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

None apart from saying that it should become a vital reference for all interested and impacting parties and that care needs to be taken to make sure it is maintained and adjusted as relevant in future - it needs to be a dynamic plan in that respect

Noted: the Plan will be supported by National Marine Plan Interactive data, which will be updated regularly. Once the pilot Plan process is completed, the subsequent individual Scottish Marine Regional plans for Orkney and for North Highland will be updated according to an agreed timetable.

We commend Marine Scotland on its open approach and the depth and effort of its consultation process. The language style and documents are quite heavy going and time consuming for private individuals. The PFYC generally supports the careful and thoughtful exploitation and development of the region providing this is done with all interests being equally considered. We believe that reasonable compromises are acceptable for overall societal benefit.

Noted and support welcome; it is worth nothing that these documents are being produced in collaboration with Orkney Islands Council and Highland Council.

AP249: We shall consult with our Advisory Group and stakeholders on the best way to make the Draft Plan as succinct but relevant to as many people as possible.

No comments

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No further comments.

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None at this stage, expect that we are happy to provide further advice and guidance in relation to our interests.

Noted: support welcome.

No comments.

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Scottish Water's primary functions are the production and distribution of potable drinking water and the collection, management, treatment and safe return to the environment of domestic, trade effluent and surface water drainage. Maintaining the integrity of our sewerage network, outfalls and pipelines discharging to the sea is vital in providing this essential service for the people of Scotland. In the interests of public health any statutory framework must take into account and balance the legitimate needs of all users of the marine environment including the water industry requirement to discharge treated effluent. Scottish Water's coastal (shoreline) and marine infrastructure assets are static and must remain operational 24hrs a day.

AP250: These aspects will be considered when drafting the Plan.

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No.

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No comment.

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We recognise that this consultation is of a strong planning and policy nature and therefore contains a lot of specialist terminology, however we would welcome future consultation papers on user-specific areas to be written in a more user-friendly style.

AP251: We shall consult with our Advisory Group and stakeholders on the best way to make the Draft Plan as succinct but relevant to as many people as possible.

No comments.

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No further comments.

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The Draft Plan is of a very high quality and is both legible and concise, clearly setting out the key policy and legislative drivers behind development of the plan. Furthermore the emphasis on sustainable development and the importance of these underpinning principles that are presented throughout the plan are welcomed and supported.

We hope to be engaged in further stages of the plan preparation process and look forward to seeing the proposed plan and its policies.

Noted: comments and support welcome but note that the PIOP is not a draft of the plan; that will be the next stage.

Subject to any comments provided elsewhere in this response, The Highland Council is supportive of the stated 'preferred option' in respect of each of the proposed policies.

The Highland Council welcomes being part of the Working Group that is developing the Plan and has made significant commitment to this in terms of officer time. We look forward to continuing involvement in the Working Group and continuing engagement of the wide variety of Council interests as the development of the pilot marine spatial plan is taken forward. The Plan has potential to be a very useful document to help further sustainable economic development in North Highland. We are particularly keen to ensure that marine and terrestrial planning are appropriately integrated and aligned and would welcome further discussion on how that may be achieved.

Noted: comments and support welcome.

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The overall approach is warmly welcomed and the planning issues and options paper is well considered document clearly demonstrating the benefits of multidisciplinary partnership working between Marine Scotland and Highland and Orkney Councils. We look forward to further consultation on the pilot plan.

Noted: comments welcome.

Introduction, Page 5, Paragraph 1.2

Mention is given to the Marine Energy Park; however it is not explained how this designation fits into the current consultation on the PFOW MSP. Clarity should be given as to this and also how this might affect future marine renewables developments.

AP252: The Draft Plan will provide additional detail on the status of the Marine Energy Park ( MEP). All the key players involved in the MEP are part of our consultation database.

Figure 4, Page 19

No representation is made in this figure of the Sectoral Plans for wind, wave & tidal or the current consultation on the MPA coherent network.

