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

The ones shown in the table make eminent sense to me, and I am not qualified to comment on the extent and scale of the interactions identified

Noted.

I would simply say again that another category i.e. Seaweed Industry should be included, given its potential scale and economic impact, and the interactions arising worked out - probably similar to those of Aquaculture and Commercial Fisheries, but with some notable differences, and also depending on the exact nature of any industry that would develop

AP219: The Scottish Government is, at the time of writing, developing draft seaweed policy which will help inform the Draft Plan.

AP220: Seaweed will be considered under the aquaculture sector of the Draft Plan.

The spatial plan needs to consider all aspects of current users and new users in an integrated manner. There will likely always be an impact between sectors and local residents and necessary compromises need to be understood and agreed. Such a system needs to be dynamic as environmental knowledge, technology, economics and demand will continuously change.

This is a key challenge of drafting the Plan, hence our strive to ensure all sectors and stakeholders are involved in the process.

Biodiversity and Natural Heritage:

Intermediate to low interaction.

It would be useful to note in the pilot plan that the impacts on marine biodiversity vary between gear types ( e.g. creeling is very low-impact). Maintaining biodiversity will help ensure a productive and sustainable fishery

AP221: The Working Group will discuss with local fisheries stakeholders to ensure the main types of fishing gear are considered.

Climate Change

Intermediate interaction

Possible changes in the abundance of commercial stocks. Possibility of increased fishing effort in more sheltered inshore areas as a result of frequent extreme weather events.

The pilot plan should recognise that fishermen require spatial flexibility to be able to respond to the effects of climate change on their stocks. The pilot plan should identify appropriate mitigation measures for responding to increased fishing pressure in inshore waters, both for the fishery itself and other sectors.

The Draft Plan is not adopting a strict zoning approach to allow flexibility but stock management is beyond the scope of the Plan. However, we would welcome further input from fishermen to ensure their interests are represented. Climate change has the potential to change the species mix e.g. introduce invasive species that were previously unsupported in the PFOW area, potentially resulting in major effects.

Cultural Heritage and Historic Environment:

Minor interaction to no interaction.

Fisheries are and important part of Orkney's cultural heritage and the pilot plan should bring awareness to this fact. Links to positive cultural identity enhance 'well-being'.

As fisheries are important part of Orkney's cultural heritage, as well as the north coasts of Caithness and Sutherland's within the Draft Plan area, there is a significant intermediate effect. Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. The cultural aspects will be added to the quality of life/well being policy sector.

Water and Marine environment

As with biodiversity and natural heritage.

Noted.

Marine Renewables:

Major interaction

Potential impacts on fish and shellfish ecology (from habitat removal, noise, EMF and potential risks of collision). Potential for displacement of fishing effort to other areas with knock-on implications for sustainability of stocks. Restriction of movement for fishing vessels due to implementation of exclusion zones. Recommend the plan ensures development is steered away from fishing grounds, especially spawning and nursery grounds and any habitat e.g. maerl, that supports immature commercial stocks.

AP222: Additional text in the Draft Plan will explore these effects.

Noted. Any additional site specific data the OFA can supply will be most welcome. Given a number of sites are in various development stage for renewable energy, there may be potential for these to also act as additional nursery grounds e.g. wave development sites.

Aquaculture

Major interaction

Organic enrichment (from waste feed, faecal matter, chemical pollutants) causing anoxia, algal blooms, changes in sediment quality and benthic species composition. Effects can spread to as far as 1.2km from salmon cages (Milewski,2001) depending on intensity and direction of currents. Effects on local fishery potentially profound, especially if salmon farms are located close to important spawning grounds and habitat (eg maerl beds) for commercially important species such as king scallop (Pectin Maximus). Displacement of divers and creelers from prime fishing grounds is a serious concern with regard to aquaculture developments. The pilot plan should address this conflict by conferring a priority to fisheries when a negative interaction between the two sectors is likely to occur.

