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Blue Seas - Green Energy: A Sectoral Marine Plan for Offshore Wind Energy in Scottish Territorial Waters - Part B Post Adoption Statement

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B.1 POST ADOPTION STRATEGIC ENVIRONMENTAL ASSESSMENT ( SEA) STATEMENT

B1.01 This Section of the Post Adoption Statement focuses on how the SEA findings have informed the finalisation of the Plan for Offshore Wind. Part 3 of the Environmental Assessment (Scotland) Act 2005 sets out the requirements for the post-adoption stage of SEA. This includes publication and advertising of the Plan, the Environmental Report and a Statement setting out:

  • How environmental considerations have been integrated into the plan (Section 18(3)a of the Environmental Assessment (Scotland) Act 2005);
  • How the environmental report has been taken into account (Section 18(3)b);
  • How consultee opinions have been taken into account (including transboundary consultations) 1 (Section 18(3)c and d);
  • The reasons for choosing the plan or programme as adopted, in the light of the other reasonable alternatives considered (Section 18(3)e); and
  • Measures to be used to monitor the significant effects of the plan (Section 18(3)f).

B1.02 In order to fulfil these requirements, in the following paragraphs the findings of the technical and environmental assessment have been brought together and linked with the consultation findings on a topic by topic basis. To aid interpretation of the statement, the following questions provide the structure for this part of the report:

1. What options were considered within the SEA, and how were they identified?

2. What environmental effects were predicted by the SEA and what did consultees say about them?

3. What were the views on developments in specific locations or regions?

4. What were the views on the Plan as a whole and its SEA?

5. What are the reasons for choosing the Plan as adopted?

6. What monitoring will be undertaken?

What options were considered within the SEA, and how were they identified?

B1.03 The first set of issues and questions relate to how options within the Draft Plan were identified for the purposes of the SEA. This was an important part of the SEA and planning process, as it allowed the SEA to focus on areas where offshore wind was potentially feasible, as opposed to generally assessing the whole area of Scottish Territorial Waters, including areas where development was unlikely to be feasible.

B1.04 The development of the Draft Plan was informed by detailed consideration of a range options for development. At the outset of the process, the 10 sites announced by The Crown Estate in 2009 were identified as a practical and realistic set of potential development options for the Plan. However, the Plan also aimed to look beyond these sites to give fuller consideration to options for development going forward into the medium and long term. As a result, and in consultation with the Offshore Wind Industry Group ( OWIG), The Crown Estate's Marine Resource System ( MaRS) was used to ascertain where development may or may not be sustainable as a result of baseline environmental and technical conditions. This took into account a range of environmental and technical constraints and exclusions, as set out in Section 2 of the Draft Plan. 2 This led to the identification of a further 30 medium term 'options' - essentially forming areas of search where development could be considered further.

B1.05 In broader terms, the SEA also included consideration of the option of 'business as usual' as an overarching alternative to the Draft Plan as a whole.

B1.06 The SEA subsequently assessed the individual and cumulative effects of these options, together with the short term options. The findings from this process were set out in full in the SEA Environmental Report 3 and its Appendices 4, and are summarised below under the relevant headings.

Consultee views on options selection

B1.07 The Consultation Analysis Report 5 and a further Addendum set out the detailed views from respondents on how the options were identified, including information used within this process. Three key questions (see below) were highlighted to steer consultees towards commenting on this aspect of the Plan and its SEA. Views on these questions were varied. The following key points emerged in response to each of these questions:

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

B1.08 Some consultees considered the options to be a reasonable first step in the planning and SEA process, whilst others sought clarification of the status and weighting of options as a result of their inclusion in the Plan.

B1.09 Concerns about the limitations of MaRS were raised by a number of consultees, primarily those who believed that the outputs were dependent on providing good quality environmental data. Some considered that the modelling would be commercially biased, noting for example that MaRS does not enable non-designated areas to be explored. Others were of the view that environmental matters were too heavily weighted within the mapping, and that social and cultural issues should be afforded further consideration. Of the SEA Consultation Authorities, Scottish Natural Heritage ( SNH) raised particular concerns about MaRS and suggested that further testing should be undertaken to ensure that these options were valid. In the meantime, restraint was recommended to reflect their concerns.

B1.10 The transparency of the MaRS system was questioned, and some consultees suggested that it would be useful to involve stakeholders more fully in data collection and input, to ensure that the information used, and therefore the options identified, accurately reflected their interests. The need to acknowledge and address data gaps was also raised. Industry stakeholders stated that the use of MaRS had meant that the SEA had sought to conduct too detailed a level of analysis, within what should be a high-level national plan. This view was supported by some other individuals and organisations.

B1.11 Some respondents noted that different criteria had been used to identify the short and medium term sites. This remained a fundamental point of concern throughout the SEA and associated consultation process.

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

B1.12 A range of additional information was raised by respondents, to take into account within the identification of options. This included reference to onshore development, including the grid connections and support facilities, other types of renewable energy development, further socio-economic information, information on fishing, aviation, defence activities and munitions and more detailed environmental evidence.

B1.13 More specifically, the key environmental information raised included bathymetric information, bird data, Marine Protected Areas, bats, mobile species (marine mammals and fish), landscape sensitivity information, aspirations for marine and coastal national parks, archaeological data, World Heritage sites in England and Northern Ireland. In addition to using this available information, some respondents emphasised that the Plan should explain how strategically significant data gaps will be addressed.

Consultation Question 3. Do you consider that the Draft Plan represents a practical set of options?

B1.14 Some organisations viewed the options to be practical, at the very least forming a useful starting point for the assessment. Some reiterated views raised in response to Question 1 that the options are too detailed for a high level, national plan. There was also overlap with comments on the data sources used to define the medium options, with respondents considering them to be impracticable if, in their view, their interests had not been adequately covered.

B1.15 Suggestions of alternative approaches included setting a clearer target for the Plan as a whole, to better articulate the options for contributing these aims at different scales.

Response to issues raised within the Finalised Plan

B1.16 The table on the next page explains how these issues and views have been addressed within the Plan.

Issue / View

Response

Overall shortcomings of MaRS including data, transparency should be recognised.

These shortcomings have been recognised and taken into account. Data sources have already improved since the Draft Plan was developed, and it is expected that this will continue to be the case over the course of the Plan's two year review cycles. As explained in Section B5, further work (sensitivity testing) has been progressed and will be further undertaken by Marine Scotland Science to explore the application of MaRS to options identification more fully.

Options are overly specific for a national level plan.

To reflect uncertainty at this scale, the medium term options are simply regarded as indicative areas of search. These will be revisited as the above further study progresses.

Inconsistency of mapping approaches used to identify short and medium term options.

This is acknowledged as an issue for the Plan. However, whilst different processes were used to identify the short term sites and medium term options, the SEA applied the environmental assessment objectives to them in a consistent way.

The different approaches to selecting sites and options is likely to have been a key factor in the varying environmental effects identified in the assessment.

Comments on the additional data that should be used to feed into the MaRS process / identification of options. Acknowledgement of ongoing data gaps is required.

See the comments relating to MaRS above. These data can be taken into account and developed further, in consultation with key stakeholder organisations as the MaRS modelling is revisited within the 2 year review process.

Clarification should be provided on the status of options within the Plan.

As clarified in the Plan, inclusion of any site or option within the Plan does not imply 'deemed consent' for development in that area.

The spatial recommendations and mitigation proposals are intended to be guidance which should be taken into account, as and where appropriate, at the project level.

What environmental effects were predicted by the SEA from the Draft Plan as a whole, and what views were expressed about them?6

B1.17 The SEA predicted the environmental effects that could arise on the environmental receptors that are required to be considered under the terms of the SEA Directive and consequently the Environmental Assessment (Scotland) Act 2005. Extending beyond the focused consultation questions, the SEA findings, and comments in response to them, were extensive.

B1.18 Integrating the responses to these questions with those on the options and regional prioritisation, key issues are set out in relation to the overall topics and issues below.

Climatic Factors

B1.19 The environmental assessment concluded that the Draft Plan would have major beneficial impacts on climatic factors as a result of the role of operational wind farms in the long term in reducing greenhouse gas emissions. In terms of the short term sites, it was noted that the Argyll Array had the potential to make the greatest positive contribution to renewable energy generation targets as a result of its size and location.

Consultee views

B1.20 Consultee views relating to this topic area tended to be made in conjunction with opposition to some of the short term options, rather than taking the form of broader comments on the Plan as a whole. A number of consultees raised concerns that the proposed developments would make only a minimal contribution to climate change mitigation. Some contended that this was due to some sites, particularly in the Solway Firth but also Kintyre, being located in areas with relatively low wind speeds. Others believed that wave and tidal energy generation would be more reliable sources of energy than offshore wind. Again in the South West, many asserted that more information on the efficiency and output of Robin Rigg wind farm should be made available, to allow their view that offshore wind was not worthwhile to be substantiated. A few consultees expressed doubt that climate change was a real issue and therefore questioned the necessity and efficiency of offshore wind development.

B1.21 A significant number of consultees expressed support for the broad aim of the Draft Plan to secure a greater contribution to climate change mitigation from offshore wind or renewable energy more generally. This view was often tempered by comments that this should not mean that offshore wind energy development should take place at any cost. The RSPB, for example, questioned the benefits identified by the assessment as they contended that climate change impacts will arise over the very long term and are uncertain. As a result clarification was sought as to how the precautionary principle had been applied to the assessment.

Issue / View

Response

The Plan was predicted to generate significant positive effects on climatic factors.

The need to maximise the contribution of offshore wind to renewable energy generation in Scotland has underpinned the development of the Plan. The finalised Plan has drawn on the available evidence and responses to the associated consultation, to achieve this in a sustainable way.

Consultee views on the potentially limited contribution of offshore wind to climate change mitigation.

The Scottish Government is committed to maximising the contribution of offshore wind, along with other types of renewable generation, to the overall energy mix. This will help to ensure that Scotland meets ambitious renewable energy and climate change targets and secures related economic and environmental benefits. Views on the productivity of offshore wind are recognised but the options are nevertheless expected to provide scope to generate a significant amount of low carbon electricity.

Consultee preferences for wave and tidal energy generation.

This Plan only goes as far as considering the opportunities for offshore wind energy generation. The process of developing a separate sectoral plan for wave and tidal energy has commenced, building on the published Marine Energy SEA as a starting point for the process. These sectoral plans will be taken into account within the national and regional marine planning processes.

The SEA took into account potential for cumulative effects as far as possible at this stage. In addition, cumulative effects and synergies between offshore wind and marine energy generation will be considered as part of the development of the Marine Renewables Plan, and will be subject to further assessment and public consultation.

Consultee views that renewable energy should not be given preference over other users of the sea or environmental issues.

There is no intention to develop renewable energy in a way that overrides the needs of other users of the sea or environmental issues. To provide reassurance in response to consultee concerns, this is noted within the Plan itself.

Water Resources

B1.22 There is potential for this type of development to disturb the seabed, with consequences for the water environment and the associated habitats and species. The assessment concluded that the impacts of the Draft Plan on water quality remained uncertain at this stage. However, it was noted that this type of effect could impact on the ability of fish species to spawn, breathe and feed, and that there was potential for shellfish waters to be affected.

B1.23 The SEA showed that construction and decommissioning effects would be temporary but could be significant. Extending into the wind farm operational phase, removal of energy from the water column was also found to have the potential to affect wave climate, hydrology and water quality, and these effects remain largely uncertain at this stage.

Consultee views

B1.24 Some consultees asked for further clarity on the impact of the Draft Plan on the water environment. The Scottish Environment Protection Agency ( SEPA) identified areas where impacts on water quality had the potential to be most significant and advised that the baseline information on water could be improved by making reference to the status of waters, as classified in line with the Water Framework Directive. Fishing sector respondents questioned how the Draft Plan related to the requirement for marine waters to reach good environmental status by 2020.

B1.25 SEPA identified where, at a regional, option and site level, there may be particular issues arising with water quality. This included: Bell Rock, Kintyre, N1, and NW8. Where this is found to be the case, there would be a need to justify development on the basis of a lack of other alternatives. SEPA pointed out that, in some cases, further morphological assessment will be required.

B1.26 Other consultees raised issues about the potential effects of development on the wave climate and sediment. The wave climate (dampening of waves, changes to height or direction) was raised by several people, including those with particular interests in water sports, and those with more general environmental awareness. Sediment movement and effects on currents was also highlighted as an issue. In contrast, some developer groups suggested that, on the basis on information gathered at the regional level, it may have been possible to scope water out of the assessment.

Issue / View

Response

Effects of the Draft Plan on water resources were viewed as uncertain.

This uncertainty has been taken into account within the finalised Plan. Further assessment focusing on the effects of offshore wind on water, and in particular the wave climate is required, as noted in Section B5.

Impacts on the wave climate and currents were noted by consultees.

SEPA identified areas where water is a key concern and recommended further assessment. The context of the Water Framework Directive and good environmental status was emphasised.

This issue has been noted, and will require further consideration at the project level.

Geology, Sediments and Coastal Processes

B1.27 The SEA concluded that effects of the Draft Plan on geology, sediments and coastal processes were also uncertain. However, potential for disturbance of the seabed was raised, together with possible effects on sediment transport dynamics and water quality, with secondary implications for other matters including biodiversity.

B1.28 It was noted that the short term sites in the east region had the highest potential to impact on the seabed and cause erosion or accretion of designated geological sites, and there was potential for these effects to combine with other activities to generate more significant effects in areas such as the Firth of Forth.

Consultee views

B1.29 Responding to the consultation, the fishing sector recommended more work on impacts on sediments, including research to establish its consequences for commercial fishing operations. This was also raised as local concern in some areas, including Wigtown Bay and Kintyre. In terms of the Solway, people were concerned that sediment disturbance could also mobilise radioactive particles on the seabed.

B1.30 Coastal processes were also raised and potentially sensitive areas highlighted. This included the Gauldrons and the Machrihanish Dunes on the Kintyre coast, and Tiree. Geology was also a concern in these locations, in terms of ability to construct wind farms and the likelihood of seismic activity at Kintyre.

Issue / View

Response

Effects of the Draft Plan on geology, sediments and coastal processes were viewed as uncertain.

This uncertainty has been taken into account within the finalised Plan. Further research focusing on the effects of offshore wind on geology, sediments and coastal processes is proposed in Section B5 of the Plan, which highlights the need for collaboration between key parties to achieve this. This issue will also need to be explored in more detail within the site licensing process.

