Draft Sectoral Marine Plan for Offshore Wind Energy 2019: consultation analysis report

4 Sustainability Appraisal

4.1 Introduction

4.1.1 The consultation posed seven questions, one for each of the seven supporting sustainability appraisal documents. These questions were:

• Do you have any comments on the Strategic Environmental Assessment Environmental Report?
• Do you have any comments on the Habitat Regulations Appraisal?
• Do you have any comments on the Social and Economic Impact Assessment?
• Do you have any comments on the draft Regional Locational Guidance?
• Do you have any comments on the Sustainability Appraisal report?
• Would you add or change anything in the partial Equality Impact Assessment?
• Would you add or change anything in the partial Islands Communities Impact Assessment?

4.1.2 The responses to each are summarised below.

4.1.3 Across all questions discussed below 15 responses from individuals refer their answers to the views of the SFF and SWFPA, discussion of which is covered through discussion of the organisational responses.

4.2 Question 8 - "Do you have any comments on the Strategic Environmental Assessment Environmental Report?"

4.2.1 Of the 84 responses received to question 8, 12 stated that they did not have any comment to make. Table 10 breaks down the responses by sector.

4.2.2 Of the 18 individuals who made specific comment (excluding the 15 individuals who refer their answers to the SFF / SWFPA comments), four (4) were specifically focussed on the SW region. Two (2) considered visual impacts in this area to be the constraining factor, one (1) highlighted the importance of transboundary data sharing whilst one (1) raised concerns that some potential impacts on bird features from development in SW1 were under-assessed.

4.2.3 At a national scale a further two (2) individuals highlighted visual effects or more widely all impacts and their subsequent impacts to tourism as the most significant risk. Three (3) responses agreed with the conclusions of the SEA, while two (2) considered that fishing grounds had not been sufficiently taken into account. Three (3) responses raised concerns regarding the impact of piling and construction on crabs, mackerel and marine mammals but did not comment on the assessment within the report. Two (2) further responses did not comment on the outcome of the assessments but considered that impacts on environmental receptors were significant.

4.2.4 Within the organisational responses, 11 from the Energy sector considered that there is a lack of information regarding reasonable alternatives, including detailed assessment of the 'do nothing' alternative and rationale for selection of DPOs. A further three (3) from the energy sector requested additional detail on the process used to determine the maximum development scenarios.

4.2.5 In addition to the 12 responses which stated that they did not have comment to make, six (6) responses, including statutory nature conservation bodies, across sectors broadly agreed with the conclusions of the SEA and / or the requirements outlined for further project assessment. Two referred specifically to SW1 and considered that development in this DPO is likely to cause a significant adverse effect. Further points raised by small (one (1) or two (2)) numbers of respondents are:

• Consideration should be given to the need for further assessment of grid connection infrastructure (subsea cabling / onshore development)
• Risks to aviation should be managed at a policy level.
• Further technology specific detail would provide greater confidence in the assessment.
• Additional project level mitigation measures could be identified within the assessment.
• New data is available to support assessment of landscape / seascape issues, (considered to be under-assessed at some sites).
• Additional data on migratory fish (specifically Atlantic Salmon) is provided regarding migratory routes and potential visual disturbance.
• Consideration that additional data is required to support the assessment.

Table 10 Sectoral breakdown of respondents to Question 8

Sector	Number of responses
	No comment	Commented	Total
Individual	3	33	36
Commercial fisheries	-	6	6
Energy	3	16	19
NA	4	16	20
Ports & harbours	1	-	1
Shipping	1	-	1
Tourism and recreation	-	3	3
Total	12	74	86

4.3 Question 9 - "Do you have any comments on the Habitats Regulations Appraisal?"

4.3.1 Of the 74 responses received to question 9, 15 stated that they did not have any comment to make. Table 11 breaks down the responses by sector.

4.3.2 Of the ten (10) responses from individuals who made specific comments on the HRA, one (1) agreed with the outcome of the assessment, two (2) considered additional protection was required, one (1) requested additional consideration of fisheries interests, three (3) considered that addition assessment of SW1 was required due to ornithological, marine mammal and Site of Special Scientific Interest (SSSI) constraints and one (1) highlighted the potential impact on receptors from development in W1.

4.3.3 Eight (8) organisational responses to question 9, including statutory nature conservation bodies stated that they concurred with or broadly agreed with the conclusions of the HRA, in some cases whilst offering additional comments. Five (5) organisations from the energy or commercial fishing sectors questioned the outcome of the assessment. Nine (9) responses from the energy sector requested that consideration should be given to the decisions taken to consent offshore wind projects to date with the competent authorities concluding no AEOI. Five (5) responses, again from the Energy sector, requested clarification about the potential for individual projects to progress by means of derogation under Article 6(4) of the Habitats Directive.

4.3.4 Five (5) organisational responses identified that they considered there to be further assessment required for migratory birds, three (3) of which specifically discuss potential risks arising from development in SW1.

