Draft Sectoral Marine Plans for Offshore Renewable Energy in Scottish Waters - Sustainability Appraisal

2 Introduction to the Plans and Sustainability Appraisal

2.1 Introduction

2.1.1 The Marine and Coastal Access Act 2009 (Schedule 6 s10) states " a marine plan authority preparing a marine plan must carry out an appraisal of the sustainability of its proposals for inclusion in the plan". Whilst this applies to the statutory marine planning undertaken through the National Marine Plan process, the non-statutory sectoral plans for offshore wind, wave and tidal energy have also been subject to a Sustainability Appraisal ( SA) for consistency in approach.

2.1.2 The plans are required to undertake a Strategic Environmental Assessment ( SEA) under the Environment Assessment (Scotland) Act 2005 and the Environmental Assessment of Plans and Programmes Regulations 2004. The plans were also required to undertake a Habitats Regulations Appraisal ( HRA) under the Conservation (Natural Habitats, &c.) Regulations 1994 and The Conservation of Habitats and Species Regulations 2010. The technical reports are available online ^{1, 2}.

2.1.3 Furthermore Marine Scotland commissioned ABPMer and RPA to analyse the potential economic impacts of the Draft Plan Options on other activities that make use of the sea, and any consequent social impacts that could arise as a result of these. This analysis, ' Developing the Socio-economic Evidence Base for Offshore Renewable Energy Sectoral Marine Plans in Scottish Waters' ³ (henceforth the 'socio-economic assessment') is published as a supporting document to this Sustainability Appraisal.

2.1.4 The inputs from the SEA and HRA constitute the 'environment' sections of the SA. The socio-economic assessment has informed the 'people and health' and 'economy and other marine users' sections of this SA.

2.1.5 This SA report has been prepared to accompany the plans for offshore wind, wave and tidal energy and considers the relevant sustainability issues facing the potential development of offshore renewable energy. It also highlights the recommendations from the assessments for improving the sustainability of the plans for consideration.

2.1.6 The structure of this document is set out as follows:

• Section 1: Non-Technical Summary
• Section 2: Introduction to the Plans and Sustainability Appraisal
• Section 3: Findings of the SA for the Plan for Offshore Wind
• Section 4: Findings of the SA for the Plan for Wave
• Section 5: Findings of the SA for the Plan for Tidal
• Section 6: Cumulative Effects of Offshore Energy
• Section 7: Next Steps

2.1.7 This SA report is available for consultation alongside the plans, and the technical assessments ( SEA Environmental Report, HRA Record, and socio-economic evidence base report). Consultation opened in July 2013 and will run for a period of 16 weeks. Greater detail on the consultation is provided in section 5 of this report.

2.1.8 Throughout the 16 week consultation period, Marine Scotland will be holding a series of open meetings for stakeholders and members of the public to raise awareness of, and encourage further discussion on the Draft Plans and the Sustainability Appraisal. Locations and timings will be published on the Scottish Government website.

2.2 Evolution of the Plans for Wind, Wave and Tidal Energy

2.2.1 Marine Scotland is currently undertaking a review of its Sectoral Marine Plan for offshore wind energy development. Scottish Ministers adopted ' Blue Seas - Green Energy: the Plan for Offshore Wind Energy in Scottish Territorial Waters' in March 2011 ⁴ . ' Blue Seas Green Energy' set out a number of areas for offshore wind energy development including six 'sites' for development in the short term, and around 25 further 'areas of search' for consideration in the medium to longer term. It contained commitments to further research, data collection, stakeholder engagement and monitoring to accompany this programme of development. It also made a commitment to a 2 year review period, reflecting the fast pace of change within the offshore renewable sector and prompting the current revision of the plan.

2.2.2 ' Blue Seas, Green Energy' considers the potential of Scottish territorial waters to accommodate offshore wind energy developments in the short, medium and long term. It was also subject to a SA which comprised a SEA ⁵ , HRA ⁶ and socio-economic assessment ⁷ .

2.2.3 At the same time as the aforementioned review, Marine Scotland is also commencing preparation of Sectoral Marine Plans for Wave and Tidal Energy. A Marine Renewables SEA was undertaken during 2004-06 and an Environmental Report was published in 2007 which examined the environmental effects of developing wave and tidal power.