Impacts of sediments was raised by consultees, including the fishing sector.

Impacts on coastal processes was raised generally, and in relation to specific locations.

Geology and coastal processes was raised as a potential issue in relation to Tiree and Kintyre.

These issues have been noted and identified as key issues requiring further consideration in the mitigation measures identified in the finalised Plan (West Region).

Biodiversity, Flora and Fauna

B1.31 A range of effects were predicted in relation to this environmental topic. Adverse effects included those that could impact on underwater habitats and associated species in the footprint of the development, displacement or disturbance of birds, mammals, fish, benthic communities and flora through a combination of factors including noise (multiple noise sources), vibration, visual and light intensity changes, water quality changes, habitat disturbance or the presence of structures or vessels. Further potential cumulative effects were identified, particularly in relation to mammals and migratory fish from an increased number of barriers affecting movement, multiple noise sources during construction and increased vessel disturbance. It was also noted, however, that many of the effects would arise during construction and decommissioning and may therefore be temporary and reversible.

B1.32 Given the high level nature of the Plan at this stage and acknowledged data gaps, the assessment showed some uncertainties in these types of effects. This included impacts on nature conservation sites through changes in coastal processes and sediment circulation. In addition, it was noted that the sensitivity and behaviour of species to particular noise and vibration generating activities was uncertain and that species distribution is also unknown. In addition, effects may vary from those predicted depending on the baseline at the project level. For example, effects may be less significant in areas which have already been subjected to trawling.

B1.33 Positive effects were also predicted by the assessment, including the creation of artificial habitats for marine organisms resulting from the presence of new structures.

B1.34 In terms of the options, it was noted that in the North East and East, there is potential to affect the population of bottlenose dolphins which is resident in the Moray Firth, as well as internationally important resident and migratory birds. In the South West, impacts on wintering wildfowl and waders in international conservation sites and Important Bird Areas were predicted.

B1.35 The assessment concluded that all of the options had potential to impact on cetaceans, seals, migratory birds, otters and fish nursery and/or spawning areas. More specifically in relation to fish, most of the short term options were shown to have the potential to impact directly on spawning grounds for mackerel, plaice or sandeels and nursery areas for plaice, whiting, herring, cod or saithe.

Consultee views

B1.36 Many consultees commented on the potential effects of the Draft Plan on offshore and onshore biodiversity, including habitats and species. These impacts were raised in virtually all of the Plan's regions, and consultees highlighted assets which are particularly valued. Some also emphasised the importance of natural heritage to coastal and marine tourism. Several environmental organisations (both statutory and non-statutory) recommended restraint, given the potential significance of effects overall, and the uncertainty about biodiversity impacts that remains at this stage.

B1.37 Some comments recommended further evaluation, for example those focusing on impacts on marine mammals, birds and fish species. Issues were raised about designated sites, from the international to local level. Wider biodiversity, which is not afforded as high a level of protection, was also noted to be of comparable importance to communities and other interested parties. Several consultees emphasised the importance of ensuring that the assessment of effects takes into account natural heritage interests lying beyond Scottish Territorial Waters, including the RSPB, the Northern Ireland Environment Agency ( NIEA) and Natural England.

B1.38 The fishing sector questioned conclusions of the assessment suggesting that displacement of trawling activity or the creation of artificial reefs would provide benefits. Others, specifically wind industry respondents supported the conclusion that habitat creation or enhancement would occur. This underlines the need for further study of this matter, as set out in Section B5.

B1.39 Impacts on migratory birds and mobile marine species were a particular focus, with organisations being particularly concerned with how impacts on them could be undertaken in a meaningful way. Detailed responses focusing on biodiversity impacts were received from the RSPB and Scottish Environment LINK. The RSPB considered that there was a need to more fully assess collision risk for migratory and passage birds, taking into account factors including low visibility at sea. Scottish Environment LINK highlighted a number of issues and provided clarification and corrections on some of the data and associated conclusions. This information was supplemented by further detailed views from other environmental organisations. Further responses focused on potential impacts on bats, arising from collision risk, and asked that this is given further consideration.

B1.40 Questions were also asked about the data used to inform the assessment, and on how known data gaps would be filled. In terms of the baseline, comments were made about the timing of the Plan in relation to designation of Marine Protected Areas and marine foraging Special Protection Areas ( SPAs), with some consultees viewing development proposals as premature on this basis. Further environmental problems were raised to feed into the assessment. SNH had questioned the data used in mapping options within MaRS, with concerns including the use of incomplete information on biodiversity. Information on marine mammals was raised by a number of respondents, with further data including basking shark hotspots and on cetaceans providing a particular focus. Construction activities including pile driving and noise, and cables were noted as particular issues. Scottish Environment LINK suggested that clear recommendations and resourcing are required to address data gaps, and recommended that SNH take a lead in compiling and updating information held by stakeholders. Some aspects of the baseline were welcomed, including the reference to Important Bird Areas ( IBAs) which overlap with and extend beyond statutory designations.

B1.41 Several consultees made recommendations for the Habitats Regulations Appraisal ( HRA) (see Section B3).

Issue / View

Response

Negative effects on underwater habitats and species.

This has been taken into account within regional recommendations, and in terms of mitigation measures for each of the short term sites, to be explored in more detail at the project level. The need for further research on the effects of offshore wind on biodiversity is acknowledged. Key priorities are noted in Section B5 of this Statement.

Some consultees believed that these effects would be significant and therefore recommended a precautionary approach.

Negative effects on birds including wildfowl and waders in the South West.

This issue has been noted within the Plan as requiring further consideration in the South West Region. In addition, recommendations have been made for further research on biodiversity nationally and regionally within Section B5.

Negative effects on marine mammals including bottlenose dolphins.

The Habitats Regulations Appraisal ( HRA) (see Section B3) has explored the potential for effects of developments in various locations on bottlenose dolphins and other marine mammals. Mitigation measures and further research have been identified as set out in Section B5. Further assessment will be required at the project level, as noted in the Plan.

Potential effects on fish nursery / spawning areas.

A commitment to further research on the interaction of spawning and nursery areas of commercial fish species with offshore wind energy development has been identified in Section B5. Further assessment will be required at the project level, as noted in the Plan.

Effects on otters.

Effects on this species were explored in more detail in the HRA. Further assessment will be required at the project level as more specific development proposals come forward.

Views that impacts on existing and future designated sites and species should be considered further.

The HRA has assessed the potential for effects on internationally designated sites and this will continue within the 2 year review process. Further assessment will be required at the project level as more specific development proposals come forward.

Concern about uncertainty about biodiversity effects at this stage, data gaps and the need for further research.

The need for further environmental data to be gathered and taken into account within the selection of options is acknowledged in Section B5 and is a key driver for the further sensitivity testing of MaRS to be undertaken within the two year plan review process.

Concerns about secondary social and economic effects arising from biodiversity impacts, including on tourism and fishing.

Impacts on tourism and fishing have been considered within the socio-economic assessment and will be addressed within the 2 year review process.

Effects on bats should be considered further.

Effects of development on bats should be explored further, through research and at the licensing stage as more specific development proposals emerge.

Positive effects through the creation of artificial habitats from new structures.

It is acknowledged that views on this finding are mixed. They range from those who consider that the positive effects have been overstated, to those who consider the assessment to underestimate the benefits. To clarify this, Section B5 of this Statement includes a commitment to review monitoring data and available evidence to establish if there is scope for these benefits to accrue.

Migratory / Anadromous Fish.

Review undertaken by Marine Scotland Science ( MSS) and SNH. Further research identified and will be taken forward within the Plan review process.

Landscape, Seascape and Visual Amenity

B1.42 Effects of offshore wind energy development on coastal landscapes, seascapes and visual amenity formed a key consideration in the environmental assessment associated planning process. Taking into account the likelihood of significant environmental effects at a national scale, two further specific questions were included for consultees, to ensure that this issue was explored as fully as possible:

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 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?

11. Do you have any other views on the findings of the SEA? Do you think that all the environmental effects have been identified? Are there other issues that we should be taking into account in the preparation of the Draft Plan?

B1.43 The assessment identified a range of effects, from neutral to major change on landscape character and visual amenity. The options located within 8km of designated landscapes and receptors on the coastline were predicted to have potentially significant effects. These effects were characterised as 'changes', rather than positive or negative effects, as the assessment explained that this can be subjective, depending on the preferences and perceptions of viewers. It was also noted that decommissioning would reverse these effects.

B1.44 It was recommended within the SEA Environmental Report that further consideration is given to the combined presence of existing and proposed wind farms in the southern part of Scotland. It was also noted that at the project level the combined effects of other types of development with wind energy generation proposals will need to be fully assessed.

B1.45 Significant changes and effects on seascape / landscape character were predicted for the Islay, Kintyre, Argyll Array (Tiree), Solway Firth and Wigtown Bay proposals, given their proximity to medium-high sensitivity seascapes. It was noted that these developments could have major visual impacts as a result of their locations close to land and nationally designated landscapes. Solway Firth and Wigtown Bay were also predicted to have potential cumulative impacts when combined with the effects of Robin Rigg wind farm. The assessment emphasised the significance of these effects, given that the two sites are within 8km of visual receptors on the coast and nationally designated landscapes ,and may together be visible from a single point on the coastline.

B1.46 In terms of medium term options, the assessment showed that NW5 and NW6 could have major impacts on seascape / landscape and visual amenity due to their proximity to high sensitivity seascapes, the coast and National Scenic Areas ( NSAs). Development in all of the other options (except E1) were shown to have the potential to affect medium or high sensitivity seascapes. All options (except SW2) were predicted to have minor impacts on nationally designated landscapes where they are located within 24 to 35 km of the sites.

Consultee views

B1.47 The overwhelming majority of respondents to the consultation focused on this issue. Many regarded it as the most significant issue that requires serious consideration and mitigation.

B1.48 Firstly, with regard to information, some respondents suggested that the landscape and visual impact assessment methodology should be updated, and made reference to other aspects that should be built into the mapping of options. This included non designated landscapes (with reference to the European Landscape Convention) key views, proximity to shore and associated areas of importance on the coast, scenery which is important to tourism, and the setting of cultural heritage remains and historic buildings (see below). Some noted that local authorities could provide a finer grain of information to feed into the baseline.

B1.49 The assessment methodology and guidance was also questioned and many consultees debated the apparent conflict between options close to shore and their interpretation of SNH guidance that appeared to suggest that a minimum separation distance of 8km or 13km between the coast and turbines should be followed. A range of other minimum distances were proposed within responses and during the consultation events.

B1.50 Specific views on these effects were raised in relation to local areas and regions, and there was a close correlation between the proximity to shore of several short term options, particularly Kintyre, Solway Firth, Wigtown Bay and the Argyll Array, and levels of public concern about their significance. As well as visual impacts on coastal and inshore receptors and the more technical impacts on landscape character or seascape sensitivity, wider issues were raised about lighting of turbines and the effect of natural light, including sunrises and sunsets, upon them. Also, the 'feel' and experience of landscapes was frequently alluded to, with visual issues extending to include qualities such as tranquillity. Impacts on key views were particularly emphasised in many parts of the West and South West, including perspectives from or to key features or important areas.

B1.51 Potential cumulative effects of the options when considered together, or with existing development and in relation to potential future plans, were also recognised by many stakeholders. Many consultees were concerned that this was likely to culminate in the industrialisation of areas.

B1.52 Impacts on National Scenic Areas ( NSAs) and wild land were discussed by a significant number of consultees, including SNH. In particular, concerns were raised about impacts of the Wigtown Bay and Solway Firth sites on NSAs in the South West, and on a regional scenic area. Impacts of the Kintyre proposal on NSAs were also raised by many environmental organisations and members of the public. Impacts of these three sites on Areas of Outstanding Natural Beauty ( AONBs) beyond Scotland were also raised, with responses from Northern Ireland and England.

B1.53 Secondary effects were also a key concern. Close links were made between landscape and scenic quality, and secondary impacts on tourism and quality of life more generally. Impacts on property values were also raised by a good number of consultees.

B1.54 Views on the available mitigation measures to address landscape, seascape and visual effects were also specifically sought within the consultation documents. The majority of respondents believed that mitigation, in the form of the design or layout of arrays would be ineffective. Many considered that the only measure that could have any real impact would involve removing the option in question from the Plan altogether, or, in a more limited number of responses, increasing the distance of the development from the coast or substantially reducing the number of turbines. A significant number of respondents questioned why significant landscape effects had not been viewed as sufficient grounds to merit the removal of any of the options from the Draft Plan, and strongly suggested reconsideration of this position.

Issue / View

Response

Effects on landscapes and seascapes and visual effects - individual and cumulative.

These issues have been taken into account at a national level. The Scottish Government has identified these effects as significant issues that will require robust assessment and mitigation at a project level. The Plan also acknowledges that in some cases, this may be very difficult to achieve for some projects, particularly at some of the short term sites.

Questioning of the LVIA methodology, baseline information and guidance.

The guidance is in the process of being updated. The revised version will be taken into account as the Plan is revisited. This guidance will also help to ensure that these effects are more fully and robustly assessed at the project level, as more specific details on the development proposals emerge.

Close correlation between levels of concern and proximity to the coast.

This key message has been noted. The regional guidance in the Plan aims to provide a clear signal as to where this is a significant issue.

Preference for mitigation taking the form of removing options from the Plan or scaling down / moving development further from shore.

Concerns about secondary impacts on tourism, the economy and quality of life.

This has been noted and the Scottish Government has taken this factor into consideration with regard to considering options in the Plan. Guidance on assessment at the regional and project levels will be progressed. Marine Scotland is taking forward a licensing manual to cover offshore wind development. Visual impact assessment methodology and guidance will be considered initially within this initiative and for other strategic guidance.

Effects on nationally designated landscapes. This was viewed as being so significant that affected options should be removed from the Plan. Many consultees were of the view that impacts on NSAs and AONBs meant that options should be reconsidered.

This is noted as a nationally significant issue. It has informed the Plan's guidance on the South West and West Regions. Further work on this issue will be taken forward by SNH and Marine Scotland.

