Publication - Consultation analysis
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
33. Sectoral Policy 8: Pipelines, electricity and telecommunications infrastructure
33.1 Summary of responses received
| Stakeholder | Count |
|---|---|
| Commercial | 2 |
| Fisheries and aquaculture | 2 |
| Individual | 0 |
| Non-governmental organisation | 0 |
| Public sector | 5 |
| Recreation | 1 |
| TOTAL | 10 |
33.2 Main themes
33.2.1 One of the main themes of the responses to this policy was that it was worded differently to the other polices and respondents suggested several changes to the text. These are included in the table below.
33.2.2 A recreational sector respondent provided information on a revision that is underway by the Maritime and Coastguard Agency to Marine Guidance Note ( MGN) 371, which sets out requirements for UK navigational practice for developers of renewable energy installations. The revision will specify there should be no more than a 5% reduction in Chart Datum from cable protection and this is already an accepted practice.
33.2.3 Links with Local Development Plans was raised by two stakeholders (both public sector). One noted that network infrastructure such as that described in paragraphs 478 and 479 (now 484 and 485) could exert significant (particularly cumulative) impacts in the coastal zone. They noted that marine planning partnerships will need to have liaison and alignment with Local Development Plans to address landing points on the coast and suitable locations and routes for onshore and offshore grid infrastructure. The second respondent queried whether Local Development Plans make land allocations for such infrastructure and, if so, whether these could be included in the Plan.
33.2.4 Another public sector respondent highlighted that connectivity is a major factor in ensuring sectors can thrive in the PFOW and noted ongoing work on the 132kV Orkney/Caithness bootstrap and the Scottish Government's Digital Strategy will assist with the Plan's policy.
33.2.5 Scottish Water noted the proposal for colocation of existing pipeline corridors but stated they would wish to be consulted on a case by case basis where their assets may be affected.
33.2.6 Scottish Water noted they have contributed data on Urban Waste Water Treatment discharge locations to National Marine Plan interactive. However, they comment that to map some other infrastructure would be difficult owing to the numbers of locations. This would make accuracy an issue and could lead to a lack of consistency between marine regions.
Table 33.1 Sectoral Policy 8 Pipelines, electricity and telecommunications infrastructure - Table of suggested modifications
| No. | Suggested modification | Action taken | Reason |
|---|---|---|---|
| 366 | Para 463: Delete the words in parenthesis in the second line. | PARAGRAPH 463 (now 468): Deleted words in parenthesis. | Correction. |
| 367 | As with SP6 the format of SP8 is different to all others within the Plan. Consider a change of format. SP8 is also a long and wordy policy - could it be split into two smaller, simpler policies? | None. | Policy was drafted with a lot of stakeholder input and has been worded to be consistent with National Marine Plan wording agreed with stakeholders. |
| 368 | Insert word development into first paragraph for consistency between policies. | POLICY TEXT: First paragraph amended to 'Development(s) and/or activities'. | Consistency between policies. |
| 369 | The MCA are currently revising MGN 371 (which will have a different number), which sets out the requirements for UK navigational practice for developers of renewable energy installations. In this revision, MCA specifies that there should be no more than a 5% reduction in Chart Datum from cable protection and this is already an accepted principle, unless the developer can demonstrate there is no adverse impact on navigational safety. | NEW PARAGRAPH 470 (now 476): The Maritime and Coastguard Agency also provides guidance in Marine Guidance Note 371 (or subsequent updates) in relation to cables associated with Offshore Renewable Energy Installations. | To accommodate request. |
| 370 | Add reference to additional guidance in relation to submarine cables. | PARAGRAPH 468 (now 473): Changed to 'The Crown Estate has published and supported several publications 12 dealing with submarine cables….' and add link 12 http://www.thecrownestate.co.uk/media/5658/ei-km-in-pc-cables-082012-proximity-of-offshore-renewable-energy-installations-submarine-cable-infrastructure-in-uk-waters-guideline.pdf to FURTHER INFORMATION section. |
To accommodate request. |
| 371 | Existing and likely future Scottish Water assets, such as sea outfalls or drinking water pipelines, will be located within the geographical scope of the emerging marine spatial plan and should be recognised as performing essential functions. Planning should make provision for appropriate development and safeguard against potential uses which could conflict with infrastructure needs. | None. | Protection of existing and future Scottish Water assets is covered by text in paragraphs 460 (now 460) and 463 (now 468). |
| 372 | Scottish Water suggest 250m buffer zone, our outfalls and undersea pipelines may be vulnerable to damage from trailing anchors, fishing equipment etc. and care should be taken not to damage these assets. | None. | No specific guidance issued, 250m buffer is a suggested approach. |
