Offshore Wind SEA Consultation Events - Dumfries - 25 January 2011
Influence of consultation on decision making
Many of the community felt that that earlier notification of the Analysis of Consultation Responses prior to the meeting would have been beneficial. It was also felt by some attendees that holding the event on Burn's night had impacted on attendee numbers - this was acknowledged as unfortunate, but unintentional.
The purpose of the meeting was to check that the Analysis Report was accurate. Any further views were requested by 31 January 2011. It was requested that Marine Scotland be informed if respondents intended to make further comment but were unable to meet this deadline as late responses would be accepted.
Clarification was sought on the consultation engagement process as some participants emphasised that interest in the consultation extended into Cumbria and the Isle of Man and that these groups had not been fully engaged in the process.
Attendees were informed that a link to the analysis report had been issued to all respondents to the summer consultation, advertisements had been placed in national newspapers, posters had been placed in community post offices and representatives groups had been asked to disseminate notification to interested members. The SEA process had also met statutory requirements by including a trans-boundary consultation. This was undertaken via the Department for Communities and Local Government ( DCLG) as required and involved contacting EU Member States. Two responses to this trans-boundary consultation had been received and the responses included in the Analysis Report. The strategic nature of the consultation on what is a National Plan was reiterated. Further consultation on proposed areas of potential further development would be required at next stage of the process.
The Scottish Government were asked to clarify the extent to which the decision making process was a devolved matter. It was clarified that Scottish Ministers have responsibility for Licensing and Marine Scotland Licensing Operations Team will deal with Marine Licence applications within Scottish Territorial Waters and following executive devolution of licensing powers under the UK Marine and Coastal Access Act in 2009 and implementation of the Marine (Scotland) Act 2010 will deal with applications in Scottish Waters out to the 200 nautical mile limit.
Clarification was given on the process that would be undertaken after these events. The community were informed that additional views and issues not included in the Consultation Analysis would be set out in an Addendum to the summary which would be made available to Scottish Ministers and published on our website. It was reiterated that inclusion of regional development in the Plan does not equate to consent for a development project.
Some members of the community felt that the representatives from The Crown Estate Commissioners ( CEC) and the Developer should have been in attendance. The attendees were informed that an invitation to attend had been extended to CEC.
An example of effective community engagement of an onshore windfarm development was given by a member of the audience, who asked what the Scottish Government can do to ensure that communities are fully engaged in the future. They felt that polarisation of views would continue unless the communication and engagement process changed. The community were informed that funding for community energy schemes were available under Government or Agencies funding schemes. The ongoing consultation on "Securing the Benefits" ( http://www.scotland.gov.uk/Publications/2010/11/26094907/0) was highlighted. It was noted deadline for responses is 18 February but late responses would be accepted providing Marine Scotland is notified.
Attendees believed that there was not the same appeal measure for offshore developments as there was for onshore and this needed to be addressed. They were informed that if a planning authority objects to an offshore development, this could trigger a public local enquiry for offshore developments. Clarification of this issue would be provided by Marine Scotland.
There was a strong feeling from some attendees that a lack of understanding of processes and the use of jargon was hampering their ability to stop the development - their fundamental objective. This was noted by Government representatives as an important issue.
Attendees requested further information about the point in the licensing process when public consultation would take place so they could engage effectively. It was explained that for each proposed project an Environmental Impact Assessment ( EIA) will be required to be undertaken and will include a process of screening and scoping. This will involve looking at potential impacts of the project such as effects on habitats and species, navigation routes, pipelines etc. During this process it is considered by many developers as good practice to organise consultation events with the local community - as has been seen for East Coast proposals. On completion of screening and scoping, an EIA will be undertaken as part of the licence application - all of which will be submitted to Marine Scotland Licensing Operations Team. It is the role of the Licensing Team to make recommendations on the project application to Scottish Ministers. It is anticipated that it will take around 9 months from application submission to a decision being made on granting a licence. Attendees believed it would be helpful if this information, including when public consultation takes place, was included within the Plan. This was noted by officials.
The community asked how they would know about the public meetings held by developer groups on the east coast. Marine Scotland agreed to notify the Solway Firth Partnership on screening and scoping and would ask them to disseminate this information. They were also informed that the Forth and Tay Developers' Group ( FATDOG) actively used their website to seek engagement and that much of the information was therefore publicly accessible.
Clarification of the site selection process was given as attendees expressed concern that the whole process seemed developer led. Attendees asked why the areas of potential development could not be chosen by the community and not the other way around. It was explained that 25 medium term options were identified through marine planning and were Government led. It was noted that the 9 short term options had been presented to the Scottish Government through the identified exclusivity agreement between The Crown Estate Commissioners and the developers.
Clarification was sought from attendees on the number of turbines anticipated for the proposed sites as a couple of attendees had undertaken calculations resulting in an estimated figure of 900. Clarification was sought on whether this estimated figure related to actual turbines or the turbine pilings and it was noted that this is not yet known and would depend on the design of the site and further project level assessment.
Attendees asked for the development category to be changed from "offshore" to "inshore" There was a strong opinion expressed by attendees that proximity to the shore of the proposed development and the resulting visual impact was not what they believed should be termed "offshore" referring to the Danish Government view of a minimum of 8 km exclusion zone before offshore development should be considered. It was noted that this was a concern which had been raised in other areas and that the terminology is technical, originating from the oil and gas industry. They were informed that for the purposes of the national level Offshore Wind Plan all sites were considered to be offshore but that the SEA has identified visual impact (arising from proximity to the coast) as an issue of significance and this would be conveyed to decision makers. Attendees also thought that England has a minimum of 8 to 13 km exclusion and asked why this is not the case for Scotland. Further work on the visual impact of offshore wind will be taken forward under marine planning and marine licensing workstreams.
