Berwick Bank Offshore Windfarm

Offshore wind development located in significant and highly sensitive areas can have substantial adverse impacts on the natural environment, partially seabirds. Seabirds are relatively long-lived, and as a result, their populations are sensitive to small increases in adult mortality. Their survival and productivity rates can be impacted by offshore windfarms directly (i.e. collision) and indirectly (e.g. displacement from foraging areas and having to use more energy to reach feeding grounds). They are also already under severe pressure. Between 1986 to 2019 according to the Scottish biodiversity indicator the number of breeding seabirds in Scotland has declined by 49%. On top of this, seabirds have also been impacted by Highly Pathogenic Avian Influenza (HPAI) outbreaks. At some seabird colonies, such as the Northern Gannets at Bass Rock, this virus decimated breeding attempts in 2022.  

The predicted impacts of Berwick Bank Offshore Wind Farm are extremely large. For Puffin at the Forth Islands SPA, in combination with other North Sea windfarms, after the 35-year lifetime the development, the population size of the SPA is expected to be between 7.4 and 12% lower that it would have been in the absence of the development. For Kittiwakes at St Abbs, after the life time of the development, the size of the SPA population is expected to be between 59 and 65.9 % lower than it would be in the absence of the development.  

When the impacts are allocated to SPA seabird colonies, the Applicant has identified that could result in an adverse effect on site integrity (AEoSI) at eight SPAs for Kittiwake, Guillemot, Puffin and Razorbill. We welcome this recognition, but we are mindful of the state of Scottish seabirds and the pressures they already face. These predicted SPA colony size as percentages in absence of the development do not account for secondary impacts from building on sandeel habitat and are additional to existing population declines and events such as HPAI. Kittiwake and Puffin are also red listed in the Birds of Conservation Concern and have been assessed as vulnerable to global extinction. Following analysis of the recommended approach, we consider potential for AEoSI cannot be excluded for Kittiwake, Gannet, Razorbill, Guillemot and Puffin at twelve SPAs.   

An AEoSI means potential effects from the development that are also likely to prevent the achievement of an SPA’s conservation objectives and cannot be mitigated. These international sites are the most important sites for wildlife. They are legally required to be conserved and if necessary restored to favourable conservation status.  

Under the Habitats Regulations, a project that would result in AEoSI cannot be permitted unless it can be demonstrated there are no less damaging alternative solutions, there are imperative reasons of overriding public interest (IROPI) for the project to go ahead, and ecological compensation to maintain the coherence of the UK/National Sites Network for the affected species can be secured.  

Following a review of the application, RSPB Scotland do not consider the search for alternative solutions performed by the Applicant is adequate. It has dismissed Scotwind sites without proper assessment of whether they would meet the same objective as the proposed development and whether they would be less harmful.  

We also do not believe that the proposed compensation measures are sufficient. There are evidence gaps around the colony compensation measures in terms of the species targeted, the feasibility of their implementation and their effectiveness. The proposed fisheries compensations measure to limit sandeel fishing are also problematic. Although RSPB Scotland strongly support the closure of the UK Exclusive Economic Zone industrial sandeel fishery, we view it as a vital measure to build resilience in seabird populations in the face of mounting pressure from food web disruption, offshore renewable energy development and HPAI. We do not consider it a mechanism to compensate for an additional pressure. Furthermore, Scottish Government has already committed to the closure of the industrial sandeel fishery in Scottish waters to help meet the obligations of Good Environmental Status for our seas under the Marine Strategy Regulations 2020 and to accord with the Scotland’s Fisheries Management Strategy.  

Although the Applicant holds a lease to allow it to develop a windfarm at this location, RSPB Scotland do not believe this is the right location for this type of development. We recognise there is a need for renewable energy and have sympathy with the Applicant’s position. They have invested large resources, both time and financial, into thoroughly assessing modelling impacts. We greatly appreciate the work they have done to understand the site. This unfortunately does not however make the impacts acceptable.  

Overall, it is a highly sensitive area in which to place a windfarm. Inevitably the magnitude of the predicted impacts reflects this. The sediments and other environmental aspects that make an area of sea a good nursery and spawning area for fish and foraging area for seabirds cannot be relocated. It is also not possible to relocate seabird breeding colonies. It is however possible to put an offshore windfarm development in a different location and there are alternative sites available where the same objective of this application would be met. We therefore must stand up for nature and object to the proposed development.

Application documentation is available here: Section 36 Consent - Berwick Bank Offshore Wind Farm - Firth of Forth | Marine Scotland Information 

Scottish Environment Link Response: LINK response to Berwick Bank Offshore Wind Farm proposal - Scotlink  

• Gannet 
• Guillemot 
• Kittiwake 
• Puffin 
• Razorbill 

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