Publication - Strategy/plan
Sectoral marine plan: post adoption statement
Sets out the changes between the draft and final sectoral marine plan for offshore wind energy in accordance with Section 18(3) of the Environmental Assessment (Scotland) Act 2005 (“the 2005 Act”).
2 Integration of Environmental Considerations
2.1 The Strategic Environment Assessment Process
2.1.1 The 2005 Act requires public bodies in Scotland to carry out a Strategic Environmental Assessment ("SEA") of their plans, programmes or strategies. SEA is a way of examining plans as they develop to identify any significant effects they may have on the environment. It ensures that environmental considerations are taken into account and, where required, proposes mitigation measures to avoid or minimise any potentially significant adverse environmental effects.
2.1.2 The SEA process was undertaken throughout the planning process, providing an opportunity to add value by exploring the potential environmental constraints, reducing environmental impacts arising as a result of the plan by refining the plan option areas throughout the process from Areas of Search, to Draft Plan Option areas and subsequently to the Plan Option Areas presented in the final Plan and in Figure 3, avoiding areas of highest constraint.
2.1.3 The SEA process commenced with scoping, and a scoping report was submitted to the SEA Gateway in June 2018[7]. This was consulted on in June 2018 to July 2018 and a consultation report prepared[8].
2.1.4 The scoping report was followed by the Environmental Report in December 2019[9] which was based on the Draft Plan Option areas (Figure 2). This was consulted on from December 2019 to March 2020 and a consultation report prepared[10] which summarises the comments.
2.1.5 Following the completion of the consultation process, further modifications were made to the assessed areas, prior to them being accepted by Scottish Ministers as Plan Options. The reasoning behind these modifications is captured in Section 5 below, and a review of the impact of these changes, and any further information released following publication of the Draft Plan on the conclusions of the SEA, is contained within Annex A. In summary, the modifications made do not significantly impact on the conclusions of the SEA, although the removal of two sites (SW1 and NE5) and the modifications made to W1 reduce the proportion of the sites in inshore regions, and therefore may reduce associated impacts such as those on landscape and seascape.
2.1.6 The Post Adoption Statement is the final output from the SEA process and is required under the 2005 Act. It outlines how the findings of the SEA and the views of consultees have been taken into account as the Plan was finalised and presented for Ministerial approval.
2.2 The SEA
2.2.1 The SEA process commenced in 2018, with the preparation of, and consultation upon, the scoping report. The Scoping Report described the baseline information and key sustainability issues and set out the SEA Framework (objectives) against which potential effects were assessed. Information contained within the scoping report and from consultation responses was used in guiding the development of the Environmental Report.
2.2.2 The SEA has considered environmental effects against a set of agreed SEA objectives (outlined in Table 1) below, which were based on those developed for previous offshore wind plan SEAs and updated following advice from the consultation authorities during the scoping phase. This 'objective led' approach provides a useful mechanism to draw together and comment on potential impacts of the Plan.
| SEA Topic | SEA Objective |
|---|---|
| Biodiversity, Flora, and Fauna |
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| Population and Human Health |
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| Soil (Marine Geology and Coastal Processes) |
|
| Water Quality |
|
| Climatic Factors |
|
| Cultural Heritage |
|
| Landscape/Seascape |
|
2.3 How the Environmental Report has been taken into account
2.3.1 Table 2 summarises how the environmental report, produced based on the Draft Plan, has been taken into account within the final Plan in accordance with Section 18(3) of the 2005 Act. The table describes how the environmental report has been taken into account in the adopted Plan and what specific changes were made, particularly where significant negative and cumulative effects were identified. This table highlights when mitigation is to be considered, if there is a need for a more detailed assessment at a later stage in the planning process (i.e. project-level implementation).
