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

I have no issue with the Strategic Issues identified in the table, or with the associated commentary but I would point out the omission of any mention of the "seaweed industry". Whether you would want to call that Mariculture (although that implies deliberate cultivation of seaweed as opposed to making sustainable use of natural stocks), as a convenient overview name, or the Seaweed Industry is a moot point, although the latter is more accurate.

Noted. This will be addressed in the Draft Plan.

AP182: Seaweed will be considered under the aquaculture sector of the Draft Plan.

There is clearly potential for conflict between some of the developing economic priorities, but I believe that re-development of a sustainable seaweed industry in the region would work well alongside some activities such as Marine Renewables.

Noted. This is dealt with by Guiding Principle 5 in the PIOP.

It should be noted that, in the historic past, and based on details in historical texts, up to 100,000 (wet) tonnes p.a of seaweed was harvested in Orkney alone - that could, if re-established, lead to businesses with annual revenues exceeding £50 m pa on the assumption of adding value to the seaweed locally. The economic impact to the local economy, although not as large as the above number would probably be of some £25m pa into the local economy

Noted.

Biodiversity and Natural heritage - On face of it this would be an ideal source for careful exploitation as long as amenity maintained. However must not exploit some species at expense of others. One of the assets of the region is little general disturbance of bio-systems.

Noted: the accompanying draft Environmental Report aims to assess and address in detail the effects of the various types of development discussed on the environment, including biodiversity, cultural heritage.

Cultural heritage and historic environment - This is also an asset that must be preserved and could be exploited. Some compromises may be necessary to allow other users access to region

Noted. See comment above.

Marine renewable energy - if done acceptably this is an asset that should be carefully exploited as socio-economically beneficial to region and potential beneficial to environment.

Noted.

Electricity grid infrastructure - If carried out in a sympathetic manner then upgrading and extending the electrical infrastructure is a necessary facility to allow other exploitation. The region must not end up as a cable bridge sending clean energy elsewhere with limited local benefit. We should consider using our electricity generated locally for creating other opportunities locally.

Noted: whilst this may be a good idea, it is likely to be technically unfeasible in the short to medium term but may be an option for the subsequent Scottish Marine Regional Plans in due course.

Shipping and Navigation - Although of little local benefit shipping and navigation should still be encouraged as generally beneficial to society. New uses within the region need to be permitted only where safe to do so without unduly compromising shipping.

Noted: shipping is a vital importance to the local economy, providing lifeline ferries, transport of goods and servicing many marine industries, to name a few. The Draft Plan will have a Shipping, Navigation and Marine Safety to help address these issues.

Ports and harbours - As generally brown field sites (although often full of biodiversity) we have no general problem with development and exploitation of our ports and harbours for the benefit of new users. This must be done in a manner that does not unduly compromise or discourage existing users - including leisure use.

Noted: the Draft Plan aims to provide knowledge to allow balanced decisions to be made and these will inform the Ports and Harbours policy. Development of business industrial land in ports and harbours is dealt with in Local Development Plans.

Oil and Gas - Whilst environmentally damaging hydro-carbon energy remains essential to modern UK society and provides local socio-economic benefit and should continue to be exploited. Controls to be in place to minimise and repair, where possible, the damage.

Noted.

Marine aggregates and dredging - As a general rule we do not support extraction of such resources from this region. However we recognise that we are all consumers of such resources and would reconsider this where it can be demonstrated that less sensitive sources are not available elsewhere. We would not agree to the damage such extraction would cause to such a pristine environment simply for commercial gain. Similarly we would aggressively object to commercial large waste / spoil dumping but accept some limited dumping to assist with other developments.

Noted.

AP183: A separate dredging and disposal policy sector will be developed.

Other infrastructure ( e.g. flood and coastal erosion defences) - only if done sympathetically with the culture of the region and acceptable environmental damage.

AP184: Potential cultural and environmental impacts will be part of the criteria in the Coastal Protection and Flood Defence section.

