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


40. Regional Locational Guidance

40.1 Summary of responses received

Stakeholder Count
Commercial 2
Fisheries and aquaculture 1
Individual 1
Non-governmental organisation 1
Public sector 3
Recreation 1
TOTAL 9

40.2 Main themes

40.2.1 The majority of respondents suggested changes and corrections based on their knowledge of the particular sector they were representing. These are listed in the table below.

40.2.2 Other comments were in relation to the status of the Regional Locational Guidance and the process for updating the information contained within it. One respondent commented it needed to be clear how this document differed from Regional Locational Guidance produced for the Sectoral Plans. Another respondent felt it offered limited added value to information already available on National Marine Planning Interactive and the Sectoral Plans.

40.2.3 The same respondent noted that they anticipated future marine planning partnerships would go beyond presentation of existing spatial data in maps to bespoke analysis of spatial data layers within their region. They noted this would refine existing sectoral option areas and provide more understanding of likely spatial constraints or opportunities for future development.

40.2.4 One respondent felt the Plan Options needed to be revisited to take account of the challenges relating to wind climate and grid connection in offshore wind areas and also the increasing interest in floating wind devices.

40.2.5 The working group also made corrections and updates to the document during the editing process. Some of these are listed below but minor changes and references to more up to date documents are not. Many of the figures have been updated with more up to date information, this will be an on-going process with Regional Locational Guidance so not every change has been noted.