Population and Human Health

B1.55 Given the environmental focus of the SEA, as agreed with the Consultation Authorities at the scoping stage, the assessment focused on a limited range of factors including outdoor recreation activity and access to renewable energy supplies. The SEA concluded that the Plan would be beneficial by helping to secure a renewable energy supply for the projected growth in the Scottish population. However, more negative effects on recreational users were also noted, as a result of combined pressure on those using the sea and the coast. Potential effects included disturbance to, displacement or loss of coastal and marine recreational areas, impacts on the wave climate and activities with associated effects on the enjoyment and potentially the safety of marine users. It was also noted that most of these effects would be reversible, subject to decommissioning.

B1.56 In terms of the regional distribution of these effects, the assessment showed that all short term options had the potential for impacts on recreational users, predominantly in and around the Firths, where concentrations of activity are greatest. It was noted that Wigtown Bay and Solway Firth could generate cumulative recreational pressures during construction together with Robin Rigg wind farm, that the Solway Firth as a whole was of great importance for informal recreation including sea angling, and effects would be exacerbated by visual amenity and seascape effects. Similar effects were predicted from the medium term options.

Consultee views

B1.57 Many individuals and organisations raised issues relating to population and health in their responses. Clear messages arising included the need to ensure that the Plan balances consideration of environmental issues, with a full assessment of its impacts on quality of life more generally.

B1.58 Recreation interests provided comments relating to their specific interests. This included a detailed response from Sportscotland and organisations including the Royal Yachting Association ( RYA) Scotland, the Scottish Canoe Association and surfing groups. These responses indicated areas where it was anticipated that impacts on these activities could be most significant. In particular known surfing areas, areas for watersports, yachting and cruising areas and coastal recreation paths and beaches were all raised as key receptors requiring further consideration. These organisations also noted that secondary effects on the economy, health and wellbeing should also be considered.

B1.59 Many consultees questioned the positive effects which were expected from the Plan in terms of its contribution to supplies of renewable energy. In the South West, there was great scepticism about the efficiency of offshore wind and questions were asked about the output from Robin Rigg. Here and in other areas, a general preference was expressed for wave and tidal energy by many. At the same time, concerns were raised that the cumulative effects of different types of generation had not been viewed in a joined up way. People also believed that it was difficult to consider the scale of development without clearer regional targets for levels of generation being set.

B1.60 Strong views arose from communities, particularly those closest to the proposed short term options, that the SEA needed to be supplemented with more detailed consideration of the effects of the Plan on people and communities. Many were concerned that the impacts of the offshore developments would fundamentally reduce their quality of life, and issues were also raised about the onshore elements of developments. This was a particular concern in the South West, in Kintyre and in Tiree in relation to the Argyll Array.

B1.61 More detailed comments are set out in the relevant sections focusing on each of the regions, but frequently cited onshore issues included grid connections, cumulative impacts from on and offshore development, impacts on infrastructure and services, and the construction of ancillary structures. The fragility of many rural and remote communities was emphasised and also linked with cultural heritage by emphasising that there is a fundamental question about the effects of development on their way of life and identity. In addition, detailed responses relating to fishing emphasised that impacts on the sector cannot be judged from analysis of the available data, with small scale concerns having a vital role to play as part of rural communities, and impacts therefore being potentially greater than had been suggested by the assessment and Draft Plan. Fishing is considered in more detail below.

B1.62 Concern about changes to workforce and population migration was also a key theme. Some communities ( e.g. Tiree) viewed this as a threat to their way of life, infrastructure and services. Others (largely in the South West) expected that development could deter people from relocating into the area, thereby undermining local communities, services and economies.

B1.63 Impacts on health were raised by a number of consultees. Key concerns included the effects of shadow flicker (potentially being exacerbated by low sun or the aspect of developments), noise (including infrasound), secondary effects from loss of outdoor recreation and effects on more general wellbeing. It was also suggested that the assessment should take into account the potential long term effects of climate change on health, in order to better reflect the full range of potential positive and negative effects of the Draft Plan.

Issue / View

Response

Negative effects on recreational activity.

These effects have been noted where relevant in relation to specific options and regions. A commitment to further working with recreation sector organisations and representatives has been included in Section B5.

Respondents noted areas where development could generate significant impacts on the basis of known recreation activity.

Potential issues at a regional scale have been identified and guidance provided on where this is expected to be a significant issue at the project level. This will require more detailed assessment at the project level.

Positive effects on renewable energy supplies.

These issues were discussed in relation to 'climatic factors' above.

Consultee issues about the legitimacy and efficiency of offshore wind as a part of the overall energy mix.

The Scottish Government is committed to maximising the contribution of offshore wind, along with other types of renewable generation, to the overall energy mix. This will help to ensure that Scotland meets ambitious renewable energy and climate change targets and secures related economic and environmental benefits.

Consultee concerns about impacts on communities.

This has been noted as a key concern. It is also noted that effects are expected to be particularly significant where developments are located close to the shore, and therefore will be visible from areas where people live and work. Where this is a particular regional or option-specific issue, it has been highlighted within the Plan, for further consideration at the project level where appropriate.

Community wellbeing was expected to be affected by development.

This has emerged as a key regional theme within the development of the Draft Plan. As noted in the Plan, a pilot project exploring scope for community led masterplanning is being taken forward for Tiree, to identify how the onshore elements of the Argyll Array proposal can be implemented in a sustainable way. It is expected that this approach, which is led by the planning authority also involves the community, developer, The Crown Estate, HIE and the Scottish Government, should be rolled out to other communities, where there are expected to be similar challenges. It is expected that this approach will also be adopted for Islay and could also be applied in other projects. The Scottish Government and its partners will reflect on this experience and ensure any lessons learned are fed into both the licensing process and the future iterations of the Plan as a whole.

Concerns about noise generated by developments and impacts on health.

Noise effects of the developments will require further assessment at the project level.

Consultee concerns about impacts on health: shadow flicker.

Shadow flicker is not expected to be a significant issue arising from the proposals for offshore wind. However, the Plan indicates that this should be assessed where relevant at a project level, and appropriate mitigation deployed.

Assessment should include consideration of the role of the Plan in reducing the long term impacts of climate change on health.

This is noted as a potential benefit of the Plan, and is part of the reasoning behind the overall commitment to climate change mitigation that underpins the Plan and Scottish Government renewable energy policy.

Concerns about changes to migration patterns: effects of large scale in-migration to small communities and concern about loss of in-migration.

This was noted as a key issue requiring further consideration. Some island communities are concerned that incoming workforces could overwhelm the local community culture and affect their way of life. Other communities require 'incomers' to retire or settle in their area to maintain house and business prices.

Cultural Heritage

B1.64 Potential adverse effects on cultural heritage were predicted in the SEA, specifically in relation to proposals for development of short term sites at Bell Rock and the Argyll Array, given the proximity of these sites to listed lighthouses and combined impacts arising from the Round 3 wind farms.

B1.65 The assessment also noted that other unknown, submerged or non-designated archaeological assets, features or palaeo-landscapes may also be present within the footprint of the short term options. Some medium term optionswere also shown to have potential for direct impacts on two designated wrecks (N7), and the St. Kilda World Heritage Site ( NW1 and NW3).

Consultee views

B1.66 Comments on the predicted cultural heritage effects of the Draft Plan were largely made in relation to specific sites or options. Historic Scotland agreed with many of the assessment findings, including the potential for effects on lighthouses and their settings and designated wrecks. In addition, Historic Scotland noted that much had been passed to the project level, given the scale of the Plan, and recommended further thought being given to identifying the generic types of monuments that would require further consideration. It was noted that fortifications, duns, brochs, lighthouses, ecclesiastical sites, chambered cairns, castles and A listed structures could be particularly affected by offshore wind proposals and will require further consideration.

B1.67 The importance of considering impacts on onshore coastal archaeology, wrecks and underwater landscapes was also raised. In some areas, specific coastal sites were identified that could be affected by offshore wind development. Other responses noted the importance of non-designated resources including sacred sights, historic routes and culturally important views. In Tiree, it was emphasised that the island and its community constituted a resource and way of life of cultural heritage significance in their own right. This theme also emerged in other communities. Shetland Islands Council also noted potential impacts on Sule Skerry Lighthouse, the Heart of Neolithic Orkney World Heritage Site, and the setting of numerous coastal scheduled sites.

B1.68 The National Trust for Scotland highlighted a number of key options which could impact on the views from, and setting of, their properties including St Abbs Head (Forth Array) and others in the South West. Further issues raised by English Heritage and the Solway Firth Partnership included the potential impact of development on the Lake District National Park and Hadrian's Wall World Heritage Site. The Northern Ireland Environment Agency also noted concern about effects on the Giant's Causeway World Heritage Site.

B1.69 Historic Scotland broadly welcomed the overarching approach to mitigating impacts on cultural heritage, including detailed positioning of sites and turbines within option boundaries to avoid or reduce impacts. This was considered particularly important for the options on the west coast.

Issue / View

Response

Cultural heritage effects on listed light houses (Bell Rock and Argyll Array).

These have been noted as issues that will require further assessment and appropriate mitigation at the project level.

General adverse effects on archaeology.

Effects on designated wrecks.

Further consideration to types of features that could be affected by development at a project level would be welcomed.

Effects on non-designated aspects of cultural heritage should be taken into account.

Comments on specific types of monuments which could be sensitive to change.

Effects on the St. Kilda World Heritage Site.

Two of the early medium term areas of search that had the potential to adversely impact on the outstanding universal value of the WHS were removed from the Draft Plan as a result of the SEA.

Impacts on other World Heritage Sites: Hadrian's Wall and the Giant's Causeway.

The SEA findings have been reviewed and it is acknowledged that specific projects could have impacts on these sites. This information has been taken into consideration in the Plan's recommendations for the West and South West Regions.

Mitigation measures are appropriate for a high level plan.

The mitigation measures identified in the SEA and HRA have been incorporated into the Plan. This includes a commitment to further research identifying submerged archaeology.

Material Assets and Other Technical Issues

B1.70 The development of the Draft Plan included consideration of navigation under the heading 'material assets' as well as early consideration of further issues which were viewed as lying beyond the scope of the SEA, as agreed with the Consultation Authorities. This included commercial aspects of fishing (fish stocks having been addressed under 'biodiversity'), radar and aviation issues and other forms of offshore renewables (wave and tidal). In addition, the MaRS mapping system that was used to identify medium term options included consideration of more detailed factors, such as the presence of cables and munitions on the seabed. These issues were set out in the Draft Plan and are discussed below.

Navigation

B1.71 Potential navigation issues were identified in the development of the draft Plan. This included the building key navigational data into the MaRS process, including referring to shipping density and RYA cruising routes, sailing areas and racing areas, anchorage areas and navigation aids and technical issues. International Maritime Organisation ( IMO) routes were identified as exclusions within the mapping process.

B1.72 Navigation issues were identified in all of the regions, and it was noted that development could impact on areas of moderate or high vessel activity. Key areas of concern included the North where some options lay within heavily used shipping routes (routes between north west Orkney and Shetland) and, in the North West where the Minches and a ferry route were particular concerns. In terms of mitigation, it was noted that the Maritime and Coastguard Agency would manage these effects to ensure there are no hazards to shipping.

Consultee views

B1.73 As with many other topics, much of the focus of comments on navigation related to the effects of specific developments, or on certain areas or regions. Issues were raised in all of the areas covered by the Plan, with varying levels of concern about the possible consequences of development for safe navigation.

  • In the North, concern was expressed about impacts on the use of the Pentland Firth and Fair Isle Channels, and the importance of Lerwick was raised.
  • Navigation in the Moray Firth was noted in the North East, and recognition of ports in the area was welcomed.
  • In the East, individual and cumulative effects of the short term sites in combination with the Round 3 zone, beyond Scottish Territorial Waters, were key concerns.
  • In the South West, people and organisations were concerned about impacts of development on busy shipping routes, including the impact of option SW1 on the Belfast and Larne to Loch Ryan ferry crossing and on traffic between the coast, North West England and the Isle of Man.
  • Dumfries and Galloway Council provided more detailed information on navigation which suggested that the Wigtown Bay proposal should be removed from the Plan. This was supported by the public's view that the site was located on a navigation route, and would require more detailed assessment. Recreational boating was also a key concern.
  • In the West, impacts on shipping routes were also raised and it was noted that diversions would incur costs, with particular implications for small fishing concerns.
  • Area W1 raised concerns as a result of its potential to restrict access from the Minch and the impact of W4 on users of the IMO route in the North Channel were also raised.
  • Significant issues were raised in relation to the North West, with several options potentially impacting on important shipping routes. Access to the Minch from both north and south was raised by several key consultees, and will require further consideration.

B1.74 Recreational sailing and navigation by the fishing sector were also highlighted at the regional and option levels. General concerns were raised about the data that had been used to assess impacts on navigation, and it was particularly emphasised that AIS data does not cover small vessels. Some respondents also noted issues about access to ports and harbours. Mitigation was touched on by some consultees, who noted that physical gaps or restrictions in operations could be used to reduce safety risks to an appropriate level.

Issue / View

Response

Potential navigation issues, particularly in the North and North West

Further liaison with the shipping sector will be undertaken at a national level, as recognised within the Draft Plan.

Specific hotspots identified at the regional and option level

These hotspots have been noted and referred to as appropriate within the regional and site specific recommendations.

Impacts on recreational and fishing vessels

Shortcomings of shipping data used in the assessment

This has been noted. Further information on shipping will be provided through traffic navigation assessment work at the regional level.

Scope for mitigation.

Mitigation measures will be identified following more detailed assessment at the regional level and project stage, but should include consideration of the potential cumulative effects arising from multiple developments in specific regions.

Further liaison with key organisations and more detailed risk assessments will be required to identify the need for mitigation at the project level.

Fishing

B1.75 In terms of commercial fishing activity, information gathered to inform the development of the Plan showed that the impact of offshore wind options was likely to vary between regions, but that the Draft Plan as a whole was expected to have potentially significant adverse effects on the Scottish fishing industry. Commercial fishing value was one of the criteria that was viewed as a 'technical constraint' and embedded in the MaRS process. In addition, particularly high levels of catch were noted in some areas such as the West and North West, whilst others, including the South West, were considered to be potentially less sensitive to development as a result of relatively low recorded catches.

B1.76 This assessment was linked with the SEA findings relating to fish (including spawning and nursery areas), as recorded under the heading of 'Biodiversity' within the Environmental Report.