Commercial fisheries - We support sustainable and sensible commercial and leisure fishing. We believe that fishing authorities need to exercise more control such that the sea is farmed rather than just exploited. The quota system does not seem an adequate means for protection for either the fisherman or the resource.

Noted.

Aquaculture - as long as rights of navigation and anchorages for existing users are not impaired in an unacceptable manner we have no objections in principle to this type of farming. We are aware of the serious environmental damage poorly managed / legislated farms cause that must be stopped.

Noted. These issues are addressed in the appropriate Supplementary Guidance.

Tourism and recreation - we are naturally supporters of environmentally well manage exploitation of the natural resources for the purposes of tourism and recreation. As well the direct fiscal advantages, we believe that such amenities provide a soft benefit to local residents and visitors that enhance the region for the benefit of developers and residents.

AP185: 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.

AP186: A Quality of Life / Well Being policy section will be developed in the Draft Plan.

Strategic issues:

Knowledge gap on the effects of climate change on commercial fish stocks and fishing activity including how this in turn will affect quotas for fish.

The Draft Planning process will aim to use the most up-to-date data available on climate change effects. However, the effects of climate change on fish stocks and setting quotas are an international/national issue, beyond the remit of the Draft Plan. That said, we shall provide a policy framework that balances the sustainability of existing users, new developments and environmental sustainability.

Opportunities to address strategic issues:

Provide a policy framework that ensures the interests of commercial fisheries are safeguarded when assessing consent applications for new development.

The principle of supporting co-existence and multiple use of marine space is supported by guiding principle 5 in the PIOP.

Promote the conservation, enhancement and restoration of commercial stocks and their supporting habitats within the PFOW.

AP187: 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.

Ensure that fishermen maintain the flexibility to be able to respond to the effects of climate change on their stocks in terms of quotas gear types and diversification.

Noted.

Opportunity to highlight the strategic importance of fishing for meeting the growing demand for food.

Noted.

Ensure that local fishermen have a strong voice in the sustainable development of the PFOW.

We value input from the OFA. Stakeholder engagement is a vital part of the development of the Draft Plan and the Working Group have consulted on an individual and wider basis throughout the process. The consultation events to date i.e. the workshops, evening drop in sessions and the opportunity for one to one meetings were widely advertised and provided many opportunities to discuss the development of the Draft Plan. There will be sector specific focus groups to work through development of policy for the Draft Plan and these are open to all fishermen that wish to participate.

Table 9.1 is very helpful to understanding the basis for identification of key issues and associated opportunities that will inform policy development within the Plan. We broadly agree with the information presented in it, but suggest that there are some omissions and areas where greater detail would be helpful, as follows:

Noted.

Biodiversity and Natural Heritage: suggest that the section on drivers for change explicitly mentions provisions for designation of Marine Protected Areas under the Marine (Scotland) Act and for designation of marine SPAs under the Birds Directive. Additional strategic issues include declining regional populations of common seals and many species of seabirds and the risk of introduction or spread of marine invasive non-native species ( INNS). INNS risk should also be highlighted as an issue with respect to expansion of Shipping and development of Ports and Harbours (and linked to, for example, the provisions of the Ballast Water Management Convention). We note that INNS are explicitly considered within proposed cross cutting and sectoral polices ( e.g. see our response below at Proposed Policy Options - Response Box 3 , so presume their omission in this table is an unintended oversight.

AP188: A 'drivers for change' section will be part of the Draft Plan and we shall ensure that the information supplied regarding MPAs, declining species' populations and INNS are included, as appropriate.

The Marine Renewable and Energy and Aquaculture sections correctly identify the need to comply with legislation designed to safeguard the environment. However, this also applies to Ports and Harbours developments (particularly during the construction phase) and in all instances should be reflected in an associated Opportunity for the marine plan to provide a policy framework and associated spatial information to guide development to those locations where compliance may be most readily achieved (and hence risks both of significant impacts on the natural heritage and of added costs or delays for developers minimised).Electricity Grid Infrastructure: in addition to impacts of cables (and associated infrastructure) at landfalls, routing at sea, in particular in relation to Marine Protected Areas and Priority Marine Features is also an important consideration.

