Draft Sectoral Marine Plans for Offshore Renewable Energy in Scottish Waters- Strategic Environmental Assessment: Environmental Report and Appendix A

3 The Approach to the Assessment

3.1 Overview

3.1.1 The alternatives, as described in Section 2.8, provide the basis for the assessments of the draft plans. The SEA and draft plan processes were undertaken alongside each other in order for the results of the SEA, together with the results of the HRA and Socio-Economic Assessment, to inform the development of the final draft plans. The following Section sets out the approach to the assessment.

3.2 Scoping the Assessment

3.2.1 Scoping reports were produced in August 2012 for the wind energy plan and a joint scoping in July 2011 for the wave and tidal plans. These were consulted upon with the statutory bodies. The reports set out the approach to the assessments of the plans, which this assessment is based upon, and the information required for the assessment. During this process it was determined that the air quality topic would be scoped out of the assessment, as at a national level the Plan's effects on it will not be significant.

3.2.2 The material assets topic has now also been scoped out of this project, as set out in the wave and tidal scoping. Whilst this topic could cover a range of material to covering the effects on other marine users it is felt that these have been adequately considered within the assessments. The impacts on commercial fisheries, including the potential for long term displacement of fishing activities, will be covered within the socio-economic assessment. The potential for effects on spawning and nursery grounds have been covered, as far as possible, within the biodiversity, flora and fauna section of this SEA. The socio-economic assessment will also consider displacement of commercial shipping, recreational boating and tourism. Issues of navigational safety and collision risk for vessels have been covered, as far as possible, within the population and human health section of this SEA.

3.2.3 Consultation responses on the scoping reports have been reviewed and where appropriate have been built into the assessments. The approach to the assessments is set out below.

3.3 Approach to the Assessment

3.3.1 The first phase of the assessment was the assessment of alternative technologies. The purpose of this stage was to identify the range of potential effects that could result from the installation and operation of wind, wave and tidal energy devices in the marine environment. The assessment has drawn on a number of different sources of information. This included the results of previous SEAs, research studies including those undertaken for Marine Scotland and by the marine energy industry, guidance for the environmental assessment of devices, and available Environmental Impact Assessments of marine renewable energy projects where relevant. The detail of the assessment of technologies is documented in Appendix C.

3.3.2 The design of some device technology is still developing with testing and refining ongoing, in particular tidal technologies but also some wave. Therefore the potential effects specific to an individual technology or device may at this stage be uncertain. Whilst they may ultimately provide solutions for development within Draft Plan Options, as yet potential impacts for commercial scale deployment may have not yet been fully ascertained. In these instances professional judgement has been used to consider whether the effects of similar technologies would also be applicable. Where this is the case it has been documented within Appendix C.

3.3.3 During the development of this assessment, stakeholders included within the project advisory group ( PAG) recommended that relevant environmental information on potential impacts could be reviewed and drawn, as far as possible, into the assessment from the Environmental Impact Assessment ( EIA) process of existing or emerging offshore wind, wave and tidal projects. Whilst it is acknowledged that many environmental effects are likely to be dependent on site specific factors, the findings of previous project level assessments undertaken around the Scottish coastline have helped to broadly identify potential issues and environmental impacts that may, in general terms, be associated with different renewable technologies in the coastal and marine environment.

3.3.4 Stakeholders in the PAG also indicated that some of the information available in EIAs is currently under review within the marine licensing and consenting process, and is yet to be validated by the wider sector. For this reason, a detailed review of EIAs has not been formally presented within this report. As such it is just their more general findings that have been incorporated into this assessment.

3.3.5 In some instances some of the general findings of project level information have also fed into the consideration of potential cumulative impacts associated with plan option areas. Specifically, those in the close vicinity of existing of emerging offshore renewables developments ( e.g. in Orkney, Shetland, Western Isles, Aberdeenshire coast and the Solway Firth).

3.3.6 However, as project level EIA work progresses, and data is obtained through further investigative work at the consenting stage and via operational monitoring programmes, this information could then be used in a more formal basis to help feed into the evidence base of future plan level assessment.

3.3.7 Once the evidence base was established and the potential impacts of the devices were established, the second stage of assessment was undertaken. This encompassed an assessment of each of the alternative Draft Plan Options against the environmental baseline, reflecting on the environmental features of the option areas and the potential effects identified in the assessment of technologies.