B1.77 In terms of regional findings of the SEA, most of the options were found to overlap with nursery and / or spawning grounds of commercial fish species. However, the consultation highlighted a need for much more information about fishing activities to inform planning and development activities. Work to achieve this is underway (see Section B5), and there will be a need for further assessment of regional level socio-economic impacts arising from specific proposals.

Consultee views

B1.78 Many respondents focused on fishing, including key sector representative organisations, individuals and businesses.

B1.79 Firstly, concerns were raised about the data used to develop the Plan. The information which had been used within MaRS to identify options was questioned, as well as the weightings and scorings that had been applied. The Scottish Fishermen's Federation ( SFF) offered to provide data at a finer grain, whilst the National Federation of Fishermen's Organisations ( NFFO) stated that the data were deficient, suggesting that there was a particular need for further information to be gathered from the Cumbria Sea Fisheries Committee and the Irish Sea Marine Conservation Project. The West of Four Fisheries Management Group ( WOFFMG) contended that there was a need for more data on commercial fishing and for that data to be afforded the highest weighting. The Sea Angling Conservation Network raised similar issues. As a result, the outputs from MaRS were not considered to be accurate by those responding from the fisheries sector.

B1.80 In terms of regional perspectives, key issues can be summarised as follows:

  • In the North, it was noted that further information on the creation of artificial reefs and loss of fishing grounds is required.
  • Fishing impacts were a key issue in the North East, with the Moray Firth Inshore Fisheries Group, for example, raising particular concerns about specific aspects of development including cabling, test sites, navigation and diversion, exclusions and safety.
  • In the East, the conclusions of the assessment about potential impacts on fish stocks were questioned by the prospective developers, given the lack of certainty about the site layout at this stage.
  • Many responses focused on fishing in the South West from the fishing sector and the wider public. There was concern about impacts and a view that these interests had not been fully covered within the SEA, but also an offer of assistance in undertaking a fuller assessment of the Plan was offered.
  • Displacement of activity and the consequential increase in pressure in remaining areas was a key issue. Respondents reported particularly high impacts on small vessels originating from Cumbria and the Isle of Man.
  • Key issues also included impacts on migratory fish routes, nursery and spawning grounds. Effects on salmon and sea trout (questioning the impact of cables), cockle and shellfish aquaculture, lamprey, smelt and eels.
  • Fishing was noted to be a major economic driver for the region as a whole. Overlaps with trawling routes and potential interference with static gear activities were raised. It was emphasised that there is a lack of safe alternatives to sheltered fishing areas which could be affected by the Plan.
  • In the West, key responses focused again on the data used in MaRS and it was emphasised that current activity and the value of catch were inaccurate. Migratory fish were also a key concern.
  • Questions were asked about compensation and the Clyde Fishermen's Association asserted that impacts on safe navigation and displacement of activity had been inappropriately overruled by a drive towards renewable energy development.
  • It was emphasised that many small communities rely on fishing and that seemingly small scale effects may nevertheless be very significant for their survival in socio-economic terms.
  • In the North West, fishing interests were a significant concern. Again it was recommended that more detailed data are built into the assessment.
  • Concern was expressed about engagement with the sector and it was noted that the Plan would only add to ongoing challenges. It was suggested that a common sense approach to exclusions was needed.
  • In Barra, the fishermen pointed out that they had historic rights to harvesting the water column and should therefore be entitled to the benefits arising from its development.

B1.81 It was recommended by sector respondents that these issues are explored in more detail to ensure the implications of the Plan on the fishing fleet as a whole was fully understood before it is adopted.

Issue / View

Response

Impacts on commercial fishing activity particularly in the North and North West were raised by the SEA.

Consultees raised further concerns about fishing in other regions, particularly the South West but also the East, North and North East, in addition to the West and North West.

This has been noted as a key issue at the national, regional and local scales. At the national and regional scale, further liaison with stakeholder organisations will be undertaken to establish how the Plan can be delivered with minimal effects on the fishing sector. Commitments to this and to further research relating to the sector is set out in the Plan and Section B5 of this statement respectively. This will include fishing activity mapping and evaluation and regionally focused socio-economic assessment. In addition, further assessment and appropriate mitigation measures will be required regionally and locally, as specific development proposals come forward for licensing at the project level.

Concerns about data used in MaRS to identify options - view that they do not reflect fishing interests.

The issue of available data is being addressed through further research on fishing activity. This information will be fed into the ongoing use of MaRS to refine options and subsequent review of the Plan as part of the 2 yearly cycle.

Impacts on the Scottish fishing fleet should be further assessed in the socio-economic study.

This has been explored in more detail in the socio-economic assessment and will be informed by the further spatial analysis of fishing activity and regional assessment, set out in Section B5.

Aviation and Radar

B1.82 Aviation and radar issues were built into the MaRS process as constraints, including a 24km buffer around Ministry of Defence airfields, UK Civil Licensed Aerodromes, helicopter platforms and routes and Radar Interference Zones. In addition, the Draft Plan highlighted where regional radar issues were expected to arise. This included NATS radar areas potentially affecting a number of sites within all of the regions, and buffer zones for airports, influencing potential development in the East and West. In addition, helicopter activity and potential interference with RAF Lossiemouth and Kinloss were identified in the North East.

B1.83 The analysis was broad at this stage, reflecting the national coverage of the Plan and noting that these issues are better resolved at a project level when further information on the height and number of turbines and layout of arrays are clearer.

Consultee views

B1.84 A number of specialist stakeholders responded to the consultation, highlighting potential issues in more detail. The Civil Aviation Authority ( CAA) provided further detailed information on aviation issues, covering terminology, distances and buffer zones. It was noted that these issues will be fully considered at the project level, but suggested that further consideration of potential in-combination effects, including of offshore development combined with onshore projects, would be useful.

B1.85 Further information on aviation to and from the Isle of Man and Northern Ireland was requested. Representatives were critical of the dataset used within the assessment. North Sea helicopter routes and longer distance flight paths were highlighted as further constraints.

B1.86 In terms of regional issues, the following key points were raised:

  • In the North East, Highlands and Islands Airports Ltd. ( HIAL) stated an interim objection to the short term option of Beatrice, as a result of potential impacts on Wick Airport, but it was noted that mitigation should be possible.
  • In the East, the CAA questioned how radar issues have been avoided, given the existence of military and civil aviation radars.
  • Responses relating to the West focused particularly on the potential impact of development of the Kintyre site on Campbeltown Airport. This was viewed as unfeasible by Loganair / Flybe, a key operator using the facility. The safety issues arising here were highlighted, and it was explained that they are corresponding with the prospective developer to seek a solution.
  • In addition, potential impacts on air traffic control from the Argyll Array were noted by consultees.

Issue / View

Response

Potential effects on aviation and radar, particularly in the West and East.

These issues will need to be addressed at the project level. Liaison with the aviation sector is already underway at a number of the short term sites.

Further assessment required at the project level

Datasets used at this level may not be suitable.

Views on the limitations of the datasets used is acknowledged, but the information used at this stage is considered to provide a sufficiently broad perspective on likely issues that will require further assessment at regional and / or project levels.

Cumulative assessment of on and offshore development should be undertaken.

Assessment of these issues will be required at the project level to take into account cumulative effects arising from on and offshore development.

Regional / site specific issues in the North East, East and West.

These have been noted as significant issues and in relation to the specific short term sites and medium term options.

Military Activity and Munitions

B1.87 The Draft Plan explained where development sites and options coincided with military activity. For the medium term options, the MaRS mapping process took into account Ministry of Defence (MoD) munitions dumps and Danger Areas as exclusions to development, and MoD Practice and Exercise Areas ( PEXA) were viewed as a constraint.

B1.88 The Draft Plan also identified where there were potential issues at a regional level. In the North, this included the MoD exercise area at Cape Wrath, a munitions dump off the Aberdeen coast and MoD training area in the Dornoch Firth, military interests in Fife (Rosyth and Leuchars) affecting sites in the East, MoD training areas and a munitions dump in the South West, and MoD training areas in the West and North West.

Consultee views

B1.89 The MoD provided a very detailed response to the consultation, confirming areas of potential constraint at a regional level. It was noted that PEXA had been identified as a constraint, but that there may be scope to accommodate development in these areas, depending on issues being addressed on a case by case basis. The MoD did not support the approach to using buffer zones around radar facilities, as its analysis uses actual radar coverage data and line of sight assessments to provide a more accurate picture of effects. In addition, the MoD had concerns that precision approach radar systems at military aerodromes, Ministry air traffic control facilities not at aerodromes, air defence and meteorological radar sites had not been covered.

B1.90 At the regional level, more detailed information was provided:

  • In the North, the air defence radar at Saxa Vord should be considered as it could be a constraint to development in the vicinity of the Shetland Islands.
  • In the North East, the constraints identified at Kinloss and Lossiemouth should be extended to reflect air traffic control radars. Other key assets include the Hill of Dudwick Meteorological Radar, RAF Tain Air Weapon Range (potentially affecting NE1) and MoD Danger Areas in proximity to NE1 and NE2.
  • In the East, the potential impact of the medium term option on Naval Exercise Areas was noted as an issue requiring further consideration. In addition cumulative impacts of the short and medium term options were a concern as a result of their potential to block key maritime and strategic defence navigational access to the Firth of Forth.
  • In the South West, medium term options were a concern and it was noted that ongoing military training should be seen as a further constraint. The public in the area also raised concerns about munitions dumps and the existence of live shells in the proximity of Dundrennan MoD range.
  • In the West, impacts on MoD low flying exercises and exercises at sea were noted. Some consultees also raised concerns about the likelihood of munitions migrating on the seabed.
  • Extensive MoD activity was raised in relation to development options in the North West. Air traffic control radar on St. Kilda and South Uist and the Drium-A-Starraid Meteorological Radar near Stornoway were raised. Further potential conflicts arising from some medium terms options ( NW6, NW7) were raised, with the MoD recommending their relocation as a result.

Issue / View

Response

Effects on military activity across the regions.

These have been noted as key areas where further liaison with the Ministry of Defence will be required.

Incomplete data on military activity and installations at this stage in the process.

Regional level constraints and potential impacts on further installations and activities identified by the MoD.

Further comments on the likelihood of munitions migrating on the seabed.

This issue will require further assessment at the project level.

Other marine renewables

B1.91 The interrelationship between wave and tidal power proposals and offshore wind was broadly considered within the assessment. The Draft Plan included some areas of exclusion at the MaRs mapping stage, including the European Marine Energy Centre ( EMEC) and other wave and tidal power lease sites.

B1.92 In the North Region, The Crown Estate leasing round for wave and tidal development were noted. Areas with potential for marine renewables in the West and North West were also noted within the Draft Plan.

Consultee views

B1.93 The majority of respondents referring to this issue expressed a general preference for wave and tidal energy as an alternative to offshore wind. Many people questioned whether cumulative effects and potential positive synergies between different types of activity had been taken into account. This issue arose particularly in the South West, where many consultees suggested that a tidal barrage across the Solway Firth would be a preferable development proposal and questioned why no Saltire Prize areas had been identified in this location. In the West, wind industry respondents and The Crown Estate questioned the identified cumulative effects arising from the Sound of Islay project in combination with medium term options. They suggested that timing of the development and mitigation measures identified in the Marine Renewables SEA should be explained further to provide a clearer picture of these effects. Potential development areas were identified in the area between Kintyre and Rathlin. Opportunities for co-development of wave and tidal and wind projects were also raised in the West region. In very broad terms, many respondents believed that marine renewables offered a more sustainable and efficient form of generation than offshore wind.

B1.94 Others suggested that, in the absence of fuller consideration of areas identified for wave and tidal development, the MaRS analysis was incomplete. For example, Comhairle nan Eilean Siar recommended further consideration of information gathered to inform The Saltire Prize.

Issue / View

Response

Areas of constraint as a result of ongoing and future wave and tidal energy in the North, West and North West.

As noted under the heading of 'climatic factors' above, the need to reconcile aspirations for offshore wind, wave and tidal energy will be considered further within the Marine Renewables SEA and Plan, and national and regional marine planning processes.

Consultee preference for wave and tidal energy generally, particularly within the South West.

This is noted, and will be explored further within the ongoing Marine Renewables Plan development process.

Estimation of cumulative effects of tidal and wind energy - Sound of Islay.

This is noted. The findings of the SEA and this opinion should be taken into account in Plan review, Marine Renewables Plan development and more detailed regional and project level assessment.

Electricity Transmission Grid

B1.95 Grid capacity and availability were not specifically considered within the development of the Draft Plan, as this was viewed as lying beyond its scope, and therefore its assessment. This also reflected a general assumption that, should developments proceed, a connection will be provided and will require to be considered at the project level. Further strategic options will be considered within the Plan review process.

Consultee Views

B1.96 The electricity transmission grid was raised by several respondents as an issue requiring further consideration.

B1.97 Firstly, concerns were expressed about the potential onshore implications of development and additional environmental effects arising from associated grid connections. With regard to the MaRS stage of the process identifying options, some consultees, including SEPA and Scottish Environment LINK, suggested that the assessment was incomplete in the absence of further information about the grid. Argyll and Bute Council asserted that this omission meant that an opportunity was being missed to consider infrastructure requirements, and as a result the full range of environmental effects could not be identified. SNH also viewed the lack of consideration of cable connections to be a major omission.

B1.98 At the regional level, this was a particular concern in the South West, where people also anticipated that any potential developments would connect with the grid in England, thereby reducing their potential benefits to Scotland. Questions were also raised about the grid connection in the West.

B1.99 In the North West, it was emphasised that development should proceed at a faster pace, in order to enable upgrading of grid connections.

Issue / View

Response

Likely grid connections and associated environmental effects remain unknown at this stage.

This remains the current position. The Plan does not cover matters relating to the grid.

However, the proposed Marine Renewables Sectoral Marine Plan, the review of this Plan, national and regional marine planning and project assessment will explore this issue further.

MaRS should have incorporated further consideration of grid capacity and connections.

This will be explored further within the further work on the MaRS model as outlined in the Plan and Section B5.

Cumulative on and offshore effects from the grid connections should be considered further.

It is not possible to fully define these effects at the Plan level. As specific requirements for connections emerge, further Plan review and regional level consideration of this issue will be undertaken. Cable and grid connection issues will have to be addressed at the project level.

Scope for the Plan to achieve grid upgrades should be taken into account.

What were the views on developments in specific locations or regions?

