Orkney Islands Regional Marine Plan: Consultation and Modifications Report

5. Modifications

5.1. Overview

This section of the report sets out statements of modifications that have been made to the proposals as published in the consultation draft of the Plan. A summary of the key modifications is provided at 5.1.2 and the modifications made to the Plan are identified 5.1.3.

5.2. Summary of modifications

Summary of key modifications to the consultation draft Plan following the public consultation:

• A greater emphasis has been placed on promoting and supporting sustainable development.
• The Plan has been updated to clarify that the Plan does not include policies that directly aim to address the management of fisheries.
• A vision period has been included to 2045.
• The aim of the Plan has been updated to include reference to the twin climate and nature crises.
• Further detail has been provided to help deliver sustainable development including using sound science responsibly, effective community engagement and valuing local knowledge.
• The Plan has been updated to clarify how the policies should be used by public authority decision makers.
• A new objective has been added; Objective 10: Local communities are effectively engaged in decisions affecting the Orkney Islands marine region.

The Plan has been updated to better align with relevant policies and strategies including:

• Scotland’s Blue Economy Vision
• The National Plan for Scotland's Islands.
• Scotland's National Strategy for Economic Transformation.
• Scottish National Adaptation Plan 2024-2029.
• Scottish Biodiversity Strategy to 2045 and supporting Delivery Plan 2024 to 2030.
• Just transition policy actions.
• Wellbeing Economy Governments (WEGo).
• Vision for Sustainable Aquaculture.
• Marine Tourism: Giant Strides 2020-25.
• Marine environment: unexploded ordnance (UXO) clearance Joint Position Statement.

Further guidance has been identified to support the implementation of specific policies:

• Orkney Islands Marine Region: Supporting sustainable social and economic benefits guidance (to support General Policy 4).
• Orkney Islands Marine Region: Amenity, wellbeing and quality of life guidance (to support General Policy 14).

General Policy 1: Sustainable development, activities and use has been modified to promote effective engagement with local communities and to make provision for local knowledge to inform the design and assessment of development proposals.

The Plan has been modified to align with Orkney Partnership’s target outcomes for sustainable development including support for community wealth building.

The Plan has been modified to align with the Orkney Partnership’s net zero vision.

The Plan has been modified to include reference to the Marine Spatial Planning Addressing Climate Effects (MSPACE) programme. The Orkney Islands Regional Marine Plan is a case study within this programme which is designed to drive forward the implementation of climate-smart marine spatial planning in the UK.

Reference to the OIC Coastal Change Adaptation Plan has been added to the Plan to support integration between the marine planning and coastal adaptation processes.

A policy provision to support the assessment of potential impacts on non-designated historic environment assets has been included in General Policy 8: Historic Environment.

The Plan has been modified to acknowledge the transformative social and economic benefits offshore renewable energy and harbour developments can deliver for island communities, as well as the need to manage potential adverse onshore impacts on infrastructure and services.

General Policy 1b: Sustainable development principles has been modified to state that impacts on existing infrastructure and services should be addressed as opposed to resolved as part of the consenting process.

General Policy 4: Supporting sustainable social and economic benefits amended to state that opportunities have been considered to maximise the identified socio-economic benefits in the policy.

General Policy 5: Safeguarding natural capital and ecosystem services has been modified to remove reference to ‘disturbance and degradation’ and these terms have been replaced with ‘avoid, minimise and/or mitigate’ in relation to the consideration of impacts on natural capital and ecosystem services.

General Policy 5: Safeguarding natural capital and ecosystem services has been modified to state that it will be implemented by decision makers, ‘where appropriate’.

General Policy 9b modified to replace ‘biodiversity enhancement’ with ‘marine enhancement’ to create scope for broader environmental enhancement to be delivered.

General Policy 9 has been modified to specify the use of best practice methods for proposals to enhance and/or restore the coastal and/or marine environment.

General Policy 9d has been modified to align with the National Marine Plan and to state that proposals for development and/or activities should have regard to the relevant policy provisions in the National Marine Plan regarding Priority Marine Features.

General Policy 11 modified to replace policy provision for Priority Marine Features with policy provisions for European Protected Species.

Policy context to Sector Policy 1: Commercial Fishing modified to acknowledge the contribution of commercial fishing to food security and quality of life for fishers, and that fishing is culturally and historically significant to Orkney communities.

Policy context to Sector Policy 1: Commercial Fishing modified to reflect the up-to-date position with fisheries management in Scotland.

Sector Policy 1: Commercial Fishing modified to provide a standalone policy strand on the consideration of impacts on the cultural importance of fishing in local communities.

Policy context to Sector Policy 2: Aquaculture modified to acknowledge that finfish and shellfish farming make an important contribution towards food production and food security.

Sector Policy 2 modified to state that proposals for development and/or activities should avoid, minimise and/or appropriately mitigate significant adverse impacts on active aquaculture sites.

Additional supporting text has been added to Sector Policy 5: Offshore wind, wave and tidal energy generation stating that the European Marine Energy Centre (EMEC) is investigating and examining options for a national floating wind test centre located to the west of Orkney.

The Plan has been modified to clarify that the OIC Islands Archaeologist can advise on matters affecting Orkney’s historic environment assets and places.

The plan has been modified to state that General Policy 14: Amenity, wellbeing and quality of life of local communities supports a place-based approach to planning, development and community engagement.

Text added to context section to Sector Policy 1: Commercial fishing on the National Fisheries Management Strategy 2020, alongside reference to Inshore Fisheries Management Improvement (IFMI) Programme.

Text added to context section to Sector Policy 3: Shipping, ports, harbours and ferries to improve alignment with National Transport Strategy 2.

