical of the consultation process, and reported feeling disengaged from the process. People felt that priorities should be revisited, as other factors appear to be overshadowing the views of people. As in the West Region, some consultees felt that the planning process was being progressed too late, after the 10 exclusivity agreements for the short term sites had already been granted. Questions were asked about links with and between national and regional marine plans, and consideration of Marine Protected Areas.

Figure 14: Mapping of Views on the North West Region

Figure 14: Mapping of Views on the North West Region

Fishing

3.243 Fishing impacts were a concern of regional significance. Overlapping with comments on the West Region, the Small Isles and Mull Inshore Fisheries Group raised concerns about most of the options in the Plan and noted the need for further detailed information and assessment to avoid adverse impacts on fishing. Concern was also expressed at a public consultation workshop in Ullapool (3 August 2010) about a perceived lack of adequate engagement with the fishing industry, and it was suggested that inshore fisheries groups and local fisheries offices were used as a channel to informing individual fishermen about the Plan.

3.244 Fishing was discussed at the Stornoway public event, and participants asked for fuller mapping of the productive levels of areas for fishing in relation to the medium term options. Concerns were raised that the impacts of renewable energy would add further pressure in addition to ongoing challenges for the industry, such as fuel prices. People suggested a common sense approach to exclusion zones, recognising the issues for different types of fishing activity. The need for further baseline information was noted.

3.245 Fishing was also a key issue discussed in the Barra event. People suggested that as fishermen have historically had harvesting rights in the water column, should similarly be entitled to a share of the profits from harvesting wind power in the area. It was suggested that these benefits should have been identified prior to areas being identified, as proposals may change the value of the seabed and therefore impact on whether the community is able to own it.

3.246 SEPA noted that there was potential for option NW8 to result in the downgrading of Water Framework Directive status and would need further assessment, and / or further justification on the basis of there being no other options and socio-economic benefit.

Landscape, seascape and visual effects

3.247 Concerns about visual and seascape impacts were noted in the Stornoway workshop, with implications for tourism. It was emphasised that tourism is growing in the Western Isles in terms of surfing, sailing and sea kayaking.

3.248 Some views focused on the recreational use of the area. The Scottish Canoe Association noted that kayaking could be particularly affected by development of the sites near St. Kilda, Foula (in Shetland) and North Rona, and asked for further opportunities to comment at a later stage.

3.249 The Mountaineering Council of Scotland expressed concerns about some specific areas (see below) and stated that wild land should be given further consideration through further mapping, given the importance of these areas for tourism and in view of the lack of coverage of this characteristic within the National Scenic Area ( NSA) designation. It suggested that this is required before any of the options in the area are taken. It was noted that the value and qualities of areas for tourism could not be judged by the numbers of visitors to areas - in many cases the quality of their experiences in the north west is high due to qualities such as wildness, and loss of this will be more significant than in areas of lower sensitivity, regardless of numbers of people affected. This view was supported by a number of individuals who emphasised the special qualities of the region for tourism and recreation, noting qualities such as scenic value, tranquillity, wildness, and remoteness, as being important. As with the West and South West Regions, the dark skies of the area were also noted.

3.250 Other key issues raised at the public workshop event in Ullapool included potential for visual impacts on people living near the site, recognising that perceptions can be very subjective. Specific points were also made in relation to the medium term option area NW6. Questions were raised about the timescales for the options, focusing in particular on area NW6, and it was clarified that it was unlikely development in this area would arise for several years. The group also requested that further consideration be given to grid connection options for this region.

Other environmental issues

3.251 The RSPB expressed concern that the Draft Plan had not acknowledged the large numbers of resident and breeding, internationally important bird populations in the region. Concern was noted about potential impacts arising from the medium term options on these species. It was recommended that greater consideration is given to potential impacts on Icelandic passerine migrants and Scandinavian migrants moving around the north of Scotland.

3.252 SNH concurred with the suggestion in the consultation questions that there were relatively high concentrations of environmental constraints in this region. In particular, the high number of Natura designated sites with qualifying interests that could be affected by this type of development was noted.

Shipping and navigation

3.253 Further regionally significant issues also included shipping and navigation. Again, many of the key points related to specific sites, but detailed responses were received from the Chamber of Shipping, Maritime and Coastguard Agency ( MCA), and Northern Lighthouse Board. Several options raised concerns about important shipping routes, although some of these views were balanced with a recognition that there should be scope for mitigation at a project level, through gaps or restrictions in operations. However, a regionally significant issue emerged in the form of concerns about access to the Minch from both the north and south, that will need further consideration should all of the options in this region be taken forward.

