12.1.1 Provided that the initial plan-level mitigation (i.e. project-level HRAs and the IPR) and a temporal moratorium on windfarm development within E3 and NE2-6 is applied, it is concluded that the Sectoral Offshore Wind Plan will not lead to an AEOI either alone or in-combination with other plans or projects. In order for these areas to be released for development, a number of knowledge gaps, discussed in Section 11 above will require addressing.
12.1.2 Successful bidders for future lease options will need to re-visit the issues identified within the plan-level HRA; ensuring that they adhere to relevant project-level mitigation measures where necessary to avoid an AEOI.
12.1.3 Developments at some DPOs are likely to pose a greater risk of impact on European/Ramsar sites and features than at other DPOs. Therefore, development at some DPOs will present greater challenges and require more mitigation (at possibly a greater cost) than at others, in order to ensure no AEOI. Similarly, development within some areas of a given DPO will be less likely to result in a significant effect than other areas within the same DPO. Spatial planning at a project level will allow developers to avoid sensitive features and thereby reduce consenting risk.
12.1.4 There is a considerable amount of ongoing strategic research which will help to reduce uncertainty on the predicted impacts of windfarms through the provision of robust evidence. Concurrent to the research, empirical data is being generated through large scale monitoring programmes, such as the coordinated surveys being proposed by the commercial windfarm developers for Inch Cape, Neart na Gaoithe and Seagreen in the Forth and Tay regions.
12.1.5 The conclusions of these studies will be acknowledged within future iterations of the Draft Plan through the IPR process. Hence, as the Draft Plan evolves, the required mitigation (see Section 11) may also change. If, for example, sufficient evidence becomes available to conclude that the in-combination effects from windfarm development at either E3, NE2, NE3, NE4, NE5 or NE6 will not lead to an AEOI, then the conclusions of the Draft Plan will change accordingly. Conversely, new evidence may indicate that additional steps and measures are taken to avoid AEOI, in which case, the recommendations within the Draft Plan will be adapted following the outcomes of Advisory Group meetings. Such recommendations may include:
- Avoidance of certain areas;
- Technology preferences; and
- Further strategic research.
12.1.6 The mitigation requirements will also change during the iterative process, ensuring that project-level measures are reasonable and effective to avoid or reduce effects on an interest feature. These changes will be acknowledged within the Draft Plan, allowing developers to remain abreast of the most recent and applicable evidence.
12.1.7 It is recognised that as the Draft Plan evolves, some of the inherent uncertainties of early iterations will diminish as a greater understanding is developed (see Section 11). For example, the potential exists for the cable alignments and landfall positions, once identified, of almost all DPOs to directly or indirectly affect European/Ramsar sites. There was no presumption within this plan-level HRA that European/Ramsar sites will not or cannot be directly or indirectly affected in this manner although clearly the risks of impact and requirements for mitigation are likely to be greater where this is the case. However, it is expected that developers will, in the first instance, seek to avoid European/Ramsar sites (as noted above) and address any residual risks associated with cable installation at a project level.
12.1.8 A key assumption of this plan-level HRA is that there is scope for development within the DPOs which avoids AEOI. Therefore, at a high-level there should be certainty that should development occur within a DPO it will not lead to an AEOI. In most cases this level of certainty is not possible without the intervention of project-level HRA; however, it is concluded that any windfarm development in DPOs E3 and NE2-5, could result in an AEOI based on current scientific evidence, with development at NE6 also having the potential to result in an AEOI.
12.1.9 There will be a statutory requirement for future project-level HRAs to accompany any development resulting from the Draft Plan. These HRAs will take account of project level detailed considerations and the content of the plan-level HRA, allowing the planning of windfarms and their cable routes to occur in a manner that does not lead to an AEOI. However, through this high-level assessment, recommendations have been made which will guide regulators and developers to reduce the likelihood of AEOI through the implementation of the Sectoral Offshore Wind Plan.
12.1.10 This document represents Stage 10 of the HRA process – the draft record of the HRA. The final Stages (11-13) will follow consultation and amendments to the document.