1. Stakeholder Engagement and Consultation

1.1. Introduction

  1. This chapter of the Offshore Environmental Impact Assessment (EIA) Report summarises the stakeholder engagement and consultation undertaken during the pre-Application stage of the Offshore EIA Report for the Berwick Bank offshore wind farm. The offshore components of the Project (hereafter referred to as the ‘Proposed Development’) include the offshore wind farm (the wind turbines, their foundations and associated inter-array cabling), together with associated infrastructure including Offshore Substation Platforms (OSPs)/Offshore convertor station platform, their foundations and the offshore export cables and cable protection.
  2. In conjunction with the Pre-Application Consultation (PAC) Report (Onshore and Offshore) (SSER, 2022d), this chapter provides a record of the stakeholder and public engagement that has been undertaken in the pre-Application stage for Proposed Development.
  3. This report, in conjunction with the PAC Report (SSER, 2022d),summarises stakeholder and public engagement up to and including the 01 October 2022 and aligns with Marine Scotland Licencing and Operation Team (MS-LOT) guidance (MS-LOT, 2018) which advises that “Informal consultation at the pre-application stage and ongoing dialogue with MS-LOT, its advisors and other stakeholders, including local interest groups and the public will also help to ensure that appropriate consideration is given to all stakeholder concerns (including the public) and that opinions are integrated into the project decision making process.” This report forms part of the Offshore EIA Report which supports the Application for Consents and Licences (as set out in volume 1, chapter 1) for the offshore components of the Project (see paragraphs 8 and 9).
  4. Berwick Bank Wind Farm Limited (BBWFL) is a wholly owned subsidiary of SSE Renewables Limited and will hereafter be referred to as ‘the Applicant’. The Applicant is developing the Berwick Bank Wind Farm (hereafter referred to as ‘the Project’). The Applicant is committed to thorough stakeholder engagement, as has sought to use feedback gathered during stakeholder engagement and consultation to inform decision making and Project design. All stakeholder feedback has been collated and reviewed as part of the pre-Application phase to ensure all feedback has been considered as part of the development of the Proposed Development. Engagement with stakeholders will continue during the post-Application phase as the Proposed Development continues to develop.

1.2. Purpose of this Chapter

  1. The primary purpose of the Offshore EIA Report is outlined in volume 1, chapter 1. It is intended that the Offshore EIA Report will provide the Scottish Ministers, statutory and non-statutory stakeholders, with sufficient information to determine the likely significant effects of the Proposed Development on the receiving environment.
  2. In particular, this Stakeholder Engagement and Consultation Offshore EIA Report chapter summarises:
  • the approach taken to consultation by the Applicant during the pre-Application stage for the Proposed Development;
  • informal and formal stakeholder engagement undertaken;
  •         key feedback received during the pre-Application phase; and
  •         the stakeholder engagement processes applied to the pre-Application stage.
    1. A separate report detailing the PAC process (SSER, 2022d) provides further detail of consultation undertaken and is provided as an accompanying report to this Offshore EIA Report. In addition, the following reports provide a summary of views raised and response provided by the Applicant:
  •         PAC Report appendix 1 - Berwick Bank Report on Consultation November 2020;
  •         PAC Report appendix 2 - Berwick Bank Report on Consultation October 2021;
  •         PAC Report appendix 3 - Berwick Bank Report on Consultation December 2021; and
  •         PAC Report appendix 4 - Berwick Bank Report on Consultation March 2022.

1.3. Background

  1. The Project is a proposed offshore wind farm located in the outer Firth of Forth and Firth of Tay, approximately 37.8 km east of the Scottish Borders coastline (St. Abb’s Head) and 47.6 km to the East Lothian coastline (see Figure 1.1   Open ▸ ). The Project is comprised of both the offshore and onshore infrastructure required to generate and transmit electricity from the Proposed Development array area to a Scottish Power Energy Networks (SPEN) 400 kV Grid Substation located at Branxton, south-east of Torness Power station. The Proposed Development export cable corridor will make landfall on the East Lothian coast, specifically at Skateraw.
  2. As described in volume 1, chapter 3, the Applicant is developing an additional export cable grid connection to Blyth, Northumberland (the Cambois connection). Applications for necessary consents (including marine licenses) will be applied for separately. The Cumulative Effects Assessment (CEA) for the Cambois connection is based on information presented in the Cambois connection Scoping Report (SSER, 2022e), submitted in October 2022.
  3. The key offshore components of the Proposed Development (seaward of MHWS), as illustrated in Figure 1.2   Open ▸ will include:
  • up to 307 wind turbines (each comprising a tower section, nacelle and three rotor blades) and associated support structures and foundations;
  • up to ten OSPs/Offshore convertor station platforms and associated support structures and foundations;
  • estimated scour protection area of up to 10,984 m2 per wind turbine and 11,146 m2 per OSP/Offshore convertor station platform;
  • a network of inter-array cabling linking the individual wind turbines to each other and to the OSPs/Offshore convertor station platforms plus inter-connections between OSPs/Offshore convertor station platforms (approximately 1,225 km of inter-array cabling and 94 km of interconnector cabling); and
  • up to eight offshore export cables connecting the OSPs/Offshore convertor station platforms to Skateraw landfall. It is possible that either High Voltage Alternating Current (HVAC) or High Voltage Direct Current (HVDC) cables will be used for the Proposed Development.