2.2.4 The 2007 SEA has been reviewed as part of the current SEA process, which in turn has informed this SA Report. It has also fed into the preparation and delivery of the Scottish Government's strategy for the development of marine energy in Scotland's marine environment out to 12 nautical miles. The 2007 SEA also provided marine developers with data on the most appropriate and best locations to place wave and tidal devices on the north and west coasts of Scotland; setting out the issues which had to be tackled to facilitate the breakthrough of the wave and tidal energy sectors.

2.2.5 The 2007 SEA reported that there were considerable marine renewable energy resources around Scotland and that there were also significant levels of existing users and constraints within the marine environment. The SEA highlighted that the sector would require locational guidance and simplified regulation and that uncertainties concerning environmental interactions with new technology deployments would need to be addressed. Since then on-going studies have been undertaken by The Crown Estate ( TCE) and Marine Scotland to identify suitable areas in Scottish territorial waters for wave and tidal development.

2.2.6 As a result of this activity Marine Scotland has developed a process of sectoral marine planning to identify the most sustainable locations in Scottish Waters for the development of commercial scale offshore renewable energy ⁸ . This has enabled the review of the Plan for Offshore Wind Energy in Scottish Territorial Waters has been undertaken alongside the production of new Sectoral Marine Plans for Wave and Tidal Energy technologies (' the draft plans').

2.2.7 The sectoral marine planning process firstly involved the production of a scoping study using of the Crown Estate Marine Resource System ( MaRS), a Geographic Information Systems ( GIS) based system that has enabled Marine Scotland Science to undertake a technical and scientific exercise to identify areas of constraint and opportunity. This identified strategic areas of search which were suitable for development.

2.2.8 Building upon the scoping study, the next stage of the process was the development of draft Regional Locational Guidance ( RLG). At this point, consideration was given to more detailed environmental, technical and socio-economic issues in relation to the strategic search areas identified in the scoping study. The resultant information was then made available online for informal comment in draft locational guidance. The areas of search were also published within draft Initial Plan Frameworks ( IPF). These early stage documents outlined the potential options for areas of search along with the process for developing the draft plans.

2.2.9 The draft RLGs and IPFs for the wind, wave and tidal plans were made available for an initial period of comment during a pre-consultation process during September and October 2012. The pre-consultation involved workshops held with sectoral stakeholders and organisations. Regional workshops were held in 10 locations across the country to engage with members of the public

2.2.10 The results of the consultation events and the information presented in the draft RLGs were used to refine the search areas to create Draft Plan Options that have been subject to this and the previously mentioned assessments. This report alongside the plans and technical assessments will be subject to consultation with statutory consultees and the public. All consultation responses received will be compiled and presented in a Consultation Analysis Report. This document will also provide an analysis of the key issues arising.

2.2.11 The issues and responses arising from the consultation on both the plans and the Sustainability Appraisal Report will then be used to inform the Final Sectoral Marine Plans, which will be put before Scottish Ministers for adoption. When the plans are adopted, a Post-Adoption Statement will be produced which will provide an account of the development of the plan post consultation and an audit of consultation exercise. See Figure 2.1 for the full plan making process.

Figure 2.1 Sectoral Marine Planning

2.3 Summary of the Draft Plan Options

2.3.1 The areas of search included within the draft RLG have now been developed into Draft Plan Options within the plans for offshore wind, wave and tidal energy. The Draft Plan Options constitute a range of alternative locations in which development might occur. At this stage of the process the plans do not stipulate whether all or some of the sites will be developed, and do not stipulate the number or precise type of device that might be developed. Furthermore, the boundaries of the sites are not fixed at this point and consultation with stakeholders may result in the requirement for amendments. Any proposals for change will occur after the consultation process, as a result of the analysis of responses. Therefore the Draft Plan Options represent distinct locational alternatives that could be subject to some level of change in the draft plans. It is these alternative locations that have been considered as part of the assessments. Figure 2.2 - 2.4 set out the Draft Plan Options. The draft plans provide further detail of the evolution of Draft Plan Options from the Areas of Search set out in Initial Plan Frameworks ( IPFs) for wind, wave and tidal energy.

