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

It needs to be a key element of the plan in that responsible economic development will underpin the future economic success and stability of the region. Economic development, in the Orkney/Pentland context, could mean various things, and tourism could be considered as relevant and important as new industries. New businesses which intend to develop in the context or framework of the plan and its key principles (respect for the environment, sustainability etc) need to be supported and encouraged, especially those which create highest added value for the community

Noted.

I have a frequently articulated view on development which centres on the need to add value locally, especially through new and high value manufacturing activities which will have a long term future.

AP157: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

I would like to see the "seaweed industry" in its broadest sense included in the scope of the (economic) activities within the scope of the plan, whether existing or potential for the future (the seaweed will always be there) - our goal would be to see an integrated renaissance of the region's seaweed industry, with relevant outputs such as seaweed for foods or seaweed components produced locally. There is the potential to create a local seaweed industry of the scale of £50 m pa in business revenue terms, and this would be a sustainable and valuable contribution to the region's economic future

AP158: Seaweed will be considered under the aquaculture sector of the Draft Plan.

The PFYC has no preferences for any particular type of exploitation as long as consistent with our comments previously - beneficial, acceptable level of damage, fits with existing users. For some types of development this is easier to achieve than others. For example seabed tidal turbines will likely have less impact than surface mounted wave generators.

Noted.

Economic growth requires removing the burdens from businesses and individuals to be able to prosper. For fisheries, increased development in the marine environment could potentially cause displacement of fishing effort and/or exclusion from important fishery grounds. Combined with increasing fuel prices and volatile market prices for catches, the prospects for innovation and growth in this sector are not looking good. There needs to be a clearer understanding of how the fishery operates in Orkney as well as the social context in which it is embedded. For example, despite their not making a significant economic return, many fishermen continue to fish because it represents a family tradition or because they enjoy the level of autonomy they have over their job. We recommend making the fishing industry in Orkney a local strategic priority and propose that all future growth in the marine environment is located, designed and managed in a way that does not adversely impact on it.

AP159: There is current research on a number of fisheries related projects including e.g. ScotMap, the effect of displacement; vessel tracking and these data will be used to inform the Draft Plan.

AP160: In developing the Draft Plan strategies the objectives will take into account existing economic activity including fisheries.

It is also relevant to note that GDP is now no longer the sole indicator of a country's economic success and the Office for National Statistics now rates 'wellbeing' as a significant national policy goal.

AP161: A Quality of Life / Well Being policy section will be developed in the Draft Plan.

We consider that a central purpose for marine planning, in support of sustainable economic development is to provide clarity at a strategic level with respect to key constraints, and opportunities to enable robust decision making by both developers and regulators at project level. Please also refer to our answer to question 11a.

Noted.

While we appreciate this is an important issue it is not directly within our remit so we have not provided comment.

Noted.

Economic Activities which should be encouraged to grow in the area are:

• Adventure Tourism: The Spatial plan could assist this aspiration to develop.
• Use of Natural Products
• Operational & Maintenance Support based out of key ports and harbours (Scrabster, Gills in Caithness)

AP162: Consider existing adventure tourism activities within the PFOW tourism and recreation case study. Support the growth of adventure tourism in the Draft Plan tourism and recreation policies.

Noted. It is unclear what the 'use of natural products' is referring to specifically.

The port and harbour development and infrastructure policy in the Draft Plan will support the development of port and harbour infrastructure for marine renewable energy operations and maintenance.

Land based facilities and appropriate land use allocation at ports and harbours are within the remit of local development plans and associated development briefs.

AP163: The Working Group will work to co-ordinate onshore and offshore planning policies.

Scottish Water believes that these issues should be set in the context of the overall sustainable development of Scotland and must take socio-economic aspects into account at the policy development stage.

Noted.

The scale of development is critical. If we go for a "boom town" approach we will lose an awful lot. If we go for a measured approach then the existing infrastructure will readily absorb these new developments and new workers, but the focus should be on training existing young and not so young people in the counties.