Figure 1.1:
Location of the Proposed Development Array Area, within the Former Firth of Forth Zone, and Proposed Development Export Cable Corridor

Figure 1.1: Location of the Proposed Development Array Area, within the Former Firth of Forth Zone, and Proposed Development Export Cable Corridor

Figure 1.2:
Project Overview[1]

Figure 1.2: Project Overview[1]

 

1.4. Policy and Legislative Context

  1. Policy and legislation on renewable energy infrastructure is presented in volume 1, chapter 2 of the Offshore EIA Report. Policy and legislation specifically in relation to stakeholder engagement and consultation is contained in the Aarhus Convention (The United Nations Economic Commission for Europe (UNECE) documents, The Aarhus Convention: An Implementation Guide (2011 and 2014 versions) represent best practice in respect of how to consult with members of the public on major projects; the EIA Regulations; and for the Scottish Inshore Region, in the Marine Licensing (Pre-application Consultation) (Scotland) Regulations 2013 (“PAC Regs”). A summary of the legislative provisions relevant to stakeholder engagement and consultation are provided in Table 1.1   Open ▸ and Table 1.2   Open ▸ , and in relation to the PAC regulations in the PAC Report (section 2.2) (SSER, 2022d).

 

Table 1.1:
Summary of the Aarhus Convention Relevant to Stakeholder Engagement and Consultation

Table 1.1: Summary of the Aarhus Convention Relevant to Stakeholder Engagement and Consultation

 

Table 1.2:
Summary of EIA Directive and Regulations Relevant to Stakeholder Engagement and Consultation

Table 1.2: Summary of EIA Directive and Regulations Relevant to Stakeholder Engagement and Consultation

 

1.5. Good Practice in Consultation

  1. The Applicant has sought to follow good practice throughout pre-Application consultation on the Proposed Development, including complying with advice from MS-LOT on continued engagement throughout pre-Application processes. MS-LOT recommends that “developers recognise the importance of continuing engagement between developers, MS-LOT and its advisors, and other stakeholders (including local interest groups and the public) to ensure that appropriate consideration is given to all stakeholder concerns and that opinions are integrated into the project decision making process. Details of all the consultation undertaken as part of the EIA, leading up to application, should also be documented (including how any concerns/issues have been addressed) (Marine Consenting and Licencing Guidance, Scottish Government, 2018)”.
  2. The Applicant has reviewed and considered all feedback provided as part of stakeholder consultation in the pre-application, and this is documented in the following reports:

 

Table 1.3:
Guiding Principles for Stakeholder Engagement and Consultation

Table 1.3: Guiding Principles for Stakeholder Engagement and Consultation

 

  1. Throughout the development phase of the Proposed Development, the Applicant has carried out consultation with statutory and non-statutory consultees, and with members of the Public following the principles and good practice set out below:
  • the Aarhus Convention;
  • the EIA Regulations;
  • Marine Consenting and Licencing Guidance, Scottish Government, 2018; and
  • the Gunning Principles.

1.6. Public Engagement

  1. Key groups of Public stakeholders have been engaged throughout the pre-Application phase of the Proposed Development, as follows:
  • Strategic Engagement: Engagement focussed on local and national Government bodies including local authority councillors;
  • National Engagement: Engagement focussed on statutory stakeholders and non-statutory bodies with particular interest in offshore activity; and
  • Local Engagement: Engagement focussed on local organisations, local communities and members of the Public.

