Mr Matthew Barnette
Lead Environmental Project Manager (Scotland)
Scottish Hydro-Electric Transmission Limited
Inveralmond House
200 Dunkeld Road
Perth
PH1 3AQ
c.c. matthew.barnette@sse.com
25 April 2012
Dear Mr Barnette
SCOPING OPINION UNDER PART 3, REGULATION 13 OF THE MARINE WORKS
(ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2007 (AS AMENDED)
SCOTTISH HYDRO ELECTRIC TRANSMISSION LTD (SHETL): SUBSEA CABLE CONNECTION,
PETERHEAD TO TYNESIDE
Thank you for your letter dated 27 February 2012 and accompanying Consultation Document and
Environmental Impact Assessment Scoping Report (February 2012) requesting a Scoping Opinion in
accordance with The Marine Works (EIA) Regulations 2007 (as amended). These regulations
transpose the provisions of the EIA Directive (97/11/EC) into UK law.
We welcome the commitment from SHETL to conduct a voluntary Environmental Impact Assessment
(EIA), and to produce an Environmental Appraisal (EA) for each component of the project as follows:
Onshore Scotland; Offshore; and Onshore England. This Scoping Opinion relates to the Offshore
component of the project within the boundaries of Scottish territorial waters.
Background
The objective of the EIA scoping process is to seek agreement from all the key stakeholders on the
assessment methodologies; this includes the scope of issues to be addressed and the method of
assessment to be used. The scoping exercise also allows consultees to have early input into the EIA
process, to specify what may be required to be addressed and to supply information that could be
pertinent to the EIA process. In association with any comments herein, full regard has been paid to
the information submitted in the Consultation Document (Eastern HVDC Link Offshore Works
Consultation Document, February 2012) and Scoping Report (Eastern HVDC Link Offshore Works
Scoping Report, February 2012) by RSK.
Project Description
The Eastern High Voltage Direct Current (HVDC) Link to be developed by Scottish Hydro Electric
Transmission Ltd (SHETL) and National Grid Electricity Transmission plc (NGET) will facilitate
increased power flows across the Scotland to England transmission network boundary; and will
therefore facilitate the UK’s commitment to achieve 15% of energy consumption from renewable
resources by 2020; in line with the Renewable Energy Directive 2009/28/EC.
The Eastern HVDC Link will increase the electricity transmission capacity between the North and the
South of Great Britain by approximately 2 Giga Watts (GW). It will use Direct Current (DC)
technology to reinforce the existing UK transmission system in order to transmit electricity across the
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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country in very large volumes. DC electricity is created by converting conventional Alternating
Current (AC) electricity at a converter station for onwards transmission at high voltages. At the other
end of the high voltage cable, DC electricity is converted back to AC electricity at a second converter
station and then transmitted through the AC system for onwards distribution to homes and
businesses.
In both England and Scotland this will require the construction of the following electricity transmission
equipment:
• An HVDC converter station;
• A 400kV substation and associated infrastructure; and
• A corridor for two HVDC cables to land at the shoreline and connect to the converter
station.
The precise route of the cable is to be determined following routing studies and a baseline data
collection exercise as detailed in the Scoping Report. The proposed date for commencement of
operational service of the Eastern HVDC Link is 2018.
This Scoping Opinion relates to the development required for the transition of electricity, in its DC
form, from Scotland to the English electricity transmission system, and relates solely to the Scottish
marine area.
General Comments
RSK has presented an EIA Scoping Report which details the data sources and techniques used, or
those to be used, in describing the marine environmental baseline and potential impacts on human
beings, flora and fauna, landscape, geology, water and any interactions between the above, which
will be identified within the Environmental Statement (ES). Information will be derived from routing
studies and a baseline data collection exercise, to include the completion of geophysical,
geotechnical and benthic studies of the marine environment, and identification of the potential
impacts of the proposed Eastern HVDC Link and their assessment, mitigation and residual impacts
after mitigation.
The ES will include sections on marine geology and coastal processes; oceanography and water
quality; the biological environment, including: benthic ecology; fish and shellfish; and marine
mammals; the human environment, including: commercial fisheries; shipping and navigation; and
other marine users; and archaeology and cultural heritage.
As MS-LOT’s remit is principally related to the marine environment, comments are restricted to
sections of the Scoping Report that are relevant to this area and are as follows:
Consultation Document
Methodology (Section 4)
It is recommended that direct consultation is carried out with local fishermen, in addition to fishing
federations, to take account of those fishermen who are not affiliated, for example non VMS (satellitebased vessel monitoring system) vessels. Other useful points of contact are the MS Compliance
Fishery Offices, and the Inshore Fishery Groups for the Moray Firth and the South East, who may
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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provide additional information of key areas of use by smaller vessels. MS-LOT will also consult with
these bodies following receipt of the ES and application.
Regional Review (Section 5)
The environmental constraints collated adequately reflect the environmental baseline.
Route Corridor Options (10 KM Wide Corridors) (Section 6)
The rational followed and conclusions reached are sound.
Route Refinement (500 M Wide Corridors) (Section 7)
The rational followed and conclusions reached are supported in the main. However, it is noted that
Redcar Sands Route B avoids higher intensity areas of fishing whilst mostly avoiding difficult
substrates.
Scoping Report
Proposed Scope of Voluntary EIA
The proposed scope of the EIA for the marine component of the project is generally sound with the
following comments to be made:
Environmental Baseline and Potential Impacts (Section 3)
Biological Environment
Consideration should be given to any UK/ EU designated sites around the proposed works,
specifically any potential effects and mitigation where appropriate; If there is a likely significant effect
on any of these features or a cumulative significant effect then an Appropriate Assessment (AA) may
be necessary in accordance with the Council Directive 92/43/EEC (Habitats Directive) and the ES
should contain a separate section to address impacts on these sites entitled ‘Information for
Appropriate Assessment’.
