5. COMMENTS ON THE OVERALL APPROACH WITHIN THE PLAN
5.1 This Section of the report sets out views on the overall approach within the Plan. If focuses on four key questions:
- Question 6, which asked for ideas on how the Plan could be improved,
- Question 7, which invited opinions on the scale and pace of development,
- Question 8, asking for views on the balance between social, economic and environmental issues in the Plan, and
- Question 9 which focused on the proposal of a 2 year review period for the Plan.
5.2 The responses to each of these questions is explored in turn.
Question 6: How can the Draft Plan be improved? What should be taken forward differently and why?
5.3 Overall, some respondents felt that the Plan needs to be improved before being adopted, whilst others felt that it could be left to the review stage. Many acknowledged that the Draft Plan was the starting point in a longer term process of planning and environmental assessment.
Regional versus site specific approach
5.4 As noted in earlier sections, many of the industry responses focused on the level of detail and criticised the project specific approach. The majority of industry respondents felt that the focus on options had blurred the boundary between consideration of environmental issues within SEA and EIA and recommended a higher level or more regionally focused approach. Scottish Renewables suggested that the approach taken incongruous with its national coverage. They felt that this had caused confusion amongst consultees, as was apparent during consultation workshops in some areas. They argued strongly that detailed assessment and mitigation was more appropriately dealt with at the project level, by developers. They expressed concern that the findings of the SEA could conflict with the EIA process, with potentially onerous implications for developers.
5.5 Scottish Renewables also suggested that the Plan would benefit from further detail on how additional data will be gathered, including timing, responsibility for actions and resourcing. This view was shared by others, such as Highland Council which suggested an additional section on implementation that sets out the role of Marine Scotland and partner organisations. The Crown Estate considered it was willing to work with the Scottish Government to agree areas of responsibility, identify additional action and leads.
5.6 These broad industry views were supported by groups of developers and individual industry responses. The Forth and Tay Wind Developers Group felt that uncertainty at this stage could lead to incorrect or misleading conclusions. Scottish Power Renewables felt that the focus on short term options was too narrow. Other developers felt that the Plan should be more flexible to allow projects to be taken forward in areas lying outside those identified as options. Future Electric argued that other areas may prove to be suitable as a result of more detailed information, and their exclusion from the Plan may unnecessarily blight their development.
5.7 SSE Renewables felt that being clearer about uncertainties at this stage would go some way towards addressing concerns. In particular, it was suggested that there should be transparency about disparities between the availability of data on different receptors. As with other consultees, they suggested that regional options would have been better, or consideration of alternatives that better reflect a high level strategy.
Timescales and phasing
5.8 It was also suggested that the timescales were rather arbitrary, and could hinder development - again relating to the view that the Plan may be too prescriptive given the uncertainties that remain. Whilst Comhairle nan Eilean Siar considered the Plan to be scientifically robust, having considered all of the main constraints, it also was critical of the timescales, noting that projects being progressed at present are already developing options for 2020 and beyond. As a result, the Council considered the Plan to be lagging, and potentially a barrier to development of the industry at optimum speed. The Crown Estate also questioned the timescales used within the Plan, suggesting that the assumption that all developments would progress concurrently could lead to an unnecessarily pessimistic view of environmental impacts. It suggested clarification the status of medium and long term options and decoupling of these staged deom specific timescales.
Links with Onshore Developments, Assessment and Planning
5.9 Some responses suggested covering the grid, infrastructure, other renewables and landfall aspects of the developments in more detail to give a fuller view of the likely development implications. The Highland Council felt that this would assist with planning on land and for the coast. Argyll and Bute Council also called for further consideration of onshore infrastructure and servicing requirements, and recommended that this is considered in social and economic terms to better inform both the SEA and Plan.
5.10 SNH advised that grid connection works should be addressed within the Plan and SEA, and consideration should be given within this to zones 1 and 2 and round 3 and other marine renewables activities that will require connection. It recommended assessing this based on a 'worst case' scenario.
5.11 Some consultees called for greater transparency, including being clearer about uncertainties that remain, or making scoring and weighting used in the assessment. This included, for example, Dumfries and Galloway Council which felt that the maps could better presented and that there would benefit from a more reasoned argument focusing on how the options were arrived at.
5.12 Visitscotland also felt that the SEA scoring and weighting was difficult to understand, and suggested that the best approach would be to take developments with least impact to the project stage, to allow stakeholders a further opportunity to influence their final shape.
5.13 In terms of presentation generally, Fife Council felt that the wording in the Plan should be reduced, and that more graphics would improve its legibility. Highlands and Islands Enterprise felt that some of the mapping was unclear, including the layering of information in some figures, and classification used in specific Tables.
5.14 Some comments related to the clarity of specific datasets. NERL asked for clarification as to how radar impacts were calculated, contending that referencing and mapping sources and interpretation were unclear with regard to this issue. They suggested that this issue needs to be assessed on a case by case basis and that caution should be applied in using generally published information.
5.15 One consultee felt that an Executive Summary for the Plan would be useful, but also acknowledged that its preparation may be challenging.