2.3.2 The SEA and socio-economics assessment also considered alternative scenarios for the potential percentage occupancy of technologies within the Draft Plan Options as a whole. The socio-economics also considered scenarios for the indicative scale of development, in gigawatt (GW). Details of the location of Draft Plan Options and the scenarios follow.

Figure 2.2: Draft Plan Options for Wind Energy

Table 2.1: Details of scale and occupancy scenarios for wind energy

Scenario	Indicative Scale of Development (GW)	Indicative Occupancy (%)
Low	3	4.8 - 26.5
Medium	7	11.6 - 26.5
High	15	25.1 - 26.5

Figure 2.3: Draft Plan Options for Wave Energy

Table 2.2: Details of scale and occupancy scenarios for wave energy

Scenario	Indicative Scale of Development (GW)	Indicative Occupancy (%)
Low	0.5	0.2 - 0.6
Medium	1.25	0.5 - 0.6
High	2.5	1.0

Figure 2.4: Draft Plan Options for Tidal Energy

Table 2.3: Details of scale and occupancy scenarios for tidal energy

Scenario	Indicative Scale of Development (GW)	Indicative Occupancy (%)
Low	0.5	0.8 - 2.5
Medium	1.25	2.6
High	2.5	5.1

2.4 Approach to the Sustainability Appraisal

2.4.1 The full details of the approaches to each of the technical assessments are set out in each of the technical reports however the following sections provide a brief overview of the assessment processes.

Outline of the SEA

2.4.2 The SEA was undertaken in a number of stages and was overseen by a Project Steering Group, which included representatives of key stakeholders and consultees. The initial stage involved a review of relevant policies, programmes and strategies to identify relevant environmental objectives, and to compile a baseline of the current and future environmental issues and data that the plans were assessed against. This information was drawn from existing data sources available from SNH, SEPA, Historic Scotland, other environmental groups, and from Marine Scotland Science, and the draft RLGs produced by Marine Scotland.

2.4.3 The next stage of the assessment sought to identify the environmental effects associated with alternative offshore wind, wave and tidal technologies. This involved: reviewing research documents produced for Marine Scotland and the renewables industry; guidance on the effects of renewable energy devices produced by statutory consultees and important stakeholders; and the initial findings of project level environmental impact assessments and monitoring.

2.4.4 The results of the assessment of alternatives technologies helped to inform the next stage of work, identifying the environmental effects of the alternative Draft Plan Options. This assessment was led by baseline information relating to environmental receptors scoped into the report prepared in the initial phase of work. The assessment then involved identifying the potential for significant effects within the Draft Plan Options on the receptor and then proposed mitigation measures where relevant.

2.4.5 The next stage of the assessment considered the cumulative effects and included an assessment of the potential for effects associated with the alternative occupancy scenarios. Finally a high level summary of the effects of the plans as a whole on SEA objectives was undertaken.

2.4.6 The detailed findings of the assessment are set out within the environmental report however the headline findings identified are summarised below:

• The precise significance of effects will depend on the presence, location and sensitivity of environmental receptors and the pathways between the activities associated with construction and operation of devices.
• Some technologies are still developing and this adds a level of uncertainty to effects prediction, and as a result the level of significance of effects in many cases may only be determined as projects come forward. The SEA therefore sought to identify a level of risk for significant effects on a range of identified environmental receptors.
• The results of the monitoring of the effects of initial projects as they are deployed, alongside the results of ongoing and further research should be drawn together to inform a formal plan review process.
• Development of technologies can support the transition to low carbon energy production and support Scotland's carbon emission targets.
• Devices could have effects on biodiversity, either as a result of direct effects on seabed habitats or interactions with mobile marine species (birds, fish and mammals). However, the nature and significance of these interactions in some cases remains unknown and further research and monitoring of developments is recommended.
• Some technologies, wind devices in particular, may have effects for landscape, seascape and the setting of some features of the historic environment, although the significance of effects can reduce with distance from the shoreline. Whilst several near shore wave and tidal devices may be predominantly under the water, some effects may result from infrastructure and lighting associated with the devices.
• Some effects on recreational users could result, particularly as a result of potential displacement of users from any exclusion zones, and resulting concentration of vessels in areas outside of these.
• There may be effects as a result of changes to the complex patterns of hydrodynamics and sedimentation for water quality and coastal processes, and these will require further consideration as projects are developed.

