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
31. Sectoral Policy 6: Marine transport
31.1 Summary of responses received
| Stakeholder | Count |
|---|---|
| Commercial | 2 |
| Fisheries and aquaculture | 3 |
| Individual | 1 |
| Non-governmental organisation | 0 |
| Public sector | 4 |
| Recreation | 2 |
| TOTAL | 12 |
31.2 Main themes
31.2.1 Some respondents had some concerns regarding wording within the background text and policy and, in some cases, suggested alternatives. These are noted in the table below.
31.2.2 One public sector respondent noted that the policy did not cover the impacts of marine transport on the environment e.g. mooring and anchoring can have important benthic impacts.
31.2.3 A recreational stakeholder commented that they had more concerns regarding creel users with floating lines but that conflicts with marine traffic were few and far between. They noted that fish farms can sometimes be a problem as can fishing gear across bays. This stakeholder also made the point that the impact of marine renewables is yet to be seen but suspects it will be minor.
31.2.4 Scottish Water noted that their outfalls and undersea pipelines may be vulnerable to damage from trailing anchors and care should be taken not to damage the assets. They strongly believe that existing functional assets and rights to legitimate, licensed activities should be safeguarded.
31.2.5 There were two comments from aquaculture stakeholders regarding non-native species. One queried the assumption that an increase in fish farm traffic would lead to an increase in non-natives and asked whether this was justified when the increase in tanker traffic via the adoption of the Orkney Islands Council ballast water management policy could significantly increase the risk. The second comment noted that yachts, cruise liners and tankers are all vectors for invasive species.
31.2.6 A public sector stakeholder suggested the increase in marine traffic requires to be monitored so as not to lead to congestion or displacement issues.
31.2.7 A fisheries sector stakeholder noted that the Succorfish data will only provide a snap shot of some of the navigational routes. This stakeholder stressed the importance of ports and harbours to fishermen and also the different seasonal patterns of fishing and noted that data collected at a single point in time may miss the complexity of use.
Table 31.1 Sectoral Policy 6 Marine transport - Table of modifications
| No. | Suggested modification | Action taken | Reason |
|---|---|---|---|
| 344 | The wording of SP6 is a different format to other sectoral policies. For conformity it should be in the form of: The Plan will support developments where: etc etc | POLICY TEXT amended to: 'Development and/or activities will be supported by this Plan when it can be demonstrated that: Adverse impacts on existing or planned shipping and ferry routes, navigational safety and access to ports and harbours have been avoided or appropriately mitigated, taking account of movements in all weather conditions. Development proposals which would have an adverse impact on efficient and safe movement of shipping between ports, harbours and other recognised anchorages should be refused'. |
To accommodate request and to provide additional clarity. |
| 345 | Section 441 should include a definition of anchorages as being those marked on Admiralty charts and those listed in the Clyde Cruising Club Sailing Directions and Anchorages N & NE Scotland and Orkney Islands. There are issues related to anchorages that appear in sectoral policies 2, 5, and 6 and some cross referencing might be helpful. | GLOSSARY: Definition of anchorage added 'those anchorages marked on Admiralty charts and those listed in the Clyde Cruising Club Sailing Directions and the Anchorages N & NE Scotland and Orkney Islands'. | To provide additional clarity. |
| 346 | Make text referring to Shipping Study more clear as to why commercial fishing was not included. | PARAGRAPH 440 (now 445): Changed text to 'Commercial fishing (under licence) was excluded from the work as this is covered by the other licensing requirements. | To provide additional clarity. |
| 347 | In examples of marine transport change 'yachts' to 'recreation craft' as this is more inclusive and gets us away from the more common usage of the word yacht which is frequently misrepresented. | INFORMATION BOX 24: 'Yachts' changed to 'recreation craft'. | To accommodate request. |
| 348 | The terminology used in this policy, i.e. "..should be refused...", is distinctly different, and more explicit and definitive, than the text in other policies. It is unclear why there is this different approach to this marine use over others. In addition the terms "efficient" and "unduly compromised" appear significantly open to interpretation. | None. | Different topics and policies may require different approaches depending on the issues considered. This approach is similar to that taken by the National Marine Plan. |
| 349 | Existing and likely future Scottish Water assets, such as sea outfalls, will be located within the geographical scope of the emerging marine spatial plan. The plan must recognise this essential function, make provision of appropriate development of this nature and safeguard against potential uses which could conflict with infrastructure needs or potentially cause damage to our assets. |
Noted. | As highlighted in paragraph 42, detailed mapping of infrastructure (including Scottish Water assets) can be found on NMPi. |
| 350 | On what basis is it assumed that an increase in fish farm traffic would lead to an increased risk of introducing NNS? Is this justified when an increase in Tanker traffic (via the adoption of new OIC ballast water management policy) could lead to significantly increased risk? | PARAGRAPH 443 (now 448): First sentence amended to read 'As development, such as marine tidal devices and shipping, along with a growing aquaculture industry and all other marine traffic, accelerates….'. | Examples clarified and see General Policy 9. |
| 351 | Reword sentence regarding Emergency Towing Vessel provision as there is on-going discussion of this matter. | PARAGRAPH 443 (now 448): Change text to 'This anticipated increase in traffic will require careful consideration of Emergency Towing Vessel provision for the PFOW area'. | To take account of on-going discussions. |
| 352 | We note that the policy wording states in paragraph 2 that developments which have adverse impact are to be refused. Paragraph 3 further states that developments are not to unduly compromise shipping routes. We believe the test of adverse impact in paragraph 2 is too onerous and open to misinterpretation. We request the wording alters for paragraph 2 to state 'where no reasonable alternative exists'. | None. | The text is appropriate. |
| 353 | Paragraph 2 captures an economic and navigational safety issue in a single policy statement. These are separate issues and should be captured in separate policy wording. A proposed development may have economic impacts but the overall benefit outweighs these. A development with unacceptable navigational safety impacts should not proceed. | None | The text is appropriate. |
| 354 | We suggest that paragraph 3 is vague - it does not add anything further already captured in other wording of the policy. | None. | Elements of the text are a direct result of stakeholder requests at the Planning Issues and Options Paper stage. |
| 355 | Para. 442 it should be noted that fishing vessels have a right to safe navigation and this includes transit journeys and journeys to and within fishing grounds setting gear and moving gear. | None. | Text is sufficient as it states '…all vessels have the rights of innocent passage and freedom of navigation…' |
| 356 | Para 443 This section doesn't cover the impacts of marine transport on the environment. Mooring and anchoring can have important benthic impacts but that doesn't appear to be covered here. | PARAGRAPH 443 (now 448): Added after second sentence 'In addition, anchoring can have important benthic impacts'. | To accommodate request. These issues are also covered in the Environmental Report. Mooring is generally in relation to attachment to land via a pier therefore would not have benthic impacts. |
| 357 | This section should highlight the importance of emergency tugs to the area. | PARAGRAPH 443 (now 448): New sentence added 'This anticipated increase in marine traffic adds to the case to retain the existing Emergency Towing Vessel provision for the north of Scotland'. | To accommodate request. |
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