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Offshore Wind Energy in Scottish Territorial Waters Draft Plan and Strategic Environmental Assessment - Analysis of Consultation Responses - Addendum


Offshore Wind SEA Consultation Events - Campbeltown - 10 January 2011

Inclusion of short term options in the plan

Concern was raised that the 10 short term sites had 'passed the Strategic Environmental Assessment principles' yet page 27 of the draft report, section 3.2.4, states that the Kintyre site could have significant environmental effects. Why is this not viewed as being of sufficient concern to allow a site to be removed? SEA and Plan making have 2 main purposes, the first is to consider if development should and should not be considered and secondly to steer the main issues that have to be taken into account in the licensing process.

Attendees felt strongly that the approach taken for the Socio-economic report and the HRA of regionalised and national level analysis was appropriate for the strategic level needs, but appeared to be based on an assumption that short term options would be progressed. Questions were asked about how open Ministers would be to removing sites from the Plan, and it was noted that views on this had been invited in the consultation. People felt that the approach to the socio-economic assessment could result in the disbenefits of the development being overlooked as a result of its broad approach. They also believed that the significant level of response on the Kintyre site could be ignored.

Decision making process

It was clarified that no decision had been made on the sites. This would be part of the licensing decision making process and the information from all the strategic assessment findings would be used to inform this process ensuring that the environmental impacts will have to be addressed .

It was clarified that the decision maker on the Plan - Scottish Ministers - will have the findings of the HRA, Social Impact Assessment, SEA and accompanying summary of consultation responses finding to inform the decision making process. It was suggested that with all the assessments the amount of information could be overwhelming, the consultation analysis and the follow up workshops are aimed at refining and summarising information.

It was clarified that all of the assessment reports would be published.

Consultees asked about what status inclusion of the options within a plan would provide for the sites. Options will be put to Ministers. Clarification of the licensing process was given. Licence applications will be handled by Marine Scotland Licensing and operations Team who will require Environmental Assessments, including screening, scoping, assessment and reporting. The Licensing Team will advise Ministers on whether on not to award a licence.

Influence of consultation

People asked how much weight would be given to the strength of feelings on this site (Kintyre) when there are many other requirements to consider. It was assured that via the four assessments decision makers would be provided with the information to make an informed and balanced decision. The post adoption statement will add transparency to this as it will provide a summary of the points consultees have made and how these have been taken into account..

Confirmation was given that any additional views raised in the events or shortly afterwards would also be reported to Ministers as an Addendum to the Consultation Analysis.

The Crown Estate Commission

Clarification was sought as to whether the Crown Estate Commission ( CEC) is a public body. People considered this to be an important issue in the future and some did not agree that the CEC is a public body.

Consultees asked who had identified the Kintyre site for development. This was confirmed as an agreement between the CEC and the developer. It was suggested that the CEC should pre-screen site selections and consult on these selections, this received support. Consultees were encouraged to participate in the current consultation on Securing the Benefits and copies of the consultation document were provided..

Consultees asked if the CEC was willing to take part in the consultation workshops. It was confirmed that they had been invited but had declined to attend.

Summary of Consultation Responses document

Campbeltown Sailing club response was not listed on the list of respondees. This was noted and will be checked.

The report appears to contain a discrepancy regarding the proximity of the proposed turbines of the Kintyre site to the coast, stating both 2 km and 3 km. Clarification was sought as to how this met with a consultees opinion that the EU Regulatory minimum distance was 7 Km from shore.

There was concern that the summary of consultation responses stated that there is general support for the plan and SEA, but given the strength of opposition in Kintyre for the proposed development consultees opposed any Plan which included this site. It was emphasised that the summary is of the responses received and that there is general support for the Plan as a first step in the process of strategic planning of offshore wind. The strength of feeling opposing the Kintyre site remains evident despite this broader point.

People asked whether the additional points raised and any anomalies identified in the summary report be amended before being issued for supporting information in the Ministerial decision making process. It was clarified that amendments etc would be drawn to the attention of Ministers. It was hoped this would be undertaken within a month.

It was highlighted that there was a lack of reference within the Consultation Analysis to a point raised on the need to link the Plan with the Marine Policy Statement.

The report had not included the Loganair response stating proposed turbines would only leave 15 meters clearance on the flight path. This was also noted. Subsequent to the meeting, it was clarified that this response had not been submitted in the formal consultation (having been addressed to consultants advising the developers not Marine Scotland). The response has now been recorded.

