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

Especially in the Orkney part of the region, with its myriad islands and extended coastlines, it is key to have an overarching spatial strategy which is a baseline reference for all parties. It should perhaps not be as black and white as indicating "do's and don't's" or "can's and can't's" but it would certainly be very beneficial for e.g. any new business proposing a development with a marine aspect to be aware of the local situation, and, if considered to be developed, and subsequently managed carefully over the longer term, fairly and with due consideration for all, it would be a very valuable document/tool (whatever one wants to call it)

Noted.

Yes. See answer to question 15. The spatial strategy, as seems to be the plan, needs to include:

Local amenities and residents; existing users; new planned users; possible future uses; impacts (environment, geology etc.) Exploitation, unless complete benign (unlikely) should only be permitted where: Of general society / socio-economic benefit and not just for fiscal benefit; environmental / archaeological etc. damage is acceptable; the compromises necessary from existing users are reasonable.

Noted: it is hope this Plan will help ensure the type of sustainable development suggested by providing information on all the sectors and issues in one document.

Uncertain as we believe a ranking strategy on existing users should be defined ordered by historical access and use underpinned by the fundamentals of human need which is food. Any fixed or inflexible strategy for the sea could work against the dynamic interests of fishing which require maximum flexibility.

Noted: the Draft Plan will adopt a flexible approach to its policies.

Following from Q15, we strongly support the need for an overarching spatial strategy within the Plan. With respect to natural heritage interests, particular consideration will be needed as to how to present spatial information on mobile species ( e.g. cetaceans) and related concepts and potential constraints such as connectivity between European sites and the features for which they are protected ( e.g. some types of development within PFOW may have potential to impact upon Natura sites outwith the Plan area.

Noted. Any guidance SNH can give on how to map mobile species will be welcome.

While we would not favour prescriptive zoning and creation of fixed lines on maps there may be scope to provide broad indications of areas of higher or lower levels of opportunity/constraint for particular types of development ( e.g. the use of narrow straits for passage by vulnerable populations of marine mammals may constrain options for development of arrays of tidal turbines).

Noted.

We would also strongly support the use of a web-based GIS to provide up to date spatial information relevant to implementation of the Plan policies. This may be what is being proposed at 10.4, but we would welcome some clarification of the final sentence.

AP242: All the spatial data in the Draft Plan will be 'live' and updated as appropriate within the National Marine Plan Interactive web pages. This will be accompanied by supporting text in the Draft Plan.

We agree that it is important to have an overarching spatial strategy. Such an approach mirrors that recommended for terrestrial planning and as a result would result in greater integration with local development plans.

Noted.

We suggest that the strategy should identify the most appropriate location for new development, taking into consideration all the available constraint and opportunities information. Such an approach will give greater confidence to developers that developments in such areas is likely to be acceptable and hence help support sustainable economic development.

AP243: Further consultation with key stakeholders may be required to determine the best method of mapping opportunities and constraints.

Yes. To ensure a co-ordained and structured approach looking at the whole area not just a single development.

Noted.

We would support the development of an overarching spatial strategy so as to safeguard the investments made in essential existing asset and to safeguard their function and compliance

Noted.

I am impressed by the work that has gone into this paper, and look forward to continued liaison.

Noted: continued support very welcome.

The strategy has to be all encompassing. It has to be able to ask why, wherefore and therefore. It cannot just say take it or leave it. For everything it wants to do it has to be able to look at all arguments and come up with fair decisions or mitigations. The strategy is not just for the environment it is for all the people. You just have to be able to prove it.

Noted: the extensive consultation process, with regular updates and opportunities to comments on all the key documents produced, along with the extensive evidence base used to inform the plan making process aims to do this.

No comment

N/A

RYAS supports an overarching spatial strategy. In the case of recreational boating, it should illustrate the main cruising routes (as provided by the RYA UK Coastal Atlas of Recreational Boating), anchorages and facilities such as marinas and harbours.

Noted. Detailed mapping of specific layers will be held on the National Marine Plan Interactive web pages.

No comments.

N/A

No comments.

N/A

Yes this is important. See other comments on sport and recreation - these should form part of the strategy.

Noted.

Yes, we believe it is important to have an overarching spatial strategy and this is what the plan should be attempting to achieve, balancing the different marine activities, sectors and interests to achieve the objectives set out in the vision.

Noted.

An overarching spatial strategy is important as it can provide a coherent framework that clearly portrays the fundamental elements of the plan. Such a strategy would provide certainty to marine sectors active within the region and it would help avoid ambiguity as to the key intentions, aims and objectives of the plan.

