Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Strategic Environmental Assessment Post-Adoption Statement.

Strategic Environmental Assessment Post-Adoption Statement.


5 Views on the Sustainability Appraisal for the Draft Pilot Plan

5.1 Overview

5.1.1 The following sections set out a summary of the findings of the SA and the views expressed in the consultation on the SA Report. This section also sets out how the findings were considered in the development of the Draft Pilot Plan, and also how they influenced the finalisation of the Pilot Plan.

5.2 Findings of the Sustainability Appraisal

Ambitions and Themes

5.2.1 The SA found that many of the themes and ambitions set out in the draft Pilot Plan and its constituent policies are also key threads running through wider policy; notably the inclusion of support for sustainable development, sustainable social and economic benefits, and the need for balancing this with environmental considerations. The SA found that setting these out in the Pilot Plan will likely complement and add further weight to the positions of existing policy and planning, and reinforce their relevance in relation to the future management and use of the PFOW area and its many resources.

5.2.2 Furthermore, by setting out these ambitions and working in-combination with existing consenting processes ( e.g. Marine Licensing, Town and Country Planning), the SA identified the potential for the Pilot Plan to positively contribute to promoting the sustainable management of activities in the PFOW area.

Potential for Environmental and Socio-economic Effects

5.2.3 In general terms, the assessment identified the potential for largely positive environmental and socio-economic effects from the development of the non-statutory Pilot Plan. However, it also found that the delivery of any benefits is likely to be contingent on having the support and 'buy in' of coastal and marine stakeholders.

5.2.4 The SA found that the fundamental focus of the Plan in supporting sustainable development in the Pilot Plan area has the potential to make a significant contribution to the protection of the coastal and marine resources in the PFOW area. From this, it identified the potential for associated benefits for coastal and marine environments themselves, and for those that use them. It also considered that this potentially presented an opportunity to help in delivering overall benefits for the many varied sectors operating in the PFOW and also the communities that they support, particularly those dependent on the coastal and marine resources of the area.

5.2.5 Alongside these overarching ambitions, the SA found that many of the general policies in particular seek to safeguard both socio-economic opportunities and environmental features in the PFOW area, whilst also reflecting wider ambitions. For example, supporting the wider sustainability objectives of the Scottish Government, Orkney Islands and Highland Councils.

General Policies

5.2.6 The SA found that many of the general policies offer built-in mitigation against the potential for adverse effects that can be associated with inappropriate development or coastal/marine use. For example, the inclusion of 'safeguarding' policies in the Pilot Plan could help to promote the sustainable use and conservation of important environmental and social features ( e.g. biodiversity, landscape/seascape, cultural heritage and historic archaeology).

5.2.7 The SA noted that this increase in focus given through inclusion in the Pilot Plan could also help to reduce the risk of adverse effects that may be generated through increased use of the coastal and marine environments in the PFOW. It could also support the work of existing mechanisms such as current consenting processes supported by protection legislation, HRA and EIA, amongst others; particularly when used as material considerations in decision-making ( e.g. marine licence applications). The inclusion of messages in the Pilot Plan, particularly the overarching themes of efficient use of the marine area, co-existence and shared used of space and facilities, are also likely to further emphasise these themes in the coastal and marine environment of the PFOW area and further strengthen wider ambitions.

Sectoral Policies

5.2.8 The inclusion of the sectoral policies in the draft Pilot Plan was identified as a further opportunity to support for sustainability ambitions at the sectoral level. The SA identified the potential for these policies to set out expectations for these sectors and provide guidance for developers, marine users, consenting authorities and other stakeholders to ensure that any future growth in the region is centred on appropriate development and co-existence. However, the SA also noted the likelihood of incompatibility between some marine users, and identified the potential for displacement of some activities as a consequence of increased use of the PFOW coastal and marine areas.