Policy context to Sector Policy 3: Shipping, ports, harbours and ferries modified to acknowledge that the Orkney Harbour Masterplan Phase 1 identifies development proposals for a new pier infrastructure at Hatston and a new deep water quay facility at Deepdale, Scapa Flow, which are national developments identified in NPF4.

Sector Policy 4: Pipeline, electricity and telecommunications infrastructure and Sector Policy 6: Zero fossil carbon fuels, and oil and gas transition have been modified to clarify that these policies only apply to public authority decision making that falls under devolved competencies.

Marine cables and pipelines added as a consideration under ‘other marine users’ in Sector Policy 3: Shipping, ports, harbours and ferries and Sector Policy 7: Safeguarding tourism, recreation, leisure and sport uses.

Sector Policy 7b: Safeguarding tourism, recreation, leisure and sport uses modified to state that proposals for development and/or activities should consider options to avoid, minimise or appropriately mitigate significant adverse impacts on tourism, recreation, leisure and sport uses.

5.3. Modifications to the consultation draft plan

5.3.1. Overview

Modifications made to the consultation draft Plan are identified in Table 2. The Plan paragraph references have been updated through the Plan modification process. The paragraph numbers identified in Table 2 are those in the Orkney Islands Regional Marine Plan (finalised Plan). Where these paragraph references are different to those in the consultation draft Plan, reference to the relevant section or paragraph in the consultation draft Plan is provided.

5.3.2. Modifications

Modification to Foreword

Updated Foreword in the finalised Plan. Updated post consultation to reflect the up-to-date position.

Modification to Executive Summary

Updated Executive Summary in the finalised Regional Marine Plan. Updated post consultation to reflect the content of the finalised Plan.

Modifications to Section 1: Introduction

1. Cross reference to Map 1 added to paragraph 1.1. Modified for clarity.

2. Paragraph 1.4 modified to remove unnecessary detail on governance and to remove repetition. Modified for clarity and conciseness.

3. Paragraph 1.6, 1.7, 1.8 and 1.10 modified to clarify how the plan and its policies should be used in decision making. (Consultation Draft reference: paragraph 1.15, 1.16, 1.17 and 1.18). Modified for clarity and to support plan implementation.

4. A new paragraph added at 1.8 to clarify that the Plan has been prepared without policies that directly aim to address further management of fisheries. Modified for clarity.

5. Paragraph 1.11 amended to clarify the role of Orkney Islands Council, as the delegate, as a consultee on marine licensing. (Consultation Draft reference: text added after paragraph 1.8). Modified for clarity and to support plan implementation.

6. Paragraph 1.11 added regarding the provisions of the Marine Licensing (Consultees) (Scotland) Order 2011. Modified to acknowledge the statutory role of OIC.

7. Reference to devolved competencies added to Table 1. Modified to clarify that the plan only applies to developed competencies.

8. ‘Impacts or effects from development and activities’ section removed from Section 2 and 3 and added to Section 1, paragraph 1.18 to 1.23. (Consultation Draft reference: paragraphs 2.11 to 2.16 and 3.11 to 3.16). Modified to remove repetition of text.

9. Paragraph 1.18 modified to remove the term ‘long distances’. (Consultation Draft reference: paragraph 2.11). Modified for greater accuracy.

10. Paragraph 1.18 word ‘deposited’ replaced with ‘settling’. (Consultation Draft reference: paragraph 2.11). Deposit is a specific term used in marine licencing. Replaced with a word of equivalent meaning to avoid misinterpretation.

11. Paragraph 1.19: Plan modified to include ‘economic receptors and infrastructure’. (Consultation Draft reference: paragraph 2.12). Modified to highlight the potential for economic and infrastructure related cumulative impacts.

12. Paragraph 1.22 has been updated to provide further detail on avoiding sites with potential to have adverse impacts. (Consultation Draft reference: paragraph 2.15). Modified for clarity and to support appropriate implementation of the plan policies.

13. Paragraph 1.26 amended to include vision period to 2045. (Consultation Draft reference: paragraph 1.17). Modified to align with the vision period for NPF4 and wider relevant plans and strategies.

14. ‘Human activities’ replaced with ‘the marine environment’ in Table 2, B. Modified to ensure the consistent application of the definitions in Table 1.

15. ‘and/or activities’ inserted in Table 2, E. Modified for clarity and consistency.

16. Paragraph 1.28 amended to identify that Orkney Islands Marine Region: State of the Environment Assessment includes the identification of relevant data gaps. (Consultation Draft reference: paragraph 1.19). Modified for clarity and accuracy.

17. Text inserted at Paragraph 1.29 to refer plan users to National Marine Plan interactive hyperlinks/smart URL in the maps and direct to Appendix 3 to access hyperlinks directly. (Consultation Draft reference: paragraph 1.20). Modified to improve access to the finalised Plan’s online spatial information.

18. Paragraph 1.31 reworded to include reference to all relevant available data alongside the NMPi. (Consultation Draft reference: paragraph 1.22). Modified to include reference to wider relevant data.

19. Text stating that ‘Information on how to use NMPi is provided in Appendix 3’ moved from paragraph 1.31 to paragraph 1.29. (Consultation Draft reference: paragraph 1.22 and 1.20). Modified for clarity.

20. Aim of the Plan in Table 2 updated to refer to tackling the twin climate and nature crises. Modified to better align the aim of the plan with the policy provisions, and wider relevant plans and strategies.

21. Reference to ‘environmental limits’ removed from Guiding Principle A and replace with ‘protecting the environment’. Modified to enable unambiguous interpretation and implementation of the finalised Plan.

22. Guiding Principle B and the aim of the Plan updated to refer to the climate and nature crises. Modified for clarity and to set the appropriate context for the more detailed objectives and policies.