2.3.2 Comments received on the SEA have also been taken into account and are addressed under Question 8 in Section 5.
| SEA Topic | SEA Objective | Findings from the environmental report | Integrated into the Plan (Y/N) | How integrated/taken account or reason not taken into account | When should mitigation be considered? |
|---|---|---|---|---|---|
| Biodiversity, Flora, and Fauna | To safeguard marine and coastal ecosystems, including species, habitats, and their interactions | Development within the DPOs and along the export cable routes will have some direct and indirect effects on species and habitats. These effects can be minimised through careful site and route selection and implementation of appropriate mitigation. The increase in renewable energy capacity will, in the long-term, contribute to reducing greenhouse gas emissions associated with energy generation and thus help to limit the effects of climate change on marine ecosystems. | Y | The Plan recognises the importance of the sector in contributing to the reduction in greenhouse emissions. The Plan identifies project level assessment and mitigation, as proposed by the SEA which should be considered during project planning and development. | Mitigation should be considered throughout the project EIA and HRA development process for all project stages. |
| To avoid adverse effects on both designated and non-designated habitats and species (note links with HRA) | None of the DPOs overlap with designated sites, however the HRA identifies potential for interaction between offshore wind development in the DPOs and the foraging ranges of bird species from SPAs. The proposed plan-level mitigation measures will help to avoid/minimise impacts to designated features. Where potential cable routes might intersect designated sites, adverse effects can be avoided or minimised through careful route selection and installation methods. Risks to non-designated habitats and species can be avoided or minimised through careful project design and adoption of appropriate mitigation measures. | Y | The Plan incorporates specific mitigation measures to help avoid / minimise impacts to designated features. In addition, the Plan identifies the requirement for project level assessment and mitigation, as identified within the SEA. | Mitigation should be considered throughout the project EIA and HRA development process for all project stages. | |
| To avoid the introduction and spread of INNS. | Risks associated with vessels can be minimised through the implementation of biosecurity plans for construction operation and decommissioning of offshore wind farms. The presence of offshore wind farms will provide new substrate which could be colonized by INNS. However, experience to date does not indicate that this is a significant risk pathway for the spread of INNS. | Y | The Plan identifies the requirement for biosecurity management plans as part of project level assessment and mitigation. | Biosecurity management plans should be considered during project planning and assessment for all stages of project development. | |
| Population and Human Health | To maintain the accessibility of natural areas for recreation | Within the DPOs themselves, recreational activity is limited to yachting activity and angling. There is potential for displacement of this activity, however spatial planning within the DPOs can be used to avoid areas of key effect and mitigate any deterioration against this objective. There are some areas inshore of the DPOs where recreational activity may be affected by export cable installation. However, effects from cable installation are considered to be temporary, and planning of the cable route to avoid key areas can mitigate deterioration against the objective. | Y | The plan recognises potential effects on recreational users and recommends that project level mitigations are identified to reduce impacts on recreational users. | Impacts on recreational usage should be considered as part of the project level assessment and consultation processes. |
| To minimise or prevent the discharge of pollutants into the natural environment | The implementation of the plan will not directly support achievement of this objective; however, it is not considered likely that implementation of the plan will lead to a deterioration against this objective. At a project level, pollution management plans will be produced to mitigate against the effects. | Y | The Plan identifies the requirement for pollution management plans as part of project level assessment and mitigation. | Pollution management plans should be considered during project planning and assessment for all stages of project development. | |
| To avoid adverse effects on human health and safety | The implementation of the plan has the potential to cause deterioration of the environment against this objective due to negative effects on navigational safety. There is potential for effects on navigational safety, particularly in NE4 and NE6. In addition, where DPOs overlap at a lesser scale with navigational routes, spatial planning can be used at a project level to allow for safe transit through the DPOs, in part through the application of MCA guidance in MGN 543. At a plan level, it is considered that there will be a residual deterioration against this objective. | Y | The Plan recognises the potential impacts on navigational safety and identifies requirements for project level assessment and management, including adherence to MCA guidance. | To be considered during project planning and assessment, including during consideration of array design. | |
