Pilot Pentland Firth and Orkney Waters Marine Spatial Plan

Section 1: Introduction and Plan Vision

Purpose of this Marine Spatial Plan

1 We are in an era of great change with regard to the use of the marine environment with many emerging opportunities to support the sustainable management of resources and sustainable economic growth. The pilot Pentland Firth and Orkney Waters Marine Spatial Plan ( PFOW MSP) sets out an integrated planning policy framework to guide marine development, activities and management decisions, whilst ensuring the quality of the marine environment is protected.

2 It is essential that marine resources are appropriately managed if we are to realise the enormous potential for our seas to provide sustainable resources, jobs and wider economic benefits. Many activities such as commercial fishing, renewable energy, tourism, recreation, aquaculture, shipping, and oil and gas all contribute towards this diverse marine-based economy and these need to be properly managed to ensure these benefits are lasting and sustainable. This pilot Marine Spatial Plan aims to balance the needs of these economic sectors and local communities, whilst protecting the environment on which they depend.

3 The main purposes of the pilot Plan are:

to establish a coherent strategic vision, objectives and policies to further the achievement of sustainable development including the protection and, where appropriate, enhancement of the health of the Plan area

• to inform and guide the regulation, management and use of the area to which the Plan applies
• to provide reliable and robust information to support the Plan policies
• to guide the location of all marine development(s) and/or activities and ensure they occur in the most suitable and least sensitive areas
• to minimise conflicts of interest and encourage compatible uses
• to provide clarity and direction to users of the marine environment as to how it will be managed and regulated and the framework within which decisions will be taken
• to set out sustainable development objectives that respect environmental limits to ensure healthy and productive seas in the future
• to develop a policy framework that supports integrated marine and terrestrial planning and development

The purpose of the pilot Marine Spatial Plan process

4 The marine spatial planning pilot in the Pentland Firth and Orkney Waters aims to put in place a planning policy framework in advance of statutory regional marine planning to support sustainable decision making on marine use and management. It is anticipated that this pilot Marine Spatial Plan will establish a useful basis for the preparation of the two separate regional marine plans for Orkney and the North Coast Scottish Marine Regions. Through the process of producing this pilot Marine Spatial Plan for Pentland Firth and Orkney Waters, there have been many lessons learned. These will be published separately and will inform the preparation of future regional marine plans and the governance arrangements that could underpin Marine Planning Partnerships. The pilot has enabled the working group (see paragraph 27) to consider effective ways to:

• consult relevant stakeholders and communities to develop a strategic vision, objectives and plan policies
• where possible, streamline the processes for input from stakeholders to minimise unnecessary burden
• document the process of developing a pilot Marine Spatial Plan so that it can then be utilised by future marine spatial planners, i.e. to develop regional marine plans across Scotland
• consider appropriate governance arrangements and identify lessons learned to effectively deliver marine plans at the regional level. Governance arrangements for the pilot Plan are set out in the Pentland Firth and Orkney Waters Marine Spatial Plan Governance Paper

5 Following the preparation of the pilot Marine Spatial Plan, the working group will review the process, document the outcomes and disseminate the knowledge gained to inform other marine planning initiatives.

Geographical coverage of this Marine Spatial Plan

6 The geographical extent of this Marine Spatial Plan comprises the territorial waters from mean high water springs out to 12 nautical miles. The Plan area includes the intertidal coastline of Orkney, Sule Skerry and Sule Stack, Stroma and the north coast of mainland Scotland from Duncansby Head along the Caithness and Sutherland coast to Cape Wrath (Map 1). This area encompasses the full extent of the Orkney and North Coast Scottish Marine Regions.

Map 1: Geographic coverage of the pilot Pentland Firth and Orkney Waters Marine Spatial Plan. The area combines the Scottish Marine Regions of Orkney and the North Coast.

Spatial approach to the coastal zone

7 A coastal zone has not been geographically identified within this Marine Spatial Plan. For Orkney, the Orkney Local Development Plan (Adopted - April 2014) ^[1] identifies a coastal zone. The revised Caithness and Sutherland Local Development Plan proposes to include elements on marine and coastal planning to ensure an integrated approach though it is not intended that the coastal zone will be identified.

