Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Consultation Analysis and Modifications Report.

The Pentland Firth and Orkney Waters Marine Spatial Plan is a pilot process undertaken by a working group consisting of Marine Scotland, Orkney Islands Council and Highland Council in advance of statutory regional marine planning. This report presents an


21. General Policy 7: Integrated coastal and marine development

21.1 Summary of responses received

Stakeholder Count
Commercial 3
Fisheries and aquaculture 2
Individual 1
Non-governmental organisation 0
Public sector 3
Recreation 2
TOTAL 11

21.2 Main themes

21.2.1 The policy was generally welcomed by respondents but some felt there should be changes or additional text added.

21.2.2 There were some comments in relation to the reference to a single Environmental Impact Assessment ( EIA) with one respondent suggesting a single EIA should always be carried out for marine and terrestrial components of a development project that are inextricably linked to the main works and suggested that the phrase 'where appropriate' should be removed. Another respondent disagreed with the term 'inextricably' and noted it was unreasonable and not supported in precedent to require a developer to submit a single EIA where e.g. parts of the supporting infrastructure are not being developed by them but are separate projects in their own right and which in many cases will be developed by a separate entity ( e.g. grid connections).

21.2.3 Another public sector respondent noted the policy should include consideration of indirect impact of terrestrial developments on marine ecosystems. This respondent felt there should be a more strategic approach to identifying cable landing issues and land based support infrastructure for renewables.

21.2.4 Other points raised included the need for the licensing and consenting authorities to consult one another at an early stage in order to streamline the process and enable projects to meet their planned timeframes.

21.2.5 Two aquaculture stakeholders raised a similar issue and felt the policy should go further and emphasise the importance of 'consenting authorities' to ensure they have sufficient resources in place to facilitate pre-application engagement and to deal with development proposals efficiently and effectively. A different fisheries stakeholder noted the importance of fishing harbours as access to their working environment.

21.2.6 One stakeholder queried the value of Map 12 as the information contained within it does not show up well.

21.2.7 A recreation stakeholder noted there were many complex inter-related issues to be considered e.g. development of harbours to support high fee paying industry may reduce amenity for locals.

21.2.8 Another response queried whether users are 'relevant stakeholders' and, if so, why fish farm applications 'always miss out the users'?. The stakeholder expressed his view that this had only happened since planning permission was transferred to the Local Authority.

Table 21.1 General Policy 7 Integrated coastal and marine development - Table of modifications suggested

No. Suggested modification Action taken Reason
204 Clarify text in relation to when there is a need for a single EIA. Suggestion to delete the wording 'where appropriate'. POLICY TEXT: Deleted 'Where appropriate, a single EIA should be carried out for marine and terrestrial components of a development project that are inextricably linked to the main works'. Point adequately addressed in paragraph 270 (now 269).
205 Add text to take account of indirect impacts of terrestrial developments on marine ecosystems. None. Issue addressed on General Policies 1A and 1C.
206 A more strategic approach to identifying cable landing issues and land based infrastructure for renewables is needed. None. This issue is addressed in the context of the associated local development plan and supplementary guidance.
207 Para. 264 - Consider substituting fish farming for 'aquaculture' (see comments above). Typo. "extend" should be "extends". None. Within this context the terminology 'aquaculture' is appropriate.
208 Para. 267 - The duty to have regard to the UK Marine Statement and Marine Plans extends to all functions of public bodies, not just planning functions. None. Paragraph 267 (now 266) is clear in this regard.
209 Para. 271 - Now Planning Circular 1/2015. PARAGRAPH 271 (now 270): Text replaced with 'Planning Circular 1/2015 The Relationship Between the Statutory Land Use Planning System and Marine Planning and Licensing, sets out further guidance '.
PARAGRAPH 271 (now 270): Planning Circular 1/2015 reference and weblink has been updated to http://www.gov.scot/Publications/2015/06/5851/downloads.
Updated to reflect the current status of the Circular.
To updated weblink to the latest Circular.
210 Para. 272 - Typo. "with the Plan area." PARAGRAPH 272 (now 271): The final sentence has been amended to read 'within the Plan area'. To correct a typographical error.
211 Para. 273 and Para 275 - Delete "together". PARAGRAPH 273 (now 272) and 275 (now 274): The word 'together' has been deleted. To accommodate the requested change.
212 Policy could go further and emphasise the importance of 'consenting authorities', ensuring they have sufficient resources to facilitate an efficient process. None. The resources available to the various consenting authorities are out with the remit of the Plan.
213 Consider using the 'Protocol for Preparing Planning Applications for Aquaculture Development' which is referred to in Circular 1/2015. As a model of best practice in this area, it is suggested this should feature in an "Information Box" in the final Plan. None. General Policy 7 is not an aquaculture specific policy.

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