5.2.9 However, the SA also identified the potential for opportunities through the development of the Pilot Plan to improve communication and engagement between future developers, marine users and other stakeholders; including the potential to manage interactions and conflicts at an early stage. Whilst dependent on achieving the 'buy in' of these stakeholders, the SA found that this could also help to identify potential opportunities for synergistic benefits amongst stakeholders and help to improve efficiency in the development process. For example, the SA identified the potential for streamlining current consenting processes around which applicant-lead engagement with stakeholders is considered to be a key potential benefit.

5.2.10 The SA also noted that having the 'buy in' of future developers, marine users, local communities and consenting authorities was likely to be an essential factor in the realisation of any potential benefits associated with the Pilot Plan. The SA also considered this to be a key factor in the Plan's role in informing and shaping the development of the two upcoming Regional Marine Plans, and particularly in fostering further engagement with stakeholders in their development.

5.3 Mitigation and Enhancement Opportunities identified in the Sustainability Appraisal

5.3.1 While the drive for sustainable development and growth within the PFOW area was seen as a key ambition of the Pilot Plan, the growth of marine industry in the region is also likely to present a number of challenges in the future. In particular, the SA identified the potential for the Pilot Plan and its policies to have significant positive effects but also that this is likely to depend on achieving the 'buy in' of stakeholders to the ambitions set out in the Pilot Plan. Without the support of developers, marine users, consenting authorities and local communities, the SA considered that many of the potential positive effects identified in the assessment would be unlikely to materialise. As such, the formal public consultation process supported by ongoing engagement with stakeholders was identified as a key component, as well as playing an important role in obtaining feedback on the draft Pilot Plan and in identifying possible improvements, opportunities and limitations. In particular, the stakeholder engagement undertaken in the development of the Pilot Plan and the lessons learned through its development should lay the foundation for future discussions and stakeholder involvement in the development of Regional Marine Plans for Orkney and the North Coast. The documentation of lessons learned in the Pilot Plan's development should also usefully inform the development of the regional plans; both those for the PFOW area and in other parts of Scotland.

5.3.2 The staged approach taken in the development of the draft Pilot Plan was specifically adopted to help identify and fill data gaps and uncertainties in relation to the marine environment and allow stakeholder engagement early in the process; in particular, the inclusion of a stage for studies for the Plan's development and the subsequent preparation of RLG and the Environmental and Socio-economic Baselines. Building upon this knowledge-base is likely to be a critical aspect in progressing regional marine planning in the PFOW area, and particularly in further developing the required spatial information likely to be needed to inform the development of relevant and useful Regional Marine Plans. The consultation process and ongoing engagement with stakeholders may also provide opportunities to seek input on the information outlined in the Pilot Plan, the SA and the RLG, and for identifying opportunities to enhance this data.

5.3.3 The SA identified the potential for conflicts between some coastal and marine users, and the potential for some sectors to grow or develop at the expense of others. The potential for impacts on existing sectors and marine users through the emergence of new or evolving sectors was also identified ( e.g. offshore renewables, offshore aquaculture). This is likely to be an important consideration in future iterations of marine planning in the PFOW area, particularly if developed with a more spatial approach. The resilience of coastal communities to change, particularly those reliant on specific industries ( e.g. fishing, recreation and tourism), was also identified as a concern, particularly as sectoral growth is likely to be driven by market forces. In addition, ensuring any environmental, social or economic risks associated with sectoral growth are minimized while growth itself is optimised was also seen as a likely challenge.

5.3.4 As areas of pressure or opportunity become more apparent, the regional plans and their future iterations could be used to rebalance regional ambitions, including the identification and management of adverse impacts. Maintaining links with wider policies such as the NPF3, NMP, Sectoral Marine Plans for Offshore Renewables and existing consenting processes should also help to ensure that the scale of development in different areas is recognised and addressed through strategic level mitigation, as well as that at the project level. Further, this could be used to guide future monitoring programmes, ensuring that they are appropriately targeted towards priority data gaps and produce relevant and useful outcomes that inform future decision-making.