3.3.8 The assessment methodology followed the tabular approach set out at the scoping stage, and involved the completion of a table for each Draft Plan Option and for each SEA topic scoped into the assessment, as shown by Table 3.1. Given the amount of relevant baseline information required for the assessment and presented in Appendix B, the first column of the table highlights only the key relevant headline baseline information for an individual Draft Plan Option, rather than all of the detail considered in the assessment. This provided a means for the relevant environmental baseline and problems to be a key component of the framework for the assessment. This approach is known as a 'baseline-led assessment' and sets the context of Draft Plan Options within their receiving environment.

3.3.9 The second column discussed the potential effects of developing the type of device promoted within the Draft Plan Option, on the receiving environment. The third column describes the characteristic of the effect. This provides a summary of the relevant dimensions of effects set out in Schedule 3 (6) of the Environmental Assessment (Scotland) Act 2005. This includes the timescale of effects, whether effects are permanent or temporary, positive or negative, and whether there are particular secondary, cumulative or synergistic effects where these could be determined and relevant to the assessment of significance.

3.3.10 The final column considers the potential mitigation that might be available to prevent, reduce and as fully as possible offset any significant adverse effects. The results of these assessments are set out in Appendix D.

Table 3.1: Example Assessment Table

SEA Topic	Key Baseline Evidence	Potential for Effects	Characteristics	Mitigation Available and Potential Residual Effects
Biodiversity, Flora and Fauna
Etc.

3.3.11 The next stage of the assessment was the cumulative assessment. This sought to firstly identify the potential impacts of development of devices in multiple Draft Plan Options, then investigated the effects of the Draft Plan Options alongside the developments set out in previous plans and the projects in development. This stage of assessment was informed by the SEA of existing plans and the general effects identified in reviewing project level EIA. As part of this process the assessment considered the broad scenarios for high, medium and low occupancy of the total Draft Plan Options set out in Section 2.8.

3.3.12 The assessments of individual Draft Plan Options, alongside the range of effects of potential devices, demonstrate the difficulties in apportioning the precise significance of effects. As a result the cumulative impact assessment has been informed by a risk-based approach. This seeks to identify where higher risks of significant effects might occur, whilst acknowledging that the identification of potential effects will continue through the project level EIA process. Table 3.2 sets out the rules that have been used to guide this risk based approach.

Table 3.2: Risk Based Approach Used in this Report

Lower Risk	Medium Risk	Higher Risk
Based on the best available information whilst the environmental receptor may be impacted, the value and vulnerability of the environmental receptor is considered to be lower ( e.g. whilst considered important the species or areas are undesignated or not considered to be of particular value or sensitivity, the environmental receptor may be considered replaceable). Based on the best available information the number and extent of environmental receptors, potentially impacted, is considered low ( e.g. species, people, designations, in light of the relative to the total size and extent of the environmental receptor). Whilst there is potentially a link or pathway between the type of renewable technology and the environmental receptor is not considered to be direct. Effects are likely to occur only in the short term ( e.g. associated with the construction phase only)	Based on the best available information the environmental receptor may be impacted, although this may not be certain, and the value and vulnerability of the environmental receptor is not considered to be particularly high ( e.g. local designations and features of interest, acknowledged importance of species, the environmental receptor is sensitive and/or difficult to replace). Based on the best available information the number and extent of environmental receptors, potentially impacted, is considered to be notable ( e.g. species, people, designations, in light of the relative to the total size and extent of the environmental receptor). There is a clear link or pathway between the type of renewable technology and the environmental receptor under consideration. Effects are likely to occur only in the short and medium term ( e.g. initial loss of features or designations but that might recover in the long term).	Based on the best available information whilst the environmental receptor will be impacted, and the value and vulnerability of the environmental receptor is considered to be high ( e.g. international level designations of species or areas containing important features, the environmental receptor is very sensitive and/or irreplaceable). Based on the best available information the number and extent of environmental receptors, potentially impacted, is considered to be notable and significant to the point that the features within any location might be lost ( e.g. species, people, designations, in light of the relative to the total size and extent of the environmental receptor). There is a clear and strong link or pathway between the type of renewable technology and the environmental receptor under consideration. Effects may occur from the short term but are likely to also be long term ( e.g. loss of features or designations that cannot recover)