3.254 Navigation issues were also raised at the Stornoway workshop. People felt that there is a need to consider shipping and navigational safety, as some of the options seem to interfere with the traffic separation scheme from the Butt of Lewis to Cape Wrath. The importance of consulting the MCA for local information on navigation was emphasised, and confirmation was given that this will be dealt with in the licensing process.

Other Technical Issues

3.255 The Ministry of Defence raised some further issues including the need to consider air traffic control radars at St. Kilda and South Uist, as these could become a constraining factor for development. Similarly, the Drium-A-Starraid Meteorological Weather Radar near Stornoway would require further assessment.

3.256 The grid was also raised as an issue in the Stornoway workshop. People felt that there is a need to ensure that there is available grid connection, and questions were raised as to whether this had been considered in the process of identifying the short term sites. It was noted that there is a group looking at a strategic plan for the National Grid. Questions about the responsibility for grid upgrades were also raised in the Barra workshop.

3.257 At the Barra public workshop, surprise was expressed that the Plan had included short, medium and long term options as it was presumed that wave and tidal will take over in the long term and that wind is only a short term solution. As in the West Region, people highlighted opportunities to combine these technologies in the future and suggested this is given further consideration.

Medium Term Options

3.258 In terms of specific comments on the medium term options, the following specific views were recorded:

Site

Comments

NW2

  • The West of Four Fisheries Management Group ( WOFFMG) concerned about impact on fisheries.
  • Historic Scotland agreed with assessment of impact of this option on St Kilda WHS.
  • Area of exceptional landscape and seascape quality.
  • RSPB surprised that effects on birds not expected to be significant, given proximity to SPAs. Potential barrier to species migrating from Iceland was noted.

NW4

  • May affect naval operations in direct support of national defence. Dimensions may require amendment and further consideration at the project level is needed.
  • Northern Lighthouse Board and the Chamber of Shipping concerned about potential cumulative impact on shipping through the Minch.
  • WOFFMG concerned about impact on fisheries.
  • Area of exceptional landscape and seascape quality.

NW5

  • May affect naval operations in direct support of national defence. Dimensions may require amendment and further consideration at the project level is needed.
  • Northern Lighthouse Board and the Chamber of Shipping concerned about potential cumulative impact on shipping through the Minch.
  • WOFFMG concerned about impact on fisheries.
  • The Stornoway workshop noted a high number of smaller fishing vessels operating in this area.
  • Mountaineering Council of Scotland concerned about the impact of this option (parts nearest land, impacts on wild land / high sensitivity seascapes).

NW6

  • In proximity to sensitive MoD acoustic range facilities in Danger Area D71 near Rona. MoD extremely concerned about location and extent of zone, suggesting relocation.
  • Northern Lighthouse Board and the Chamber of Shipping concerned about potential cumulative impact on shipping through the Minch.
  • WOFFMG concerned about impact on fisheries.
  • Mountaineering Council of Scotland concerned about the impact (parts nearest land, impacts on wild land / high sensitivity seascapes).
  • This area was raised as a concern by an individual as a result of its location in an area of exceptional landscape and seascape quality.
  • People attending the Ullapool workshop also noted the importance of the area as a route for cetaceans, with the area around Skye being frequented by basking sharks. It was also stated that the area could pose problems for fishing as it is an area which is used for trawling.
  • It was noted that the area is known for Nephrops in the Stornoway workshop. There are also a lot of smaller vessels operating in this area.

NW7

  • Will impede naval operations in direct support of national defence requirements. MoD request it is relocated or its dimensions re-examined.
  • Chamber of Shipping expressed concern about impact on shipping through the Minch. The site also impacts on traffic using the west coast deep water route and Atlantic traffic.
  • Maritime and Coastguard Agency suggest removing the site to permit safe access to ships.
  • Northern Lighthouse Board noted with concern potential cumulative impact on shipping through the Minch and noted that the site also has an impact on traffic using the West Coast Deep Water Route and Atlantic traffic.
  • WOFFMG concerned about impact on fisheries.
  • Mountaineering Council of Scotland concerned about the impact of this option (parts nearest land, impacts on wild land / high sensitivity seascapes).
  • This area was raised as a concern by an individual as a result of its location in an area of exceptional landscape and seascape quality.
  • RSPB noted that the western arm of the area could form a barrier across the main arrival point for Whooper swans, Greenland geese species and other waterbirds migrating from Iceland in autumn, given that this is the shortest sea crossing route.
  • A possible increase in mobile gear activity was noted.

