Sectoral marine plan: islands communities impact assessment

Summary of information gathered and consultation feedback to date:

The sectoral marine planning process

The sectoral marine planning process (as shown in Figure 2) is an iterative process, which has involved intensive technical planning work and extensive stakeholder engagement.

The key stages of the planning process in relation to the identification of the Draft Plan Options are:

1. Opportunity and Constraint (O&C) Analysis – Iteration 1
2. Opportunity and Constraint (O&C) Analysis – Iteration 2 - Single Issue Constraint Analysis
3. Scoping Consultation
4. Opportunity and Constraint (O&C) Analysis – Iteration 3
5. Identification of Draft Plan Options
6. Next Steps

Two cross-sectoral Steering Groups have been formed to support the planning process and provide expert guidance, including representation from the fisheries, renewables and natural heritage sectors and Highlands and Islands Enterprise.

1. Opportunity and Constraint (O&C) Analysis – Iteration 1

The identification of initial Areas of Search (AoS) was carried out through the use of an O&C analysis.^[5] It built upon previous work carried out by Marine Scotland Science in 2011^[6] and the production of draft regional locational guidance for potential deep water floating offshore wind test sites in 2014.^[7] The analysis was iterative, so updates could be incorporated as required in order to reflect stakeholder feedback.

Full details of the O&C analysis can be found in the AoS scoping report published for consultation in 2018.^[8] The O&C analysis sought to identify areas of opportunity for the future development of offshore wind, whilst also identifying areas that minimised potential negative impacts to the environment, other sectors and users of the sea. This analysis was completed through the use of GIS and numerous spatial data resources.

2. Opportunity and Constraint (O&C) Analysis – Iteration 2

Sectoral engagement workshops were held in spring 2018. The AoS were then refined with consideration to specific spatial issues and feedback from the workshops.

This refinement process identified a range of distinct AoS. As the draft Plan is technology neutral, no commercial or technology specific information was used in this refinement process.

3. Scoping Consultation – Screening and Scoping Reports

Scottish Ministers then consulted on the screening and scoping stages of the Plan process during June and July 2018. Screening and scoping reports were prepared and published online for the SEA, HRA and SEIA alongside the AoS scoping study.

Comhairle nan Eilean Siar provided detailed comments on the implications of further offshore wind development, advising that the Plan would need to take into account the implications of Part 6 of the 2018 Act coming into force and the enactment of the Scottish Crown Estate Bill (as was, now the Scottish Crown Estate Act 2019), advising that the SEIA will provide a useful baseline for this process. Opportunities for the deployment of floating offshore wind technology off the Outer Hebrides were welcomed.

Comhairle nan Eilean Siar stated that "there is strong community support for marine energy development around the islands" and that it should not be automatically assumed that development in the area landward of the IMO Shipping Route would be deemed unacceptable on visual impact grounds without further consultation with the potentially impacted communities. This feedback has been considered and this assumption was discussed and tested via consultation in late 2019/early 2020. Feedback during consultation did not indicate any substantial difference of opinion and was in fact confirmed by several parties.. Opportunities for community ownership of renewable energy developments were also highlighted by Comhairle nan Eilean Siar.

Other respondents highlighted potential negative impacts on recreational boating as a result of development. Higher costs associated with grid connections for islands were highlighted as a potential barrier to deployment and development. The importance of communication with the island Local Authorities was highlighted by respondents, to ensure that the right framework is in place to enable the successful delivery of the Plan.

Respondents also highlighted that Community Benefit, by way of transfer of a portion of energy generation to island communities, may be possible where offshore export cables make landfall on an island. There is a high level of uncertainty, however, regarding the possible number or location of export cables. All areas inshore of DPOs have been considered as potential export cable corridors, unless there is a clear cable landfall point indicated by current/planned grid connection points. The potential impacts of offshore export cable corridors and landfall points will be required to be assessed fully at a project-level, once further detail(s) are available.

