Dear Mr Scarf,

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Ms Kate Berry,
Seagreen Wind Energy Limited,
C/o SSE Renewables,
1 Waterloo Street
Glasgow
G2 6AY
2 March 2011
Dear Ms Berry,
Thank you for your letter dated 4 February 2011 and attached Seagreen Position Paper:
Fish and Shellfish Resources Characterisation and Assessment for the Round 3 Zone 2 Firth
of Forth Offshore Wind Farm.
I will address your covering letter and then highlight specific points in relation to the Paper.
With reference to benthic ecology and natural fish you ask if Marine Scotland (MS) would be
supportive of the removal of benthic trawls as a potential method for benthic sampling and
natural fish sampling. Benthic trawling is a necessary part of the pre-installation survey. MS
advises that benthic trawls are a satisfactory method of sampling epibenthos but are a
technique less applicable to the sampling of fish and so MS would support the removal of
benthic trawling for natural fish population sampling but retain the benthic sampling
component in line with the 2 or 4m beam trawl as laid down in your Benthic Survey Plan.
On the subject of commercial fisheries, you state your intention to present 10 years of data
and where necessary longer. Please identify areas that you intend to cover with longer data
sets. The fishery sensitivity maps held by MS have been sent to you be e-mail. Marine
Scotland Science (MSS) suggest you review landings, effort and value data of both marine
and migratory fish species, covering a wide range of vessel sizes through appropriate
consultation. You have previously been advised by MS-LOT that trawls and surveys for
commercial fisheries are not required (letter dated 27 January 2011).
On the topic of migratory fish, you suggest proceeding on the basis of available data, in the
absence of specific studies using “your best judgement” regarding the use of, and behaviour
in, the area by migratory fish species. Marine Scotland-Licensing Operations Team (MSLOT) is content for you to proceed on this basis, provided that we are made aware of the
thinking behind your judgements at the earliest opportunity. MS-LOT consider that the
potential for impacts on migratory fish should be addressed through desk-based study using
commercial and recreational catch statistics and including thorough analysis and
interpretation of current literature concerning the potential interactions of wind farms with
migratory fish. We also consider that predictions based on literature and modelling
simulations would be an acceptable approach, and that field surveys may be onerous and
potentially of little value. Please take account of both operational and installation related
disturbance. Robust installation and operation noise assessment must be undertaken and
linked to assessment of the sensitivity of the species present in the area to the potential
noise generated by your operations. Again, where a paucity of data exists this should
highlighted. Should you wish to access salmon catch statistics on a district level please
provide us with the request and we will ask MSS colleagues to respond.
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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MS-LOT response to Seagreen Position Paper: Fish and Shellfish Resources
Characterisation and Assessment for the Round 3 Zone 2 Firth of Forth Offshore Wind
Farm
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In section 1.3, please clarify how you intend to give consideration to the ecological
importance of prey species.
MSS have stated that sufficient data sources have been identified in section 2
(question 1).
With reference to the table spanning pages 5 and 6, please identify how physical
disturbance has been scoped out. You state in your Scoping Report that this will be
confirmed by phase and zone wide data collection. Please confirm the status of this
data collection.
Please provide the rationale, and suitably reference any information, used to scope
out the increase in diversity and number of individuals as a result a result of the
alteration of the environment by the foundations and structures.
Please define what is meant by ‘ecological linkages’.
Please consider the presence of vessels on the site during the installation as a
construction impact.
Please give some consideration to the operational noise of the structures as an
operational impact.
Please clarify how you will use the MS fisheries survey data to inform the
assessment of construction noise and vibration.
Please expand on the phrase ‘prevailing conditions’ in section 4.3
Please consider elasmobranchs in your approach to impacts from electromagnetic
fields (EMF).
Please consider habitats other that the seabed in the assessment of loss of habitat,
for example aerial and aqueous habitats.
Please consider expanding section 5.0 as the meaning is not particularly clear.
Should you have any further questions then please do not hesitate to get in touch.
Yours sincerely,
Mike Bland
Marine Licensing Casework Manager
Licensing Operations Team
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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