Planning Scotland's Seas: Sectoral Marine Plans for Offshore Wind, Wave and Tidal Energy in Scottish Waters. Consultation Analysis Report.

3 Plan Development

3.1 This section of the report focuses on the first seven questions included in the consultation questionnaire. These questions aim to explore the information and process used in developing the Plans and the Draft Plan Options. The responses to each of the questions are explored in turn.

In summary:

• Many more respondents explicitly agreed (35) than disagreed (9) with the approach used to develop the Plans.
• There was fairly broad support that the Sustainability Appraisal Report ( SAR) covers all main social, economic and environmental effects at a high level or in summary form. Nevertheless, respondents recognised gaps in information already acknowledged in the SAR as well as identifying additional issues that should be taken into account in preparing the Final Draft Plans.
• The limitations of existing information and the need for ongoing research and monitoring resulted in many respondents finding it hard to take a clear view on mitigation measures identified in the SEA environmental report or on the impacts on sea users identified in the Socio-economics Report.
• The limitations of available information also resulted in many respondents finding it hard to comment with confidence on the scale and pace of development that could be sustainably accommodated in Scottish Waters or the balance achieved in the Draft Plans.
• A recurring theme was the need for a continuation of the iterative process and for ongoing research and monitoring to contribute to regular updates and reviews.
• Slightly more respondents agreed (18) than disagreed (11) that an appropriate balance, between tackling climate change, maximising opportunities for economic development and dealing with environmental and commercial impacts had been achieved in the Draft Plans.

Question 1: Do you agree with the approach (outlined in Section 3 of the Sectoral Marine Plans) used to develop the Plans?

3.2 As the table overleaf shows, many more respondents explicitly agreed (35) than disagreed (8) with the approach used to develop the Plans. Only small numbers of individual respondents and some respondents in the fisheries grouping expressed explicit disagreement; opinions were divided within both these respondent groupings.

Table 3.1 Proportions of those answering the question that agree with the approach (outlined in Section 3 of the Sectoral Marine Plans) used to develop the Plans

Respondent group	Yes	Yes Qualified	No	Other
Individuals (9*)	4 (44%)	-	5 (56%)	1 (11%)
Local Authorities (9)	8 (89%)	-	-	1 (11%)
Fisheries (6)	3 (50%)	-	3 (50%)	-
Energy (5)	5 (100%)	-		-
Local Groups (2)	2 (100%)	-		-
Public Sector (6)	3 (50%)	1 (17%)		2 (33%)
Recreation/Tourism (3)	3 (100%)	-		-
Environment/Conservation (4)	4 (100%)	-		-
Historic/Heritage (1)	1 (100%)	-		-
Academic/Scientific (1)	1 (100%)	-	-	-
Aquaculture (1)	1 (100%)	-	-	-
Other (1)	-	1 (100%)	-	-
Total responding to question (48)	35 (73%)	2 (4%)	8 (17%)	4 (4%)

*An individual answered both yes and no; individuals' responses therefore add to 10 (111%)

3.3 Thirty-seven of the 48 respondents who responded to this question provided comments. Many of these, most notably those who had answered 'yes', reiterated their general or broad agreement with the approach used.

3.4 Specific areas of praise, each noted by only one or two respondents and collectively identified by a variety of respondent groupings, related to:

• The provision for those being consulted to be properly informed at each stage;
• The consistency of approach;
• The use of a regionalised approach that allows for customisation;
• The overall systematic approach and in particular the systematic approach to developing the Draft Plan Options;
• The aim of directing commercial development to low areas of constraint;
• The use of a sustainable approach;
• The quality of the process chart;
• The sound nature of the SAR;
• The fairness and transparency of approach.

3.5 The next most common theme, predominantly from those who disagreed with the approach and within that subset from fisheries organisations specifically, related to belief that development of offshore installations is being given preference over existing fishing activity. In addition, the Scottish Fishermen's Federation and other fisheries organisations questioned the extent to which the content of the Marine Policy Statement ( MPS) had been observed.