4. Opportunity and Constraint (O&C) Analysis – Iteration 3

Iteration 3 of the O&C analysis was undertaken, which considered the responses received during the Scoping Consultation. For more details see the Consultation Analysis.^[9]

The AoS were refined with consideration to the outputs of the Iteration 3 O&C Analysis. As a result, certain AoS were either removed or refined to avoid/incorporate certain areas of Scottish Waters.

This stage also considered the areas of seabed proposed by stakeholders via the scoping consultation. A number of the areas proposed overlapped with existing AoS, while others overlapped with areas with higher levels of constraint or entirely new areas.

Upon review of the above information, a number of areas were identified to move forward in the plan process. Additionally, some additional areas were included at this stage, where there was significant stakeholder interest, but also increased constraint. The Sustainability Appraisal stage will assess these areas in greater detail.

5. Identification of Draft Plan Options

The 22 revised Areas of Search, with a potential capacity for around 90 GW (calculated at 5 MW/KM²), were made available to the Sectoral Marine Plan Project Board and the two Project Steering Groups for consideration and comment.^[10]

Responses from both the Board and Steering Groups, together with the outputs of the initial assessments, was presented to Scottish Ministers to inform their decision on which AoS should progress to the Sustainability Appraisal for more detailed assessment.

17 revised AoS were selected as DPOs.

6. Public consultation – draft Plan and Sustainability Appraisal (including partial ICIA)

Public consultation was undertaken on the 17 DPOs and the Sustainability Appraisal (comprising of the Strategic Environmental Assessment, Habitats Regulations Appraisal and Social and Economic Impact Assessment), draft Regional Locational Guidance and the partial ICIA and Equalities Impact Assessments between 18 December 2019 and 25 March 2020. A total of 443 responses were received during this time period and the findings are summarised in the published Consultation Analysis Report.

In addition to online publication of the documents, a series of 17 consultation events were held across Scotland during February and March 2020, including events in Stornoway, Lerwick, Stromness and Bowmore, to facilitate engagement and stakeholder feedback. Further details are provided in the Consultation Analysis Report.

Views were sought on a range of topics, including the DPOs selected, the policies contained in the draft Plan and the findings of the Sustainability Appraisal. Responses were received from across a range of sectors relating to the DPOs included within the ICIA – including the commercial shipping, commercial fishing and natural heritage sectors.

Individual Draft Plan Options

Question 1 asked respondents whether they supported the selection of the following DPOs, responses were received for the DPOs included in this ICIA as follows:

Table 1 Draft SMP Consultation Question 1 - "Do you support the selection of the following DPOs?" - Responses

DPO	Strongly support	Somewhat support	Neither support nor oppose	Somewhat oppose	Strongly oppose
N1	28	8	37	4	23
N3	28	9	39	4	17
N4	23	10	44	5	15
NE1	26	13	38	1	21
NE2	28	11	32	2	30
W1	28	8	43	4	19

Commercial fisheries

The majority of feedback in relation to the DPOs related to commercial fisheries. A summary of the suggested amendments to the DPOs made by the membership of the Scottish Fishermen's Federation ("SFF") and Scottish White Fish Producers Association ("SWFPA") is provided at Figure 3 for context. The recommendations equated to substantial reductions for DPO N1 (up to 40% of the seabed area) and NE1 (up to 50% of the area).

NatureScot (formerly Scottish Natural Heritage)

In its response, NatureScot advised that it considered that the significance of potential visual and landscape impacts had been underestimated in some instances (in relation to DPOs N1, NE1 and NE2) and referred to the detailed guidance it has produced on seascape, landscape and visual impacts.^[11] In addition, NatureScot expressed concerns regarding the proximity of DPOs W1 and N4 to shore. NatureScot stated it considered that the potential ornithological impacts (in relation to collision risk) had been underestimated for DPOs N1 and N4.

