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

6 Strategic Environmental Assessment

6.1 This section of the report focuses on five questions (13 - 17) relating to the Environmental Report and to identification of additional relevant sources of information.

In summary:

• There was praise for the comprehensive nature of the Environmental Report and more respondents expressed broad agreement with the predicted environmental effects than disagreement.
• The main theme relating to the recommendations and proposals for mitigation of environmental effects was that more research and monitoring is required.
• Respondents suggested a number of additional information sources that they felt might be helpful.

Question 13: To what extent does the Environmental Report set out an accurate description of the current environmental baseline? Please also provide details of any additional relevant sources.

6.2 22 respondents, two individuals and 20 organisations, made comments at this question.

6.3 Several respondents, drawn from public sector and energy organisations, local authorities and individuals, referred to the largely comprehensive nature of the Environmental Report.

6.4 Another recurring theme related to the benefits of more signposting or obvious cross-referencing of environmental information between the SEA report and the sectoral marine plans.

6.5 Two environment / conservation respondents, Scottish Environment Link and RSPB Scotland, specifically suggested the inclusion of a map showing both the Draft Plan Options and possible MPAs and MPA search locations.

6.6 The following additional relevant sources were identified in responses at this question:

• Raw ESAS data;
• In the future, RSPB's work on FAME and modelling seabird distributions;
• Brooks et al. (2013) Characterising Scotland's marine environment to define search locations for new Marine Protected Areas;
• The identification of key geodiversity areas in Scottish waters (Scottish Natural Heritage Commissioned Report No. 432)

Question 14: Do you agree with the predicted environmental effects of the plans as set out in the Environmental Report?

6.7 25 respondents, five individuals and 20 organisations, made comments at this question.

6.8 Nine respondents indicated general overall agreement with the predicted environmental effects of the plans as set out in the Environmental Report. Some of these respondents noted their broad agreement, notwithstanding comments that they had made earlier in the consultation.

6.9 Some respondents reiterated concerns detailed at earlier questions whilst expressing no overall agreement or disagreement.

6.10 Two recreation/tourism organisations indicated disagreement and also identified areas of disagreement as follows: RYA Scotland referred to mitigation proposals relating to navigational safety that have been detailed earlier in the report, whilst Pentland Firth Yachting Club commented that there was there is insufficient data to predict reliably what the impact will be.

Question 15: Do you agree with the recommendations and proposals for mitigation of the environmental effects set out in the Environmental Report?

6.11 24 respondents, two individuals and 22 organisations, made comments at this question.

6.12 Five respondents answered 'yes' or 'generally yes' and two respondents answered 'no' without additional comment. A further six respondents asked that reference be made to the comments they had made at question 3 of the consultation.

6.13 The main theme that emerged from remaining responses related to the need for more comprehensive understanding and monitoring of impacts.

6.14 Scottish Fishermen's Federation commented that they perceived the required mitigation to be ambiguous. The respondent cited as an example 'effects on features of the historic environment can be avoided through appropriate siting of devices away from vulnerable coastlines and known historic marine features' and felt it was unclear how this would be possible.

6.15 A tourism/ recreation organisation, Pentland Firth Yachting Club also felt that mitigation statements were vague and many appeared to relate to additional monitoring rather than mitigation features per se.

6.16 JNCC identified the main mitigation proposals regarding biodiversity impacts as being the timing of construction to avoid sensitive life stages of the species and EIA/ HRA at project level and expressed agreement that the former has potential to mitigate impacts. The respondent identified other measures including changes in project design and modification of authorised areas.

6.17 The Highland Council commented that there might be too much reliance on individual project level mitigation, particularly in relation to cumulative effects.

6.18 SSE Renewables observed that some aspects were not mitigation but more design considerations and that the level of detail provided was variable.

Question 16: Are you aware of any additional on-going research or monitoring that may help to fill gaps in the evidence base, particularly relating to the marine environment and its interactions with renewable energy devices? Please give details of additional relevant sources

6.19 Nineteen respondents, one individual and 18 organisations, made comments at this question. Eight of the organisations and the individual respondent answered 'no' and ten other organisations gave more detailed responses

6.20 The sources that were identified as additional relevant sources were:

• Moray Firth research;
• Evidence from throughout Europe;
• A Crown Estate commissioned review of wave and tidal EIA/ HRA issues and research priorities ('A Consolidation of Wave and Tidal EIA/ HRA Issues and Research Priorities');
• PFOW Shipping and Navigation Study;
• Forthcoming tourism and recreation case study for PFOW;
• Pilot Pentland Firth & Orkney Waters marine spatial plan project and related Stage 2 studies;
• Shetland Islands' Marine Spatial Plan;
• The national strategy into strategic research for offshore marine renewables and anadromous fish;
• A conference paper prepared by researchers at the ICIT in Orkney: Bell, M., Side, J., Kerr, S., Johnson, K., Baston, S. & Collin, R. (2010) The emergence of a new marine renewable industry - what are the implications for fisheries? ( ICES Annual Science Conference 2010);
• West Islay Tidal Environmental Statement and associated technical appendices;
• Fair Head Tidal Baseline monitoring;
• Work of the International network for Social Studies of Marine Energy ( ISSMER) ( http://www.issmer-network.org/) and the NERC funded Marine Renewable Energy Knowledge Exchange Programme ( MREKEP) Fishery and Marine Renewable Energy Working Group;
• Research carried out in Strangford Lough where an extensive monitoring programme and an adaptive management approach was undertaken as part of the deployment of a free stream tidal energy device;
• The Comhairle bid, with local partners, for the Third Party Management Contract in respect of The Crown Estate leasing round for Wave Demonstration and Testing for which consideration of environmental interactions will be a key part of the management process;
• The Western Isles international Environmental Interaction of Marine Renewable Technologies conference in late April 2014;
• Lews Castle College monitoring of the marine resource around the Western Isles;
• Research in other UK and EU countries.

Question 17: Are you aware of any further environmental information that will help to inform the environmental assessment findings?

6.21 Sixteen respondents, one individual and 15 organisations, made comment at this question. The individual respondent and seven of the organisations simply answered 'no' and seven other organisations gave more detailed responses.

6.22 The environmental information sources suggested by respondents were as follows:

• Shetland Islands' Marine Spatial Plan (two mentions);
• Shetland Regional Locational Guidance;
• Findings from research carried out in Strangford Lough where an extensive monitoring programme and an adaptive management approach was undertaken as part of the deployment of a free stream tidal energy device;
• Brooks et al. (2013) Characterising Scotland's marine environment to define search locations for new Marine Protected Areas. Part 2: The identification of key geodiversity areas in Scottish waters. Scottish Natural Heritage Commissioned Report No. 432. ^[2] ;
• Pilot Pentland Firth & Orkney Waters marine spatial plan project and related Stage 2 studies;
• Areas of Search for possible future SPAs in the marine environment, currently being considered, as well as any proposed sites that come forward during Plan review;
• The Comhairle bid, with local partners, for the Third Party Management Contract in respect of The Crown Estate leasing round for Wave Demonstration and Testing for which consideration of environmental interactions will be a key part of the management process;
• The Western Isles international Environmental Interaction of Marine Renewable Technologies conference in late April 2014;
• Lews Castle College monitoring of the marine resource around the Western Isles;
• Location of spawning and nursery grounds for commercial fish and shellfish stocks;
• Amateur groups who may have data going back many years.