8 Marine and terrestrial environmental assets, sensitivities and/or constraints (e.g. nature conservation designations, listed buildings, scheduled monuments) have been spatially identified within this Plan. To avoid duplication, and to avoid plans becoming outdated and inconsistent with each other, as a general principle other terrestrial planning constraints, assets and receptors identified in neighbouring local development plan proposals maps, or in supplementary guidance, have not been mapped within this Plan. For example, coastal land use allocations (e.g. housing, business and industrial land) have not been spatially identified within this Plan. For these land allocations, reference to the relevant local development plan, associated supplementary guidance or development brief has been provided.

9 The location of existing coastal infrastructure (e.g. ports, harbours and slipways) has been identified in this Plan.

Vision, guiding principles, aims and objectives

10 An overarching vision, set of guiding principles, aims and objectives establish the context for the preparation of the policies with this Plan. The Planning Issues and Options Consultation Paper ^[2] published in 2013, provided an opportunity for stakeholders to put forward their vision for the Plan area and to provide input into the development of the Plan's guiding principles, aims and objectives. The working group, in collaboration with an advisory group, have developed the following framework taking cognisance of stakeholder views and the wider legislative and policy context including the UK Marine Policy Statement ^[3] and the National Marine Plan ^[4] .

11 This Marine Spatial Plan has been developed to closely align with the National Marine Plan, National Planning Framework 3 and Scottish Planning Policy. To achieve this, the Plan was prepared in parallel with Scotland's National Marine Plan. It is recommended that users of this Marine Spatial Plan refer to Scotland's National Marine Plan for further information on relevant topics and issues. Future statutory regional marine plans will be expected to comply with the objectives and policies within the National Marine Plan.

Vision

Pentland Firth and Orkney Waters will be a clean, healthy, safe, attractive and productive marine and coastal environment that is rich in biodiversity and managed sustainably to support thriving and resilient local communities.

Guiding Principles

• Sustainable development
• An ecosystems approach to the management of human activities, climate change adaptation and mitigation
• Multiple use of marine space, supporting coexistence of marine development and activities
• Partnership working and stakeholder involvement

Aims

To ensure sustainable use and management of the marine environment by providing a strategic planned approach that supports:

• sustainable licensing, consenting and management decisions in relation to development and activities in the Pentland Firth and Orkney Waters area
• marine developers in early identification of localities of most and least constraint
• environmental protection and, where appropriate, enhancement measures, to satisfy statutory requirements and policy commitments, and to provide identifiable socio-economic benefits for local communities and wider stakeholders

Objectives

1. Support long-term productivity in the marine environment that provides benefits and prosperity for local communities and wider stakeholders.
2. Support the transition to a low carbon economy.
3. Encourage a sustainable coexistence and synergies between existing and new marine activities and developments, to the mutual benefit of multiple stakeholders.
4. Provide reliable information on existing and proposed marine activities.
5. Promote best practice to manage and make use of natural resources within sustainable limits.
6. Within an ecosystem approach, protect and enhance the biological, chemical and physical functioning of the marine and coastal environment, the scenic quality and coastal character.
7. Promote an ecosystem based approach to the management of human activities to support the achievement of Good Environmental Status of marine and coastal waters under the Marine Strategy Framework Directive.
8. Support the cultural and social wellbeing of local communities including the maintenance and enhancement of quality of life, and visual amenity in coastal areas.
9. Support management of the marine environment, marine development and infrastructure that mitigates and is resilient to the effects of climate change.
10. Support sustainable management of the coastal zone and inshore waters, including minimising and mitigation of cumulative impacts from marine developments.
11. Identify marine planning and/or governance related issues to inform the future regional marine planning process.
12. Pilot the development of an integrated marine planning policy framework for the future North Coast and Orkney Scottish Marine Regions.
13. Assist Plan users to navigate the complex legislative and policy framework more easily and effectively.
14. Provide a clear strategic direction and greater certainty for prospective developers, investors and local communities in the Pentland Firth and Orkney Waters area.

Spatial Diagram

12 The spatial diagram (see below) presents an indicative overview of key marine activities, infrastructure, natural and historic environment assets within the PFOW area. It should be noted that the spatial diagram is designed to give an overall impression of the complex patterns of use in the Plan area. The detailed data that underpins the spatial diagram is displayed in the general and sectoral policy maps in the Plan. The diagram shows that the use of the Plan area is highly complex with most areas having multiple uses. For accurate versions of these datasets please see National Marine Plan interactive ( NMPi, see paragraphs 43-44) or the map accompanying the relevant policy within the Plan. Marine aggregates data are not displayed on this diagram as there is currently no commercial marine aggregate extraction activity in the Plan area and its inclusion on the diagram would have significantly reduced legibility.