Improving the Plan through further Engagement
5.16 Several respondents, particularly individuals and communities but also the fishing and shipping sectors, called for further consultation and active engagement. Numerous individual consultees felt that the best way of improving the Plan would be to listen to the views of local communities. For some, this reflected broader dissatisfaction with the consultation to date, whilst others were simply recognising that this is just the beginning of a longer term process.
5.17 Some consultees, particularly those focusing on Tiree and the Argyll Array, emphasised the particular importance of further consultation with the 'proximate community' at every stage in the process, underlining the need to engage those who would be primarily affected by development proposals, over broader interests. Based on the views of others, this principle would be equally applicable to other areas, specifically communities close to the short term options. It was emphasised that local people had better knowledge of their community and environment, and that this should feed into the process.
5.18 Scottish Environment LINK expressed disappointment that they had not previously been engaged in the process, but offered further liaison and communication as the Plan is further refined and implemented.
Further Socio-Economic Analysis
5.19 Partly linking with responses to some of the previous Questions, in particular Question 2, some respondents noted a need for further socio-economic information to better inform the Plan. This was particularly the case for additional social and economic information, data on shipping and fishing.
5.20 The Scottish Fishermen's Federation again suggested that fishing should have been considered more fully under the heading of material assets. They contended that this should have bee undertaken before conclusions were drawn on the short term options. They considered the work on fishing to date to have been superficial. They felt that the Plan reflected a strong presumption in favour of this type of development, and suggested that the only way the sector could overcome this was to concentrate activity to the extent that it would be difficult for them to be displaced. The NFFO felt that the Plan would be improved once further work was undertaken on the spatial sensitivities of the fishing industry. The WOFFMG that a more focused approach should be informed by fuller consultation with marine stakeholders.
5.21 The Galloway Static Gear Fisherman's Association, like the wind industry consultees, felt that the Plan would benefit from a more regional focus, to allow better consideration of cumulative effects. They also felt that there was too great a division between consideration of on and offshore development, and suggested that experiences from Robin Rigg pointed to very limited economic benefit resulting from this type of development.
5.22 The Small Isles and Mull Inshore Fisheries Group asked for further consideration of cumulative effects on fisheries from a Scottish and UK wide perspective, as consideration of these issues in isolation was not effective. It emphasised the potentially far reaching consequences of loss of fisheries, and suggested that all potential exclusions should be viewed together, over the medium term to fully define the impacts of the Plan on the fishing fleet. They also explained that it was important to consider cabling, given its potential for cumulative effects on fishing, and were concerned about fragmented consideration of this in relation other development elements, given the nature of the consenting process.
5.23 These fishing industry views were supported by a number of individual respondents. One suggested that the consultation should extent to all registered fishermen, who should be given details of exclusion areas, and information on compensation. Comhairle nan Eilean Siar also noted that the needs of marine users such as the fishing sector would need to be addressed through more detailed, site specific consultation.
5.24 Some consultees also felt that the Plan would be strengthened through additional consideration of shipping and navigation issues. The Maritime and Coastguard Agency referred to their response to Question 1, setting out the need for a full maritime risk assessment of the Plan.
5.25 Other views on additional socio-economic issues to be covered in the assessment raised in response to Question 11 in particular, were also referenced by some consultees in response to Question 8. For example, the Argyll Renewables Communities recognised that the SEA has formed an integral part of developing the Plan, but were concerned that socio-economic considerations have been considered less. They felt this could be developed further under the SEA heading of 'population and health' and that appropriate consultees should be engaged to comment on the issues more fully (such as the NHS). They noted that, if the precautionary principle was applied to the Plan, the socio-economic assessment would have a much greater influence on the Plan. The need to consider the implications of the procurement stage within this was also emphasised. Further detail to steer the socio-economic assessment was helpfully provided.
5.26 The Scottish Boating Alliance welcomed the clear commitments within the Plan to further work with the shipping and fishing sectors, but also emphasised the need for further work on marine tourism and recreation boating activities. The Moray Firth Partnership recommended making reference to up to date economic research establishing the value of the Moray Firth Dolphins for tourism.
Consideration of Offshore Wind in its Broader Context
5.27 Numerous views on the Plan asked that for fuller consideration of offshore wind energy in its broader context. This included proposals for a proper cost-benefit analysis of offshore wind technology, linking with comments on the socio-economic assessment.
5.28 Reflecting an issue raised in responses to Question 11, some people suggested that the Plan would benefit from being better linked with approaches to marine renewables being taken forward by other parts of the UK. Many consultees felt that consideration of offshore wind in relation to other sources of energy, most specifically wave and tidal, would strengthen the plan as a whole. Several specifically referred to opportunities for large scale tidal energy generation in the Solway, noting also that this could exacerbate the cumulative effects of the short term proposals for wind in the area. Other areas with tidal potential mentioned included the area between Kintyre and Rathlin. Some suggested that wave and tidal energy would be sufficient to meet demand, and others called for a more coherent strategy for all renewables, extending beyond the Plan's focus on offshore wind. Cost-benefit analysis was suggested as a tool for analysing and communicating this. Dumfries and Galloway Council asserted that tidal and barrage options would generate more consistent electricity and therefore be more sustainable, and was concerned that the focus on offshore wind could prejudice this type of development. Argyll and Bute Council also felt that consideration of these options would provide a more complete picture of energy needs.
