B2. SUMMARY OF THE CONSULTATION PROCESS
B2.1 Public and stakeholder engagement has formed an integral part of the development of this Plan. This is a requirement, specifically within the terms of the Environmental Assessment (Scotland) Act 2005, but also reflects the importance placed by Scottish Ministers on effective consultation at all stages of information gathering and assessment. For example, option assessment, at strategic level, has been considered by consultees from affected sectors and regions, to help identify or confirm the impacts, concerns, gaps in knowledge, and further work requirements. Consultation on this Plan has allowed Scottish Ministers to consider the high level impacts from the Draft Plan, and to gauge views, including sectoral and public acceptability of the development proposals it contains.
B2.2 As required by the Environmental Assessment (Scotland) Act 2005, the key opinions expressed on the Plan and the SEA have been set out in Section B1 'The Post Adoption SEA Statement'. This Section also explains how these views have been taken into account. In addition, this section of the Report provides an overview of the engagement process itself, to clarify the steps that were taken to ensure that the development of the Plan was transparent and robust.
B2.3 Consultation on the Plan began at the start of the planning and assessment processes. As required by the 2005 Act, SEA screening and scoping involved a 5 week statutory consultation with the SEA Consultation Authorities via the SEA Gateway. Transboundary consultation was also undertaken via the Gateway and the Department of Communities and Local Government ( DCLG). The report was also made available online at www.scotland.gov.uk/consultations allowing for interested individuals and organisations to comment at that stage.
B2.4 When the SEA Environmental Report was commissioned, a steering group was formed which included the Consultation Authorities. The contractors undertaking the SEA periodically reported to relevant groups, including the Offshore Wind Industry Group. Discussion with these groups included a focus on agreeing the environmental objectives to be used in the SEA process and subsequently involved debate on the use of the MaRS model to develop medium term options.
B2.5 Prior to publication of the Environmental Report, five pre-consultation workshops were held to explain the environmental assessment process. The offshore wind, shipping, fishing and recreation sectors were invited to these workshops, along with environmental non-governmental organisations, the SEA Consultation Authorities and other relevant bodies identified by the SEA consultants.
B2.6 A range of issues emerged at this stage in the process, particularly on the suitability of information gathered, key sectoral concerns and engagement in the process of identifying medium term options.
B2.7 The SEA Environmental Report and Draft Plan were published for consultation on the Scottish Government's website on 19 May 2010. The Report and Plan were made available initially for a 12 week statutory consultation period, although this was subsequently extended for a further 6 weeks. Statutory adverts were placed in national newspapers at this time.
B2.8 A set of key questions were included in the consultation, to help focus consultee views on significant challenges arising from the Plan and its assessment, and provide a structure for the consultation analysis, but consultee responses were not restricted to returns of this questionnaire.
B2.9 The process of engagement extended beyond formal, written consultation and responses. To ensure that the process was as transparent and participative, as resources would allow, a number of stakeholder and public meetings were held. A series of sectoral workshops were undertaken, involving fishing, shipping, ports and harbours, aquaculture, aviation, offshore wind, tourism, recreation, environmental and other representative bodies. A joint consultation workshop was held with the Scottish Coastal Forum and Scottish Environment LINK. In addition, a set of regional workshops were undertaken in Ullapool, Inverness, Edinburgh, Peterhead, Stornoway, Lerwick, Dumfries, Wigtown, Campbeltown and Oban.
B2.10 Following consultee feedback Scottish Ministers agreed to extend the consultation period to 18 weeks to allow consultees more time to respond to the consultation and to allow further regional venues to be included, based upon requests for further regional dialogue, especially from communities in Argyll. Further regional workshops were therefore held in Tiree, Islay, Barra and Dundee. Scottish Government officials also attended a workshop in Kirkcudbright at the request of local councillors to present the SEA Environment Report findings and Draft Plan.
B2.11 In summary, the engagement process included:
- 24 consultation workshops, attended by more than 500 people. Many of these people were individuals, but a significant number represented organisations with wider membership.