5.4 Views on the Sustainability Appraisal

Summary of Views on the Sustainability Appraisal

5.4.1 The consultation yielded broadly positive feedback from respondents on findings of the SA and general agreement over the consideration of the SEA issues included within the assessment. In particular, there was broad agreement on the likely positive effects of the development of the Pilot Plan; specifically the potential for benefits such as increased transparency in decision-making from the collation of policies and ambitions. However, some felt that the benefits of the Pilot Plan had been overstated and some felt that the policies were unlikely to significantly alter the current baseline condition. As a consequence, several felt that the effects are likely to be more neutral than positive, particularly in relation to several sectoral policies ( e.g. commercial fisheries, aquaculture, ports and harbours, defence).

5.4.2 The Consultation Authorities also made comments on the approach taken in preparing the SA. While they felt that the SA addressed all the SEA topics scoped into the assessment and expressed support for the use of key questions in the SA to guide the assessment process, they stated that they found it difficult in some instances to distinguish the findings relating to social, economic and environmental factors. However, they also gave positive feedback on how the assessment had evolved; particularly that many of the issues that had been raised in the 2013 consultation in relation to the Initial Draft Environmental Report had been addressed in the SA Report. For example, there was support for the clarification and explanation provided in assessing the policies and on the rationale behind the grading system used in the assessment.

5.4.3 These views are set out in greater detail in Table 5.1.

Views on the Environmental Issues Raised in the Sustainability Appraisal

5.4.4 Specific comments received in the consultation and the responses to them are set out in Table 5.1.

Table 5.1 Summary of Views on the Environmental Issues Raised in the Sustainability Appraisal