5.29 Others asked for reassurance of clarification that offshore wind would be beneficial overall, taking into account issues such as the need for standby power requirements. Many of these consultees doubted the effectiveness of offshore wind as a sustainable and effective energy solution. Some felt that more input was needed from stakeholders such as the National Grid, electricity supply companies, wind turbine suppliers and offshore contractors to more fully assess the Plan and better match supply and demand. One consultee suggested that the Scottish Government should work with these interests to develop a staged approach to construction that better matches development with equipment and contractors.
5.30 The Moray Firth Partnership again reiterated a need for targets for overall energy production from offshore renewables to be set to form a better context for the Plan. It was concerned about progressing the medium term options in particular, without having established their necessity in meeting such targets. Clarification of the estimated operational generation capacity of developments as opposed to maximum designed generation capacity levels was sought.
5.31 Marine planning was again raised, with consultees such as the Kintyre Offshore Wind Farm Action Group contending that it would be premature to agree the Draft Plan before marine planning regulatory requirements are in place. They also pointed out that Marine Protected Areas have not yet been agreed, and that there was therefore a risk that the developments within the Plan could overlap with them.
Reinforcement of Regional and Spatial Issues
5.32 In response to this question, several consultees restated their specific objections to individual developments, or to the broader scale of development within a particular region. Inclusion of some sites, particularly Wigtown Bay in the plan was considered a key failing and it was again suggested that the project was either removed or pushed into the medium term. Some of these consultees felt the Plan was lacking broader, multi-sectoral regional analysis that linked environment with socio-economic issues. Again, potential for cumulative effects, particularly in the Solway, were raised as a concern and considered to undermine the credibility of the Plan as a whole.
Habitats Regulations Appraisal
5.33 Scottish Natural Heritage noted the need for an HRA of the two proposed phases of development. It also stressed the need to take into account planned and emerging research in order to fill current gaps in data. The Dutch Government suggested that the HRA should be thought through in more detail, with more specific reference to the species and habitats covered by the Directive that need to be included in the assessment.
Prioritisation of Options
5.34 Aberdeen City Council felt that it would be beneficial to prioritise the medium term sites through the evaluation system. This was expected to provide a clear structure for implementing this phase of development. This echoed a number of responses to other questions within the consultation, that asked for fuller comparison of the alternatives to inform the final Plan content. Responses to Question 12 also picked up on this issue.
5.35 One individual suggested that the Plan should be revised to exclude short term schemes with low returns and high adverse effects, in favour of prioritising medium term options with scope for higher returns.
5.36 These issues are summarised in Figure 17.
Figure 17: Mapping of Views on Scope to Improve the Plan
Question 7: Do you have views on the scale and pace of development that could be sustainably accommodated in Scottish Territorial Waters, taking into account the findings from the SEA and the technical assessment?
5.37 This Question aimed to establish views on the overall level of development and the proposed timescales.
Concern about the proposed pace and scale of development
5.38 In response to this question, several consultees felt that the plan being progressed at to rapid a pace. This included those opposing specific schemes (some comments related to specific proposals notably Kintyre as opposed to the Plan as a whole), and also the fishing and shipping sectors.
5.39 Dumfries and Galloway Council had some serious concerns about the scale and pace of development that could be accommodated in territorial waters, taking into account information gaps and potential impacts. They felt that these issues needed to be addressed before the Plan is finalised.
5.40 Fishing groups also commented on this. The NFFO had concerns about the proposed pace of development, based on the potential for cumulative effects of some significance when the Plan was considered together with other energy infrastructure developments. As a result, they suggested more conscious pacing of development, progressing stages to ensure mitigation can be built in. They also questioned whether targets for development were appropriate and noted that inshore waters should be viewed in the context of the wider UK territorial sea area, to take on board the greater likelihood of conflict arising from areas with multiple users.
5.41 The Small Isles and Mull Inshore Fisheries Group felt that the scale of development could not be understood unless the Plan was set within a broader context of national targets for energy outputs. It also noted that the scale and capacity of developments will change as technology improves. However, it felt that the scale of development currently proposed could not be accommodated by the fishing industry over the medium term, but that scope for deferring or dismissing proposals within the Plan was unclear. At a practical level, by way of mitigation the group suggested that construction should be co-ordinated to take into account and manage temporary exclusions, and recommended that this needed to be done at a national level, and not deferred to the project scale.
5.42 Some consultees suggested that there was a need to build in more time to allow for proper study of all the issues arising from development. For example, the prospective developers of the Machrihanish Dunes project suggested that there was a need for fuller consideration of alternative technologies that may become available within the overall timescale for the Plan. The need to remain flexible to allow for obsolete projects to be abandoned was emphasised.