3.6 Individual respondents who did not agree with the approach variously commented that the (National) Marine Plan must be agreed before the allocation of sites and that insufficient research had been undertaken in specific aspects of tide activity.

3.7 Orkney Islands Council commented that Section 3 of the Sectoral Marine Plans should make clear the relationship between the Sectoral Plans and the National Marine Plan ( NMP) and 'particularly, that the NMP Policy Renewables 1 states a presumption in favour of adopted Plan Options identified through the sectoral planning process'.

3.8 There were no other recurring themes regarding the approach to development of the Plans, although a variety of comments was each made by one or two respondents from across groupings. Some of these related to lack of available information, data or knowledge to inform the Plans and a need to address this in the future:

• RYA Scotland commented that whilst they felt the approach used to develop the Plans was good, they felt it disappointing that small and demonstrator schemes that might be sited close to the Areas of Search were not included;
• The Association of Salmon Fishery Boards commented on a lack of existing knowledge of marine migration routes of Atlantic salmon and the marine feeding areas for sea trout;
• Galloway Fisheries Trust also commented that lack of knowledge on migration routes and feeding grounds for certain species meant that the planned approach does not cover all environmental and biodiversity aspects in the Strategic Environmental Assessment.

3.9 Dumfries and Galloway Council commented more broadly that there was inadequate explanation as to how the proposals had been reached or to enable comparison of the relative Draft Plan Options.

3.10 EDPR UK felt that an explanation should be given as to why areas of search had been removed from the draft regional plan or why boundaries had been changed.

3.11 The Crown Estate and Highland Council commented on the volume of material spread across different documents and suggested that greater cross-referencing would be helpful.

3.12 Scottish Enterprise and the Crown Estate commented on the need for clarification of timings and a variety of other issues going forward. For example, further refinement of areas in order to reduce uncertainty for users of the sea. SEPA questioned how the Plans will fit with other sectors when it comes to spatial planning decisions.

3.13 Other comments included;

• A view that pre-statutory consultation could have been more directed to involve local stakeholder groups;
• A question from an individual respondent regarding the skills and experience of local authorities to deal with the planning process and objectors;
• A local authority requested improvements to the layout and readability of the Draft Plans.
• A concern from another individual respondent regarding lack of explicit detail and discussion around safety, related to installation and operation as well as all others users of the environment concerned.

Question 2: Do you have any views on the findings of the Sustainability Appraisal Report? Do you think that all the social, economic and environmental effects (positive and negative) have been identified? Are there other issues that should be taken into account in the preparation of the Final Draft Plans?

3.14 Forty respondents, six individuals and 34 organisations, commented at this question.

3.15 More than a third of the organisations that commented noted broad support for the issues covered and information provided in the SAR, albeit some of these respondents also commented that this was at a high level or provided only summary information. A few respondents included comments of appreciation that issues relating to their sphere of interest had been taken into account, including:

• The Institute for Archaeologists welcomed recognition of the need to identify effects on archaeological remains;
• The National Trust for Scotland was appreciative that the importance of seascape and landscape and visual impacts on the setting of historic assets had been considered.

3.16 Association of Salmon Fishery Boards ( ASFB) commented that they had contributed to the steering group for the process and that their views had been taken into account.

New or Emerging Data

3.17 A small number of respondents noted that the SAR acknowledged that there are gaps in evidence. The Joint Nature Conservation Committee ( JNCC) acknowledged that there were proposed projects and monitoring to fill those gaps and supported this, whilst others commented on the need for clarity regarding removal or refinement of draft plan options on the basis of emerging information.

3.18 An academic / scientific respondent commented that some data for Shetland is incomplete or inaccurate, for example relating to sea kayaking. They added that available local data relating to Shetland and provided to Marine Scotland had not been included in the Plans [sic] and that this affected the quality of conclusions drawn from the assessment and site selection.

