This report summarises additional points and clarifications raised by the public in response to published analysis of consultation responses. It also highlights broader issues raised in this second round of discussions, as set out more fully in the Appended meeting notes.
Summary of key issues arising in each feedback workshop
The Scottish Government published its Analysis of Consultation Responses to the Draft Plan for Offshore Wind in Scottish Territorial Waters and its accompanying Environmental Report on 23 December 2010. In order to ensure that this report accurately identified issues raised by respondents to the consultation, a series of feedback workshops were held by Marine Scotland. Focusing on areas where there are particularly high levels of interest in the Draft Plan and its SEA, these events were held in Campbeltown, Tiree, Islay, Dumfries, Wigtown and Maryport.
These additional consultation events sought to double check that the report had accurately and comprehensively reflected people's views. However, at most of the events, concern was raised that the timescales between publication and the event were not long enough, and attendees were unable to fully comment as they had limited time to review the report. However, it was agreed that subsequent to the events, further comments could be taken on board. Some issues were also raised about the accessibility of information during the process (e.g. availability of large print documents and difficulty searching the website).
Minutes of all of these meetings are provided as an Appendix to this report. However, in summary, the following key issues were raised at each of the events or in responses that were subsequently received in writing from members of the public.
Campbeltown - 10 th January 2011
The meeting in Campbeltown allowed for a full discussion of the Plan, the ongoing HRA and socio-economic assessment. Most of the views raised related specifically to the Kintyre proposal and people were concerned that the process was too generic (Scotland-wide) to allow for full discussion of specific projects. An unofficial minute of the meeting was produced by the Kintyre Offshore Wind Action Group ( KOWAG) and can be viewed online via http://www.kintyreoffshorewindfarmag.co.uk/news. A petition was also submitted by KOWAG, calling on Scottish Ministers to reject plans for the Kintyre offshore wind farm as a result of its scale, location and impacts on Kintyre's amenity, tourism and recreation, bird life and many other aspects. This has been signed by a total of 1106 individuals (1003 signatures and 103 signing the online version) and has the support of a number of councillors, MSPs and MPs. During and after the meeting, the scale of opposition to the Kintyre proposal was emphasised and compared with the relatively low level of response focusing on the Islay project.
Comments were also provided on the consultation analysis report. It was acknowledged by some participants that the report was a good attempt to summarise a high volume of responses. However, a number of specific points were raised in addition to those set out in the report:
- Lack of reference to the point made by the Clyde Fishermen's Association that the Plan should relate more closely to the Marine Policy Statement, and a wider view that the Plan was timed to prejudice selection of Marine Protected Areas.
- Concern from a representative of the Royal Yachting Association Scotland ( RYAS) that the deadline for responses had passed but that the Association had a further meeting planned to discuss the Plan and sea safety issues. RYAS submitted a full response in relation to Kintyre which included the following points:
- RYA note that UK Government policy is that consent should not be given to windfarms where they would pose unacceptable risks to safety whatever mitigation measures are attempted.
- Having examined the available information and met with the developer, RYA have concluded that a wind farm on the Kintyre site would constitute an unacceptable risk to navigational safety whatever mitigation measures are attempted. RYA formally asked that the option be removed from the Draft Plan.
- The North Channel is a major shipping lane for all kinds of shipping, and RYA strongly emphasised that a wind farm in that area would be a dangerous obstruction. There are a number of challenges in the North Channel for smaller craft due to turbulent seas; exposure to the Atlantic Ocean; lack of shelter and safe havens; wind; fog; restricted width, and the distance to the nearest lifeboat station. Sailing around the proposed site would leave vessels in waters either close to shore, where reefs are present; through the array, where collision risks are high; or west of the array into exposed waters where tidal streams could prove dangerous to small vessels and where the risk of coming into contact with the Traffic Separation Zone ( TSZ) is high. RYA are concerned that small craft trying to avoid the wind farm may inadvertently stray into the path of Atlantic-bound shipping who are legitimately using the TSZ
- RYA note that their comments will apply to recreational boating and to other small craft such as fishing or fish farm service boats who also frequent those waters.
- Questions as to whether the report had reflected detailed points including impacts on the Burnet moth, shadow flicker, and the full range of sporting and recreation issues including the impact of coastal scour. These were reiterated in subsequent correspondence. Other detailed aspects of the environment were highlighted in subsequent responses, including the South East Islay SPA, noted by SNH to be of high scenic value, the importance of the area for seals, impacts on the Jura NSA which lies within sight of the development, Important Bird Areas, basking sharks and cetaceans.
- Comments on Scottish and Southern Energy Renewables' Shipping Study. This was considered by the Kintyre Offshore Windfarm Action Group ( KOWAG) to have significant deficiencies and to be lacking in impartiality. A fuller critique of the report was provided subsequent to the meeting. This includes the following key points:
- It is critical of the data used (length of sample, timing of data collection and focus only on AIS data). It was noted that a further study has been recommended (covering leisure craft and small fishing vessels) but contended that it would be useful to view this information in one document to gather a complete picture.
- It also states that the study does not include quantification of the costs of using alternative routes and questions their suitability in light of other plan options.
- The lack of searoom for ships to achieve clearance of the array was noted, particularly as moving the development west would impinge on the Islay route and a submarine exercise area.
- Lack of analysis of the submarine exercise area, the most direct transit route for submarines going to Faslane.
- Concern that the recommendations cover both sites (Kintyre and Islay) and does not take into account their differences and features, including the different types of ships using routes and their varying distances from shore.
- Dissatisfaction that the main recommendation aims to address wind farm site optimisation and overlooks what appears to be a significant impact: vessels being unable to use the sheltered coastal route and being forced to use alternative, more hazardous routes. KOWAG contend that the location of the development is fundamentally wrong as a result.
