4. COMMENTS ON THE SEA FINDINGS
4.1 This Section of the Report focuses on two questions that focused on the findings from the SEA. The first (Question 10) asked for views specifically on landscape and visual effects and the scope for mitigating them, whilst the second (Question 11) invited consultees to share their views on the assessment findings more generally, and on any other environmental effects that could usefully be taken into account.
Question 10: The SEA has identified that there could be significant adverse effects, from the Draft Plan as a whole, on Scotland's landscapes and seascapes. Measures for the mitigation of these effects have been identified in the SEA environmental report. Do you have a view on these findings? Do you think that the proposed mitigation measures will be effective? Do you have any additional suggestions?
4.2 A total of 72 responses focused on this question.
Regional perspectives on landscape and visual effects
4.3 Many consultees agreed with the findings of the assessment of landscape, seascape and visual effects. Several reiterated their views on specific developments. In particular, concerns were raised about the landscape, seascape and visual effects of the proposals for Wigtown Bay and Kintyre and also the Argyll Array. Consultees provided more detail on the factors that made these particular options unacceptable in their view, in terms of landscape, seascape and visual effects, including:
- Proximity to shore. This was perhaps the most frequently raised concern.
- Cumulative effects taking into account existing developments (Robin Rigg) and the other options within the Plan.
- Scale of development.
- Density of development.
- Industrial character of development.
- Impacts on iconic views.
- Impacts on sunsets.
- Secondary impacts on tourism enjoyment of an area.
- Proximity to resident populations.
4.4 Dumfries and Galloway Council provided detailed comments on the landscape and visual sensitivities arising from the Wigtown Bay development and were of the view that whilst relocation of the development further offshore would address these effects to some extent, it would also generate further impacts on vessel movements.
4.5 Also focusing on the South West, the Galloway Static Gear Fisherman's Association felt that the assessment of landscape impact was weak, and was unclear as to how mitigation could be delivered to address effects on seascapes. The Galloway and Upper Nithsdale Liberal Democrats Constituency Party shared this view and were concerned that the assessment had not covered the relationship between on and offshore developments, viewing the application of separate regimes to these elements as a significant issue. They were unclear how seascape mitigation could be achieved.
4.6 Argyll Renewables Communities felt that there were particular challenges arising from visual impacts on the West coast, taking into account its character and the importance of views from the coast and ferries. They suggested that additional mitigation could include reducing the number of turbines, addressing proximity to land and guidance on lighting.
4.7 Landscape and visual effects in other regions were also discussed. The North Berwick Environmental Trust was concerned about impacts on natural beauty and views potentially arising from development in the Forth, noting the likely severity of effects on the Bass Rock. The Trust was concerned about the impacts on locally important receptors including the relationship between the town and its seascape.
4.8 Fife Council felt that the effects of the Plan would be less substantial than those in the North and North West, and viewed the mitigation measures as sufficient to address the impacts in its region. Aberdeen City Council agreed that mitigation would be impossible given the scale of proposals and taking into account subjectivity of the viewers. It supported the recommendation for a further landscape capacity study but were unsure how effective this would be. It suggested using the European Offshore Wind Development Centre in Aberdeen to test and demonstrate issues raised in the SEA, and undertaken further research. This was a similar response to some other councils who suggested that additional research could be undertaken in areas such as the Western Isles, to increase the benefits from the industry in their area (see below).
4.9 Comhairle nan Eilean Siar felt that St. Kilda was the key visual constraint in their region and that this had been well covered in the assessment. It agreed that it is not possible to hide offshore wind infrastructure from sight, but also emphasised that the region's communities are open to sensible deployment of development at sea, given that they have always depended on the sea for their livelihood. It was noted, however, that community reaction to the visual effects of development would only emerge through further consultation at a local level. In contrast, an individual consultee felt that all development in this region, together with the West, should be deferred.
4.10 The Northern Ireland Environment Agency welcomed the broad mitigation measures for landscape and seascapes within the Plan, including the commitment to further work at the EIA level to address potential effects of options SW1, W4 and Kintyre on the Northern Irish Areas of Outstanding Natural Beauty. They also welcomed the recognition of WHS within the Plan but suggested that the restrictions applied to developments in the vicinity of St. Kilda WHS should equally apply to the effects of developments in the West on the Northern Irish WHS.