3.19 The Crown Estate commented they would support the refinement or removal of any draft plan options that may not be suitable for development in the light of new information that might emerge from the consultation, as opposed to new information simply being made available to inform project level assessment.

Onshore Impacts

3.20 Whilst a disparate range of social, economic and environmental effects was identified as requiring further attention and consideration in preparation of the Final Draft Plans, a number of these related to onshore impacts.

3.21 National Trust for Scotland and Argyll and Bute Council commented specifically on the need to consider the grid infrastructure and its possible effects on the landscape and communities. Respondents noted that it would have been preferable for the grid proposals to have been incorporated into the current Draft Plans.

3.22 National Trust for Scotland also commented that whilst the assessment had taken into account most environmental effects they would welcome stronger recommendations for Seascape, Landscape and Visual Impact Assessment to be included as part of the EIA at the project stage.

3.23 Pentland Firth Yachting Club felt that impacts on local facilities and infrastructure were not fully taken into account. As an example they cited displacement of recreational users from harbours. An individual respondent felt the SAR did not take into account of the cumulative impact of offshore and onshore windfarms on either residents or the tourism sector, particularly in the South West.

Impacts of Displacement

3.24 Several respondents raised concerns regarding lack of detailed attention to the impacts of displacement, most notably displacement of commercial fishing. Their comments related to potential social, economic and environmental effects.

• Orkney Fisheries Association commented on the need for more research into the social and economic impacts on local areas, and particularly on island groups, resulting from displacement of commercial fishing activity.
• Orkney Islands Council also commented that the Sustainability Appraisal focusses at a high level on regional effects and that greater focus and attention to each development zone would be helpful.
• National Trust for Scotland highlighted potential displacement of fishing activity into areas designated for conservation or historic environment sites.
• Scottish Fishermen's Federation questioned many assumptions made regarding the impacts of displacement.

Environmental Conservation

3.25 A variety of concerns were each identified by only one or two respondents in relation to particular species. The National Trust for Scotland commented that they would welcome greater attention to the indirect effects of developments, for example where prey species are impacted, acknowledgement of the impacts on the species that rely on the prey species.

3.26 A lack of data on the location of spawning grounds for pelagic species was cited as an environmental concern as well as an economic concern.

3.27 Shetland Islands Council commented that it was an over-simplification to state that avoidance of tidal devices is a likely response to their presence by mobile marine fauna; the respondent would welcome greater attention to the topic.

3.28 Whale and Dolphin Conservation commented on concerns that the SAR had not recognised potential for injuries as a result of pile driving, the use of acoustic deterrent advices and 'corkscrew injuries' from ducted propellers. The respondent commented that 'corkscrew injuries' are a serious collision risk for Scotland's harbour seal population and also commented that noise associated with construction is likely to be a consideration, notably in the North East.

3.29 The Scottish Geodiversity Forum expressed concerns that the SAR and SEA do not fully recognise the importance of seabed geodiversity features. This respondent put forward specific suggestions as follows:

• That in in areas of the SAR, the term Marine Geodiversity should replace Marine Geology;
• That where the effects on coastal geodiversity are considered this should be extended to recognise the sensitivity of the 35 key marine geodiversity areas of the seabed, as well as coastal geological SSSI and Geological Conservation Review sites.

3.30 RSPB Scotland and Scottish Environment LINK both highlighted potential for indirect effects of Plan Option development on protected mobile marine species.

Fisheries and the Fisheries Supply Chain

3.31 Scottish Fishermen's Federation indicated that they 'would not quibble that the likely effects of renewables installations on fishing have been identified', whilst Orkney Fisheries Association questioned the validity of the SAR because it was informed by the Socio-economics assessment which they perceived to have significant gaps.

3.32 The Crown Estate noted that the Socio-economics assessment suggests that estimates of the costs to the fishing industry may be overstated and reported their view that the assessment is based on a worst-case scenario, whilst Aberdeenshire Council noted the potential impacts of any loss in income for fishermen on the fisheries supply chain.