- People reiterated strong feelings about likely visual impact and questioned why the site was in the Draft Plan, when SNH had raised significant concerns about this issue.
- Deficient stakeholder consultation based on non-inclusion of fishing industry and recreational sailing representatives in Scotland and Northern Ireland.
- Concern about an apparent lack of cumulative impact assessment addressing issues raised by organisations including SNH was also raised. This included consideration of cumulative impacts of the recent tidal power project off the south west of Mull and related to concern that the scale of development including the medium term options and onshore developments would make Kintyre a "potentially over industrialised renewables zone." Questions were also raised about the likely grid connection and people felt that this should be fully considered before the Plan proceeds.
- Some people emphasised that more weight should be afforded to Machrihanish Beach, around 2km from the turbines of the Kintyre array, specifically its designated Blue Flag status. This was viewed as an important tourist draw, and at risk from the impacts of the proposed development, including scour, coastal erosion and pollution from oil and chemical spills. It was also pointed out that Machrihanish Dunes is a designated SSSI.
- The need for analysis of the benefits of the development in terms of power generation was raised. The likely output of the Kintyre array was considered to be much lower than had been suggested by the developer. It was requested that the socio-economic study analyses this, taking into account BERR statistics on wind speeds and estimated outputs. Reference was made to the output of the onshore Tangy wind farm as being 21.63% according to Ofgem ROC reports. There was a general view that the output of the Kintyre array (and therefore its benefits) would be limited when compared with its impacts, and potential disbenefits. People attending the meeting and responding subsequently raised concerns about high levels of subsidies being granted to the sector to facilitate development.
- The socio-economic study and HRA were discussed and subsequent to the meeting a detailed critique of the draft socio-economic study report was submitted. This considered the assessment to be fundamentally flawed for a number of regions. It was felt that the benefits of the development should be more clearly defined. There was concern that the short term options had been viewed in isolation without consideration of their cumulative impacts. However, there was also criticism that consultee requests for site specific assessment had been ignored and that the specific impacts and differences between individual sites had not been drawn out in the report, giving a skewed set of conclusions on benefits and disbenefits. It was proposed that the assessment had not covered the full range of alternatives, focusing only on 'do nothing' or 'do everything' and it was contended that people should have been given an opportunity to suggest removal of any given site from the Plan. Many other detailed issues were raised, which will be taken into account as the socio-economic study is finalised.
- Assurance was sought that the site specific impacts of the Kintyre array would be fully and honestly put to Ministers.
- People felt that the plan's strategic perspective would dilute the key messages raised. They felt that each project should be considered on its own rather than as part of a wider Plan. Many people felt that much more project specific information was required. One respondent, for example, noted there was little primary data to draw on, such as comprehensive seabed surveys, and sought further consideration of the acoustic effects of devices on marine vertebrates, impacts on seaweeds and seabed communities, and the reef effects of offshore structures. Another expressed concern about impacts on Golden Eagles, Greenland White-fronted geese, salmon migration, and electrical currents from subsea cables.
- People sought clarification of whether reporting of the event and subsequent responses would take the form of evidence or a discourse with recommendations. They also asked that a site specific analysis for each of the short term sites be provided, setting out their benefits and disbenefits and taking into account consultation responses.
- A reiteration of the point raised repeatedly during the consultation, here and in other key areas, that there should be a minimum distance of 8 miles between developments and inhabited coastline to mitigate impacts. There was further debate on guidance from SNH and its apparent recommendation of a minimum 8km or 13km separation distance for offshore development.
- Lack of mention in the analysis report that the proposed Kintyre array would interfere with the main west coast migration of the North Atlantic Salmon, despite the fact this had been raised at three consultation workshops.
- People asked whether points about underwater mining and development stability and impact had been addressed in the analysis of responses.
- It was highlighted that the Campbeltown Sailing Club response had not been incorporated into the report. This was due to an administrative error. This response raised the following key points:
- Strong objection to the Kintyre development, despite supporting renewable energy generally. This is based on the scale of the development and its proposed location.
- Expectation that the development would impact on the local sailing community and on those from the Clyde, Ireland and further afield who use the waters regularly. Impacts on leisure yachting were raised, and it was considered that this would conflict with the proposed expansion of the marina at Campbeltown during construction and operation of the wind farm. These impacts were expected to extend further afield, up the west coast, and to affect key events.
- Concerns about safety - negotiating a route through the turbines was considered dangerous particularly during rough sea or strong tidal conditions. Generally, users sail close inshore around the Mull of Kintyre, and the wind farm's proximity to shore would not allow for this, or for safe anchorage prior to negotiating the Mull. It was expected that people will instead bypass the Mull of Kintyre and use the Crinan Canal instead. Nautical advice steers mariners away from wind farms at all times on safety grounds.
- Concern about radar interference based on evidence of this.
- Concern about impacts on time taken to reach emergencies from the Campbeltown RNLI Lifeboat station.
- Light pollution arising from MCA recommendations on lighting requirements.
- Landscape, seascape and visual impacts and industrialisation of the area, and biodiversity impacts, were expected to be detrimental or off-putting to sailors.
- Specific comments were also provided in response to consultation questions, including a view that the Kintyre array should be removed from the plan and alternative locations which do not impact on sailing activity should be sought. In response to Question 10 (focusing on landscape effects and mitigation), the Club did not believe that mitigation measures would be effective, given the scale of development and its proximity to shore.
- Two individual respondents were concerned that their responses had not been taken into account as they have not been posted on the SG website. Further investigation showed that these have been logged but have not appeared online due to technical problems. The issues raised in these responses are considered to be fully covered in the consultation analysis report, focusing on issues reported including scale and proximity of development to shore, impacts on Campbeltown Airport and impacts on tourism and golf.