AP253: The left graphic on the left hand side of the figure shows the RLG for the sectoral marine plans: this will be updated if required. However, it is likely that new graphics will be required in the Draft Plan to update the information now published on a range of SG documents which were not available at the time of writing the PIOP.

Page 24, Paragraph 6.8

Mention is made of the plan being used in the determination of marine licensing applications - it is assumed that this includes Section 36 applications as well as applications for a Marine Licence? It may be better to be specific here.

Within this section called "The status of the pilot marine spatial plan" it may be opportune to set out exactly where it is likely to fit in the bigger picture and how it is likely to relate to all the other plans either currently being consulted on ( i.e. the NMP) or likely to come out in the foreseeable future.

AP254: The Draft Plan will provide greater detail on the how the Plan will be used and its status.

This information is provided in Figure 3 and will updated as appropriate.

Page 24, Paragraph 6.9

This paragraph is contradictory in nature stating initially that the proposed pilot plan will be a material consideration in any consent application determination. However, the latter part of the paragraph then goes onto state that the plan is non-statutory in nature and will only act as guidance. Paragraph 6.10 then goes onto describe that it is the Regional Marine Plans that are statutory in nature.

The pilot plan will be both a material consideration and guidance; these are not mutually exclusive. As this is a pilot process for regional marine planning, the pilot plan will be non-statutory and be used to inform the process of developing the 11 Scottish Marine Regional Plans, which will be statutory.

Page 87, Paragraph 13.2

We welcome the acceptance that the plan will have to be reviewed and updated. This is not currently clear in the consultation, but we look forward to this being addressed within the monitoring and reviewing framework within the final consultation document.

Noted.

No further comments.

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Orkney Trout Fishing Association ( OTFA) attended the Marine Spatial Plan workshop held jointly between OIC, Marine Scotland and ICIT in early July in the King Street Halls in Kirkwall. We'd like to reiterate and add the following points :

Noted.

1) In relation to Aquaculture we believe that Marine Scotland need to decide on a safe distance between salmon cages and sea trout spawning burns. Everybody (excepting some industry bodies apparently) now accept that there is a serious risk to wild salmonids from the artificially high levels of sea lice frequently found distributed on salmon farms. The massively disproportionate levels of this otherwise naturally occurring parasite, emanating from salmon farms, quite simply devastates unwitting wild fish populations. No amount of management or medicinal procedure can safely mitigate for this threat with increasing evidence of lice having evolved resistance to treatments such as Slice. Recently MS advised OIC in relation to sea based salmon farms and with regard to a proposed new aquaculture development (Cava South), that new sites should be at least 14 km away from wild salmonid spawning burns. A point that was either ignored or misinterpreted, as the development went ahead.

The Plan will not replace existing statutory requirements for aquaculture planning but will ensure that the aquaculture policy is in line with existing legislative requirements.

2) With respect to the above point there really needs to be a situation where siting and relocation of all current salmon farms is reviewed with regard to their proximity to, and influence on, wild sea trout spawning burns. Much new research and acceptance of the controversial link has emerged since most of these initial licenses were granted.

It is outwith the scope of the pilot marine plan to undertake such action; most aquaculture sites have been granted or are in the process of being granted, permanent planning permission either as part of the Scottish Government audit and review process or the local authority planning process.

3) OTFA have done a massive amount of voluntary electro-fishing and survey work to provide the local authority with information allowing the mapping of all known local sea trout spawning burns. That provides an excellent premise to avoid future conflict with wild fish populations when it comes to marine spatial planning and proposed new salmon farms. A situation so far side stepped by the powers that be.

AP255: Noted: we shall use the data to help shape the Draft Plan.

