Planning Scotland's Seas: Sectoral Marine Plans for Offshore Wind, Wave and Tidal Energy in Scottish Waters. Consultation Analysis Report.

4 Draft Plan Options

4.1 This section of the report focuses on four questions regarding the Draft Plan Options. Questions 8, 9 and 10 asked about Offshore Wind, Wave and Tidal energy respectively and each asked respondent's views on the Draft Plan options, whether they are in the correct place and whether there are reasonable alternatives that should be considered. Question 11 asked whether respondents believed any draft plan options should be removed from the Draft Plans for Offshore Wind, Wave and Tidal Energy and, if so, invited them to explain their reasons.

4.2 This chapter reports the findings from responses to questions 8-10 by region, and by technology within region. Details of campaign responses are also included in reporting related to the South West. The chapter then reports on question 11.

In summary:

• Comments focussed specifically on individual Draft Plan options although a small number of relatively common themes emerged:
• There were concerns expressed relating to a number of Draft Plan options regarding potential overlap with existing or potential designated sites;
• There were concerns expressed relating to several Draft Plan options about potential impacts on navigational routes, commercial and recreational;
• There were also concerns relating to several Draft Plan options regarding potential impact on migration routes, most commonly for salmon.

• Only 19 standard responses specifically stated that any Draft Plan options should be removed from the Draft Plans although the volume of campaign texts in the South West should also be borne in mind.

• The main theme from those who commented was that caution should be taken, particularly pending further evaluations, research and monitoring.

Questions 8-10 asked: The Draft Plan for (Offshore Wind / Wave /Tidal Energy) proposes (number) Draft Plan options. What are your views on the (number) Draft Plan options? Are they in the correct place? Are there reasonable alternatives that should be considered?

Please indicate which proposed Draft Plan option(s) you are commenting on using the relevant indicator

South West

4.3 The Draft Plans contained two potential future options for Offshore Wind and one potential future option for Tidal Energy in the South West region:

• OWSW1
• OWSW2
• TSW1

Offshore Wind Options

4.4 Fifteen responses, six from individuals and nine from organisations, made specific reference to Draft Plan Options for Offshore Wind in the South West. In addition, campaign texts were submitted in relation to OWSW1 and OWSW2 and these are detailed under the relevant headings.

4.5 The main themes that emerged in relation to Offshore Wind options in the South West related to public acceptability, environmental and visual impact, a perception of limited or no potential for regional economic benefit and a possibility of adverse economic impacts. All of these themes were encapsulated in the response from Dumfries and Galloway Council.

4.6 Scottish Natural Heritage referred to potential concerns already highlighted to Marine Scotland relating to the cumulative impacts of offshore windfarm development, both visual and on birds and marine mammals. In relation to the South West specifically, they commented that the cumulative effects upon Seascape, Landscape and Visual Impact that may arise from further offshore windfarm development in the Solway Firth might limit any further such development, and that military interests in the seas offshore of Luce Bay could potentially impose additional constraint.

4.7 Community Energy Foundation commented that both OWSW1 and OWSW2 are too close to the Galloway Coastline and that standard industry guidelines are for offshore wind farms to be sited at least 12 miles from "sensitive" coastlines. The respondent added that they felt it undeniable that the coastline is sensitive in this area.

OWSW1

4.8 Dumfries and Galloway Council commented that they perceived OWSW1 to replace an earlier Wigtown Bay proposal and that the Council's opposition remained unaltered given the absence of any fundamental change. The Council added that OWSW1 would significantly impact on the views from the Fleet Valley National Scenic Areas.

4.9 Scottish Environment LINK and RSPB Scotland identified a number of key issues to be included for consideration in the assessment, some of which were also cited by Dumfries and Galloway Council, as follows:

• The presence of nationally important populations of gannets;
• Harbour and grey seals;
• Seabird foraging areas which may overlap with the proposed Plan Option;
• Mull of Galloway ( RSPB reserve) is the largest breeding seabird colony in the region, supporting guillemots, black guillemots, fulmars, kittiwakes, shags, cormorants and gull species and is close to the Plan Option;
• Manx shearwaters are found inshore in this region throughout the summer and other species, including wader species, make passage through the Mull in spring and autumn;
• Internationally important pink-footed and barnacle geese and whooper swans pass through Wigtown Bay Local Nature Reserve ( LNR) (Cree Estuary SSSI) and some whooper swans have been tracked by the Wildlife and Wetlands Trust ( WWT) offshore in the proposed Plan Option;
• Wigtown Bay is nationally important for pintail and curlew.