Other Issues

3.33 Aquamarine Power detailed a number of concerns regarding lack of consideration for the requirements of all Oscillating Wave Surge Converter ( OWSC) technology types and the associated benefits of certain technology types. Further comment from this respondent suggested that the Areas of Search for wave energy development do not include enough near shore locations and disagreement that there is a need for a 10km buffer of development from surfing beaches. The respondent also cited a lack of scientific evidence and transparency regarding predicted effects in the SEA.

3.34 Shetland Island Council commented on a number of possible omissions or errors in the SAR, including:

• Text indicating an overlap between Plan Option OWN2 and the Pobie Bank cSAC, which the respondent felt was not borne out by available maps;
• Lack of consideration of the potential downstream impacts of other marine developments on wave devices;
• Lack of cost benefit analysis considering the potential carbon footprint in developing and installing new technologies and the offset in terms of their energy production efficiency;
• Insufficient consideration of landscape and seascape impacts of wave developments;
• Interactions with a proposed MPA designation for sand-eels and Mousa to Boddam pMPA, TN5, and possibly WN3;
• Reference to the proximity of TN7 to the northern boundary of the Fetlar to Haroldswick pMPA, which has black guillemot as a feature of interest;
• Incorrect labelling of tables, for example Tables 5.7 and 5.9 describe data for the North region but have West in the title;
• Lack of clarity as to whether the PV costs for commercial fisheries in the North region have included pelagic fishing to the north of Unst and south of Sumburgh.

3.35 Highland Council suggested that greater attention should have been given to opportunities for synergy and impacts upon aquaculture, harbours' capacity and associated marine supply chain issues.

3.36 Galloway Fisheries Trust noted that potential impacts on fish migration routes should be assessed in addition to the list of potential effects already noted.

3.37 RYA Scotland commented that potential costs associated with possible collisions with types of wave and tidal devices have not been included.

3.38 A local group (Banff and Macduff Community Council) commented that the SAR does not include reference to the sustainability of the economics of developments that were in the last Sectoral Plans (Regional Guidance) and are no longer included, nor the effects on the local communities involved.

3.39 Marine Spatial Planning Section, NAFC Marine Centre identified local data sets that had not been included in the assessment, notably for Shetland.

3.40 Sportscotland commented that the SAR did not give sufficiently detailed consideration to impacts on recreation and that there appeared to be uncertainty as to impacts on the recreation sector or that impacts were only considered to be relevant at a project level and therefore not assessed as part of the SAR.

3.41 RSPB Scotland and Scottish Environment LINK commented similarly on omissions that they recommended should be included in the final report:

• Incorporation of all Saltire Prize Identified Areas on maps;
• Representation of terrestrial conservation features in the SEA;
• Omission in the environmental assessment of the future deepwater test and demonstration offshore wind sites for which a new leasing round is progressing.

3.42 Seagreen expressed some concerns about lack of consistency in terminology between the SAR and other documents. For example, the respondent questioned how an 'activity' listed in the Sustainability Appraisal relates to 'issues' in the Draft Sectoral Plan.

3.43 Other comments, primarily from individual respondents, included:

• That the social and economic measures only deal with employment and that this is does not fully encompass 'value', both material and in terms of well-being;
• An assumption that decommissioning of the sites would be covered in the process before development of the Final Draft Plans;
• Concerns about impacts on Orkney due to perceived confusing and contradictory references within the SAR, in particular with regard to adverse effects on the integrity of the area. The respondent commented that no reference was made to adverse impacts on people's psychological wellbeing and felt that some conclusions regarding economic and social impacts were arguable;
• A query regarding the suggestion of findings that there is 'no fishing industry of consequence in the South West', citing a Lobster, crab, whelk and scallop fishery in the area;
• A variety of specific comments from an individual respondent relating to the ways in which safety issues had been treated.

