Moray Firth wind farms

Tagged with: Casework status: Open Casework type: Energy Site designations: SAC Site designations: SPA
Pink footed geese Anser brachyrhyncus, in flight past wind turbines, Near Diepholz, Lower Saxony, Germany,

Overview

Scottish Government is considering two offshore wind farm applications for the Beatrice and Outer Moray Firth projects, proposed by SSE and EDP Renewables respectively.

Located adjacent to each other in the Moray Firth, these large offshore projects combined amount to a maximum total capacity of 2.5 gigawatts of electricity capacity and a maximum of 420 turbines. 

These projects can contribute towards the reduction of emissions that are causing climate change and help achieve Scottish Government's ambitious renewables targets of 100 per cent of electricity demand met by renewables by 2020. However, these proposals also represent a significant scale of development not previously seen in Scottish waters, within a region which supports a wealth of marine habitats and species.

We have engaged with both projects to try and help identify and avoid the significant risks of impacts to seabirds in the region.

Map

Black guillemot standing on lichen covered rock carrying fish.

Why is it worth fighting for?

The coastline of the Moray Firth, with its cliff faces and suitable habitat supports a variety of seabirds including gannet, puffin and guillemot during their breeding season, whilst the waters provide foraging grounds for these and other seabirds as well as cetaceans and seals.

Internationally protected sites of the region include East Caithness Cliffs Special Protection Area and the Moray Firth Special Area of Conservation. Scottish Government is also working towards the designation of a Marine Protected Area network and in the Moray Firth there is the Southern Trench site off to the north of Fraserburgh.

This area is a proposed search area for future designation as an MPA that would support cetaceans but the site is also of great importance as a seabird foraging hotspot. Seabirds from as far north of Orkney and the Fair Isles and as far south as Aberdeenshire coast have been tracked from their colonies, foraging in this coastal region (tracking data from the FAME (Future of the Atlantic Marine Environment) project).

The importance of the Moray Firth to seabirds is a key consideration when appraising offshore wind proposals, particularly as the potential interactions of breeding seabirds with offshore turbines is not very well understood.

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A view of the loch at Abernethy

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 Atlantic puffin Fratercula arctica, on Fair Isle, Scotland

Our position

We have had early detailed discussions with both applicants and Marine Scotland (the licensing authority) and we welcome the efforts of both developers to engage with us.

Our priority concern is the potential collision and displacement effects of the wind farms on seabirds, including populations of kittiwake, great black-backed gull and puffin at East Caithness Cliffs Special Protection Area (SPA). Specifically,  we are greatly concerned by the high level of uncertainty of the environmental assessment and its conclusions. The uncertainty originates from the lack of empirical data on how birds will interact with the offshore wind farms. Given the scale of proposed development there are real large-scale risk of adverse environmental impacts.

We have objected to both applications and have liaised directly with the developers and Marine Scotland to raise our specific concerns, and our suggestion to reduce the scale of development to avoid likely adverse effects on seabird populations and the risks of breaching European Law.

Our objection is on the following grounds: 

  • The environmental impacts, in isolation and in-combination, of the proposed developments would be likely to adversely affect the integrity of the East Caithness Cliffs Special Protection Area (SPA). 
  • The environmental impacts, in isolation and in-combination, of the proposed developments would be likely to result in unacceptable harm to a range of seabird species, most notably great black-backed gull, herring gull, gannet, kittiwake and puffin. Furthermore, the national population trends of some of these species are deteriorating, which exacerbates these concerns. 
  • A high degree of precision in the process of assessment, interpretation and the setting of predicted impacts and thresholds has been applied. We consider this level of precision is unjustified, particularly given the inherent uncertainty of the assessment process that is compounded by a lack of understanding and empirical data on the biological and behavioural ecology of seabirds and seabird populations. As a result, the robustness of the conclusions of the assessments is questionable and this requires that adequate precaution is taken. 

Ministers are due to make decisions in early January and we will continue to support a much reduced scale of development that can achieve the greatest renewable energy capacity for least environmental impact.

Timeline

  • March 2014
    Scottish Ministers granted consent for both offshore windfarms in the Moray Firth on 19 March 2014. RSPB Scotland fully supports the development of offshore wind in Scotland but we still hold major concerns about the impact these two huge windfarms could have on Scotland's internationally important seabird populations, even at the reduced 75 per cent capacity consented. These developments could tip seabird populations even further over the edge and in some cases exacerbate the already dramatic population declines we are seeing nationally. RSPB is considering the detail of the consents in light of our outstanding objection and are keeping all options open before deciding on our next steps. However it is clear that now it is more important than ever that Scottish Ministers rapidly progress a network of marine protected areas to help deliver protection for Scotland’s seabirds and we will now be pressing harder on this issue to get them designated.
  • January 2014
    RSPB's final position is an objection to both applications. Marine Scotland has indicated that they are going to announce determinations early 2014.
  • 2013
    Continued engagement and discussion on assessment methodologies and requests for further information by Marine Scotland and their statutory advisors (SNH & JNCC).
  • November 2012
    RSPB submits objection letter to EDP Renewable's application, making a request for further information and clarification of assessment methodologies.
  • June 2012
    RSPB submits objection letter to SSE's application on grounds that the application is incomplete.
  • Summer 2012
    SSE submits application for Beatrice offshore wind farm (1GW capacity). EDP Renewables submits application for Outer Moray Firth offshore wind farm (1.5GW)