1.6.2.    Strategic and National Engagement

  1. The Applicant has met regularly with Ministers for the Scottish Parliament, Members of Parliament (MPs), Scottish Cabinet Secretaries and held an exhibition in the Scottish Parliament. In additional the Applicant has held an exhibition and attended a reception in the Scottish Parliament. Please see details in the PAC Report (SSER, 2022d).

1.6.3.    Local Engagement

  1. The Applicant has met regularly with local authority councillors, local organisations and members of the public.
  2. Due to COVID-19 pandemic restriction in 2020, 2021 and early 2022, some public exhibitions and consultation events were held online only. Please see PAC Report (SSER, 2022d) for full breakdown of public consultation events, feedback received, and measures taken to compensate for COVID-19 pandemic restrictions.

1.6.4.    Pre-Application Consultation

  1. Public consultation for the Project during the pre-Application phase took place during COVID-19 pandemic restrictions, therefore, by necessity, some public exhibitions and consultation events were held online only. The Applicant team has always aimed to go above and beyond statutory requirements, to establish best practices in the offshore wind sector. To fulfil this aim, the Applicant ran 13 virtual events and 17 in-person events (which followed the Scottish Government’s guidance), seeking to ensure feedback was received from as diverse a range of public groups as possible. Details about these public exhibitions are set out in chapters 5 to 8 of the PAC Report (SSER, 2022d). Materials used at these events were also made accessible on the Project website – www.berwickbank.com.
  2. The following public exhibitions/engagement events have taken place:
  • a virtual public exhibition to introduce the Project to the public was held in November 2020;
  • a Community Roadshow was undertaken in October 2021;
  • a second public exhibition in December 2021; and
  • an additional public exhibition was held in March 2022.
    1. The aim of the exhibitions was to provide updated information on the Proposed Development and allow the Applicant to respond to any questions the public may have. They were also an opportunity for Scottish companies to register their interest in helping support the successful delivery of the Proposed Development for Scotland.
    2. For further detail on the approach to formal consultation events and the outcomes of these events please see the Project PAC Report (SSER, 2022d). In summary, 77 days of consultation over four phases has been carried out, 33,496 mail drops have been sent out, and 30 events have been run, with 1,820 attendees.
    3. Information has also been made available on virtual platforms such as bespoke virtual consultation platforms, creation of a specific Project website and LinkedIn.

1.6.5.    Community Engagement

  1. A dedicated Stakeholder Engagement Manager (SEM) has been in place from the commencement of development of the Proposed Development, to facilitate and support engagement with the community. The SEM is available 9 am to 5 pm, Monday to Friday, or alternatively by appointment outside of these hours. Contact details for the SEM has been made available on the Proposed Development website, and public exhibitions, online events and via direct mailings to all residents located within three miles of North Berwick, Dunbar, Innerwick and East Linton.
  2. In addition to formal consultation events, the SEM carried out local engagement with public, community councils, businesses and local organisations in the form of virtual and in person meetings. A Project specific e-mail for public queries was also set up, monitored and responded to when appropriate by the SEM.
  3. A Project mailing list has also been created and is managed by the Project SEM. This list allows members of the public to voluntarily provide their e-mail address to ensure they are directly contacted with major project information, such as notification of when the planning application is submitted and how to view/comment on the application.

1.6.6.    Information Provision and Awareness Raising

  1. Throughout the pre-application process, the Applicant has sought to engage with stakeholders, including members of the public, through provision of information. Information has been communicated through a variety of channels as outlined within this section.

Fisheries Liaison Officer

  1. A FLO has been engaged on the Proposed Development since July 2019. With fisheries expertise; the FLO acts as the primary point of contact for liaison with the fishing industry on behalf of the applicant. The FLO has the delegated authority to fully represent the Applicant on fisheries related issues, such as; attending necessary Commercial Fisheries Working Groups (CFWG’s); timely communication of any programmed works; negotiating any necessary disruption settlements etc. The applicant has appointed Brown and May Marine Ltd (BMML) to act as FLO on the Proposed Development. BMML has over 35 years’ experience in the provision of commercial fisheries consultancy services to the offshore industry across the UK. BMML have extensive experience of developing long-term working relationships with regional, national and international fishermen organisations, statutory stakeholder bodies, government research centres and government and EU ministries.
  2. Further to this, since 2020, the Applicant has employed a dedicated in-house Commercial Fisheries Manager. The Commercial Fisheries Manager is responsible for managing and providing technical expertise on all fisheries related internal Proposed Development operations across the Applicant’s offshore development portfolio and leads the company's external representation on strategic fisheries work and stakeholder liaison.