Clarification was sought that light pollution and shadow flicker had been considered as it was felt this could have a significant effect. It was confirmed that this has been considered in the report.

Consultees questioned how ongoing areas of research and subsequent findings would be incorporated into the consultation process. Any ongoing research or assessment work will be taken on board when it can. If information is forthcoming in the very near future it can be considered for this round of Plan making, however it is proposed to revisit the Plan on a 2 year cycle through the SEA review process.

The Royal Yachting Association Scotland representative felt that the consultation process was complete so further incorporation of report findings, such as that of work undertaken by Anatec would not be taken into account. Assurance was given that new information will be taken on board now if possible. Marine Scotland was not aware of further work being taken forward by RYAS.

Visual Impact

It was noted that the most common concern for sites was the proximity of short term sites to the shore. Consultees asked whether guidelines could be applied or set to ensure this issue would not occur again. It was noted this issue had been raised by a number of respondents, and would be conveyed to decision makers but that it was unlikely that such guidelines would be set for this version of the Plan.

The consultees conveyed a very strong feeling that the unique vistas enjoyed by the community that are intrinsic to the sense of place will be destroyed. It was noted that the consultation analysis report has taken into account special qualities of this nature which cannot be quantified easily.

Environmental impacts

A Sports Scotland representative noted that the impact on surfing had been recorded only as a landscape impact, and asked whether issues such as changes to coastal processes and wave patterns had been included in the report.

Scour pits and the environmental damage they can cause was also raised as a concern.

Questions were asked bout the likelihood of water heating from electrical transmission cabling. It was explained that there is some information on environmental information on deep water transmission cables. Clarification was sought as to whether transmission cables could raise the temperature to a level where benthic species are adversely affected and alien species are supported. It was suggested that this was unlikely, in the professional view of the consultant.

Habitats Regulations Appraisal and Ecological Impacts

Further explanation was sought on the relationship of HRA and the designation of Marine Protected Areas.

It was felt that sites should be prejudiced from entering the selection process as the selection criteria had not been set, how was it possible to fully protect potentially important species and sites?

Consultees asked for clarification of the implications of the HRA. Questions were asked about why SNH had expressed concern about the impact of the site in their response to the SEA, but had agreed with the HRA findings suggesting that mitigation should be available to address issues arising.

Clarification was given that protection measures were in place to meet European Law requirements, in addition emerging designations will be taken into account through and the SEA review process which is proposed to take place on a 2 year basis. It was also noted that inclusion of regional development proposals within the Plan would not mean that sites are automatically given the green light. A comprehensive Licensing process will be required to consider issues at the project level. Further assessment will be required to test proposals fully at the local level. Questions were asked about when this would take place and Consultees were advised that Marine Scotland Licence and Operations Team would handle offshore wind applications but developers would decide when to take forward project level screening, scoping, assessment and application..

Concern was raised about the timing of the HRA, and the lack of scope within the timescale (October 2010 to January 2011) to allow for seasonal coverage of data collection. It was clarified that primary data collection is not undertaken at the HRA level, this type of assessment draws on published information and available data on designations. Further questions explored whether there has been habitat surveys of the area. It was noted that this is SNH's role. HRA has to make use of the best available information.

It was also noted by participants the HRA focuses on the top of the food chain and that consideration should also be given to the bottom of the food chain (i.e. algae) to be complete.

Participants also raised concerns that the developer is overlooking the existence of dolphins in the area. Dolphins are regularly seen. It is important that the developer uses accurate factual information.

Discussion also focused on the level of change due to development which may or may not be acceptable. It was emphasised that the HRA requirements mean that a precautionary approach is required. For some sites this can be a very exacting test as effects on European designated sites cannot be significant.

Ministers will be informed of the finalised findings from the HRA process and these will be taken into account as the Plan is finalised.

Consultees asked how the study could be finalised at the end of January when information is currently being gathered on the effects of cables on migrating salmon by the North Atlantic Salmon Trust. This information will not be available until April 2011. This was noted and it was explained that the HRA has sought to address the issue using the best available information. It was agreed that it would be useful to have the North Atlantic Salmon Trust report within the Plan timescale, but in the meantime a precautionary approach has been applied in the development of mitigation at the strategic level. It was acknowledged that the information may not be perfect or comprehensive, but that the Plan plays a role in taking forward identifying issues to address data gaps through further research.