- Questioning of an apparent discrepancy within the report's statements about the distance of the Kintyre site from shore.
- Questioning of the overall conclusion from the analysis that there is general support for the Plan, given the scale of opposition in Kintyre for the proposed development.
- A response by Loganair to the scoping study at the project level was provided. People asked why this had not been included in the report, but it was subsequently clarified that this had not been submitted to the Scottish Government consultation on the Plan. This response includes comments on aviation issues, including significant concern about the likely height and location of turbines in the Kintyre array and the likelihood this will encroach on clearance distance required for flight paths into Campbeltown Airport. Further points were raised about the apparent conflict between the Kintyre site and the recommended 24km buffer for radar.
- Subsequent to the meeting, respondents emphasised that the SEA should undertake fuller consideration of the effects of development on people, in addition to the work focusing on the environment. They also suggested the process had been rushed. Additional points were raised to reflect concerns about impacts such as sleep disturbance, noise and associated health impacts. It was reemphasised that people in the area object to the siting and feel it is intrusive and insensitive. One respondent noted he would reconsider plans for a foreign tourism business if development were to go ahead. Consultees thought that development would have a negative effect on the local economy. An alternative site south east of Campbeltown was suggested.
In addition to the element of the meeting focusing on the Consultation Analysis Report, many other issues were raised. Some of these points reiterated views raised in the formal consultation period, but in some cases new issues were raised or given particular emphasis. These are set out in the attached minute of the meeting.
People were made aware that they could provide further feedback on the report by the end of January, and if that deadline was not feasible, some flexibility would be given if they made contact with Marine Scotland.
Tiree - 13 th January 2011
The Tiree meeting focused largely on the Argyll Array proposal. The following additional views were made in response to the Consultation Analysis Report in Tiree:
- Concern that the graph within the report showing overall numbers of responses, and the recording of 26 responses focusing on the Argyll Array were misrepresentative. People strongly emphasised during the meeting and afterwards, that the scale of responses relative to the local population of Tiree was as significant as that noted for other developments, such as Kintyre. It was requested that this point was clearly emphasised to ensure that the level of concern about the development, and its environmental effects, is not underestimated.
- A view that the Tiree population is being provided with less information about the Argyll Array, compared with information provided by other developers to communities elsewhere. This was considered to be prejudicial to their ability to provide an informed response to the consultation.
- The community reiterated their earlier view that they should be regarded as a statutory consultee within the process. It was confirmed that Marine Scotland Licensing Operations Team has recorded them as a consultee. Assurance was also given that Argyll and Bute Council are a statutory consultee.
- It was noted that whilst several national bodies had responded to the consultation, these organisations had not in turn consulted with local interests to gain a more accurate picture of effects in specific communities and areas.
- There was discussion about the HRA and socio-economic study. Data sources were discussed and the community asked that the work does not rely wholly on information provided by the developers or on data that may be out of date. The community also emphasised the need to ensure impacts on small businesses were considered. They felt that the work should include direct liaison with local businesses and that the methodology lacked consideration of impacts on people - an ongoing concern. It was emphasised that information on watersports was out of date and that the study should reflect the distinctions between different communities and impacts within Argyll. It was noted that masterplanning would provide an opportunity to reflect local distinctions more fully. However, people remained concerns that the study had not focused enough on 'people'.
- Subsequent to the meeting, a number of individuals sought access to the socio-economic assessment report. It was felt that this should have been integral to the SEA, as its findings should underpin the Plan and further consultation on the findings was sought, as in some other areas.
- Some environmental effects were discussed and / or raised by consultees in further written responses after the events. This included infranoise, coverage of the European Landscape Convention, cultural heritage (impacts on Skerryvore, seagoing heritage), impacts on Stanton Banks Site of Community Importance, and impacts on basking sharks (large numbers spotted around Tiree) and porpoises. Explanation was sought on why significant seascape effects had not been viewed as sufficient reasoning to warrant removal of sites from the plan.
- The environmental impacts of the onshore aspects of development were viewed as having been insufficiently considered within the SEA. These were expected to be very significant for the island, given the size of the proposed development.
- People felt that future environmental designations (e.g. p SPAs and MPAs) must be fully considered in the assessment.
- There was concern that not all of the consultation responses can be viewed online. It was explained that this was due to some respondents having chosen for their responses to remain confidential.
- People also asked for further information on how views being raised at this stage would be taken into account. It was explained that these would be set out in this report, and that the report would be published online.
- Concerns about impacts on shipping were raised. It was pointed that the nearby shipping lane was a route where there are frequent movements of bulk oil tankers, heightening the risk of collision.
- Clarification was sought about the technical constraints which had been used to identify options for the Plan. People questioned the inclusion of areas which seemed to be restricted for development by radar coverage. Also people asked how the short term option had been identified in close proximity to the shore, whilst the medium term options had been apparently limited to areas further offshore.
- Concerns about the likely output of windfarms was raised subsequent to the meeting, with an individual noting that reports of activity had shown particularly low outputs during certain months in 2010.
- Concern that information used to assess the effects of development on waves (and therefore surfing) was not applicable to the Tiree environment, where the wave climate is specific to the area.
In addition to the element of the meeting focusing on the Consultation Analysis Report, many other issues were raised. Some of these points reiterated views raised in the formal consultation period, but in some cases new issues were raised or given particular emphasis within the discussion. Many of the views raised focused on the masterplanning and licensing elements of the process. The masterplanning project is being taken forward and it was agreed that Marine Scotland Licensing Operations Team should visit the island at the earliest opportunity. The visits by Marine Scotland officials were considered helpful, and people were keen to see this continuing on a regular basis. The need for much greater communication with the developer was also repeatedly emphasised. The full views are set out in the attached minute of the meeting.