4.10 Northern Lighthouse Board noted in their response that they felt OWSW1 offered significantly more scope for shipping than the previous Area of Search.

4.11 The Crown Estate indicated that an Exclusivity Agreement had been put in place to undertake a feasibility study in an area of search that includes OWSW1. The respondent commented that if OWSW1 is included in the adopted Plan and that Dong does not seek to enter into an option agreement, The Crown Estate would only make the relevant area available as part of a wider commercial leasing round.

4.12 RYA Scotland commented that this area is crossed by routes of recreational vessels and is considered important to both the recreational and tourism markets. The respondent noted that this should be taken into account in planning for this area.

4.13 As noted in the introduction chapter, 46 campaign responses were received that related to OWSW1. In these instances, respondents submitted campaign text indicating they were not in favour of developing the Solway Firth at OWSW1/ TSW1. These respondents comprised 44 individuals and two tourism/ recreation organisations. Thirty-two of the individual respondents who included postcode information with these campaign texts were responding from or 'care of' an address in the Dumfries and Galloway postcode area (representing 89% of the 36 individuals who submitted the text and provided postcode information).

4.14 A further four standard responses included the campaign text alongside the respondent's own views.

4.15 The campaign text is appended to this report and it focused on:

• The volume of listed buildings in the area;
• Potential damage from turbines to blue carbon sinks;
• The fact that Luce Bay is an accredited SAC and related concerns about damage to natural habitats;
• Potential impact of underwater turbines on a gannetry at the Scare Rocks;
• Potential impacts on sea birds at the Mull of Galloway RSPB reserve;
• Potential adverse economic impacts.

OWSW2

4.16 Several respondents commented that they saw no real change in circumstance since an extension to Robin Rigg wind farm was dropped from the Offshore Plan for Wind Energy in March 2011 and that objections put forward by these respondents and others at that time remained.

4.17 Dumfries and Galloway Council commented that an extension to Robin Rigg would significantly impact on the views from the East Stewartry Coast National Scenic Areas and therefore affect qualities for which it has been designated.

4.18 Scottish Environment LINK and RSPB Scotland identified the following key issues for consideration, which they suggested should be addressed within the plan by stipulating the requirements of developers to address and assess these impacts at the project level:

• Monitoring of the original and operational offshore wind farm (Robin Rigg) has not fully established an empirical database of the movements of birds and porpoises through and around the area;
• No remote sensing surveys have been undertaken and therefore significant uncertainties remain over how birds and porpoises react to the wind farm and any subsequent collision risks or disturbance issues respectively;
• These issues remain outstanding in the face of additional potential development in this area/ extension to the Robin Rigg site;
• There are nationally important numbers of red-throated divers and common scoter within the general area of Robin Rigg and the inner Solway area is important as an overwintering and passage area for large numbers of migrant waterfowl;
• The proposed Plan Option is significantly larger than Robin Rigg and could bring the site closer to the coast, increasing the potential for interactions with the Upper Solway SPA/Ramsar site and other designations.

4.19 Northern Lighthouse Board noted in their response that Draft Plan Option OWSW2 is not restrictive to current shipping patterns (other than existing routes for offshore wind support vessels).

4.20 There were 443 campaign responses received that related to OWSW2. In these instances, respondents submitted campaign text indicating they were not in favour of developing the Solway Firth at OWSW2. These respondents comprised 434 individuals and nine organisations. Three hundred and fourteen of the individual respondents who included postcode information with these campaign texts were responding from or 'care of' an address in the Dumfries and Galloway postcode area (representing 73% of the 385 that submitted the text and included their postcode with their response).

4.21 The campaign text is appended to this report. It focused on:

• Adverse impacts on views from the East Stewartry Coast National Scenic Area;
• The cumulative effects of this Draft Plan Option and the existing turbine site at Robin Rigg;
• The proximity to Special areas of Conservation, a Site of Special Scientific Interest and several Important Bird Areas;
• Environmental concerns associated with Marine Geology and Coastal Processes;
• Broader issues of public acceptability, environmental and visual impact;
• Potential adverse economic impacts.