23. Objective 1 updated to refer to sustainable development, activities and use. Modified to better align with the aim of the plan and policy term definitions.

24. A new objective has been added; Objective 10: Local communities are effectively engaged in decisions affecting the Orkney Islands marine region. Modified to better reflect the priorities of local communities identified via the Plan consultation.

Modifications to Section 2: General Policies

1. Paragraphs 2.3 and 3.4 added to clarify the role of the general policies in supporting applicants preparing proposals for development and activities. Modified for clarity.

2. Paragraphs 2.3 and 3.4 from the consultation draft Plan have been removed and included in Section 1. Modified to remove duplicated text from the Plan.

3. Paragraph 2.8 amended to state see Section 1 for details on the use of spatial information and data. Modified for clarity.

4. Paragraph 2.9 and 3.10 amended to remove unnecessary detail. (Consultation Draft reference: Paragraph 2.9 and 3.9). Modified for clarity and brevity.

5. Reference to ‘environmental limits’ removed from paragraph 2.11. (Consultation Draft reference: paragraph 2.17). Modified to enable unambiguous interpretation and implementation of the Plan.

6. Paragraph 2.11 and 2.12 updated to emphasise support for sustainable development including a thriving Orkney economy. (Consultation Draft reference: paragraph 2.17 and text added after paragraph 2.17). Modified to emphasise support for sustainable development.

7. Paragraph 2.14 added to align with the Scottish Government Blue Economy Approach. (Consultation Draft reference: text added after paragraph 2.18). Modified to align with Scotland’s Blue Economy Approach.

8. Paragraph 2.13 amended to include reference and supporting weblinks to Scottish Government policy on a just transition, community wealth building and a wellbeing economy. (Consultation Draft reference: paragraph 2.18). Modified to include the relevant policy context for General Policy 1 and wider related policies.

9. Paragraph 2.15 added to explain that offshore developments can have significant impacts on adjacent island communities including infrastructure, community services and facilities. (Consultation Draft reference: text added after 2.18). Modified to provide relevant context to General Policy 1.

10. Paragraph 2.16 added stating that using sound science responsibly, effective community engagement and valuing local knowledge are principles that underpin the approach to sustainable development in the Plan. (Consultation Draft reference: text added after 2.18). Modified to provide clear context for the approach to sustainable development in the Plan and General Policy 1.

11. General Policy 1b ii. added to include policy provision on effective engagement with local communities. Modified to better reflect the priorities of local communities identified via the Plan consultation.

12. The following headings added to General Policy 1b to aid policy understanding by plan users:

• ‘Maximising benefits.
• Effective community engagement.
• Addressing direct/indirect impacts.
• Addressing cumulative impacts.Effective and efficient use of existing infrastructure and services.
• Addressing impacts on existing development and marine users.
• Using sound science and local knowledge’.

These were added to assist plan users to identify the purpose of each policy strand in General Policy 1b.

13. ‘and’ replaced with ’and/or’ in General Policy 1b v. (Consultation Draft reference: GP 1b iv.). Modified for accuracy, and consistency with General Policy 1b vi.

14. ‘resolved’ replaced with ‘addressed’ in General Policy 1b vi. (Consultation Draft reference: GP 1b v.). Modified to acknowledge that it may not be possible to fully resolve all issues regarding impacts on existing infrastructure and services as part of the consenting process i.e. prior to a decision notice being issued. Some issues may need to be resolved post consent.

15. 'alongside relevant local knowledge' added to General Policy 1b viii. (Consultation Draft reference: GP 1b vii.). Modified to recognise the importance and value of local knowledge in decision making.

16. Table 3 amended to identify additional indirect contributions towards the plan objectives and alignment with National Marine Plan policies GEN 2, GEN 3, GEN 18, GEN 19 and GEN 21. Modified to support plan implementation, and the monitoring and evaluation of the plan.

17. NPF4 ‘Policy 12b’ edited to state ‘Policy 12bi’ in Table 3. Modified for greater accuracy.

18. Reference to the owner and operator of the Flotta Oil Terminal removed from paragraph 2.22. (Consultation Draft reference: paragraph 2.24). Modified to future proof the accuracy of the finalised Plan.

19. ‘Policy intent’ for General Policy 3 modified to refer to greenhouse gas emissions. Modified for clarity, and consistency with relevant legal and policy frameworks.

20. Paragraph 2.25, data and reference updated. (Consultation Draft reference: paragraph 2.27). Modified to use UK specific climate data.

21. Additional text inserted at 2.26 to reflect Orkney Partnership vision for a climate resilient and net zero future. (Consultation Draft reference: text added after paragraph 2.27). Modified to reflect the updated local policy context that has emerged since the consultation draft plan was published.

22. Paragraph 2.28 added after paragraph 2.27 to provide further information on just transition. Modified to align with the Orkney Partnership's vision on net zero and a just transition where the economy, communities and natural environment all prosper and benefit, building their resilience, and adapting to the changing climate.

23. Paragraph 2.27 amended to refer to zero fossil carbon fuels. (Consultation Draft reference: paragraph 2.28). Modified to recognise the potential contribution of e-fuels to decarbonisation.

24. Paragraph 2.30 amended to refer to e-fuels. (Consultation Draft reference: paragraph 2.31). Modified to recognise the potential contribution of e-fuels to decarbonisation.

25. Paragraph 2.27 amended to refer to greenhouse gas reduction measures and the Scottish National Adaptation Plan 2024-2029. (Consultation Draft reference: paragraph 2.28). Modified to better align with General Policy 3 and to reflect the up-to-date policy context.