Outline of the HRA

2.4.7 The HRA was taken forward in line with HRA Guidelines published by SNH in 2012 ⁹ and was overseen by a Project Steering Group which included representatives of key stakeholders and consultees. Separate HRAs were undertaken for each of the Sectoral Marine Plans, but it was recognised that a substantial amount of information will be common across all three plan processes. Therefore, five joint documents were created (a pre-screening report, screening report, information for Appropriate Assessment, in-combination effects and plan implementation review, and a non-technical summary review). Within these documents clear distinctions were made between the differing sensitivities of key species and habitats to the various technologies. This is because of the precautionary nature of the HRA process and the fact that there remain numerous uncertainties about the nature of future developments and about the impacts of these plans on their own, together and in-combination with other plans or projects.

2.4.8 The initial stage of the HRA was pre-screening. This was to confirm the need for, and scope of, an HRA and then identify the designated European/Ramsar sites and their interest features that could be affected by the Sectoral Plans.

2.4.9 As a first step in this review, the possible impacts of energy generation projects were reviewed and a list of 20 key "impact pathway" categories were identified. Then, in very broad terms, a list of the potentially affected designated sites was assembled, pending a more detailed review within the screening report. This site selection process including all the designated sites that lie within 100km of the 28 option areas for wind, wave and tidal energy generation. This arbitrary boundary was used as a quantifiable and objective area that is likely to encompass many of the mobile species interest features (fish, seabirds and mammals) in sites which could be indirectly affected by projects within the Draft Plan Options. This stage also set out a methodology for undertaking a further screening assessment.

2.4.10 The next stage, screening, used the methods that were identified in the pre-screening report to create a final list of designated sites, and their qualifying interest habitats and species, for which there could be a likely significant effect ( LSE) from the draft plans. These sites and features were then taken forward into the subsequent assessment phase. At this stage potential measures for limiting the effects of plans cannot rule out LSE and as a result all sites and features were considered in the next phase. Further details of the screening process are available in the HRA Report and Non-Technical Summary.

2.4.11 The next stage of the HRA was the Appropriate Assessment Information Report ( AAIR), which assembles the information required to complete an Appropriate Assessment ( AA). Building upon the information already assembled during the pre-screening and screening work, the review included the following details:

• An overview of activities and changes that will arise under the Sectoral Marine Plans that could have an impact on the key marine habitats and species groups;
• A review of the sensitivities to impact of the key marine habitats and species groups identified; and
• An assessment of the impacts on each habitat and species groups in view of the available (and generic) conservation objectives;

2.4.12 The conclusion of this assessment is that it was necessary for two "additional mitigation measures" to be applied in order to ensure that the Sectoral Marine Plans will have no adverse effects on the integrity ( AEOI) on any designated sites either alone or in-combination with other plans or projects. These measures are:

• The legal requirement for individual projects to undergo HRA; and
• The implementation of the Plans through an iterative plan review ( IRP) process.

2.4.13 Details about the project-level requirements and the IPR process were set out in summary within the AAIR and in greater detail within the next reporting stage of the HRA which was the in-combination effects and plan implementation report. This fourth report assessed the effects of the Draft Plan Options on the European sites in combination with a number of plans and projects identified within the HRA. These include coastal development projects, planned offshore renewables developments and areas of lease, and strategies for renewable energy in UK waters.

2.4.14 The in-combination review was, necessarily, conducted at a high level. It is recognised that the assessment of in-combination effects will need to be revisited and addressed in a more comprehensive way at the project-level when more detailed information is available. The conclusion from this work reinforced the findings from the AAIR and noted that the uncertainties that exist about the scale, location and timing of project developments this Plan-level.

Outline of the Socio-Economic Assessment

2.4.15 The social and economic analyses in the Sustainability Appraisal are based on the findings of the socio-economic assessment, which was commissioned by Marine Scotland and undertaken by ABPmer and RPA. This study focussed on assessing potential economic impacts that could arise as a result of interactions between Draft Plan Options and other marine activities taking place in the same area, and any social impacts that could potentially arise as a consequence. The analysis was based on consideration of Draft Plan Options, but has been reported at a regional level, due to the strategic nature of the plans. The project was steered by a Project Steering Group and advised by a Project Advisory Group, which consisted of members of the Scottish Government, plus stakeholder representatives from NGOs, marine activities (including renewable energy interests), local government, the Crown Estate, and the Enterprise Agencies.