Tidal Option

4.22 Eight respondents, two individuals and six organisations, commented on the Tidal Draft Plan option in the South West. In addition, the campaign text that we have reported in relation to OWSW1 was titled OWSW1/ TSW1.

4.23 Dumfries and Galloway Council commented on the overlap between TSW1 and OWSW1 and felt that no discussion was made of the implications of this overlap, although the Council noted that since grid connections had been raised in relation to the former, they felt it likely to be an issue for the latter. The Council also referred to TSW1 having been highlighted as the main navigational concern by the Kirkcudbright Harbourmaster, stressing that any apparatus on or near the surface of TSW1 would be very hazardous to vessels.

4.24 In addition to navigational issues, the Council's response referred to the impact on fishing at TSW1, commenting that the Socio-Economic Evidence Base recognised the financial loss in value of potentially lost landings as between £10,000 and £60,000 depending on scenario. They also commented that TSW1 has a similar potential to OWSW1 for impact on seabirds as well as the potential for collision and noise impacts on whales and dolphins, seals, basking sharks and other fish species known to be present in this area.

4.25 Similarly, Scottish Environment Link reiterated some of the concerns they had expressed in relation to OWSW1 and added that RSPB Scotland has brought forward two sites to the MPA consultation as third party proposals, including Scare Rocks MPA and Mull of Galloway MPA, both of which would be marine extensions to existing SSSI designations. The respondent requested that the Plan fully considers the potential direct and indirect impacts on features for which the proposed extensions were put forward for designation and for the MPA search features which are known to exist in these areas.

4.26 Scottish Natural Heritage noted that no mention was made in the Plans of the military interests in the seas offshore of Luce Bay, coincident with TSW1, which might limit such development.

4.27 The Association of Salmon Fishery Boards commented that TSW1 is very likely to represent a key migration route for Atlantic salmon, and possibly sea trout, arising from the rivers in the Solway Firth, including the River Bladnoch SAC.

4.28 Galloway Fisheries Trust also commented that the TSW1 option appeared close to Luce Bay and to the River Luce and other important rivers in terms of fish species (salmon, sea trout, shad species and lamprey species). The respondent added that TSW1 may be located within a prime feeding area or in the middle of a migration route for many of south west Scotland's rivers, as well as those of the English west coast and the northern Irish/east Ireland coasts.

4.29 Drummore Harbour Trust commented in relation to TSW1 that Tidal Energy was their preferred method and had a proven track record.

4.30 Individual respondents commented on potential impacts on the breeding colony of seabirds at Scare Rocks and disturbance to the seabed with displaced sediment having a detrimental effect on feeding areas for birds on the shores of Luce Bay and on reiterations of concerns related to OWSW1.

West

4.31 The Draft Plans contained nine potential future options for Offshore Wind, Wave and Tidal Energy in the West region:

• OWW1;
• OWW2;
• OWW3;
• WW1;
• WW2;
• WW3;
• WW4;
• TW1;
• TW2.

Offshore Wind Options

4.32 Five organisations and no individuals commented on Draft Plan Offshore Wind Options in the West.

4.33 Whale and Dolphin Conservation commented on the proximity of OWW1 and OWW2 to the Skye to Mull MPA search location, which has been recognised for minke whales and basking sharks. The respondent stressed that full consideration should be given to the potential environmental impacts of offshore wind in this location on the mobile species represented. Scottish Environment LINK also commented on OWW2 as a search location for basking shark.

4.34 National Trust for Scotland commented that OWW3 appears to overlap the Barra Fan and Hebrides Terrace Seamount pMPA and OWW2 appears to overlap with the Staton Banks SAC and Skye to Mull MPA search location. The respondent suggested that these options be modified so there is no overlap until there is greater certainty about the effects of these developments on the aspects that have been designated.

4.35 Northern Lighthouse Board noted that Draft Plan Options OWW1 and OWW2 straddle the southern approaches to the Minches and suggested that there may be scope for further development in the eastern parts of these areas.

4.36 No Tiree Array commented that all options off Tiree should be dropped as the respondent felt they had no relation to current technological development. Specifically in relation to OWW2, they commented that with the Tiree Array on hold as there is no solution to its design that is fit for purpose this rendered OWW2 unfeasible.