NW8

  • WOFFMG concerned about impact on fisheries.
  • Historic Scotland noted that this area is centred on north Rona. It contains the scheduled early monastic site of St Ronan's church, and remoteness contributes to its setting. As a result, project level assessment and mitigation is required.
  • RSPB surprised that effects on birds not expected to be significant, given proximity to SPAs. Potential barrier to species migrating from Iceland was noted.

Question 5: Are there other options we should consider in the medium or long term?

3.259 This Question invited views on other options that could be considered over the longer term.

3.260 Some respondents suggested that other technologies, specifically wave and tidal would be better options in the long term. Wave and tidal in areas closer to the end user were suggested as an 'ideal' alternative. A large share of those supporting tidal energy were referring to the South West region, with many mentioning the possibility of a Solway tidal barrage as a greatly preferred option to offshore wind.

3.261 The RYA asked that the relationship between floating wind farms in the longer term, wave and tidal be thought through. This was based on concern about the cumulative impacts arising from neighbouring renewables developments, but also the opportunities arising from possible sharing of facilities such as power connections to minimise infrastructure requirements. Other consultees debated this further, noting that marine planning should consider which areas would be best suited to different types of renewable energy generation. This was based on an assumption in some cases that one type of installation could preclude the others.

3.262 Hydro, land based wind power, carbon capture, hydrogen and nuclear options were also raised. Many noted that energy efficiency and reducing consumption would be preferable to any generation methods.

3.263 Responses noted uncertainty over the longer term, and the need to keep an open mind about emerging technology and options which are not currently apparent but could become practicable in the future. Several felt that it is likely, with some, such as VisitScotland noting that the review process should reflect these. References were made to new areas arising in deeper water, the use of floating turbines and the use of shared infrastructure such as grid connections. This linked to comments throughout the responses about developments being 'in-shore' rather than 'offshore' and expressing a preference for the latter within the Plan.

3.264 Some noted that other areas that were not currently viewed as options at present should not be ruled out at this stage as they may offer good opportunities in the future. They suggested that it cannot yet be concluded that they are unsuitable on the basis of information gathered to date, just as conclusions about suitability remain difficult at this stage. Others asked for explanation of how ad hoc proposals are covered by the SEA. Fife Council noted that the Plan should be sufficiently flexible for new options emerging in the longer term to be environmentally assessed in a consistent way.

3.265 Scottish Natural Heritage recommended consideration of the demonstrator sites at Aberdeen and Methil, and that developer aspirations for new and emerging technologies including floating turbines were taken into account. They also noted this should be taken into account within the HRA.

3.266 Some respondents suggested areas with highest wind speed should be prioritised. These tended to be those who were opposed to development in the Solway where wind speeds are considered lowest. Dumfries and Galloway Council specifically noted the low wind speeds in the Solway, as shown in Figure 5.1 of the Environmental Report.

3.267 Fishing sector respondents recommended that areas with fewer sensitivities for fishing would be preferable. Some respondents from this sector were quite clear that there were no other suitable options, including the Scottish Fishermen's Federation and fishing interests in the North, who noted that Shetland's waters were already largely filled with development options. However, it was also suggested that the fishing industry should have further dialogue with Marine Scotland, to help identify less sensitive areas (specifically referring to the South West).

3.268 Comhairle nan Eilean Siar felt strongly that some of the options in the North West should be considered and assessed as possible short term options. A developer also requested the inclusion of a specific demonstration site within the plan (Firth of Forth / Musselburgh Bay).

3.269 Argyll and Bute Council felt that if the SEA was robust, it should be regarded as the appropriate means of identifying development options. It also noted the many uncertainties at this stage and the difficulty with forecasting development in the medium to long term. Some consultees preferred medium term options over short term options. This included sites in the South West (in preference to Wigtown Bay and Solway options) and Argyll and Bute Council's support for area W4 in preference to Kintyre in the short term.

3.270 Aberdeen City Council asked for clarification as to whether the 25 options constitute the total potential of Scottish Territorial Waters, or are simply the most appropriate sites to focus on in the short term.

3.271 Some novel locations were also suggested by some individuals, including along major transport infrastructure (M74), on the tops of high buildings in cities and making better use of MoD land where access and visibility are currently restricted.

Question 12: The Draft Plan has identified environmental and technical issues in the north and north west regions of Scotland, in particular. It may therefore be reasonable to give further consideration to these regions. Do you think that development in these regions, or individual options within them, should be given lower priority or perhaps deferred to the long term?

3.272 Several consultees restated views they had already put forward in response to the fourth consultation question. This included lobbying to remove Kintyre and the Argyll Array and further comments on development in the South West, as discussed below.

