Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Strategic Environmental Assessment Post-Adoption Statement.
Strategic Environmental Assessment Post-Adoption Statement.
3 Views on the Planning Issues and Options Consultation Paper (PIOP) and Draft Environmental Report
3.1 Overview
3.1.1 The following sections of this Statement provide a summary of views expressed in the consultation on the PIOP undertaken in June and July 2013, those received on the draft SEA Environmental Report, and how these have been considered in the development of the Pilot Plan.
3.2 The Consultation and Engagement Processes
3.2.1 A total of 30 responses were received in the relation to the PIOP during its public consultation, including several respondents that also submitted separate responses relating to the draft Environmental Report, or provided comments on both the PIOP and the draft Environmental Report in joint responses. Consultation events were also held in Kirkwall and Thurso alongside public drop-in sessions in July 2013, and meetings with stakeholders were also conducted at this time to actively seek out the views and suggestions from stakeholders at an early stage in the Pilot Plan's development.
3.2.2 A detailed breakdown of these responses and further detail on the themes and issues raised during the consultation is provided in the Consultation Analysis [8] and the Consultation Report [9] .
3.3 Summary of Views Received on the PIOP
3.3.1 A wide range of detailed comments were received in the consultation on the PIOP and there was also discussion on a diverse range of issues at each of the workshops and drop in sessions.
3.3.2 The views expressed by respondents in the consultation largely focused on issues that the respondents felt were important considerations to ensure that the Plan was fit for purpose. For example, the suggestions included ensuring that the vision and objectives of the Pilot Plan were clear, that a balanced approach to planning and sustainability was undertaken, and reinforcing the importance of ongoing engagement with stakeholders in the Plan's development.
3.3.3 These views are summarised in Table 3.1 alongside an explanation of how the issues raised were considered, and where appropriate, addressed in the evolution of the Pilot Plan.
Table 3.1 Summary of Views Received on the PIOP
| Summary of views received in the consultation on the PIOP | Response |
|---|---|
| The Pilot Plan should have a clear vision and objectives. | The vision and objectives for the plan were developed and set out in the draft Pilot Plan and considered in the SA report. These have since been taken forward in the development of the finalised Pilot Plan. |
| There should be clear and consistent use of terminology and definitions, with links to relevant Scottish Government work, plans and other relevant information. | This comment has been noted. Engagement with stakeholders and numerous public consultations has enabled the use of terminology and definitions to be progressively refined prior to the publication of the finalised Pilot Plan. The development of the PIOP, draft Pilot Plan and Pilot Plan involved several stages of review of the policy context of the Pilot Plan. This process enabled the progressive identification of links to other relevant plans and studies; many of which were developed since the initiation of the Pilot Plan process ( i.e. National Planning Framework 3 ( NPF3), Scottish Planning Policy ( SPP) and National Marine Plan ( NMP)). |
| A very clear need was identified for on-going consultation with a wide range of stakeholders. | Consultation was a key aspect of the Plan development process from its initiation. Stakeholder engagement was undertaken in the development of the PIOP, the development of the draft Pilot Plan and its General and Sectoral Policies, and several stages of consultation on both these documents, and their associated documents ( i.e. RLG, draft Environmental Report, SA). The SA also identified the importance of engagement and achieving the 'buy in' of stakeholders, planning bodies and communities in order to achieve the potential benefits identified. |
| It was felt that clarity was needed in relation to the information that will be used for the evidence base to inform the Plan. | Baseline information gathered in the preparation of the draft Environmental Report on the PIOP; the SA, RLG and socio-economic baseline processes for the draft Pilot Plan; and the views expressed by attendees of workshops, drop in sessions and via written responses were important considerations in the development of the Pilot Plan and its policies. |
| Some respondents provided detailed comments in relation to the proposed policies, and some suggesting changes to wording. | All comments received have been noted in the progression and finalisation of the Pilot Plan. The views expressed by attendees of workshops, drop in sessions and in written responses have been important considerations in the development of the Pilot Plan and its policies. |
