Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Strategic Environmental Assessment Post-Adoption Statement.

4 Views on the Draft Pilot Plan and its Associated Reports

4.1 Overview

4.1.1 The following sections set out a summary overview of the views expressed in the consultation undertaken on the draft Pilot Plan and its associated documents.

4.1.2 At total of 31 responses were received in the consultation including 28 responses containing comments specifically in relation to the draft Pilot Plan and a further three responses from the Consultation Authorities specifically addressing the Sustainability Appraisal. The Consultation Analysis and Modifications Report ^[12] presents a detailed breakdown of these responses and sets out how respondents' views have been considered and where appropriate, actions have been taken in the finalisation of the Pilot Plan.

4.2 General Views on the Draft Pilot Plan

4.2.1 A wide range of comments were received in the written consultation and during consultation workshops. These ranged from detailed responses covering a broad spectrum of topics and issues, to others that addressed specific issues, activities and/or sectors. A broad summary of the key findings of the analysis of views expressed in the consultation and workshops is presented below, with further detail provided in the Consultation Analysis and Modifications Report for the Plan ^[13] .

4.2.2 Overall, many respondents welcomed the development of the Pilot Plan and the approach taken by the Working Group. There was a general view that the Pilot Plan would form a good basis for the development of the two upcoming statutory Regional Marine Plans in the PFOW. Some also stated that they welcomed the opportunity for involvement in the process and expressed support for the collaborative work undertaken between Marine Scotland, Orkney Islands Council and the Highland Council in the Pilot Planning process. This was coupled with strong support by many stakeholders for being involved in the development of the Pilot Plan and its policies, and support for continued involvement in the development of the upcoming Regional Marine Plans.

4.2.3 The content of the Pilot Plan was the primary topic of discussion amongst the responses received. Some of these comments related to the ambition and focus of the plan. For example, one respondent felt that the Plan should more strongly reflect strategic/forward thinking in the planning process and that it could provide a 'call to action' to help inform the management of activities that are not subject to marine licensing. It was also noted that setting out key actions could help the upcoming Regional Marine Plans drive progress beyond current statutory regulatory requirements, and help contribute to the management of specific activities, including those that do not currently require spatially-specific consent.

4.2.4 Many respondents provided suggestions for improvement to the Plan and/or its development process. In particular, the detail of the Pilot Plan was raised in many responses with mixed views expressed over its length. Some felt the Plan was too lengthy, with one stating that it contained "a lot of information". For example, some felt that the text in the policy sections could be more concise or be focused on particular issues relevant to the PFOW area. However, others suggested the inclusion of further or alternative information would be beneficial. For example, some felt that additional information, particularly spatial information, could have been included to help guide potential developers and streamline the planning process ( e.g. inclusion of a constraints mapping component). Several also gave suggestions for clarifying or correcting information presented in the Pilot Plan, its RLG and/or Sustainability Appraisal.

4.2.5 It was also noted by some that the policies set out in the Plan largely followed those contained within the NMP, and several also felt that the ambitions and actions set out in wider policy should also be reflected in the development of policies in the Pilot Plan ( e.g. Plans for offshore renewables, fisheries and aquaculture policy). However, others suggested that the policies should be in a similar format to those within the NMP, or that these could be linked to those in the NMP or National Marine Plan Interactive ( NMPi).

4.2.6 Many of the responses provided comments addressing the general and sectoral policies set out in the Pilot Plan; particularly those from marine users. Many were related to potential for improvements to the policies, including some that suggested the use of terminology, clarifications and corrections. However, these comments were primarily related to the policy content itself. There was overall support for the inclusion of many of the policies within the Pilot Plan; notably the inclusion of policies relating to invasive non-native species, the range of sectors included, and the consideration of sustainability ambitions in the Plan in the social, economic and environmental context. In particular, the importance the Pilot Plan provides in seeking to preserve and improve the management of high quality marine ecosystems in the PFOW was noted, and its fundamental role in providing a basis for sustainable development.

4.2.7 A need for co-ordination between marine and terrestrial planning was identified and the need for links to Local Development Plans ( LDP) also discussed for some activities spanning both the marine and coastal environments ( e.g. ports and harbours, pipelines, electricity and telecommunications infrastructure). Support for licensing and consenting authorities working together in 'streamlining' application processes was also conveyed, although there appeared to be mixed views held by respondents over the use of single EIAs for projects with both marine and terrestrial components.

4.2.8 Some respondents felt that co-existence between users is not always possible; a view that reflected similar comments provided on some of the sectoral policies. However, this view was coupled with those of other respondents that identified a range of synergistic effects associated with coastal and marine use in the region ( e.g. the importance of ports and harbours for numerous sectors). There was also much discussion of how the policies and their performance would be measured and how this could contribute to meeting wider goals; many of which were viewed as challenging to measure ( e.g. well-being, quality of life and amenity).

4.2.9 There was some disagreement over the way some marine activities were addressed in the sectoral policies, with these views being split largely along sectoral lines. While many comments were received on issues promoting activities in specific sectors, some also expressed concerns that some marine activities are not likely to be compatible for co-existence and that there is likely the potential for displacement of some activities.

4.2.10 In contrast some respondents also supported the ambition for promoting communication and engagement between coastal and marine users, and stated that the potential for impacts can often be avoided or mitigated through early communication. Some commented that the policies included in the draft Pilot Plan were "vague" and that they should more closely reflect the marine activities of the region and pressures. In particular, some felt that the sectoral policies should contribute more than they did in the Draft. For example, one respondent felt that it should both provide a strategic direction and look at impacts of coastal and marine activities on the environment, including their effects on other marine activities ( e.g. effects on navigational safety, displacement of other activities and users).

4.2.11 Some identified data gaps that they felt needed to be addressed, and many raised a need for further monitoring to both inform future decision-making and monitor the Pilot Plan's performance ( i.e. investment in monitoring, identification of specific monitoring needs, post-consent monitoring).

4.2.12 The Consultation Analysis and Modifications Report ^[14] presents a detailed breakdown of these responses and sets out how respondents' views have been considered, and where appropriate, the actions that have been taken in the finalisation of the Pilot Plan.