Summary of Views on the Environmental Issues Raised in the Sustainability Appraisal Response
General Comments
The Consultation Authorities noted that they found it difficult to distinguish between findings relating to social, economic and environmental factors in some parts of the SA Report. They felt that the narrative did not always make it clear which of the above interests were under discussion. The marine environment plays a prominent role in supporting many communities in the PFOW region, and as a consequence, there are close interactions between environmental and socio-economic aspects and effects. The SA was developed to consider the potential for impacts on these closely linked aspects, and to the environment, communities and other sea users to be considered in a cohesive way, and to enable recommendations of a holistic nature to be drawn. As a consequence, many of the effects identified and discussed in the SA had common environmental and socio-economic elements.
Appendix E of the SA Report was included to set out how the Report complied with the 2005 Act, and to identify the sections of the report that addressed environmental issues in the context of the SEA.
In light of the comments received, the need for greater clarity in narrative has been noted for consideration in future SEA/ SA work.
Several made suggestions for improvement and/or corrections to text in the SA Report. These comments have been noted for consideration in future SEA/ SA work.
One respondent noted that the use of key questions in the SEA was undertaken for the second tier of assessment, but that the policy assessments were framed at the topic level and did not explicitly refer to these questions.
They stated that it seemed 'counter-intuitive' to apply these questions to the Plan as a whole rather than to its constituent elements.
Section 6.3 of the SA Report set out the two tier approach taken in the assessment including the use of key questions to consider the overall cumulative effects of the Plan and its group of general and sectoral policies within the wider policy and regulatory context.
As the Plan and its policies took shape, it was considered that some policies, by themselves, were unlikely to have significant social, economic or environmental effects. Rather, it was felt that the primary role of many of the policies would largely be in their contribution to the delivery of wider environmental and socio-economic ambitions ( e.g. sustainability, protection of the marine environment, reduction of GHG emissions). While these questions were used to guide the assessment of the general and sectoral policies themselves set out in Appendices A and B and the SA Report, and provide a common link between the two tiers of assessment, it was therefore considered that they would be best utilised in considering the effects of the Plan and its policies as a whole.
One respondent felt that there was no reference in the SA Report to the assessment of "the limited range of policy alternatives identified at the issues and options stage" and that they "would have anticipated that all reasonable alternatives identified would have been subject to assessment".
Specifically, it was anticipated that an SEA of a regional marine spatial plan be applied to regionally specific, spatial and non-spatial, alternatives at all levels within the developing plan, including individual policies and/or policy areas.
The PIOP and draft Pilot Plan set out the scope and limitations of the Pilot Planning process, and the identification of alternatives to the development of the Pilot Plan.
Section 6.6 of the SA Report set out the reasonable alternatives considered in the assessment, including the consideration of both spatial and non-spatial options. Many of the options raised by stakeholders during the many consultations and engagement events were adopted into the Pilot Plan's development, and this is further discussed in both the SA Report and this Statement.
In the development of the PIOP it was suggested that the Pilot Plan be an overarching spatial strategy, with the inclusion of a series of maps identifying key features. This approach was generally supported by the majority of respondents, and it was considered that taking a greater spatial focus or a strict 'zoning' approach' was not currently achievable. However, the inclusion of spatial information in the plan-development process ( i.e. in the Environmental Baseline of the SA and RLG) should both inform decision-making and also aid the potential for further spatial focus in future regional marine planning.
Baseline
Several respondents suggested information sources for inclusion in the environmental baseline.
Sources such as Caithness.org, research programmes and studies such as Joint Nature Conservation Committee's ( JNCC) Seabird Monitoring Programme and the current Succorfish study in Orkney, and the seabird tracking data illustrating where tracked seabirds commute and forage during the breeding season when providing for their young, were identified by respondents.
These sources were considered in the development of the Pilot Plan and in the development of future Regional Marine Plans both within and outwith the PFOW area.
Another respondent welcomed the intention of the SA to assess the draft SPAs ( dSPA) in the HRA, but also felt that this should be consistently applied or recognised throughout the plan. Until formally proposed by the Scottish Government, these sites have no legal standing under the Birds Directive [15] . However, Section 7.4 of the SA Report identified the 14 draft SPAs in Scotland, and the presence of North Orkney dSPA and Pentland Firth and Scapa Flow, Orkney dSPA within the PFOW Marine Spatial plan area. It stated that these "sites have been identified to alert stakeholders to additional marine sites that are likely to be considered by the Scottish Government for designation".
Section 9.4 of the SA Report and the HRA Record set out how the dSPAs had been considered in the HRA process.
Whilst mentioned in the Report, one respondent also felt that Local Nature Conservation Sites ( LNCS) should be presented alongside other nature conservation areas. While not considered to be material to the findings of the assessment, this comment has been noted for consideration in future SEA work.
One respondent felt that commercial crustacean stocks should receive greater consideration in the SA Report.
They also felt that the assessment should consider the role of latitude, depth, tidal flow and water temperature in and around the Orkney Islands that together contribute to a unique growing environment for these stocks.