Correspondence was received after the meeting from the No Tiree Array ( NTA) Group. They view the designation of the site without sufficient technical information to undermine their constitutional right to submit a fully considered response. Lack of coverage of onshore impacts was viewed as hindering the ability of the community to fully evaluate and comment on the effects of development on their island. They were also concerned that the consultation had been confined to the strategic level, prohibiting full discussion of project specific issues. Access to information was also raised and they were concerned that people had been unable to attend the local event due to insufficient notice being given. As a result NTA are calling for adoption of the Plan to be delayed, the consultation to be extended, further review of information available to the public, publication of a more holistic database and the inclusion of onshore draft design information relating to the Argyll Array.
NTA also provided a detailed response representing the views of the organisation and other Tiree residents. They reiterated the need to view responses from Tiree as a proportion of the population. Viewing them in this context shows extensive concern in the community.
Site specific concerns are: lack of visualisations produced by the developer - NTA have now produced these based on information from the developer. NTA feel that development near Tiree should be considered a 'special case', and feel that the uniqueness of the Hebrides, and Tiree in particular, has been dismissed - any development would have far reaching effects. They note that Argyll Array should be added to list of options seen as inappropriate.
NTA noted that the Tiree Community Development Trust do not represent the community and NTA should be added to the list of consultees. The community, including second home owners, needs to become part of the decision making process, but the masterplanning exercise may be premature and influence the consenting process. No consultation has been undertaken with local fishermen - NTA noted that the follow up event was in January which is traditionally when Tiree fishermen are on holiday.
Tourism is crucial to the local economy - primary drivers are sea/landscapes and water based sports, including the Tiree Wave Classic international surfing event. Up-to-date figures, detailed assessment and analysis is required before decisions are taken. The radar NATS station on Tiree has not been included and NTA suggested this will close down, losing jobs. It was also noted that the Skerryvore lighthouse, which is Category A listed, would be extremely adversely impacted.
Impacts on the wave and wind regime need to be considered - NTA do not believe the developer intends to study this. They feel that there is not enough environmental information to consent the project or reject it, and that a full socio economic impact assessment is required specifically for Tiree. NTA noted that developer has already started the EIA and may ignore the outcome of the Plan.
At the strategic level, concern was raised that the HRA and socio-economic assessment were not available during the public consultation period. NTA suggest this makes consultation with the Tiree community flawed and incomplete. Also, the timescale to publication of the final plan is deemed to be too short. They note there is a need to ensure that SSSI candidate/Natura 2000 or in-process locations such as Stanton Banks need to be taken into consideration, without bias to commercial enterprise. There is also a need to consider the cumulative effects of Round 1, 2 and 3 sites and SNH should initiate a full visual impact study of the entire west coast. A full study of tourism and its economic benefits should be undertaken prior to submission to Ministers and assessment should consider communities as living entities.
NTA are concerned about current noise guidelines being out of date and inappropriate for offshore wind farms. Issues of infrasound and 'blink', when the sunlight flashes behind blades, need to be considered, and SNH should provide information to NTA on shadow flicker and associated health risks. Both offshore and onshore planning processes need to be explained in full. NTA question investment in technology which is deemed obsolete. It was noted that other countries are investing in research and development for deep water offshore turbines.
No information was made available in Gaelic by Government or developer - there is a strong Gaelic community on Tiree, and many are concerned that Gaelic culture will be diluted or destroyed if many additional residents arrive on the island with development.
The Tiree Community Development Trust ( TCDT) also provided further comments. raising concerns regarding site selection - specifically noting concern that the sites were identified in advance of completion of the SEA and questioning the differing criteria for short and medium term sites - in particular whether the short term sites would have met the criteria used for the medium term options. The level of constraints constituting the cut off between a suitable and unsuitable site was questioned and the TCDT wished to know whether any sites had yet been removed from the plan. They also questioned whether an independent socio-economic impact assessment would now be required for offshore developments.
Further individuals provided some detailed views on the plan and its SEA. Whilst the Plan was supported in principle, it expressed grave concerns about the potential for the drive for renewable energy and offshore wind to overshadow commitments to protecting ecosystems and communities. It also emphasised the special qualities of Tiree and the need to take this into account when planning 'industrial scale' development such as the Argyll Array. The importance of the west coast of Scotland was also emphasised and it was proposed that the impacts of developments must be fully explored and mitigated, including by including local communities in decision making process. Another respondent reiterated the potential for detrimental impacts on a fragile crofting and tourism based economy and the need for research to investigate this. Respondents highlighted noise and light pollution; infrastructure and fuel issues and questioned the impact of development on any other potential investors in Tiree. Support was expressed for renewable energy in general, but in the right location. SNH and European guidance on distance of development to the shore was highlighted.
People attending the event were made aware that they could provide further feedback on the report by the end of January, and if that deadline was not feasible, some flexibility would be given if people made contact with Marine Scotland.
Islay - 20 th January 2011
Views raised at the Islay event related primarily to the Islay wind farm proposal, and there was also discussion of wider issues for the plan. A limited number of points were raised in relation to the Consultation Analysis Report. As in Tiree, there was concern that the analysis had reported numbers of responses. Islay participants felt that this was misleading and may overlook the strength of feeling about the development on the island. Again, assurance was given that the report included both qualitative and quantitative analysis.
Other issues discussed in the meeting included the following:
- Questions about site selection and the role of different bodies in identifying the short term options. It was confirmed that neither Marine Scotland, nor the statutory SEA consultation authorities ( SNH, SEPA and Historic Scotland) had been involved in the selection of these sites. Further explanation was sought as to why areas had been identified (medium term options) that appeared to impact on a National Scenic Area ( NSA). These options were noted to be areas of search as opposed to specific 'sites'. It was also explained that inclusion of options in the plan would not necessarily mean that at the licensing stage they would be given consent.
