Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Consultation Analysis and Modifications Report.

The Pentland Firth and Orkney Waters Marine Spatial Plan is a pilot process undertaken by a working group consisting of Marine Scotland, Orkney Islands Council and Highland Council in advance of statutory regional marine planning. This report presents an


28. Sectoral Policy 3: Oil and gas

28.1 Summary of responses received

Stakeholder Count
Commercial 2
Fisheries and aquaculture 0
Individual 1
Non-governmental organisation 1
Public sector 2
Recreation 1
TOTAL 7

28.2 Main themes

28.2.1 One response from a public sector stakeholder felt the lack of information on the impact the oil and gas sector can have on climate change was a significant omission.

28.2.2 The same respondent felt this chapter should set out the short, medium and long term approaches to this industry and that this policy should facilitate the transition to a low carbon economy.

28.2.3 A respondent from the recreational sector noted concerns that 'oil dollars' will always win over environmental matters or local impacts.

28.2.4 The Crown Estate noted that Carbon Capture and Storage ( CCS) is not mentioned in this policy but is mentioned in Sectoral Policy 10 Defence and suggested the reference is removed or text is added to this policy in relation to CCS.

28.2.5 The same respondent noted it was not clear from Map 16 where any conflict between ocean energy and offshore wind would occur and also suggested anchoring areas within Scapa Flow in relation to Ship-to-Ship transfers should be included on the map.

28.2.6 A public sector respondent noted the importance of this industry to the Plan area and it must be supported. The importance of engagement with this industry to ensure they are sighted of any modifications or changes within their areas of concern was noted.

28.2.7 Another respondent queried whether this policy covered shale gas and its various processes if this was ever found in the PFOW area.

Table 28.1 Sectoral Policy 3 Oil and gas - Table of suggested modifications

No. Suggested modification Action taken Reason
297 Clarification as to whether this policy is intended to cover shale gas. NEW PARAGRAPH 377 (now 378): 'No shale gas deposits or development pressures have been identified within the Plan area during the plan making process'. To accommodate request.
298 Add climate change impacts to the 'pressures' section. NEW PARAGRAPH 378 (now 379): Scotland will need a mixed energy portfolio, including hydrocarbons, to provide secure and affordable heat and electricity for decades to come. As use of renewable energy sources is increased, there is also a duty to minimise carbon emissions in line with climate change targets. The approach is one of careful stewardship of finite resources.
NEW PARAGRAPH 379 (now 380): The Scottish Government supports a low carbon economy which involves the move away from fossil fuels based energy consumption towards investment in renewable energy and increased energy efficiency. However, oil and gas are set to remain a vital source of energy while we move towards a future based upon renewable energy and it is sensible to secure reserves domestically as far as possible for as long as they may be needed.
Text added to note climate change targets and provide background to Scottish Government approach (provides background for next comment listed in row 299 as well).
Text consistent with National Marine Plan.
Outwith the scope of this Plan to set out the short, medium and long term approach to the oil and gas industry.
299 Set out the short, medium and long term approach to this industry. Text added (see row 298 above). Text consistent with National Marine Plan. Outwith the scope of this Plan to set out the short, medium and long term approach to the oil and gas industry.
300 Policy should facilitate transition to low carbon economy. New paragraphs 378 (now 379) and 379 (now 380) added as background information. To accommodate request.
301 Provide text on Carbon Capture and Storage in this policy or remove reference in Sectoral policy 10. Text on Carbon Capture and Storage removed from Sectoral Policy 10. Clarity.
302 Map 16. Clarify where conflict as mentioned in paragraphs 378-379 would occur. PARAGRAPH 378 (now 381): Second sentence changed to 'The main interactions in the Pentland Firth and Orkney Waters if there was further oil and gas related activity in this area are likely to be…..' Clarity.
303 Map 16. Add Ship-to-Ship anchorages in Scapa Flow. MAP 16: Anchoring areas within Scapa Flow in relation to Ship-to-Ship transfer added. To accommodate request.
304 Policy too long in relation to level of oil and gas activity in the Plan area. None. Noted.
305 The correct name (and has been for a while) for the Flotta Oil Terminal operator is Talisman Sinopec Energy UK Ltd - not Talisman Energy as shown in Sec Policy 3. As oil and gas - both in supply type vessels and tankers - is going to remain a relatively large industry for this part of Scotland for a while yet, perhaps there should be a cross reference to Sec Policies 3 (Oil & Gas), 6 (Maritime Transport) & 7 (Ports & Harbours) as there is a link between each?
In para 375 in Sec Policy 3 there appears to be a reference to "pollution matters" in the last sentence resting with the Scottish Government. Although at the beginning of this sentence there is a reference to emissions and discharges this may be lost to the general reader when the word pollution is used. Oil Pollution in the sea whether caused by a ship or terminal is the responsibility of the Harbour Authority / MCA all as per the National Contingency Plan - it is not a devolved matter. Perhaps this should be clarified in this para?
PARAGRAPH 369: Changed third sentence to 'The terminal operators, Talisman Sinopec Energy, signed….'. Text change in response to request. All policies are cross linked in some way so no specific need for referencing in this policy. Text in relation to Paragraph 375 has been drafted in close consultation with DECC to ensure it is correct.
306 Update to take account of establishment of Oil and Gas Authority and to clarify text. POLICY TEXT: First paragraph delete 'and when established' and 'new'. Third bullet point delete 'will', sixth bullet point delete 'must' and change 'take' to 'takes'. Updated text to take account of establishment of Oil and Gas Authority

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