Offshore Wind Sectoral Marine Plan Scoping Consultation

Offshore Wind green energy is one of the key deliverables of the National Marine Plan. However, the NMP has not been mentioned in the Context Report whereas since 2015 it has been the overriding reason driving all marine spatial planning.

Clause 6.1.3 appears to acknowledge mistakes were made with the first round of windfarm planning consents sited off the East Coast of Scotland. Mobile gear fishermen have been permanently displaced from traditional fishing grounds in breach of NMP Planning Principle No1 which instructs there should be a presumption in favour of protecting food resources. It also acknowledges that seabirds and sea mammals fish where commercial fishermen fish.

Clause 6.1.5 refers to a new focus on siting wind farms in deep waters to lessen the impact on inshore fishing except it fails to acknowledge that supply routes and cable routes have been allowed to go through inshore fishing grounds causing significant disruption, loss of gear and income as well as some displacement to local static gear fishermen.

Whilst the scope and assessment methodology looks impressive, neither the first round or this one requires consultation with the fishermen working in the proposed area, who could provide a wealth of local information and data if asked.

A recent report commissioned by FLOWW reported on 5th July 2018, that without local knowledge an initial area of search stated there was no lobsters in the largest lobster fishery in Europe (Holderness). Without local knowledge, mistakes will be made.

It should be noted that there are more areas in the sea where there is no commercial fishing than where there is commercial fishing. The key inshore and offshore fishing grounds could be quickly and cheaply mapped using available data sources. Siting windfarms outwith these areas would ensure compliance with the EU Directive & NMP requirement to avoid conflict between sectors and avoid unnecessarily killing large numbers of seabirds.

The other baseline information that is missing is the critical habitats (spawning grounds & nurseries) for target species. Without this information, a windfarm may inadvertently be built on a critical habitat in breach of the NMP planning principles and Section 6 Fisheries 1 & 2 in particular.

I'm not qualified to say.

The draft plan was overseen by a Project Advisory Group consisting of the Scottish Government, Crown Estate Scotland and unspecified 'relevant stakeholders'. The Scottish Government funds the IFGs to participate in 'marine management developments' and are widely representative of all sectors (pelagic, demersal & shellfish). Had the IFG's been represented on the PAG, we could have helped advise where we don't fish to avoid unnecessary spatial conflict and knock-on consequences.

Re 2.1.1, ABPmer advised IFMAC that decisions were made in Round One without sufficient fishing data and A.7.6 confirms significant data limitations still exist. However, it is rather negligent not to place any obligation on planning applicants to approach those fishermen who are liable to be affected to get their fishing data from them. This would be a cheap exercise to establish which area would be most suitable to site their windfarm to avoid fishermen, seabirds and sea mammals.

Re 2.6 which states that due to the uncertainties around export routes, no economic impact assessment will be made. This is nonsense. Commercial fishermen have been unnecessarily displaced from traditional fishing grounds by cable routes and 'safe routes' and are having their gear towed away by supply vessels. It would be a quick, cheap and effective to take advise from local fishermen at the Areas of Search stage, which routes would be most suitable to avoid unnecessary conflict.

To save OW applicants time and money, they should be instructed to liaise directly with the fishermen liable to be affected to get their fishing data and provide a fully accurate view of the Areas of Search. The IFG's can organise introductions to those fishermen as we are independent and better placed to bring together all relevant vessel owners to encourage their co-operation encompassing fishing data and potentially vital local knowledge.

Not to do so, could lead to a breach in the NMP planning policy Fisheries 1, that existing fishing opportunities and activities are to be safeguarded and that other sectors take in to account the need to protect fish stocks.

The need to protect food sources whilst moving forwards with green energy plans was emphasised by a statement made on 12th June 2018 by Cabinet Secretary Roseanne Cunningham to the Scottish Parliament.

None

Yes, all the area where there is no commercial fishing or critical habitats for target species.