4.11 Some noted specific issues arising from a sectoral or interest-specific perspective. For example, the National Trust for Scotland stressed the importance of seascapes in relation to National Scenic Areas, and noted that there are gaps in information to support consideration of this issue, as many NSAs do not have management or development plans in place. It noted, however, that a number of its properties have outstanding coastlines which could be impacted by proposals for offshore wind.
4.12 Providing a slightly different perspective, the Royal Yachting Association Scotland explained that wildness is an important draw for recreational sailors and that views from vessel to shore are as important as view from shore to sea. They felt that mitigation of impacts on these areas and views would only have limited effectiveness. RYA also discussed options including reducing turbine height, but noted that this could generate higher numbers of turbines and therefore further environmental impacts. They emphasised that mitigation to reduce visual impacts should not undermine this safety driven limitation. It was noted that although wild the nature of some iconic views is likely to be lost, some man-made structures, such as lighthouses, have in themselves become iconic. It was therefore suggested that good design of structures could be part of mitigation. These views were also supported by the Scottish Boating Alliance.
4.13 An individual echoed this view, emphasising that landscape has already been heavily modified and responding to climate change should be a key issue for this decade. As a result, it was suggested that landscape effects should not be given undue influence on the Plan. Another considered that the effects of offshore wind turbines on seascapes would be minimal, and not be viewed as significantly negative.
Scope for Mitigation
4.14 Twenty nine of the seventy two consultees responding to this question felt that mitigation would be insufficient. In some cases, this was because the Draft Plan to date had not addressed their concerns about specific sites by excluding them. This included multiple responses from people who opposed Kintyre and Wigtown Bay on the basis of their landscape, seascape and visual effects.
4.15 Some suggested that reducing the proximity of some developments to the shore would be the only effective mitigation measure. They were concerned about the lack of measures within the SEA. Keep Wigtown Bay Natural referred to the SNH guidance on the matter, and were of the view that this recommended a minimum exclusion zone of 8km from the coast, and up to 13km of the coast was considered to be a sensitive area. Others felt that the 13km distance constituted an exclusion. In comparison, it was noted that the Wigtown Bay site is within 4km of the land and that visual effects would also be exacerbated by the aspect of the site. In response to these issues, the group felt that approach within the SEA to reserving mitigation to the project level was meaningless.
4.16 Several consultees felt that the only effective mitigation measure available at this stage would be removal of options from the Plan. Argyll and Bute Council felt that this should be done where cumulative effects were expected to be significant, or where there would be impacts on local landscape designations or socio-economic issues. Decisions on this should include consideration of onshore requirements and assessment of their impacts.
4.17 Historic Scotland welcomed the overarching approach to mitigation, and noted that this would involve positioning of sites within option boundaries to reduce their impacts. This was noted to be important when dealing with impacts on coastal historic environment assets, particularly on the West coast.
4.18 In direct contrast to this, developers were concerned that the SEA went too far towards identifying these effects and associated mitigation measures. Scottish Power Renewables, SeaEnergy Renewables, Seagreen, SSE Renewables, E.ON and the West Coast, and Forth and Tay Wind Developers Group all contended that project level mitigation should not be identified at the strategic level, as it would require specialist study in relation to project level EIA. The strategic measure suggested of removing options was not supported by several of these consultees. SSE Renewables, for example, emphasised the risk this would present to projects and asked whether this measure would apply only to medium term options, or also potentially to short term options. Scottish Power Renewables was also uncomfortable with any measures aiming to offset habitat loss at this stage.
4.19 Scottish Renewables summarised the industry views, by claiming that it was not necessary for the SEA to include EIA scale mitigation measures, as these would be explored further at the project level through developer surveys and assessments. They also felt that some of the proposed measures were not supported by evidence - for examples suggestions that navigation should be restricted without full knowledge of levels of use of routes. These shortcomings were viewed as problematic, given their potential to frustrate regional and site level studies, that would explore cumulative effects fully in any case. Scottish Renewables was also concerned about the statement that the 10 short term sites could proceed subject to mitigation, as it was based on incomplete information and insufficient detail at this stage.