| 373 | Page 177 Paragraph 460 SSEPD welcome the recognition that electricity distribution infrastructure is ultimately paid for by electricity bill payers in the north of Scotland and must therefore be economically justified. This principle must be considered in the approach to the installation of subsea cables, whether they be new installations or replacements of existing assets. SSEPD is undertaking a Cost Benefit Analysis approach to help inform the installation of future subsea cables and it is crucial that this process is supported by Marine Scotland and given appropriate weighting in the decision making process. The plan as currently drafted does not recognise that Transmission infrastructure may be installed in the future. SSEPD would therefore recommend the following change, or words to that effect: Currently States: "electricity distribution network…" Proposed Alteration: "electricity network" |
PARAGRAPH 460 (now 465): Deleted the word 'distribution' in last sentence. | Correction. |
| 374 | Page 177 - Paragraph 461 - Line 4 There are currently two distribution cables between Orkney and Caithness. SSEPD would therefore recommend the following change, or words to that effect: Currently States: "The existing cable between Orkney and Caithness is at full capacity…" Proposed Alteration: "The existing cables between Orkney and Caithness are at full capacity…" |
PARAGRAPH 461 (now 466): Changed to'...Orkney and Caithness are at full capacity...' and changed 'cable' to 'cables' in second sentence. | Correction. |
| 375 | Page 177 Paragraph 463 The plan as drafted discusses the fact that oil and gas and water need to be safeguarded but it does not recognise a similar requirement for power cables, which are essential infrastructure of national importance, providing key lifeline services for the island communities that depend upon it. SSEPD would therefore suggest electricity network infrastructure is recognised and supported to the same extent as that of oil and gas and water. |
PARAGRAPH 463 (now 468): Added text '….associated with the electricity network, communications, water supply….'. | To accommodate request. |
| 376 | Page 179 - Paragraph 473 - Line 1 The statement: "The most common proven cause of damage to submarine cables is ship anchors followed by risk from fishing activity" suggests that there is evidence to support it, hence the use of the word "proven". In SSEPD's experience its assets, in the majority, fail due to electrical failure or abrasive wear after +25 years of operation. In the absence of any substantive evidence to support the above statements as drafted, SSEPD would therefore request this is either amended accordingly to reflect SSEPD's experience of the common causes of cable faults, or evidence is provided to support the statement as currently drafted. |
PARAGRAPH 473 (now 479): Added numbered link to the word 'proven' to reference [Green, M. and Brooks, K. (2011) The Threat of Damage to Submarine Cables by the Anchors of Ships Underway. CIL- ICPC Workshop on the Protection of Submarine Cables 14-15 April 2011, Singapore. http://cil.nus.edu.sg/wp/wp-content/uploads/2011/04/Mick-Green-and-Keith-Brooks-The-Threat-of-Damage-to-Submarine-Cables-by-the-Anchors-of-Cables-Underway.pdf] and [International Cable Protection Committee (2009) Damage to Submarine Cables Caused by Anchors. Loss Prevention Bulletin 18 March 2009.] | To accommodate request. |
| 377 | Third sentence requires rewording, it is not clear what the word 'this ' refers to at the beginning of the sentence. | PARAGRAPH 473 (now 479):Text changed to 'Burial protects the cable….' | To improve clarity. |
| 378 | Page 179 - Paragraph 473 - Line 4 SSEPD believes there is a requirement on mariners to avoid conflict with subsea electricity infrastructure and this should be reflected within the Plan. SSEPD would therefore recommend the following change, or words to that effect: Currently States: "This protects the cable and minimises risk of interactions which can be a danger to maritime activity through snagging of the cable with fishing gear" Proposed Alteration: "Protecting the cable has the potential to minimise the risk of interactions with maritime activity, however, vessel operators still have a duty to avoid contact with existing and known submarine infrastructure to ensure the safety of the crew and vessel." |
None. | Already covered in paragraph 469 (now 474). |
| 379 | Page 179 Paragraph 475 SSEPD believe the plan should also recognise the requirement that cable routes are also required to be put on UK Hydrographic Charts. |
PARAGRAPH 475 (now 481): Added text at end of paragraph 'After laying, cable routes should be notified to UK Hydrographic Office ( UKHO) who will update charts in accordance with UKHO policy' | To accommodate request. |
| 380 | Page 180 - Paragraph 4 - Line 1 Currently States: "Any deposit, removal or dredging carried out for the purpose of executing emergency inspection or repair works to any cable is exempt from the marine licensing regime…" Query: SSEPD strongly support provisions to exempt emergency inspection or repair from the marine licensing regime which will help maintain electricity supplies to Scotland's island communities and allow for quicker repairs and restoration in the event of cable fault. However, it would be helpful to understand what would be deemed as a repair. Cable replacement can often be deemed the most preferred method to repair cable faults given it can be more economical, less impacting on seabed, more sustainable in terms of securing future electricity supplies and can have less impact on other marine users as well as allowing faster restoration than a cable repair. Clarity on whether this example would be exempt from marine licensing would be helpful. |
No changes to text. | Emergency inspection or repair works would be assessed on a case-by-case basis. |
| 381 | Page 180 Paragraph 5 Subsea Cables UK are a prominent force informing and promoting good "industry practice" which could be referenced here. |