5.43 Scottish Environment Link, supported by a number of individual stakeholders with an interest in the environment, urged caution and asked for further consideration of the biodiversity and landscape effects of development off the west and northern coasts. IEEM noted that the scale and pace of change was largely dependent on the outcome of the HRA process.
5.44 Others felt that pace was less important than scale of development. An individual suggested that this was 'extreme', raising particular concerns about continuous wind farm development along the Solway Coast. It was suggested that further development in this area should be postponed until at least 2020. Others, such as the Scottish Boating Alliance also suggested that pace was less important than the suitability of the environment to accommodate development.
Concerns about delays
5.45 In contrast, other consultees contended that the scale and pace of change proposed by the Plan was lacking in ambition. For example, Future Electric raised concerns that the timescales were too rigid and that spatially, the Plan did not make provision for development outside option areas. This was viewed as giving a negative message to the industry.
5.46 Comhairle nan Eilean Siar also felt that the scale and pace of the Plan was too limiting, noting that international developers are already challenging it parameters by advancing technology. They asked that the Plan is revised to send out clearer investment signals to developers, getting to a position where technology and development of the grid follows the Plan, as opposed to vice versa.
5.47 SSE Renewables felt that wholesale redefinition of the options at this stage would incur delays, suggesting instead that the references to specific projects within the Plan were replaced with broader analysis. They were also concerned that changes to licensing, the Habitats Regulations Appraisal and marine spatial planning could slow down the process, but acknowledged that the streamlining of consenting regimes may reduce this to an extent.
5.48 Aberdeen City Council stated that the scale of the opportunity necessitated rapid action. They felt that it was essential that this must be balanced with issues such as mitigation and information gathering, to ensure the Plan was sustainable.
5.49 NERL called for more time to allow wind farm developers to undertaken proper consultation on radar issues. It was emphasised that this can take many months, and should therefore be taken into account when considering implementation timescales. Early engagement was recommended as a result.
Learning from experience as it emerges
5.50 Several consultees noted that progress can be reviewed when the Plan as a whole is revisited. Scottish Natural Heritage recognised that it is in the interest of timely development to focus on areas of lowest risk first, but also noted that further work is required to be able to identify such areas. It advised caution in proceeding on the basis of 'poor data' at this stage and urged close working with stakeholders and ongoing monitoring and research programmes to minimise uncertainty in planning and consenting. SNH noted that to an extent pace will be dictated by the experience of developing the short term sites, and that this experience should be reflected in the planning of further sites. The need to ensure grid transmission capability was also noted, although it was recognised that this falls beyond the scope of this Plan and its SEA.
5.51 The RYA Scotland suggested that there was a need for a mechanism to facilitate sharing of experience between offshore wind farms, such as the role of EMEC for wave and tidal energy.
5.52 Similarly, The Highland Council felt that the pace of change was broadly correct, but that lessons may be learned from the further development of technology and implementation of the short term sites. As a result, it was suggested that the scale and pace of the Plan may be adjusted within future reviews, to ensure that the sector develops in a sustainable way. Several individual consultees asked for further evaluation of Robin Rigg to be undertaken, before further development is progressed.
5.53 Whilst the Scottish Fishermen's Federation had significant reservations about the Plan overall, they also suggested that a sequential approach may help to ensure that lessons can be learned from one development, before the next one proceeds.
5.54 Monitoring more generally was raised as a key mechanism that would facilitate the periodic review of the scale and pace of development as more information becomes available. Several respondents suggested that there was a need to align the pace of development with the outcomes on monitoring. Seaenergy Renewables noted that Cowrie had summarised the results of monitoring to date as required by FEPA and recommended that this is taken into account. The Dutch Government expressed particular interest in the monitoring programme, as well as any solutions emerging from the Plan for managing cumulative effects.
5.55 Seaenergy Renewables noted that there were no specific studies exploring capacity, and felt that this could provide a clearer view on whether development is sustainable in the short, medium and long term. As with several other questions, respondents also stated that progress of the Plan in relation to capacity, was difficult to gauge in the absence of the plan being linked with stated targets on energy generation.
5.56 Some industry representatives and others felt the Plan's timescales appeared to be too rigid and prescriptive. Several consultees suggested greater flexibility.
Linking the implementation of the Plan with other factors
5.57 Several consultees noted that the scale and pace of implementation will depend on a range of other factors. Some felt the grid was a key constraint to development. The Tiree Community Development Trust suggested that the weakness of the grid is a constraint to development, and proposed that Government leadership is required to define the scale of development and therefore schedule grid developments. SSE Renewables noted that the pace of development will be closely linked with support and availability of infrastructure and materials, quayside manufacturing facilities, the availability of vessels and material resources for wind farm construction. This view was also supported by Scottish Renewables, which emphasised the need to consider competing demands on resources including finance and the supply chain, although taking into account Round 3 projects. Scottish Power Renewables recommended further detailed discussions with developers, industry, the supply chain and others to achieve a joined up approach to phasing of investment.
5.58 Visitscotland also emphasised the importance to planning to take into account supply chain infrastructure. Phasing was recommended as part of this, and it was noted that the onshore implications of development may be substantial, requiring sensitive management of impacts on residents and visitors. Similarly, Scottish Renewables noted the importance of taking into account impacts on other marine users as projects progress.