- Clarification on the planning and licensing elements of the process was sought. Explanation was provided on the process, including the role of consultation within it. The masterplanning approach in Tiree was also discussed and participants indicated that this would be useful for Islay, to address some concerns about lack of early information on the development proposals. Monitoring of the plan and associated future consultation was also discussed.
- Questions were raised about the SEA process, including its coverage of cultural heritage and archaeology issues.
- There was some discussion of the role of Habitats Regulations Appraisal and the Socio-Economic Study. It was noted that procurement should be explored within this and that national and local benefits should be drawn out.
- The need to maximise local employment and economic opportunities was emphasised.
In addition to the element of the meeting focusing on the Consultation Analysis Report, other issues were raised. Some of these points reiterated views raised in the formal consultation period, but in some cases new issues were raised or given particular emphasis. These are set out in the attached minute of the meeting. As the meeting was poorly attended, community representatives were asked to distribute further copies of the consultation analysis locally, and advised that further views could still be submitted to Marine Scotland. In terms of timing, some flexibility would be given if those who wished to respond made contact with Marine Scotland.
Dumfries - 25 th January 2011
A feedback event was held in Dumfries on 25 th January 2011. Clarification was sought throughout the evening of the distinction between these processes and again it was reiterated that inclusion of a site within the Plan would not necessarily guarantee a licence being granted at the project level.
In terms more specifically of the Consultation Analysis, the following key points emerged:
- At the outset it was noted that the timing of the event was not ideal, and that people would have found it useful to have received the Analysis of Consultation Responses directly, prior to the event. Questions were also asked about the level of engagement with people in Cumbria, the Isle of Man and other stakeholders. Assurance was provided that the consultation had been advertised and distributed in line with statutory requirements. As with the other events, a significant proportion of the event focused on licensing as opposed to plan level issues and questions were asked in subsequent written responses about likely timescales for this part of the process.
- There appeared to be a view that the report, and the summary presentation, had accurately recorded the overall issues and views raised in response to the consultation. Some concerns were raised that organisational responses may not fully represent their memberships.
- The issue of the proximity of some short term sites to land was strongly re-emphasised. Many felt that the Wigtown Bay and Solway Firth options were inappropriate as a result of this factor. Reference was made to the Danish Government's current stance on a minimum separation distance of 8km. People also felt that the plan was erroneously titled, relating to 'inshore' as opposed to 'offshore' development.
- People asked for greater emphasis to be given to their view that there is a need to learn lessons from Robin Rigg, before further development takes place. This included information about its productivity and impacts. The Wildfowl and Wetlands Trust ( WWT) made a further submission after the event, which noted its support for renewable energy development, but also raised issues relating to potential impacts on internationally important bird populations. The WWT proposed that Robin Rigg in the Solway Firth provides an opportunity to monitor the impact of the development on the migratory movements of the Whooper swan, a species which is known to fly through the Solway in large numbers under varying light conditions. Monitoring could be undertaken during two key months to provide a useful dataset that would be applicable to assessment of the proposals in the Solway and further afield. In addition, spring monitoring of the Svalbard Barnacle Goose migration route through the Firth of Forth was also suggested. Without such data, the WWT anticipated that they would be opposing developments at the licensing stage, as it would be based only on assumptions and modelling. The WWT also raised concern that agreed radar remote monitoring for Robin Rigg has not yet been implemented by the developer. It recommended that this technique should be set up at sites where developments are proposed or have already taken place to provide more effective monitoring and datasets to allow a more accurate assessment of cumulative effects to take place.
- Participants felt that offshore wind should be viewed within the broader context and assessed alongside other types of generation, specifically hydro, wave and tidal. Questions were also raised about decommissioning.
- Questions were raised about the actual scale and composition of the development proposals, as participants felt that this information was necessary in order to fully define its environmental effects.
- People were concerned about the impact of the plan on migration patterns, given that the area's scenic qualities are a key part of its attraction.
- Detailed points were raised in relation to the HRA. Data gaps were highlighted including in relation to geese and swans (see WWT response above), and again participants felt that the Robin Rigg wind farm should be the source of further data to allow effects to be more accurately identified. People wanted to know the level of species loss which was deemed to be acceptable. It was explained that SNH would be expected to provide guidance on this.
- Socio-economic issues were discussed and it was felt that the assessment had not adequately addressed impacts on communities and people. The points identified in the consultation analysis relating to likely economic benefits (i.e. doubt that these would be secured) were reiterated and concerns about tourism were repeated. One participant suggested that further information on tourism impacts would be helpful - for example seeking visitor feedback on their perceptions of the area if a wind farm was developed.
- Linked with this, people were sceptical that the consultation process would result in any change to the Draft Plan. People felt that more should be done to engage communities in the process and ensure that development benefits would be secured. Some felt the process is being rushed through, and are concerned that the process undertaken for Robin Rigg will be repeated. It was suggested that ongoing dialogue is required to ensure all views are represented, including minority views.
- Some of the discussion focused on broader energy policy. It was explained that offshore wind is viewed as having a role to play within the broader mix of low carbon energy sources. However, people remained sceptical about the likely output of this type of development and asked why other countries appeared to be less eager to take similar plans forward. Questions were also raised about where the developments would link into the transmission grid. People also questioned the apparent aim of generating more energy than is required within Scotland and compared this with their potential costs. Subsidies of the sector were also raised.