Shetland Islands Council ("SIC")

SIC provided a response to the consultation stating that it 'somewhat supports' offshore wind development in NE1, "The development of up to 2 GW of offshore wind generating capacity in NE1 would have a significant impact on the Shetland economy during all development and operational phases. Our support is based on the Economic and Social Impact findings of annual employment associated with the development being between 150 jobs (low scenario estimates) and 600 jobs (high scenario estimates)… Our support is caveated on the Scottish Government and CES making sure that all licensed activity on DPO NE1 is planned in a manner that complements important economic and environmental factors, which must be addressed. From an economic and social perspective, fishing and all its ancillary activities are an essential part of the Shetland economy so every effort must be made to minimise the impact on fishing in DPO NE1. Similarly, the impact on navigation in the commercial marine transport and leisure tourism sectors needs to be investigated fully".

SIC made further comments in relation to the works licensing requirements for the portion of NE1 which lies within 12 nm of Shetland and the relationship with the emerging Shetland Islands Regional Marine Plan.

Argyll and Bute Council ("ABC")

ABC provided a response stating that it agreed with the findings of the SEIA, that W1 would have "minor impacts to wildlife and socio-economics for the West Coast and Argyll in particular". ABC further recognised that development within W1 could "have a significant environmental benefit in supporting the decarbonisation of the energy sector and aid the establishment of a secure energy supply in Argyll." ABC stated that it considers it important that servicing, operation and maintenance bases are located in Argyll to secure economic benefits for the region.

Orkney Islands Council ("OIC")

OIC's response highlighted that the DPOs to the North of Scotland have potential to contribute significant social and economic benefits for Orkney communities and that Orkney harbour infrastructure could provide locational and operational benefits for offshore wind developers. OIC highlighted that "it is essential that offshore wind development in these areas accrue significant benefits to Orkney communities to offset any significant adverse impacts on existing sectors and to benefit our island economy". OIC further highlighted the importance of detailed engagement with local stakeholders, including the fishing sector to minimise adverse effects and maximise potential benefits. OIC highlighted the issues surrounding grid constraint and transmission charging faced by development in these DPOs.

OIC further submitted comments as the Statutory Harbour Authority regarding potential impacts on navigational safety. In particular, this response queried why Ports and Harbours were scoped out of the SEIA. The Statutory Harbour Authority consider that these impacts have been incorrectly scoped out (i.e. wider benefits to wider port authority, employment, local community and reducing carbon footprint by having a port and harbour near a DPO). The response suggested that a full Ports and Harbours study should be completed to inform the planning process. Our position on this point is that the scope of the assessment was agreed with the Steering Groups at the start of the process and further project-level assessment will be completed with regard to impacts on ports and harbours (as required).

Comhairle nan Eilean Siar (Western Isles Council) ("CNE-Siar")

CNE-Siar provided a response outlining strong support for DPOs NE2-NE4 and that it "somewhat supported" all other DPOs. CNE-Siar noted the close proximity of DPO N4 to shore and the potential for higher visual impact associated with this, however, "Notwithstanding, the Comhairle urges Marine Scotland to retain and promote DPO N4 because of its accessibility and wind resource and the requirement for developers in DPO N4 to connect to Grid infrastructure on Lewis. The Isle of Lewis is currently host to circa 450MW of consented and contracted Onshore Wind generation, awaiting connection to the National Grid by a £700m HVDC Radial Connector. The local population has accepted the considerable visual impact of these Onshore deployment on the tacit understanding that the next generation of energy production will be in the marine environment. The local population is therefore prepared for, and supportive of, large scale deployment of Offshore Wind off Lewis and has not reacted negatively to the potential visual impact in the way other coastal regions in Scotland have… The Comhairle therefore strongly supports DPO N4 because it will kick start the island supply chain and provide much needed jobs and benefits to the local population." Further, CNE-Siar stated that it considers development in N4 will not have a detrimental impact on the tourism sector.