5.59 Other consultees developed this theme further, for example suggesting that the Plan should be linked with the need for manufacturing and the supply of labour and equipment to come from Scotland, to maximise the economic benefits of development. The need for further links with N- RIP was raised by several consultees including Highlands and Islands Enterprise. This was regarded as a key means of targeting and phasing development in a way which maximises the sector's economic benefits. One consultee suggested that there will be a need for development planning to be prepared to progress associated onshore elements within the Plan's timescales. The Argyll Renewables Communities noted that onshore developments will impact on host communities, and expressed concern that these would be considered after, and separately from, decisions on the offshore elements of the Plan. As a result, they recommended more integrated assessment and decision making.
5.60 Fife Council noted that there will be a need to ensure that skills are available to match the scale and pace of development. They suggested that further support is provided to communities by the Scottish Government, to enable them to capitalise on employment opportunities at a local and regional level.
5.61 These responses are summarised in Figure 18 below:
Figure 18: Mapping of views on the overall scale and pace of development within the Plan
Question 8: Have we got the balance right in the Draft Plan, between tackling climate change, maximising opportunities for economic development and dealing with environmental and commercial impacts?
5.62 This question aimed to explore views on the overall emphasis and balance within the Plan as a whole. Some consultees asked further questions in response, specifically "benefits for whom?" and "what against what?". This reflected views that more detailed information is required to judge this.
Balance informed by targets
5.63 Some consultees sought more information on the role of the plan in meeting targets. Seaenergy Renewables, for example, asked how MW capacities for regions would be developed, before commenting on the balance within the Plan.
5.64 Some consultees felt that the Plan was too driven towards meeting what some considered to be 'arbitrary' targets, and expressed concern about the consequences of this approach for other marine users or the environment. The Galloway and Upper Nithsdale Liberal Democrats Constituency Party was doubtful that the Plan was appropriately balanced and concerned that it focused too much on offshore wind, and not enough on other contributors to climate change mitigation.
5.65 Others suggested that offshore wind may only be a short term solution, noting that a greater contribution could be secured from other technologies including wave and tidal and nuclear. Several consultees were concerned that the short term sites had been driven by commercial feasibility, and that this heavily outweighed the impacts of developments within the Plan.
5.66 Some went as far as questioning the necessity of development in the first place, with one consultee suggesting that the actions were merely 'symbolic'. Views on climate change generally were raised by some individuals, who felt that there was insufficient evidence to demonstrate that this type of development would have a net benefit for reducing emissions. One consultee questioned why Scotland was embracing offshore wind when other countries were retreating from it, and was unconvinced about climate change more generally.
5.67 Several consultees felt that a balance had not been struck in terms of concerns about economic impacts. This was particularly the case for tourism and fishing, and communities in more general terms.
5.68 As noted in responses to other Questions (particularly Question 2), these consultees and others called for a detailed socio-economic assessment. This was reinforced by numerous respondents who opposed specific projects, did not respond directly to this question, but expressed significant concerns about visual impacts, impacts on tourism and communities. Some called for more detailed and explicit cost / benefit analysis. Many felt that the losses incurred by the tourism and fishing sectors would not be offset by gains in the renewables industry, particularly at a local scale.
5.69 Individuals felt that their businesses or that the economic viability of their wider local community would be adversely affected by development, suggesting that climate change mitigation was heavily outweighing these concerns. Many of the people responding to this question were focused on the Kintyre proposal, and also raised the conflict between the development and the investment planned for the Machrihanish Dunes project.
5.70 Several respondents who opposed the Wigtown Bay option or development in the Solway more generally were also critical of the broader balance within the Plan and its apparent lack of consideration of tourism and other economic effects. Some felt that the net effect on the local economy of the Wigtown Bay proposal in particular would be 'devastating.' These consultees also felt that impacts on tourism and fishing had been underplayed and that, based on the experience with Robin Rigg, losses would not be replaced by growth in the renewables sector locally. Aspirations to generate income from environmental quality, with projects such as Marine National Parks, were expected to be undermined if development proceeded.
5.71 The fishing sector felt that their interests had been overlooked in the drive to meet energy and climate change targets. As a result, the need for compensation was raised. This went beyond concerns about economic losses to also include concerns about the social effects on small rural communities who rely on fishing. The Small Isles and Mull Inshore Fisheries Group felt that the significant burden imposed by the Plan on individual vessels must be acknowledged and addressed, asking for urgent clarification of arrangements for compensation. The NFFO questioned whether the sector was good value, when costs to consumers and tax payers were taken into account. The need to fully recognise effects on commercial fishing was also recognised by other consultees, including Comhairle nan Eilean Siar. The Dutch Government suggested further consideration of the impacts of the Plan on fishing grounds in the North Sea would be required, perhaps even at an international level.
5.72 Again, many who opposed development of specific projects or in certain regions, questioned the viability of offshore wind in terms of cost, subsidy and financing by taxpayers and consumers. People also asked whether development of this scale was necessary if the energy was to be exported.