| Some noted a need for a balanced and sustainable approach to planning. | As set out in the Environmental Report, the development of the Pilot Plan was focused on "balance[ing] the competing demands of economic sectors and local communities for the use of the coastal and marine waters in the PFOW, whilst promoting sustainability, early engagement amongst stakeholders and the protection of the coastal and marine environments on which these sectors and communities depend". Undertaking the SA on the Pilot Plan and its many policies took this approach further forward, and set the foundation for providing a balanced assessment of the potential for social, economic and environmental effects associated with the adoption of the Plan; one with sustainability as a key component. |
| It was felt that the Plan area should be based on the proposed Scottish Marine Regions Orkney and North Coast regions. | This comment was noted and the area considered by the Pilot Plan was expanded to reflect the development of the Orkney and North Coast Marine Regions. The revised Pilot Plan area is set out in the Pilot Plan. |
| The need for integration of marine and terrestrial planning was identified in the responses. | The integration of marine and coastal planning was addressed primarily through the inclusion of General Policy 7 (Integrating Coastal and Marine Development) in the Pilot Plan. |
| Some also noted a need to ensure that existing legislation was taken into account and that the policies did not add unnecessary extra requirements. | The development of the General and Sectoral Policies for the Pilot Plan involved the review of existing legislation and relevant plans, programmes and strategies ( PPS) relevant to the sectoral and cross-cutting issues associated with the Pilot Plan. These reviews are set out in the PIOP, the draft Pilot Plan and the finalised Pilot Plan. The General and Sectoral policies were developed through engagement with stakeholders and the wider public, including representatives of the sectors themselves. The draft Environmental Report and SA Report also set out the policy context for the Pilot Plan, including a review of relevant environmental protection objectives and consideration of cumulative and in-combination effects. |
| One consultee felt there was a need for an overarching spatial policy for the Plan. | A re-occurring theme throughout the plan making process for some stakeholders related to how spatial the Plan should be. The PIOP suggested an overarching spatial strategy with maps identifying key features such as natural heritage designations. This was generally supported by the majority of respondents and throughout the process, and it was generally viewed that taking a strict zoning approach was not achievable at this stage of the marine planning process. The inclusion of a more spatial or zoning policy was considered and assessed in the SA, and details of this process are discussed further in Section 6. |
3.4 Summary of the Findings of the Draft Environmental Report
3.4.1 The draft Environmental Report was prepared alongside the PIOP and published for public consultation in 2013. As a draft, the Report explored the potential for environmental effects associated with the adoption of a Marine Spatial Plan for the PFOW area, and provided an early assessment of a range of policy sectors against seven SEA objectives [10] . This work was undertaken at an early stage of the development of the Pilot Plan, and the assessment within the draft Environmental report reflects this. Subsequently to the consultation, both the approach to the development plan and its SEA and SA also evolved.
3.4.2 The Draft Environmental Report identified that, on balance, the development of a Pilot Plan area would likely lead to significant environmental benefits by providing a holistic approach to marine development in the PFOW area. However, the potential for impacts on environmental resources in the PFOW area was also identified, relating primarily to impacts and pressures from marine use in general, and the importance of appropriate management of its resources.
3.4.3 The draft Report also identified the potential for localised and cumulative impacts on a number of environmental topic areas; a finding further explored in undertaking the SA of the draft Pilot Plan. In particular, the potential for impacts on biodiversity and natural heritage ( i.e. disturbance, damage to, or loss of, habitats and species) and visual, access and noise amenity value for coastal residents and visitors were identified. The SEA also identified the potential for significant benefits for climatic factors.