Information provision, project website and digital information

  1. Stakeholders have had the opportunity to contact the Applicant via e-mail, phone and the Project website throughout the pre-Application stage. The SEM has made himself available for virtual or in-person meetings whenever requested by stakeholders.
  2. There is also a postal address for those stakeholders who prefer to make written submissions. This address is: 1 Waterloo Street, Glasgow, G2 6AY.
  3. A dedicated email address has been administered throughout the pre-application phase at: berwickbank@sse.com.
  4. A dedicated Project website was hosted by the Applicant and can be found here:

www.berwickbank.com.

  1. The Berwick Bank Wind Farm Project website has been kept up to date with relevant information including both onshore and offshore aspects of the Project. The website also includes a Berwick Bank Wind Farm Briefing Pack with details and facts about the Project, and ways to contact the Project team.
  2. The Applicant have also provided digital versions of key documentation to allow easy access and user flexibility. Digital documentation provided includes:
  • Digital Offshore EIA Scoping Report (SSER, 2021a);
  • Digital Offshore Likely Significant Effect (LSE) Screening Report (SSER, 2021b);
  • Digital Offshore EIA Report; and
  • Digital Offshore Report to Inform Appropriate Assessment (RIAA) (SSER, 2022c).
    1. Consultation events were advertised in the Courier, East Lothian Courier (including their website and Facebook page), St Andrew’s Citizen and Berwickshire News. Details on this are set out in section 4.7 of the PAC Report (SSER, 2022d).

1.7. Stakeholder Engagement

  1. A thorough statutory and non-statutory stakeholder engagement process has been undertaken by the Applicant, supported by their Consultants. This has included meetings, correspondence, meeting minutes, and provision of digital documentation. Due to COVID-19 pandemic restriction in 2020, 2021 and early 2022, all statutory stakeholder engagement has taken place virtually. By necessity, some public exhibitions and consultation events were held online only.
  2. The list of organisations that were approached/consulted during the pre-Application process (including Scoping and LSE screening) for the Proposed Development are:
  • Angus Community Councils;
  • Angus Council;
  • Business, Energy and Industrial Strategy (BEIS);
  • Berwickshire Marine Reserve;
  • British Telecom (BT);
  • Chamber of Shipping (CoS);
  • Craig Hoy Member of Scottish Parliament for South Scotland;
  • Cruising Association;
  • Department for Environment, Food and Rural Affairs (DEFRA);
  • East Lothian Community Councils;
  • East Lothian Council;
  • East Lothian Industry & Partnership Group;
  • East Lothian Works;
  • Edinburgh & Midlothian Chamber of Commerce;
  • Fife Community Councils;
  • Fife Council;
  • Fisheries Stakeholders;
  • Historic Environment Scotland (HES);
  • Kenny MacAskill Member of Parliament for East Lothian;
  • Local Residents;
  • Local Ward Councillors for Angus;
  • Local Ward Councillors for East Lothian;
  • Local Ward Councillors for Fife;
  • Local Ward Councillors for Scottish Borders;
  • Marine Analytical Unit (MAU);
  • MS-LOT;
  • Marine Scotland Science (MSS);
  • Maritime and Coastguard Agency (MCA);
  • Martin Whitefield Member of Scottish Parliament for South Scotland;
  • Michael Matheson, Scottish Cabinet Secretary for Net Zero, Energy & Transport;
  • Ministry of Defence (MOD);
  • Naert Na Goithe (NnG);
  • National Air Traffic Services (NATS);
  • Natural England;
  • NatureScot;
  • North East Regional Inshore Fisheries Group (NERIFG);
  • Network Rail;
  • Northern Lighthouse Board (NLB);
  • Northumberland County Council;
  • Northumberland Inshore Fisheries and Conservation Authority (NIFCA);
  • Paul McLennan Member of Scottish Parliament for East Lothian;
  • Port Authorities including Forth Ports;
  • Royal National Lifeboat Institution;
  • Royal Society for the Protection of Birds (RSPB);
  • Royal Society for the Protection of Birds Scotland (RSPB Scotland);
  • Royal Yachting Association Scotland (RYA);
  • Scottish Borders Community Councils;
  • Scottish Borders Council;
  • Scottish Environment Protection Agency (SEPA);
  • Scottish Fishermen’s Federation;
  • Scottish Government members, officials and ministers;
  • Scottish Power Energy Networks;
  • Scottish Seabird Centre;
  • Scottish Surfers Federation;
  • Scottish Water;
  • Scottish White Fish Producers Association (SWFPA);
  • Transport Scotland;
  • Visit Scotland; and
  • Whale and Dolphin Conservation (WDC).
    1. For some topics, a “Road Map” processes of engagement was undertaken. These topics were:
  • benthic subtidal and intertidal ecology, fish and shellfish ecology and physical processes;
  • marine mammals;
  • ornithology; and
  • shipping and navigation.
    1. The list of organisations which engaged with the Road Map processes are detailed in volume 3, appendix 8.2, appendix 10.3, appendix 11.8 and, appendix 13.2 respectively. These Road Maps provide a summary of the pre-Application discussions with key stakeholders for these technical areas.