26. Paragraph 2.28 updated regarding alignment with National Planning Framework 4 (NPF4) and National Marine Plan (Consultation Draft reference: paragraph 2.29). Modified to provide the relevant national policy context to General Policy 3a Climate Crisis.

27. Paragraph 2.29 amended regarding reference to blue carbon. (Consultation Draft reference: paragraph 2.30). Modified to ensure that the potential contribution of blue carbon to climate mitigation is not over emphasised in the finalised Plan when compared to other examples of mitigation.

28. General Policy 3c iii. amended to refer to ‘nature-based solutions’. Modified to align with terminology in NPF4.

29. ‘adequate' and ‘including appropriate nature-based measures’ deleted from General Policy 3c ii. Modified to remove ambiguity and improve clarity.

30. Reference to Marine Spatial Planning Addressing Climate Effects (MSPACE) programme added at paragraph 2.36. (Consultation Draft reference: paragraph added after 2.36). Modified to acknowledge the role of the Orkney Islands Regional Marine Plan as a case study within the MSPACE project.

31. Paragraph 2.37 text amended to state social as well as economic opportunities and to refer to sustainable economic development and the role of marine planning in delivering this. Modified to better reflect the approach to sustainable development that underpins the plan aim and objectives.

32. Text amended at paragraph 2.38 to provide appropriate context for General Policy 4. Modified to improve description of the purpose and context for General Policy 4.

33. Paragraph 2.38 amended to include reference to upstream and downstream businesses. Modified for clarity.

34. Text inserted at paragraph 2.39 on community wealth building and the Orkney Partnership’s target outcomes for sustainable development include supporting community wealth building. And updated to include the principles of community wealth building in the Orkney context. Modified to improve alignment with NPF4 and Orkney Partnership targets.

35. General Policy 4a (i. ii. and iii.) modified to state that ‘opportunities have been considered’. Modified to align with the current Scottish Government policy position.

36. General Policy 4a ii. amended to refer to skills development. Modified to acknowledge the importance of addressing skills development to enable local people to access new job opportunities, and where relevant, assist in the delivery of a just transition to net zero.

37. General Policy 4a iii. amended to better align with the definition of key policy terms in Table 1. Modified to improve clarity for decision makers when implementing this policy.

38. General Policy 4a iv. amended to remove the term ‘net’. Modified to support clearer policy interpretation.

39. General Policy 4c added to make provision for guidance to support the implementation of General Policy 4. The consultation highlighted that guidance would be beneficial to support the implementation of General Policy 4. Supporting guidance will be developed post adoption of the Plan.

40. Paragraph 2.40 updated to refer to current as well as future generations. Modified to acknowledge the importance of considering current generations.

41. Locally relevant habitats added to paragraph 2.42. Modified for clarity, accuracy and local relevance.

42. General Policy 5 modified to remove reference to disturbance and degradation and these terms have been replaced with ‘avoid, minimise and/or mitigate’ in relation to the consideration of impacts on natural capital and ecosystem services. There is no clear definition for disturbance or thresholds available to be implemented in this context.

43. General Policy 5 i. modified to add ‘where appropriate’. Modified to make clear that there is discretion to the decision maker to decide when it is appropriate to apply this policy.

44. General Policy 5 ii. ‘coastal and/or marine’ added. Modified for clarity and accuracy.

45. Table 7 amended to identify additional indirect contributions towards the plan objectives. Modified to support plan implementation, and the monitoring and evaluation of the plan.

46. Paragraph 2.47 amended to include the Scotland River Basin District (Status) Directions 2024. Modified to include reference to up-to-date regulations.

47. Paragraph 2.48 updated to all water environment types covered by the Directions. Modified for clarity.

48. General Policy 6 ii. wording amended to aid understanding and interpretation. Modified for clarity.

49. Table 8 amended to identify additional contributions towards the plan objectives. Modified to support plan implementation, and the monitoring and evaluation of the plan.

50. Date added to Map 3. Modified for clarity.

51. Text added to paragraph 2.54 to acknowledge that a changing climate affects the rate of coastal change. (Consultation Draft reference: paragraph 2.53). Modified for clarity.

52. Text added at paragraph 2.56 on the emerging Orkney Coastal Change Adaptation Plan. Modified to reflect the up-to-date planning/policy context.

53. General Policy 7b ii. amended to improve clarity of interpretation. Modified for clarity.

54. Proposed Scapa Flow Historic Marine Protected Area replaced with Scapa Flow Historic Marine Protected Area in paragraph 2.58. (Consultation Draft reference: paragraph 2.56). Modified to acknowledge site designation in August 2025.

55. ‘Canmore’ replaced with ‘Trove.scot’ in paragraph 2.60. (Consultation Draft reference: paragraph 2.58). Canmore has been replaced with Trove.scot.

56. Historic environment assets’ replaced with ‘Historic assets and places’ in paragraph 2.60. (Consultation Draft reference: paragraph 2.58). Modified for compatibility with NPF4.

57. ‘Many historic environment assets’ replaced with ‘Many historic assets and places’ in paragraph 2.61. (Consultation Draft reference: paragraph 2.59). Modified for compatibility with NPF4.

58. Reference to Historic Environment Scotland (HES) practical guidance on conserving underwater heritage added to paragraph 2.61. (Consultation Draft reference: paragraph 2.59). Modified to include up to date relevant guidance in the Plan.

59. Reference to early engagement with HES and the Orkney Islands Council Islands Archaeologist included in paragraph 2.62. (Consultation Draft reference: paragraph 2.60). Modified to support policy implementation and assist applicants.

60. Modification made to paragraph 2.62 to state that the OIC Islands Archaeologist can advise on matters affecting Orkney’s historic environment assets. (Consultation Draft reference: paragraph 2.60). HES has changed their procedures to only comment on matters affecting the historic environment assets of national significance. The Islands Archaeologist can advise on other relevant matters.

