Case studies of EIA in practice - Introduction to Environmental Impact Assessment - page 296

9.8.5 Issues raised in consultation responses
The environmental report produced at the end of the SEA process was subject to a short
period of consultation. An analysis of the consultation responses reveals a number of key
issues that were raised by interested stakeholders. These include a range of concerns
about the quality and effectiveness of the SEA process, and its influence on decisions for
the next phase of wind energy developments. Many of these concerns arose from the tight
timescale for the SEA work and the resulting practical difficulties encountered. The main
points raised in consultation are highlighted briefly below (a fuller discussion can be
found in DTI (2003b)). Many of the issues raised are interlinked; for example,
weaknesses in baseline data may be due to limited consultation or a tight timescale in
which to complete the SEA.
• Pre-selection of the three strategic areas, and lack of a national-level SEA. The three
strategic areas in which Round 2 development was to be focused were selected as
having the greatest development potential, based on the potential wind resource
available, the bathymetry of the offshore area, proximity to existing grid connections
and initial expressions of interest from developers (DTI 2003b). However, the
selection did not appear to take explicit account of environmental constraints, and this
was a cause of concern to a number of respondents.
• The tight timescale for the SEA and uncertainty over the influence of the SEA process
on decision-making for future developments. The timescale for the SEA was
considered too tight to allow effective stakeholder engagement and consultation, or to
allow additional baseline data to be collected. The fact that developer bids for Round 2
sites were invited before the completion of the SEA Environmental Report was also a
source of concern.
• Concern over the rapid development of offshore wind energy, prior to the proper
consideration of potential impacts. Some respondents argued that the development of
the offshore wind energy industry was too rapid and premature; greater efforts should
be made to understand the impacts of the smaller Round 1 developments before
allowing large-scale expansion of the industry.
• The need for clearer locational guidance. There was felt to be a need for clearer
recommendations on suitable and unsuitable locations for future offshore wind energy
development (including the definition of exclusion zones or “no-go” areas), and it was
considered that these had not emerged sufficiently from the SEA process.
• Concerns about the scope and methodology of the SEA. Most respondents were
supportive of the overall methodology of the SEA, including the risk-based approach
to the assessment of impact significance, but there was some disagreement over the
detailed scores awarded to specific receptors or geographical areas.
• Weaknesses in the available baseline data. A recurrent theme in the consultation
responses was limitations in the baseline data available to the SEA study. This
included missing data for certain important environmental constraints (which could
not be mapped) and areas in which the data used in the SEA was not the most accurate
or appropriate. Some respondents thought that these data limitations were sufficiently
serious as to invalidate the identification of areas of high and low constraints in the
SEA. Data gaps and uncertainties about impacts also led respondents to urge a