Memorandum submitted by the Royal Society
for the Protection of Birds
EXECUTIVE SUMMARY
The challenge of climate change demands nothing
short of a revolution in the way we use and generate energy. It
is clear that we will need to end our dependency on fossil fuels,
massively reduce the amount of energy we use and deliver environmentally
sustainable renewable energy. We want this revolution to take
place in harmony with the natural environment. The RSPB has argued
that the natural environment is not sacrificed in pursuit of wider
public policy objectives. This is the context for debates about
future exploration of offshore oil and gas.
The main concerns associated with oil and gas
developments with respect to seabirds, and other wildlife are
disturbance, displacement from habitat or food resources, risks
from oil spill, both major and minor from both the exploitation
infrastructure and the associated shipping, and especially the
cumulative effects of these, either separately or in combination.
Damage to wildlife can be minimised by:
— Investing in sustained environmental
surveys of marine wildlife, including seabirds. Impacts on seabirds,
and the marine environment more generally, can be minimised by
financing the surveys required to fill the gaps that have been
identified in previous offshore Strategic Environmental Assessments
and studies. The data collected can help to guide development
to those areas of least risk and inform selection of a network
of marine protected areas.
— Designating a comprehensive marine
protected areas network. The absence of a network of Marine Protected
Areas (MPAs) is not only bad news for wildlife, but also risks
undermining investor confidence in energy infrastructure projects.
Energy developers want clarity about the most sensitive locations.
This is why it is in everyone's interest to deliver a network
of MPAs as soon as possible. Certainty regarding the location
of important sites for marine wildlife will aid decision-making
process on marine projects for offshore energy, such as oil and
gas and marine renewables.
— Using environmental assessment tools
more effectively. Offshore energy Strategic Environmental Assessment
(SEA) and Environmental Impact Assessment (EIA) processes offer
an opportunity to collect more data. However, despite data collation
and collection through previous SEAs 1-8, there are still significant
information gaps, especially for seabirds at sea. Although SEA
and EIA of offshore oil and gas developments and plans is improving,
these assessment tools are still falling short of their potential.
Future strategic assessments of offshore oil and gas licensing
plans could be improved by i) considering an appropriate and wide
range of reasonable alternatives, ii) focusing on evaluating cumulative
effects, and iii) applying the precautionary principle. Strategic
assessments should also, where possible, consider spatial alternatives.
— Careful consideration of whether
to unlock resources west of Shetland. Unlocking these resources
could have potentially adverse effects on Scotland's marine environment.
We recommend that certain sensitive areas are excluded for future
rounds of oil and gas licensing, including the area around St
Kilda and the Hebrides. We would also recommend a buffer zone
around these areas to ensure that feeding seabirds are adequately
protected. The area west of Shetland has significant data gaps,
and available data on seabirds is old and limited in geographic
and seasonal scope.
The future role of oil and gas in the UK's energy
policy
1. The RSPB believes that climate change
is the greatest threat we face and that unless action is taken
to reduce greenhouse gas emissions, one third of all land based
species may be committed towards extinction by 2050. We have welcomed
the UK Government's plans to cut emissions by 80% by 2050 and
we support the Government's pledge to deliver the UK's share of
the EU renewable energy target for 2020.
2. The Government's Renewable Energy Strategy
has proposed that, to contribute its fair share to the target,
it will seek to generate 15% of its energy (and up to 40% of electricity)
from renewable sources. This will require a revolution in the
way that we generate and use energy. To meet these targets, research
we have undertaken with others (The 80% Challenge—Delivering
a low-carbon UK by IPPR, WWF and RSPB) suggests that much
more effort needs to be invested in reducing the amount of energy
we use, in stabilising aviation emissions and decarbonising the
electricity sector.
3. The contribution that the UK's remaining
oil and gas reserves should make to the UK's future energy needs
must be considered in this context.
What can be done to minimise the environmental
impact of exploiting the reserves
4. Inappropriately designed and/or sited
energy projects, including oil and gas developments, can seriously
damage biodiversity. Such damage is not inevitable, and we believe
policies should be designed, and safeguards put in place, so that
damage to wildlife can be minimised. Our experience of working
successfully with renewable energy developers, such as the London
Array Ltd in the Thames Estuary, demonstrates that energy developments
which avoid unnecessary conflicts are achievable.