Commercial fishing activities were considerations in the development of the Pilot Plan, particularly the development of Sectoral Policy 1 (Commercial Fisheries), the RLG and in the SA.
These comments have been noted for consideration in future work.
One respondent felt that the pressures listed in the baseline could have been more specific. One felt that these were limited to the consideration of future developments and did not consider pressures that may arise from existing, and in particular unregulated, activities in PFOW. The key pressure boxes in the SA Report were developed to provide a broad overview of the main pressures discussed in the environmental baseline sections for each environmental topic area.
With the potential for further spatial considerations in future Regional Marine Plans in the PFOW area, it is likely that further detail and greater specificity of the key pressures could be better implemented in future Plan development and SA processes.
This comment was noted in the finalisation of the Pilot Plan and its SA, and for consideration in future assessment work.
Several respondents provided suggestions for improvement to the environmental baseline, either generally or via specific recommendations.
For example, it was noted that Sule Skerry and Sule Stack are not within territorial waters out to 12 miles.
Several respondents noted the reference to nephrops landings in Orkney, and stated that this was a small fishery. Rather, it was felt that landings of Brown crab, lobster, Velvet crab and King scallops would be better examples.
This comment was noted in the finalisation of the Pilot Plan and its SA, and for consideration in future assessment work.
One respondent suggested that the Fishing Liaison with Offshore Wind and Wet Renewables ( FLOWW) group be mentioned in discussion on stakeholder engagement. This comment was noted in the finalisation of the Pilot Plan and its SA, and for consideration in future assessment work.
Environmental Effects
One respondent felt that the level of uncertainty in relation to the assessment of landscape/seascape impacts was not as high as that set out in the Environmental Report. They felt that with "the assessment of landscape and visual impacts, and landscape character assessment, are well-established methodologies" it should be possible to determine at a strategic level whether certain policies are likely to have a positive, neutral or negative impact on landscape objectives. The SA Report acknowledged the available guidance, including that published by SNH relating to the siting and design of installations for the aquaculture industry and offshore wind. It noted that these have been developed to address approaches to impact and capacity assessment, and also to help in minimising visual impacts.
The policy assessments undertaken in the SA identified that whilst this guidance is in place, an assessment of landscape and visual impact of development in the coastal and marine environment remains uncertain and dependent on location-specific factors. Rather, such an assessment is likely to be better considered at the project or activity level, and within existing mechanisms ( e.g. planning applications). The Pilot Plan and its SA may support these assessments through acting as material considerations in these processes.
One respondent felt that more emphasis should be put on the direct and indirect benefits of the amenity aspects ( e.g. sport and leisure use), not just commercial tourism. The assessment of Sectoral Policy 6 (Recreation, Sport, Leisure and Tourism) identified the potential for positive effects for landscape/seascape through more consistent consideration of sectors based around the appreciation and enjoyment of these assets, in addition to commercial tourism.
Some queried the specific scores applied to the environmental topic areas in the Assessment Tables in the SA Report. These comments were noted for consideration in future SEA work. However, the suggested changes were not considered to be material to the overall findings and outcomes of the assessment nor the finalisation of the Pilot Plan.
One respondent felt that the SA over-estimated the significant positive effects the Plan will have on the environment in some instances. They considered that it also considered the effect of the policy activity rather than how it would be influenced by the Plan.
Some felt that the effect of Pilot Plan and many of its policies would likely be neutral. They felt that while benefits in setting out the making the decision process more transparent, they were unlikely to enhance or improve the current baseline situation.
These comments have been noted.
As the respondent noted, the assessment identified the potential for positive effects overall via implementation of the draft Pilot Plan and its policies. It considered that these were likely to be principally related to setting out expectations and providing guidance for marine users, consenting authorities and communities for the sustainable use and management of natural resources in the PFOW, and the promotion of appropriate development and co-existence.
However, the SA also noted that the delivery of any such benefits was also likely to be contingent on having the 'buy in' and support of stakeholders. Without this support, it considered that any potential benefits would be unlikely to materialise.
One respondent felt that the assessment could have been used as a mechanism to ensure that individual elements of the Plan where enhanced or to ensure that as a whole the policies delivered a range of positive effects to all aspects of the environment ( e.g. climate change). The draft Environmental Report was prepared alongside the PIOP and the SA was undertaken alongside the development of the Pilot Plan. Integrating the assessment and the data gathering in the preparation of the RLG, into the plan development process was undertaken to enable the findings of these processes to inform the development of the Pilot Plan. For example, this played an important role in guiding the development of both the safeguarding general policies and the sectoral policies.
It is anticipated that the SA findings and the information in RLG will form a useful foundation for the development of the Regional Marine Plans in the PFOW area.
One respondent felt that due consideration had not been given to the potential adverse effects on biodiversity from Sectoral Policy 7 (Ports and Harbours). They asked if this policy would have otherwise been considered had the report focused on purely environmental issues as required by SEA. They felt that the narrative largely concentrates on the impacts on marine users, safeguarding of jobs and industry requirements. Appendix E of the SA Report set out how the Report complied with the 2005 Act.