| Soil (Marine Geology and Coastal Processes) | To avoid exacerbating coastal erosion and maintain the integrity of coastal processes | There are several areas where the development of a DPO and associated export cable installation has the potential to affect coastal processes. At the plan level it is not possible to determine the extent of these effects, therefore at a project level it is possible that hydrodynamic and sediment modelling may be required to determine if a development will affect coastal processes. | Y | The Plan recognises the potential impacts on coastal processes and identifies requirements for project level assessment and management. | To be considered during project planning and assessment. |
| To maintain and protect the character and integrity of the seabed, including avoiding the pollution of seabed strata/bottom sediments | The installation of turbines and subsea cables will affect the seabed within their physical footprint, and immediate vicinity. The development of offshore wind within the DPOs and associated export cable installation will therefore cause deterioration against this objective. The degree of effect will, however, vary significantly depending on the technology employed, the level of scour protection required, and the seabed type. | Y | The Plan recognises the potential impacts on coastal processes / seabed integrity and identifies requirements for project level assessment and management. | To be considered during project planning and assessment. | |
| To avoid significant adverse physical damage to coastal geodiversity sites from coastal infrastructure | There is considerable uncertainty regarding potential cable landfall locations, therefore the effect on coastal geodiversity sites cannot be assessed at a plan level. Assessment against this pathway will be undertaken at a project level, however it is expected that cable routes will be planned to avoid geodiversity sites. | Y | The Plan recognises the potential impacts on coastal processes and coastal geodiversity and identifies requirements for project level assessment and mitigation. | To be considered during project planning and assessment. | |
| Water Quality | To avoid pollution of the coastal and marine water environment | The implementation of the plan will not directly support achievement of this objective; however, it is not considered likely that implementation of the plan will lead to a deterioration against this objective. At a project level, pollution management plans will be produced to mitigate against the effects. | Y | The Plan identifies the requirement for pollution management plans as part of project level assessment and mitigation. | Pollution management plans should be considered during project planning and assessment for all stages of project development. |
| To maintain or work towards achieving good ecological status | The implementation of the plan has the potential to cause deterioration of the environment against this objective. Where potential for effects on the ecological baseline are identified above, recommendations have been raised to mitigate this at a plan level. At a project level, spatial planning can generally be used to avoid areas of high effect within an individual DPO and associated cable routes, and the WFD regulations place requirements on developers to avoid significant effects on the ecological status of coastal or transitional water bodies. | Y | The Plan incorporates specific mitigation measures to help avoid / minimise impacts to designated features. In addition, the Plan identifies the requirement for project level assessment and mitigation, as identified within the SEA. | Mitigation should be considered throughout the project EIA and HRA development process for all project stages. | |
| Climatic Factors | To contribute to a diverse and decarbonised energy sector | The development of offshore wind in line with the plan has the potential to significantly contribute to the achievement of this objective. | Y | The Plan recognises the contribution of offshore wind in supporting the decarbonisation of the energy sector. | N/A |
| To ensure that adaptation to predicted climate change impacts are taken into account (for example, through consideration of resilience and changing environmental sensitivity) | The plan cannot be assessed against this objective, however individual developments will be required to take account of and ensure that designs incorporate resilience against potential climate change effects. In addition, any changes to the baseline as a result of climate change will be incorporated into the plan as part of the iterative plan review process. | N | The plan does not specify climate resilience requirements; however individual projects will be required to demonstrate this under the overarching National Marine Plan (Policy: Gen 8). | Mitigation should be considered throughout the project planning and design phases. | |
| To preserve marine carbon stocks and carbon sequestration potential (note: this objective is closely linked to the SEA topic of 'Biodiversity, Flora, and Fauna') | There is potential for marine carbon stocks to be present within DPOs or within export cable corridors, and to be affected by development of offshore wind. At a project level spatial planning will be required to avoid areas of sensitive marine carbon, however there is potential for disturbance of seabed sediments, which form a significant carbon sink. The disturbance of seabed sediments is dependent on the technology selected, however it is considered unlikely that effects will cause deterioration against this objective at a national level. | N | Whilst this is not directly addressed within the Draft Plan, it will be managed as per the biodiversity topic above, and is expected to be included in project level assessment. | Mitigation should be considered throughout the project EIA and HRA development process for all project stages. | |
