4. The SEA Reasonable Alternatives
4.1 The Environmental Assessment (Scotland) Act 2005 Act (the ‘2005 Act’) requires that the Scottish Government identify, describe and evaluate the likely significant effects on the environment of any reasonable alternatives to the preferred policy position, taking into account the objectives and geographical scope of the plan or programme. A new set of four SEA Reasonable Alternatives have been derived to address the comments made by respondents to the September 2018 Environmental Report. Compared to the preferred policy recommendation the first two of the SEA Reasonable Alternatives would provide a greater level of provision for the bird species, and the third and fourth would provide a reduced level of provision.
4.2 Appendix A provides detailed information on the pSPAs, including the qualifying species under each of the SEA Reasonable Alternatives.
4.3 SEA Reasonable Alternative 1 – this alternative also classifies all 13 pSPAs that form the Final Advice from SNH and JNCC, but the qualifying interests would be all species that regularly occur in qualifying numbers. This would result in two additional qualifying interests at East Mainland Coast, Shetland pSPA: long-tailed duck and red-breasted merganser, but in all other respects the network of sites would be the same as the preferred policy option based on SNH’s Final Advice. However in addition this Reasonable Alternative would identify conservation measures, including Priority Marine Feature (PMF) status for some species to further enhance conservation benefits.
4.4 The Network Assessment identified a number of species where additional conservation measures would be beneficial. No bird species have PMF status at the present time, and its provision would give additional consideration for listed PMF species in the planning and consenting systems. This scenario meets the objective of fulfilling the statutory requirements of the Birds Directive however it includes a higher level of representation of some species in the network than considered necessary as well as PMF status which goes beyond what is statutorily required.
4.5 In the previous ER consulted on in Autumn 2018 the High Scenario Reasonable Alternative (which SEA Reasonable Alternative 1 replaces) included another positive conservation measure to develop a Scottish Seabird Conservation Strategy. In the intervening period this has become a Programme for Government commitment meaning this measure no longer forms part of the Alternatives assessed in the current ER.
4.6 SEA Reasonable Alternative 2 – This alternative also classifies all 13 pSPAs with all species that regularly occur in qualifying numbers. The qualifying interests of the sites are the same as for Reasonable Alternative 1.
4.7 SEA Reasonable Alternative 2 considers the pSPAs and qualifying species contained in SEA Reasonable Alternative 1 but would not include PMF status for marine bird species. Neither is PMF status considered in the subsequent SEA Reasonable Alternatives. This SEA Reasonable Alternative meets the objective of fulfilling the statutory requirements of the Birds Directive. However, as with SEA Reasonable Alternative 1, it includes a higher level of representation of species in the network than is considered necessary to meet the objective of fulfilling statutory obligations for SPA classification under the Birds Directive.
4.8 SEA Reasonable Alternative 3 - This would provide a reduced provision for the bird species compared to the preferred policy recommendation by removing the qualifying status of breeding red-throated diver from neighbouring marine pSPAs.
4.9 This SEA Reasonable Alternative reduces local geographic replication of breeding red-throated diver in the marine SPAs. Under this Alternative the number of marine SPA’s with breeding red-throated diver as a qualifying species would be limited to one in Orkney and one in the Shetland. This would result in the Bluemull and Colgrave Sound pSPA not being classified reducing the proposed network to 12 sites. If North Orkney pSPA and Scapa Flow pSPA are taken forward, this scenario would also result in the removal of breeding red-throated diver as a qualifying species from the North Orkney pSPA (see Section 6 below).
4.10 A limitation of SEA Reasonable Alternative 3 is that it does not reflect the highly restricted distribution of breeding red-throated diver in Scotland. Scotland supports all of the GB breeding population of red-throated diver (an Annex 1 species identified as rare and vulnerable in the Birds Directive) with the Northern Isles supporting over 40% of this. A reduction on the basis of local geographic replication would result in the second and fourth largest SPA populations not being included in the UK SPA network. In addition, both pSPAs provide protection to feeding grounds used by red-throated diver from terrestrial SPAs.
4.11 There is the potential that this SEA Reasonable Alternative would result in more needing to be done to adapt the network in the future to meet the favourable conservation status needs of species that are less well represented.
4.12 SEA Reasonable Alternative 4 - would reduce replication in the Scottish network for species already well represented in the existing UK marine SPA network and where the majority of their population is not in Scotland.
4.13 Under this SEA Reasonable Alternative for species where Scotland holds the majority of the population (taken as >50% GB population), the findings on the Network Assessment with respect to the existing level of representation for each species in the Scottish marine SPA network is relevant and appropriate at a UK level and therefore, further reduction in the Scottish network is not considered appropriate. For species where Scotland does not support the majority of the population and where there is already existing UK SPA provision the number of Scottish SPAs for which these species are identified as qualifying species could be reduced. This SEA Reasonable Alternative presents the same limitation as SEA Reasonable Alternative 3 with respect to breeding red-throated diver. In addition, non-breeding red-throated diver would be removed as a qualifying feature from the Moray Firth pSPA and common scoter and black-headed gull from the Solway Firth pSPA.
4.14 In addition to the limitations around breeding red-throated diver, there are a number of factors that affect how replication at the UK scale is accounted for. Key to this is the requirement under the Birds Directive to provide SPAs for the conservation of species in the geographical seas where they occur. This is accounted for in the UK SPA Selection Guidelines under Stage 2.2 which prioritises selection of areas to those for a given species in the UK that ‘provide as wide a geographic coverage across the species’ range as possible’. This means we would expect to have the full geographic range of a species (based on its UK distribution) in the UK represented in a UK marine SPA network. This scenario does not ‘provide as wide a geographic coverage across the species’ range as possible’ and would result in no SPA provision of non-breeding red-throated diver in the northern extent of its GB range and no SPA provision of common scoter and black-headed gull in the northwest extent of their range.
4.15 There is the potential that this SEA Reasonable Alternative will result in more needing to be done to adapt the network in the future to meet the favourable conservation status needs of species that are less well represented.