The PFOW marine environment

13 The waters of the Pentland Firth and around Orkney are rich in biodiversity, supporting a wide range of valuable and important habitats and species, many of which are considered rare and/or vulnerable. In addition to forming key elements of the quality of biodiversity in the PFOW and Scotland's seas, these species and habitats also provide essential environmental, social and economic benefits.

14 The value of many marine and coastal habitats such as submerged reefs, maerl beds, sandbanks, salt marshes and dune systems is recognised through their designation at the European (e.g. EC Habitats Directive (92/42/ EEC ⁵) Special Areas of Conservation ( SACs)) and national levels (e.g. Sites of Special Scientific Interest ( SSSI)). There are four SACs in Orkney (Sanday, Loch of Stenness, Stromness Heaths and Coast, and Hoy) and three SACs on the north Caithness and Sutherland coast (Strathy coast, Invernaver, and Caithness and Sutherland Peatlands). These are designated for the protection of marine and coastal habitats, with 29 sites having coastal or marine biodiversity interests in Orkney and along the north Caithness and Sutherland coast receiving protection as SSSI. Furthermore, three Marine Protected Areas ( MPAs) were designated in the PFOW in 2014 with biodiversity interests; North-west Orkney for sandeels; Wyre and Rousay Sounds for kelp and seaweed communities on sublittoral sediment and maerl beds; and Papa Westray for black guillemots.

15 Outwith these designations, some 27 seabed habitats are considered to be Priority Marine Features ( PMF), including many that are considered to be characteristic of Scotland's marine environment ^[6] . These features, ranging from kelp beds and flame shell beds in coastal areas, to coldwater reefs and offshore deep sea muds in deeper seas, are considered to be of conservation importance.

Figure 1: Spatial diagram

16 The Pentland Firth and Orkney Waters are internationally renowned for their importance to many species ranging from seabirds and wintering waterfowl to a variety of marine mammals (e.g. cetaceans, seals) and other marine fauna. The Caithness and Orkney coastlines are recognised for their importance in supporting extensive colonies of migratory and breeding seabirds such as Atlantic puffins, black-legged kittiwakes, Arctic skuas, Arctic terns, razorbills, northern fulmars, common guillemots, storm petrels, northern divers, Slavonian grebes and greater black-backed gulls. The importance of the Plan area for many bird species and populations is further reflected by the designation of 12 Special Protection Areas ( SPAs) in coastal areas in Orkney and along the north Caithness and Sutherland coast.

17 In addition to birdlife, the waters of the Plan area supports a wide range of fish species and marine mammals. The River Borgie and River Thurso SACs have been identified in recognition of the Atlantic salmon populations they support. Additionally, the PFOW are internationally recognised for their importance for seal populations in particular, demonstrated by the designation of a harbour seal conservation area surrounding Orkney, the presence of two SACs within Orkney Waters for breeding seal colonies (i.e. Faray and Holm of Faray for grey seals, and Sanday for harbour seals). Additionally, 19 cetacean species have been recorded in the PFOW since 1980, and of these, six species occur regularly (i.e. harbour porpoise, minke whale, white-beaked dolphin, Risso's dolphin, killer whale and bottlenose dolphin) ^[7] . Several, such as bottlenose dolphins and harbour seals, are also listed under Annex II of the Habitats Directive.

18 Marine habitats and species depend on a clean and healthy water environment and, in turn, water quality plays a crucial role for many industries including aquaculture, fishing and water recreation. The primary mechanism for monitoring and managing the quality of Scotland's waters is the Water Framework Directive ^[8] ( WFD). The PFOW area is largely classified as 'good' status under the WFD, the eastern portion of the Pentland Firth from Duncansby head southwards are of 'high' status. Several transitional waters in the PFOW, such as the Loch of Stenness, Long Ayre and Loch of Ayre in Orkney, amongst others, are also classified as being of 'high' status. The Marine Strategy Framework Directive ^[9] ( MSFD) aims to ensure that priority is given to achieving or maintaining Good Environmental Status ( GES) in the marine environment through adherence to targets, for which 'descriptors' of GES have been established.