4) Orkney Trout Fishing Association are a one hundred year old, 500 member voluntary organisation who cherish and fight for the free access, effectively community owned, wild trout fishery which is almost unique in this nation. Many more local people enjoy that resource without being members. Free and responsible trout angling is engrained in our increasingly unique Orcadian identity, and therefore wherever psychological "well being" can be added to the list of criteria considerations in the document it should be. This was repeatedly mentioned at our table on the workshop day. It obviously also relates to cultural heritage, but increasingly I know of people who have given up on their previous, often massive personal volunteer effort to try and protect our wild fishery from a sea of new development proposals, often from foreign owned companies providing foreign markets with what is effectively unsustainably produced salmon. This is a sad reflection on a much changed planning system that increasingly seems to exist solely to suit new political ends. It used to be considered our human right to fish for an easily sustainable wild fish and now lots of people are giving up because of damaged and lost populations of sea trout to badly located salmon farms. This does have a psychological effect on ones sense of well being and "quality of life".

Noted.

AP256: A Quality of Life / Well Being policy section will be developed in the Draft Plan.

5) Another concern raised at our table at the workshop was that the voluntary sector is suffering from consultation fatigue and the constant barrage of lengthy and increasingly complex consultation documents. There is also a feeling that responses that go against current political will are routinely ignored and side stepped, to the point that it was generally agreed that the larger community in Orkney are totally disillusioned and disengaged with the whole concept of consultation. Similarly the increasingly rare members of the general public who have to find the time to do this are constantly up against an army of financially interested professionals only interested in "economic growth" or some other political agenda.

Whilst recognising there are many public consultations in the area, we have a duty to consult and do value local opinion. We also have a duty to conform to Scottish Government policy to support the local economy, thus supporting the viability of local communities.

6) In an official survey carried out a few years ago, angling tourism was valued at £1.7 million per annum and is a valued part of Orkney's existing and eminently sustainable portfolio of economic resources. This resource, because it already exists and provides valuable income to a whole range of businesses, needs to be protected when any proposed new developments - increasingly carrying the ominous attachment of "being in the greater national interest" - are put on the table.

AP257: It would be helpful if any data held by OTFA could be supplied to help shape the Draft Plan. As the Plan will bring together information on all the main sectors currently or proposing to use marine resources it will highlight existing users and the balance required between new and existing activity.

7) In relation to the above, I have found that visiting anglers hold our cultural heritage and Orcadian "character" in high esteem as well as naturally associating the word "Orkney" with a relatively pristine and not overly developed land and seascape. It currently enjoys a fine balance of agricultural and wild land as well as partially developed sheltered coastline and large areas of beautiful and undeveloped coast - often epitomising the word "wild". A massive and increasingly vulnerable asset.

AP258: Any coastal designations of wild land will be mapped in the Draft Plan or the supporting National Marine Plan Interactive.

8) Orkney Trout Fishing Association ( OTFA), in the absence of any local Fisheries Trust or Rivers Board, are widely accepted as being the local organisation with a responsibility to, and active interest in, wild salmonids.

Noted.

We want nothing more than a truly sustainable and responsible aquaculture industry that is willing to coexist with an increasingly rare, historically important and eminently sustainable wild sea trout population.

Noted.

I attended the recent Marine Spatial Plan workshop in Kirkwall and would like to add the following points.

Whilst recognising there are many public consultations in the area, we have a duty to consult and do value local opinion. We also have a duty to conform to SG policy to support the local economy, thus supporting the viability of local communities.

1) It was generally agreed at our table that everyone is suffering from consultation fatigue, especially the few people who have to engage voluntarily on behalf of community organisations and local groups. We also came to the conclusion that there was a complete mistrust locally after repeated local consultations had effectively ignored many well known concerns. I notice a new raft of consultations are currently out with regard to marine and country planning and there is a feeling that they exist not to protect our land and seascape any more but to allow politically motivated, big business growth in previously "no go" areas.

Noted: however, this Plan will also cover north Caithness and Sutherland therefore a balance is required between these areas.

2) What is considered to be justifiable when it comes to allowing development in previously undeveloped and wild areas of coastline seems to now rest on phrases like "in the national interest" and again this seems to put a national political agenda in higher priority than local cultural concerns. This needs to be addressed especially with regard to Orkney's unique cultural identity where we are Orcadian first and Scottish only second. Along with Shetland, Orkney is the least "Scottish" of all the island groups therefore we also have our own version of "national interest" it being "Orcadian interest" !

