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20 September 2008
Consultation On Proposed Marine Extension To North Caithness Cliffs
Ex councillor Bill Mowat has sent us this copy of his response the Scottish Natural Heritage consultation on an extension to the North Caithness Cliffs 'Special Protection Area'. At a recent meeting of Caithness councillors meeting in Wick where representatives of SNH set out what they were trying to do the councillors stated similar doubts about the extensions in Caithness at a time when the potential for marine energy was being looked at as a potentially vital component in securing future employment in the county and for the whole of Scotland and the UK in exploiting one of our biggest renewable energy sources. The Caithness councillors left the SNH representatives in no doubt that they were against the proposed extension particularly at this crucial time and in the light of he fact the SNH is a consultee in every planning application for the areas concerned and can make representations to change or alter locations and make suggestions on how to lessen perceived threats to wildlife.  Opposition has been expressed by several local groups and bodies to this extension at this crucial time for marine energy developments........... Bill Fernie

The consultation by SNH ends on 22 September 2008 and can be found at http://www.snh.org.uk/about/directives/ab-dir15aa.asp Anyone wishing to make representations about the proposals needs to do it in the next two days.

SUBJECT: RESPONSE TO CONSULTATION ON PROPOSED ‘MARINE EXTENSION’ TO THE NORTH CAITHNESS CLIFFS ‘SPECIAL PROTECTION AREA’.

FROM : WILLIAM ‘BILL’ MOWAT, SEPTEMBER 2008: ‘Balquholly’, JOHN O’GROATS, Caithness KWI 4YR , also at 3E REAY STREET, INVERNESS IV2 3AJ, to which reply.

TO: SCOTTISH NATURAL HERITAGE/ FOR INFORMATION TO OTHER PARTIES WITH ‘PENTLAND FIRTH INTERESTS’.

PERSONAL BACKGROUND: b. Thurso, native of John O’Groats, educ. Wick High, Edinburgh University, M.A.(Hons); served as elected Councillor (North East Caithness ward 5) on Inverness- based local authority for four terms (16 years); presently vice-chair of Gills Harbour, a community owned facility on shores of Pentland Firth 4 miles west of John O’Groats that has agreement with Pentland Ferries Ltd, allowing provision of thrice-daily year-round RO:RO passenger/freight service to St Margaret’s Hope, Orkney; FEI (Fellow of Energy Institute).

APPLICATION BACKGROUND: Scottish Natural Heritage is proposing to extend (by fifteen-fold) the present SPA (presently applies to the sea-bird nesting cliffs/their bases of the South side of the Pentland Firth) by 2 kilometres offshore to include the sea-surface, water-column and sea floor of much of the Firth. This includes almost all of the Inner Sound between the Scottish Mainland coast between John O’Groats/Gills Bay and uninhabited Stroma Island. It represents a near 25-fold increase in the area covered by the ‘Special Protection Area’ (see p. 8 of the SNH document)

MY RESPONSE: An objection, on the grounds that sea birds are cited in isolation, to the exclusion of other subjects, several involving statutory bodies, in the Pentland Firth. There are other natural and human matters/interests that are subject to UK and Scottish Government policies (both present and projected) and to international obligations/conventions (both European Union and United Nations agencies) that the UK Government is a signatory to.

REASONS FOR OBJECTION: (a) Seabirds.
It is true that the cliffs here house large breeding colonies of sea birds. Those are amongst the attractions to tourists to visit the John O’Groats area and provide a plank of ‘wild life’ summer-season cruises for the jet-powered RIB ‘North Coast Explorer’ and 250-passenger capacity ‘Pentland Venture’; as Councillor I was successful in getting access road to Duncansby Head upgraded to provide coach access plus parking for same to enhance numbers of persons able to enjoy the scenic beauties of these perpendicular red-sandstone cliffs with horizontal ledges that house the largest sea-bird colony here and the dramatic offshore sea-stacks, plus sighting wild sea-mammals ; and with honorary office-bearers of Duncansby Head Common Grazings Committee to provide access by cliff-top path; and with others (including a predecessor body of SNH) to provide some passive interpretation facilities. This access allows less able visitors (e.g. elderly) to observe a seabird colony at first hand as the cliffs are indented with impressive gashes/inlets with vertical horizontal-strata rock-faces known as ‘geos’.