61. The title of General Policy 8a changed to ‘Historic assets and places’. Modified for compatibility with NPF4.

62. ‘place’ replaced with ‘places’ in General Policy 8a(i). Modified for compatibility with NPF4.

63. Modification made to General Policy 8a i., ‘*Where relevant, for EIA development and/or activities refer to: HES, Environmental Impact Assessment Handbook’. Modified for clarity.

64. Reference in General Policy 8a iii. updated to ‘The Crown Estate: Archaeological Written Schemes of Investigation for Offshore Wind Farm Projects’. Modified to include reference to the up-to-date guidance.

65. General Policy 8j added to include policy provisions for non-designated historic environment assets. Modified to provide clarity on how non-designated historic environment assets are assessed and considered in decision making.

66. Reference to Scottish Biodiversity Strategy and Biodiversity Delivery Plan amended at paragraph 2.67 (Consultation Draft reference: paragraph 2.65). Modified to bring the plan up to date with the latest Scottish Biodiversity Strategy and Biodiversity Delivery Plan.

67. Paragraph 2.68 modified. (Consultation Draft reference: paragraph 2.67). To provide the relevant national policy context to General Policy 9a: Climate Crisis.

68. Paragraph 2.69 amended to remove site hierarchy and to reference SiteLink. (Consultation Draft reference: paragraph 2.67). Modified to provide access to the most up to date information.

69. Table 11 title amended to remove the term hierarchy. Modified for accuracy.

70. Paragraph 2.74 updated to state that Priority Marine Features are protected under relevant legislation. (Consultation Draft reference: paragraph 2.72). Modified for clarity.

71. Text added to General Policy 9b i. on the use of best practice assessment and implementation methods. Modified for clarity and consistency with NPF4.

72. General Policy 9b i. modified to replace biodiversity enhancement with the enhancement and/or restoration of the coastal and/or marine environment. Modified to create scope for broader environmental enhancement to be delivered.

73. General Policy 9d ii. modified to state that proposals for development and/or activities should demonstrate that they have considered, where possible, how any significant adverse impacts on Priority Marine Features have been avoided, minimised and/or appropriately mitigated. Modified for clarity and to aid alignment and conformity with the National Marine Plan.

74. General Policy 9d ii. amended to state that proposals for development and/or activities should have regard to the relevant policy provisions in the National Marine Plan. Modified for clarity and to aid alignment and conformity with the National Marine Plan.

75. Paragraph 2.76 modified to remove the phase 'world class'. (Consultation Draft reference: paragraph 2.74). Modified as the term world class has no clear definition.

76. Paragraph 2.79 added regarding the potential impacts of development on landscape and seascape. (Consultation Draft reference: text added after paragraph 2.76). Modified to provide appropriate context to General Policy 10.

77. The title of General Policy 10a changed to ‘Seascape and landscape’. Modified to align with the relevant terminology in National Marine Plan.

78. Map 10 title updated. Modified for accuracy.

79. Reference to Planning Advice Note 1/2011 included at paragraph 2.81. (Consultation Draft reference: paragraph 2.78). Modified to include reference to relevant planning advice.

80. The noise related pressures identified at paragraph 2.82 have been reordered. (Consultation Draft reference: paragraph 2.79). Modified for clarity.

81. Paragraph 2.82 has been amended to refer to pressures as opposed to sectoral activities. (Consultation Draft reference: paragraph 2.79). Modified to refer to pressures as opposed to sectoral activities.

82. The word ‘deterrent’ has been removed from paragraph 2.82. (Consultation Draft reference: paragraph 2.79). Modified for accuracy.

83. Reference to under water noise modelling removed from paragraph 2.84. (Consultation Draft reference: paragraph 2.81) as the reference is not specifically relevant to the policy context.

84. Reference to Marine environment: unexploded ordnance (UxO) clearance Joint Position Statement added to paragraph 2.85. (Consultation Draft reference: paragraph 2.82). Modified to provide reference to the relevant policy statement on UxO clearance.

85. General Policy 11b ii. amended to remove reference to Priority Marine Features (PMFs). A separate policy provision on PMFs is not needed in addition to General Policy 11b i and General Policy 9d.

86. General Policy 11b ii. amended to address European Protected Species (EPS). Modified to make approach provisions for EPS regarding noise impacts.

87. Text added to reference Fishing for Litter project at paragraph 2.88. (Consultation Draft reference: paragraph 2.85). Modified to include reference to this relevant local project.

88. Paragraph 2.92 updated to include up to date reference to the Great Britain Invasive Non-native Species Strategy. (Consultation Draft reference: paragraph 2.89). Modified to reflect the up-to-date policy context.

89. Reference to Orkney Native Wildlife Project added to paragraph 2.95. (Consultation Draft reference: paragraph 2.92). Modified to provide web link to relevant supporting information.

90. Added appropriate reference to the NatureScot Marine Biosecurity Planning Guidance into GP 13 i. Modified to reflect the up-to-date policy context.

91. General Policy 13 iii. amended to refer to the Marine Directorate. Modified to include updated terms.

92. Paragraph 2.96 amended to refer to Orkney Islands Marine Region: Amenity, wellbeing and quality of life guidance. Modified to support implementation of General Policy 14.

93. Paragraph 2.97 amended to state that The Town and Country Planning (Scotland) Act 1997, as amended, identifies outcomes for planning including improving the health and wellbeing of people living in Scotland. (Consultation Draft reference: paragraph 2.94). Modified to set out the relevant statutory context.

94. Paragraph 2.96 and 2.100 amended to state the beneficial effects of sustainable economic development on wellbeing and quality of life. (Consultation Draft reference: paragraphs 2.93 and 2.96). Modified for clarity.