B1.100 The development of the Draft Plan was based on the identification of short and medium term options for offshore wind energy development. Whilst this created additional complexity and raised questions about the extent to which apparently site specific issues could or should be addressed in a strategic level assessment, it also provided a useful means of exploring the full range of potential environmental effects of the Draft Plan.

B1.101 In order to explore the Draft Plan and its effects from a regional perspective, consultees were asked the following questions:

4. Should any options be removed from the Draft Plan?

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

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 or other regions, or individual options within them, should be given lower priority or perhaps deferred to the long term?

B1.102 The following section summarises the key effects and opinions relating to each of the regions containing short and medium term options. These issues have been taken into account in the development of the Plan. In addition, the recommendations for each of the regions should form a guide for the project assessment stage. Whilst it is acknowledged that more detailed information, proposals and environmental assessment may rule out some of these issues, they will form a reference position.

East: Short term options

Potential Environmental and Technical Effects

  • Potential adverse effects on marine mammals, including Moray Firth bottlenose dolphins.
  • Potential effects on resident, breeding and migratory birds.
  • Direct adverse impacts on fish spawning grounds.
  • Minor to moderate visual effects, minor to moderate seascape effects.
  • Adverse impacts on shipping accessing the Firth of Tay and Firth of Forth.
  • Potential impacts on commercial fishing activity.
  • Potential impacts on migratory fish.

Opinions

  • There will be a need to assess cumulative effects of short term options in combination with option E1.
  • Cumulative impacts of short term options are already being considered at a regional scale.
  • Concerns about individual and cumulative effects on navigation and access to ports.
  • Potential impacts on beaches and surfing (wave climate).
  • Concern about potential radar issues and impacts on access to defence related ports on the Forth.
  • Concern that the Habitats Regulations Appraisal ( HRA) could create uncertainty.
  • A view that sufficient information has been identified to inform strategic level planning. This contrasts with others expressing concern that the Plan and the assessment attempt to cover issues which should be addressed at the project level. As a result some of the findings were considered questionable, and are not borne out by site level work. This included information on shipping and fish stocks.
  • Low level of broader general public interest or concern about the Plan or the assessment findings.

Recommendations

The following matters require further consideration within the Plan review and project level Environmental Impact Assessment:

  • Appropriate navigation mitigation, taking into account individual and cumulative effects in collaboration with the shipping industry.
  • Further consideration of impacts on fishing, in collaboration with the fishing industry.
  • Resolution of radar issues and avoidance of potential conflict with defence activities, in collaboration with the relevant stakeholders.
  • Satisfactory completion of project level HRA, taking into account mitigation measures identified in the HRA of the Draft Plan as appropriate. This should include a focus on potential effects on the Moray Firth Dolphins.
  • Cumulative and in-combination effects have to be addressed including the adjacent Round 3 site.
  • Further research is required to cover potential impacts on migratory fish.

East: Medium term areas of search

Potential Environmental and Technical Effects

  • Potentially significant cumulative effects, when short term options and Round 3 sites are taken into account.
  • Impacts on navigation and access to ports.
  • Impacts on commercial fishing activity.
  • Potentially major visual and seascape impacts due to proximity to land and nationally designated landscapes.
  • Potential effects on migratory and breeding birds.
  • Direct effects on fish nursery and spawning areas.
  • Potential impacts on migratory fish.
  • Potential effects on coastal processes and sediment transport.

Opinions

  • Impacts on Ministry of Defence activity, with potential for blocking strategic defence access to the Firth of Forth.
  • Impacts on sensitive coastal sites, including designated sites with high conservation value. Impacts on seabirds, grey seals, migrant birds, migratory fish, cetaceans, sharks, rays and skate were also raised.
  • Proximity of development to the Berwickshire Coast and associated potential for significant landscape, seascape and visual effects.
  • Low level of public interest / concern.
  • Cultural heritage effects, on the setting of Bell Rock Lighthouse, sensitive coastal sites and properties.

Recommendations

Area E1 has potential to provide longer term options for development. However, there will be a need to ensure that cumulative effects of development proposals arising within the area of search are considered in combination with the short term sites, onshore development and the Round 3 zone to the east of the region.

To address issues raised above, the following factors should be taken into account within any future site selection process within this option area:

  • The need to retain an east-west corridor allowing for maritime navigation.
  • Avoidance of significant visual effects by maintaining an appropriate distance from the coast and taking into account cultural heritage concerns.
  • Ecological assessment, including HRA to inform the site selection process.

North East: Short term option

Potential Environmental and Technical Effects

  • Potential adverse effects on marine mammals, including the Moray Firth dolphins, common and grey seals, harbour porpoise and various species of dolphin and whale.
  • Potential impacts on resident, breeding and migratory birds and fish.
  • Direct effects on fish spawning and nursery areas.
  • Minor changes in views for land based receptors, and minor seascape effects.
  • Impacts on commercial fishing activity.

Opinions

  • Information on spawning and nursery grounds is incomplete - project level data can provide a more accurate source.
  • Interim objection by HIAL on basis of impact on Instrument Approach Procedures to Wick Airport.
  • Limited general public interest / concern.

Recommendations

The following matters require further consideration within the Plan review process and / or project level Environmental Impact Assessment, which has to take account of the adjacent Round 3 site:

  • Further information on fish, being gathered at the project level should be taken into account.
  • Further discussion of the proposal with HIAL will be required.
  • Potential impacts on birds and marine mammals require further exploration, including within project specific HRA.
  • Further liaison with the fishing and shipping industries will be required.

North East: Medium term areas of search

Potential Environmental and Technical Effects

  • Potential adverse impacts on marine mammals including cetaceans and seals.
  • Potential adverse impacts on migratory and breeding birds and fish.
  • Adverse impacts on spawning and nursery areas.
  • Moderate impacts on medium sensitivity seascapes. In particular, area NE1 lies only 3km from the coast and as a result major visual change has been predicted.

Opinions

  • Concern about fishing impacts, given the importance of the area including Peterhead port to the industry. Concerns identified in the assessment were extended to include issues around cabling and potential exclusions. Further effects on food security, safety and employment were raised, as well as the need for further consultation with the fishing sector, to establish a more accurate baseline and discuss mitigation measures.
  • Questions were raised about potential grid connections onshore, and into wider European networks.
  • Shipping issues in the Moray Firth, and potentially affecting ports. Further liaison should be undertaken to address potential conflicts between marine users.
  • Ministry of Defence concerns, including the need to take into account impacts on bases, air traffic control and meteorological radar, aviation and danger areas.
  • RSPB views that the assessment of Natura impacts would require further consideration.
  • The need to recognise the economic contribution and value of the Moray Firth Dolphins.

Recommendations

There are some significant constraints to development in the North East, but it is anticipated that many issues will be overcome at the project level, and through appropriate site selection in the future. There is a need to consider cumulative and in-combination effects including those associated with the adjacent Round 3 offshore wind proposal.

To address issues, the following considerations should be built into medium term site selection within the areas of search:

  • Fishing is a key consideration requiring further data and liaison within the region as a whole. This should be linked with broader consideration of navigation issues.
  • Careful consideration should be given to the potential for significant visual impacts arising from sites within area NE1.
  • An HRA should be undertaken to inform future site selection within the areas of search and address potential effects on marine mammals, birds and fish.
  • The presence of an adjacent Round 3 site has to be taken into account.

North: Medium term areas of search

Potential Environmental and Technical Effects

  • Potential adverse effects on marine mammals, including cetaceans and seals.
  • Potentially adverse impacts on migratory and breeding birds and migratory fish.
  • Direct adverse impacts on spawning grounds and nursery areas for fish species.
  • Moderate to major adverse impacts on medium and high sensitivity seascapes from all options except N5, N6 and N8, and potential moderate visual impacts on land based receptors on the coastline, except for N1.
  • Moderate averse impacts on the Heart of Neolithic Orkney World Heritage site, although no significant impacts on the Outstanding Universal Value of the WHS are expected.
  • Potential for adverse impacts on two designated wrecks, protected under the Protection of Wrecks Act 1873, and lying within area N7.
  • Potential effects on tourism, aviation, navigation and commercial fishing.

Opinions

  • Support for further development around Orkney to support aspirations for associated economic opportunities - Orkney Islands Council suggested that options should not be ruled out at this stage.
  • Further consideration should be given to the Shetland Marine Spatial Plan and recognition of the greater potential for wave and tidal energy, given significant water depths.
  • Questions were raised about whether zoning areas for wind would preclude other marine renewables. It was also noted that technological development will be required to install turbines given water depth and wave height within the area.
  • Landward infrastructure and development should be considered further.
  • Further work on fishing is required to explore potential loss of fishing grounds and substantiate the expectation of benefits from the creation of artificial reefs.
  • Recommendation that the 250m buffer for marine mammals is extended and that UK Biodiversity Action Plan ( UKBAP) priority habitats should be recognised.
  • Likely cultural heritage effects, including on Sule Skerry Lighthouse (N1), the Heart of Neolithic Orkney World Heritage Site (including its setting), castles fortifications and churches on the north coast of the mainland, and effects from N4, N5, N6, N7, and N8 on scheduled sites on the coasts.
  • Agreement with the conclusions on effects on designated wrecks.
  • Clarification on the governance of the Plan and the roles of key organisations was sought: Will power be exported or available for purchase locally? Is there grid capacity?
  • Concerns about noise, vibration and safety of offshore wind turbines.
  • Likely impacts on resident or breeding birds. The RSPB noted particular issues with N1 and N3, given their potential impacts on high numbers of seabirds associated with Sule Skerry and Sule Stack SPA. N4 and N5 could impact on the Isle of Foula SPA. The RSPB noted concern about overall levels of development in this area.
  • Fish displacement should be considered and there is a need for further biodiversity studies to fill data gaps.
  • Navigation is a key issue - shipping routes in close proximity to option areas require further consideration. Impacts on the port of Lerwick also requires further consideration, and reference should be made to Sullom Voe.
  • Development in N1 could result in the downgrading of the water body's Water Framework Directive Status and would therefore require justification on the basis of a lack of other alternatives.
  • The MoD defence radar at Saxa Vord requires consideration.
  • Several recreation issues were raised. High levels of recreational sailing should be taken into account - these are not necessarily covered by mapped areas. N2 could impact on surf beaches on the North Coast. Kayaking could be affected by development of sites near Foula.

Recommendations

There are some significant constraints to development in the North, but it is anticipated that many issues will be overcome through appropriate option assessment and site selection within the options.

To address key issues, the following considerations should be built into medium term site selection within the areas of search:

  • Fishing is a key consideration requiring further data and liaison within the region as a whole. This should be linked with broader consideration of navigation issues.
  • Careful consideration should be given to the potential for significant visual impacts on scheduled sites, the Orkney WHS and designated coasts within the site selection process.
  • Further consideration of potential impacts on radar and shipping is required.
  • Sterilisation of areas for marine renewables should be avoided.
  • Impacts on water body status from N1 will require further consideration and liaison with SEPA.
  • Impacts on recreation should be considered further, in discussion with SportScotland and other interest groups.
  • An HRA should be undertaken to inform future site selection within the areas of search and address potential effects on marine mammals, birds and fish. Further data on biodiversity in the region will be required to achieve this.
  • Potential onshore impacts will require further consideration, and if site options emerge 'scenario' or 'masterplanning'.
  • Marine Scotland will undertake further scoping and regional locational guidance work for offshore wind, in line with The Saltire Prize initiative work undertaken for marine renewables.

North West: Medium term areas of search

Potential Environmental and Technical Effects

  • Potential adverse impacts on marine mammals including cetaceans and seals.
  • Potential adverse impacts on migratory and breeding birds and migratory fish.
  • Direct impacts on spawning grounds and nursery areas for fish species.
  • Major adverse impacts on seascapes. Impacts on Loch Druidbeg NNR / UNESCO Biosphere Reserve Many be affected. All options (except N8) could affect a nationally designated landscape or impact on visual amenity.
  • Collision risk arising from conflict with ships using the Minch and the IMO route to the west of the Outer Hebrides.
  • Potential effects on tourism, aviation, navigation and commercial fishing.

Opinions

  • Strong support for further development in the short term to support economic development within the area.
  • Regionally significant fishing impacts require further consideration. This should be taken forward in collaboration with the sector, and informed by further baseline information that ensures that smaller vessels are considered.
  • NW8 could result in downgrading of the Water Framework Directive status of the water body and could therefore require justification on the basis of a lack of alternatives.
  • Concerns about visual, landscape and seascape effects and secondary effects on tourism and recreation require further consideration. Potential effects on wild land.
  • NW6 raised particular concerns in terms of visual impacts.
  • Further information on the relationship between development and the grid is required.
  • The SEA should acknowledge the large numbers of resident and breeding internationally important bird populations. Further consideration of impacts on Icelandic passerine migrants and Scandinavian migrants is required.
  • High concentrations of Natura sites will require careful assessment. Basking sharks should be recognised alongside seals and cetaceans.
  • Shipping and navigation issues are likely to be significant, particular in relation to sites affecting access to the Minch from the north and south and the traffic separation scheme from the Butt of Lewis to Cape Wrath.
  • MoD issues include the need to consider air traffic control radar at St. Kilda and South Uist, and the Drium-A-Starraid Meteorological Weather Radar near Stornoway.
  • Relationship with marine renewables also requires further consideration.
  • Cultural heritage issues should be explored further, including impact on North Rona.

Recommendations

There are some significant constraints to development in the North West, but it is anticipated that many issues will be overcome through appropriate option and site selection within the areas in the future.

To address key issues, the following considerations should be built into medium term site selection within the areas of search:

  • Where environmentally and technically feasible, further development in this area should be prioritised.
  • Further consideration of potential impacts on radar and shipping is required. In particular, detailed discussions will be required to ensure that site selection does not reduce access to the Minch and takes into account other shipping designation and guidance.
  • Fishing is a key consideration requiring further data, assessment and liaison within the region as a whole. This should also be linked with broader consideration of navigation issues.
  • Impacts on water body status from N1 will require further consideration and liaison with SEPA.
  • Impacts on recreation should be considered further, in discussion with Sportscotland and other interest groups.
  • An HRA should be undertaken at the regional level to inform future site selection within the areas of search and address potential effects on marine mammals, birds and fish.
  • Further data on biodiversity in the region will be required to achieve this.
  • Potential onshore impacts will require further consideration and if site options emerge 'scenario' and / or 'masterplanning'.
  • Careful consideration should be given to the potential for significant impacts on scheduled sites, including those on North Rona arising from NW8.
  • Sterilisation of areas for marine renewables should be avoided.
  • The social and cultural identity of remote, particularly island, communities should be taken into account in project planning and assessment.
  • Marine Scotland will undertake further scoping and regional locational guidance work for offshore wind, in line with The Saltire Prize initiative work undertaken for marine renewables.