Highlands and Islands Enterprise ("HIE")

HIE did not provide detailed views on the SA or DPOs, but noted its consultation response that DPOs "could potentially negatively impact commercial fisheries, commercial shipping, aquaculture, tourism and recreation sectors which are also priority sectors for HIE and we therefore welcome the project level mitigation measures identified in the Plan to reduce or remove impact on these vitally important industries to the communities and economy of the Highlands and Islands." HIE also highlighted the substantial challenge posed by grid constraint and transmission charging in this region, which is being addressed by separate workstreams.

Comments relating to the draft partial ICIA

A specific consultation question sought views on the partial ICIA (as published), "Question 14 – Would you add or change anything in the partial Islands Communities Impact Assessment?"

A total of 60 responses were received to this question, with 46 respondents stating that they would not add or change anything within the ICIA, whilst 2 respondents stated that they 'did not know'. Of the 3 responses from individuals which proposed changes, 2 suggested that further information be included regarding the potential benefits of offshore wind development by either reducing the need for more carbon intensive energy generation for isolated communities, and through potential for co-location with hydrogen / green fuel production retaining jobs in island communities, as opposed to exporting energy to the national grid network. The third response agreed with the approach taken and emphasised the need for consultation with island communities.

9 organisational responses were received to this question, which tended to focus on the area of interest for each organisation. Two responses highlighted the importance of navigational safety to island communities, both regarding recreational boating and lifeline ferry services. Two responses addressed fisheries, with 1 recommending that further information be collected for Shetland and the other seeking assurances that access to offshore development areas is retained, particularly for fixed gear fishermen. One respondent highlighted the inclusion of subsea cabling as an industry of high importance for island communities in the provision of power / telecommunications. One organisation queried why a similar level of community assessment has not been applied for rural mainland communities. These responses have been taken into account in the finalisation of the Plan (see below.)

CNE-Siar stated, "The Comhairle is satisfied that, through this process, the Plan making process has clearly had regard to island communities. The Comhairle is of the view that any potential negative community impacts can be addressed through good project management and continuing engagement". All island Local Authorities highlighted the need for detailed and ongoing engagement with potentially impacted sectors at both a strategic (plan) level in relation to iterative plan review and during project-level assessment in their responses. The importance of existing sectors, such as commercial shipping, fishing and tourism, were also highlighted by all Local Authorities.

Finalisation and publication of the Plan

The feedback received during the consultation process has been used to support the finalisation of the Plan and the production of the final Regional Locational Guidance.

15 Plan Options, across four regions, were chosen to progress as final Plan Options. Two DPOs (SW1 and NE5) have not been progressed at this time and amendments were made to the boundaries of 7 DPOs, to reflect the comments raised during the consultation (as shown in Figure 4). These include boundary amendments to 3 DPOs included within this ICIA - NE1, NE2 and W1.

The boundaries of W1 have been reduced to increase the distance to shore and mitigate the potential negative impacts on commercial shipping (along the western boundary) and seascape, landscape and coastal character (eastern and northern boundaries). This has resulted in a reduction of 32% of the total seabed area. Discussion took place with Argyll and Bute Council regarding this proposed approach.

The total seabed area of NE2 has been reduced by 26% to mitigate potential negative impacts on fishers in this area (although it is possible that negative impacts could be borne in other areas – depending on where the fishers originate). Reduction of the total seabed area is intended to support the co-existence of the fishing and offshore wind industries.

NE1 has been amended to remove the area of overlap with the Shetland Islands' works licensing regime. This minor reduction (3% of the seabed area) reduces the potential administrative burden for all parties. This approach was agreed in consultation with the Shetland Islands Council.

The Post Adoption Statement details the changes made to the Plan as a result of consultation feedback in full.

The application window for the ScotWind leasing process will close after the final Plan is adopted. Applicants will only be able to apply for Option Agreements for areas of seabed located within the Plan Options included in the final Plan.