Table 40.1 Regional Locational Guidance - Table of suggested modifications

No. Suggested modification Action taken Reason
396 In Fig. 47 the cruising routes have been truncated at the old PFOW boundary because the shipping study was carried out before the boundaries were changed. The routes towards Cape Wrath can be found by extrapolating the existing routes as most vessels pass close to the cape except when the firing range is in operation. Many recreational vessels anchor in Loch Eriboll where there are several anchorages. The ones at Ard Neackie are the most important. None. The maps generated for the Shipping Study are considered appropriate for this Regional Locational Guidance. As the pilot marine spatial plan area had not been decided during the time of this study the area used was based on the Crown Estate strategic area. It is acknowledged that there is a data gap in the west of the pilot plan area but this is the best available data at this time.
397 Elaborating on section 4.15.5, about a quarter of visiting boats transmit an AIS signal and their tracks provide a good indication of the routes taken by most recreational vessels. However, smaller vessels with local knowledge are unlikely to transmit a signal and these boats tend to go closer inshore and cut through shallow passages. Noted. This is acknowledged as an issue with this type of study and there is on-going research to fill this data gap.
398 4.12.3 Denwick? I checked through the Admiralty Pilot to see if there was such a name and there isn't. The name should be Rerwick Head This has been corrected in the text wherever it is mentioned. Correction.
399 4.14.9 The two fixed platforms are single point moorings. The eastern one is decommissioned. The paragraph that mentions the moorings has been corrected. Correction.
400 4.14.10 Houton does not appear to be a commercial development area any longer. Available land has been designated for housing. The text has been updated as appropriate. Correction.
401 4.14.11 Policy SD7 deals with waste the required Policy is SD6 The reference to the policy has been corrected. Correction.
402 Table 8. Ports and Harbours in the North Region
This table needs to be updated. Ports and harbours at Birsay does not exist. Deerness is a slipway of which there are a numerable amount in Orkney. I would recommend that as far as Orkney is concerned you should use the Orkney Harbours Port Handbook. Brough is purely a slip. Recommend the use of the Admiralty Pilot, rather dated, and the Imray North and East Scotland Pilot although Scarfskerry is sadly missing from this.
The table has been amended and updated. In response to request.
403 4.15.7 This paragraph needs to be investigated remembering that AIS data for recreational craft only covers around 17%. The script looks more like that for ferries. The reference to data has been checked and updated as necessary. In response to request.
404 Paragraph numbering from after 4.15.11 seems to have gone a bit awry. Should be 4.15.12 - 18 The paragraph numbering has been corrected. Correction.
405 4.15.3 (14) Dinghy sailing clubs are located in Kirkwall, Stromness, Holm (St Mary's), Longhope and Westray in Orkney and Scrabster on the North Coast (Figure 47). It is important that these dinghy sailing clubs are recorded, as the waters they have historically used should be free from pollution. The dinghy clubs listed have been included on this figure. Correction.
406 We welcome the inclusion of a section within the Regional Locational Guidance ( RLG) on seabirds and illustrations of seabird vulnerability, Figures 21-28. We would recommend these vulnerability maps are supported by text that acknowledges they are indicative and they do not negate the need for project level survey required to support environmental assessment of the projects impacts. The text has been updated to include the suggested change. In response to request.
407 Seabird tracking data is being loaded onto the NMP interactive webmap. Referencing this data set within the RLG is recommended either through use of map extracts or links direct to the data set on NMPi. Noted, as these data are in the process of being updated on NMPi a link cannot be provided at present although it has been made clear in the text that the data will be available. It is clear in the Regional Locational Guidance that NMPi is one of the main sources of information so it is anticipated that these data would be found easily.
408 It should state up front how this RLG document differs from the Sectoral Plan document due out shortly, given that the boundaries used appear the same. One potential difference is the use of region specific data; however, why this data is not used in the Sectoral Plans is unclear. This would intimate that the RLG data is more accurate and better informed than the Sectoral Plans. None. This Regional Locational Guidance has been updated and includes some regional specific data e.g. recreational data. There will always be a need to review and update Regional Locational Guidance as more data become available.
409 WN2 appears to bisect Westray, and there appears to be an additional area near Marwick Head. This has been corrected. Correction.
410 Paragraph 1.5.5 discusses the updating of the RLG. Will this remain necessary once the Sectoral Plans have been finalised and the RMPs are in place? Multiple updates of the same information may be a waste of resources. None. There will always be a need to review and update Regional Locational Guidance as more data become available. It is likely that Marine Planning Partnerships will play an important role in updating and developing Regional Locational Guidance further.
411 Paragraph 3.2.2 mentions eight AfL's in this area, which is incorrect. There are currently only four AfL's for wave in the entire PFOW MSP area, including both EMEC sites. Relevant text has been updated. Correction.
412 Figure 7 highlights how spatially distinct marine renewables and aquaculture are in this region. This point has been made in our comments above in relation to the main consultation document. Noted and dealt with in relevant policy text in main Plan document. In response to request.
413 Section 4.3 appears to have incorporated quite generic data. However, there is very accurate data for this region (gathered by MS, developers, EMEC, etc.) and how this has been incorporated into the assessment should be discussed where appropriate. None. As more data becomes available there will be a need to review and update the Regional Locational Guidance.
414 Figure 15 shows extensive overlap between offshore wind, marine renewables and nature conservation areas. Despite this there is no discussion in relation to potential co-location and how any issues may be resolved. Additional information should be provided given that this is a major theme within the main consultation document. Noted and dealt with in Sectoral policy 4 text in main Plan document In response to request.
415 Paragraph 4.15.11 - it should be noted that certain dive boats have also been utilised for surveys in relation to marine renewables projects. Text has been updated. In response to request.
416 4.7.4 Seals no comments on the SACS however they are shown in table 2 page 24. This section has been reviewed and updated as necessary. In response to request.
417 We believe the RLG plan options require revisiting - particularly with regard to offshore wind and the increasing interest in floating wind. Whilst OWN1 has significant potential it has particular challenges relating to wave climate and grid connection. We would suggest that the RLG for offshore wind needs to recognise the need for near to medium term development options for floating wind which we believe exist along the north coast of Scotland both within and outwith the 12nm limit. Noted. Dealt with in response to comments received with regard to relevant policy.
418 4.1 Aquaculture activity would be better quantified by biomass rather than site number - as expansion of sites often equate to and entire new site. Also if spatial area is to be quantified it should take in the AZE also which potentially affects the development cycle of commercial shellfish. None. Links to reports cited include biomass quantities from aquaculture farms.
419 Table 7 - was any analysis done to identify if those in favour of the Orkney Caithness link were those who individually were set to benefit? None. Outwith the remit of this work.
420 4.3 Sea bed bathymetry is a good prediction of commercial species presence- predictive maps would be useful not just for protected species. Noted. Noted for future reference in Lessons Learned report.
421 4.14.10 a data omission for constraints are the capture grounds for adult commercial stocks (fin and shellfish) and the other areas where their cycles of development occur from spawning to juvenile feed grounds. Noted. This is an acknowledged data gap and there is on-going work, supported by Marine Scotland, to gather more data.
422 Table 8 - St Margarets Hope, South Ronaldsay port is run by a trust not the local authority The text has been updated. Correction.
423 4.15.1 The report cited here has been widely discredited. None. Noted for future reference.
424 4.15.2 The 145 figure relating to sea angling employees seems exaggerated. None. Noted for future reference.
425 4.16 seasonal transiting of large pelagic vessels is not captured by snap shot studies which miss their fishing activity (Spring and Autumn). None. It is acknowledged that there are data gaps and there is on-going work to address these.

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