Publication - Consultation analysis

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report

Published: 2 May 2014
Part of:
Marine and fisheries

Planning Scotland’s Seas: Scotland’s National Marine Plan was published for consultation in July 2013. Independent analysis of all written responses to the consultation has been undertaken and is presented in this report.

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report


Chapter summary

  • Some of those responding to this chapter simply noted their overall support, or their support for specific elements.
  • Key comments were that offshore energy and telecoms infrastructures should be able to co-exist in relatively close proximity; and that there is a need to pay heed to geodiversity.

15.1 The Draft National Marine Plan noted that the 1990s bought unprecedented growth in international telecommunication cables; over 95% of these are submarine cables. Roughly 40% of all the UK's active international cables are on the Scottish seabed.

15.2 Telecommunications are of national and international economic importance. While submarine cables are generally benign, growth in other sectors increases the risk of potential damage to cables. The main sectoral interaction expected will be between seabed cables and fishing activity.

15.3 The installation and operation of telecommunication cables may cause minimal impacts on the marine environment, including the historic environment. The primary impact of this is likely to be the loss or disturbance of sensitive habitats and fragile species during installation. Climate change and associated sea level rise is expected to increase the incidences of coastal flooding and erosion and this may have implications for the landfall of cable.

15.4 The Draft NMP presented four marine planning policies for telecommunication cables and outlined some issues for consideration for submarine cabling in the future.

Comments on Telecommunications, Chapter 14

15.5 Respondents were asked:

Question 31: Do you have any comments on Telecommunications, Chapter 14?

15.6 Table 15.1 shows that 25 respondents opted to provide some form of comment to this question. The greatest number of comments came from respondents in the energy, Local Authority, environment/ conservation and public sectors.

Table 15.1 Question 31: Do you have any comments on Telecommunications?

Respondent group
Individuals (16) 1
Academic / scientific (7) 3
Aquaculture (5) -
Energy (12) 5
Environment / conservation (9) 4
Fisheries (13) -
Historic / Heritage (5) -
Industry / transport (9) 1
Local Authority (15) 6
Local coastal partnership (7) -
Local group (5) -
Other public sector (10) 4
Recreation / Tourism (7) -
Other (4) 1
Total (124) 25

15.7 A significant number of those responding welcomed some or all of aspects of this chapter; some noting overall support, some welcoming specific objectives and / or planning policies for this sector.

15.8 Two respondents in the energy sector noted that offshore energy infrastructure and telecoms infrastructure should be able to co-exist in relatively close proximity providing appropriate distances from telecoms cables are maintained. Respondents, one in the environmental/ conservation sector and one in the public sector noted the need to pay heed to geodiversity, for example, the need to be sensitive when considering new developments.

15.9 Another public sector organisation noted that the same consideration should be given to water pipelines, an energy organisation noted that good practice in relation to cable laying and cable installation is also relevant to the offshore renewable sector; and an energy company noted the need for a consistent approach to be applied to electricity export cables for strategic grid connections, individual renewables energy projects and telecoms. An individual made a specific suggestion for an alternative route for a cable line.

Alternative policies

15.10 Respondents were then asked:

Question 32: Are there any alternative planning policies that you think should be included in this chapter?

15.11 Only three respondents made suggestions for alternative policies or objectives. These were:

  • An objective around future telecommunications cables, for example supporting the roll out of high speed broadband in the Highlands and Islands;
  • Policies relating to the development of electricity networks that are of essential benefit to the development of the energy sector, but require strong policy support to address the differences in regulatory approaches across nations and alleviate uncertainty for the industry. Policies to consider include the Supergrid and the National Policy Statement for Electricity Networks Infrastructure ( EN-5) which "may be a relevant consideration in planning decisions in Scotland";
  • In terms of wastewater pipelines, these should be considered as subsea infrastructure within the NMP. This could be incorporated in a section on general cables and pipelines;
  • A policy on moorings should be considered i.e. commercial moorings such as wave rider buoys etc.