The Scottish Fishermen's Federation also raised issues about the HRA and the relationship between the Plan and the designation of Marine Protected Areas. It was suggested that the Plan is being progressed rapidly ahead of these designations being made.

It was requested that impacts on the Burnet moth be taken into account. This fragile and delicate species attracts many people to the area.

Socio-economic issues and assessment

Clarification was sought on the source of the figure that 20,000 jobs could be created. This was noted as a gross figure and there was some debate on the source of the information.

Concern was expressed that the assessment is putting together individual sites and local areas when the issues in each place are not the same. The issues are very different in Islay, Tiree and Campbeltown, and this should be recognised. Consultees believed that the work must be more specific, or risks being fundamentally flawed. It was noted, that the study will seek to examine who stand to benefit or dis-benefit from the developments.

It was pointed out by consultees that there appears to be no existing data on socio-economic impacts of developments located so close to shore. Other experiences may not therefore be comparable. This was noted, and assurance was given that information gaps, uncertainties and the consultee views will be captured within the report.

Reference was made to experiences with the Burbo Bank windfarm near Liverpool. A study had shown that there were no net benefits (in terms of additional jobs) from the development for the Liverpool conurbation. This was noted, but it was also noted that work on projects such as the National Renewables Infrastructure Plan are aiming to address this by seeking to examine how Scotland can maximise local benefits. However, participants appeared to remain unconvinced that there would be local benefits from the Kintyre site.

A question was raised about whether the study will take into account EC procurement rules when jobs are being considered. This was viewed as being possibly too detailed for the higher level analysis, which focuses on new jobs and taking into account displacement.

The consultees suspected that the emphasis of the study would be too focused on benefits, and that more should be done to explain the costs of development. Attendees also asked for a greater emphasis on the social (as opposed to economic) side of the assessment. It was noted that the consultants are discussing the study with the Scottish Fishermen's Federation. Consultees were concerned that unquantifiable costs may be outweighed by more readily identifiable benefits.

It was noted that the consultation responses will form an important source of information on social impacts.

It was suggested that the study includes consultation with local clubs and recreation user groups, who could provide useful data on the importance of the area for their activities at the strategic and local area. It was also emphasised that sport is about more than just recreation but also provide health (physical and mental) benefits and wider community benefits such as improving social well being and community cohesion.

Consultees asked whether the benefits will be offset by any environmental costs. It was noted that these are not being quantified in detail but will be broadly taken into account.

Questions were raised by attendees about the efficiency of wind farms, with figures quoted that suggested turbines only run for 98 days a year with average running efficiency of 28% to 32%. In response it was noted that figures vary widely and that there are no conclusive data on this. Building on this, the Kintyre Wind Farm Action Group referred to information published by NASA that ranks the potential output of existing and proposed wind farm sites. On this, Argyll Array ranks 15 th, Islay 20 th and Kintyre 402 nd.

It was noted that Scottish Renewables are on the advisory group for the project, and the steering group for the HRA.

The final Socio-economic report is due on 18 th February 2011. The points made by consultees will be taken into account.

General comment.

A previous statement from the Scottish Renewables Industry body was quoted, which stated that historically objections to onshore wind was not a major issue so it was not expected be an issue for these developments especially where development would not be within sight of the coast.

One participant, who had moved to the area relatively recently stated that he had heard many reasons during the course of the event as to why the development should not proceed, but none on why it would be a good idea, beyond hypothetical expectations of employment generation. He asked that the developers and the Crown Estate be more forthcoming with the reasons for identifying the site in the first place. These were thought to be primarily water depth, ease of development and therefore development costs.

Consultees believed that the presence of the developer SSE Renewables would have been useful at the meeting.

Clarification was sought as to the final decision maker on the Plan. It was noted that this was likely to be the Cabinet Secretary for Rural Affairs and the Environment, and that other Ministers including the Minister for Enterprise, Energy and Tourism would be included in the process. An appeal was made to the group by one participant to contact the Cabinet Secretary and the Minister directly to express their views on the development.

Participants were asked to contact Marine Scotland if they wanted to raise any further issues that had not been addressed in the Consultation Analysis report or at the event itself verbally or by putting their views onto the questionnaire in writing.