Noted.

Marine renewables are not looking too healthy. Aquamarine results show them to be heavily in debt and it would not be surprising to see others in the same position. With very little income and large outgoings in development this is not surprising. To get out of this predicament the modification of the infrastructure needs to be running ahead of renewables development. OIC are doing a considerable amount with the providing of port facilities but outside of Orkney everything seems to be getting bogged down.

Noted.

This also includes connection and transmission charges. At present the authorities are playing round the edges and will be most unlikely to come up with a satisfactory conclusion. The bullet needs to be bitten and a complete new formula written. Whether you are in the SE of England, the Central Valley of Scotland, the Scottish Islands or Lands End the charges should be identical, not per unit nor per mile but the actual figure. This might also have benefits with equalising the spread of people throughout the UK. Unless all this is done stagnation will take place and the population will start to ask government why they are having such a large increase in their bills and seeing no results. How you could write this into a Marine Spatial Plan might be difficult but hasn't this all been raised because of renewables. To get things moving on a permanent long term basis the developers need to know that the infrastructure is going to be there in time, of sufficient scale and at the right price.

Noted. The importance of developing grid infrastructure will be acknowledged in the electricity and telecommunications infrastructure section of the Draft Plan.

The greatest possibilities may be with marine tourism. Orkney, Shetland and the Norwegian Coast are just waiting to be opened up the same as France has been for many years. Many of the yachtsmen in the south of England and the Clyde must be longing to get to new and completely different venues. However to bring a boat up from these areas takes just too long especially if you have to take it back again. Studies will need to be made concerning the potential market, the supply of hard standing preferably under cover, availability of maintenance with the necessary skills, sales literature etc.

AP164: Consider these issues in tourism and recreation PFOW case study and policies in the Draft Plan.

Aquaculture as regards finfish should be limited to areas where there is sufficient flow of water to prevent damage to the sea bed and is not in direct opposition to other users. This will generally mean onshore cultivation where there should be no pollution of the local waters, no opposition to other users of the sea, no need for expensive work boats, no damage to wild fish and a reduction in marine litter.

Spatial guidance for aquaculture development is addressed in the Orkney Aquaculture Supplementary Guidance. In Highland, locational policy will remain within the LDP and related guidance until such time that national guidance dictates otherwise. The pilot MSP will not replace existing guidance; rather compliment and support sustainable development of the sector. There is a presumption against finfish development on the north coast of Scotland as set out in Scottish Planning Policy.

Aquaculture as regards shellfish needs a lot more investigation. One of the biggest problems is with amnesic shellfish poisoning ( ASP). There needs to be a major study into this and from this can it be prevented or how can you mitigate against it.

Noted. Procedures are in place between local authorities and the Food Standards Agency to monitor toxic phytoplankton and take any necessary action.

Sail training, as has already been mentioned, provides great opportunities for the development of personal character in its ability to work with others, to command, to make correct judgements and frequently all done under stress. There is a need for this form of training to be set up in Orkney to work in conjunction with schools and youth clubs. It may be possible for the cost of this to be partially offset by using the vessels for bonding exercises with the various companies in renewables etc.

Noted.

It should be seen that Marine Scotland through the spatial plan is supplying the opportunities for not only protecting the environment but that the plan is able to create the social environment for producing work and opportunities for the population.

Noted. This will be supported by the guiding principles of the plan.

The plan should recognise the importance of devolved fisheries management and the extent to which existing traditional industries are dependent on the entire area (see Section 5 comment above regarding larvae distribution). The plan should consider how the deployment of marine energy devices may impact on inshore fishing, and support the notion of co-operation between different industrial sectors

AP165: Liaise further with local fisheries stakeholders to consider how devolved fisheries management in PFOW can be addressed in the Draft Plan.