3.4.4 However, it found that any such effects would likely be dependent on a range of local factors ( i.e. location, siting, design, layout and construction processes required for each sector); many of which were uncertain. Notwithstanding this uncertainty, it was anticipated that most effects could potentially be mitigated. For example, the SEA considered that the potential for adverse effects on biodiversity, cultural heritage, landscape, geology and water quality had the potential to be largely mitigated at the project level through measures such as Environmental Impact Assessment ( EIA), Appropriate Assessment ( AA), and appropriate planning, assessment design and construction of developments.
3.4.5 Furthermore, the draft Report found that the consultation process would assist in identifying outstanding issues and that the data from the plan-making process would likely help in finalising policy options that minimise environmental impacts. Along with the consultation process, the findings of the Draft Environmental Report directly informed the development of the Pilot Plan, its SA and the preparation of the SA Report. The findings of the SA are summarised in Section 5.4.
3.5 Views Received on the Draft Environmental Report
Overview
3.5.1 Comments relating to the draft Environmental Report were received from six respondents, including the three statutory Consultation Authorities [11] , one recreational organisation, one environmental non-governmental organisation ( NGO) and a public body.
3.5.2 The main issue raised in these responses related to the assessment methodology used in the SEA. The Consultation Authorities' comments raised concerns regarding the approach to the assessment and the transparency of communication of the decisions made. These comments included suggestions for improvement for the next iteration of work.
3.5.3 There was support amongst respondents for ensuring that future development and use of the marine area did not result in irrevocable damage to the marine environment, either specific activities in isolation or cumulatively. There was also support expressed for the inclusion of those who seek, and have aspirations for, the protection, enhancement and sustainable management of the PFOW area's natural resources as 'users of the marine environment'. However, it was a common theme amongst respondents that existing users also need be taken into account.
3.5.4 Some respondents also made specific comments relating to some policy areas; in particular, topics such as aggregate extraction, sea dumping [of dredged material], artificial structures along the coastline, the protection of fish and commercial fishing under controlled circumstances, and the impact of the aquaculture industry on safe navigation and anchorages were discussed by respondents. However, many respondents also identified a need to fill knowledge gaps in these areas; data gaps in biodiversity in particular.
Specific Comments on the Draft Environmental Report
3.5.5 Specific comments received in the consultation and the responses to them are set out in Table 3.2.
Table 3.2 Summary of Views Received on the Draft Environmental Report
| Summary of views received in the consultation on the Draft Environmental Report | Response |
|---|---|
| The responses received from the Consultation Authorities indicated that they were not clear that the Report was a draft, and was not the final Environmental Report. | A meeting was arranged with the Consultation Authorities, the Working Group and a representative of the Scottish Government Environmental Assessment Team in August 2013 to discuss this lack of clarity. This also provided an opportunity for the Consultation Authorities to outline what they expected from the final Environmental Report. The views expressed by the Consultation Authorities were noted and used to inform the subsequent SEA process. These views and suggestions were used to develop the SA ( e.g. provision of greater clarity and revision of grading of environmental effects, amongst others). |
| One respondent felt that there was a need for consistency between the Plan purpose and its objectives. | This comment was noted. |
| Some respondents provided updates to references for sections of the draft Report. | These suggestions were noted and used in the development of the finalised Pilot Plan. |
| It was noted by one respondent that they felt it was difficult to accurately assess the environmental impacts of the Plan in any detail as the proposed policies, at this stage, had not been finalised. | At this stage of the SEA process, the draft Environmental Report was developed to assess the impacts of a marine plan that was still in development. As such, the assessment was based on the objectives and vision of the general and sectoral policy areas proposed for inclusion in the draft Pilot Plan; and as such, this involved a number of assumptions. The development of the SA took the findings and assumptions of the Environmental Report forward, and was focused on both the specific policies as they were being developed and considered the potential overarching effects of the Plan and its many policies. |