Support for deferring options

3.273 Eight consultees agreed that development in the North or the North West could reasonably be deferred. The Scottish Fishermen's Federation felt that these areas could be given lower priority, if it is established that they would have a material effect on fishing activity, but noted that further information will be required to justify this. The WOFFMG also agreed. The Small Isles and Mull Inshore Fisheries Group also supported this approach, but noted a need for proper consideration of whether or not options should be dismissed on the basis of environmental issues identified.

3.274 An individual consultee pointed out that options in these areas may not be efficient as a result of the cost and problems arising from the required grid connections. As a result, further assessment of the strength of feeling about developments within these areas was suggested. Others considered that de-prioritisation of these areas may be feasible in the early stages, but that the longer term scope for development should be taken into account when opportunities for extending the grid network to support terrestrial wind farms were being considered.

3.275 The Scottish Boating Alliance felt that this area was one of Europe's last accessible wildernesses, and important for recreation and tourism. It felt that there was a case for placing projects in these areas lower on the list of development, to await further technical progress, including tidal generation. Its concerns also extended further south to relate to development of Machrihanish and the seas around the Mull of Kintyre. This was supported by one individual respondent who asked that development was deferred to avoid 'industrialising' the water.

Further information required to inform the decision

3.276 Several consultees responding to Question 12 suggested that further information was required before such a decision could be made. This included further analysis of the socio-economic effects of the Plan.

3.277 Some of these consultees felt that, until further investigation was undertaken, all regional options should be deferred. People called for more information on the efficiency of wind power as compared to other forms of generation, to help establish the need for this type of development. Some, such as the Argyll Renewables Communities, considered the short term plan to be ambitious enough, and noted the need for monitoring and evaluation before further decisions are made. NERL again pointed out that mitigation of radar effects can take considerable time to establish, and that case by case evaluation will be required regardless of location. Scottish Power Renewables felt that there was insufficient information at this stage to assess the medium term options, and were concerned that any prioritisation at this stage could increased pressure on other areas. Other industry representatives restated their views that specific spatial analysis should not be undertaken at this stage.

3.278 Historic Scotland felt there would be benefit in taking forward further work recommended in the Environmental Report, to allow for better decision making. SEPA would also support further assessment of medium term options in north of Scotland prior to finalising the Plan, and suggested deferral of these options to the longer term may be appropriate if this cannot be achieved within current timescales.

3.279 Scottish Natural Heritage concurred that there are greater environmental constraints in these regions, particularly given the high concentration of Natura sites within and around them and the number of European Protected Species known to occur. Given their views on the need for additional information to be built into the process, deferring these areas was recommended until MaRS constraints mapping was rerun to take account of SNH's concerns.

Development should not be deferred

3.280 However, several consultees argued strongly against deferring options in these areas in response to Question 12. Significantly, Comhairle nan Eilean Siar provided a strong steer towards maintaining the pace of the development, and contended that excluded areas would be short sighted. This echoed responses also provided by Orkney and Shetland Islands Councils which, although not specifically addressing Question 12, reflected strong support for development within these areas.

3.281 The Highland Council also disagreed with removing these regional options. They suggested that they should remain in the Plan, and be considered further the light of further information from monitoring and in relation to the grid. They suggested that, if appropriate, the options could be removed from the Plan in the future. Scottish Renewables and SSE Renewables acknowledged the need to give further consideration to wave and tidal energy developments in these areas, including their interaction with offshore wind.

3.282 The Maritime and Coastguard Agency agreed that these options should not necessarily be ruled out, but made reference to their view that there were significant issues with developments that could act as a barrier to shipping movements in and around the Minches.

Other regions proposed for deferral

3.283 Seven consultees argued for options within the South West to be deferred, instead of the North and North West. It was reiterated that all of the options in the area should await further information to emerge from the Robin Rigg Project. Some pointed out that the South West Region's significant environmental challenges warranted either deferral or removal of the options from the Plan. Some sought deferral until technology was available to develop wind farms further offshore. Overall, these consultees felt the Solway was expected to accommodate a disproportionate share of development within the Plan as a whole. Dumfries and Galloway Council suggested reprioritisation on the basis of windspeed, noting the disadvantage of the South West in this respect.

More general points on prioritisation

3.284 Some consultees raised more general points about prioritisation, suggesting that it would be logical to develop the sites with least challenges first. However, IEEM also pointed out that giving some options a lower priority could increase pressure on remaining areas to meet national renewable energy targets. Nevertheless others noted that more significant technical issues would increase project costs, providing incentive to review priorities on this basis.