95. New paragraph added at 2.98 provide further detail on the place-based approach to planning, development and community engagement. Consultation Draft reference: text added after paragraph 2.94). Modified for compatibility with NPF4 and to provide appropriate context to General Policy 14.

96. General Policy 14a ii. wording amended to assist with clearer interpretation. Modified for clarity.

97. General Policy 14c title changed to ‘Delivering benefits for places and local communities’. Modified for compatibility with NPF4.

98. Consultation Draft General Policy 14c ii. removed. To remove duplication of 14c i. and the ambiguity of policy requirements. Modified for clarity and to remove duplication.

99. ‘where appropriate’ replaced with ‘where applicable’ in General Policy 14b ii. (Consultation Draft reference: GP 14c iii.) Modified for greater clarity and accuracy.

100. Consultation Draft General Policy 14c iii. moved to General Policy 14b ii in the finalised Plan. Modified to improve the structure and layout of the policy to aid implementation.

101. General Policy 14d added to identify provision for Orkney Islands Marine Region: Amenity, wellbeing and quality of life guidance, where available. Modified to support policy implementation.

102. Table 17 amended to identify a direct contribution to objective 10 and an indirect contribution to objective 4. Modified for clarity and accuracy.

Modifications to Section 3: Sector Policies

1. Paragraph 3.2 amended to refer to sustainable economic development. Modified to better reflect the approach to sustainable development that underpins the plan aim and objectives.

2. Paragraph 3.5 modified to cross reference to section 1 and remove duplication of text from section 1. (Consultation Draft reference: paragraph 3.4). Modified to remove duplication of text.

3. Paragraph 3.10 modified to provide updated context to Appendix 1. (Consultation Draft reference: paragraph 3.9). Modified for clarity.

4. Paragraphs 3.11 to 3.16 in the consultation draft Plan (1.17 to 1.22 in the finalised Plan) moved to section 1. Modified to remove duplication of text.

5. Paragraph 3.12 amended to acknowledge the contribution of commercial fishing to food security. (Consultation Draft reference: paragraph 3.17). To acknowledge the contribution of commercial fishing to food security.

6. Paragraph 3.12 amended to include reference to quality of life. (Consultation Draft reference: paragraph 3.17). Modified to acknowledge the relationship between fishing and quality of life in Orkney communities.

7. Paragraph 3.12 amended to acknowledge that fishing is culturally and historically significant to Orkney communities. (Consultation Draft reference: paragraph 3.17). Modified to acknowledge that fishing is culturally and historically significant to Orkney communities in response to consultation feedback.

8. Paragraph 3.13 amended to acknowledge the role of shoreside processing. (Consultation Draft reference: paragraph 3.17). Modified for clarity.

9. Paragraph 3.15 amended to include reference to the National Fisheries Management Strategy 2020, alongside reference to the Inshore Fisheries Management Improvement (IFMI) Programme. (Consultation Draft reference: paragraph 3.19). Modified to provide the relevant national policy context to Sector Policy 1.

10. Paragraph 3.15 to 3.17 updated to reflect the up-to-date position with fisheries management in Scotland. (Consultation Draft reference: paragraph 3.19 and 3.20). Modified for clarity.

11. The word ‘currently’ added to paragraph 3.17. (Consultation Draft reference: paragraph 3.20). Modified for clarity.

12. Paragraph 3.22 text modified to provide appropriate context to Sector Policy 1iii. (Consultation Draft reference: paragraph 3.25). Modified to improve clarity and support appropriate plan implementation.

13. Sector Policy 1 amended to provide a standalone policy (Sector Policy 1 ii.) for the consideration of the cultural importance of fishing, and amended to remove reference to cultural importance in Sector Policy 1 i. e.. Modified to acknowledge the requirement for specific assessment considerations in relation to cultural importance.

14. Paragraph 3.23 added to refer to finfish and shellfish farming making an important contribution towards food production and food security. (Consultation Draft reference: paragraph 3.26). Modified to acknowledge these wider benefits of sustainable fish farming.

15. Paragraph 3.23 amended to provide an appropriate reference to the Vision for Sustainable Aquaculture. (Consultation Draft reference: paragraph 3.26). Modified to provide reference to the relevant strategic context.

16. Paragraph 3.25 amended to explain that the degree of environmental impact depends on the type, scale, location and mitigation associated with a specific fish farming development or activity. This amendment has also been made to Paragraph 3.37, 3.49 and 3.61 for consistency across the relevant Sector Policies. (Consultation Draft reference: paragraph 3.27 and also 3.39, 3.50 and 3.62). Modified for clarity and consistency.

17. ‘Marine fish farms also require a marine licence’ replaced with ‘Marine fish farms may also require a marine licence’ in paragraph 3.26. (Consultation Draft reference: paragraph 3.28). Modified for greater accuracy.

18. Paragraph 3.26 modified to state ‘an environmental licence (for farm discharges into the water environment)’. (Consultation Draft reference: paragraph 3.28). Modified to reflect the up-to-date regulatory position.

19. Paragraph 3.28 text amended removing reference to the Orkney Islands Marine Region: Finfish Farming Spatial Guidance consultation. (Consultation Draft reference: paragraph 3.30). Modified as this consultation has ended.

20. Paragraph 3.28 amended to state 'potential' sensitivity. (Consultation Draft reference: paragraph 3.30). Modified for accuracy, and consistency with the terminology in the Orkney Islands Marine Region: Finfish Farming Spatial Guidance.

21. Paragraph 3.28 amended to remove ‘and activities’. (Consultation Draft reference: paragraph 3.30). Modified to remove ambiguity over the application of the Spatial Guidance to activities, as defined in the plan in Table 1.