It is sustainable economic growth that needs to be promoted and supported. Economic growth that has adverse effects on other sectors could have a deleterious effect on the local economy as a whole. Policy 21, tourism and recreation, captures this aspect. There is scope for an increase in the recreational boating sector particularly small scale developments in Sutherland and to the less developed parts of Orkney.

Noted. The tourism and recreation policies will address these issues, along with the sustainable development sections.

AP166: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

We would like promotion and support of economic growth to be upheld in the marine spatial plan. As a paddlesport group with awareness of increasing interest in paddlesport tourism in Orkney, we can potentially foresee the formation of professional paddlesport guiding companies in the area.

Noted. The tourism and recreation policies will address these issues.

AP167: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

We would like promotion and support of economic growth to be upheld in the marine spatial plan. As a paddlesport group with a growing membership, and awareness of an increasing interest in paddlesport tourism to PFOW, we can potentially foresee the formation of professional paddlesport guiding companies in the area.

Noted. The tourism and recreation policies will address these issues, along with the sustainable development sections.

AP168: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

Sustainably. Policy should make clear that economic development shouldn't be allowed at all costs but should be promoted in a sustainable way that doesn't destroy the particular qualities of the area.

Noted. The tourism and recreation policies will address these issues, along with the sustainable development sections.

AP169: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

In relation to recreation there is a need to recognise that for some forms of development there will be a particular locations need - e.g. changing facilities next to the resource used. Policy should provide for such locational requirements.

AP170: Prepare tourism and recreation policies in partnership with adjoining planning authorities to ensure a coordinated policy approach with coastal recreational land use policies.

In response to questions 11, 12 and 13, we consider that it is difficult to prioritise these receptors at this stage in the planning process as the development of the plan, in liaison with stakeholders, will help to define the overarching vision and objectives, setting the priorities for the plan area and ultimately identifying those activities which should be safeguarded or prioritised. The plan should aim to establish how the protection and enhancement of natural environment, historic and culture resources can be balanced with ambitions for sustainable economic development.

Noted.

The promotion and support of economic growth should be considered within the context of sustainable development, with the economy given equal weight to social and environmental considerations. There must be due recognition of the fact that the natural environment generates and sustains economic activity and brings wider benefits to society ¹.

^{1 Wellbeing through wildlife ( RSPB publication)}

AP171: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

At a strategic level, RSPB Scotland believes a more sustainable economy would be aided by the development of new measures of social and economic wellbeing to complement the traditional, but limited measure, of GDP. We agree with the recommendation from the Carnegie report ² that there should be a shift in emphasis from measuring economic production to measuring people's wellbeing.

^{2 http://www.carnegieuktrust.org.uk/getattachment/edc70373-49a0-48bb-84a3-5b0a253a5a6f/More-Than-GDP--Measuring-What-Matters.aspx}

AP172: A Quality of Life / Well Being policy section will be developed in the Draft Plan.

CNSRP's Delivery Plan for the Caithness and North Sutherland area provides a framework for onshore economic development support, and integration with this framework would substantially enhance the currency of the marine spatial plan.

AP173: Consider the Caithness and North Sutherland Regeneration Partnerships Delivery Plan when developing Draft Plan objectives.

The Plan needs to provide for growth and development of a wide range of sectors, supporting existing activities whilst accommodating growth in renewable energy (particularly marine renewables), the oil and gas sector (bearing in mind future activity west of Shetland) and tourism (both marine-based and terrestrial-based tourism).

AP174: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

The plan must support and promote sustainable economic growth. In particular, the plan should support the growth of offshore renewable energy. It should do this by supporting the sectoral planning process and prioritising the areas identified within it by introducing a presumption of use for renewable energy development in these areas. By doing this, the plan will also support the Scottish Government's decarbonisation, renewable energy and climate change targets.