4.20 The West Coast Offshore Wind Developer Group suggested that the assessment should be revisited in the light of updated guidance on seascape assessment issues by JNCC and SNH during the consultation period. The need for a flexible approach to distance was emphasised, again reinforcing the view that this is better dealt with at the project level. It was, however, recognised that there would be merit in considering scheduling and aligning mitigation measures on this basis, although SPR pointed out that this may be difficult in practice, taking into account wider issues such as weather. As a result, the Group suggested aligning assessments and implementation of strategic mitigation measures across UK boundaries. A co-ordinated approach was also welcomed by the Crown Estate, which offered to assist with its delivery.
4.21 Some wider consultees supported some of these concerns, with the Highland Council for example noting that whilst cumulative effects and associated mitigation measures needed to be explored, further detail on specific projects would emerge from later, more detailed assessment, allowing for further scrutiny at that stage. Similarly, Highlands and Islands Enterprise felt that mitigation appeared to be sufficient, but that local concerns about projects and more specific issues would require further work including continuing communications with communities.
4.22 IEEM felt that there should be a greater emphasis within the SEA on national and regional mitigation measures, as opposed to prejudging measures that would be better identified at the project level. In particular, it was noted that cumulative effects will increase as more consents are given, and so it would be useful to understand and address these at a regional or national level.
4.23 Others found it difficult to comment as they had been unable to identify any specific mitigation measures within the report. This included the Tiree Community Development Trust, which felt that there were only general references to measures. The SFF found the question confusing, referencing the Environmental Report that reserves mitigation to the project level.
4.24 Visitscotland was concerned that the mitigation measures do not address tourism impact. It suggested that measures should be developed taking into account local opinion, visitor views, numbers of people visiting landscapes and seascapes and designations. It felt that decommissioning and reversibility arguments were irrelevant, if the installations have a 50 year life.
4.25 Fishing interests were sceptical about the effectiveness of mitigation to address seascape effects, and were concerned that changes to the spacing and configuration of turbines could have negative or positive effects on fishing. The NFFO asked that these 'knock on' effects be taken into account as mitigation is developed.
4.26 Some consultees suggested that mitigation should take lessons from existing developments. One person pointed out that one of the most effective ways of addressing concerns about blight and public perceptions of negative effects would be to deliver the first few developments without generating adverse publicity.
4.27 Scottish Environment LINK provided detailed discussion of the Section within the Environmental Report focusing on mitigation. It felt that the measures identified were very vague, and suggested amending the Plan to provide further detail. Specific examples were provided, such as shutting down turbines on migratory routes. They also expressed serious concerns about the effectiveness of the identified measures, noting that there should only be reliance on measures which have been proven. However, the commitment to removing options on the basis of HRA findings as necessary and the commitment to continuing stakeholder liaison were welcomed. LINK confirmed it would be happy to continue communications with the Scottish Government and others to help avoid or minimise the environmental effects of the Plan.
Question 11. Do you have any other views on the findings of the SEA? Do you think that all the environmental effects (positive and negative) have been identified? Are there other issues that we should be taking into account in the preparation of the Draft Plan?
General Views on the SEA Findings
Sufficient information at this scale
4.28 Many of the respondents' views on the overall or specific findings from the SEA process formed an integral part of more detailed views on the spatial options, as described in detail in Section 3. However, a good proportion provided views on the assessment as a whole, in response to this specific question.
4.29 The Highland Council felt that the main environmental effects had been identified, but were unsure about how comprehensive the assessment was. They felt that future environmental assessments should be informed by experiences gained in implementing short term projects. Similarly, Visitscotland noted that more environmental and other effects will become apparent at the project stage. Several other consultees agreed that some of the early developments will provide important information for subsequent projects.
4.30 Fife Council felt that the assessment was sufficiently detailed, and that there would be opportunities to address outstanding issues within additional assessment work. Similarly, Aberdeen City Council agreed that many effects have been identified, but that there remain many as yet unidentified. As a result, they supported the recommendations for further work to address gaps, uncertainties and identified negative effects.
4.31 Historic Scotland acknowledged that much has been passed to the lower level assessments, given the scale of the Plan. They recommended outlining further thoughts on generic types of monuments requiring further consideration at the subsequent levels of assessment, and commented on specific options, as explained in Section 3. They suggested that fortifications, duns, brochs, lighthouses, ecclesiastical sites, chambered cairns, castles and A listed structures would be particularly sensitive to this type of development, requiring further information in lower level assessments. Others felt that cultural heritage could be assessed in more detail, to take into account sacred sights and culturally important views.