West: Short term options

Potential Environmental and Technical Effects

  • Short term options within the region are relatively large scale, and therefore provide significant potential to contribute to climate change mitigation.
  • Potential adverse impacts on marine mammals, including harbour porpoise, white-beaked dolphin, grey and harbour seals.
  • Potential effects on birds, including breeding storm petrel, auks and terns.
  • Direct adverse impacts on fish spawning grounds and nursery areas.
  • Potential impacts on migratory fish.
  • Major visual and seascape impacts due to the proximity of the site to land and high sensitivity seascapes.
  • Potential adverse impacts on the setting of listed lighthouses, and A-listed buildings.
  • Potential effects on tourism, aviation, navigation and commercial fishing.
  • Community and public acceptability.

Opinions

  • Strong community concern in some areas about the scale of development and its likely impacts.
  • Concern that community views would not be given full consideration and that developer engagement and information should be increased significantly, to allow this to take place in a meaningful way.
  • Particular concern about the onshore implications of development on infrastructure, services, health and quality of life. This extends to fundamental concern that the development could undermine community / island culture and way of life.
  • Further cultural heritage effects, including on onshore coastal archaeology such as coastal fortifications and early church sites and marine archaeology, and wrecks.
  • Significant concern about impacts on landscapes and seascapes, taking into account the scale and proximity of development.
  • People emphasised the sensitivity and value of non-designated landscapes.
  • The methodology for assessing these effects and the baseline information (seascape characterisation) were also raised. Related qualities such as tranquillity and lack of industrialisation were raised. Shadow flicker and light pollution were also raised.
  • Questions were asked about why the short term options were located much closer to shore than medium term options.
  • Ecological impacts were raised, with further information on birds (wintering, breeding and migratory birds), marine mammals and wildlife, the machair, and candidate Natura Sites.
  • Prospective developers questioned the data used in the SEA and recommended consideration of their scoping study.
  • Potential impacts on air traffic control.
  • Possible effects on climate affecting parts of the west coast.
  • Fishing issues, with particular concerns about impacts on small vessels with static gear and further implications this might have for the rural community.
  • Lack of opportunities for mitigation ( e.g. relocation of activities during construction were also raised).
  • Broader issues around energy policy and the need to ensure that renewable energy is taken forward in a sustainable way.
  • Views extended beyond site specific impacts to include concerns about the potential overall scale of development into the medium term, potential for islands or remote communities becoming servicing bases for numerous proposals in the west region.
  • Further work is required to assess the combined effects of the development with proposals for wave and tidal energy in the area.
  • Concerns about the level of engagement at this stage and comments on the need to ensure that the community is fully engaged at both the Plan and project level.
  • Industry views that there remains significant uncertainty about development proposals at this stage, and as a result impact assessment for the Plan should be expressed in broader terms, focusing on regional options.
  • The Kintyre site generated very significant levels of public concern - with objections amounting to more than a third of all responses.
  • People were concerned about impacts on the area's special qualities, including its views, sunsets, tranquillity and overall environmental quality. Light pollution was also raised and people were concerned about the accuracy of visualisations of development. Linked with these effects, many people were concerned about the impact this could have on tourism and recreation. In turn this was viewed as a significant economic issue.
  • Many people raised the importance of taking into account plans for investment in the Machrihanish Dunes golf course. Some viewed this as being at risk as a result of the visual effects of the proposal.
  • Other recreation activities were raised, including the importance of the area for surfing, wildlife watching and walking.
  • Numerous further environmental constraints were noted by consultees. Further information on coastal processes, the seabed, fish, birds (with an extensive response from the RSPB), marine mammals (including dolphins) and many other species and sources of more accurate local data were highlighted.
  • Concerns about impacts on communities, including quality of life, property values (including potential impacts on their stability as a result of construction works), radio and TV reception and way of life generally.
  • Concerns from Argyll and Bute Council and SNH about the Kintyre proposal, and a view from the former that one of the medium term options should be considered as an alternative.
  • Issues around radar and aviation interference, including a detailed response from Loganair / Flybe setting out constraints on the approach routes to Campbeltown Airport.
  • Navigation issues, affecting particularly recreation activity. This included concerns about the safety of small vessels navigating the Mull of Kintyre and effects on local marinas and related tourism income.
  • Numerous responses from visitors to the Kintyre area, supporting views that tourism would be adversely impacted.
  • Concerns from Northern Irish organisations about impacts on the Giant's Causeway World Heritage Site and confirming the findings relating to AONBs from the assessment.
  • Issues around potential cumulative effects and conflicts arising from the combination of offshore wind, wave and tidal energy in the region.

Recommendations

The SEA and consultation identified some significant concerns and constraints relating to this type of development in the West region. The scale of development and its proximity to sensitive environments suggests that very careful planning would be required to develop a combined on and offshore development proposal that avoids impacts and significantly undermining quality of life of communities and their unique environments.

The following matters require further consideration within Plan review and project level Environmental Impact Assessment of the short term options generally:

  • Development of a scenario / masterplanning approach which links on and offshore aspects of development and considers issues including onshore connections and ancillary development, infrastructure upgrading, and socio-economic impacts in addition to environmental effects.
  • Full assessment of the landscape, seascape and visual effects of development. This should take into account the scale of proposals and their positioning within the site boundary.
  • Visual impact and public acceptability issues can be improved if turbines can be moved further from the shore, or the scale of development (overall or in terms of the turbines) could be reduced.
  • Further consideration of impacts on shipping and fishing and scope for mitigating these effects, in collaboration with the fishing industry and local community.
  • Resolution of radar issues, in collaboration with the relevant stakeholders.
  • Further ecological data collection and detailed assessment of impacts on designated (see below) and non-designated habitats and species.
  • Detailed consideration of cultural heritage impacts, including on offshore assets such as lighthouses, onshore remains and their settings, marine archaeology, and less tangible aspects of cultural heritage.
  • Satisfactory completion of project level HRA, taking into account mitigation measures identified in the HRA of the Draft Plan, and any further research and review work, as appropriate.

The SEA and consultation identified very significant concerns and constraints relating to the Kintyre development. The consultation in particular reinforced the findings of the SEA and emphasised that the development would not be publicly acceptable to many who live and visit Kintyre. It was anticipated that these issues would be extremely difficult to resolve at the project level for the following reasons:

  • Resolution of the likely significant effects of the development on internationally and nationally significant landscapes and seascapes.
  • Consideration of increasing the distance of the site from the coast, resulting in significant visual impacts.
  • The potential for adverse effects on tourism and recreation, including investment in the Machrihanish Dunes international golf course project. A full socio-economic study relating specifically to the site would have been required.
  • Technical issues arising for the navigation and aviation sectors.
  • Effects on biodiversity, which include, but also extend beyond designated sites, species and habitats and the sensitivities raised by consultees, particularly in connection with birds, fish and rare species.
  • Potential effects on the wave climate, water quality, sediments and coastal processes, which could adversely impact on coastal features and stability, Machrihanish beach and recreation activities including surfing.
  • Impacts on the fishing sector.
  • Impacts on aviation and flight activity into and out of Campbeltown Airport.
  • Significant community opposition and lack of public acceptability of the proposal.

West: Medium term areas of search

Potential Environmental and Technical Effects

  • Potential adverse impacts on marine mammals including cetaceans and seals.
  • Potentially adverse impacts on birds including migratory birds, breeding birds and migratory fish.
  • Direct adverse impacts on fish spawning ground and nursery areas.
  • Moderate or major effects on seascapes, as all of the medium term options lie within medium or high sensitivity seascapes.
  • W1, W3 and W4 are likely to have significant impacts on coastal receptors due to the proximity of the coastline.
  • Potential effects on tourism, aviation, navigation and commercial fishing.
  • Community and public acceptability.

Opinions

  • Concerns about the effects of some of the options on navigation. This included the impacts of W1 on ships accessing the Minch and of W4 on vessels entering the IMO Route in the North Channel.
  • W1 and W4 were also of primary concern to the Ministry of Defence, given ongoing use of these areas.
  • W4 also raised issues about aviation.
  • Conflict arising from area W4 and investment in infrastructure to support economic development.
  • Further effects on local regeneration plans, including work centering on realising the benefits of recreational boating.
  • Potential effects on cultural heritage from W1 (affecting coastal sites and Barra Head lighthouse), and from W4 where the linkages and views between islands and their historic sites could be impacted.
  • Confirmation that the location of area W4 relatively close to the coast could generate significant adverse visual an seascape impacts, with secondary impacts on tourism.
  • Further views on visual, landscape and seascape effects, noting potential for significant regional cumulative effects and highlighting particular sensitivities such as the impact of W2 on wild land and views from National Scenic Areas.
  • RSPB concerns about potentially significant cumulative effects on a range of species using the East Atlantic Flyway, locally breeding birds and seabirds. The potential to affect birds crossing or travelling through the Minch was raised, and it was emphasised that impacts on Natura sites in the region required further consideration.

Recommendations

There are some significant constraints to the medium term options for development in the West, but it is anticipated that some of issues will be overcome through appropriate further option selection work and Plan review, and site selection within the options.

To address key issues, the following considerations should be built into medium term site selection within the areas of search:

  • The overall environmental sensitivities and special quality of the West Region should be taken into account. Potential for large scale cumulative landscape, navigation and biodiversity effects should be fully explored.
  • Potential for significant impacts on sensitive seascapes will require further assessment and mitigation.
  • Further consideration of potential impacts on shipping (particularly from areas W1 and W4) is required. In particular, detailed discussions will be required to ensure that site selection does not reduce access to the Minch and takes into account other shipping designation and guidance.
  • Fishing is a key consideration requiring further data and liaison within the region as a whole. This should be linked with broader consideration of navigation issues and socio-economic assessment.
  • Potential onshore impacts will require further consideration. This is particularly important to area W4.
  • An HRA should be undertaken to further inform future regional option and site selection within the areas of search and address potential effects on marine mammals, birds and fish. Further data on biodiversity in the region will be required to achieve this.
  • Careful consideration should be given to the potential for significant impacts on cultural heritage sites, including coastal archaeology, will be required.
  • Effects on tourism and recreation within the region as a whole will require more detailed assessment.
  • Sterilisation of areas for marine renewables should be avoided.

South West: Short term options

Potential Environmental and Technical Effects

  • Potential adverse impacts on marine mammals.
  • Potential adverse impacts on birds including wintering wildfowl and waders in the adjacent international nature conservation sites and Important Bird Areas in the Solway Firth.
  • Direct adverse impacts on fish spawning grounds and nursery areas, a Regulate Cockle Fishery and mussel and winkle fisheries on the shores of the Solway.
  • Major visual and seascape impacts due to proximity to land, National Scenic Areas, AONBs and the presence of the high sensitivity seascape of the Outer Solway.
  • Potential impacts on migratory fish.
  • Potential effects on tourism, navigation and commercial fishing.

Opinions

  • Around a half all respondents to the consultation expressed opposition to the two short term development options in the Solway Firth.
  • The most frequently raised concern related to the individual and cumulative visual, landscape and seascape effects of the developments, on both designated areas and other less formally protected areas and receptors.
  • Dumfries and Galloway Council, supported by the wider public who responded, considered the scale of development and their proximity to shore to be unacceptable.
  • Views from the coast, across the Solway and to Cumbria, the Isle of Man and Ireland were all expected to be affected.
  • Lighting and impacts on the area's dark sky status were also a key concern.
  • Many respondents were concerned about cumulative and in-combination effects with Robin Rigg, onshore wind energy developments, the two short term sites and medium term options for development.
  • People envisaged a 'wall of turbines' across the Firth.
  • Impacts on communities, tourism and recreation were viewed as also being negatively affected. Key issues included impacts on quality of life and employment, general disturbance, noise, shadow flicker.
  • People were also concerned that impacts would not be offset by economic gains from the development.
  • Fishing was a key concern. The area's fishing interests were expected to be significantly affected by the development.
  • Concerns came from local businesses and further afield. Safety concerns and implications for business viability was raised. All types of fish and shellfish resource were expected to be affected. Concern was also raised about recreational angling, and migratory fish species.
  • Various environmental bodies raised further environmental issues. Some highlighted key areas of value, including the Wigtown Bay Local Nature Reserve ( LNR), and the Wigtown Bay (Cree Estuary) SSSI.
  • Significant issues were expected for a number of internationally and nationally important bird species.
  • Concerns about impacts on fish species, shellfish, crustaceans and bottom feeding fish were raised.
  • Issues about water quality, sediment, coastal processes and the wave climate were raised.
  • People were concerned about areas where munitions are likely to be present.
  • Shipping and navigation were also key issues and concerns about data raised in relation to the Plan as a whole were emphasised in relation to the sites. Entry to harbours and impacts on key commercial and recreation routes were highlighted and people called for a full navigational assessment.
  • Further concerns about impacts on cultural heritage were raised, including potential for effects on Hadrian's Wall World Heritage Site, including from English Heritage and the Solway Firth Partnership.
  • There were also concerns about radioactive particle disturbance on the sea bed.
  • People believed that the economic benefits of the development would be limited and not accrue in the Dumfries and Galloway Region, based on their experience with Robin Rigg.
  • Impacts on coastal paths and recreation were raised.
  • Further work on establishing the value of the coastline in economic terms was proposed.
  • The sites were noted to be an important fishing area.
  • Concerns about navigation from Maryport and Whitehaven were raised, alongside impacts on key fishing grounds.

Recommendations

The SEA and consultation identified very significant concerns and constraints relating to development in the South West. The consultation in particular reinforced the findings of the SEA and emphasised that the development would not be publicly acceptable to many who live in and visit Dumfries and Galloway. It is anticipated that these issues would be extremely difficult to resolve at the project level for the following reasons:

  • Significant effects of the development on nationally significant landscapes and seascapes including impacts on Hadrian's Wall World Heritage Site.
  • Distance of the sites from the coast, causing significant visual impacts.
  • Potential for adverse effects on tourism and recreation. A full socio-economic study relating specifically to the site would be required.
  • Technical issues arising for the navigation sector - a full navigational risk assessment would be required.
  • Effects on biodiversity, including but also extending beyond designated sites, species and habitats and taking into account the sensitivities raised by consultees, particularly birds and fish species.
  • Significant impacts on the fishing sector.
  • Significant community impacts and lack of public acceptability of the proposals.
  • Potential net socio-economic costs for the regional economy.