Wave Options

4.37 Five organisations commented on Draft Plan Options for Wave in the West region.

4.38 National Trust for Scotland commented again that they would like the Draft Plan Options modified to remove any overlap with designated sites. They cited specific overlaps as:

• WW4 with The Barra Fan and Hebrides Terrace Seamount pMPA;
• WW3 within the Skye to Mull MPA search location;
• WW2 within the same Skye to Mull MPA search location.

4.39 They also felt that until research into Skye to Mull MPA search area is completed and a decision taken with regard to an MPA proposal there should be no wave energy devices deployed.

4.40 Scottish Environment LINK also cited WW3 as overlapping with the Skye to Mull MPA search location, an area that the respondent described as a basking shark hotspot.

4.41 RYA Scotland commented that in their view WW1, WW2, WW3, WW4 might be possible sites but discussions would be needed at project level to minimise risk.

4.42 Sportscotland also expressed concerns that WW3 could have a significant impact on surf/windsurf sports and suggested a full assessment be made of the importance of this option (as well as options in two other regions) for surf sports and of the potential impact of wave devices on these sports.

4.43 No Tiree Array also commented that no explanation is offered as to how WW3 can co-exist within the proposed Tiree (Argyll) Array.

Tidal Options

4.44 Three organisations and no individuals commented specifically on the Tidal Draft Plan options in the West.

4.45 The Crown Estate commented that their analysis had indicated an average depth greater than 100m in TW1 and felt this may be challenging for development. The respondent suggested a review of the Option area to reflect a more feasible development area.

4.46 The Association of Salmon Fishery Boards commented that TW2 may sit on the key migration route for all Atlantic salmon arising from the Solway and the Clyde (including the River Bladnoch and River Endrick SACs) and that TW1 may also represent the key migration route for all fish in the South West of Scotland. The respondent identified a need for greater understanding of migration routes before any significant developments.

4.47 Galloway Fisheries Trust also commented that TW2 and TW1 could also potentially impact on the migration routes of salmon from the Solway, the west coast of England and the east coast of Ireland/ Northern Ireland.

North West

4.48 The Draft Plans contained one potential future option for Offshore Wind and one for Wave Energy in the North West region:

• OWNW1;
• WNW1.

Offshore Wind Option

4.49 Six organisations and no individuals commented on Offshore Wind Draft Plan Options in the North West.

4.50 Comhairle nan Eilean Siar commented that OWNW1 is a critical area for the Western Isles and that significant commercial interest has already been shown in this area for innovative Offshore Wind. The respondent described it as vitally important that OWNW1 is retained, serviced and marketed to industry.

4.51 The Highland Council noted that some mitigation had been proposed to avoid busy shipping channels in areas such as OWNW1, whilst commenting that it would have been helpful if more detail had been provided for the rationale of site choice within the Draft Plans, eliminating a need for reference to supplementary documents.

4.52 The Crown Estate commented that OWNW1 would be most suitable for turbines deployed using floating foundations.

4.53 Sportscotland expressed concerns that OWNW1 has potential to impact on an area particularly valued for its wild land qualities, whilst adding that if visibility of turbines from the mainland is negligible they have no objection. The respondent also noted this is a popular area for sailing and a wind farm is likely to have a significant impact on the landscape/seascape qualities of the area.

4.54 RYA Scotland commented on concerns relating to potential impacts on recreational sailors and suggested that if the Draft Plan Option is taken forward then the southern edge should be moved north.

4.55 Whale and Dolphin Conservation noted that OWNW1 plan option lies adjacent to the Eye Peninsula to the Butt of Lewis MPA search location, which has been recognised for Risso's dolphins and sandeels. The respondent suggested that if OWNW1 site remains as a Plan Option then the plan must stipulate the requirement for any future development in this area to adequately assess the potential direct impacts to these species.

Wave Option

4.56 Six organisations and no individuals commented on Wave Draft Plan Option in the North West.

4.57 National Trust for Scotland commented that elements of WNW1 appeared to be adjacent to NSAs and stressed a need for caution to ensure that impacts on any of the designated features are assessed and mitigated at the project design stage.

4.58 RYA Scotland commented that WNW1 includes important recreational sailing routes such as to the St Kilda archipelago and suggested discussion would be needed with navigational stakeholders to reduce the size of this area and reduce impacts.

4.59 Sportscotland also expressed concerns again here that WNW1 could have a significant impact on surf/windsurf sports and suggested a full assessment be made of the importance of these areas for surf sports and of the potential impact of wave devices on these sports.