19 A review of the Environmental Baseline for the Pentland Firth Orkney Waters area has been prepared to inform the preparation of the Marine Spatial Plan, and this is presented as part of the Sustainability Appraisal ^[10] . The Sustainability Appraisal outlines the findings of a Strategic Environmental Assessment ( SEA) and Socio-Economic Assessment on the draft Marine Spatial Plan and its policies. The Appraisal also presents the findings of work undertaken to meet obligations under the European Commission ( EC) Habitats Regulations.

Social and economic activity

20 The Pentland Firth and Orkney Waters area supports a diverse marine economy including commercial fisheries, marine renewables, aquaculture, oil and gas, ferries, shipping, recreation, tourism and heritage. A Socio-Economic Baseline Review ^[11] of the Pentland Firth and Orkney Waters area has been prepared to inform the preparation of this Marine Spatial Plan and is presented as part of the Sustainability Appraisal.

Pressures and impacts

21 The use of coastal and marine resources within the Plan area has the potential to result in direct and cumulative effects on the environment and human activities. The Strategic Environmental Assessment ( SEA) carried out in parallel with this Plan identifies the key environmental pressures to be addressed. In terms of pressures on human activities, while many activities are likely to be compatible, there is potential for displacement of some marine users due to increased competition for space. The following pressures identified in the SEA highlight the key issues which the Plan policies aim to tackle:

Biodiversity

• Potential for adverse effects on marine and coastal habitats and species from increased development in marine and/or coastal areas (e.g. disturbance, barrier effects, damage to, or loss of, habitats, pollution)
• Potential for cumulative or in-combination effects on biodiversity interests from increased use of coastal and marine environments (e.g. disturbance, barrier effects, damage to, or loss of, habitats)

Climatic factors

• Climate change impacts on coastal areas are expected to include sea level change, exacerbating the effects of extreme waves and storm surges
• Climate change impacts on marine ecosystems can include changing ocean acidity, salinity, rising sea temperatures and rising sea levels
• Scotland has set targets and implemented actions for reducing greenhouse gas emissions across many sectors, including those for renewable energy generation, with the potential for increased spatial pressure on coastal and marine areas
• Climate change adaptation is likely to be required in response to the predicted effects on the coastal and marine environment, particularly in the minimisation of impacts and the potential loss of vulnerable species and habitats

Population and human health

• Potential loss of amenity value of settlements, key routes and landscapes. Disturbance during construction works (e.g. noise)
• Potential for increased accident risk associated with greater use of the marine environment and installation of infrastructure (e.g. collisions)
• Potential for secondary effects on human health through impacts on water quality

Landscape and seascape

• Sensitivity of coastal landscapes and communities to landscape and visual impacts from coastal and marine development as a result of their high landscape and seascape quality, natural character and wildness
• Potential for cumulative impacts from often incremental and increased onshore and offshore development on landscape/seascape character and scenic value
• Pressures on landscape/seascape in coastal areas from coastal erosion due to the expected effects of climate change and inappropriate development

Cultural heritage and historic environment

• Inappropriate development has the potential to affect the setting of historic assets located in both coastal and marine areas
• Construction or infrastructure installation works have the potential for both direct and indirect impacts to historic assets located in coastal areas or on the seabed, either as direct damage to historic features or through seabed disturbance, or secondary effects such as changes to coastal processes and sediment dynamics

Soil, marine geodiversity and coastal processes

• Pressures from coastal erosion due to both natural effects, offshore or coastal development, and the expected effects of climate change have been widely identified

Material assets

• Increased use of coastal and marine resources within the PFOW and the potential for cumulative effects from these activities
• While many activities are likely to be compatible, there may be the potential for displacement of some marine users from increased activity or the placement of infrastructure in marine or coastal areas

Water

• Potential for contamination of the water environment from marine or coastal activities such as the use of anti-fouling paint, pollution from oil spillage and sewage, construction activities
• Potential for pollution of coastal waters resulting from activities on land, particularly agricultural activities and storm water runoff
• Potential for secondary impacts to coastal and marine industries such as inshore fisheries, tourism and aquaculture, amongst others
• Potential for secondary impacts to coastal and marine biodiversity, including impacts of marine litter and other marine activities

Integration of marine and terrestrial planning

22 Marine plan boundaries extend up to mean high water springs and local development plan boundaries (i.e. terrestrial planning) extend to mean low water springs, with the exception of marine fish farming. There is therefore an overlap in the intertidal area. This overlap is intended to assist the integration of, and consistency between, both planning regimes.