4.3.5 Five (5) organisations highlighted the requirement for HRA updates to be undertaken upon receipt of updated evidence, three (3) of which provided reference to specific new evidence they consider should be included:

• updated bird foraging ranges (Woodward et al., 2019) (2 responses)
• 'as-built' data (as opposed to the outcome of assessments / modelling)

4.3.6 Five (5) organisations recommended that a review of the mitigation presented was required, to ensure relevance and to clarify the extent to which projects might be required to adhere rigidly to the proposed mitigation measures.

4.3.7 Two (2) comments were raised regarding impacts on fish, one (1) focused on potential impacts on herring spawning grounds and sought assurance that these would be protected, whilst the other requested further consideration was given to potential impacts on migratory fish.

Table 11 Sectoral breakdown of responses to Question 9

Sector	Number of responses
	No comment	Commented	Total
Individual	4	25	29
Commercial fisheries	-	4	4
Energy	3	14	17
NA	4	16	20
Ports & harbours	1	-	1
Shipping	1	-	1
Tourism and recreation	2	-	2
Total	15	59	74

4.4 Question 10 - "Do you have any comments on the Socio-Economic Impact Assessment?"

4.4.1 Of the 92 responses received to question 10, four (4) stated that they did not have any comment to make. Table 12 breaks down the responses by sector.

4.4.2 Within the individual responses, six (6) (in addition to those referencing SFF / SWFPA comments) considered that the impact on fisheries was underestimated, although conversely, one (1) response posited that the emotional attachment to fishing might outweigh the economic benefit.

4.4.3 Nine (9) comments referenced potential negative impacts associated with the loss of tourism revenue, seven (7) of which specifically highlighted concerns regarding potential impacts from development in SW1, and one (1) highlighted the potential for impacts from development in W1.

4.4.4 Seven (7) responses highlight the potential for benefits from development of offshore wind through employment, cheaper electricity or additional benefits from co-location with hydrogen generation. One (1) of these responses noted that a training programme was likely to be required to support job creation.

4.4.5 There were 45 organisational responses to the SEIA, which represent a range of sectors. Six (6) responses broadly agreed with the outcome of the SEIA or concurred that project level assessment would be important in determining potential project specific impacts. One (1) additional response identified the importance of early consideration of subsea cabling in a project lifecycle. Four (4) responses highlighted tourism as a specific concern, although one (1) local authority response specifically referring to N4 considered that the potential impacts were likely to have been overstated. Eight (8) responses specifically addressed SW1, noting that they considered the costs to outweigh the benefits and additionally questioned the validity of the benefits identified. Three (3) responses identified risks to recreational boating and associated navigational safety as key concerns, whilst one (1) indicated that additional consideration should be given to potential impacts on ferry routes.

4.4.6 There was disagreement between the fisheries sector and Energy sector about the potential impacts to commercial fisheries. The commercial fisheries sector considered impacts to be either correct (but significant) or understated based on anecdotal / additional evidence (11 responses from fisheries / local council representation) whilst the Energy sector considered fisheries impacts to be significantly overestimated due to incorrect assumptions (16 responses). The key assumption challenged by the Energy sector is that in a worst case scenario fisheries would be permanently excluded from a development and that the fishing effort would be lost rather than displaced. In addition, two (2) responses from the Energy sector requested clarification about the policy assumption that the Energy sector would be required to address all costs to the aviation sector for radar replacement going forwards.

4.4.7 One response from the Carbon Capture and Storage (CCS) sector considered that the assessment underestimated interactions between the sector and offshore wind.

Table 12 Sectoral breakdown of responses to Question 10

Sector	Number of responses
	No comment	Commented	Total
Individual	-	41	41
Carbon capture and storage	-	1	1
Commercial fisheries	-	7	7
Energy	2	17	19
NA	2	16	18
Ports & harbours	-	1	1
Power Interconnectors / telecoms	-	1	1
Shipping	-	1	1
Tourism and recreation	-	3	3
Total	4	88	92

4.5 Question 11 - "Do you have any comments on the draft Regional Locational Guidance?"

4.5.1 Of the 68 responses received to question 11, 19 stated that they did not have any comment to make. Table 13 breaks down the responses by sector.

4.5.2 In general, responses from individuals making specific comments focussed on the potential impacts on visual amenity and tourism (three (3) responses), the importance of stakeholder engagement (one (1) response) and fisheries (one (1) response). Three (3) responses supported the format and commented on the usefulness of the RLG.

4.5.3 Six (6) organisational responses stated they were happy with the outputs presented in the RLG. Responses from organisations generally focused on the inclusion of additional sector specific detail, with over half (14 responses) providing additional information for consideration across the following topics:

• Carbon capture and storage
• Ports and harbours (particularly with regards to supporting offshore wind development
• Migratory birds
• Migratory fish
• Defence
• Fisheries
• Recreational angling
• Presence of radioactive particles from Dounreay in the North region
• The cruise industry

4.5.4 Six responses noted the significant potential for visual impacts in the SW region, whilst four (4) responses from the energy sector and one (1) from the commercial fisheries sector requested clarification on the selection process for the DPOs.