3.3.13 The final stage of the assessment provides a means to summarise the overall effects of the draft plans against the SEA objectives identified in the scoping phase. The objectives are aspirational and formed from the objectives of wider plans, programmes and strategies set out in Appendix A. This 'objective led approach' provides a useful measure to draw together and comment on the combined performance of the plans. The SEA objectives are set out later in the Table 3.3

Table 3.3: SEA Objectives

SEA Objectives
Biodiversity, Flora and Fauna
To safeguard marine and coastal ecosystems, and their interactions.
To avoid adverse effects on the integrity of Natura sites ( NB: this will be established through the parallel HRA work)
Population and Human Health
To avoid adversely affecting recreational users.
To avoid adverse effects on human health and safety.
Water and the Marine Environment
To avoid pollution of the coastal and marine water environment.
To maintain or work towards good ecological status.
Climatic Factors
To reduce greenhouse gas emissions from the energy sector.
To ensure that adaptation to climate change impacts are taken into account, e.g. through consideration of resilience, changing environmental sensitivity
Marine Geology and Coastal Processes
To avoid exacerbating coastal erosion.
To maintain integrity of coastal processes
To maintain and protect the character and integrity of the seabed
Historic Environment
To protect and, where appropriate, enhance the historic marine environment.
To avoid damage to known and unknown coastal and marine archaeology.
To avoid adverse effects on the character and setting of historic sites and buildings.
Landscape / Seascape
To avoid where possible, or minimise, adverse effects on landscape/seascape
To promote the protection of seascape and coastal landscapes
To avoid or minimise adverse visual effects

3.4 Meeting the Requirements of the 2005 Act

3.4.1 The following table sets out how this report has set out to meet the requirements of the Environmental Assessment (Scotland) Act 2005. The text in bold indicates which part of the requirement can be located at the signposted section.

Table 3.4: Compliance checklist

2005 Act Requirements for Environmental Reports	Location within this Report
An outline of the contents and main objectives of the plan or programme, and of its relationship (if any) with other qualifying plans and programmes (Schedule 3 (1)).	Section 2
An outline of the contents and main objectives of the plan or programme, and of its relationship (if any) with other qualifying plans and programmes (Schedule 3 (1)).	Section 2 and Section 4.2
The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme (Schedule 3 (2)).	Section 5 and Appendix B
The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme (Schedule 3 (2)).	Section 5
The environmental characteristics of areas likely to be significantly affected (Schedule 3 (3)).	Section 5 and Appendix B
Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Council Directive 79/409/ EEC on the conservation of wild birds and Council Directive 92/43/ EEC on the conservation of natural habitats and of wild flora and fauna (as last amended by Council Directive 97/62/ EC) (Schedule 3 (4)).	Section 5 and Appendix B
The environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation (Schedule 3 (5)).	Section 4 and Appendix A
The environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation (Schedule 3 (5)).	Section 4 and Appendix A
The likely significant effects on the environment, including- (a) on issues such as- (i)biodiversity; (ii) population; (iii) human health; (iv) fauna; (v) flora; (vi) soil; (vii) water; (viii) air; (ix) climatic factors; (x) material assets; (xi) cultural heritage, including architectural and archaeological heritage; (xii) landscape; and (xiii) the inter-relationship between the issues referred to in heads (i) to (xii); (b) short, medium and long-term effects; (c) permanent and temporary effects; (d) positive and negative effects; and (e) secondary, cumulative and synergistic effects (Schedule 3 (6)).	Section 6 and Appendix C and D
The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme (Schedule 3 (7)).	Section 6 and 7, Appendix C and D
An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of expertise) encountered in compiling the required information (Schedule 3 (8)).	Section 2.8
An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of expertise) encountered in compiling the required information (Schedule 3 (8)).	Section 3
A description of the measures envisaged concerning monitoring in accordance with section 19 (Schedule 3 (9)).	Section 7
A non-technical summary of the information provided under paragraphs 1 to 9 (Schedule 3 (10)).	Section 1

3.5 Difficulties encountered in compiling the Information

3.5.1 Whilst new information on the marine environment continues to emerge there remain some uncertainties regarding the interactions between marine features and potential new marine infrastructure.