South West: Medium term areas of search

Potential Environmental and Technical Effects

  • Potential effects on marine mammals including cetaceans and seals.
  • Potential adverse effects on migratory and breeding birds off the Irish coastline and elsewhere.
  • Direct adverse impacts on fish spawning grounds and nursery areas.
  • Moderate or major seascape impacts due to the presence of medium and high sensitivity seascapes and nationally designated landscapes.
  • Effects on migratory fish.
  • Potential effects on tourism, aviation, navigation and commercial fishing.

Opinions

  • Concerns about the consultation process and views that further work is required to address the many concerns about development in this area, from within Dumfries and Galloway and also extending to Cumbria, the Isle of Man and Northern Ireland.
  • Concern about the overall scale of development in the area as a whole, and its impacts on the special qualities of the Solway Coast.
  • Significant concerns about visual and seascape impacts from development areas, individually and cumulatively. These related to both designated and undesignated landscapes and included impacts on NSAs, AONBs, and a regional scenic area.
  • Concern about secondary impacts on communities, tourism and the local economy.
  • Environmental issues, including impacts on the proposed biosphere reserve, marine wildlife, birds, fish and local nature reserves.
  • A need for closer links with wider processes of regional marine planning.
  • Significant concern about impacts on the commercial fishing sector, with activity from ports around the Solway and further afield potentially being directly impacted by development, to the extent that development could significantly undermine the viability of businesses.
  • Recreational issues relating to boating, sea angling and diving in the region.
  • Concern about impacts on navigation, including access to ports and key routes for both commercial and leisure vessels. This included detailed responses from the Maritime and Coastguard Agency, and the DETI Northern Ireland.
  • Issues around impacts on undesignated cultural heritage resources, as well as designated sites. In particular, impacts on the Hadrian's Wall and the Giant's Causeway World Heritage sites emerged as key concerns for conservation agencies.
  • Particular concern about options in the vicinity of Luce Bay - some suggesting the impacts would be as great as those expected for Wigtown Bay, but others proposing this as a preferable option.
  • Concern about development within danger areas, areas where munitions may exist on the seabed, Ministry of Defence activities and radar issues.

Recommendations

There are some significant constraints to the medium term options for development in the South West, including widespread public opposition to development within the Solway as a whole. Some of these issues may be overcome through appropriate site selection within the options in the future.

To address key issues, the following considerations should be built into medium term site selection within the areas of search:

  • The overall environmental sensitivities and special quality of the South West Region should be taken into account. Potential for large scale cumulative landscape and biodiversity effects should be fully explored.
  • Potential for significant impacts on sensitive seascapes and designated areas will require further assessment and mitigation.
  • Effects on tourism and recreation within the region as a whole will require more detailed assessment.
  • Further consideration of potential impacts on navigation is required.
  • Fishing is a key consideration requiring further data and liaison within the region as a whole. This should be linked with navigation issues.
  • Potential onshore impacts will require further consideration.
  • An HRA should be undertaken to inform future site selection within the areas of search and address potential effects on marine mammals, birds and fish. Further data on biodiversity in the region will be required to achieve this.
  • Careful consideration should be given to the potential for significant impacts on cultural heritage sites, particularly the two nearby WHS, will be required.
  • Sterilisation of areas for marine renewables should be avoided.
  • The need for SEA, HRA and socio-economic assessment at the regional level was emphasised. This should include an integrated review focused on this level to further assess the medium term options.

In summary, the Scottish Government believes that any prospective developer considering taking forward offshore wind development in the South West faces significant challenges with regard to: visual and ecological impact, as well as socio-economic issues of concern to the fishing, shipping and tourism sectors. The developer would therefore have to work closely with Marine Scotland and Dumfries and Galloway Council to ensure these issues were tackled and public acceptability issues addressed.

What were the views on the Plan as a whole and its SEA?

B1.103 The consultation on the SEA and Draft Plan included four further questions that aimed to address the environmental effects of the Plan as a whole. The responses to these questions were detailed in full in the Analysis of Consultation Responses Report. The following paragraphs provide a summary of key issues raised, and the response to each of them.

Question 6: How can the Draft Plan be improved? What should be taken forward differently and why?

B1.104 In summary, respondents raised the following views.

B1.105 A range of interests suggested that a more regional approach would be appropriate for a national level plan. The wind industry representatives particularly considered it to be important that the SEA does not prejudge issues that require more detailed consideration at the project scale. Linked with this, consideration of higher level alternatives to the Plan as a whole was recommended to test out some assumptions more rigorously.

B1.106 Timescales were considered to be arbitrary by some respondents, given the pace of change within the sector. Concerns included a view that too rigid an approach could hinder the pace of development. TCE pointed out that, in reality, all of the developments will not proceed concurrently, and therefore cumulative effects may be overstated as a worst case scenario.

B1.107 Clarification of the status of medium and long term options was sought by many respondents. Some suggested that further prioritisation or comparison of the medium term options using an evaluation system would be useful.

B1.108 Some consultees recommended further consideration of the links between offshore wind and onshore developments and planning. This included several local authorities with responsibility for development planning. Such considerations could include further consideration of infrastructure requirements and cumulative effects, and also extends to include Round 3 wind energy sites and other marine renewables.

B1.109 Some consultees asked for further clarification on specific issues and in doing so underlined the need for maximum transparency within the Plan. This included concerns about the apparent lack of information on the way in which MaRS had been used, clarification of some aspects of the assessment methodology and more general views on the visual presentation of the Final Plan. The importance of further engagement in the Plan was emphasised, by members of the public and by key sectors: specifically fishing and shipping. This reflected concerns about the consultation process on the Plan throughout its preparation, and local level views that the opinions and requirements of communities was being overlooked. Some expressed disappointment about their engagement in the development of the Draft Plan and its SEA, but offered to assist further as the Plan is refined and implemented.

B1.110 Many stakeholders and members of the public expressed a strong view that further analysis of the social and economic effects of the Plan was required, prior to its implementation. The need to focus more on social effects, and build in further data on shipping and fishing was particularly emphasised. The fishing sector in argued that their perspective should have been fully addressed under the heading 'material assets' within SEA. They believed that their needs were coming second to the aspiration for renewable energy development, but that there was scope to improve the Plan, if further analysis of the spatial sensitivities of the fishing industry is incorporated. Similarly, the shipping sector noted that the Plan could be improved if it took into account further information on navigation and levels of activity, and allowed for a risk assessment based approach.

B1.111 It was also recommended that the broader context and contribution of the Plan should be considered further. This could usefully include reference to the National Renewables Infrastructure Plan ( N-RIP), the grid (explored in more detail above), and overall targets for renewable energy generation, to which the Plan should relate.

B1.112 The need for a Habitats Regulations Appraisal of the Plan was emphasised by several consultees, including Scottish Natural Heritage, the RSPB and Scottish Environment LINK.

Issue / View

Response

A regional perspective is preferable to the emphasis within the Draft Plan on specific sites and options.

This key point has been taken into account. It appeared from the consultation that, regardless of their stance on offshore wind and development proposals, consultees were agreed that there is insufficient information at this stage, and some suggested that this meant that the Scottish Government was not in a position to make a fully informed decision on specific projects.

As a result, the Plan aims to recognise these uncertainties and focuses on national and regional level recommendations, supported by finer grained information which can be used as guidance for the project assessment stage. It is acknowledged that further review is required and more detailed, studies and data collection may indicate that these issues may not be valid at the regional and / or project level.

Higher level alternatives should have been considered.

The SEA considered the options that were considered within the formulation of the Draft Plan. These primarily took the form of spatial options. Broader options, such as alternative renewable energy technologies, will be considered within sectoral and non-sectoral plans, such as the National Marine Plan.

Timescales should be flexible.

This is noted. Timescales presented within the Plan are indicative at this stage and will be reconsidered within the Plan review process.

Medium and long term option status should be clarified and more fully evaluated and prioritised

This recurring concern has been addressed in the finalised version of the Plan.

Further consideration of offshore and onshore links is required, together with Round 3 sites and marine renewables.

The SEA considered cumulative effects of development as far as practicable at this stage. However, it is recognised that further work on this is required. This is being taken forward by the regional groupings of developers at present. The outputs from this process will be used to inform project level EIA and associated licensing. Also, the Plan review process will expand the geographic scope of SEA, HRA and socio-economic assessment for offshore wind out to the 200 nautical mile limit, capturing the adjacent Round 3 sites and further future development potential within this expanded geographic scope. In addition the Scottish Government will take forward a similar approach for marine renewables and start to share information across these plans and their assessments..

Information used within MaRS and assessment methods should be made more transparent.

The Scottish Government remains of the view, shared by some consultees, that the use of MaRS provided an appropriate means of focusing on potential future Plan options, as a starting point for the SEA. However, it is acknowledged that there are issues which require to be revisited in line with the original intention of the approach to modelling, including coverage of datasets and transparency. The Plan has indicated that the medium term options are indicative areas of search at this stage, and states a commitment to revisiting MaRS in collaboration with stakeholders to explore how sensitivity testing can be applied and model calibration / normalisation can be achieved as the Plan undergoes review.

The final Plan should be presented in a clear, accessible way.

Noted. The Scottish Government has endeavoured to make the Plan comprehensive, but also as clear and accessible as possible.

Need for continuing engagement in the planning process, particularly for the fishing and shipping sectors.

The Plan emphasised the importance of ongoing liaison with key sectors and the public as an integral part of its review and implementation strategy. The Scottish Government is also trialling scenarios and masterplanning techniques to include communities within the process and will consider other best practice techniques.

Need to ensure local communities continue to have a voice within the planning and implementation processes.

Further socio-economic assessment is required.

The findings of the socio-economic assessment are summarised in Section B4 of this Post Adoption Statement. These findings have been taken into account in the Plan.

Further consideration of the fishing sector, based on fuller data coverage, is required. This should have been addressed under 'material assets' within the SEA.

The Scottish Government included an assessment of the environmental aspects of the fishing sector within the SEA, in relation to biodiversity. The socio-economic assessment provided further consideration of the economic aspects of the sector. These studies, together with the extensive consultee views from the sector, have been taken into account in the finalised Plan, which also includes a commitment to further liaison with the sector (see Section B5).

Further consideration of the shipping sector is required.

Shipping activity were considered within the environmental assessment and the socio-economic study. The issues identified, together with consultee views have been taken into account in the same way that fishing issues have been covered in the finalised Plan. Marine Scotland will consider how it can work with the shipping industry and address its concerns within the Plan review process and at the project level.

Offshore wind should be considered within the context of overall targets for renewable energy generation.

The Scottish Government has sought to incorporate environmental factors into the Plan by frontloading the SEA and using it as a plan-making tool. The socio-economic study explored this issue in more detail. The Plan has sought to provide further context for the offshore wind sector, by explaining the likely overall contribution that could be achieved nationally.

There is a need to link the Plan with N-RIP proposals.

The socio-economic study has helped to highlight this further. Further liaison with key partners at the national and regional levels will be required to achieve this as implementation of the Plan progresses.

A Habitats Regulations Appraisal of the Plan is required.

This has now been undertaken. The findings are set out in Section B3 of this Report. Further HRA is likely to be required as monitoring research and assessment are taken forward as part of the Plan review. The recommendations for mitigation will need to be taken into account and used to inform project level HRA.

Question 7: Do you have any views on the scale and pace of development that could be sustainably accommodated in Scottish Territorial Waters, taking into account the findings of the SEA and the technical assessment?

B1.113 This question aimed to encourage consultees to consider their views on the Plan as a whole, as opposed to focusing entirely on their specific interests or options being proposed. In response, the following key points were raised.

B1.114 Some consultees believed that the pace of development was too ambitious and was likely to lead to significant environmental, social and economic impacts. This included many of those who had focused on objecting to specific development proposals, the shipping and fishing sectors. Many of these viewed this as a serious issue but were not convinced that this would result in any changes to the Plan. Several consultees asserted that more time is needed to provide a fuller assessment of the Plan and its environmental effects. As a result, groups such as Scottish Environment LINK urged that the precautionary principle is applied.

B1.115 In contrast, others believed that the Plan lacked ambition and could hinder development aspirations. In particular, strong views were expressed by Comhairle nan Eilean Siar that there is a need to send out strong positive signals from the Plan to ensure its potential benefits would be maximised.

B1.116 Some considered the scale and pace of change to be about right. For example, with Aberdeen City Council, recognised that the scale of the opportunity necessitated rapid action, providing that this was balanced with work to gather better information and secure mitigation. The Highland Council believed that the scale of development proposed was broadly correct, providing there is scope to adjust the Plan as implementation processes.

B1.117 Some respondents considered that there was scope for the Plan to evolve over time, with continuing reviews of progress and information informing future changes. SNH recommended that within this, priority should be given to lowest risk development, and advised caution in the absence of comprehensive data. Several other stakeholders referred to the need to revisit the Plan periodically to take on board further information, and the findings of monitoring, as they emerge. Some considered the Plan's timescales to be too inflexible, requiring refinement as work progresses.

B1.118 Several organisations considered there to be a need to view the proposals in terms of capacity - for generation (energy targets) or in terms of environmental capacity. Suggestions were made about how the Plan could be better linked with other factors, including grid capacity, infrastructure constraints, availability of materials, quayside manufacturing facilities, skills and development planning.

Issue / View

Response

Scale and pace of development within the Draft Plan is too great.

The Scottish Government recognises this concern, but is seeking to take forward development in a practical way which realises ambition for renewable energy and associated economic development, but avoids generating significant adverse environmental impacts. Further liaison with the fishing and shipping sectors, will be used to consider an acceptable level and pace of development.

Scale of pace and aspirations are too limited.

Scale and pace proposed is necessary to capitalise on this significant opportunity in a sustainable way.

Further information is required prior to development proceeding.

This is a strategic environmental assessment of a high level plan. It is expected that further information will need to be gathered to inform review of the Plan and more detailed environmental assessment at the project level.

No development will take place before project level EIA is undertaken. In the meantime, the inclusion of options or areas of search in the Plan does not indicate that consent will be granted at licensing.