- Many concerns related to the site selection process for the 10 short term areas. The workshop participants were concerned that this appeared to focus largely on issues of commercial viability and development economics. Clarification was given that the public will be provided with further opportunities to engage in the process at the project stage, and associated Environmental Impact Assessment. People felt that a more proactive and early approach to developer engagement would have been beneficial.
- A number of more specific points were raised in relation to the Consultation Analysis Report. People felt that the natural beauty of the South West and its economic benefits should be particularly emphasised. Tourism and economic issues now, and in the future, should form a key part of the equation.
- Points previously raised on the 8km and 13km separation distances were reiterated, and comparisons were made to England and Denmark where a more formal 'buffering' approach has been adopted.
- Concern was raised that in their response to the Plan, SNH had questioned the methodology used to assess landscape and visual impact within the SEA. It was felt that all proposals should be put on hold until a review of this methodology had been undertaken.
- It was recommended that the various stages in the planning and licensing processes are more clearly defined, within consultation events and in the published reports. Respondents wanted to know how they can influence decision making.
In addition to the element of the meeting focusing on the Consultation Analysis Report, many other issues were raised. Some of these points reiterated views raised in the formal consultation period, but in some cases new issues were raised or given particular emphasis. These are set out in the attached minute of the meeting.
Consultees attending the Dumfries event were made aware that they could provide further feedback on the report by the end of January, and if that deadline was not feasible, some flexibility would be given if they made contact with Marine Scotland.
Following the meeting, further issues were raised in a number of additional responses. These reemphasised many of the points made at the meeting, and focused on: the need to consider cumulative effects if several developments were to go ahead; questions regarding knowledge gaps, ongoing and existing research, and cultural and historic concerns.
The Solway Firth Partnership reiterated some points made in their original consultation response, noting they feel the consultation process has been unsatisfactory; environmental and socio-economic impacts have not been adequately assessed; conclusions have been based on value judgements not evidence, and that the Plan risks destabilising marine planning in the Solway Firth. They point to disparities between DECC and Marine Scotland SEA conclusions regarding proximity to shore and feel there is a lack of cross-border consistency. They suggest that the Plan should be revisited to provide further assessment of evidence relating to the Solway Firth and that publication timing should be considered. Concerns were raised regarding the availability of consultation responses online, timing of, and advertising for events. The Partnership felt that the process and opportunities for public participation could have been made clearer. It was noted that Hadrian's Wall should be recorded as a World Heritage Site. Overall, the Partnership did not feel that the strength of local opposition to the Draft Plan and SEA and the dissatisfaction with the process had been sufficiently captured.
Wigtown - 26 th January 2011
The event in Wigtown was attended by approximately 130 people. At the outset of the meeting, it was made clear by attendees that whilst the principle of renewable energy was supported, it was vital that the Plan should steer development to appropriate locations. There was consensus that the short term option of the Wigtown Bay site and all other development in the Solway was inappropriate.
The following key points were made in relation to the Analysis of Consultation Responses Report:
- People were concerned that their personal details had been published online. A commitment was made to addressing this as a matter of urgency.
- The community were actively working with other local communities and Dumfries and Galloway Council, and it was noted that they would seek alternative courses of action (e.g. public local inquiry, judicial review) to stop the development going forward. Subsequent to the meetings, Dumfries and Galloway Council reiterated its concerns, as set out in its response to the Draft Plan. It suggested that the Plan and its SEA could be open to challenge on the basis of its inadequacies and the associated consultation process, and stated that the Council would consider all alternatives, including legal challenge, should the short term options remain unchanged in the finalised plan.
- Clarification was sought on the process for identifying the short term options, including any tendering process. Timescales for development were raised, particularly in relation to other marine developments. Concerns were raised regarding lack of contact from developers and a meeting would be welcomed.
- Great concern was raised about the impact of development on tourism, fishing and farming, in an area viewed as of high natural beauty. This should be emphasised further within this Report as the Analysis Report had focused more on landscape effects than those on the tourism sector in particular. These industries form the core of the local economy and employment. Migration into the area is also important, and people were concerned that this, along with property values, could be adversely affected. Subsequent to the meeting, responses also questioned why the report expressed concerns about tourism in terms of 'perceived effects' - this was viewed as being no more based on perception than any other effects identified in the assessment. Specific views on job losses from the fishing sector were also raised.
- Specific concerns about fishing and shipping were raised, including in relation to safety. Representatives of the industry felt that development in the Solway would seriously jeopardise their livelihoods, and that more engagement is required. Wigtown Bay shipping movements in particular need consideration, as does development at Creetown Harbour. Aquaculture needs to be considered as it may be able to co-exist with offshore wind.
- As with other areas, concern was raised about the proximity of development to the shore, and associated visual and landscape impacts. It was noted that other countries (e.g. Denmark) have introduced a minimum separation distance to address this issue. This was also raised in a subsequent submission. Concern was raised that in their response to the Plan, SNH had questioned the methodology used to assess landscape and visual impact within the SEA. It was felt that all proposals should be put on hold until a review of this methodology had been undertaken.
- As in Dumfries, people pointed out that the Plan covered 'inshore' development, and was not confined to 'offshore' proposals. The difference between these locations was emphasised and it was noted that offshore developments would have less significant impacts than those which were 'inshore'. People also suggested clearer mapping, showing the actual distances of the developments from the shore would be useful, as would localised regional information.
- Economic viability of the development was questioned. As in Dumfries, people felt that Robin Rigg may not be efficient and were concerned that information on the development's output was not in the public domain, again suggesting that lessons should be learnt before further development proceeds. One participant questioned the validity of climate change as a driver for offshore wind, whilst others expressed a preference for other types of energy generation. The carbon balance of any development was questioned.
- Strong feelings were expressed that the area was better suited to hydro, wave and tidal energy, and that these sources should be at least considered alongside offshore wind. It was felt that more suitable locations should be considered, particularly in terms of wind speed. Community wind farms should be investigated.