2.4.16 A detailed discussion of the methods and analytical approach employed in the study is given in Chapter 2 and Appendix B of the socio-economic assessment. Potential impacts on other marine activities arising from Draft Plan Options have been assessed on the basis of potential additional energy generation capacity across different technologies that could be installed under different development 'scenarios' ¹⁰ , over and above capacity that is already included within 'baseline' capacity ( i.e. developments in the planning system, or for which leases and/or licences have been granted). Portions of additional generation capacity are allocated across Draft Plan Option areas on a spatial 'pro-rata' basis, based on evidence-based assumptions as to the spatial footprint of 1MW of generating capacity for different technologies, and subject to a share of generation capacity in the Draft Plan Option areas exceeding a 'minimum' capacity required for commercially viable projects.

2.4.17 The report has assumed that the development of arrays within the Draft Plan Option areas will take place after 2020. For the purposes of the analysis, the study assumes that construction of any arrays developed following this sectoral planning process begins in 2023, and that those arrays will be operational by 2025. However, it is recognised that this is a simplifying assumption for purposes of the analysis, and that development in individual areas could begin earlier or later than this, depending on developer, market and site circumstances.

2.4.18 The assessment of the potential impacts of offshore renewable arrays is based on the assumption that the main impact pathways relevant to the analysis are: the potential for exclusion of marine activities from marine space 'occupied' by future arrays; or the potential for impacts arising from the alteration of seascape on activities.

2.4.19 A scoping exercise was undertaken to assess the potential for significant interactions between renewable arrays and other marine activities in each Draft Plan Option area. In areas where this was identified, the analysis attempted to quantify and apply monetary valuations to the resulting impacts as far as possible. This has been attempted for both negative impacts (which create costs) and positive impacts (which create benefits). Where it was not possible to provide monetary valuations, qualitative or qualitative assessments were made. Similar analysis was undertaken for hypothetical cable routes between arrays and the mainland.

2.4.20 When undertaking qualitative or quantitative analysis of the scale of impacts, and when valuing costs and benefits arising for other marine activities from Draft Plan Options, the scale of those impacts has been assessed relative to a 'do nothing' option. This option represents what could potentially occur in a Draft Plan Option area, were that Draft Plan Option not to be taken forward. The impacts assessed, and the quantified and unquantified costs and benefits identified as a result, therefore represent those impacts, costs and benefits that would not have arisen in the absence of Draft Plan Options being developed.

2.4.21 The assessment takes place over a 20 year period starting from the time at which decisions over the content of the final plans are likely to be made (it is assumed that decisions over the content of the final plans will be made in 2014, following a public consultation in summer 2013). As previously stated it is assumed that that construction of any arrays developed following this sectoral planning process will commence in 2023, and that those arrays will be operational by 2025. Where it has been possible to estimate monetary values for costs and benefits over the appraisal period, these have been converted into present values (in line with HM Treasury Green Book guidance) to reflect the value of future costs and benefits in today's terms.

2.4.22 The socio-economic assessment has also attempted to assess the potential social impacts that could arise as a consequence of costs and benefits from development of offshore renewable arrays within Draft Plan Option areas. The social analysis has identified the potential ways in which economic costs and benefits might have social impacts, what social groups ( e.g. different age groups, minority groups, genders, and specific geographical communities) could potentially experience these impacts, and in what way they might experience them ( e.g. through changes to employment environment, health and access to services). This analysis also attempts to identify the significance of these impacts and effects, but is largely qualitative in nature. The methodology underpinning the social analysis is described in more detail in Chapter 2.4.4 of the socio-economic assessment.

2.4.23 Where potential impacts will need up-front mitigation by the developer, as a condition of consent, the socio-economic assessment has assumed that the residual impacts will not give rise to significant socio-economic impacts. The mitigation costs to be met by the developer have not been included in the costs presented in the assessments described within the study. For example, in the case of potential impacts to aviation radar, mitigation by the developer will therefore mean significant impacts to the aviation sector will be avoided.