- 856 written responses were received from individuals and organisations who wished to comment on the SEA Environment Report and Draft Plan. If correspondents provided permission to do so, the responses to the consultation were published online. 7
B2.12 As many as possible of the events were advertised in local newspapers. In all areas posters were distributed and emails to organisations and local networks were also utilised to advertise the events. Adverts were placed in:
The Oban Times, The Shetland Times, Buchan Observer, Dundee Courier, Stornoway Gazette, Campbeltown Courier, Guth Bharraidh.
B2.13 Advertisements were also placed in national and local newspapers to inform the public of the extension to the deadline for the consultation when it was announced in August 2010. Adverts were placed in:
The Scotsman, The Herald, Aberdeen Press and Journal, Ross-shire Journal, Northern Scot, John O Groats Journal, Caithness Courier, Northern Times, Highland News Group, Inverness Courier, Ullapool News, West Highland Free Press, Fraserburgh Herald, Buchan Observer Group, Aberdeen Evening Express, Shetland Times, The Orcadian, Stornoway Gazette, Dundee Courier, Fife Free Press, Edinburgh Evening News, East Lothian Courier, Dumfries and Galloway Standard, Galloway Gazette, Stranraer and Wigtownshire Free Press, West Cumberland Times and Star, Oban Times.
B2.14 For the second round of events, adverts were placed in national and local newspapers, which highlighted the publication of the consultation analysis (see below). In all areas posters were distributed and emails to organisations and local networks were also utilised to advertise the events. Adverts were placed in:
The Herald (all Scottish events), Campbeltown Courier, Oban Times, The Ileach, Galloway Gazette, Whitehaven News, West Cumberland Times and Star, Stranraer and Wigtownshire Free Press, Dumfries and Galloway Standard, West Highland Free Press.
B2.15 The Scottish Government webpages were also used to encourage responses and provide further information as the work progressed. This included publication of accompanying information, such as Frequently Asked Questions arising during the process. 8 Links to the relevant documents, including the Draft Plan and SEA outputs were available online throughout the consultation process.
B2.16 Notes of the consultation meetings and written responses to the consultation were reviewed and analysed as part of the process. To aid transparency, a summary of the analysis was published, which reflected the main points raised from the consultation process as a whole. 9
B2.17 The analysis examined the responses from sectors, authorities, statutory bodies, environmental NGOs, community bodies and individual members of the public. The geographic spread of consultee responses was summarised, along with the main environmental, sectoral and community issues. This highlighted where specific proposals were raising issues of public acceptability, allowing Scottish Ministers to take these views into account within their decision making process.
B2.18 The consultation questionnaire responses were used to categorise issues and graphs and mind mapping techniques were used to explain and summarise consultee views. The analysis highlighted that there were particular significant public acceptability issues raised in relation to three short term options identified in the Draft Plan: two in the Solway Firth and one off Kintyre. However, the analysis also showed that there are significant issues which have to be overcome at other sites and across the regions, and subsequent consultation emphasised that levels of concern cannot be fully gauged by recording numbers of responses alone. The key issues identified through the strategic assessment, and the responses to them, are set out in Section B1 of the Post Adoption SEA Statement.
B2.19 The Consultation Analysis was published on the Scottish Government website on 23 December 2010. To ensure that consultees were aware of this publication, Marine Scotland contacted all individuals and organisations who contributed to the consultation process by e-mail or letter if they had provided contact details.
B2.20 To further check that the Consultation Analysis publication fully reflected consultees' views a set of Regional Workshops were held at consultation 'hotspots'. The consultation 'hotspots' were identified as Campbeltown, Tiree, Islay, Dumfries, Wigtown and Maryport, based upon mapping of the origin of responses, previous workshop attendance and strength of views expressed. If consultees identified relevant omissions or explained issues differently their views were captured within workshop notes or through consideration of consultee submissions. These were included within an Addendum to the Consultation Analysis, brought to Scottish Ministers' attention and again published on The Scottish Government website. The meeting notes were published online. 10