4.60 Comhairle nan Eilean Siar noted concern at the deletion of the scoping area of search west of the Uists (from Harris to Barra). They recommended that this area be re-opened and noted they had aspirations for localised district heat and power schemes in the Uists, powered by wave energy in the area.

4.61 Scottish Natural Heritage noted concern relating to WNW1 that possible visual impacts of such development off the west coast of Lewis appear to have been under-estimated.

4.62 The Association of Salmon Fishery Boards noted the close proximity of WNW1 to Atlantic salmon SACs.

North

4.63 The Draft Plans contained twelve potential future option for Offshore Wind, Wave and Tidal Energy in the North region:

• OWN1;
• OWN2 ;
• WN1;
• WN2;
• WN3;
• TN1;
• TN2;
• TN3;
• TN4;
• TN5;
• TN6;
• TN7.

Offshore Wind Options

4.64 Seven organisations and no individuals commented on Draft Plan Options for Offshore Wind in the North.

OWN1

4.65 Orkney Islands Council expressed support for the fact that OWN1 would not be directly adjacent to the Hoy and West Mainland NSA and within the direct line of visibility from monuments within the World Heritage Site ( WHS). They questioned whether consideration had been given to locating the site further offshore in order to reduce the potential magnitude of impacts on shipping and navigation, inshore fisheries, cultural heritage, recreation, landscape and seascape.

4.66 Orkney Fishermen's Association commented that much of OWN1 is currently fished and much of it represents a particularly productive area for brown crab. The respondent added that consultation with their members operating in the area suggested that the fishing effort heat maps released along with the RLG for offshore wind were an under-representation of fishing activity and contained some noticeable gaps. They suggested that consultation with fishermen will be needed to determine the locations where the erection of turbines might interfere with fishing and to discuss appropriate options for mitigation.

4.67 National Trust for Scotland noted that OWN1 is close to the Hoy & West Mainland NSA and also Neolithic Orkney WHS and commented on the importance of ensuring that any developments in the areas does not impact unduly on the qualities for which these areas have been designated.

4.68 Three environment/ conservation organisations noted that the plan option lies adjacent to and overlaps the proposed North West Orkney Marine Protected Area, for the conservation of sandeel. The respondents stressed that the Plan must fully consider the potential environmental impacts of offshore wind in this location on this species and the potential indirect impacts on seabirds, marine mammals and other sandeel predators. They also added that should the OWN1 site remain as a Plan Option the plan should stipulate the requirement for any future development in this area to adequately assess the potential direct impacts to sandeel and the indirect impacts to other species.

4.69 RYA Scotland noted that this area is crossed by sailing routes from Stromness to Shetland and Fair Isle and commented on the importance of any development leaving adequate room for safe navigation.

4.70 The Northern Lighthouse Board also noted that Option OWN1 includes the Fair Isle Channel route used by trans-Atlantic traffic and suggested there may be scope for further development in the South-western part of this area and the Fair Isle Channel route should be maintained for shipping.

4.71 Orkney Islands Council observed that the identified overlap between OWN1 and WN2 may result in competition for space, and that there may be competition for grid connection between developments around Orkney and Shetland.

OWN2

4.72 National Trust for Scotland noted that OWN2 appears to overlap with two historic MPAs and suggested that at the project design stage checks should be made to ensure that these MPAs are in no way impacted by the development.

4.73 The Northern Lighthouse Board noted that Option OWN2 includes the approaches to the port at Lerwick, and also impinges into the Northern Fair Isle Channel and suggested there may be scope for further development, particularly in the northern part.

Wave Options

4.74 Six organisations and no individuals commented on Wave Draft Plan Options in the North.

4.75 National Trust for Scotland commented that elements of WN3 and WN2 appeared to be adjacent to NSAs and stressed a need for caution to ensure that impacts on any of the designated features are assessed and mitigated at the project design stage.

4.76 The Scottish Salmon Producers' Organisation commented that WN2 Orkney and WN3 Shetland showed potential for developments to impact on existing and proposed salmon farms and suggested these potential impacts should be considered in any Sustainability Appraisal and Licensing process for development proposals.

4.77 RYA Scotland also commented that whilst there are locations within WN2 which might be suitable for wave energy generation, there should be coordination between the present sectoral plan, the pilot Pentland Firth and Orkney Waters Marine Spatial Plan currently being developed and the Crown Estate Pentland Firth and Orkney Waters Strategic Area Navigation Appraisal.