23 It is essential that strategic planning for marine and terrestrial areas is carried out in a consistent and integrated way. Marine and land use policies and guidance need to be consistent and mutually supportive, particularly when making provision for resources, development and infrastructure that encompass the land sea divide, e.g. for ports and harbours, grid connections and natural heritage designations. To achieve integration at the national level, local development plans should be consistent with the UK Marine Policy Statement, the National Marine Plan and any subsequent statutory regional marine plans for that area. Equally, marine plans should be consistent with local development plans and with national objectives for land use planning set out in Scottish Planning Policy ^[12] and the National Planning Framework ^[13] , this pilot Marine Spatial Plan has taken account of these.

24 At the regional level, the role of the Highland and Orkney Islands planning authorities in the preparation of this Plan has facilitated integration and consistency with the respective local development plans, particularly addressing a joined-up approach to development in the coastal zone. Representation from the Orkney Harbour Authority and Scrabster Harbour Trust on the advisory group has sought to facilitate an integrated approach to policies for ports and harbours. For further information about the relationship of this Marine Spatial Plan to the relevant local development plans refer to Section 3 Legislative and Policy Context.

25 Further guidance is available in Planning Circular 1/2015 : The relationship between the statutory land use planning system and marine planning and licensing ^[14] . General Policy 7 (of this Plan): Integrating coastal and marine development sets out guidance relating to development with marine and land based components.

Governance arrangements for preparing the Plan

26 This pilot marine planning process has tested governance mechanisms to consider how Marine Planning Partnerships might operate in the future. The pilot Pentland Firth and Orkney Waters Marine Spatial Plan Governance Paper prepared in 2012 set out the governance arrangements for preparing the Plan which included the role of the working group, the advisory group and the linkages with decision making processes within the 'parent' organisations.

The working group

27 Between 2008 and May 2012 the Marine Spatial Plan process was managed by Marine Scotland. The preparation of the pilot Marine Spatial Plan has been led by Marine Scotland as part of a working group including Highland Council and Orkney Islands Council. The working group was created in May 2012, establishing a partnership approach to the delivery of the Plan between Marine Scotland and the local Councils. This approach enabled the pilot Marine Spatial Plan to be prepared in way that balances local and national issues, and has enabled more effective engagement with local stakeholders. This partnership arrangement between Marine Scotland and the local planning authorities has been a successful mechanism for developing marine planning policies that integrate with local land use planning policy.

The advisory group

28 To provide additional guidance, an advisory group was set up in January 2013. The advisory group has overseen the work of the working group and provided expertise and guidance on its outputs. The advisory group was established to ensure that the essential statutory requirements are addressed within the pilot Marine Spatial Plan and to provide high-level technical input across a broad range of expertise. The members of the advisory group were drawn from organisations with knowledge of the protection and enhancement of the Pentland Firth and Orkney Waters area and from those whose members use the area for commercial and recreational purposes.

29 The advisory group members were:

• Orkney Harbour Authority
• Scrabster Harbour Trust
• Scottish Natural Heritage
• Historic Environment Scotland
• Scottish Environment Protection Agency
• Highland and Islands Enterprise
• Royal Yachting Association Scotland

30 The advisory group was not intended to represent every single interest in the Pentland Firth and Orkney Waters area. Specific sectoral, recreational and community interests, for example, were addressed through engagement and consultation with those stakeholders, including on a one-to-one basis as required.

Stakeholder engagement and consultation

31 Input from a wide range of stakeholders is critical to the success of a Marine Spatial Plan. To this end, the Plan preparation process has been publicised at the various key development stages to seek engagement from a broad range of stakeholders.

32 The interests of local communities, the various commercial sectors, community and interest groups have been taken into account through focused discussions, stakeholder engagement events and consultation. The list of organisations and individuals that have been engaged in the making of this Plan are provided in Annex 1. The compilation of the stakeholder database commenced at the very beginning of the Plan-making process and was updated as new stakeholders came forward through each stage of the Plan's development.

The Plan preparation process

33 The preparation process has followed, as closely as possible, the key steps set out in the Marine (Scotland) Act 2010 Schedule 1 ^[15] for the preparation of a regional marine plan (see Figure 2 and Table 1). However, as this is not a statutory regional marine plan, the plan-making process could not follow all of these steps (e.g. undertaking an independent investigation) though many lessons have been learnt for the preparation of future regional marine plans by broadly adhering to the statutory plan-making process.