3.44 The Community Energy Foundation commented on potential to apply a community benefit model that may be used in relation to onshore wind farms in order to ensure communities affected by offshore wind farms take a degree of ownership in order to support the communities and help mitigate any negative economic effects.

Question 3: The SEA has identified a range of potential effects from the Draft Plans. Measures for the mitigation of these effects have been identified in the SEA environmental report. Do you have any views on these findings? Do you think that the proposed mitigation measures will be effective? Do you have any additional suggestions?

3.45 Thirty-eight respondents, four individuals and 34 organisations, commented on this question.

3.46 The main theme to emerge from these comments related to the recognised shortfall in available data and research that might enable respondents to comment more knowledgeably or in any detail on mitigation measures or their likely effectiveness.

3.47 Many of the respondents who made comment, including a range of organisations as well as individuals, noted that project level assessment and site specific monitoring will be essential to identification of effects, mitigation and mitigation effectiveness. However, Pentland Firth Yachting Association commented that the focus appeared to be on measuring effects rather than avoidance measures.

3.48 Some respondents expressed a view that it is appropriate for mitigation measures to be project specific and that only broad good practice and design measures were appropriate at this stage. Others noted that they would welcome a more detailed assessment of broad or cumulative impacts. Whale and Dolphin Conservation commented that close links are needed between the SEA recommendations and project level EIAs and resulting consent conditions.

3.49 Several fisheries respondents expressed disagreement that mitigation is a matter for project level design and commented that the SEA made little mention of fishing. This in turn led to a comment that mitigation measures have not been adequately identified or addressed that would make good losses that would be sustained by the fishing industry.

3.50 The Institute for Archaeologists commented that they welcomed attention to both designated and non-designated heritage assets and to potential direct effects on submerged archaeology during construction.

3.51 National Trust for Scotland commented that any areas of particular sensitivity, including Natura 2000 sites, pMPA sites, historic MPAs, designated National Scenic Areas ( NSA) and World Heritage Sites, should be excluded from any draft Plan Options. Marine Spatial Planning Section, NAFC Marine Centre also expressed surprise at proposed search locations close to Natura 2000 sites.

3.52 Three environment / conservation organisations cited possible MPAs or MPA search locations as areas to be avoided for overlap with draft Plan Options.

3.53 Dumfries and Galloway Council commented on inadequate attention to general landscape considerations outwith designated areas and potential consequential impact on tourism.

3.54 Other specific and detailed comments included:

• The need for consideration to floating tidal devices in tables relating to Population and Human Health;
• The need for further consideration to potential effects on seabed geodiversity;
• The need to incorporate proposals to mitigate impacts on commercial fishing in the North region;
• Concern that exclusion zones for wave and tidal schemes are not an effective mitigation measure due to potential difficulties in recreational sailors avoiding them;
• Concern that some suggested mitigation measures, such as avoiding certain work in key seasons, might make development commercially unviable;
• The need to avoid situations where the Crown Estate enters into an Agreement of Lease with a developer and a site is then removed or a boundary changed during plan reviews.

Question 4: The Socio-economics Report has identified a range of potential impacts on existing sea users. Do you have any views on these findings? Do you think that the proposed mitigation measures will be effective? Do you have any additional suggestions?

3.55 Thirty respondents, two individuals and 28 organisations, commented on this question.

3.56 The major theme that emerged from responses related to insufficient detail or data relating to impacts on fishing.

Fishing

3.57 The Scottish Fishermen's Federation, as well as other respondents in the fisheries sector that are its members, made detailed observations including:

• The assessment did not take account of areas released or subject to agreement to release, meaning that the total impact on fishing is not shown;
• The assessment did not identify thresholds at which synergistic impacts might result in activity becoming uneconomic and potentially lost;
• A calculation, based in part on information in the assessment that suggests a potential loss of around £65 million turnover to the fishing sector;
• In relation to displacement effects, a failure to factor for the need for quota acquisition for species not traditionally fished by a displaced vessel;
• Concern about lack of precision in estimates as well as absence of what is perceived as ineffective mitigation in some areas.