AP189: As there is a requirement for all activities to comply with legislation designed to safeguard the environment, this information will be stated at the beginning of the relevant sections of the Draft Plan.

Providing constraints and opportunities mapping will be an integral part of the Draft Plan and related supporting documents.

Impacts on biodiversity, as covered in the Environmental Report and HRA, will be reflected in the Draft Plan.

Marine Dredging: the development of the Plan provides an opportunity for strategic review of existing dredge disposal sites to assess their suitability for further disposal of spoil, particularly given likely increase in volumes of such material if aspirations for ports and harbours developments are met.

AP190: Discussions with relevant parties ( e.g. the Crown Estate) are providing information that should be available for the Draft Plan to address this issue.

AP191: A separate dredging and disposal policy sector will be developed.

Commercial Fisheries: the statement that there is no clear guidance on acceptable activities within protected areas is somewhat misleading. Under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) Marine Scotland is the Competent Authority with respect to management of fisheries activities that might affect the integrity of a European marine (Natura) site ( EMS).

We note the requirements of the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) and Marine Scotland duty as the Competent Authority with respect to management of fisheries activities that might affect the integrity of a European marine (Natura) site ( EMS).

With respect to the development of Marine Protected Area ( MPA) proposals, efforts have been made in advance of the anticipated consultation to provide stakeholders with an indication of the management implications for all proposed sites. The consultation will be supported by Management Options papers in relation to all activities, including fisheries where relevant. Stakeholders have already been engaged in this process via national representatives and at local meetings at a variety of locations from April this year.

We note the content of the Management Options paper.

Other infrastructure: should include potential for creation of fixed links between some of the islands in Orkney; such proposals could exert significant impacts on the marine environment.

Noted. These issues will be taken into consideration.

Other activities: there is already some commercial harvesting of seaweeds in Orkney waters and we anticipate future proposals for new enterprises. Extraction of marine algae, including maerl, has potential to significantly impact the natural heritage and may also increase the risk of coastal erosion. The potential for future cultivation of seaweeds should also be included (under aquaculture).

AP192: Seaweed will be considered under the aquaculture sector of the Draft Plan.

We have no specific comments to make on the Table but when developing the Plan we would wish you to continually consider potential impacts on local water bodies.

Noted.

Cultural Heritage & Historic Environment: Caithness Archaeological Trust should be a consultee.

Tourism and Recreation: The area offers some of the UK best (and challenging) sea kayaking in the area. The area should be recognised as offering a destination for adventure tourism (water based) - surfing (board & kayak); sea kayaking; diving; sailing (see www.sailnorth.com) etc.

AP193: They will be added to consultation database if permission given.

AP194: A tourism and recreation study will provide data to support this sector's policy development in the Draft Plan. This issue will be considered in the tourism and recreation sections.

Scottish Water notes that discharges are considered a strategic issue in relation to Biodiversity and Natural Heritage.

We would state again that, as part of the critical infrastructure supporting safe sanitation for the people of Scotland, the need to discharge safely to the marine environment in compliance with environmental licences needs to be acknowledged.

AP195: Whilst compliance with environmental licences would be at individual project level, we have a cross-cutting policy that covers the water environment. This will address the comment made.

A lot of thought has gone into this table, with a broad view of the issues. Please continue along these lines.

Noted.

The Interactions Matrix as set out in the PFOW Spatial Plan Framework and the Consultation Paper May 2013 are different in various respects. The main one as concerns Recreational Sailing is that in the Framework it is included with Shipping and Navigation whilst in the Consultation Paper it has been excluded as a separate item. Including it within Recreation and Tourism would tend to mask what are completely different types of operation one being land based in that nights are spent ashore whilst the other being sea based nights are spent on the water. The former would include such items as dinghy sailing, fishing, diving and sight seeing whilst the latter would include cruising boats.