Benthic Ecology
Predicted impacts should be categorised as high, medium or low impacts, and dealt with
appropriately.
Fish and Shellfish
The possible effects on salmon, sea trout and eels should be considered, in particular the effects of
electromagnetic fields. It may be helpful to consider using the generic scoping advice for offshore
renewables as a guide (Appendix 1).
Regard should be paid to the effect on salmon and sea trout rivers, in particular SAC rivers for
salmon.
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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Commercial Fisheries
Please note that there are seven aquaculture sites within the area of search for the proposed Eastern
HVDC link project. To the north there are four active shellfish production sites: two pacific oyster
sites operated by MacKenzie Oysters and Black Isle Seafood Ltd; and two common mussel sites
operated by Cromarty Mussels and Spey Bay Mussel Farm. There is another common mussel site to
the north just outside of the area of search in the Dornoch Firth operated by Highland Fresh Mussels
Ltd. There are two finfish sites within the Moray Firth area, inactive since 2003, both owned by
Northern Isles Salmon. To the South of the area of search there is an active lobster hatchery in the
Firth of Forth operated by The Firth of Forth Lobster Hatchery, which uses pumped ashore seawater
for the production of European lobsters (Appendix 2).
Shipping and Navigation
The proposed scope outlined in this section is appropriate.
Proposed Envrionmental Assessment Methodolgy (Section 4)
Benthic Ecology
It is recommended that the number of samples to be collected is increased, given the large area of
impacted seabed covered in any of the potential cable routes. The following information should be
included in the ES: the approximate proportion of the total cable route surveyed; locations of
samples; details on the benthic sampling regime programme, including the number of replicate
samples, if any, taken per sampling position; and, if appropriate, whether TV/ digital stills are
collected by ROV, sledge or drop-frame.
Thank you for consulting with us on this matter and if you require any further assistance or advice on
Marine
Licence
matters
please
contact
the
Licensing
Operations
Team
at
MS.MarineLicensing@scotland.gsi.gov.uk
Yours sincerely
Catherine Green
Marine Licensing Casework Officer
Marine Scotland – Licensing Operations Team
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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Appendix 1
Scoping comments in relation to information requirements on diadromous fish of freshwater
fisheries interest
Offshore renewable developments have the potential to directly and indirectly impact diadromous fish
of freshwater fisheries interest including Atlantic salmon, anadromous brown trout (sea trout) and
European eel. These species use the coastal areas around Scotland for feeding and migration and
are of high economic and / or conservation value. As such they should be considered during the EIA
process. Developers should also note that offshore renewable projects have the potential to impact
on fish populations at substantial distances from the development site.
In the case of Atlantic salmon information will be required to assess whether there is likely to be any
significant effect of developments on rivers which are classified as Special Areas of Conservation
(SAC’s) for Atlantic salmon under the Habitats Directive. Where there is the potential for significant
impact then sufficient information will be required to allow Marine Scotland to carry out an
Appropriate Assessment.
In order that Marine Scotland is able to assess the potential impacts of marine renewable devices on
diadromous fish and meet legislative requirements the developer should consider the site location
(including proximity to sensitive areas), type of device, and the design of any array in addition to
installation methodology. Specifically we request that developers provide information in the following
areas:
1. Identify use of the proposed development area by diadromous fish (salmon, sea trout and eels)
a. Which species use the area? Is this for feeding or migration?
b. At what times of year are the areas used?
c. In the case of salmon and sea trout what is the origin / destination of fish using the area?
2. Identify the behaviour of fish in the area
a. What swimming depths do the fish utilise
b. Is there a tendency to swim on or offshore
3. Assess the potential impacts of deployed devices on diadromous fish during deployment,
operation and decommissioning phases. Potential impacts could include:
a. Strike
b. Avoidance (including exclusion from particular rivers and subsequent impacts on local
populations)
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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c. Disorientation that could potentially affect behaviour, susceptibility to predation or by-catch, or
ability to locate normal feeding grounds or river of origin
d. Delayed migration
4. Consider the potential for cumulative impacts if there are multiple deployments in an area.
5. Assess 1-4 above to determine likely risk.
a. If there are insufficient data to determine use of the development area, these should be obtained
b. If there are insufficient data on the origin / destination of fish using the area then these should be
obtained
c. Where it is not possible to obtain site specific data, the developer should make a convincing
argument why this is the case and apply appropriate expert judgement based on published
information.
6. If there is any remaining doubt as to the potential impacts of a particular development, then the
developer should recommend a scientifically robust monitoring strategy to assess any impacts
either on stocks as a whole, or on particular rivers as necessary.
Marine Scotland Science recently completed a review of migratory routes and behaviour for Atlantic
salmon, sea trout and eels relevant to Scotland. The review is available from
http://www.scotland.gov.uk/Resource/Doc/295194/0111162.pdf.
SNH recently commissioned a review of the potential impacts of EMF and noise on migratory fish
and this is available at:
www.snh.org.uk/pdfs/publications/commissioned_reports/401.pdf
Together these reports will assist the developers in identifying what pre-existing information is
available and what supplementary site specific data may be required.
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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Appendix 2
Marine Laboratory, PO Box 101, 375 Victoria Road,
Aberdeen AB11 9DB
www.scotland.gov.uk/marinescotland
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