4.32 However, Dumfries and Galloway felt that there were significant information gaps, including on vessel movements, impacts on tourism and economic benefits. As a result, they felt that the SEA does not currently provide sufficient information to justify agreement of the short term options in principle. They recommended undertaking further, more detailed work, and contended that this could lead to a different conclusion. This view was supported by a number of individual respondents, some of whom felt that there had been insufficient long term study and that the Plan was being progressed too rapidly, without the benefit of a strong or comprehensive evidence base.
4.33 A similar view came from industry, although for different reasons. Scottish Renewables felt that it was inappropriate for the assessment to have referred to specific projects, and that its attempt to cover EIA level issues was unhelpful, as a greater level of detail was required. They agreed with the general scope of the impacts, but felt that restricting the material assets component of the assessment was a major shortcoming.
4.34 SeaEnergy Renewables felt that further explanation of the impact assessment methodology would be welcomed. They were concerned that the assessment criteria had been inconsistently applied within the assessment. They also asked for further explanation of some of the comments in Table 9.1 of the Environmental Report that sets out requirements for further work and for an explanation of how transboundary effects had been assessed.
4.35 SSE Renewables raised some presentational issues including the use of colours to illustrate different impacts in Table 8.1 of the Environmental Report. They also felt that the assessment should not assume that measures such as cable sharing would be feasible. They were concerned that fishing, military activities and aviation appeared to not have been properly considered under the heading of material assets, and asked for an explanation of why this had been the case (see below). Otherwise, they generally agreed with the scope of the impacts.
4.36 Some consultees asked that the assessment looks more widely to its broader context. For example, the RSPB felt that developments outside Scottish Territorial Waters, including around Northern Ireland, should be taken into account. This view was supported by consultees from Northern Ireland and England. The Northern Ireland Environment Agency suggested broadening of the SEA objective for cultural heritage to take into account sensitivities beyond Scottish Territorial Waters. It also recommended that the post-adoption SEA statement provides an explanation of how the SEA has taken into account the Giants Causeway and Causeway Coast WHS.
4.37 The need for the assessment to use flexible assumptions was noted by some consultees, recognising the fast pace of technological development. The North Berwick Environmental Trust, for example, asked that reference be made to the potential for turbines 150m in height to be referred to, and questioned whether there should be fuller assumptions underpinning the assessment that consider turbine size, design, numbers of blades and colours.
Requirement for Socio-Economic Assessment
4.38 Many of the people and organisations who responded to this question emphasised the need for further assessment of socio-economic effects to inform the Plan.
4.39 Respondents asked about the extent to which land and communities have been taken into account. Several respondents from Tiree, including individuals and the Tiree Community Development Trust, reiterated concerns detailed in Section 3 that there had been insufficient coverage of impacts on communities including their infrastructure, living environment and culture. Even people from further afield noted the distinct and special character of these unique communities, and expressed concerns that this could be adversely affected by development.
4.40 Others specifically requested more robust economic evaluation of the proposals. The Village at Machrihanish Dunes / Kintyre Development Company Limited felt that more detailed cost-benefit analysis was required, involving relevant interests and being independent in character.
4.41 The RYA Scotland asked for the assessment to be broadened to take into account the contribution which boating and sailing tourism makes to the economy (around £300 million). It was proposed that the socio-economic assessment should take into account future use of harbours, ports and slipways and consult with local users to identify gains and losses. Integrated Coastal Zone Management Plan for Loch Fyne was raised as an example of how shared use of areas by recreation and aquaculture could be achieved. The RYAS emphasised the need for the assessment to recognise that the west of Scotland is an internationally important yachting destination. It also noted the need to take into account impacts on surfing at Tiree. The Scottish Boating Alliance felt that most issues had been identified, but supported the views of the RYAS that further emphasis on the socio-economic benefits of recreational boating, including income and employment in remote areas, should be considered. Used of harbours, ports and slipways was also a key concern.
4.42 The Scottish Canoe Association raised potential impacts of development on sea kayaking and surf kayaking, with particular concerns about safety issues. Visual impact was also a concern, and impacts on surf beaches. They felt that landfall infrastructure should be covered more fully. Whilst generally supportive of the SEA overall, they were keen to have continued involvement in the next stages of the work.