ADDRESS ENVIRONMENTAL
DATA GAPS
AND DESIGNATE
A COMPREHENSIVE
MARINE PROTECTED
AREAS NETWORK
5. Any environmental database used to assess
the likely effects of offshore oil and gas developments should
be adequate to ensure that these developments are sited in the
least sensitive locations. The RSPB is concerned that there are
currently significant gaps in our knowledge of the marine environment.
We need to understand the risks of offshore oil and gas developments
to particular species and areas and identify the key knowledge
gaps.
6. Offshore energy Strategic Environmental
Assessment (SEA) and Environmental Impact Assessment (EIA) processes
offer an opportunity to collect more data. However, despite data
collation and collection through previous SEAs 1-8, there are
still significant information gaps, especially for seabirds at
sea. Now that these data gaps have been verified, the next step
is to fill them—this will necessitate new data collection.
7. These information gaps may limit a comprehensive
assessment of the potential effects of further oil and gas licensing
on sensitive marine species and habitats in UK waters. The RSPB
believes that the knowledge gaps are so significant, that assessments
of oil and gas licensing, e.g. most recently in the UK Offshore
Energy Plan SEA, may fall short of predicting the magnitude and
cumulative nature of these potential effects. Investment in data
collation and collection is therefore essential.
8. The absence of a network of Marine Protected
Areas is a further level of uncertainty regarding the impacts
of oil and gas exploitation on marine species and habitats. Uncertainty
due to lack of knowledge is one of the elements that leads to
delay in licensing not only oil and gas but other energy projects
at sea. This requires a step-change in the approach taken towards
resourcing the survey, identification and designation of these
sites.
9. Furthermore, we also need comprehensive
legislation to provide an effective framework for the designation
and management of Marine Protected Areas (MPAs), including Natura
2000 sites. The RSPB is advocating strong legislative provisions
for the designation of marine conservation zones (MCZs) in the
Marine & Coastal Access Bill (and equivalent Scottish Marine
Bill). Certainty regarding the location of important sites for
marine wildlife will aid decision-making process on marine projects
for offshore energy, such as oil and gas and marine renewables.
MINIMISE IMPACTS
ON SEABIRDS
BY FINANCING
THE SURVEYS
REQUIRED TO
FILL DATA
GAPS
10. The UK is of outstanding international
importance for its breeding seabirds, notably Manx shearwater,
northern gannet, great skua and lesser black-backed gull. Yet,
oil and gas developments may cause problems for colonial breeding
seabirds, non-breeding seabirds and waterbirds at sea. The main
concerns associated with oil and gas developments are disturbance
displacement from habitat or food resources, risks from oil spill,
both major and minor from both the exploitation infrastructure
and the associated shipping, and especially the cumulative effects
of these, either separately or in combination.
11. Impacts on seabirds, and the marine
environment more generally, can be minimised by financing the
surveys required to fill the gaps that have been identified in
previous offshore SEAs and studies. The data collected will have
the added value of supporting the faster delivery of a network
of MPAs, and be useful for wind leasing assessments. It is possible,
and fitting, for the Department of Energy and Climate Change to
work with Defra to invest in developing the knowledge base and
so accelerate the designation process through financial support
and prioritisation of systematic environmental surveys at sea.
We believe that it would be appropriate to also detail how any
such data gathering would be integrated with other databases to
progress the designation of MPAs and facilitate the role out of
offshore wind electricity generation.
12. In particular, we need:
(i) comprehensive baseline seabird data collection
in potential development zones, using a combination of aerial
and ship-based surveys using recommended methods. A minimum of
two years preconstruction data collection is required for potential
development zones.
(ii) a systematic survey programme to plug gaps
in spatial and temporal coverage and provide updated contextual
information for UK Continental Shelf waters. This should include
sample re-surveys of areas covered by European Seabirds at Sea
(ESAS), to determine whether broad patterns of distribution and
abundance remain unchanged or whether there have been changes
that cast doubt on the value of older data for identifying marine
Special Protection Areas (SPAs) under the Birds Directive or areas
of potential greater sensitivity for oil and gas developments.