- There was concern about public participation in the process as a whole. People felt that the consultation process was likely to be ineffective, and felt that lack of involvement in the HRA and socio-economic assessments was a breach of process which would be challenged, should the Plan go ahead with the options for development in the Solway. Concern was expressed that people are not being considered sufficiently and proximate communities should be able to influence decisions.
In addition to the element of the meeting focusing on the Consultation Analysis Report, other issues were raised which reiterated the reasons for strong local opposition to development. People asked that the strength of feeling in the area was re-emphasised and wished to know how to influence decision making. All of the issues raised are set out in the appended note of the meeting.
In relation to the documentation, it was suggested that a glossary of acronyms would be helpful.
Following the meeting, further issues were raised in a number of additional responses. These reemphasised many of the points made at the meeting. Questions were raised as to the need for offshore wind if Scotland is exporting electricity and calls for a moratorium on development, both on and offshore. Mitigation was felt to be impossible for development so close to the shore. Cumulative and in combination effects with onshore development were raised and it was suggested that nuclear energy should be considered. Concern was raised that no benefit would come to Scotland. Further investigation of environmental effects and migratory birds in the Solway is required. One respondent questioned the scientific evidence for the link between CO2 emissions and global warming, and of using this as a basis for policy. There is a need to consider the outcomes of European green energy policies as some have had a negative effect on the job market.
English Heritage also provided a response to the consultation focusing on the area around the Solway Firth. It noted the proximity of Hadrian's Wall and associated Roman frontier defences, which together form the Hadrian's Wall World Heritage Site ( HWWHS). They advised that the setting of these remains form part of the Outstanding Universal Value of the site and must therefore be protected from development that could undermine comprehension and appreciation of Roman military planning.
English Heritage also raised concerns about the mapping of options within the SEA, and the assessment findings, as they appeared to have overlooked the HWWHS and lacked sufficient detail to allow for a proper understanding of the effects of the options on the site. They advised that it may be possible to develop some of the options within the Solway, particularly those to the west and south, in a way which avoids adverse impacts on HWWHS and its setting. However, they also explained that the short term options within the Solway raised the significant potential issue of impacts on the setting of the WHS and recommended that the Plan is clear about this issue, takes these effects into account and highlights the need for appropriate proposal-specific consideration of the impacts on the WHS. English Heritage also recommended frequent review and updating of the Plan.
People were made aware that they could provide further feedback on the report by the end of January, and if that deadline was not feasible, some flexibility would be given if they made contact with Marine Scotland.
Maryport - 18 February 2011
Approximately 30 people attended the event in Maryport, Cumbria. Comments focused on the South West region and primarily related to concerns about impacts on the fishing industry in the area. Very few comments related to the consultation analysis itself.
Attendees clearly made the point that they did not support any plans for more development in the South West. The following key points were raised:
- The points presented from the responses from Dumfries and Galloway were all negative and attendees felt this was also true for Cumbria. It was noted that the consultation would have been pointless if this does not influence the final Plan.
- There was a feeling that the process was being rushed and that it would be more sensible to wait, particularly to interrogate information coming out of Robin Rigg. This would help determine whether there would be any negative environmental impacts of further development.
- Attendees noted that there is a high level of concern that the fishing industry, and hence fishing communities, will die if further development goes ahead. Fishing representatives at the event felt that fishing was not a high political priority and that they had to stand up for themselves.
- It was noted that the opportunities for fishing in the Irish Sea and the Solway Firth specifically were limited due to restrictions on areas (due to wind farms and conservation areas) and limited, seasonal fish species. There was the possibility of displacement of the Cumbrian fleet into other waters which could result in more congestion in those areas. It was also noted that compensation for displacement is difficult to claim for due to the detailed information required. Attendees strongly emphasised that it is important to know where people fish, and only using VMS data would not take into account all fishing activity as smaller vessels would not be included. Officials provided information on the pilot fishing study being undertaken in Scottish waters, but attendees specifically noted that this would not include English vessels. NFFO raised this issue in their consultation response and wished it to be considered in particular for this region. The NFFO also offered to assist in distributing information to fishermen in the area.
- Visual impact was a key issue for attendees, who did not want to see any more turbines in the area. It was felt that further development in the area would have an extremely negative impact on the visual amenity of the area. The lack of visualisations from the developer was raised as an issue, though it was noted by one attendee that when visualisations of Robin Rigg were presented, they looked very different to the reality of the constructed wind farm.
- There was some discussion of information gaps. Sand movement was an issue in the area, and questions were raised as to whether surveys had been done in relation to this. Effects of noise and EMF on fish were raised. Officials clarified that a full EIA would be required for licensing and all issues would need to be covered. However, attendees remained sceptical of what the developer would produce, noting that the developer would be more inclined to suggest the environment was sterile. The lack of available information on Robin Rigg was discussed, and attendees were frustrated that this was not yet in the public domain. Efficiency and commercial viability were raised.
- Other renewable energy sources were suggested as being more appropriate, such as wave, tidal and hydro, and previous successes with hydro power in Scotland were cited. Questions were raised as to the energy payback period for wind farms. It was also suggested that as energy is lost during transmission, energy generation should take place in cities, where the majority of energy is required. Attendees wished to know where any energy generated would come ashore, but officials clarified this information would be held by the developer. One respondent questioned whether the Grid could cope with the extra load.
- Some concern was raised that the Solway was being singled out for offshore wind development. Attendees again clearly stated they were not in favour of any further development.
- There was confusion as to why this would be going ahead when government funding is also being given to reinvigorate fishing communities through business strategies. Attendees felt this was contradictory.