However, having attended the public meeting in Canisbay Hall on September 17th called by Dunnet & Canisbay Community Council and addressed by SNH’s Ms Lesley Cranna, I remain unconvinced that civil servants drawing lines around a large ‘exclusion zone’ in the Firth can/will do anything at all to enhance the habitat/ environment for local resident and migratory sea-birds.

In the past, some were sought as human food (both guillemot carcases and ‘seagulls eggs’) and as a source for feathers; my late father was amongst those local fishermen who shot shags and cormorants for manufacture in the London area into ‘chicken paste’ for sandwiches in the 1945 food austerity era; others including rock pigeons, were shot for ‘sport’. But for many decades, the sea birds have not been under any such threat from humans.

It is accepted that there are fluctuations in numbers as detailed by the near doubling of guillemot numbers and even larger increase in puffins between 1985-88 and 1998-2002 on P. 6 of SNH Consultation Document.

The sea-bird populations are presumably affected by weather conditions during the spring/early summer breeding season and by availability of food for birds, perhaps particularly on shoals of sand-eels, a tiny fin-fish caught by ‘industrial’ trawlers using mini-mesh nets in the North Sea to provide fodder (fishmeal) for salmon farmers and fish-oil for human consumption bakery foodstuffs manufacture, etc. Industrial trawlers also catch and utilise tens of thousands of tonnes of immature edible species annually in the North Sea.

I am told by a local teenage creel-boat deckhand that a decade ago as a primary schoolboy he used to see ‘swarms’ of sand-eels in summer swimming in the harbour at John O’Groats, while now there seems to be hardly any. As well as the above-mentioned ‘industrial’ fishing pressure, all conducted entirely out-with of the Pentland Firth, there have been suggestions that the movements/migrations (?) of such shoals could be influenced by ‘global warming’.

If the apparent demise of sand-eel stocks at John O’Groats Harbour is reflected in adjacent waters, (especially in the North Sea, east of Duncansby Head) then this may (at least partially) account for the reportedly poor sea bird breeding seasons of 2006 & 2007, although crews on John O’Groats-based wildlife cruise boats say that 2008 was a ‘reasonably successful’ one for nesting seabirds.

REASONS FOR OBJECTION: (b) fishing.
Trawling for white-fish, prawns, or pelagic species (e.g. herring) or dredging for bivalve shellfish (e.g. scallops) has never been possible in the Pentland Firth, owing to the very strong tidal streams, the nature of the sea-bed and its relatively confined area. The sea-bed here in not under threat of any such disturbance.

The fishing effort here involves using static-gear creels (mainly locally manufactured) to catch brown crabs, velvet swimming crabs and lobsters; almost all of the catch is transported ‘live’ in articulated lorries carrying ‘vivier tanks’ of aerated seawater to markets in Europe, especially Spain and Portugal. There are no significant ‘discards’ of dead, fish, as unwanted or ‘under legal size’ animals are returned alive to the sea. This is in direct contrast to what pertains in the whitefish-trawling sector, where regular discarding of dead ‘non-quota’ fin-fish edible species has come to be regarded as ‘scandalous’.

There is no evidence that such shell fishing does any harm to seabirds and, as during the past two centuries, it is reasonable to suppose that such local fishermen and the seabirds can continue to ‘happily’ co-exist.

There used to be a significant line-caught Pentland Firth whitefish industry, where salted air-dried cod and ling were sold to the same Mediterranean markets as today’s crabs etc. This used to be the backbone of the economy of (especially) Stroma Island, but was ruined by overfishing by trawlers in the nearby Moray Firth (an arm of the North Sea) and beyond the Pentland Firth’s Western approaches in North Atlantic waters. This resulted in the de-population of Stroma Island; it has been uninhabited for 50 years.

Despite ‘assurances’, creel-boat skipper-owners tell me that they fear that, if granted, the proposed Marine Extension to the SPA could lead to significant restrictions being placed on their efforts in future.

REASONS FOR OBJECTION: (c) other marine wildlife.
The Pentland Firth (e.g., Stroma, Duncansby Head) is ‘home’ to large seal colonies; those are no longer harvested for seal-oil and skins nor culled (e.g. in contrast to wild red deer where SNH encourages the ‘controlled’ annual shooting of numerous hinds).

Since seal culling in nearby Orkney waters ceased in the 1970s, the colonies have noticeably expanded; there is no evidence that a nature Special Protection Area covering the waters as above will in any way enhance conditions for seals.