Figure 2: Illustration of the plan-making process. The table below provides an explanation of the key stages.

Table 1: Stages undertaken to develop this pilot Marine Spatial Plan.

Stage 1: The Pentland Firth and Orkney Waters Marine Spatial Plan Framework and Regional Locational Guidance (2011) This document set out a high-level framework for the preparation of the pilot Marine Spatial Plan. It established a three-stage process to develop the Plan. Stage 1 was the framework itself and included a baseline review of existing relevant information, identification of gaps in that information and recommendations on how those gaps should be addressed.

Stage 2: Research studies (ongoing) Various research studies to support the policies in the Plan were undertaken to fill data gaps and ran in parallel with Stage 3 (see Figure 2). These studies can be viewed at the Scottish Government Pentland Firth and Orkney Waters webpage [16] . Many of the Stage 2 studies commissioned were based on the original PFOW defined area that did not include the full north Sutherland coast. It is therefore recognised that subsequent regional marine plans may have to attempt to fill these data gaps.

Stage 3: Preparing the Marine Spatial Plan The following stages were undertaken and documents prepared and consulted on as appropriate: The Plan Scheme [17] 2012: this sets out the key stages for the preparation of this Plan, the schedule for stakeholder engagement, consultation and identified the key stakeholders. The document performed the function of a Statement of Public Participation as detailed in the Marine (Scotland) Act 2010. The Planning Issues and Options Consultation Paper [18] enabled early stakeholder engagement in the Plan preparation process. It performed a similar function to a 'Main Issues Report' used in the local development plan process. It set out the key issues and challenges facing the Pentland Firth and Orkney Waters area for consultation, based on an analysis of the characteristics of the area, the framework document and the available Stage 2 studies. It was considered important to undertake the Planning Issues and Options ( PIOP) stage for the following key reasons: to facilitate early engagement so that stakeholders could help define the scope, objectives and policies of the Plan before a draft was deposited for consultation to test whether the working group had identified all the matters that should be addressed to explain the broad options for developing the Plan policies and seek views as to which of those options should be reflected in the draft pilot Pentland Firth and Orkney Waters Marine Spatial Plan Stakeholder workshops, public drop-in sessions and individual meetings with stakeholders took place in July 2013 to discuss the document and the accompanying Draft Environmental Report [19] . The responses to this consultation are presented in the Consultation Analysis [20] and the Consultation Report [21] . An Interactions Matrix used in the PIOP process to highlight potential interactions between development, activities and the environment, was a useful tool in identifying various sectoral and cross-cutting themes. However, as many activities are likely to have both positive and negative effects, however minor, it was clear that repeating the matrix in the draft Plan would not add anything of significant value and has therefore been omitted from the Plan. Draft Pilot Pentland Firth and Orkney Waters Marine Spatial Plan The draft Plan was prepared from the information gathered at the previous stages, in consultation with a diverse range of stakeholders and taking the action points from the Consultation Report into account. Final Pilot Pentland Firth and Orkney Waters Marine Spatial Plan Following consultation on the draft Plan between June and September 2015, the final Plan and Consultation Analysis and Modifications Report [22] were prepared. It was presented to the Orkney Islands Council and Highland Council committees in early 2016, prior to approval by Scottish Ministers in March 2016. A Sustainability Appraisal [23] ( SA) was undertaken alongside the preparation of the draft Plan to consider the potential for social, economic and environmental effects of both the Plan and its reasonable alternatives. The SA included a Strategic Environmental Assessment ( SEA) required under Directive 2001/42/ EC and the Environmental Assessment (Scotland) Act 2005 (the 2005 Act), a Socio-economic Assessment and work undertaken to meet obligations under the EC Habitats Regulations. The Socio-economic Assessment component was informed by the Socio-economic Baseline [24] detailed in an accompanying report. The Sustainability Appraisal process was undertaken alongside the Plan's development from an early stage in the process, building upon the work undertaken for the development of the Draft SEA Environmental Report for the PIOP. Together, the Draft Environmental Report and the Sustainability Appraisal have enabled decision-making in this process to be informed by relevant environmental and socio-economic information, and assisted in the development and refinement of the policies contained within the draft Plan whilst also ensuring that the relevant information has been included in the accompanying Regional Locational Guidance [25] .