3.5.2 Whilst a great deal of research has been undertaken on Scotland's marine and coastal environments through public bodies such as Marine Scotland Science and SNH, and in academic and industry sectors, it is widely acknowledged that significant data gaps remain. In some instances, these gaps in knowledge have introduced a degree of difficulty in undertaking this assessment, primarily in the compilation of relevant and useful baseline information, and in the evaluation of the likelihood and extent of potential effects that may be associated with particular renewable devices.

3.5.3 As a result there is difficulty in the certainty of effects prediction within the assessments, introducing a necessarily degree of caution in both predicted significance of effects and recommendations for the response to these. For example, more comprehensive information regarding the movements of migratory species such as cetaceans, salmon and lamprey, seabirds and elasmobranchs could have added greater detail and precision to the assessment, however reliable and accepted information is yet to be available. Had this been available it would have the potential to provide a better steer on the potential for impacts in a spatial context, and a stronger link to the Draft Plan Option areas.

3.5.4 Uncertainty in the likelihood and severity of specific potential impacts of devices has introduced a degree of uncertainty into the assessment. Examples include the precise effects of Electromagnetic Forces ( EMF) on elasmobranchs and other fish, the collision and entanglement risk for cetaceans and seal with submerged infrastructure, and the precise level of sedimentation impacts from installing technologies and the ability of benthic habitats to withstand this.

3.5.5 During the course of the assessment a number of data sources have been used to provide a picture of the key environmental constraints and issues. Given the wide variety of above and below water species and features that have been considered in the assessment, where possible some 'interpretive' data sources were reviewed in order to attempt to provide a better spatial picture of use and potential effects. Cetacean and basking sharks distributions, and potential seabird displacement and collision risk, has been included in the baseline in an attempt to provide this spatial picture. These interpretations are based on the best available data. It is acknowledged that data sets may be older and incomplete.

3.5.6 Views expressed on the use of this information from the PAG have been mixed. It is acknowledged that the use of these data sources involves grouping of marine features ( i.e. all cetaceans and seabirds), and that this adds a degree of uncertainty to their results. For example an area with a lower cetacean encounter rate may still contain the majority of sightings of a rarer species. Therefore, the use of encounter rates as an indicator of distribution can introduce the potential for bias towards more larger and more prominent species over those with smaller population size and more vulnerable species. Similarly, an area with a lower collision risk for seabirds could still be frequented at times by an individual species most at risk from collision.

3.5.7 Where interpretive data has been used within this assessment it has been used to simply provide an indication of potential 'hot spots', rather than identification of areas with limited constraints, with the uncertainty in the use of the data noted. This helps to add a slightly more informed picture of spatial risk to some mobile species.

3.5.8 In some instances, where the potential benefit and scope for additional research has been identified in order to fill gaps in data and our understanding of effects, recommendations have been included in this assessment. The results of the Review of the Scottish Marine Monitoring Network undertaken for Marine Scotland ^[11] will also help to demonstrate information that could fill some of these gaps.

3.5.9 Further uncertainties remain within in the assessment and are inherent with the continual evolution of offshore renewables technologies and infrastructure. As new devices are designed and tested some potential effects could diminish and others arise. For example, below water wave technology could have reduced landscape effects but potentially increased collision risk.

3.5.10 Furthermore, marine planning in itself is new and evolving, reflected in concurrent consultation on the National Marine Plan ( NMP), and Marine Protection Areas ( MPAs). As consultations on these documents have not been undertaken at the time of assessment there remains some uncertainty on their final content. Therefore, the location and extent of final MPA boundaries are yet to be finalised, and as a result there is uncertainty over the extent of overlaps between proposed MPA and Draft Plan Options. Therefore there is a need to revisit this relationship after the end of the consultation period.

3.5.11 There remains a degree of uncertainty surrounding the potential impacts of some supporting activities as a result of the precise location of activities being unknown. For example, the location of dredging that might be required to provide fill for gravity base devices, and the precise location of onshore/offshore grid connections and cables linking devices to the electricity grid. Where possible the potential and general effects of these activities are mentioned within the assessments but have a limited spatial focus as acknowledged in the appropriate sections of this report.

3.5.12 Many of these gaps, limitations and difficulties have fed into the generation of recommendations as set out in Section 7 of this report.