The Firth’s tidal-stream waters are regularly used by various cetaceans (of whale family, including minke, ‘killer’ orcas, dolphins and harbour porpoises), especially in summer; those mainly transit through the straits and do not seem to be ‘resident’. Tourists taking John O’Groats wildlife cruises enjoy such sightings. It is known that cetacean numbers have increased since whaling off Britain’s coasts was outlawed (early 1970s). This increase has happened without the ‘benefit’ of a Marine Special Protection Area.

REASONS FOR OBJECTION: (d) national and international trade and commerce.
The shortest, quickest and most sheltered route across the Pentland Firth between Mainalnd Scotland and Orkney is via the narrow eastern end of the Channel plied by two operators, Pentland Ferries and John O’Groats Ferries. The latter runs the 250-passenger summer foot-ferry ‘Pentland Venture’ from that Council-owned harbour.

Pentland Ferries operates a year-round RO:RO service from Gills Bay and is shortly introducing a brand-new innovative (for Scotland) catamaran ship, presently en route from a Far East shipyard and expected here in October 2008. Pentland Ferries’ captains use the strong tidal streams to advantage and the option of using the lee of Stroma and Swona on the 15-mile trip gives added shelter. In contrast, the present alternative year-round RO:RO service from Scrabster, Caithness to Stromness, Orkney, is almost twice the distance (28 miles), and is almost entirely made through open unsheltered waters at the Firth’s western end. The UK taxpayers bear the entire loss (£10 million in 2007) of the Scrabster route.

Both Pentland Ferries (year-round) and John O’Groats Ferries (1st May-30th September) routes daily cross the proposed ‘Marine Extension’ to the SPA, dubbed an ‘exclusion zone’ by a prominent Highland councillor representing Landward Caithness.

The Pentland Firth is an important national and international sea-route, transited by c. 6,500 vessels per annum. As well as much UK and Irish near-waters commerce, which includes crude-oil tankers loading at nearby Flotta (Orkney) oil terminal, other transiting tankers include those carrying LPG/LNG (‘pressurised fuel gas’) plus other oil-related ‘supply-boat’ shipping servicing ‘Atlantic Frontier’ oil and gas fields/exploration ‘blocks’ on the UK continental shelf. Chemical tankers, carrying ‘building block’ liquids for a myriad of everyday items used worldwide, ply the Firth more frequently than crude-oil carriers ; some such cargoes are banned from overland road or rail transport in the UK and EU.

The Firth carries most of the multi-billion pound/euro annual sea-trade between North West Europe/ the Baltic coast on one hand and North America on the other, regularly including access by sea-ways/canals/fresh-water lakes to major ‘inland’ destinations including Montreal, Canada, Chicago and Albany (NY), as well as to Gulf of Mexico and Caribbean ports. International bulk commodity (e.g. metal ores) carriers and vessels carrying thousands of shipping containers are regular users: almost all of Iceland’s and Greenland’s sea-trade with Europe goes through the Pentland Firth.

The UK Government is a signatory to a convention by a UN agency, the London-based International Maritime Organisation, that provides ‘right of free passage’ to merchant shipping using the Pentland Firth, despite its lying wholly within UK territorial waters. Part of the SPA proposed extension covers the main through trade-route between Stroma and Swona islands; no evidence is provided that the international shipping community has either been consulted or agreed to an SPA, certain to be interpreted as a marine Nature Reserve.

REASONS FOR OBJECTION: (e) Potential large-scale green electricity generation.
This will involve capturing the ‘kinetic energy’ in the very strong Pentland Firth tide-streams using ‘horizontal hydro-power’ devices, of which c. 50 are in various stages of development world-wide; none are yet beyond the prototype stage.

2008 marks the centenary of the Firth first being proposed for electricity generation by playwright/philosopher George Bernard Shaw, who used to regularly cross on angling trips to Orkney; at aged 91 during the 20th Century’s worst winter in 1947, when snowdrifts and frozen rail points interrupted coal supplies from the pits to power stations, he publicly repeated his concept of the Firth providing electricity ‘to ‘power half of Europe’

In the early 1990s, scientists and engineers with the DTI’s Energy Technology Support Unit, based at Harwell, Oxon, conducted the first ‘desk-top’ study of the UK’s tidal stream electricity-generating potential, using information mainly held by public-sector agencies; this showed that the Pentland Firth was by far and away the best site in UK waters, its only major ‘rival’ being Alderney Race, off the Channel Islands, intersected by the ‘boundary line’ between the UK and France’s territorial sea.