None. | Already covered in paragraph 467 (now 472). |
| 382 | Page 180 - Paragraph 5 - Line 1 SSEPD supports the requirement for all policy and planning decision, including the installation of subsea cables, to be based on sound and robust evidence. SSEPD would therefore recommend the following change, or words to that effect: Currently States: "Cables should be suitably routed to provide sufficient requirements for installation and cable protection." Proposed Alteration: "Cables should be suitably routed to provide sufficient requirements for installation and, where deemed necessary and evidence based, cable protection." |
None. | Need for sound evidence is covered by the 'case-by-case' text in the second paragraph and the requirement for sound evidence in General Policy 1A and the National Marine Plan GEN 19. |
| 383 | Page 180 - Paragraph 6 - Line 1 SSEPD supports the requirement for all policy and planning decision, including the installation of subsea cables, to be based on sound and robust evidence. SSEPD also believes there is a requirement on mariners to avoid conflict with subsea electricity infrastructure. SSEPD would therefore recommend the following change, or words to that effect: Currently States: "Cables should be buried to maximise protection where there are safety or seabed stability risks and to reduce conflict with other marine users…" Proposed Alteration: "Cables should be buried to maximise protection where there are sufficient, evidence based, safety or seabed stability concerns identified. If required and feasible, burial may potentially reduce conflict with other marine users…" |
None. | Need for sound evidence is covered by the 'case-by-case' text in the second paragraph and the requirement for sound evidence in General Policy 1A and the National Marine Plan GEN 19. |
| 384 | Page 180 - Paragraph 7 - Line 1 SSEPD supports the requirement for all policy and planning decision, including the installation of subsea cables, to be based on sound and robust evidence. If protection is deemed necessary, following an evidenced based approach, SSEPD would therefore recommend the following change, or words to that effect: Currently States: "Where burial is demonstrated not to be feasible, cables may be suitably protected through recognised and approved measures (such as rock or mattress placement or cable armouring) where applicable and cost effective and as risk assessment direct." Proposed Alteration: "Where evidence determines that protection is a requirement and burial protection is demonstrated not to be feasible, cables may be suitably protected through recognised measures (such as rock or mattress placement , cable armouring, shore end marker beacons and admiralty charts updates) where applicable, cost effective and as risk assessment direct." |
POLICY TEXT: Added additional examples to sixth paragraph '...cable armouring, shore end marker beacons and admiralty chart updates) where practicable and cost-effective and as risk assessment direct'. | Need for sound evidence is covered by the 'case-by-case' text in the second paragraph and the requirement for sound evidence in General Policy 1A and the National Marine Plan GEN 19. |
| 385 | Page 181 - Paragraph 1 - Line 1 SSEPD conducts asset health checks of its subsea infrastructure as part of its overall maintenance programme. However, the Plan as drafted is unclear as to the expectations of post cable installation surveys and monitoring. Currently States: "The need to reinstate the seabed, undertake post-lay surveys and monitoring and carry out remedial action where required." Query: What are the expectations for post-lay surveys? Is this dependent on protection being applied or not? Greater clarity on this would be welcome. |
None. | This wording was agreed with stakeholders and is consistent with the National Marine Plan. |
| 386 | Page 182 - Map The Map doesn't highlight all SSEPD's existing cables. Accurate map provided in response. |
MAP 22: Updated to show existing cables. | Correction. |
| 387 | We are concerned that the policy does not explicitly state any support for new infrastructure of this sort - as opposed to a number of other sectoral policies. We suggest adding words that state; 'New infrastructure of these types will be supported where….'. | None. | Covered in paragraph 460 (now 465) and in policy text 'When laying or replacing electricity and telecommunciations….' |
| 388 | Do the Local Development Plans make any land allocations for such infrastructure which could be indicated in the MSP eg on proposed landfall requirements? | None. | Policy text notes the need to consider the appropriate policies in the relevant Local Development Plan(s) and there is ongoing work to produce supplementary guidance for these policies. |
| 389 | Para. 474 There should be a presumption for cable burial as safety in the marine environment is paramount. | None. | Text as phrased says cables 'should' be buried unless it is demonstrated not to be feasible. Risk assessments would be needed to demonstrate why the cable should not be buried and what alternative protection measures may be required. |
| 390 | Where cable burial is not possible, mitigation is vital to ensure compatibility and reduce conflict between sectors as in the UK Marine Policy Statement 2.2.1. | None. | The policy text notes cables should be buried unless it is demonstrated not be feasible. Risk assessments would be needed to demonstrate why the cable should not be buried and what alternative protection measures may be required. Policy text requires action to ensure compatibility and reduce conflict. |
Contact
There is a problem
Thanks for your feedback