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

They seem sensible although there might be some comments relating to any terrestrial industrial developments which would have, not necessarily harmful, but impactful discharges into the marine environment. SEPA might be the best entity to comment on this but perhaps especially sensitive terrestrial/marine vicinity areas could be highlighted.

The effects of discharges to the marine area will be addressed in the Water Environment policy in the Draft Plan.

We believe Principle 2 would give the most comprehensive coverage but could be the most expensive. Assuming the lead in task was completed comprehensively then Principle 1 would be a suitable (cheaper?) alternative. We disagree with Principle 3. We agree with Principle 4.

Noted.

We agree in principal with the proposals with the addition that small local ports like Tingwall, Longhope, Pierowall, Kettletoft, Burry and St Margaret's Hope, which support key small fishing fleets should be recognised and protected for their strategic locations in supporting fishing from both a commercial, socio- economic and safety perspective. Safe reach to fishing grounds and safe radius from port with the limiting factors of vessel size, geographic exposure and gear carrying capacity are factors which link these strategic ports to the different sea environments they serve. These small ports represent an important land-sea link which is not protected in legislation or planning.

AP103: Identify the small local ports in the safeguarding existing ports and harbours policy and appropriately protect these strategic locations and their role in supporting small fishing fleets and other sectors.

We would support principles 1, 2 and 4. However, information on zoning of coastal land may be directly relevant to development of realistic (spatial) options for marine developments, so we consider that summary information on coastal land use allocations should ideally be mapped within the MSP, with cross-referencing to the relevant LDP to enable users easy access to more detailed information ( i.e. we do not support principle 3).

To ensure that the marine spatial plan is accurate and up to date it is considered appropriate that land use allocations are not identified in the Draft Plan. The details of allocations and land use are appropriately addressed in LDPs. This is not to say that the location of coastal/relevant terrestrial developments and infrastructure won't be identified in the Draft Plan; just that the detailed land use allocations, land use plans in development brief etc will not.

Principle 1: To ensure integration we consider that it is very important that the adjoining terrestrial areas are appropriately mapped in the marine plan, but agree with the principle of avoiding unnecessary duplication.

Noted.

Principle 2: We support this principle.

Noted.

Principle 3: To ensure full integration between the terrestrial and marine environment we consider that it will be necessary to map coastal land use allocations and any other strategic proposals (for example in relation to the National Planning Framework or National Renewables Infrastructure Plan) which have not yet been integrated into local development plans. Without this mapping it will not be possible to get a complete picture of what is already proposed for the area and what further marine development would be achievable. For example a local development plan may propose a development which includes land reclamation works, an industrial allocation may have a number of associated marine discharges and abstractions and a new sub-station could have associated under-sea cabling. All these terrestrial developments could influence what would be a suitable use for the surrounding marine environment. Such information quickly goes out of date and to counteract this you could consider only producing an online version of the maps; this may allow easier update.

To ensure that the marine spatial plan is accurate and up to date it is considered appropriate that land use allocations are not identified in the Draft Plan. The details of allocations and land use are appropriately addressed in LDPs. This is not to say that the location of coastal/relevant terrestrial developments and infrastructure won't be identified in the Draft Plan, just that the detailed land use allocations, land use plans in development brief etc will not.

Principle 4: We support principle 4. In line with our comments above we also suggest that the Plan needs to consider the location of key proposed coastal infrastructure.

See comment directly above.

Under Principle 2 (or other appropriate principle) reference should be made to coastal visitor attractions (eg view points) or other points of interest.

AP104: Consider the potential to identify important view points.

Scottish Water strongly agrees with Principle 3 that coastal land use allocations should not be mapped within the marine spatial plan. When terrestrial constraints are mapped for context, it should be made clear that the policies and provisions of Local/Strategic development plans take precedence.

Support noted.

The application of marine spatial plans to inform planning application decisions within the coastal zone, and their legal status must be clearly identified within each Marine Spatial Plan. Reference to the relevant marine spatial plan should also be made within the relevant Local Development Plans to aid integration without repetition.

The legal status of the marine spatial plan will be explained in the 'How to Use the Plan' section of the Draft Plan. It is intended that the coastal policies within the adjoining LDPs will identify the PFOW MSP as supplementary guidance.

Agree

Noted.

I always use Admiralty charts and prefer to have all the information I need in one spot without the chart being cluttered hence prefer Principle 2.

Noted.