Such a strategy should present the priority economic, social and environmental considerations and policies that together support the aims of the plan and the principles of sustainable development.

Noted.

It is important to include a spatial strategy in the marine spatial plan. We agree with the aim and broad intentions for this as set out in paragraph 10.3 of the Planning Issues and Options consultation paper. The strategy can usefully raise awareness of marine uses and users in a spatial context, although it is accepted that the spatial strategy will not be so detailed - and should not be so rigid - as to be a masterplan for future development. The spatial strategy should be informed by the spatial strategies in the terrestrial plans and by that being set out in National Planning Framework 3.

Noted: we will continue to liaise with the two local authorities to ensure the marine plan is compatible with local plans and vice versa.

We support the development of an overarching spatial strategy. However, we are pleased the consultation document states it is intended to be an 'indicative high level strategy as opposed to a master plan for future development'.

Noted.

The sectoral plans indicate potential areas of development for offshore renewables, and as stated above, we believe there should be a presumption of use for renewable energy development in these areas. The sites are identified through the Iterative Plan Review process which enables the plans to be developed in light of the most up to date technical and environmental data. It is therefore essential the pilot plan is able to adapt to emerging data which will help to secure the best developments.

Noted: all the spatial data in the Draft Plan will be 'live' and updated as appropriate within the National Marine Plan Interactive web pages. This will be accompanied by supporting text in the Draft Plan and the final Plan, which will make use of the most up to date information available. Any development will be assessed on a case-by-case basis.

Further, the sectoral plans do not prevent developers coming forward with propositions for projects out with areas identified in the sectoral plans. This flexibility must also be retained through the pilot plan.

Noted.

Yes, yes we agree with the broad approach described in the consultation paper. Additionally a specific PFOW web based GIS tool based would be a useful asset in addition to the data being available through MSi.

AP244: We will discuss the available options for displaying the various GIS layers. It may be that using National Marine Plan Interactive may be the most viable option to avoid duplication of effort.

Page 48, Paragraph 10.2

It is not clear how important areas will be identified for all sectors ( i.e. commercial fisheries) going out 20 years from now. There is great uncertainty looking ahead season by season; therefore, the assumptions will be so great as to potentially make the spatial information meaningless. How this is to be handles within the plan should be made clear.

It is acknowledged that some aspects will be easier to map than others. Where issues are changing regularly, it may be that maps are either not provided or are updated regularly but we shall use the best information we have available. The pilot Plan will be replaced by 2 Scottish Marine Regional plans in due course i.e. one for Orkney and one for North Highland. Those plans will be updated regularly, taking new information in account.

Question 16, Page 48

[Agree it is important to have an overarching spatial strategy]

Noted.

Page 48, Paragraph 10.4

No mention is made here of fisheries data (ScotMap). This should be included.

The aim of the PIOP was to present proposed themes and polices therefore could did not go into great detail on every aspect; this will be covered in the Draft Plan, along with the many other data sets being collected to provide a sound evidence base for the Plan.

Providing 'community assets' include established fishing grounds taking account of their locational specific economic contribution to the economies of Orkney and the North of Scotland, then the issues identified in para. 10.3 and sections 11 and 12 would appear to generally encompass what should be included.

AP245: We may provide a specific list of community assets in the Draft Plan or may list them within the relevant sector policies, as appropriate.

Yes. See SSPO representations and objections to the Orkney Island Proposed LDP, the Highland Wide LDP, the Outer Hebrides Proposed LDP and the Argyll and Bute Proposed LDP. Also see Q10 above.

(i) Protect marine areas suitable for salmon farming from other forms of development.

(ii) Presumption in favour of salmon farming development in all areas other than those specifically identified as being constrained.

Noted.

Comments in Question 19 box.

Noted.

Comments in Question 19 box.

Noted.

Yes, the sky, the land, the space, the peace. Dunnet Head and Duncansby Head should be preserved.

Noted.

HIE consider it is important to have an overarching spatial strategy and consider it necessary to highlight the document is intended to be an 'indicative high level strategy as opposed to a master plan for future development'.

Noted.

Comments in Question 19 box.

Noted.

Giving the differences between terrestrial and oceanic planning, the description given in 10. Spatial Strategy and information describing the proposed strategy as indicative may be exaggerating the purpose and/or need for this.

SFF would not be keen at this time to see the development of any kind of master plan, not least because of the lack of substantive knowledge of the environment being discussed.

On the other hand the SFF can see value in having indicative information available for future use in planning.

Noted.