3.58 Clyde Fishermen's Association voiced concerns about poor quantification of impacts and potential for complete displacement for some fishermen with further impacts onshore where their businesses would be based.

3.59 Orkney Fisheries Association commented that the tools for measurement of impacts have limitations and that they would encourage the use of qualitative assessments of impacts alongside quantitative socio-economic assessments.

3.60 Comhairle nan Eilean Siar commented that static gear fishing, seaweed cultivation, mussel cultivation and similar activities should be encouraged in exclusion zones for trawling to mitigate any loss of traditional fishing area and to provide a renewable resource for onshore ethanol or heat producing anaerobic digestion projects.

3.61 Orkney Islands Council noted that the assessment of impact on commercial fisheries concludes that impacts mainly accrue to the pelagic trawlers, demersal whitefish trawlers and potters and suggested that further work will be required to understand better the impact of the development zones on inshore fisheries. The respondent noted that the impact of these developments on the fuel costs for the inshore fisheries fleet, as well as catches, should be considered.

3.62 Argyll and Bute Council cited the importance of determining cumulative issues in relation to fishing, amongst a range of other sectors.

Other Issues

3.63 Some local authorities and fisheries respondents noted the importance of further ongoing consultation with stakeholders from Marine Scotland and developers.

3.64 Argyll and Bute Council and Orkney Islands Council commented specifically on their own interest in further discussions with Marine Scotland, on a range of issues related to both assessment of impacts and the planning of future development requirements. Ports and harbours work requirements were specifically mentioned as economic aspects that should be taken into account.

3.65 Marine Spatial Planning Section, NAFC Marine Centre commented that there was insufficient consideration to impacts on local communities. The respondent disagreed with a conclusion that there will be no impact on culture and heritage.

3.66 RYA Scotland commented that there is uncertainty about impact on visitors and recreational sailors, particularly in response to a series of wind farms rather than simply individual schemes. Pentland Firth Yachting Association commented that loss of amenities and seascape beauty could have direct and indirect socio-economic impacts that were not being treated sufficiently seriously.

3.67 The Institute for Archaeologists commented that insufficient attention was given in the report to economic impacts on the marine historic environment.

3.68 The British Sub Aqua Club highlighted the need to consider possible impacts on drift diving, albeit the respondent agreed that the plans are unlikely to have significant impacts on scuba diving.

3.69 A small number of respondents provided comments relating to the perceived accuracy of detailed, individual items of data throughout the socio-economic report. There was also comment on the complexity of the information for lay readers.

3.70 A local group, Banff and Macduff Community Council, noted that the Socio-economics Report did not address the lost potential of developments that were in the last Sectoral Plans (Regional Guidance) issued but no longer included.

Question 5: Taking into account the findings from the technical assessments, do you have views on the scale and pace of development that could be sustainably accommodated in Scottish Waters?

3.71 Thirty-two respondents, four individuals and 28 organisations, commented on this question.

3.72 A key theme identified related to difficulty in taking a firm view on the potential scale and pace of development until further information becomes available.

Need for Further Research and Information

3.73 Many respondents, including public sector, local authorities, fisheries, environment / conservation organisations and academic / scientific respondents, commented that gaps in information and assessments made it difficult to gauge the potential scale and / or speed of development that could take place.

3.74 For some, this led to comments that a relatively cautious, evolving approach to development would be needed, with careful management and controls. For example, JNCC suggested a precautionary approach that would allow for more and better evidence to be gathered and analysed.

3.75 A fisheries respondent, Clyde Fishermen's Association, expressed concerns that a rushed pace is being adopted, without proper evaluation taking place.

3.76 Specific areas cited by respondents where they perceive further information and analysis may be required, included:

• Effects on the marine nature conservation resource;
• Cumulative impacts;
• Research on fish migration routes, feeding areas and spawning grounds;
• Assessment of marine tourism and recreation.