4.43 Taking forward an issue raised by some industry representatives, The Scottish Fishermen's Federation stated that fishing should have been assessed as part of the SEA. The Small Isles and Mull Inshore Fisheries Group objected to fishing being labelled as an environmental problem, noting that it can be sustainable when competently managed. They felt that the options demonstrated a lack of sufficient consideration of fishing issues and disagreed with the conclusion of the assessment that exclusion zones would preserve fish populations. They noted that whilst some benefits may arise from removal of trawling activity for biodiversity and cultural heritage, it was important to note that other areas are likely to receive additional pressure as a result of displaced efforts.
4.44 The NFFO referred to their response to earlier questions on mapping information and concluded that the identified gaps meant that fisheries issues could not all have been covered in the assessment. They emphasised that the Irish Sea is naturally constrained by topography and was therefore likely to suffer disproportionate effects. The effects on fishing in the south west were also expected to be increased by the irregular coastline and restricted distribution of seabed habitats in the area. They expressed concern that multiple rounds of wind energy development, proposals for marine conservation zones and Marine Protected Areas, and proposals to limit fishing by the Isle of Man would all have cumulative effects on fishing in the Irish Sea at a time when the fleet is already under pressure. They explained that focusing only on current and recent fishing activity would fail to capture the importance of these grounds and the associated issues.
Further Environmental Effects
4.45 Scottish Environment LINK provided an extremely lengthy response that detailed numerous environmental issues requiring further consideration. They expressed disappointment that they had not been engaged during the development of the Plan and noted the contribution which could be made by the Marine Strategic Studies Forum to the process. They also called for further detail on the environmental effects of development to be better framed within the context of relevant legislation, including the Marine and Coastal Access Act 2009 and the Marine (Scotland) Act 2010. Reference was also made to the requirement for good environmental status to be met by 2020 and set out the descriptors for this of relevance to the Plan and SEA.
4.46 LINK helpfully provided a summary of their views on potential effects. This very detailed information provided clarification of effects not covered in the SEA (carbon fixation by marine ecosystems), corrected some specific information on detailed environmental baseline characteristics, and highlighted areas where more research is required. Key messages included the need to recognise the forthcoming designation of Marine Protected Areas.
4.47 The RSPB provided a detailed response, that highlighted a number of further biodiversity related issues. They felt that collision risk arising for migratory and passage birds should be more fully addressed, taking into account the common factor of low visibility at sea. Further baseline characteristics were also described including Marine Protected Areas, proposed marine foraging SPAs and further reference to existing environmental problems. This included massive reductions in biomass of plankton in the North Atlantic, which has consequences for fish, birds and cetaceans. Details were provided on knowledge gaps. Coverage of the network of Important Bird Areas ( IBAs) was welcomed.
4.48 The RSPB also noted that the benefits identified in the assessment needed further qualification. Climate change benefits are likely to arise in the very long term, and it was suggested that they should be removed as they cannot be assumed. Similarly, they felt that habitat creation may not necessarily take place. Perhaps most fundamentally, the RSPB asked for clarification on how the precautionary principle has been applied in the assessment.
4.49 Other environmental effects were raised by consultees, for further consideration:
- Munitions were repeatedly raised as an issue requiring further consideration, reflecting health and safety concerns and taking into account associated pollution.
- Shadow flicker and associated health effects. Comments were made about the sun being low in winter, and bright sunsets in summer.
- Coal extraction, mining, tunnels and subsidence were specifically raised in relation to the Kintyre site. Also with regard to stability of structures, some suggested further coverage of geological fault lines and the likelihood of seismic activity.
- Noise. References were made to a report generated from the experience of wind farm in Newquay, suggesting a 1.5km buffer between wind farm developments and homes. Argyll Renewable Communities ( ARC) also asked that current evidence on noise effects were incorporated into the assessment.
- Overall need for and impacts of the scale of development proposed. For example, one consultee asked why Scotland should be subsidising other nation's inability to generate energy from renewables.
- Project specific visual impacts. Some consultees were particularly concerned that they had not had sight of photomontages for specific schemes - notably Tiree residents who expressed significant concerns about the impact of the Argyll Array. They felt that comparisons with smaller scale, lower density developments were not relevant.