Following discussions with our Advisory Group, it was decided that as navigation, along with linked shore-based activities, are key elements of all shipping activities, there was no need to identify individual shipping types in the confines of the matrix. The sectoral topic of shipping and navigation encompasses all craft.

Respondent included a table and hand drawn additions to matrix which are available to see here.

Amendments will be made to the individual matrix topics and these will be represented in the appropriate sections but the whole matrix will not be reproduced. As many interactions can have both positive and negative effects, these effects will not be weighted but the key issues will be discussed in the supporting text.

AP196: Clarify that all types of craft are considered in the shipping/navigation sections.

AP197: The different types/levels of impacts will be acknowledged and considered when drafting the Plan.

Ensure that local fishermen have a strong voice in the sustainable development of the PFOW.

Stakeholder engagement is a vital part of the development of the Draft Plan and the Working Group have consulted on an individual and wider basis throughout the process. The consultation events to date i.e. the workshops, evening drop in sessions and the opportunity for one to one meetings were widely advertised and provided many opportunities to discuss the development of the Draft Plan. There will be sector specific focus groups to work through development of policy for the Draft Plan and these are open to all fishermen that wish to participate.

See earlier comments in relation to question 11a in respect of biodiversity and natural heritage. The impact of recreational boating on biodiversity and the natural heritage is generally rather low, particularly when good practice guidelines are followed.

Noted. By undertaking the EIA process, the accompanying Environmental Report aims to assess and address the effects of the various types of development on the environment, including biodiversity and natural heritage.

It is a laudable aspiration for Scotland to become world leader in combating climate change and the development of appropriate renewable energy technologies is a means towards achieving that goal. Not all renewable technologies are necessarily useful in that respect. An additional strategic issue for marine renewables is their resilience to extreme wind and wave conditions. This may be impaired by climate change. In shallow waters there can be a significant interaction between wind, swell and tide. The increasing availability of metocean data should be combined with the experience of local users of the sea such as fishermen and recreational boaters to explore these risks.

Noted: we would welcome any local knowledge or data that could help shape our Draft Plan. Given the level of investment by developers, they are taking a phased deploy and monitor approach to ensure the proposed equipment is appropriate.

AP198: Climate change will be a policy area within the Draft Plan.

The importance of the Pentland Firth for shipping and navigation may increase if the retreat of the arctic sea ice allows the North-West passage to be opened up for routine commercial navigation. Increased commercial traffic can constrain the options for recreational craft. Note that navigation issues also apply to small vessels such as recreational boats and inshore fishing boats.

AP199: Clarify that all types of craft are considered in the shipping/navigation sections.

Provided that its planning and management is carried out carefully and with appropriate consultation, aquaculture can coexist with sectors such as recreational boating.

Noted.

Facilities for recreation and marine tourism on the north Highlands coast are few in number.

The Draft Plan process will be undertaking a tourism and recreation study as part of a wider national study that may identify opportunities for growth but promoting individual projects as suggested are but outwith the scope of the Draft Plan.

AP200: Develop separate tourism and recreation policy sections.

Although not many vessels currently round Cape Wrath, there are opportunities for local communities with realistic business plans to develop small scale facilities that may also benefit land-based tourism. Sailors in these waters generally expect to have to anchor so developments may well not involve moorings or pontoons. Clear branding and promotion is indeed important. Coordination with existing promotions will be essential.

Noted.

No comments.

N/A

No comments.

N/A

We recognise the aspiration for marine renewables. It is crucial that this sector is developed in a sustainable way.

Sustainable development is a cross-cutting theme throughout the Draft Planning process.

AP201: 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.