The Pentland Firth arguably holds more UK/Scottish ‘renewable energy’ potential than any other single area in the UK; concerns over carbon dioxide emissions, the ‘renewables’ targets set by both the UK and (later) Scottish Executive/Governments plus large world-wide price inflation in oil, gas and other hydrocarbons coalesced to encourage generating device engineers/developers.

The Scottish Government has set an extremely ambitious target of 50% of Scotland’s electricity coming from renewable sources within 12 years: perhaps impossible without a significant Pentland Firth input.

The European Marine Energy Centre was established in Orkney to test/evaluate marine energy generating devices; in 2007 UK Energy Minister Malcolm Wicks familiarised himself with marine generating potential by visited it. On the same visit he addressed a conference in Thurso, Caithness, called to identify/evaluate ways of replacing c. 2000 energy-related jobs in Caithness. The Dounreay Fast Reactor experimental site, on the North Coast at the western approaches to the Pentland Firth has given employment to c. 2,000 persons since the mid-1950s.

Those jobs will end in the early 2020s when employment will reduce to a handful on completion of Dounreay’s safe demolition/decommissioning. Replacement professional jobs are of particular importance to Caithness (popn. c. 26,000) as it is not within daily ‘travel to work’ distance of any other significant source of employment. The Caithness Regeneration Partnership was established in 2007 to this end and decided to place the ‘Pentland Firth Tidal Energy Project’ at the centre of its promotion; building on the resource of established Caithness-based energy-related high-tech engineering shops servicing initially Dounreay and then diversifying to supply specialist components to the international offshore oil & gas industry via Aberdeen, its European ‘hub’.

Mr Wicks revealed that his Department would consider helping with funding of generic research into the Pentland Firth’s characteristics; this has been taken up by researchers at the University of the Highlands and Islands North Highland College campus in Thurso, Caithness.

It has just (08.08) taken delivery of a small research vessel to deploy proven devices for accurately measuring tidal streams, swells and waves. College chiefs have an ambitious target of seeing 1,200 MW installed Pentland capacity by 2020: broadly equivalent to the output of one new nuclear power station. Until the measurements, as above, have been collated/analysed it is not possible to accurately state what the final Pentland Firth electricity potential will be, while doing no, or minimal, damage to the environment; but it could be eight to ten time the above figure, implying a ‘green-energy’ investment of billions of pounds.

Amongst the key topics to be addressed by water-borne research and measurements is the possibility (even likelihood) that the tidal streams of the Firth can produce large quantities of ‘base-load’, round-the clock electricity.

This would be done by the judicious linking of arrays in separate parts of the Firth to take advantage of different high-water times in short distances both along the coast and out into the Firth; this should eliminate the non-generating ‘gaps’ around tide-turn.

This so-called ‘Magee hypothesis’, enunciated by community-owned Gills Harbour’s treasurer Billy Magee, with a lifetime’s experience of traditional small-boat experience in the Firth will, if proven, add significantly to the value of electricity output. Variable weather dictates that electricity generated by wind or wave-power must always be liable to interruption, so the prospect of the Firth’s ‘horizontal hydro turbines’ offering 24/7 generation should allow a direct comparison with continuous-operation nuclear or hydrocarbons-burning (i.e. coal and natural gas) power stations. Both the latter produce ‘greenhouse’ exhaust gases (especially CO2) and both now require substantial fuel imports to the UK.

It has also been recognised that the shallower waters of the Inner Sound would be a likely ‘proving ground’ for tidal stream generation devices (for perhaps up to five years), prior to deeper-water deployment in the Pentland Firth and worldwide later. [There is a useful parallel here with offshore oil & gas platforms; those began in the shallow waters of the Gulf of Mexico, moved on to waters of 150 metre depth in the North Sea, while now deepwater sub-sea reservoirs with an water-column of 1,000 metres of more are being tapped (off West Africa, Brazil and outer Gulf of Mexico, as well as Atlantic Frontier reserves on the UKCS , are being tapped].

If reasonable access to the Inner Sound was to be denied by its classification as Special Protection Area, (this would be interpreted by potential international utility developers as a ‘no-go’ Nature Reserve) this would prevent interested persons in Caithness the from opportunity of employment within easy daily travelling distance of a pioneering tidal stream site.

There is also a possibility that such a an Inner Sound restriction could increase the risk of human accidents when it came to deeper water deployment in the deeper, more hostile, waters of the Pentland Firth and elsewhere later.