The SA Report identified the potential for positive effects for biodiversity and other environmental topic areas, due largely to the potential for a reduction in collision and pollution risk associated with promoting navigational safety and the safeguarding of port and harbour access.
It also noted that "the development of port and/or harbour facilities would also continue be subject to existing consenting processes ( e.g. Marine Licensing, Town and Country Planning, etc.) and supported by environmental assessments where applicable ( e.g. EIA, HRA, etc.). The SA "expected that any future marine development would be in accordance these requirements" and that these processes and assessments would continue to be used to identify the potential for adverse effects, and where appropriate, to avoid or apply appropriate mitigation.
One respondent stated that inappropriate beach cleaning can result in the removal of cast weed from coastal areas. They felt that it was important as these materials support important populations of wading birds in PFOW, and that their removal would have negative impacts on biodiversity. This comment was noted in the finalisation of the Pilot Plan and its SA, and for consideration in future assessment work.
One respondent stated that nature conservation designations have the potential to adversely affect communities where fishermen are prevented from "working" in them. They added that in the outer isles in particular, fishing activities provide jobs and support their communities in social ways. The establishment of nature conservation designations is considered outside the scope of the Pilot Plan.
However, this comment has been noted and passed on to the appropriate persons in the Scottish Government for their consideration.
Recommendations for Mitigation
Several respondents noted their support for the iterative plan review process, where new information would be fed back into the development of future plan iterations so that lessons can be learnt and priorities can be adapted to avoid unwanted outcomes.
One respondent suggested that the sections on mitigation and monitoring could provide more specifics in terms of the recommendations and commitments. They added that the Plan would benefit from specific actions being listed to act as an aide memoir to planners as the Plan is adopted and used to develop into Regional Marine Plans.
The comments have been noted.
It is anticipated that the publication of the Lessons Learned Report will help to inform future marine plan-making, and in particular, aid in the development of the upcoming Regional Marine Plans.
Another felt that the focus of these measures in the SA Report was primarily on future planning processes, and how some of the 'short-comings' in the pilot Plan could be further explored and addressed.
They also expressed their support for recognition of the need for a more spatial approach and of the importance of stakeholder engagement.
The comments were noted.
It is anticipated that the publication of the Lessons Learned Report will help to inform planners and aid in the development of Regional Marine Plans in the future.
A respondent stated that they anticipated additional recommendations for more specific mitigation measures to address environmental impacts that might arise from implementation of the pilot Plan. However, they noted that the absence of such measures in part reflects the high-level approach taken to the assessment of the policies. This comment has been noted.
Given the strategic and high level focus of the Pilot Plan, development of more specific mitigation measures are likely to be more appropriate at the regional marine plan and project/sectoral levels.
A respondent recommended that measures be devised to assess the extent to which the Plan (and/or RLG) is referenced in future EIAs for developments in the PFOW, and the extent to which the quality of any EIAs is improved as a result of this. This comment has been noted for consideration in monitoring use of the Pilot Plan in the future.
At present, the recommendations made at the 'gate check' stage of a proposed development usually contain a section on planning policy and legislation. It is anticipated that the Pilot Plan would be noted as a document that would need to be consulted by the developer.
The Scoping stage of the EIA process would also include reference to the Pilot Plan if it was relevant to a development in the PFOW.
A respondent felt that it would have been useful if a clear table had been provided to confirm exactly what existing monitoring would be examined in the context of the Plan, and whether any plan-specific monitoring is also proposed.
They also felt that this should be included in the Post Adoption Statement.
This comment has been noted.
Proposals for monitoring are set out in Section 7 of this Statement.
A sectoral respondent stated that data is not limited to spatial information, and that there are biological factors that are fundamental to commercial fisheries stocks. They felt that these require biological mapping and greater understanding, particularly given the multidimensional characteristics of the marine environment. This comment has been noted.
Monitoring is a key focus of research in Scotland's fisheries sector, including a range of studies being currently undertaken by the Scottish Government. For example, Marine Scotland Science surveys on abundance and collection of biological data obtained from sampling catches, being complemented by research in academia and the sector itself.
HRA
One respondent noted that while the Plan had been screened out of the need for an Appropriate Assessment ( AA) that Table F1 demonstrated that the potential for likely significant effects ( LSE) has not been able to be ruled out.
They felt that it was not appropriate to simply defer HRA to project level without undertaking AA at this plan stage.
The HRA Record sets out the findings of the HRA process undertaken for the Pilot Plan. This confirms that the policies in the PFOW have appropriate reasons to be screened out of requiring an AA.
The same respondent also noted that the Sectoral Marine Plans for Offshore Renewables and their HRA were in draft form. They felt that given this, the conclusions in that HRA could not be relied upon nor used as justification for screening the Pilot Pl an out of an AA The findings of the assessments undertaken for the Sectoral Marine Plans, including the development of the draft and final HRA Records, informed the assessments of the Pilot Plan.