4.78 RSPB Scotland and Scottish Environment Link commented that WN2 overlaps the proposed North West Orkney Marine Protected Area, which is proposed for the conservation of sandeel.

4.79 With regard to WN3, RYA Scotland commented that whilst there are likely to be locations within WN3 where a wave farm may be suitable, they felt the routes from Orkney and those into Scalloway need to be protected.

4.80 RYA Scotland commented that WN1 includes the existing Farr Point proposal and that a recreational cruising route passes through this area with a possibility that a vessel under sail would have to change course a considerable distance away to avoid it. The respondent suggested a 'deploy and monitor policy' for the first phase of Farr Point if it is consented so that risks can be properly assessed before any further proposals are considered.

4.81 Sportscotland also expressed concerns here that WN1 could have a significant impact on surf/ windsurf sports and suggested a full assessment be made of the importance of these areas for surf sports and of the potential impact of wave devices on these sports.

Tidal Options

4.82 Nine organisations and no individuals commented specifically on Tidal Energy Draft Plan Options in the North.

4.83 Four environment / conservation organisations commented on these Draft Plan Options. Whale and Dolphin Conservation as well as Scottish Environment LINK expressed concern that TN1-4 would potentially impact on declining harbour seal populations around Orkney. Scottish Natural Heritage noted an apparent inconsistency between TN6 and TN7 and the constraints map produced for the Shetland Marine Spatial Plan. National Trust for Scotland commented also on a need to remove overlap with designated sites and referenced, as examples TN6 and aspects of the Yell Sound Coast SAC, TN7 and parts of TN5 and TN1 adjacent to NSAs. Scottish Environment LINK also noted that TN4 is very close to the Wyre and Rousay Sound pMPA.

4.84 The Crown Estate commented that they understood tidal areas TN5, TN6 and TN7 to have a low mean resource, which suggested that the area might struggle to support development. The respondent indicated that they would like to see some policy support for test and demonstration projects.

4.85 The Association of Salmon Fishery Boards commented that TN1 is a key area of importance for migratory fish and that devices deployed in this area would have the potential to impact on any river in Scotland.

4.86 Orkney Fisheries Association indicated concern relating to TN1, TN2, TN3 and TN4 regarding the possibility of potential exclusion zones obstructing safe navigational channels for local fishing vessels and increasing travel time to fishing grounds.

4.87 Scottish Salmon Producers' Organisation commented that TN1- TN7 have potential to impact on existing and proposed salmon farms.

4.88 Marine Spatial Planning Section, NAFC Marine Centre commented that TN5-7 are areas of significant constraint, with navigation, biodiversity and commercial interests in these areas.

North East

4.89 The Draft Plans contained two potential future options for Offshore Wind Energy in the North East region:

• OWNE1;
• OWNE2.

Offshore Wind Options

4.90 Six organisations and no individuals commented on the Draft Plan Options in the North East.

4.91 Aberdeenshire Council commented that no reference had been made to a proposed floating turbine demonstration off Aberdeenshire between the two site options, and noted that impacts of offshore renewable developments on existing users of the sea should be kept to a minimum.

4.92 The Crown Estate commented that both wind option areas in the North East have a minimum depth of greater than 40m and this meant the respondent expected that these option areas would be most suitable for turbines deployed using floating foundations. The respondent noted that this technology is expected to have a greater footprint than some foundation types, that noise impacts during construction are likely to be much reduced and there is the potential for some restrictions on fishing activities in wind farms using floating foundations because of the presence of anchor lines, As such, the respondent indicated that the plans should indicate that floating foundations are the most likely type of foundation to be deployed in these areas and the assessment amended accordingly.

4.93 The National Grid commented that both Draft Plan Options in the North East might be affected by an offshore interconnection project between East Scotland and North East England, although final options had not been determined. The respondent added that all proposed infrastructure could probably be accommodated through appropriate consultation.

4.94 Scottish Natural Heritage commented on possible deferral of further offshore wind farm development on the North East coast until the results are known of any impact monitoring conducted around the currently proposed developments on the east coast and the cumulative effects of such additional development. This respondent also noted that the North East Region is the focus of interest for possible leases linked to test and demonstration projects for floating offshore wind technologies.