On tourism and recreation (in relation to the table but also generally) reference should be made to sport development needs and aspirations in the area. This will relate to club development, training and competition needs in the area as well as more general participation requirements. Join up with LA sport development and facilities strategies will be important in this regard as will reference to core paths plans and access strategies. It will also be important to engage with Scottish Governing Bodies of Sport and the Highlands and Islands Regional Sporting Partnership to gauge any locational proposals, plans, policies ( e.g. facilities strategies, Active Schools engagement) that might exist in the area and be relevant to the plan. Sportscotland can help in this process.

We welcome the offer of help but need to ensure the sport aspect is in relation to marine activities within the remit of the Draft Plan.

Table 9.1 provides a useful summary of the key strategic issues facing the plan area.

Noted

Table 9.1 states that "the timescales for marine spatial planning in relation to development" are a strategic issue and that "some development proposals will proceed in advance of the statutory marine spatial plan". We would suggest that reference is made in the Marine Renewable Energy section to the proposed approach of considering the 12 Agreement for Lease areas for wave and tidal stream energy projects as 'Planned Developments' as in Proposed Policy 11 (see below).

AP202: The Draft Plan will include reference to the current sites with an Agreement for Lease.

Biodiversity

'data gaps' section: should include species ecology and behaviour in addition to the knowledge gaps which refers to effects of some marine sectors on habitats, species and ecosystems.

'opportunities to address strategic issues in the pilot marine spatial plan': this section should include consideration of measures that would increase the plan's resilience to climate change e.g. adaptive management that identifies potential future scenarios specific to the region and responding with innovative solutions to counter the effects of these predicted impacts.

AP203: This information will be taken into consideration in drafting the Draft Plan.

Climate change considerations are one of the guiding principles of the marine spatial plan process and will therefore be considered across all of the sectoral topics.

AP204: Climate change will be a policy area within the Draft Plan.

For Marine Renewable Energy the strategic issues section should include marine habitats and species under the second bullet point for 'risks and barriers'.

AP205: This information will be taken into consideration in drafting the Draft Plan.

Cultural Heritage and Historic Environment - In Table 9.1, "the wider area of Caithness and north Highland" would better read "Caithness and the wider area of north Highland". In referring to potential damage to archaeological assets, reference should be made to consideration of significant adverse impacts on features, including on setting of features where relevant.

AP206: This information will be taken into consideration in drafting the Draft Plan.

Marine Renewable Energy - The reference in Table 9.1 to lack of grid infrastructure might better refer to "lack of grid infrastructure and/or limited current grid capacity". The reference to cooperation between Orkney and Caithness might better refer to "cooperation between Orkney and North Highland", bearing in mind the Plan area proposed.

AP207: This information will be taken into consideration in drafting the Draft Plan.

Electricity Grid Infrastructure - The current wording might suggest that all Grid upgrades are dependent upon Orkney links, when there is already substantial work planned for the north mainland irrespective of Orkney links, plus there are plans for sub-sea links southwards to the Moray coast, as illustrated in the recent consultation on National Planning Framework 3. Table 9.1 needs rewording to reflect this. Also, whilst it is appreciated that the Table is not attempting to describe all types of electricity grid infrastructure, it would be worth mentioning converter stations in addition to substations and power cables as these are likely to be a significant feature of development proposals in or near the Plan area. In referring to the need to consider the impact of cables making landfall on coastal areas, it would be useful to mention cumulative impacts of multiple landfalls.

AP208: This information will be taken into consideration in drafting the Draft Plan.

Shipping and Navigation - Table 9.1 should more clearly reflect that passage in the Pentland Firth is not only through the firth but also across it e.g. ferry routes, and mention could also be made here of visiting cruise ships. With regard to the recognition that the economic and strategic importance of shipping is required to support almost all other marine sectors, Table 9.1 could also acknowledge that it also is required to support some key terrestrial sectors/activities.

AP209: This information will be taken into consideration in drafting the Draft Plan.

Ports and Harbours - Gills harbour should be mentioned, both in terms of its role in marine energy and as a ferry port.

AP210: This information will be taken into consideration in drafting the Draft Plan.