2.4.24 Similarly, where potential socio-economic impacts are consequential on potential environmental impacts, it has been assumed that mitigation will be required for such impacts as a condition of consent and the residual environmental impacts will not give rise to significant socio-economic impacts. It is recognised that this is a simplification and that in some cases, as indicated by the SEA, the likelihood of significant environmental impacts occurring is not well understood, for example in relation to collision risk between mobile species and tidal stream generators or the impacts of electromagnetic fields on electro- and magneto-sensitive species.

2.4.25 There are a range of issues and uncertainties associated with this analysis. These include:

• Uncertainty over the location of Draft Plan Options that will be developed in the future, the portions of individual Draft Plan Options that will be developed, and intensity of development within individual Draft Plan Options;
• Uncertainty over the timing of developments (and therefore time when impacts are realised);
• Uncertainty over the nature and scale of impacts on other marine activities, with potential for sensitive marine planning to mitigate some of these;
• Uncertainty around location and intensity of other marine activities in the future ( i.e. uncertainty over whether they will be the same as today) and responses of marine activities to development of arrays ( e.g. will fisheries be displaced, or cease);
• Uncertainty as to the technology types that will be developed and rolled-out on a commercial scale, and the associated interactions these could have with other marine activities (particularly in the case of wave and tidal devices);
• Lack of available data or valuation evidence limiting opportunities for valuation of some costs, benefits and impacts, or impacting on the accuracy of valuation of specific impacts ( e.g. impacts on tourism, leisure and recreation activities);
• The potential for displacement of fishing activity has not been quantified in the consideration of fishing impacts, owing to the difficulties inherent in undertaking such analysis, and the wide range of factors that could influence the nature and extent of any displacement. Instead, the fishing analysis for each region and scenario considers and values a 'worst case' outcome, where the value of catch extracted from each Draft Plan Option area is not replaced by catch from other areas. In practice, however, this is unlikely to be the case, and fishing vessels may be expected to adjust their operations in order to target different fishing grounds and/or different species. Consequently, estimates of costs to the fishing industry have the potential to be overestimated.
• While impacts and their significance are assessed at regional and national levels, they may accrue and be felt to be more significant at local levels ( e.g. at the level of individual settlements). This is particularly important for (but not restricted to) social analysis.

2.4.26 The detailed findings of the assessment are set out within the socio-economic report however the headline findings identified are summarised below:

• The Present Value of the quantified costs range from £8.1m (Low Scenario) to £161m (High Scenario).
• The quantified potential cost impacts to commercial shipping accounted for around 70-90% of total quantified costs, depending on scenario.
• At a national level, the combined impact of the commercial fisheries sector in terms of impacts to Gross Value Added ( GVA) as a result of potential reductions in landings is estimated to be less than 1% of total GVA.
• The impact of renewable development sites on recreational boating is recognised as a deterrent and partly economic where a deviation is encountered to avoid development areas.
• A number of potential impacts have been identified for competing offshore renewables technologies, both in relation to competition for space and cable land falls. The combined impact of these interactions is uncertain.
• Most of the social impacts are limited to localised effects and even these are generally expected to be small.
• No significant benefits to activities could be quantified.

Outline of the Sustainability Appraisal

2.4.27 This integrated Sustainability Appraisal ( SA) provides an overview of the potential social, economic and environmental effects for the development of wind, wave and tidal devices within the alternative Draft Plan Options. It enables the potential cumulative impacts on the environment, on communities and on other sea users to be considered in a cohesive fashion and for recommendations of a holistic nature to be drawn.

2.4.28 This SA reports provides the means to synthesise the results of the assessments to enable the plan to draw upon this information in its development. Therefore, this SA does not itself involve further detailed assessment, rather concentrating on the consideration of the findings and proposing mitigation measures.

2.4.29 The SA firstly summarises the key environmental, economic and social effects of the plans for offshore wind, wave and tidal energy in turn (see sections 3 to 5), presenting these at both the regional and national level identifying key effects. Where possible relevant recommendations, mitigation and monitoring have been identified and discussed. The SA then looks at cumulative effects across all three plans, and where possible, discussing recommendations for the draft plans.