5.73 More positively, and in contrast to some of these views, Comhairle nan Eilean Siar regarded this to be a potentially significant industry for the Western Isles, which could help to reverse problems such as depopulation by creating new types of economic activity. It noted scope for local education providers to develop as centre of excellence, which helps to capitalise on the opportunities within the Plan. As a result, the Council felt that the economic benefits of the Plan may be underplayed, and that the potential for significant local economic benefits should be recognised.
5.74 Highlands and Islands Enterprise also asked for a greater focus on the likely economic benefits of the Plan and exploration of how they will be achieved, referring to the Offshore Wind Industry Group ( OWIG) route map as a tool for delivering this. This view was supported by a number of individual respondents. The Argyll Renewables Communities felt that an assessment of the commercial impact of development, and its economic development opportunities, was urgently required so that communities who may be affected by development can make use of any opportunities arising from the Plan. They also suggested that developer obligations could be used to help communities to develop skills and build capacity to enable them to become participants in the supply chain.
5.75 The Maritime and Coastguard Agency felt that the values of the benefits and costs of the Plan had not yet been provided, and so could not comment on whether the balance was appropriate. However, it noted that marine risk assessment methods included well established costs and values that could be used within further analysis.
5.76 As with its response to Question 7, Scottish Renewables felt that infrastructure links needed to be considered in order to answer this question.
Further consideration of environmental effects
5.77 Some consultees felt that there was insufficient coverage of some aspects of the environment, and called for a precautionary approach in the light of ongoing uncertainties. This included those calling for more weighting to be given to the consideration of landscape impacts, and other environmental constraints including European Protected Species. Reference was made by some consultees to the importance of the precautionary principle, and others felt that the environment should be regarded as an exclusion, rather than a constraint.
5.78 Scottish Environment LINK provided further elaboration on a set of presumptions that would, in their view, help to sustain the precautionary principle:
- Adequate baseline survey and monitoring to identify sensitivities, assess impacts and develop management and mitigation procedures;
- Ensuring that sites / species / features with particular sensitivities are protected.
- Explicit commitment that in these case consent to continue is strictly subject to evidence that there is no significant adverse impact.
- Acknowledgement that this is a risk-based approach which may allow early development, but may equally lead to withdrawal of this and further consents.
- All baseline data are made publicly available, and updated at least annually, so that they can be reviewed and fed into an adaptive management process.
- Close attention to advice of statutory consultees, particularly SNH and JNCC.
5.79 One consultee suggested that a better balance could be struck between development aspirations and their environmental impacts. The idea of 'anticipatory mitigation or compensation' was raised, and it was proposed that this could be supported by an industry wide fund to address key losses. This would be a means of achieving strategic level mitigation through partnership working, also involving the Scottish Government given its commitment to green energy.
5.80 Again, those opposing specific developments felt that some of the Plan's proposals had overridden potential environmental effects. Examples included the contention that the Kintyre proposal had placed insufficient emphasis on landscape and seascape effects. However, others were more relaxed about this, recognising that the Plan and its SEA make a start on identifying and balancing industry and environmental issues, and that the balance can be reviewed as the implementation progresses.
5.81 As noted in responses to other Questions, the need for fuller socio-economic analysis was again raised, with numerous consultees feeling that the Plan does not strike a good balance between development and community impacts. The Tiree Community Development Trust stated that likely costs of development to communities needed to be more fully established, to ensure that its economic benefits can be recouped, and this view was supported by the Argyll Renewables Communities and Argyll and Bute Council. The Council also raised concerns about the ways in which renewable energy and economic development aims have been greater consideration than wider socio-economic effects, including on established communities. They felt that this view was reinforced by the fact that the 10 short term sites had been identified before the start of the planning process.
5.82 Dumfries and Galloway Council also felt that the lack of an economic and social assessment meant that an appropriate balance had not been struck.
5.83 Scottish Renewables and SSE Renewables felt that the SEA should take into account the potential impacts of climate change on population and health, so that the long term benefits of the Plan are not understated.
5.84 One individual felt that the Plan was weighted towards environmental considerations, with insufficient coverage of the visual effects on local populations.
5.85 Some consultees were supportive of the overall balance within the Plan. This included the Highland Council, who noted that the industry remains at an early stage and there will be further time and opportunities to review the broad aspirations as implementation progresses. Also supporting the broad balance within the Plan at this stage, RYA Scotland noted that many impacts will only emerge at the project level, and that this is where mitigation will therefore be required. Fife Council also supported the approach and was of the view that each issue had been addressed in sufficient detail, and given appropriate weighting in the consideration of options. Aberdeen City Council also felt that the balance appeared to be correct, recognising that further assessment will be required to address some of the limitations of the Draft Plan at this stage.
5.86 These views are summarised in Figure 19 below:
Figure 19: Mapping of views on the overall balance within the Plan
Question 9: The Plan, once implemented, will be reviewed to take account of actual development and increasing knowledge of development factors. How often should this be done and why?