Oil and Gas - Scrabster Harbour will be the site for an Oil Supply Base for West of Shetland fields and this should be referred to. See http://www.norseagroup.com/media-center/news-archive/norsea-group-invests-in-its-first-supply-base-in-scotland.aspx Indeed whilst Table 9.1 correctly acknowledges long term contraction of the sector, it should also refer to short/medium term activity and new business opportunities in the sector. With regard to the reference to subsea telecommunications links, this may more appropriately be considered as a sector in its own right, and in that regard we note that the consultation document has identified it for a proposed sectoral policy.

AP211: This information will be taken into consideration in drafting the Draft Plan.

Identifying Strategic Issues and Interactions

• Healthy and Biologically Diverse Seas

Levels of protection should be in some way linked with the findings of the Marine Atlas. For example, the Marine Atlas finds that the PFOW area (North Scotland Coast) has no significant concerns in relation to the 'clean and safe' parameters assessed and habitats are in a relatively good condition. However, seabird, harbour seals and some commercially exploited fish are highlighted as species of concern. The decline in seabird numbers is suggested to be linked to a shortage of key prey species associated with changes in oceanographic conditions.

AP212: When drafting the Plan, we shall clarify the links to key documents such as the Marine Atlas, which have been used to underpin the Draft Plan.

We fully support further research being carried out to aid the development of the plan.

Noted.

We seek further guidance on 'research, deploy and monitor' in relation to the development of marine renewables, specifically on whether this refers directly to Marine Scotland's 'survey, deploy and monitor' policy?

AP213: More detail will be provided on this aspect in the Draft Plan: it relates to the methodology proposed by MS to assess the impacts of the emerging wave and tidal devices.

We would support standard methods for data collection and surveying from Marine Scotland. However, care must be taken in relation to setting standards for data collection from the marine renewables industry. Recent discussions through SMRRG highlighted that survey methods are maturing and developing with the industry and therefore it was not appropriate to stipulate exactly 'how' surveys should be carried out. More beneficial is guidance on exactly what outputs regulators require to see from surveys, and regulators should be less prescriptive on exactly how those outputs are achieved.

Noted.

We seek further detail on what a policy framework for assessing developments may contain.

This will be in the form of the Draft Plan.

• Marine Renewable Energy

The pilot plan must be consistent with the sectoral plans. In relation to timescale requirements for data, reference should be made to Marine Scotland's survey, deploy and monitor policy. In particular, we support the aims of promoting PFOW as a centre of excellence for renewable energy, taking advantage of energy export opportunities, the development of wider socio-economic opportunities and the recognition of the need for improved local infrastructure. We also welcome the recognition of the importance of access to grid.

AP214: Now that the draft sectoral plans, National Marine Plan and proposed MPA sites have been published, we will ensure that the Draft Plan is consistent with them. The survey, deploy and monitor policy will also be taken into account.

• Shipping and Navigation

The work of NOREL must be considered if policies related to marine renewable energy developments and shipping are to be developed.

Noted.

• Ports and Harbours

We support the intention to establish appropriate policy support for ports and harbours that can support the growth of marine renewables. The plan should therefore take account of the outputs of the NRIP process.

Noted.

• Tourism

We are pleased to see PFOW's lead in marine renewable energy recognised as a potential tourism opportunity and an aim to maximise the benefits from this.

Noted.

No comments.

N/A

Table 9.1, Page 34-44

It should be stated in the "Opportunities to address strategic issues in the pilot marine spatial plan" column as to how the additional works as set out are to be funded.

The Draft Plan can only signpost opportunities and provide guidance; it is beyond its remit to cost individual projects outwith the scope of the Plan.

AP215: As part of the 'lessons learnt' exercise after the Plan and its various stages are produced, the costs of developing the Plan process will be considered.