The Draft National Marine Plan policy 'Renewables 1' states 'there is a presumption in favour of the adopted Plan Options identified through the Sectoral Marine Plan process'. The Draft Plan will be in conformity with the policies with the National Marine Plan as required by the Marine (Scotland) Act 2010.

AP175: Polices will be drafted that clearly demonstrate the Draft Plan's support of sustainable development.

As stated above, Scotland is home to some of the best offshore renewable energy resources in the world and the Pentland Firth and Orkney Waters are the jewel in the crown of our huge marine energy resource. A recent study by Oxford University confirmed that the Firth is the best site in the world for tidal energy.

Noted.

Recent work by Baringa has shown that with the right policy and financial support, the development of renewable generation on the island could have significant socio-economic benefits to the local economies through the creation of direct, indirect and induced jobs. The analysis suggests that by 2020 some 416 full time jobs could be created in Orkney, and by 2030, that number could rise to over 4,500.

Noted. Sustainable economic development and job creation will be supported through the Draft Plan vision and Strategic Objectives.

According to the report, the vast majority of these jobs in Orkney would flow from wave and tidal generation which is labour intensive in the early years, providing the opportunity to develop local supply chains and export expertise.

Noted.

Securing these economic benefits is extremely important for the communities in the Pentland Firth and Orkney Waters area.

AP176: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

The economy should be considered within context of sustainable development and the 5 guiding principles of sustainable development as set out in the UK Government Sustainable Development Strategy.

AP177: The economy will form part of the definition of sustainable development within the Draft Plan.

Question 13a, Page 32

The status of the area as a Marine Energy Park should be highlighted within the Draft Plan, which promotes the development of low carbon technologies in order that both the Scottish and UK targets can be met. The potential economic benefit to the area through the development of the marine renewables sector is considered to be of significant benefit.

AP178: The role of the Marine Energy Park will be highlighted and supported in the Draft Plan.

The promotion of economic growth in this remote region of Scotland should take precedence- it must be the defining priority to ensure that the maximum benefits from the exploitation of our renewable resources are achieved.

AP179: The economy will form part of the definition of sustainable development within the Draft Plan. The Plan will support sustainable economic growth.

(i) See Q4 above. (ii) Salmon farming.

Sustainable aquaculture development will be supported in accordance will the relevant Local Development Plan policies and guidance.

Comments in Question 19 box.

Noted.

Comments in Question 19 box.

Noted.

Tidal and wave power perhaps - depends on damage to environment.

Noted.

The Pentland Firth and Orkney Waters is home to some of the world's best wave and tidal energy resources and is already the location of choice for wave and tidal energy developers from throughout the world. The pivotal role that the area already has in developing the global marine energy industry is instrumental in the drive towards commercialisation of the industry. The area offers a coherent, supportive business environment designed to accelerate the commercialisation of wave and tidal stream technologies. Its focus is on the opportunities offered by commercial leasing round in the PFOW but its reach is throughout the Highlands and Islands and the rest of Scotland, bringing leading academic knowledge and unrivalled industry experience together to accelerate the development of the marine energy sector. The plan must support, promote and sustain economic growth in the PFOW area where we are already seeing the likes of EMEC, Scrabster Harbour, Hatston, Lyness and Wick Harbour being supported however this is just the start of the journey. Securing economic benefits for the population in the PFOW area is of paramount importance.

Sustain economic development and job creation will be supported through the Draft Plan vision and strategic objectives.

AP180: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.

Comments in Question 19 box.

Noted.

Economic growth is surely the prime mover for the plan, but the SFF would stress that growth of any new industry or management regime must not be at the expenses of an old traditional industry.

Economic growth is of course important but equilibrium need to be maintained in relevant communities, there would be no good point in growing one industry and losing another. [Comment in relation to 13b]

AP181: The Sustainable Development policy section will be drafted to ensure the economic benefits of existing economic activity, added value and new development proposals are assessed. Consideration will also be given to developing a policy to assess economic impacts.