Practical Constraints

3.77 A small number of respondents cited practical constraints to the scale and pace of development, primarily in relation to grid infrastructure and onshore infrastructure to support operations.

Other Views

3.78 An individual respondent and a tourism/ recreation organisation, Drummore Harbour Trust Ltd, commented that the pace was not quick enough. Another tourism / recreation organisation commented on the importance of the pace allowing for consultation and giving adequate time for responses to be considered and prepared, taking account of their limited resources.

3.79 The Association of Salmon Fishery Boards commented that their views on development beyond the existing plan areas would be subject to the delivery of the national strategy into strategic research for offshore marine renewables and anadromous fish.

3.80 Some respondents commented that ambitions might be over optimistic.

Question 6: Are there aspects of the Draft Plans that you believe should be improved? Are there any aspects you believe should be taken forward differently?

Please explain any reasons for your answer and provide details of any suggested improvements:

3.81 Twenty-seven respondents, four individuals and 23 organisations, commented at this question. Many of those who provided comment referred back to or reiterated the views they had expressed at earlier questions.

Environmental Considerations

3.82 Several respondents, including public sector and environment/ conservation organisations, commented again on the environmental assessment approach and the limited environmental sensitivities information. Three environment/ conservation organisations (Scottish Environment Link, Whale and Dolphin Conservation and RSPB Scotland) summarised their key suggested improvements as follows:

• More clarity in assessment of Impact Risks;
• More transparency in how uncertainties are dealt with in the risk based

approach;

• An SEA Objective should include both pillars of the EU Habitats Directive;
• Putting the mechanisms in place to enable strategic analysis of data collected

by individual developers;

• Ensure that data is made available in a timely fashion;
• Allowing development at a pace that ensures that the key data gaps can be

answered, including through field data and completion of ORJIP projects;

• Proposed MPAs and Search Locations should be avoided, as well as designated sites;
• Overlap with proposed MPAs and Search Locations should be minimised, as

well as with designated sites or other sensitive habitats, species and ecosystem

functions;

• Ensuring that high level mitigation measures are carried through to the project

level, including enforcement;

• Improving our understanding of cumulative impacts;
• Separating out marine mammal baseline data so it more accurately reflects

distribution and status, especially for harbour seals; and,

• Better representation of marine mammal data in maps.

3.83 National Trust for Scotland also commented that the impacts of overlap of developments with MPAs need to be understood before such developments are progressed. The respondent also requested more consideration of:

• Cetacean distribution and potential impacts;
• Acceleration of designations for offshore SPAs;
• Adoption of the Precautionary Principle in dealing with risks to designated features and priority marine features.

3.84 Another environment / conservation respondent, Scottish Geodiversity Forum, recommended that the sensitivity of the 35 key marine geodiversity areas should be recognised.

Other Issues

3.85 Scottish Enterprise suggested that a clear explanation of the relationship between Sectoral Marine Plans and the legislative and policy context should be included early in the document, to ensure understanding of the relative status of various documents. SEPA also commented that an explanation of the make-up, role and responsibilities of the proposed Sectoral Plans Review Group would be helpful, particularly in relation to the interaction between Scottish Marine Regions, the regional plans, specific marine planning policies for any possible Strategic Sea Areas and the National Marine Plan.

3.86 Argyll and Bute Council and the Highlands Council both suggested greater attention to grid issues and considerations. In addition, the National Grid suggested it would be useful to provide an indication of the energy capacity ( MW) which could be provided in each area and felt this information would support the planning of related grid connections.

3.87 An academic/ scientific organisation, Marine Spatial Planning Section, NAFC Marine Centre, recommended that additional data sets should be incorporated into the plans to ensure accurate modelling.

3.88 A fisheries organisation, Scottish White Fish Producers Association, commented that more attention is needed to establishing effects on inshore fishing.