Table 9.1, Page 35, Biodiversity and Natural heritage

It mentions here both agricultural run-off and industrial discharges; however, there does not appear to be any other part of the plan which deals with these issues. Integration between marine and terrestrial legislation should be aligned in order that these issues can be considered within this and future regional plans.

AP216: This issue has been covered in some detail throughout the draft Environmental Report therefore additional text will be pulled through to the Draft Plan where appropriate.

Table 9.1, Page 37, Marine renewable energy

It states here that the plan is "statutory‟, which is at odds with previous sections which stated it was non-statutory whilst the RMPs would be statutory in nature. Clarification should be given here.

AP217: This refers to the subsequent Regional Marine Plans which will be statutory as opposed to this pilot Plan, which is not. Text will be clarified accordingly.

Table 9.1, Page 38, Shipping and Navigation

Clustering of marine developments is considered here in mitigation to shipping activities. However, this may well lead to resource conflicts between the developments. Therefore, this should not be a consideration of the plan as it has wider implications to the renewables sector. Shipping interactions should be considered by the developers of projects and minimised at a project level.

Clustering of development does not refer to renewables development specifically; it may be an appropriate for e.g. the aquaculture industry where Integrated Multi Trophic Aquaculture ( IMTA) is being proposed by Scottish Government.

No further comments to make

N/A

For SSPO one of the primary strategic issues in the PFOW area is the Scottish Government's contradictory policies whereby it seeks the substantial growth in the fish farming industry whilst at the same time maintains a ban on any new fish farms on the north and east coasts. As referred to above, there is no scientific basis or justification for such a ban on the farming of finfish generally on these coastlines.. Within the next 10-20 years, i.e. the plan period, it is likely that the farming of a number of species of fish will become not only feasible but essential as catch stock reduces worldwide. To ban all forms of fish farming from approximately half of the Scottish coastline for no apparent reason therefore seems short sighted if not perverse.

This issue is outwith the remit of the Draft Plan, which must conform to national policy.

Another strategic issue is the growing potential for fish farming to take place further out to sea, possibly beyond the 3 NM point, and in conjunction with other forms of marine development. In order to encourage investment in research into such technologies as will be required, the Plan ought to be positively disposed to such developments.

Although the Marine Atlas states that one aquaculture company has the desire to move off-shore, to date there has been limited interest from others in the industry to pursue development in deeper waters within the plan area. Should proposals come forward within the development of the Plan, it will try to accommodate such development if appropriate. National consideration to legislation and policy will be required.

A third strategic issue for the industry is the continuing uncertainty about where salmon farming will be accepted. The Plan ought to address this issue.

( See responses to Q4 and Q10 above.)

Noted. Like all other sectors, individual development will be assessed on a site by site basis. Aquaculture provides an important part of the marine economy in the Plan area and it is likely to continue to do so. The Plan process will provide support for the industry by having aquaculture policy that supports sustainable growth of the industry in appropriate locations.

Comments in Question 19 box.

Noted.

Comments in Question 19 box.

Noted.

The development of infrastructure of land and sea - e.g. at Dunnet Head will destroy its unique cultural heritage and nature.

Noted. Supporting sustainable development opportunities is a fundamental part of the Plan process and is necessary to support local community viability. However, all individual development proposals will have to ensure that any impacts on the environment are assessed, minimized and mitigated where appropriate.

It is rather difficult to comment on this table as the key issues and interactions were taken from a series of consultation workshops with stakeholders to identify the likely interactions between marine sectors and activities. This information has been reviewed by the Working Group in consultation with stakeholders therefore we feel all areas have been addressed.

Noted.

Comments in Question 19 box.

Noted.

The SFF would be concerned that the drive to eco-tourism could lead to our peripheral communities being treated more as theme parks than living dynamic areas. Indeed the table would seem to understate just how important fishing is to the area now and in the future.

AP218: When drafting the Plan we will consult with the SFF again to get detailed information for inclusion. Tourism is a key economic sector and many come to enjoy the 'wild' nature of the natural land and seascapes, therefore bearing little relation to theme parks.