Review of the Plan is essential and should provide further information which can be used to adjust the proposals. In the meantime caution is required.

The Scottish Government agrees with this point as it is a statutory requirement to monitor and revisit the SEA as necessary in any case. The Plan sets out proposals for monitoring and research within the review. More work is also required at the project level.

Prioritisation and / or a sequential approach to implementation may allow lessons to be learned and used to inform future choices.

The Plan sets out priorities at a regional scale. The need to learn from existing and future development is acknowledged and has formed the foundations of the monitoring proposals.

Greater flexibility is required.

The Plan seeks to strike an appropriate balance between providing assurance of the continuing commitment of the Scottish Government to achieving large scale benefits from offshore wind, whilst also noting that more work is required to deliver this in a sustainable way.

The Plan should be framed in relation to capacity of the environment.

In very broad terms, environmental capacity has underpinned the approach to defining regional recommendations within the Plan. However, this is a complex concept, and capacity has not been defined in absolute terms.

The Plan should be framed within broader aspirations for renewable energy generation, national and regional targets for output etc.

Further work on this was undertaken as part of the socio-economic study. The Plan aims to provide further detail on this context.

Consideration should be given to other factors: grid capacity, infrastructure, materials, manufacturing capacity, supply chain infrastructure and investment, skills supply and development planning.

This view has been noted in relation to specific areas and parts of the planning and assessment process above. The socio-economic assessment has been used to achieve a greater link between these types of issues and the proposals within the Plan itself. The Plan review process will allow further consideration of these issues.

The Plan should be framed within consideration of the needs of other marine users to accommodate change.

The needs of other marine users is fully acknowledged within the Plan. A commitment has been made to further and ongoing liaison with representative sectors and the public to deliver this as the Plan is implemented. The Plan review process will take into account regional information and assessment findings as they emerge.

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?

B1.119 The following points provide a summary of key issues raised in response to this question.

B1.120 As with the previous question, several respondents believed that an answer could only emerge if the Plan was viewed in the context of stated energy generation targets. Some considered that there was greater potential for reliable and efficient generation from other types of marine renewables. Some went as far as questioning the need for the Plan in the first place, asking why offshore wind has been prioritised in Scotland.

B1.121 Several consultees believed that the Plan had not balanced potential economic gains from offshore wind with anticipated losses, particularly for the tourism and fishing sectors and in terms of communities more generally. Specific areas were identified, where it was expected that impacts on local economies would be greatest. The fishing sector raised the need for compensation to address likely losses, extending to individual vessels. There was also a general questioning of the viability and benefits of offshore wind.

B1.122 More positively, some consultees believed that the Plan presented a significant positive opportunity for their local economy, specifically the Western Isles where it was emphasised that offshore wind could play a key role in reducing depopulation and improving skills and quality of life more generally. The local authority believed these benefits may have been underplayed within the Draft Plan. Highlands and Islands Enterprise ( HIE) supported this view, and others, such as Argyll Renewables Communities ( ARC), suggested fuller evaluation would provide a clearer view.

B1.123 In response to this question, some consultees suggested that there was a need for fuller consideration of the environmental effects of the Plan. These have already been addressed in the discussion above.

B1.124 Reasonable alternatives within the context of the SEA requirements were also raised by some consultees. It was suggested that other broad options should have been addressed within the assessment: specifically the 'do nothing' option and a comparison of the effects of offshore wind with wave and tidal energy. Instead, some consultees contended that an assumption had been made that offshore wind energy would be pursued, regardless of other points of view.

Issue / View

Response

Consideration of the Plan's (and offshore wind's) contribution can only be established in the context of the wider energy mix and energy generation targets.

The Scottish Government is committed to maximising the contribution of offshore wind, along with other types of renewable generation, to the overall energy mix. This will help to ensure that Scotland meets ambitious renewable energy and climate change targets and secures related economic and environmental benefits.

Further consideration of offshore wind in relation to other forms of marine renewables will be undertaken as further sectoral planning progresses and within the National Marine Plan as appropriate.

Economic gains are outweighed by tourism, fishing and community losses.

The socio-economic assessment sought to explore this in more detail (see Section B4).

The benefits of the Plan should be more fully evaluated and capitalised upon.

Further consideration should be given to compensation for the fishing sector.

This is an issue for offshore wind developers and the fishing sector to address.

Assessment alternatives should have covered broad options: do nothing and wave and tidal as compared to offshore wind.

The SEA included consideration of the evolution of the environment in the absence of the Plan. Given its sectoral focus, it would not have been appropriate or possible at this early stage to more fully compare offshore wind proposals with wave and tidal. It is intended that all three types of generation have a legitimate role to play within the overall mix of energy sources in Scotland. However, as further sectoral marine planning work is taken forward, the Scottish Government will seek to take account of issues and alternatives and build in inter-relationships made possible by sectoral marine planning.

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?

B1.125 Linking with proposals for monitoring, this final question focused on the proposal within the Draft Plan to undertake a review every two years, to determine whether the SEA and the Plan require updating. Views on this question were varied, and are summarised below.

B1.126 There was concern that if the Plan is reviewed too frequently, uncertainty could hinder development. Scottish Renewables raised concerns about the difficulties this would introduce for the project consenting stage, and asked for clarification on how applications for consent would be treated. Others agreed with this view. Greater flexibility was called for by some, suggesting that as opposed to a fixed time period, reviews should be linked with key milestones in research and implementation. Several wind energy representatives agreed with this view and suggested relevant points at which it would be meaningful to undertake a review.

B1.127 Some consultees agreed that the proposed two year period was 'about right', reflecting the likely pace of change in the sector and expected technological progress. Some suggested that revisiting the Plan after two years should not automatically trigger a major review.

B1.128 Specific issues to be taken into account were also raised, including the emergence of marine spatial planning, work by DECC, research findings, progress in developing other alternatives, new guidance and lessons learned from implementation of the short term sites. This latter point broadly reflected views from the public raised in consultation events, that there is a need to learn from existing and proposed developments, before taking forward further activities. Comments were also made on the information that should be referred to within the review process. Some developers asked how the review would be undertaken, and how data would be gathered as part of this, urging further discussion to avoid duplication of research. Further baseline data collection was also suggested. Many believed that the review would play a critical role in addressing uncertainties and data gaps.

B1.129 Some respondents suggested a more frequent review, to reflect the likely speed of technological and research development and concerns about rapid obsolescence. In contrast, others believed that a longer review period would be preferable, for example to achieve a better fit with development plan reviews and marine spatial planning. Some suggested that five years would be more appropriate, to allow significant change to take place in the interim period. Others suggested this on the basis of likely resourcing issues.

Issue / View

Response

More frequent review is appropriate to reflect the pace of change in the sector.

The Scottish Government is of the view that a two year review period is appropriate at least over the initial stages of Plan development. It is acknowledged that in some circumstances certain triggers may arise which merit more flexible review. The commitment extends to initially considering whether a full revisiting of the Plan and SEA are required. If there is no significant new information or progress is slower than expected, no full revision will be required. However, the HRA and socio-economic issues will also be subject to 2 yearly review.

Less frequent review is more practical.

Take a more flexible approach to the review period, linked with key milestones as opposed to fixed time periods.

Advice on information to be included in the review and its role in addressing data gaps.

This information has been taken into account in the finalised Plan's proposals for review.

Avoid uncertainty in the review period by explaining its implications for development consent applications.

This has been addressed in the finalised version of the Plan.

What are the reasons for choosing the Plan as adopted?

B1.130 The Scottish Government is committed to maximising the contribution which offshore wind can make towards meeting Scotland's ambitious renewable electricity targets, and securing the related economic and environmental benefits. It is also recognised that this type of development needs to be carefully planned, to avoid generating significant adverse effects on the environment, communities and local economies. The finalised version of the Plan has taken into account the findings from the SEA, the HRA, the socio-economic assessment and all associated consultation with stakeholders and the public. As far as possible, key issues have been explicitly addressed within the Plan itself.

What monitoring will be undertaken?

B1.131 The Environmental Assessment (Scotland) Act 2005 requires that the Post Adoption SEA Statement includes proposals for monitoring the environmental effects arising from the Plan. In addition, considerable further research will be required to ensure that current uncertainties and data gaps are prioritised and addressed. The table below sets out the formal commitments to monitoring that have emerged from the SEA. Section B5 brings requirements for data collection and research arising from this framework together with the findings and recommendations of the HRA and socio-economic assessment to provide an integrated framework for future work.

Table B1.1 MONITORING FRAMEWORK

SEA Receptors

SEA Indicators

Significant Environmental Effects

Summary of Proposed Monitoring

Data Sources

Time scale and responsibility

Climatic Factors

Provision of a renewable source of energy.

Positive contributions to reducing Scotland's 'carbon footprint'.

Extent to which climate change predictions raise the risk to population, environment and infrastructure over the long term.

The development of increased power generation by offshore wind aims to provide significant benefits in relation to climatic factors. The consultation process underlined the importance of this indicator, to provide some assurance that the developments provide net benefits in terms of reducing greenhouse gas emissions.

Measure the proportion of Scottish and UK power and renewables target generated by offshore wind development in STW.

Monitor generating capacity of offshore wind development constructed under the Plan to review its contribution to greenhouse gas reduction and minimising Scotland's 'carbon footprint'.

Scottish Carbon statistics e.g.www.Scotlandsfootprint.org and DECC data on energy generation.

To be undertaken for the life of the Plan. Progress and issues to be considered at a strategic level within the 2 year review process.

Scottish Government

Water Resources

Potential changes to surface and groundwater quality with respect to chemistry, biology or physical characteristics - e.g.EU Directives (shellfish, bathing waters, WFD etc).

The environmental effects on water resources were assessed as 'uncertain' at the strategic scale. Impacts would relate closely to specific scheme configurations.

Information on this arising from the project level, can be reviewed and eventually collated to provide a strategic level perspective.

Existing and future SEPA and developers' water quality monitoring data.

Data on effects will not emerge until the first developments have progressed.

SEPA

Marine Scotland

Geology, Sediments and Coastal Processes

Likelihood of large scale changes in geochemistry, bathymetry, sediment grain size distribution and sediment transport budgets.

Physical damage or exclusion to designated geological conservation site.

The environmental effects of wind development on geology, sediments and coastal processes are assessed as 'uncertain', this is due to the fact that impacts would relate closely to specific scheme configurations.

No strategic monitoring required. However, this can be considered as part of the review process.

Data on effects will not emerge until the first developments have progressed.

Condition of geological SSSIs ( SNH)

Integrated Coastal Zone Management plans/ future Shoreline Management Plans

Coastal protection studies

Sediment flux research projects

Regional level assessment of cumulative impacts.

Progress and issues to be considered at a strategic level within the 2 year review process.

SNH

SEPA

Marine Scotland

Developers

Biodiversity, Flora and Fauna

Presence of conservation sites within the 'footprint' of the options and likelihood of potentially adverse impacts on conservation site.

Presence of protected species within 'footprint' of the options and likelihood of potentially adverse impact on protected species.

The environmental effects of wind development on Biodiversity, Flora and Fauna are variable depending on impact receptor.

No strategic monitoring required at this stage in addition to matters identified within the HRA.

Data sources may include SNH, Environmental Clerk of Works, Marine mammal observers, NGOs.

Data on effects will not emerge until the first developments have progressed.

Regional level assessment of in-combination impacts.

Progress and issues to be considered at a strategic level within the 2 year review process.

Marine Scotland SNH, environmental NGOs and data providers.

Landscape, Seascape and Visual Amenity

Likely adverse effect on areas of high natural heritage sensitivity.

Proximity to National Scenic Areas, Heritage Coast, Areas of Outstanding Natural Beauty and World Heritage Sites.

Distance of the wind farm from the coastline.

The environmental effects of wind development on Landscape, Seascape and Visual Amenity range from 'neutral' to 'moderate to major adverse' depending on the site/area assessed.

Monitor any future changes to national level Landscape/seascape Character Assessments and updates to natural heritage features undertaken by SNH.

During the design of projects, detailed landscape/seascape impact assessments and visual assessments should be undertaken. This will provide important inputs to national monitoring.

Siting and Designing wind farms in the Landscape ( SNH 2010).

Regional level assessment of cumulative impacts.

Progress and issues to be considered at a strategic level within the 2 year review process and within the Licensing Manual.

SNH

Marine Scotland

Planning authorities

Population and Human Health

Disruption to key recreational areas for boating.

Disruption to areas of 'greatest' importance for recreation.

The environmental effects of wind development on recreation range from 'neutral' to 'major adverse depending on the site/area assessed.

Monitor significant changes arising from future coastal and marine recreation surveys carried out by both SNH and other key stakeholders, such as the RYA and ensure that these are reflected in discussed with key stakeholders and reflected in revisions to the Plan.

Existing and future SNH/ RYA recreational surveys/research

Regional level assessment of cumulative impacts.

Progress and issues to be considered at a strategic level within the 2 year review process.

SNH

RYA Scotland

Sportscotland

Marine Scotland

Cultural Heritage

Likely impact on designated site or features (and setting), military remains and/or designated wreck attributable to wind farm development.

The environmental effects of wind development on Cultural Heritage were considered to be localised within the SEA with impacts ranging from 'neutral' to 'major adverse' depending on the site / area assessed.

No strategic monitoring required.

However, during the detailed design of a scheme detailed archaeological and Cultural Heritage impact assessments will be undertaken and monitoring of localised effects will be carried out.

MoD data for military protected sites, wrecks and aircraft crash sites

Seazone

Canmore database

Historic Scotland data on listed buildings, scheduled monuments etc.

Developers

Marine Scotland

Historic Scotland

Material Assets (infrastructure and natural resources)

Likely interference with defined navigation routes and/or associated anchorage area potentially resulting in increased collision risk and restrictions on pollution-prevention methods.

The environmental effects of wind development on Material Assets are assessed as 'neutral', 'uncertain' 'minor negative' or' moderate to major negative' depending on the site / area assessed.

Liaison with OWIG etc to obtain specific monitoring data on various environmental receptors. (National coverage, ongoing dialogue).

Liaison with MCA and shipping industry to assess the progress of mitigation measures. (National coverage, ongoing dialogue).

Regional level assessment of navigation risk.

Detailed assessments of potential impacts on local and strategic material assets should be undertaken.

Progress and issues to be considered at a strategic level within the 2 year review process.