| Cultural Heritage | To protect and, where appropriate, enhance, the historic marine environment | There are no designated historic areas within the DPOs. However, there are known shipwrecks within the DPOs and, at a project level, surveys will be required to identify areas of potential historic significance, effects on which can subsequently be avoided. At a project level this will be managed through the application of a Marine Archaeology Reporting Plan (MARP). The process of developing within the DPOs therefore has the potential to identify additional heritage assets and therefore support the achievement of this objective. | Y | The Plan includes provision for project specific survey to determine cable routes of least environmental effect, including potential effects on cultural heritage assets. | Mitigation should be considered throughout the project EIA development process for all project stages. |
| To avoid damage to known and unknown coastal and marine archaeology | There are no designated historic areas within the DPOs. However, there are known shipwrecks within the DPOs and at a project level surveys will be required to identify areas of potential historic significance, effects on which can subsequently be avoided. The process of developing within the DPOs therefore has the potential to identify additional heritage assets and therefore support the achievement of this objective. There is considerable uncertainty regarding potential cable routes and landfall locations, therefore the effect on coastal heritage sites cannot be assessed at a plan level. Assessment against this pathway will be undertaken at a project level through the application of a MARP, and any sensitive heritage assets avoided through appropriate route selection. | Y | The Plan includes provision for project specific survey to determine cable routes of least environmental effect, including potential effects on cultural heritage assets. | Mitigation should be considered throughout the project EIA development process for all project stages. | |
| To avoid adverse effects on the character and setting of historic sites and buildings | There is considerable uncertainty regarding potential cable routes and landfall locations, therefore the effect on coastal or inland heritage sites cannot be assessed at a plan level. Assessment against this pathway will be undertaken at a project level, associated with the terrestrial planning process. | Y | The Plan includes provision for project specific survey to determine cable routes of least environmental effect, including potential effects on cultural heritage assets. | Mitigation should be considered throughout the project EIA development process for all project stages. | |
| Landscape/Seascape | To avoid or minimise adverse effects on landscape, seascape, and visual amenity, including designated sites; | There are significant areas identified within the DPOs within which developments will affect the landscape, seascape and visual amenity of the coastal region in high and low light conditions. Potential mitigation measures have been identified for consideration at a project level, specifically the spatial planning to avoid areas closest to land or, where this is not possible, selection of smaller turbines in areas closer to land, to minimise adverse effects. This assessment can therefore support the implementation of the plan whilst achieving against this objective. | Y | The Plan addresses the potential impacts on landscape / seascape throughout, and identifies requirements for project specific consultation, assessment and mitigation. In addition, concerns regarding impacts at the DPO SW1 raised in the SEA and during consultation contributed to this being removed from the final plan. | Mitigation should be considered throughout the project EIA development process for all project stages. |
| To promote the protection of seascape and coastal landscapes; | Assessment within the plan has identified potential risks to seascape and coastal landscapes, and proposed mitigation measures to reduce or remove effects. The plan therefore may support achievement of the objectives by identifying areas of lower risk for development. | Y | The Plan has reviewed the areas in the context of seascape and landscape concerns and removed / modified areas to promote areas of lower constraint. The Plan also identifies requirements for project specific consultation, assessment and mitigation. | Mitigation should be considered throughout the project EIA development process for all project stages. | |
| To avoid or minimise adverse visual effects. | There are significant areas identified within the DPOs within which developments will affect the landscape, seascape and visual amenity of the coastal region. Potential mitigations have been identified for consideration at a project level, specifically the spatial planning to avoid areas closest to land or, where this is not possible, selection of smaller turbines in areas closer to land, in order to reduce the visual effects. This assessment can therefore support the implementation of the plan whilst achieving against this objective. | Y | The Plan has reviewed the areas in the context of seascape and landscape concerns and removed / modified areas to promote areas of lower constraint. The Plan also identifies requirements for project specific consultation, assessment and mitigation. | Mitigation should be considered throughout the project EIA development process for all project stages. |
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