The Scottish Government have target to increase production by 32% by 2020, based on 2011 baseline (159,269 tonnes). In addition, much research has been undertaken on the impacts of aquaculture. With regard to effects of chemotheraputents, this is regulated by SEPA, whilst the farmed fish health is governed by MS and local authority planning permission is required for the site equipment. Where Priority Marine Features ( PMF), such as Maerl and Horse Mussel beds, which are also protected under Annex 1 of the Habitats Directive, are present, protection will be required from all activity likely to cause significant damage.

Recreation and tourism

Minot to intermediate interaction.

When large cruise ships come into Kirkwall, entry to the inner harbour is restricted for fishing boats. Tender vessels from cruise ships can displace boats from their normal berths and have in the past caused damage to vessels undergoing repairs beached on the hard standing due to wash from tenders entering and exiting the harbour basin at speed.

Given the relative percentage of sea area required for aquaculture in relation to that required for commercial fishing, a reasonable balance must be struck to support both industries.

AP223: The cruise ship aspect is currently discussed in the shipping section but will be cross-referenced to the tourism section and the comments taken into consideration. A Shipping Study of the PFOW was carried out to inform the Draft Plan therefore will provide detailed information on key shipping routes in relation to the Scotmap data for small boat (< 15m) fishing.

There is potential for conflict between the legitimate needs of a working harbour for large vehicle access and storage of fishing gear and the aesthetic aspirations of the tourism.

AP224: Noted: we shall address this in the Draft Plan.

We support the use of interactions matrices to inform marine planning and agree with the scoring in Table 9.2 with exception of the interaction between ports and harbours and biodiversity and the natural heritage which we would class as major, rather than intermediate (on basis of potential significance of interactions during construction [ e.g. with respect to noise impacts on cetaceans] and also of secondary impacts associated with increased shipping activity). We also question the inclusion of ICZM in this matrix as we would view it as a tool to address interactions rather than as a sector or cross-cutting issue.

AP225: The comments will be taken into consideration when drafting the Plan.

We consider ICZM to be a cross-cutting issue as well as a planning tool in the same way as marine spatial planning is both. It is important that the intertidal area is covered by the marine Draft Plan but the Plan must also be compatible with the relevant Local Plan in the two Local Authority areas as both produce marine and terrestrial plans that over lap between MHWS and MLWS.

However, we advise that more specific information will be needed on interactions to usefully inform the Plan. For example, the nature and likely significance of interactions between commercial fisheries and the natural heritage is highly dependent upon the type of fishing and gear and on its location in relation to sensitive habitats or species.

AP226: Much more information will be provided in the Draft Plan. The PIOP, by its very nature, could only set out general policy and sectoral information.

Information on some key potential interactions between marine activities and the natural heritage is available through our Managing Coasts and seas page on our website ( http://www.snh.gov.uk/land-and-sea/managing-coasts-and-sea/) We also suggest that, with respect to Priority Marine Features, the ongoing work on development of management options for Marine Protected Areas ( MPAs) proposals may provide valuable information on key interactions.

It would be helpful if SNH could provide specific information/text they think should be included for the next stage i.e. the drafting of the Plan.

We consider that a spatial element to the Plan will be critical to refining understanding, and hence management, of interactions (both positive and negative) between interests (see response to Q16). In this context, while we support the general aspiration identified at 9.5 for the Plan to focus on identifying solutions rather than constraints, we would suggest that, in some instances the constraints on certain activities at particular locations may be sufficiently great to merit their explicit identification within the Plan ( e.g. the use of narrow straits for passage by vulnerable populations of marine mammals is likely to constrain options for development of arrays of tidal turbines).

AP227: Noted; we recognize that some areas are likely to be less appropriate for development and key constraints will be mapped.

We are happy to provide further input to the consideration of interactions with the natural heritage and to advise on associated policy development via the Plan advisory group and/or other meetings or workshops.

Noted; offer of help welcomed.