3.89 In terms of taking things forward, the Scottish Salmon Producers Organisation commented that the preparation of the Final Draft Plans should take into account the salmon farming industries' plans to grow production, primarily on the north west coast and around Orkney, Shetland and the Outer Hebrides, as well as the importance of this industry to the Scottish economy, and the economies of those areas.

3.90 Aquamarine Power suggested greater consideration be given to benefits and opportunities associated with the development of Oyster technology.

3.91 No Tiree Array suggested that there should be more consultation with impacted communities.

3.92 Individual respondents commented on the slowness generally of the process including the consultations, lack of consideration to safety issues and the need for more research.

Question 7: Do you believe an appropriate balance, between tackling climate change, maximising opportunities for economic development and dealing with environmental and commercial impacts has been achieved in the Draft Plans?

3.93 As the table below shows, there were more respondents who believed that an appropriate balance had been achieved than those who did not think this was the case. Opinions appear more polarised amongst fisheries and energy organisations than other respondent groupings, although varied views are evident throughout.

Table 3.2 Proportion of those who answered this question who believed an appropriate balance, between tackling climate change, maximising opportunities for economic development and dealing with environmental and commercial impacts has been achieved in the Draft Plans

Respondent group	Yes	Yes Qualified	No Qualified	No	Other
Individuals (7)	3 (43%)	-	-	4 (57%)	-
Local Authorities (8)	7 (88%)	1 (12%)	-	-	-
Fisheries (4)	2 (50%)	-	-	2 (50%)	-
Energy (4)	1 (25%)	1 (25%)	-	2 (50%)	-
Local Groups (1)	-	-	-	1 (100%)	-
Public Sector (4)	-	2 (50%)	1 (25%)	1 (25%)	-
Recreation/Tourism (3)	2 (67%)	-	-	-	1 (33%)
Environment/Conservation (4)	3 (75%)	-	-	-	1 (25%)
Academic/Scientific (1)	-	-	-	1 (100%)	-
Total (36)	18 (50%)	4 (11%)	1 (3%)	11 (31%)	2 (6%)

3.94 All thirty-six respondents, seven individuals and 29 organisations, added comments at this question.

Main Themes

3.95 Many of the respondents who indicated that they largely or totally believed an appropriate balance had been achieved, commented on their recognition of the need for sustainable forms of energy and solutions to address climate change.

3.96 Some of these respondents indicated that there may be consequences, potential or actual and foreseen or unforeseen, which some felt may need to be accepted in the context of achieving an appropriate balance. Additionally, some commented that this is dependent on mitigations being delivered effectively.

3.97 As reported at earlier questions, several respondents found it difficult to assess whether balance has been achieved on the basis of existing research and information that is available and gaps in data were identified. Once again, the need for an iterative process taking account of emerging and ongoing research and monitoring was cited by some respondents, particularly environment / conservation organisations.

Factors and Issues

3.98 A variety of different factors were each identified by only one or two respondents as potentially affecting the achievement of balance.

3.99 SEPA commented that Climate Change priorities should be more explicitly included within planning policy and decisions.

3.100 Scottish Enterprise commented on the importance of effective grid infrastructure in realising the potential of the offshore industry as outlined in the SMPs.

3.101 The Crown Estate commented on the need to reduce uncertainty for other sea users, by refining areas, in so far as possible, before publication of the adopted Plans.

3.102 One energy respondent felt that the positive contribution of renewable energy technologies in limiting negative aspects of climate change had not been considered in sufficient detail; another felt there should be greater presumption in favour of development in less environmentally sensitive areas.

3.103 A recreation / tourism organisation, Sportscotland, commented on the need to ensure that health and well-being are considerations within social impacts in order to achieve appropriate balance.

3.104 An individual respondent commented that the plan [sic] is one sided and that all costs need to be considered alongside all benefits. Another individual noted that no manufacturing jobs are being created in Scotland by turbine production.