Public-sector jobs agency Highland and Islands Enterprise and the Scottish Government jointly appointed a consultancy, on the recommendation of the Pentland Firth Tidal Energy Project, in September 2008, to research option available to supply large quantities of Pentland Firth electricity to major markets via the UK National Grid.

They are also investigating ‘in situ’ use of large quantities of renewable electricity locally for energy-intensive users, with the example of Iceland being well-known locally with much of their serviving being by vessels plying the Pentland Firth.

There are now approximately two dozen full-time equivalent jobs involved in tidal stream research and development work in Caithness, including developers of at least two generating device designs. The Pentland Firth Project has hosted, using taxpayers’ money, several visits by groups of interested engineers/renewables utility promoters during 2008, including a device developer aiming to manufacture marine-energy generating sets in nearby Wick, Caithness.

In August 2008, ScottishPower Renewables ( a trading arm of Iberdrola Renovables of Bilbao, Spain, Europe’s largest ‘green energy’ generator) officially informed Scottish Ministers (a ‘scoping’ document) that it hopes to deploy a UK ‘Demonstration Tidal Array’ of between 10 MW to 20 MW and had chosen the Pentland Firth as its preferred locus.

The final pick is between the Inner Sound (Stroma to Canisbay Parish) or the seabed off South Ronaldsay, Orkney. It plans to use Norwegian tidal stream technology (at 300 kW scale at present) likely to be ‘honed’ and manufactured in Scotland. It hopes that installation of one unit on the seabed could be done within two years.

The local Community Council’s office-bearers are aware of several other developers, interested in Pentland Firth marine electricity generation, who have chosen not to ‘go public’ so far.

As yet, there is no single device that has gained general acceptance as being superior; the first 1 MW Anglo-Scottish designed tidal generator is due to be deployed off Korea in 2009.

It was only during 2007/08, that device developers broadly agreed that sea-bed mounted structures, giving c. 20 metres clearance from the sea-surface in the Firth’s shipping lane, will be the way forward. (this, for example, would rule out devices of the sort deployed presently in Strangford Lough, Ireland, as that device is piled to the sea-bed via a steel structure that pokes above sea-level)

Both the UK and Scottish Government wish to see a significant-scale new industry, based on marine renewable electricity generation, getting under way with a start in home waters and then able to compete in international markets.

A wide range of official consents/permits will be necessary before any generating device(s) is deployed in the Pentland Firth (or elsewhere).

Perhaps the most important of those is the very proper necessity for a thorough Environmental Impact Assessment to be undertaken.

Scottish Natural Heritage is a statutory consultation body in this process and its officers will thus have a natural sciences input into each and every tidal stream generating proposal. This should be sufficient to protect its interests, which can then be properly balanced against others, without creating a SPA here; one which offers no enhancement to local sea-bird colonies.

As with deeper water oil & gas exploration on the UKCS, it is likely that large amounts of scientific data relating to wildlife, water-movements etc. will be collected as part of the appraisal of Pentland Firth as a major source of electricity generation; perhaps arrangements should be sought/ put in place with developers to ensure SHN’s staff gain access to such raw data/samples for on-going scientific work/interpretation.

The UK Government is a signatory to the UN’s Kyoto Treaty and will hopefully play in prominent part in negotiating a successor ‘accord’ to further reduce CO2 emissions worldwide in the 21st Century’s second and third decade.

I have read suggestions that as many as 20% to 30% of the world known natural species could become extinct in the 21st century, if worldwide carbon emissions and the resultant global warming increases at the rate of the past two decades.

Scottish Natural Heritage exists to advise Government Ministers about protecting, cherishing, and if possible enhancing (as with the recent reintroduction of the sea-eagle to Scotland) the nation’s wildlife.

It would therefore be ironic indeed if this North Caithness Cliffs SPA were to be granted. There is no scientific proof of any advantage this would bring to existing sea-bird colonies on the Pentland Firth sea-bird colonies.

But such a Pentland Firth designation would be certain to deter investors and make the successful tapping of the Country’s single largest renewable electricity generating source more difficult, if not impossible.

This would leave SNH as an undoubted party to enhancing global warming, with its resultant forecast large-scale species extinction.

For the above reasons I would urge (a) the Scottish Natural Heritage withdraw the present proposal pending the outcome of negotiations with the interested national and international agencies (as above).

If they do not, then Ministers should refuse the application on the grounds that it conflicts with UK/Scottish Government agreement with current international obligations (as above) and with targets set to minimise future CO2 emissions.

18.09.08

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