AP259: We shall ensure that cultural identity, quality of life and general well being of Orcadians, along with the people of north Caithness and Sutherland, are given due consideration in the Draft Plan, with an aim to have these issues embedded within a well-being and quality of life policy section.

3) In respect to the above Cultural identity and what it means to be Orcadian is informed by where you were brought up and what you associate with being Orcadian. I have a part time career as a contemporary visual artist and am heavily involved in Orkney's cultural sector. I completely associate Orkneys wild western coastline with my identity as an islander and would hate to see - as yet - unproven technology strewn it's length and breadth as is already proposed. The Crown Estate famously set a bad precedent, and presumption for development to go ahead, by leasing these vast areas of sea without effectively engaging the local community in any way that I can find. Therefore I feel very strongly that cultural identity, quality of life and general well being need to be considered separately and wherever possible within the document.

AP260: As part of a the evidence gathering for this Plan process, we shall be undertaking a tourism and recreation case study to identify the key assets to ensure they are given due consideration within the Draft Plan.

4) To many local artists and Orkney's largely unrepresented creative sector the undeveloped western coastline of the mainland of Orkney epitomises a unique creative cultural heritage in particular. In it's undeveloped state it has been an inspiration to generations of globally recognised writers and internationally exhibited artists. All these people have to make a living and it is therefore an existing economic resource, crucially in it's current "undeveloped" state. This sort of creative economy remains a great model of true sustainable development in an island community. In the same sense tourism and it's huge influence on the Orkney economy relies on visitors wanting to come to experience this place. Time and again I am informed by visitors to Orkney (that actually spend more than a day here) that one of the main reasons for coming here is their expectation and desire to see unspoiled "island" views and nature in the "wild" which is something they are not disappointed by. Again this is part of an existing economic resource which is eminently sustainable for future generations. Therefore it needs to be quantified and properly assessed in it's current state as to it's future importance to a truly long term sustainable Orkney

Noted.

5) Orkney currently, despite the recession, has one of the lowest unemployment figures in the country. Do we really want to see 4000 new jobs in Orkney by developing Marine Energy to it's biggest projected conclusion as has recently been claimed. That would mean, along with employees partners and family's, a population increase of nearly a third !! What effect would that have on our quality of life, well being and the Orkney identity ? Socio economic assessment has to look at the negative as well as the nationally perceived positive.

AP261: A Quality of Life / Well Being policy section will be developed in the Draft Plan.

6) I hold (value) my environment and culture in the highest regard : it makes me who I am. Recent public surveys have found Orcadians and Sheltlanders to be some of the happiest people in the country. This is no accident - we do enjoy a fine balance between development and nature at the moment. This could easily be destroyed. So- called future large scale economic growth shall not necessarily benefit Orkney in the long term. However I am confident that Orkney shall survive and continue to thrive if none of this development goes ahead. Can any consultant prove otherwise ?

Noted.

No comments.

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On behalf of DSRL, I would like to submit the response below to the Pilot Pentland Firth and Orkney Waters Marine Spatial Plan.

The Dounreay nuclear site is currently being decommissioned to its "interim end state" - the point when all the redundant buildings have been cleaned out and demolished and the radioactive waste made safe for long-term storage or disposal. The aim is to achieve the interim end state by 2025. As part of our decommissioning programme we work closely with agencies to minimise the effect of the decommissioning activities to the local economy. Therefore the proposed plan is welcomed as it will assist in developing the local economy.

Noted: support welcome.

I would draw your attention to our activities associated with the clean-up of the marine environment around the Dounreay site, details of which can be found at www.dounreay.com/particle-cleanup. We would encourage anyone considering a development in the area adjacent to our site to contact us to discuss how this could be undertaken and ensuring any conflicts are appropriately managed.

AP262: We shall look at the information provided to see how we can use it to shape the Draft Plan .

No comments.

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