National Marine Plan

Map_9from_DMP The National Marine Plan (NMP) has been in gestation since 2010.

It was  adopted on 25 March 2015 and laid before Parliament on 27 March 2015 .

The NMP covers:- Sea Fisheries/Aquaculture / Wild Salmon and Diadromous Fish / Oil and Gas /Carbon Capture and Storage / Offshore Wind and Marine Renewable Energy/Recreation and Tourism/Shipping, Ports, Harbours and Ferries/Submarine Cables/Defence/ Aggregates

NTA contribution to any input to the NMP was restricted to NTA’s constitution i.e. any possible offshore renewables development within 35km of Tiree’s shoreline

Re Renewables;- in Sept 2012 Marine Scotland proposed, to the consultation, that most of offshore Scotland could be zoned for possible future wind,wave, and tidal developments!

These were subsequently rationalised, to be represented in Map 9 (above), published in the draft NMP in Dec 2014 , and  subsequently without alteration, in the Adopted NMP  laid before Parliament on 27th March 2015 Options image for submission  Nov 2013 incl Saltire notation

Ch11 of the dNMP presented the Tiree implications;- zoning of two sites,  one for a possible Wave Farm development(WW3), and the other for a possible offshore wind farm(OWW2).

The credibility of Tiree specifics of Ch11 of the NMP  may be questioned.The NMP still shows the Tiree Saltire Prize site. (See Map 9 below). But no Developer applied for the Tiree site, and the d/line to apply passed on 15 Jan 2015.

NTA speculates that by not updating the Tiree Saltire Prize site, the NMP, as published, may require modification and correction.

Not withstanding an EU aim for NMP’s, there is no time frame to deliver a NMP . To Scottish G’s credit it is ahead of the game, as no other comparable NMP has emerged from any other EU member  state .

WavemCollageWith regard to Renewables, the credibility of the NMP has to be further  questioned.   In 4Q2014 Scottish Government, de facto, dropped WAVE. Pelamis (red) went into into administration, and Aquamarine (yellow) contracted its operations.
Pelamis collapsed owing more than £15 million, including almost £13m to Scottish Enterprise(SE), which also had similar financial exposure to Aquamarine .

Aquamarine subsequently  went into administration, and ceased trading in  4Q2015.

According to a 4Q2016 audit ,the combined accrued loss to Govt ie taxpayers on both ventures , exceeded £40mill

SG has put a brave face on any continuum of a commitment to WAVE by establishing, in Feb 2015, essentially a R&D quango,’Wave Energy Scotland(WES),  co-incidentally manned by mainly ex Pelamis employees .

SG’s funding of WES is with the stated aim to seek  “ …..at least one wave technology to reach the point where it is commercially viable(anticipated  time frame 2020-2025), as UK’s Energy Technologies Institute (EIT) simultaneously  produced its report  ‘WAVE ENERGY INSIGHTS’ which stated that wave  was ‘...unlikely to make any significant contribution to the UK energy system in the coming decades’

Since publication of the dNMP in Dec 2014 , NTA has lobbied Scottish Govt-Marine Scotland to drop zoning WW3.

Planning,divorced from technical,environmental ,and commercial reality,lacks credibility.

Environmental considerations were ‘stand- alone reasons ‘to drop zoning WW3

The SEA (Strategic Environment Assessment ) with regard to WW3 was flawed. The SEA totally ignored any reference to the environmental data that contributed to SPR-Iberdrola dropping the Tiree Array.

SG and MS have rejected NTA’s lobbying to drop zoning WW3/OWW2.

RE zoning OWW2 for possible windfarm development;- it was  self evident, from SPR-Iberdrola’s reasons in dropping the Tiree Array, that a quantum leap in foundation, and turbine technology, will be required to give any credibility to any  possible development of OWW2

Other than ‘still to be tested floating turbines‘, there is no evidence of this required quantum leap. Of more immediate significance is the current slow trajectory of offshore wind development, with no investment decision, as yet ,for any of the current Scottish offshore wind projects. The distraction of cheaper, and less technically challenging Scottish-UK- European sites, suggests the possible development of OWW2 may remain an intangible concept…for a long..long.. time.

Map 9 ( below) shows the Plan Options  for marine renewables  Adopted in the NMP . It shows ALL potential Scottish Offshore Renewable Development Zones .