| The main issue raised by the Consultation Authorities was that they felt that the assessment methodology had been altered in light of comments received from the Consultation Authorities at the scoping stage. Concern was expressed that these changes meant that the assessment methodology and scoring system used in the draft Report was not sufficiently clear, and it was felt that this made it difficult to comment on the conclusions of the assessment. The respondents also felt this had led to a lack of consistency with the PIOP. |
At this stage of the SEA process, the draft Environmental Report was developed to assess the impacts of a marine plan that was still in development. As such, the assessment was based on the objectives and vision of the general and sectoral policy areas proposed for inclusion in the draft Pilot Plan; and as such, this involved a number of assumptions. As the Pilot Plan and its policy areas evolved, the SEA and its methodology also evolved to ensure that the assessment was robust and beneficial to the Plan's development ( e.g. undertaking an integrated SA). This was discussed at the August 2013 meeting between the Working Group and the Consultation Authorities, where it was clarified that the Report was a draft and that the SEA process was ongoing. The Consultation Authorities then provided their views on how they felt the work should progress and indicated their willingness to assist with this process. Their views were noted and used to inform the development of the Pilot Plan and the SA Report. |
| The respondents felt that the assessment needed further detail, particularly in how the assessment scores on the potential for impacts on the various sectors were developed ( i.e. renewables, aquaculture, ports and harbours). They felt that further clarity was needed regarding how the SEA objectives had been developed. Comments were also provided on the proposed alternative approaches to the assessment, including the assessment of cross cutting policies and development of mitigation measures. Some made suggestions for how the information presented in the draft Report could be improved. |
On-going discussion with the Consultation Authorities and other stakeholders was undertaken as the Pilot Plan and SEA developed, to consider and clarify the issues raised, and ensure that the views of the Consultation Authorities directly informed the SEA and SA processes. The views of the respondents were considered as the process evolved, including during the move towards an integrated SA approach. In particular, the development of the SEA objectives and assessment scoring process were revised and greater clarity provided on them, particularly in explaining the rationale behind the use of a grade system. |
| Another respondent supported the development of the Plan, but added that they were "not unsupportive" of developments taking place as long as existing uses were taken into account. | These comments were noted. |
| Specific comments were received relating to aggregate extraction and sea dumping [of dredged material], artificial structures along the coastline, the protection of fish and commercial fishing under controlled circumstances and the impact of the aquaculture industry on safe navigation and anchorages. | On-going discussion with stakeholders from these sectors was undertaken as the Pilot Plan and SEA developed, to consider and clarify the issues raised, and ensure that stakeholder views informed the SEA and SA processes. These comments were noted in the finalisation of the Pilot Plan and its general and sectoral policies. |
| Concerns were expressed by one respondent over the potential for long term cumulative effects, and they felt that there was a needed to ensure that development did not result in irrevocable damage to the marine environment. | These comments were noted. The potential for future development and use of the PFOW marine area to result in adverse impacts was a key focus of the SA and the development of the sustainability ambitions set out in the Pilot Plan. |
| Another respondent felt that users of the marine environment considered in the Pilot Plan should include those who seek, and have aspirations for, the protection, enhancement and sustainable management of the area's natural resource. They felt that this would include environmental NGOs. |
This comment was noted in the finalisation of the Pilot Plan and its SA. The Pilot Plan sets out an integrated planning policy framework to guide marine development, activities and management decisions in the PFOW area, and promoting integrated and sustainable decision on marine use and management. It also seeks to balance the needs of a diverse range of economic sectors with those of local communities, whilst also protecting the environment and natural resources on which these depend. |
| Specific comments were received regarding the terminology used in the Environmental Report. For example, one suggested that the phrase "sustainable economic growth" be replaced with "economic growth" or "sustainable growth". | These comments were noted and considered in finalisation of the Pilot Plan and its SA Report. |
| Suggestions were made regarding filling of knowledge gaps in relation to biodiversity, with suggestions made for additions to specific sections. | These comments were noted. Section 7 of this Statement sets out the Monitoring Framework for the Pilot Plan. |
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