5.87 Views on the proposal for a two year review period were wide ranging, with 51 responses in total to this question. Around 18 respondents felt that two years was appropriate, a small number (4) felt it may be too frequent or called for more frequent or even continuous review (6). The remainder provided further discussion or comments.
Uncertainty arising from future reviews
5.88 Several respondents were concerned about uncertainty created by too frequent reviews of the Plan, for a number of different reasons.
5.89 The industry called for clarification on the consenting process during future plan review periods, reflecting concerns about changing levels or support or over prescription of mitigation at the EIA level. Scottish Renewables, asked that developer risk be reduced in relation to project consents and this was supported by several individual developers and regional groupings. To achieve this, Scottish Renewables recommended a statement on the consenting process for short term options during future review periods.
5.90 Highlands and Islands Enterprise suggested that uncertainty could be avoided by ensuring that the consenting bodies continued to consider and determine projects based on the existing version of the Plan, rather than delaying decisions whilst awaiting new versions to be produced.
5.91 The Moray Firth Inshore Fisheries Group was concerned that a two year review period would lead to continuous redefinition of the acceptable impacts on the fishing industry in terms of access to existing sites, and the location of new locations for energy developments. However, it also noted that the layout of wind farms and tower construction will be key changes that the SEA must take into account, recommending that the range of acceptable impacts is considered and evaluated within the two year review.
More flexible review periods
5.92 Several responses suggested a fixed time period was too rigid, and suggested tailoring reviews to the emergence of key monitoring or baseline information, or linking with key development stages. Some felt that it was critical that developments are considered from the outset, rather than later on in the process, and subjected to a process of continuous review.
5.93 Some suggested that short review periods at first could be replaced by growing periods between plan reviews as certainty linked with experience grows. They noted that as knowledge improves, the need for frequent review will reduce. For example, one consultee suggested an initial two year review period to take into account rapid change and growing understanding, followed perhaps by a three year period, and subsequent reviews every four or five years. This view was supported by others who recommended an iterative process throughout the implementation stages. Another consultee called for a major review to be undertaken immediately following implementation of the short term options, prior to the medium term options proceeding.
5.94 Some industry representatives concurred with this approach, recognising that the knowledge base is evolving. Seaenergy Renewables suggested coinciding reviews with key milestones in the development of the industry, such as the release of environmental management findings or availability of post consent monitoring information. The view that a more regional approach was again supported, noting that this would be more flexible and remove the need for the Plan to be revised before realising the medium term development options.
5.95 The Village at Machrihanish Dunes / Kintyre Development Company Limited proposed that supplements to the Draft Plan should be released as and when required, on the basis of new information becoming available. They agreed that a comprehensive review every two years would be appropriate.
5.96 IEEM felt that the two year period may be too frequent. They suggested avoiding setting a rigid timetable, and instead reviewing on the basis of information becoming available. They emphasised the role of Marine Scotland in co-ordinating this process, and feeding in emerging information and research findings that address current uncertainties. IEEM also requested clear guidance on how this information will be fed back to the industry and referred to within the regulatory process.
5.97 Visitscotland considered the two year period to be sufficient, but also noted that it should be adjusted to take into account variables such as significant technical breakthrough, the discovery or minerals or natural disasters. However, the Scottish Canoe Association anticipated that there is likely to be change before 2020 that mean that medium term options should be reconsidered.
5.98 The Small Isles and Mull Inshore Fisheries Group felt that the review period would depend on the speed of development that takes place. They supported an approach specifying a minimum time period between reviews, on the basis that technology is developing rapidly and that fishing data will increase significantly in the short term. Based on their view that the Draft Plan does not adequately address fishing issues, they emphasised the importance of proper opportunities to assess the effects of short term options as they are developed, and to use this information to influence the medium term. As a result, they recommended an annual review process to provide sufficient scope for the Plan to respond to changes and additional information.
5.99 Historic Scotland also felt that it would be beneficial to update the Plan as further surveys of submerged archaeology (see Question 2) are taken forward.
Support for the proposed two year reviews
5.100 Several consultees felt that 2 years was about right, given the pace of change in the sector and technological progress. RYA Scotland was supportive, but noted that this should not necessarily imply a major revision of the Plan, simply a check for changes required on the basis of new information becoming available. They also suggested that it the process would be more transparent if these changes were set out in a separate document, and noted that to maintain credibility the Plan needed to be able to respond to any major changes that might arise. The Scottish Boating Alliance supported this view.
5.101 The Scottish Fishermen's Federation agreed with the two year period and emphasised that this was needed to ensure impacts on material assets were fully understood. This view was also supported by the WOFFMG.
5.102 Aberdeen City Council, Argyll and Bute Council, the Moray Firth Partnership, the Whale and Dolphin Conservation Society, the North Berwick Environmental Trust and the Dutch Government considered the two year review period to be appropriate, allowing further information to be taken on board. Whilst the Argyll Renewables Communities supported the review period, they noted the need for appropriate indicators to be established from the outset to ensure appropriate data collection was undertaken. Highlands and Islands also agreed with the timescale but noted that the Plan should only be reviewed where necessary to avoid problems arising from possible delays incurred.