NMP_Map_9_mar_2015_Note: The STW sites were adopted in Mar 2011( when the Tiree Array was adopted). The Developers of  all  consented STW sites have yet to make their investment  decision.  4 sites are subject to judicial review. Only 2  hold CfD subsidy support  ( a pre- requisite  for any investment decision) . None of these sites will be ‘spinning‘ before 2018, ie more than 4 yrs later than anticipated by SG following Mar 2011 Adoption.

NTA’s conclusion is that any possible development in the Tiree development zones in the NMP  will not occur in the foreseeable future.

Tiree will always be on the  ‘extreme edge ‘ of applied offshore renewables technology.

SPR-Iberdrola, following dropping of the Tiree Array, demonstrated, by continuing to develop their other English, French  and Baltic offshore wind-farm sites, that there are cheaper, more accessible, developments sites outside Scotland.  The developers of the current 4 Scottish consented sites all have extensive international development site portfolios. This suggests a raft of European offshore renewable development sites may be more attractive to Developers, long before any Tiree site will register on a Developer’s radar.

SPR-Iberdrola’s current international offshore renewables development programme confirms NTA’s conclusion .

It would appear that SG-MS has learnt nothing from SPR-Iberdrola  dropping the Tiree Array.

Any response,when,and if required,will come from a NTA MK 2!

The document below is a compilation of most of the NTA-SG-MS correspondence, from Dec 2014, regarding the NMP:-

• NTA’s e-mail(10 Dec 2014) to Fergus Ewing(Minister of Energy) 2 days prior publication of the draft NMP
• NTA’s (5Jan)  ADDITIONAL EVIDENCE SUBMISSION
• NTA’s further submission of ADDITIONAL MATTERS for CONSIDERATION
• MS’ reply (16 Jan) stating MS’ holistic methodology in drafting Ch11 of the NMP.
• NTA’s reply (22 Jan) challenging MS’ holistic methodology.
• MS’ reply (02 MAR) stating SPR’s dropping of the Tiree Array was SPR’s prerogative ,ergo irrelevant to zoning WW3
• NTA reply ( 04 Mar) stating MS’ position was disingenuous, also as SG’s  sponsored WES reduced SG’s wave  ambition to seeking commercially viable wave technology by 2025, where was the logic in zoning WW3 in 2015 ?
• NTA reply (17 Mar) on procedural issues arising from the Parliamentary debate on the NMP

SG in adopting WW3 and OWW2, has:-

  • ignored the lessons of the 2011 Adoption Process.

and

  •  ignored the technical, and environmental reasons why SPR dropped the Tiree Array

POSTSCRIPT:-

The NMP’s delivery after 5 years of  ‘stop-start‘ gestation, appears , ironically, to be rushed, even forced.

To put this in perspective the progress and delivery of the  NMP was monitored by  the  Rural Affairs, Climate Change and Environment Committee(RACCE).

11th Dec 2014 SG published the dNMP , asking for any evidential submission to be submitted to the RACCE  by the 5th Jan 2015. SG then went on Xmas Hols to return on the 5th Jan!!

30th Jan 2015;  The RACCE published its report on the dNMP stating it was “lacking in clarity”  and ‘not fit for purpose”

NTA understood that Scottish Government (SG) would reflect on this RACCE  report, and any other representations.

19th Feb 2015. SG speedily moved a Parl debate on the dNMP. SG’s motion made no reference to the RACCE report . It  was only the subsequent acceptance of two amendments, which conceded any possibility that the anxieties of the RACCE may be considered by SG, as it  moved forward to derive the NMP for Adoption .

25th March 2015. NMP Adopted. NTA cannot find any changes in the NMP which substantively reflects any of the anxieties of the RACCE report .The lack of updating the Saltire Prize sites  is indicative of a rushed job

Postscript:-

NTA subsequently enquired of Marine Scotland re Saltire Prize status . MS re-confirmed there had been no applicant for the Tiree site,and also stated bizarrely ‘ that no decision has been taken on the future of the Saltire Prize or any other related competition coming forward under the ‘Saltire Prize’ banner.’  The competition rules were set by Scot Govt (SG) in 2010 ,so  does this imply, what NTA suspects, that  SG may be considering re-writing the rules, to avoid the embarrassment of only one entry, which may not even qualify for the prize?
MS also advised that the Tiree zones,as  with all other zones in Map 9, were  ‘indicative’ only!!

It now remains to be seen if the Adopted NMP is ‘fit for purpose

 

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