Table 13 Sectoral breakdown of responses to Question 11

Sector	Number of responses
	No comment	Commented	Total
Individual	6	23	29
Carbon capture and storage	-	1	1
Commercial fisheries	1	3	4
Energy	7	6	13
NA	4	13	17
Ports & harbours	-	1	1
Shipping	-	1	1
Tourism and recreation	1	1	2
Total	19	49	68

4.6 Question 12 - "Do you have any comments on the Sustainability Appraisal Report?"

4.6.1 Of the 65 responses received to question 12, twenty (20) stated that they did not have any comment to make. Table 14 breaks down the responses by sector.

Table 14 Sectoral breakdown of responses to Question 12

Sector	Number of responses
	No comment	Commented	Total
Individual	4	23	27
Commercial fisheries	1	4	5
Energy	6	10	16
NA	7	6	13
Ports & harbours	1	-	1
Shipping	-	1	1
Tourism and recreation	1	1	2
Total	20	45	65

4.6.2 A number of the comments made by individuals in relation to the Sustainability Appraisal are repeated from those made for the individual assessments. Additional comments from individuals include reiteration of the impacts on visual amenity (two (2) responses); and consideration that the assessments as a whole do not sufficiently assess impacts on fisheries.

4.6.3 Organisational responses similarly reflect a number of comments raised by respondents on Questions 8, 9 and 10. Broadly similar points raised included:

• Impacts on tourism;
• Visual impact;
• Impacts on a SSSI (SW1);
• Impacts on recreational boating (navigational safety);

4.6.4 In addition, two comments were raised which although not specific to the Sustainability Appraisal were not raised elsewhere. These were consideration of natural capital / ecosystem services (one (1) respondent) and consideration of the potential requirements for energy storage capacity to make wind energy viable, and the consequent impacts of this (one (1) respondent)

4.6.5 Specific to the Sustainability Appraisal, two (2) responses agreed with the assessments. Seven (7) responses from the Energy sector requested clarification regarding the proposed 'temporal planning' and a potential disparity between the SA versus the SEA. One (1) comment considered that the mitigation to cap development at 10 GW was not justified and no cap should be placed on the Plan. One (1) public body (statutory consultee) with specific expertise noted that they are strongly opposed to SW1 and NE6 on the basis of navigational safety.

4.7 Question 13 - "Would you add or change anything in the partial Equality Impact Assessment?"

4.7.1 Of the 39 responses received to question 13, 33 stated that they would not add or change anything within the partial Equality Impact Assessment, while three (3) responses stated that they did not know. Table 15 breaks down the responses by sector.

4.7.2 Of the three (3) responses proposing changes to the Equality Impact Assessment, one (1) individual requested further consideration of age discrimination, one (1) individual requested further consideration of the fisheries sector and one (1) organisational response requested additional information to be included on the importance of subsea cables (including the importance of telecommunications).

Table 15 Sectoral breakdown of responses to Question 13

Sector	Number of responses
	Yes	No	Don't know	Total
Commercial fisheries	-	2	-	2
Energy	-	9	1	10
NA	-	13	-	13
Ports & harbours	-	1	-	1
Power Interconnectors / telecoms	1	-	-	1
Shipping	-	1	-	1
Tourism and recreation	-	2	-	2
Individual	2	5	2	9
Total	3	33	3	39

4.8 Question 14 - "Would you add or change anything in the partial Islands Communities Impact Assessment?"

4.8.1 Of the 60 responses received to question 14, 46 stated that they would not add or change anything within the partial Islands Communities Impact Assessment, while two (2) responses stated that the did not know. Table 16 breaks down the responses by sector.

4.8.2 Of the three (3) individual responses submitted which proposed changes, two (2) suggested further information to be included regarding the benefits of offshore wind development by either reducing the need for more carbon intensive energy generation for isolated communities, and through potential for co-location with hydrogen / green fuel production retaining jobs in island communities as opposed to exporting energy to the national grid. The third agreed with the approach taken and emphasised the need for consultation with island communities

4.8.3 The nine (9) organisational responses tended to focus on the area of interest for each organisation. Two (2) responses highlight the importance of navigational safety to island communities, both regarding recreational boating and lifeline ferry services. Two (2) responses addressed fisheries, with one (1) recommending further information be collected for Shetland, and the other sought assurances that access to offshore wind development areas is retained, particularly for fixed gear fishermen. One (1) respondent highlighted the inclusion of subsea cabling as an industry of high importance for island communities in the provision of power / telecommunications.

4.8.4 One (1) organisation queried why a similar level of community assessment has not been applied for rural mainland communities.

Table 16 Sectoral breakdown of responses to Question 14

Sector	Number of responses
	Yes	No	Don't know	Total
Commercial fisheries	1	3	-	4
Energy	-	10	-	10
NA	5	11	-	16
Ports & harbours	-	1	-	1
Power Interconnectors / telecoms	1	-	-	1
Shipping	1	-	-	1
Tourism and recreation	1	1	-	2
Individual	3	20	2	25
Grand Total	12	46	2	60