By the very nature of the Plan, we agree that "Water and Marine Environment" will have a major interaction with all aspects of the Plan.

Noted.

The interaction between recreation/tourism and marine renewables should =be a major interaction. During the installation and operation & maintenance phases there will be significantly increased shipping activity in the area. A full deployment there could be on average 1 device per day being removed from the water for planned maintenance. The activity for unplanned maintenance is unknown. This will increase the shipping hazard significantly to recreational water users in particular sail and kayaking). There is also a potential increase in noise pollution (eg during installation) which could impact on tourism.

AP228: The installation phase will be for a specified period therefore the effects of increased shipping will be temporary, whilst the maintenance phases will be on an as required basis, again not a continuous operation. Not all of the additional shipping movements will coincide with recreational users. Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text.

The matrix identified areas of major, intermediate or minor interaction but did not distinguish between positive and negative effects; as such we did not find it as informative or meaningful as had positive and negative interactions been identified. It was perhaps not detailed enough to inform a Regional Marine Plan. We would recommend that the location of incompatible activities is given equal consideration as compatible activities. The development of an incompatible activity near an established legitimate activity, such as a licensed discharge, may lead to requests for enhanced levels of treatment beyond that agreed and set out in the licence; resulting in additional costs in terms of carbon and financial cost.

This aspect has been discussed but as many of the sectors and issues can have both positive and negative effects, this may be overlooked if reading matrix in a simplified 'red, amber, green' approach without the supporting text. Given the issues above, the actual matrix will not be reproduced in an updated from in the Draft Plan, but appropriate explanatory text will be used instead to highlight interactions.

Constraints mapping will be used where appropriate; it would be helpful if Scottish Water could provide input of particularly sensitive sites when we come to draft the Plan.

Co-existence through appropriate management of incompatible activities, as suggested in the plan, may result in one sector bearing the burden of financial costs associated with a management regime

If activities are incompatible, they are unlikely to both go ahead unless one or both parties are in agreement with the developments and associated costs. This will be for developers to negotiate on a project by project basis.

I think the interaction between tidal/wave energy developments and recreation should be increased in respect of water users. Local kayak clubs have already been liaising with Meygen over the Inner Sound plans, and such liaison will be necessary in the future right across the area.

AP229: The installation phase will be for a specified period therefore the effects of increased shipping will be temporary whilst the maintenance phases will be on an as required basis, again not a continuous operation. Not all of the additional shipping movements will coincide with recreational users there we shall therefore considered these comments when drafting the Plan and provide explanatory text where appropriate.

See previous question.

Noted.

No comment

N/A

The matrix approach exemplified by Table 9.2 suffers from three weaknesses. First, many interactions are contingent on other factors. For example, tidal energy generators 8 m below keel depth will have no impact on recreational boating but ones with surface piercing elements will. Similarly, well planned aquaculture units have little impact but badly located ones can have a major negative impact by preventing safe access to anchorages

Secondly, many sectors are heterogeneous so that the impact on one part may be trivial but on others significant.

Thirdly some interactions are location specific. Whether or not a wave generation installation is a serious hazard will depend on whether there are safe alternative routes. The various coastal partnerships did work on interactions between sectors and tried to overcome these deficiencies. If the matrix is to be used as an evidence base for policy making then it needs considerably more work before we would find it acceptable.

AP230: Many of the sectors and issues can have both positive and negative effects, as noted in the matrix key.

Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. Given the complexity of marine users, the Plan can only offer guidance to the most parsimonious solutions whilst acknowledging more detailed planning will be required by individual developer projects.

Query regarding "minor interactions" between other sectors and Recreation and Tourism. Often it appears that no impact has been given. However there will always be an impact no matter how minor, so surely 'minor impact ' should have been recorded as a minimum?

AP231: Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. Whilst there may be very minor impacts for the other sectors, the matrix needs to be realistic in providing proportionate information and guidance rather than assessing every possible very minor interaction. These comments will be taken into consideration when drafting the Plan. Further detail on interactions will be provided in the Draft Plan, providing further opportunity to comment.