5.103 Scottish Natural Heritage welcomed the proposed two year review period, but suggested that more regular review of the Plan should be undertaken in the early stages to take account of:
- Marine Spatial Planning (national and regional plans);
- DECC's Offshore Energy SEA Research Programme;
- Key research findings;
- Lessons learned from the development of short term sites; and
- Other renewables lease rounds e.g. wave and tidal.
5.104 SNH also explained that work is underway which would be beneficial to future iterations of the Plan and its SEA, including development of seascape character assessment guidance in conjunction with Natural England, advice on scoping and weighting of National Scenic Areas, mapping of areas of wild land character, isolated coasts and Areas of greater Landscape Value, and revisiting on the Scott et al (2005) report which identified seascape sensitivity and capacity in order to inform the landscape and visual impact assessment for the study. SNH noted that it had reservations about this methodology and suggested further liaison to discuss the findings of their review as it progresses.
More frequent review required
5.105 A few consultees felt that more frequent review may be appropriate. Comhairle nan Eilean Siar felt that the proposed two year review period was appropriate, but also noted that annual review may also be needed, given the pace of development and the uncertainty around issues such as technology (rapid development of floating turbines), the grid, transmission charges and development incentives.
5.106 Three individuals also felt that an annual review would be more appropriate. One felt this would allow a view to be taken on whether or not offshore wind was becoming obsolete as it is overtaken by wave and tidal development. Another also suggested that better energy options are likely to become available within a relatively short space of time. A further consultee recommended reviewing the Plan 'as soon as possible' to ensure that lessons learnt are taken into account before new developments proceed.
Less frequent review suggested
5.107 Conversely, some consultees felt that a longer review cycle would be appropriate. The Highland Council argued that a five year review period could fit better with local development plan cycles. They also suggested alignment with the National Marine Plan once adopted, a view also supported by Scottish Renewables who also urged greater links with DECC. In broader terms, the importance of linking into marine spatial planning was strongly promoted by Scottish Environment LINK.
5.108 Fife Council also suggested a five year period, to allow reasonable time for change to take place. The NFFO suggested that the Plan is reviewed as often as practical, taking into account new information, but that the first review could be in the region of three to five years. Infratil felt that a two year period may be over optimistic.
5.109 Scottish Power Renewables also suggested that a 5 year review period would be more suitable, giving more time for the baseline and medium term options to be informed by data that are currently being gathered. It suggested that the technical uncertainties associated with the medium term options necessitated their ongoing review. As a result an iterative approach to development of the Plan was recommended, allowing for new technologies and significant impacts to be taken into account. Following an initial five year review, subsequent reviews could take place every three years. It was noted that the short term projects will not be constructed until 2016 and so reviews every two years ahead of this may not be required. It was explained that preconstruction surveys will be available from 2017 and operational monitoring from 2019, and proposed that these sources link into future reviews.
Views on the review process and relevant information
5.110 SSE Renewables asked for further explanation of how data will be collected and managed to allow for sharing between developers. It urged further discussion of this matter, given the potential for reviews to generate significant time and cost constraints. It suggested tabulating ongoing research, so that its implications for environmental assessments and future versions of the Plan could be more clearly seen. Clarification was also sought on when the first review would take place, and at what frequency this would be repeated thereafter. Scottish Power Renewables also asked for a transparent review structure, and clear guidance on how feedback from the process will be fed through to the industry and regulators.
5.111 Dumfries and Galloway Council and a number of consultees with particular interest in development in the South West region, felt that baseline monitoring should be undertaken, making use of information from the Robin Rigg wind farm, before decisions are made on short term options that are based on currently limited information.
5.112 Several consultees viewed the Plan review as crucial for addressing some of the uncertainties that persist in this iteration of the Plan. The Maritime and Coastguard Agency recommended that the review considers port development, climate change, maritime risk assessment, and civil hydrography in the short and medium term options and their vicinities. It also proposed that developments in the Marine Protected Areas, and wave and tidal energy should be considered and that vessel traffic pattern alterations arising from developments should be fed into predictive models of traffic behaviour for subsequent developments. NERL had no strong view on the frequency of the review period, but noted that they wished to be consulted as part of the process.
5.113 One individual suggested that businesses should prepare annual progress reports, to be submitted to the Scottish Government for annual review.
5.114 Scottish Environment LINK felt that lessons learned from short term sites should be used to inform medium term sites as a matter or urgency. It proposed that the Plan and its SEA should be reviewed as soon as this new data was available.
No Plan - No Review
5.115 Five consultees contended that it was not necessary to consider review period as, in their view, the Plan should not be implemented in the first place. Most of these responses came from people who were strongly opposed to the content of the Draft Plan including specific short term project. Some felt that tidal energy was a preferable option and should be explored further, or at least better linked with the Plan for offshore wind. Others were concerned that a two year review 'would come too late' for proposals such as the Wigtown Bay development to be changed. One consultee felt that the proposals for iteration and review were tantamount to retrospective evaluation and viewed this as a 'reckless' approach.
5.116 These views are summarised in Figure 20 below.
Figure 20: Mapping of views on the Plan Review Period