Summary of Views on the Socio-economic Baseline

5.4.5 The majority of respondents either did not provide an answer to the question in the consultation or stated that they had no comment to make in their response. Of those that did provide responses in the consultation, mixed feedback was received on the socio-economic baseline, with some suggesting a range of improvements in their responses.

5.4.6 Several respondents questioned the figures produced in the socio-economic baseline, including the employment statistics, stating that they seemed high for some sectors ( i.e. sea angling) and felt that they would need to be reviewed for the fishing sector. Some requested clarification on the information presented in the Socio-economic Baseline Review. Some of these comments were specific; for example, whether the future targets for finfish aquaculture presumed no new developments on the north and east coasts. Some suggested the inclusion of additional information in the report and felt that this presented an opportunity to better inform stakeholders and the plan development process on socio-economic issues in the PFOW area. For example, one respondent suggested that the use of total biomass figures for aquaculture sites may be more informative than presenting the locations and numbers of farm sites.

5.4.7 Several also questioned why certain information had been included, and others identified information that they felt would be beneficial or had been overlooked. For example, one respondent stated that Wick Harbour was well placed to service several offshore wind areas.

Views on the Socio-economic Baseline

5.4.8 Specific comments received in the consultation and responses to them are set out in Table 5.2.

Table 5.2 Summary of Views Received on the Socio-economic Baseline Review

Summary of Views Received in the Consultation on the Socio-economic Baseline Review Response
Clarifications and Corrections
Some respondents asked for clarifications on information presented in the baseline review.
For example, one respondent stated that it was unclear if the future targets for finfish aquaculture presumed no new developments on the north and east coasts. They felt that if so, a note should be added to this effect.
The Socio-economic Baseline Review was prepared to directly inform the development of the draft Pilot Plan and its SA. Whilst there are no current plans to revise or reissue the Review, it is anticipated that its development and the feedback obtained from the consultation process will inform the consideration of socio-economic issues in the development of the upcoming Regional Marine Plans in the PFOW area.
These comments have been noted and considered in the finalisation of the Pilot Plan, and in future assessment work.
Another noted that marine renewables and other sectors have contributed to additional passenger numbers in the PFOW area, and stated that this was not represented in the Report.
Several queried the inclusion of information in the Baseline Review and consistency with the Pilot Plan.
For example, one noted that only wave and tidal renewables technologies were mentioned in Section 9.1.1, but noted that the RLG also showed areas in relation to offshore wind.
These comments have been noted and considered in the finalisation of the Pilot Plan, and will be considerations in future assessment work.
Another noted that the potential beneficial use of dredged material was not carried over into the Plan. The adoption of the Pilot Plan was considered unlikely to lead to an increase in aggregate extraction activities or capital and maintenance dredging. Rather, the Plan advocated the preservation of natural resources and the promotion of co-existence amongst coastal and marine activities, including future aggregates extraction and dredging.
Dredging activities were also discussed in the SA Report.
These comments have been noted and considered in the finalisation of the Pilot Plan.
It was noted that whilst landings are given as those by Scottish vessels, the fleet details and employment can lead to misinterpretation of the total landings. They added that most of the landings in Orkney are made by Orkney vessels, whilst most of those in Scrabster (particularly demersal) are made by Scottish vessels from other areas.
Another stated that Scrabster is an EU designated landing port, and that this influences the value and amounts of landings made there. They added that there is no such port in Orkney, so all major landings there are crustaceans and other shellfish.
The Socio-economic Baseline Review was prepared to directly inform the development of the draft Pilot Plan and its SA. Whilst there are no current plans to revise or reissue the Review, it is anticipated that its development, and the feedback obtained from the consultation process, will inform the consideration of socio-economic issues in the development of the upcoming Regional Marine Plans in the PFOW area.
These comments have been noted and considered in the finalisation of the Pilot Plan, and will be considerations in future assessment work.