OWNE1

4.95 Aberdeen City Council expressed support for OWNE1, being its nearest and most relevant development zone.

4.96 Northern Lighthouse Board noted that OWNE1 includes most of the approaches to Aberdeen harbour, and also potentially impedes vessels transiting the East coast. This respondent commented that there may be scope for further development, particularly in the southern part of this area.

4.97 RYA Scotland commented in relation to OWNE1 that the seas off Aberdeen are very crowded with commercial vessels and recreational craft and that the proposed wind farm would be a further complication. This respondent suggested that moving the western boundary to the 12 mile limit would reduce the impact.

OWNE2

4.98 Northern Lighthouse Board noted that OWNE2 includes a much used turning point off Kinnaird Head for vessels transiting the East coast. This respondent added that there may be scope for further development in the Western part of this area.

4.99 RYA Scotland commented in relation to OWNE2 that this location is frequented by few recreational craft except those on passage between Stavanger and Banff or between Peterhead and Fair Isle or Lerwick. The respondent suggested that moving the western corner further east would reduce the impact on the latter and noted that there is already a proposal for a floating wind farm in this area (Hywind Scotland Pilot Park Project).

East

4.100 The East contained no potential future option for Offshore Wind, Wave or Tidal Energy.

Other Comments on Offshore Wind Draft Plan Options

4.101 Galloway Fisheries Trust commented that the ten options have been selected through a comprehensive process of selection specifically looking at constraints. However, the respondent expressed a concern if, for example, every offshore wind option were to be consented in one region, or group of adjoining regions, this would create an array of wind farms in one sector of Scotland's seas.

Question 11: Do you believe any draft plan options be removed from the Draft Plans for Wind, Wave and Tidal Energy?

If Yes, please indicate which proposed Draft Plan options you believe should be removed (using the relevant indicator), and explain why

4.102 As the following table shows, there were mixed opinions amongst those who answered this question directly as to whether any Draft Plan Options should be removed. Public sector organisations and most local authorities giving a direct answer did not believe any Draft Plan Options should be removed. Other respondent groupings were more mixed in their opinions.

Table 4.1 Proportion of respondents who answered this question and believed any draft plan options should be removed from the Draft Plans for Wind, Wave and Tidal Energy

Respondent group	Yes	Yes Qualified	No Qualified	No	Other
Individuals (7)	6 (86%)	-	-	1 (14%)	-
Local Authorities (8)	1 (13%)	-	1 (13%)	6 (75%)	-
Fisheries (4)	2 (50%)	-	-	2 (50%)	-
Energy (4)	1 (25%)	-	-	2 (50%)	1 (25%)
Local Groups (1)	1 (100%)	-	-	-	-
Public Sector (4)	-	-	2 (50%)	1 (25%)	1 (25%)
Recreation/Tourism (4)	3 (75%)	-	-	1 (25%)	-
Environment/Conservation (4)	3 (75%)	1 (25%)	-	-	-
Academic/Scientific (1)	1 (100%)	-	-	-	-
Other (1)	1 (100%)	-	-	-	-
Total (38)	19 (50%)	1 (3%)	3 (8%)	13 (34%)	2 (5%)

4.103 Twelve of the thirteen respondents who had indicated that none of the options should be removed provided no further comment. The remaining respondent who answered 'no', together with those who gave a qualified 'no', reiterated points discussed in earlier chapters regarding the need for caution going forward and for more research, monitoring and evaluation.

4.104 Five of the six individual respondents who had answered 'yes' cited OWSW1, three also cited OWSW2 and one cited TSW1 as options that should be removed and referred to their answers at questions eight and ten respectively for explanation. The remaining individual respondent who answered 'yes' felt all the options should be removed.

4.105 The organisations who had answered 'yes' each cited a different combination of specified options, or commented more generally, and the main theme in their comments was that caution should be taken and that they perceived a need for more evaluations, research, data and monitoring ie. that removal of options at this time represented a safer course. The gaps in information that they identified, or additional assessments that they felt were required, have been discussed at earlier questions.

4.106 Two respondents who had not answered either 'yes' or 'no' added comments, similar in theme to those above from those who had answered 'yes'. The Crown Estate noted the need for additional appraisal of tidal resource in Shetland to ensure there is sufficient resource to support commercial development relating to these plan options. EDPR UK commented that it may be necessary to avoid overlap of different sectoral plans, unless there is evidence that proves coexistence to be possible.