22. Sector Policy 2 vi and vii updated to remove ‘and/or activities’. Modified to remove ambiguity over the application of the Spatial Guidance to activities, as defined in the plan in Table 1.

23. Paragraph 3.33 text amended to state that Appendix 6 provides information on wild seaweed harvesting and reference to the Vision for Sustainable Aquaculture moved to paragraph 3.23. (Consultation Draft reference: paragraph 3.35). Modified for clarity.

24. Sector Policy 2a added to state that proposals for development and/or activities should avoid, minimise and/or appropriately mitigate significant adverse impacts on active aquaculture sites. Modified to provide clarity on how impacts on active aquaculture sites will be addressed in decision making.

25. Sector Policy 2b ii. b., Sector Policy 3d ii. b., Sector Policy 4a iii. b., Sector Policy 5a ii. b., Sector Policy 5b ii. b. and Sector Policy 7a ii. b. modified to state the national status of Priority Marine Features. Modified for conformity with National Marine Plan.

26. Sector Policy 2b ii. g. and 2c ii. f. amended to refer to active aquaculture sites. (Consultation Draft reference: SP 2a ii.g. and SP 2b ii.f.). For clarity and consistency.

27. ‘planning’ inserted to Sector Policy 2b v. (Consultation Draft reference: Sector Policy 2a v). Modified to clarify that this policy may be implemented via a condition on a planning permission.

28. Additional text inserted in paragraph 3.38 and 3.61 to provide information on potential for significant onshore impacts and benefits from harbour and renewable energy developments. (Consultation Draft reference: Text added after paragraphs 3.39 and 3.62). Modified to identify the potential for harbour and renewable energy developments to have significant onshore impacts and benefits for adjacent communities.

29. Paragraph 3.42 modified to include reference to National Transport Strategy 2.(Consultation Draft reference: paragraph 3.43). Modified to improve alignment with National Transport Strategy 2.

30. Paragraph 3.42 updated to remove reference to the John O'Groats to Burwick ferry service. (Consultation Draft reference: paragraph 3.43). Modified as the service is not currently operational.

31. Paragraph 3.43 amended to state that the Orkney Harbour Masterplan identifies development proposals for new pier infrastructure at Hatston and a new deep water quay facility at Deepdale, Scapa Flow, which are national developments identified in NPF4. (Consultation Draft reference: paragraph 3.44). Modified to state the current position with these developments and their status within NPF4.

32. Sector Policy 3d i. added to refer to the Orkney Local Development Plan, National Marine Plan and National Planning Framework. Modified for clarity and consistency across relevant policies.

33. ‘Marine cables and pipelines’ added as an ‘other coastal and marine user’ consideration at Sector Policy 3d ii. g., Sector Policy 5a ii. g., Sector Policy 5b ii. h. and Sector Policy 7a ii. g.. (Consultation Draft reference: SP 3d i. g.). Marine cables and pipelines added as they are a relevant sensitivity/constraint and for consistency across the sector policies.

34. Sector Policy 3d ii. g. amended to refer to ‘active’ aquaculture sites. (Consultation Draft reference: SP 3d i. g.). Modified for clarity

35. Annex B added to Table 20. Amended to recognise the alignment of Sector Policy 3 with the NPF4 Annex B – National Developments Statements of Need.

36. Cables running from Eday to the EMEC test site added to Map 18. Modified for completeness.

37. Text added at paragraph 3.46 clarifies that Sector Policy 4 only applies to public authority decisions where proposals fall within devolved competencies and that offshore oil and gas licensing is reserved to the UK Government including the construction and decommissioning of hydrocarbons pipelines. Modified to ensure conformity with the relevant legal requirements.

38. Paragraph 3.52 modified to state ‘Submarine cables should be appropriately protected, whilst achieving successful seabed user coexistence, in accordance with the National Marine Plan’. (Consultation Draft reference: paragraph 3.51). Modified to provide appropriate alignment with National Marine Plan on cable protection matters.

39. Reference to the United Nations Convention on the Law of the Sea 1982 removed from Paragraph 3.53. (Consultation Draft reference: Paragraph 3.52). Modified as the reference was not directly relevant to the context of Sector Policy 4.

40. Paragraph 3.54 amended regarding the identification of new cables on UK Hydrographic Office charts. Modified for clarity.

41. Sector Policy 4a updated to specify water pipelines. Modified to refer to pipeline development and/activities that are authorised under devolved competences.

42. ‘protection’ added to Sector Policy 4a i. Modified to provide appropriate alignment with National Marine Plan on cable protection matters.

43. Information on National Marine Plan in Sector Policy 4a i. moved to Context at paragraph 3.47. Modified to provide appropriate context to Sector Policy 4.

44. Sector Policy 4a iii. g. modified to refer to active aquaculture sites. Modified for clarity.

45. Sector Policy 4 modified to state that Sector Policy 4 is to be applied to relevant proposals for development and/or activities that require authorisation from a public authority under devolved competencies. Modified to ensure conformity with the relevant legal requirements.

46. Paragraph 3.61 amended to refer to inclusive economic development. (Consultation Draft reference: paragraph 3.60). Modified to better reflect the approach to sustainable development that underpins the plan aim and objectives.

47. Paragraph 3.61 amended to remove reference to the development of skills and supply chain bolstering. (Consultation Draft reference: paragraph 3.60). Modified to ensure that a broader view is taken to a just transition in addition to the considerations of skills and supply chain bolstering.

48. Paragraph 3.70 added to acknowledge that EMEC are investigating and examining options for a national floating wind test centre. Modified to ensure the plan is up to date with local strategic projects.