- Congestion in the Irish Sea is an issue both on and under the water, and safety concerns were raised in relation to this. Aquaculture around the Solway Firth must also be taken into consideration, as development could have knock-on effects such as sand movement, which has been noted following the installation of Robin Rigg.
- One attendee raised the issue of the radioactive waste repository site in Cumbria, as this could have the potential to spread radioactive waste around the Scottish coast
- The Maryport event was welcomed and it was suggested that more engagement should take place so local people are informed of the potential impacts.
The Carlisle Angling Association expressed concern that there has not been sufficient investigation into the effects on salmonids and migration. They note that only impacts on Scottish Territorial Waters have been considered and are concerned that effects on the English side of the Solway are not included. They also highlighted the potential impact on the Solway Firth AONB on the south side of the firth. Cumulative impacts with onshore development and medium term options were a concern. NFFO felt that consideration should be given to moving designations away from fishing activity, and noted it would be helpful to have coordinates to identify the medium term options. It was suggested that an enquiry form could be distributed to fishermen to identify where fishing activity takes place. NFFO reemphasised that their consultation response should be considered fully.
One respondent noted that the analysis disproportionately reflects the views of those who oppose development, and asserted there will be an apathetic majority - who are not concerned about offshore wind - whose views are not represented. It was suggested that expanding Robin Rigg would affect relatively few new people as the development already exists. It was also suggested that some will gain from any development, including job seekers, local ports and potentially tourist businesses. It was noted that there is already a company offering trips to Robin Rigg.
People were made aware that they could provide further feedback on the report. It was noted that Marine Scotland would be flexible in terms of a deadline, but that any comments should be provided as soon as possible.
Broader Plan - Further Points
The RSPB provided a further response to the consultation document. They were concerned that some of their detailed comments on the plan, including in relation to the Islay site and development more generally on the West Coast had note been mentioned, whilst comments on Kintyre and Tiree had. They emphasised that their comments on birds around the coast generally should be taken into account alongside their comments on specific proposals. They also reiterated concern about bird data being missing in the Ma RS site selection process, and emphasised that this must be considered in preparing the final plan. RSPB also noted that conclusions on the impact and suitability of sites could not be fully defined at this stage, and will required detailed site specific assessment. They would also be concerned if the plan identified any further sites in addition to those highlighted in the Draft Plan.
The Clyde Fishermen's Association ( CFA) further emphasised their belief that other renewable energy developments (e.g. wave and tidal) should be considered when assessing impacts on the fishing industry. CFA suggest that as this has not been included within the socio-economic assessment, the consultation has failed.
In addition to discussion of the socio-economic assessment within the workshops (see previous), some consultees provided further written comments. One made detailed comments on the coverage of watersports on Tiree and suggested that the figures used were dated, and therefore provided an inaccurate picture of the importance of tourism to the island. It also questioned whether the lifecycle of turbines from manufacturing through to construction had been taken into account. Again, concerns were raised that the onshore impacts of the developments had not been fully taken into account. The particular attributes of Tiree's wave climate was emphasised, and it was suggested that this is not directly comparable with assessments of impacts on waves and surf in the Irish Sea and North Sea.
In summary, the following key issues arose as common themes from the feedback events:
1. Consultees remain primarily concerned about the short term sites located close to where they live. A significant level of opposition to the Kintyre, Argyll Array, and all development proposals in the Solway Firth was re-emphasised at this stage. The reasoning behind this is provided in more detail in the minutes.
2. Consultees are concerned that inclusion of sites within the Plan means that a positive decision will automatically be made at licensing. Despite efforts to explain that this is not the case, as a result of the complexity of issues there is still confusion about the overlap and relationship between the Plan and the licensing stage. In response, further information on the role of the Plan and engagement at licensing has now been provided. People have nevertheless emphasised the importance of ensuring an integrated approach to consenting on and offshore aspects of development, raising specific concerns about onshore impacts.
3. Most of the communities believe that the developers (and The Crown Estate Commissioners) should be engaging with them more fully at the earliest stages and on an ongoing basis to provide information about the proposals.
4. Many people consider that the short term sites are 'a done deal' and that their views will not be taken into account.
5. There is support for the masterplanning (now scenario planning) process being developed for Tiree, and there is an aspiration that this is rolled out for Islay. The Kintyre and Dumfries and Galloway communities indicated no desire to go forward in this way, maintaining that their options should be removed from the Plan.
6. Consultees were concerned about the timescale for adopting the Plan, and about the time available for further responses to the consultation at this stage. It was emphasised that at this stage, the consultation events aimed to double check responses previously submitted. Nevertheless, the attached minutes and points subsequently raised highlight some new points and issues that were particularly emphasised.
7. Comments and feedback on the HRA and socio-economic assessments were also provided. The former recently concluded and the latter will report in late February. As far as possible these additional points will be fed into the Socio-Economic Assessment. Throughout the process, consultees have emphasised the need to fully consider impacts of the Plan on people - as a result it is important that this is appropriately addressed in the socio-economic assessment.
8. Broader points about energy policy, the viability of offshore wind and its likely benefits for local communities were repeatedly raised. Some attendees emphasised, however, that they support the need for renewables if they are taken forward in the right location. There also appears to be significant support for wave and tidal energy as an alternative.
9. Some new specific points were provided by individuals and professional organisations. These covered navigational safety, fishing, aviation, tourism and recreation, bird data and cultural heritage issues.
10. Subject to detailed points and clarifications being raised as set out above, and the publication of this addendum, the participants broadly agreed that the Consultation Analysis report is comprehensive and accurately records their views, although some highlighted that points of detail they had made had not been included.
11. The consultation feedback process has proven a useful means of continuing a very useful dialogue with the public on the Draft Plan and its impacts.