1.8. Feedback and Reporting

  1. All feedback received throughout the pre-Application consultation phase was recorded and collated by the Applicant, supported by their Consultants, including feedback received by written, verbal, email, phone and post submission. A separate report (SSER, 2022d) detailing the PAC process provides further detail of consultation undertaken and is provided as an accompanying report to this Offshore EIA Report. The PAC Report (SSER, 2022d) provides a summary of the number and type of feedback provided by category. Consultation for technical topics is provided in each technical assessment as outlined in Table 1.4   Open ▸ .

1.8.2.    Proposed Development - Technical Feedback

  1. Feedback received relating to the Proposed Development technical chapters has been addressed in topic chapters and appendices as outlined in Table 1.4   Open ▸ . Feedback was received via phone, email, post and verbally (as detailed in the PAC Report (SSER, 2022d). Stakeholders provided feedback as part of EIA scoping and LSE screening, and during post-scoping discussions.
  2. The following documents provide a summary of consultation feedback received in the pre-Application phase and these should be read in conjunction with this report:
  • points of discussions in relation to Road Map topics are summarised in the following Appendices to the Offshore EIA Report:

–           volume 3, appendix 8.2: Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map;

–           volume 3, appendix 10.3: Marine Mammals Road Map;

–           volume 3, appendix 11.8: Offshore Ornithology Road Map; and

–           volume 3, appendix 13.2: Shipping and Navigation Road Map.

  • An Audit Document of Post-Scoping Discussions has been requested by MS-LOT and it presented in volume 3, appendix 5.1. This report summarises key points discussed between the Applicant and MS‑LOT/NatureScot post-Scoping Report.

 

Table 1.4:
Technical Topics Feedback and where Considered in this Offshore EIA Report

Table 1.4: Technical Topics Feedback and where Considered in this Offshore EIA Report

 

1.8.3.    Other Proposed Development Feedback

  1. Community Benefit Funds were raised at various points throughout the development phase of the Project, by a range of stakeholders. The Applicant is committed to the creation of a community benefit fund in the event of successful consent. In this event, the Applicant will consult with stakeholders to develop a Community Benefit Fund in the most appropriate manner.

1.8.4.    Feedback Informing the PRoposed Development

  1. The Applicant has reviewed and had regard to all feedback received throughout the pre-application process, and as described in this document.
  2. Main feedback received relates to the assessment of potential impacts of the Proposed Development human and environmental receptors, and the measures that may be required to minimise potential impacts. Feedback has therefore been used to inform the assessment of the Proposed Development through both the Offshore EIA Report and the RIAA (SSER, 2022c), and has been used by the Applicant to inform key decisions on the development of the Proposed Development.

1.9. References

Scottish Government (2018). Marine Scotland Consenting and Licensing Guidance. For Offshore Wind, Wave and Tidal Energy Applications. Available at: https://www.gov.scot/binaries/content/documents/govscot/publications/consultation-paper/2018/10/marine-scotland-consenting-licensing-manual-offshore-wind-wave-tidal-energy-applications/documents/00542001-pdf/00542001-pdf/govscot%3Adocument/00542001.pdf. Accessed on: 1 September 2022

SSER (2021a). Berwick Bank Wind Farm Offshore Scoping Report. Accessible at: https://berwickbank-eia.com/offshore-scoping/

SSER (2021b). Berwick Bank Wind Farm Offshore HRA Screening Report. Accessible at: https://berwickbank-eia.com/lse-screening-report

SSER (2022b). Berwick Bank Wind Farm Marine Protected Area Assessment.

SSER (2022c). Berwick Bank Wind Farm Report to Inform Appropriate Assessment.

SSER (2022d). Berwick Bank Wind Farm Pre-Application Consultation Report.

SSER (2022e). Cambois connection Scoping Report.

 

 

[1] Consent is not sought in this Application for SPEN Grid Substation and overhead connections.