49. Added reference to Map 10 to 3.71. Modified for clarity.

50. Sector Policy 5a ii. g. and 5b ii. h. amended to refer to ‘active’ aquaculture sites and ‘marine cable routes and pipelines’. Modified for clarity and consistency.

51. Paragraph 3.77 modified to acknowledge the relevance of Sector Policy 6 to devolved competencies only. Modified to ensure conformity with the relevant legal requirements.

52. 3.80 updated to refer to renewable energy generation exceeding demand as well as curtailment. (Consultation Draft reference: paragraph 3.76). Modified for accuracy.

53. Reference to the Flotta Hydrogen Hub removed in paragraph 3.83 and the reference to information about Flotta on the North Sea Transition Authority added to paragraph 3.82 (Consultation Draft reference: paragraph 3.79). Modified to provide up-to-date information.

54. Sector Policy 6 modified to state zero ‘fossil’ carbon fuels in the policy title and policies at i. ii. and iii. Modified to recognise the potential contribution of e-fuels to decarbonisation.

55. Paragraph 3.85 updated to state that ship-to-ship transfer operations are licenced by the Maritime and Coastal Agency (MCA). (Consultation Draft reference: paragraph 3.81). Modified for clarity.

56. Sector Policy 6 amended to specify that it is to be applied to relevant proposals for development and/or activities that require authorisation from a public authority under devolved competencies. Modified to ensure conformity with the relevant legal requirements.

57. Map 21 updated to be titled Recreational Anchorages and Visiting Yacht Moorings. Modified for clarity.

58. Sector Policy 7a i. included to refer to the Orkney Local Development Plan, National Marine Plan and National Planning Framework. Modified for clarity and consistency.

59. Sector Policy 7a ii. g. amended to refer to active aquaculture sites (Consultation Draft reference: SP 7 a ii. g.). Modified for clarity.

60. ‘Marine' removed from Sector Policy 7a ii., 7a iii. and 7a iv. (Consultation Draft reference: Sector Policy 7a i., 7a ii. and 7 a iii.). Modified to reflect that some relevant developments may be coastal and/or intertidal.

61. Should ‘avoid' replaced with should ‘consider options to avoid' in Sector Policy 7b i. Modified to remove a potentially significant restriction on sustainable development.

62. Reference to NPF4 ‘Policy 20’ replaced with ‘Policy 30’. Modified for accuracy.

Modification to Section 4: Monitoring, Evaluation and Review of the Plan

Paragraph 4.1 updated to reflect the statutory requirements for plan review, to ensure conformity with the relevant legal requirements.

Modifications to Appendix 2: Relevant Legislation, Plans Strategies and Policies

1. Additional legislation added to Table 2A to provide the relevant legislative context:

• Delegation of Functions (Regional Marine Plan for the Scottish Marine Region for the Orkney Islands) Direction 2020.
• Wildlife and Countryside Act 1981.
• Invasive Alien Species Regulation 1143/2014.
• The Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017.
• The Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017.
• The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017.

2. Additional plans, strategies and policies added to Table 2A to provide relevant policy context:

• The National Plan for Scotland's Islands
• Scotland's National Strategy for Economic Transformation
• Scottish National Adaptation Plan 2024-2029
• Vision for Sustainable Aquaculture
• Marine Tourism: Giant Strides 2020-25

3. Reference to Bute House Agreement and Orkney Biodiversity Action Plan 2018-22 removed from Table A2 to reflect the current policy context.

Modification to Appendix 3: National Marine Plan interactive

Paragraph A3.3 added to state that maps within this Plan contain hyperlinks to display the specific map data within NMPi where available, and map hyperlinks (smart URLs) added again here. Modified to provide appropriate reference to relevant data on NMPi.

Modification to Appendix 4: Natural Capital and Marine Ecosystem Services

Reference provided to the Nature Capital Assessment for the Orkney Marine Region Area at paragraph 2.42 and A4.6. (Consultation Draft reference: paragraph 2.42 and A4.6). Modified for clarity.

Modifications to Appendix 6: Seaweed Harvesting

1. Appendix 6 title updated to refer to wild seaweed harvesting. Modified for clarity.

2. Paragraph 3.33 updated to include cross reference to Appendix 6. (Consultation Draft reference: paragraph 3.35). Modified for clarity.

Modifications to Appendix 7: Definition of Key Concepts, Acronyms and Glossary

1. Glossary and Key concepts tables merged into Table 4A. Modified for clarity, and to support plan implementation.

2. Co-existence definition updated in Table A4 to align with National Marine Plan 2 Planning Position Statement definition. Modified for consistency with the national approach.

3. Just transition definition amended in Table A4. Modified to align with the Scottish Government definition.

4. Quality of life definition updated in Table 4A. Modified to support policy implementation.

5. Reference to ‘maerl beds’ replaced with ‘seagrass beds’ Table A4. Modified to reflect the current Scottish Government position on blue carbon.

6. Devolved Competence definition added to Table 4A. Modified to support plan implementation.

7. Orkney Islands marine region definition added to Table 4A. Modified to support plan implementation.

Additional Modifications

1. All footnote references updated and added where necessary. Modified to include up-to-date references.

2. Symbology and colours updated in all maps. Modified to improve accessibility.

3. All map data reviewed and updated to ensure that the most recent data sets are used. Map 3, 4, 5, 6, 12, 16, 18, 19, 21 updated with new data. Modified to ensure the plan is up to date at the point of publication.

4. New text added to each map annotation including NMPi smartURL hyperlink. Modified to enable plan users to access map specific data online.

5. Paragraph numbers updated for accuracy.

6. Table of contents numbering updated for accuracy.

7. Tables and Figures tables of content have been updated with the correct page numbers updated for accuracy.