- Bats. This was viewed as a serious omission given international status. One consultee stated that curtailment periods should be a requirement to mitigate mortality risk, and noted that this is being tested in other countries and could be achieved at a low cost.
- As with responses to other questions, the wind industry representatives felt that the assessment should be more regionally focused than site specific.
- Effects on wading birds and migratory birds could be covered more fully.
- Some people felt that technical aspects required further explanation, addressing issues such as energy efficiency, the cost of power, origins of employments, and implications for the national grid. Other asked for further information on the project lifespan and overall carbon footprint.
- NERL stated that radar, voice communications and navigational aids should be addressed within the assessment.
4.50 Onshore impacts, including power lines and transfer stations, were also raised as a key issue requiring further consideration. IEEM felt that it would have been useful for the assessment to identify the grid connections proposed for short term options, given that cable routing may impact on benthic and shoreline ecology. Argyll and Bute Council sought greater coverage of cumulative effects of on and offshore developments, particularly where developments are close to shore. Many others, focusing on issues in the South West, noted that cumulative effects of on and offshore developments, should take into account developments at all scales, ranging from large on shore wind farm developments to small scale installations on farms.
4.51 The Northern Ireland DETI pointed out that the Environmental Report does not go as far as considering the cumulative effect of the Plan with other developments proposed throughout the UK. This was tackled in the Northern Ireland Offshore Renewables Report, and mitigation identified included liaison between relevant devolved and UK administration and the Republic of Ireland. They would welcome further discussion of the matter.
4.52 Natural England expressed concern that environmental assets in England could be impacted by developments in Scottish Territorial Waters. Concern was expressed that this had not been adequately assessed in the SEA, and stated that it must be considered further as the Plan is implemented from the short through to the long term.
Comments on Requirements for further Assessment, Research and Liaison
4.53 Some comments were made about the objectives and priorities for further research. IEEM suggested that a more detailed and firmer commitment should be made to this work, with Marine Scotland championing this process. They also recommended collaboration between the Scottish Government and DECC to address key gaps, and felt that a roadmap should be developed to guide the process. Scottish Environment LINK also raised major points in relation to the need for further information gathering to be undertaken to provide a sound evidence base and address known gaps. A long, but not finite, list of research priorities was provided in the LINK response.
4.54 SEPA welcomed the recognition within the assessment of a need for robust monitoring to be undertaken throughout and after the construction process.
4.55 Comhairle nan Eilean Siar noted a dearth of data about the marine environment in their region, and that further work is required in advance of marine renewables development. In particular, they were concerned about availability of information on the occurrence of marine mammals and the possible impact of turbines on them, including acoustic issues. They felt that this work could be undertaken locally, providing further local benefits from the industry.
4.56 The RYA supplied its position paper on minimising the impacts of marine renewables on recreational sailors, and suggested this should be built into mitigation of the developments.
Habitats Regulations Appraisal ( HRA)
4.57 The RSPB felt that the treatment of Natura sites in the assessment was confused and noted that this must be addressed in the HRA. Further information on the HRA was also requested and it was recommended that issues raised in the assessment, including additional survey requirements should be prioritised and fast tracked. The need to renew surveys for offshore seabirds and cetaceans was noted, and the RSPB noted that it was important that developer data collection was properly targeted.
4.58 Similarly, Scottish Renewables felt that it was regrettable that no HRA had been prepared alongside the draft Plan, and offered to provide advice on this part of the process. Scottish Environment LINK shared this view and noted that the HRA should consider effects on important seabed habitats i.e. those identified as Priority Marine Features, and noted that the areas of focus suggested in the Plan were not viewed as a comprehensive list.
4.59 The robustnesss of the HRA was a key concern shared by industry representatives and others including Highlands and Islands Enterprise. SSE Renewables emphasised the critical importance of the HRA and asked that it be progressed as soon as possible, suggested that a staged approach would accelerate the process. They were concerned that options may be removed from the Plan on the basis of the HRA and asked to be engaged at this stage.
4.60 The following two diagrams summarise the key issues raised in relation to Questions 10 and 11 in turn.
Figure 15: Mapping of Views on Landscape, Seascape and Visual Effects
Figure 16: Mapping of Views on SEA Findings