Consultation on the Strategic Environmental Assessment for 15 proposed Special Protection Areas

The Port of Inverness welcomes the opportunity to consult further on the proposal for 15 new Special Protected areas. With specific regard to the Strategic Environmental Assessment (SEA), the Port of Inverness broadly agrees with findings of the assessment, and has no substantive comment regarding the current contents of the report. However, we do object to the scope of the assessment since socio-economic impacts were scoped out of the SEA, on the basis that a Socio-Economic Impact Assessment (SEIA), and associated Business Regulatory Impact Assessments (BRIA) have previously been provided. As such, the only aspect of the pSPA Network, where negative impacts may have been identified, has been excluded from the SEA. This means that the SEA could only ever reach a positive conclusion, which we find rather defeats the purpose of conducting such an assessment.

A SEA should provide a holistic overview of all potential impacts on the receptors detailed in Schedule 3 of the Environmental Assessment (Scotland) Act 2005. Specifically, potential impacts on ‘Population’ should be assessed, which include socio-economic aspects. Since there is the potential for impacts on Population resulting from the socio-economic implications of the pSPA network, it is inappropriate to scope this topic out of the assessment, regardless of the previous assessments conducted. Instead the SEA should refer out to the finds of the SEIA and associated BRIAs, summarising the potential impacts identified by these assessments. This would result in a single Strategic document, providing a comprehensive overview of the potential impacts of the pSPA network, thus allowing the consultees to make an informed decision on the pros and cons of the proposal, based on a single document. Currently, the assessment has been salami-sliced, resulting in a SEA which could only result in a positive conclusion, which means constultees are required to review multiple assessments, in order to ascertain a balanced appraisal of the overall impacts of the proposal.

The point is exacerbated by the fact that serious concerns were raised by ourselves, and numerous other stakeholders, regarding the findings of the SEIA and associated BRIAs due to the inaccurate assumptions made to underpin these assessments. These concerns have never been addressed, and as such the socio-economic impacts of the pSPA network have still not been adequately assessed, which we find to be a significant oversight.

The Port of Inverness have no comments to the SPA Network Assessment.

The Port of Inverness is unable to provide feedback with regard to the scenario categories. This is due to the fact that insufficient detail regarding the specifics of each scenario has been provided in either the Network Assessment or the SEA.