Another felt that EU regulations have influenced the type of fin fish targeted in Orkney waters, and that a scale of subsidised public investment in the different industries is needed. These comments have been noted for consideration in the finalisation of the Pilot Plan.
The comments have also been passed on to the relevant policy area for their consideration.
Several respondents suggested changes to the text included in the Report. For example, consistency in currency units across documents. Cross referencing should be done to ensure consistency and allow direct comparison.
Another noted that Figure 11 did not show the aerial zones presented in other documents.
The Socio-economic Baseline Review was prepared to directly inform the development of the draft Pilot Plan and its SA.
Whilst there are no current plans to revise or reissue the Review, it is anticipated that its development, and the feedback obtained from the consultation process, will inform the consideration of socio-economic issues in the development of the upcoming Regional Marine Plans in the PFOW area.
These comments have been noted and considered in the finalisation of the Pilot Plan, and will be considerations in future assessment work.
One respondent felt that employment figures would need to be reviewed for the fishing sector, whilst another felt that the employment statistics for sea angling seem high.
One respondent stated that the employment figures did not mention the large number of divers in Orkney diving for Scallops. They felt that these divers can contribute to aquaculture and tourism with charter vessels depending on time of year.
A respondent noted that Carbon Capture Storage ( CCS) had been raised in the Socio-economic Baseline but not in in the main document under Oil and Gas. No CCS sites have been identified in the PFOW area. Should this change in the future, it is anticipated that this would be reflected in the development of the upcoming Regional Marine Plans.
A respondent stated that the energy generation details provided in Section 9 of the Baseline Review for Inner Sound and Lashy Sound are incorrect. This comment has been noted and considered in the finalisation of the Pilot Plan.
Another felt that considering the total biomass figure rather than the number of fish farm sites would be more informative. They felt that several extensions in recent years have been of the equivalent of installing an entirely new site.
They also felt that the addition of the total spatial occupation, including moorings and the parameters of the filter systems are of spatial and biological were relevant to developing commercial crustacean stocks.
The Socio-economic Baseline Review was prepared to directly inform the development of the draft Pilot Plan and its SA. Whilst there are no current plans to revise or reissue the Review, it is anticipated that its development, and the feedback obtained from the consultation process, will inform the consideration of socio-economic issues in the development of the upcoming Regional Marine Plans in the PFOW area.
These comments have been noted and considered in the finalisation of the Pilot Plan, and will be considerations in future assessment work.
They also felt that gross incomes for aquaculture sites in the isles would be helpful, alongside additional information on the types of jobs in the sectors ( e.g. workers, management, directors.
Another felt that a breakdown of business profiles in the commercial fisheries sector would also be beneficial.
Suggestions for Inclusion
Several felt that additional information should have been included. For example, one respondent noted that there is no mention of the proposed SPAs ( pSPAs) in the Baseline Review, and that these may enhance tourism. These comments have been noted and considered in the finalisation of the Pilot Plan.
The presence of Special Protection Areas ( SPA), including the presence of draft and pSPAs, were discussed in both the SA and the Pilot Plan.
Another noted that Section 4 focused on primary production for Aquaculture, and that unlike the section on fisheries, it had no information on processing. They also noted that Stromness Lobster Hatchery had not been mentioned, and felt that it may be an important form of mitigation with respect to renewables developments. The Socio-economic Baseline Review was prepared to directly inform the development of the draft Pilot Plan and its SA. Whilst there are no current plans to revise or reissue the Review, it is anticipated that its development, and the feedback obtained from the consultation process, will inform the consideration of socio-economic issues in the development of the upcoming Regional Marine Plans in the PFOW area.
These comments have been noted and considered in the finalisation of the Pilot Plan, and will be considerations in future assessment work.
A respondent noted that Wick Harbour is also well placed to service several offshore wind areas.
A respondent stated that the use of local firms and contractors in the supply chain is significant in the context of the Orkney Isles, and added that this should be identified.

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