We agree in principal with the proposals with the addition that small local ports like Tingwall, Longhope, Pierowall, Kettletoft, Burry and St Margaret's Hope, which support key small fishing fleets should be recognised and protected for their strategic locations in supporting fishing from both a commercial, socio- economic and safety perspective. Safe reach to fishing grounds and safe radius from port with the limiting factors of vessel size, geographic exposure and gear carrying capacity are factors which link these strategic ports to the different sea environments they serve. These small ports represent an important land-sea link which is not protected in legislation or planning.

AP105: Identify the small local ports in the safeguarding existing ports and harbours policy and appropriately protect these strategic locations and their role in supporting small fishing fleets and other sectors.

The key principles are good. However, there will inevitably be cases where the interpretation of them becomes important. There may be some aspects of coastal land allocation that are relevant for the Marine Spatial Plan. These might refer to sport, recreation, and tourism, and issues related to place making.

Noted.

Principle 1: Agree.

Noted.

Principle 2: Agree.

Noted.

Principle 3: Further consideration of whether coastal land use allocation should be mapped in the marine spatial plan is required.

To ensure that the marine spatial plan is accurate and up to date it is considered appropriate that land use allocations are not identified in the Draft Plan. The details of allocations and land use are appropriately addressed in LDPs. This is not to say that the location of coastal/relevant terrestrial developments and infrastructure won't be identified in the Draft Plan, just that the detailed land use allocations, land use plans in development brief etc will not.

Principle 4: Agree.

Noted.

Principle 1: Agree - no conflict with paddlesport activities foreseen.

Noted.

Principle 2: Agree - no conflict with paddlesport activities foreseen.

Noted.

Principle 3: We advocate further consideration of whether coastal land use allocation should be mapped in the marine spatial plan.

To ensure that the marine spatial plan is accurate and up to date it is considered appropriate that land use allocations are not identified in the Draft Plan. The details of allocations and land use are appropriately addressed in LDPs. This is not to say that the location of coastal/relevant terrestrial developments and infrastructure won't be identified in the Draft Plan, just that the detailed land use allocations, land use plans in development brief etc will not.

Principle 4: Agree - no conflict with paddlesport activities foreseen.

Noted.

No comments.

N/A

We believe this section would benefit from some clarification as it is not entirely clear what is being proposed ( e.g. it is not clear whether principle 1 is suggesting that constraints are or are not mapped to avoid duplication). Provision of a table indicating what is proposed to be mapped and what is proposed not to be mapped may assist.

Noted.

Whilst avoiding duplication of those features mapped in terrestrial plans, it is likely that many terrestrial activities and plans will also directly or indirectly influence the marine area and visa-versa, particularly along inshore and coastal zones. It is recommended, in drafting a list of terrestrial activities/ developments, that a thorough review is undertaken to consider all potential links to activities in the marine area.

These issues will be addressed in the Integrating coastal and marine development policy in the Draft Plan.

Overall the proposed key principles seem adequate.

Noted.

Yes, agreed. The proposed key principles set out a pragmatic way forward. We would however add the following:

Noted.

Firstly, the marine spatial plan should make it clear which constraints are mapped in the plan and importantly which are not, with reference made to where information about the latter may be found e.g. Local Development Plans;

AP106: Where constraints are not identified with the Draft Plan, signpost to where relevant information can be accessed.

Secondly, key coastal infrastructure to be identified under Principle 4 should include onshore electricity grid for offshore operations, such as interconnectors, hubs and converter stations.

AP107: Identify the location of existing coastal and marine grid infrastructure within the electricity and telecommunications Infrastructure section of the Draft Plan.

Thirdly, the Marine Spatial Plan should be prepared in a way that is consistent between the two Council areas, therefore the key principles should be applied consistently.

Noted.

We support the proposed key principles outlined in paragraph 6.18

Noted.

We agree the key principles listed.

Noted.

Question 7, Page 27

SPR agree with the key principles.

Noted.

As described, although the order of the principles and examples listed should in no way be interpreted as giving any rating of the level of consideration that will be assigned, for example potential impacts on marine archaeology should not by inference take precedence over impacts on housing land allocations.

Noted. These principles have not been presented in order of importance.

Yes.

Noted.

Comments in Question 19 box.

Noted.

Comments in Question 19 box.

Noted.

No comments.

Noted.

HIE are in agreement with the proposed key principles but would encourage Marine Scotland to provide clearer guidance around Principle 4

Noted. The identification of existing, and appropriate proposed coastal infrastructure, will be clarified in the relevant sections of the Draft Plan e.g. ports and harbours, the electricity and telecommunications infrastructure sections.

Comments in Question 19 box.

Noted.

The Principles suggested seem to be reasonable, and avoid cluttering each regional plan with unnecessary terrestrial detail, and ensuring clarity within the plan Boundaries.

Noted.