No comments.

N/A

No comments.

N/A

Managing the interaction between sectors and competing activities is a key issue to be addressed by the plan and should therefore constitute one of the key objectives of the plan. Please also see our comments in response to question 4.

Noted: this is a major challenge for regional marine spatial planning.

The management of interactions in the plan should be evidence based, informed by a practical understanding of how activities interact from a technical perspective. Acceptable proximity distances will become an important issue as discussions regarding co-existence and co-location develop.

AP232: Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text.

No comments

N/A

Defence should be added in to Table 9.2 as an additional, discreet sector.

In Table 9.2, if Marine Renewables is intended to cover not only wave and tidal but also offshore wind then this should be made clear.

A233: Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. These comments will be taken into consideration when drafting the Plan.

AP234: This will be clarified in the supporting text.

It is unclear how table 9.2 has been developed and how the proposed level of interaction has been decided. Many of these interactions are already considered and addressed through the RLG and the sectoral marine planning process. Further, through groups including NOREL, FLOWW and the Scottish Government's Fishing Focus Group, guidance to help with potential interactions between the marine renewables industry and other sectors, including shipping and fisheries, is being developed. The plan should not try to duplicate the work of these groups and should instead refer to where industry wide guidance has been, or is being, developed.

As noted in the original matrix in the RLG, " it will be refined and updated…during the development of the MSP, as more detailed information on different sectors and activities is generated".

AP235: Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. The comments provided will be taken into consideration when drafting the Plan.

AP236: We shall seek out the information held by the groups listed. This MSP process is looking at all sectors, not just marine renewables and will pull the relevant information together in one document, with signposting to specific technical guidance where appropriate.

No comments.

N/A

Question 15, Page 45

It is not clear in Table 9.2 what "Other Infrastructure" is and, for instance, why commercial fisheries do not interact with it, however marine renewables does.

Additionally, some of the levels of interaction in relation to marine renewables will be technology specific and also relate to the proposed development site. This should be stated somewhere as it is not currently considered.

AP237: Text will be provided in the Draft Plan to clarify: the term relates to infrastructure that is largely terrestrial/intertidal but not covered by other categories e.g. flood defences. As all marine renewables will require landfall for cables and sub-stations there is potential for interaction whereas fishing is unlikely to have discernible impacts and vice versa.

The PIOP aimed to set out proposed general policy themes and issues. The Draft Plan will also provide much greater detail on all of the sectors.

The interaction between marine renewables and recreation and tourism may be understated in being classified as 'minor'. Business tourism in Orkney in connection with marine renewables is a growth area of the tourism sector. Furthermore, many are known to have returned to the islands on holiday after initially visiting on business.

AP238: Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text. The comments provided will be taken into consideration when drafting the Plan: see response to comment 7.

Yes. See second paragraph of response to Q14.

Noted.

Comments in Question 19 box.

Noted.

Comments in Question 19 box.

Noted.

Promotion of archaeology and of archaeological research before infrastructure is urgently needed. Development too fast.

AP239: The Draft Plan will set out guiding policy to ensure it is a key consideration. All development will have to take the significant archaeological interests in the area into account. As part of 'Project Adair' marine heritage sites in the PFOW have been mapped and will therefore provide data for the Draft Plan that will also help inform developers.

HIE are unable to comment on this table other than flagging up the fact there are a number of interactions already taking place and being developed and therefore should be taken into consideration and not duplicated within this piece of work.

AP240: A key aim of the Plan is to provide information on all the sectors and issues in one place, signposting where appropriate. Text will be provided to discuss existing sectors/activity and planned development.

Comments in Question 19 box.

Noted.

Commercial fishing will have more than a minor impact on ICZM, Oil and Gas, and more than an intermediate interaction with marine aggregates and dredging.

AP241: We shall consult further with the SFA further to get data to support any changes.