People noted that the findings of the SEA had identified significant information gaps and sought clarification on the process that would be undertaken to address this. They were informed that a group will be set up to assist in reviewing the gaps and identifying a monitoring strategy, areas of research and to steer further assessment. It is proposed to undertake review on a two year basis.
Impacts on tourism were also a key concern. It was noted that the socio-economic study would assess these impacts at a strategic level.
There was a strong concern expressed by consultees that there were fundamental impact and economic viability lessons to be learned from the Robin Rigg development and that this information should be incorporated into the assessment process. Failure to take this into account would be a significant omission.
It was also considered to be unacceptable that key economic information (i.e. the output of Robin Rigg) was not publicly available due to commercial confidentiality and that no radar monitoring equipment had been installed on the site, despite this having been a condition of the licensing consent. It was explained that lessons learned during the licensing process of this development were considered during the development of the Marine Renewables Licensing Manual which was a living document and will be subject to further periodic review. Economic considerations will be taken into account at the licensing stage. It was proposed by consultees that this could be too late and should be given greater consideration at policy level. Marine Scotland would also check the issue concerning radar and the licence conditions for the Robin Rigg development.
Attendees considered that impacts on the human population had not been considered adequately. There was concern regarding lack of data on potential loss of jobs, impact on tourism and fishing. Members of the community believed that in terms of cost/benefit there would be no benefit to Dumfries and Galloway and ultimately developments would result in a significant negative economic impact, including in terms of property and business values as it would deter people from moving to the area due to lack of jobs and/or visiting the area due to an industrialised environment. Some attendees considered this shortfall in information mean that their perspective was not reflected in decision making and questioned the impact of the consultation process: asking, for example, whether the consultation could reduce the number of sites within the Plan. They were assured that the socio-economic assessment would address the effects on human population and that the consultation process and SEA has identified these impacts as an issue of great concern. Officials noted that the strength of views from the community on the proposals in the South West gathered from the consultation process would be conveyed to decision makers but it was not possible to foresee Scottish Minister's decision. Attendees believed that the Scottish Government had captured the views of the community well within the Report, but that politicians would ignore this advice. It was suggested that Ministers should visit the area to see the potential impacts for themselves.
Habitats Regulations Appraisal (HRA)
Concerns were raised with regards to information gaps and the integrity of the data being used to inform the Habitat Regulations Appraisal ( HRA). Of particular concern were geese and swans and the lack of radar tracking at Robin Rigg was again emphasised as a missed opportunity to learn more about these impacts. It was also asked if a species was found to be at risk, what proportion was deemed expendable. It was explained that the HRA is a high level assessment looking at the overall effects of the Draft Plan. This would identify gaps in knowledge, issues to be addressed and mitigation measures that would need to be considered at the project level by the prospective developer and was not a green light for development at the licensing stage. Marine Scotland would have to consider HRA issues at the project level. The data sources utilised are held by organisations such as SNH who are independent advisors and would additionally advise on the level of risk to species. Marine Scotland also carry out further monitoring and research and revisit the strategic HRA within the review process, currently proposed to be on a 2 year basis.
Marine Scotland were asked if it was producing a wave and tidal version of the Plan as it was considered by many that marine renewables should be equally considered and in a more joined up approach with offshore windfarms. Attendees were informed that Regional Locational Guidance has already been produced and that work is commencing on a Plan which will contain SEA, HRA, Socio-economics and Consultation Analysis.
Energy security and economic viability were raised as a concern. It was believed by attendees that windfarm developments were only economically viable due to Government subsidies and that wind alone was not a reliable source of energy. It was explained that Scottish Government policy is to have an energy mix and that offshore wind and other renewables have a role to play within this. There was a suggestion that energy in Scotland will get more expensive using renewables whereas other countries may opt for cheaper shale oil. The Government's Low Carbon Economy Strategy was recently published: http://www.scotland.gov.uk/Publications/2010/11/15085756/0.
Consultees considered that a bibliography would be helpful. The SEA, HRA and socio-economic assessments will each have bibliographies.
Coverage of views within the Consultation Analysis Report
The community attendees were asked if they considered their views had been captured in the Consultation Analysis report. They were asked to provide points they believed were missed or wanted re-emphasised. These have been condensed and bulleted below:
- The natural beauty of the area and its economic benefits should be emphasised.
- The Solway has a history of cross border co-operation - this should be recognised.
- The Plan should take into account changes and the future baseline, to reflect changes to the population and the economy over the long term.
- The study should look at decommissioning aspects, to reflect people's doubt that wind power will prove economic returns.
- Attendees asked why there was not a comparable impetus to install offshore wind power in Ireland or Norway.
- Robin Rigg connects to the grid in to England - people assumed that other sites will do the same.
- Offshore wind is not suited to the Solway.
- The consultation process appears to have been rushed - people would have been able to engage more effectively had they had prior sight of information. There is a need for timescales to be provided for the plan and licensing processes, so that the community know when they can engage effectively.
- Funds should be made available to assist communities to respond to these types of consultations.
- Humans should be given the same consideration as 'biodiversity'
- Several attendees raised key points on data. Gaps in navigation data were raised, as AIS data does not enough to cover small vessels. This point applies across Scotland. Lack of information on the output and life cycle of working turbines.
- Attendees reiterated their view that the process should wait until lessons have been learned from Robin Rigg.
- It was suggested that The Crown Estate Commissioners and developers should be required to attend consultation events.