(iii) further research into foraging ranges and
areas used by priority species relevant to each development zone,
making use of developing technology such as data loggers and habitat
suitability modelling (also relevant to SPA identification).
(iv) Note: baseline data for other marine species
and habitats is also required.
13. A Geographic Information System atlas
of bird distribution and abundance, pulling together all available
information, would be an extremely useful component of a constraints
assessment for offshore energy, whilst also enabling information
gaps to be identified (thereby updating the (then) DTI's seabird
gaps analysis by Pollock & Barton 2006[14]).
Inclusion of down-weighted ESAS data where older than say 10 years
would be advisable.
14. The RSPB has reviewed the likely impacts
of wind farms on seabirds and waterbirds in UK waters. We have
also identified those bird species which are most likely to be
priorities for data collation and collection as part of the Round
3 SEA and subsequent individual project Environmental Impact Assessments,
particularly in the areas mapped by the Crown Estate as potential
development zones. Some of this review may also be applicable
to offshore oil and gas developments.
15. We note that where offshore seabird
data collection has been more intensively conducted, this has
yielded some significant results, such as the discovery of the
extent of the Liverpool Bay common scoter population.
USE ENVIRONMENTAL
ASSESSMENT TOOLS
MORE EFFECTIVELY
TO MINIMISE
ENVIRONMENTAL IMPACTS
16. Environmental assessment tools, such
as SEA and EIA, are key to minimising the environmental impacts
of oil and gas developments. In the absence of an MPA network
including marine Natura 2000 sites, these assessment tools are
also the main processes through which marine environmental data
is collected.
17. Strategic Environmental Assessment (SEA)
in particular is a key tool for integrating environmental considerations
into the planning and decision-making process, thereby enabling
the impacts of development on wildlife to be avoided, or at least
minimised. It evaluates the significant environmental effects
of development proposals and reasonable alternatives to them,
so that the most environmentally damaging proposals can be eliminated
early on before significant resources have been invested in working
them up through the design stages. Where preferred alternatives
are likely to have negative effects, SEA can identify how these
can be reduced and positive outcomes enhanced to benefit biodiversity.
18. Because SEA is strategic, it provides
decision-makers with the information they need to license the
least environmental sensitive areas for oil and gas developments.
This is something that project-level EIA cannot do because it
begins when developers are already seeking consent for specific
areas. Any plan to exploit remaining oil and gas reserves should
be subject to SEA, and if it is likely to affect a Natura 2000
site, appropriate assessment (AA).
19. Although SEA and EIA of offshore oil
and gas developments and plans is improving, these assessment
tools are still falling short of their potential. Future strategic
assessments of offshore oil and gas licensing plans could be improved
by i) considering an appropriate and wide range of reasonable
alternatives, ii) focusing on evaluating cumulative effects, and
iii) applying the precautionary principle. Strategic assessments
should also, where possible, consider spatial alternatives. Environmental
Impact Assessments further down the line should take on board
the conclusions of strategic assessments, as well as any recommended
mitigation and monitoring measures.
20. There could be potential conflicts between
the oil and gas licensing applications and our as yet incomplete
MPA network, including both marine Natura 2000 sites (European
Marine Sites) and the forthcoming MCZs network (required to fulfil
Government's obligations under OSPAR). Applying appropriate assessment
at plan and project levels is central to avoiding conflicts between
the oil and the future offshore Natura 2000 network. Prior to
licensing areas that include proposed and existing European Marine
Sites, an appropriate assessment must be carried out. Licensing
should proceed only if the appropriate assessment concludes that
there will be no adverse affect on these sites. We also recommend
an energy licensing policy that avoids damage to areas that include
features meeting protected status criteria, particularly where
no sites have been designated for a particular feature yet and/
or the network is not complete.
What steps need to be taken to unlock resources
west of Shetland
21. Unlocking resources west of Shetland
could have potentially adverse effects on Scotland's marine environment.
In particular, the cumulative effects of oil and gas activities
with non-oil and gas activities could be significant. We recommend
that certain sensitive areas are excluded for future rounds of
oil and gas licensing, including the area around St Kilda and
the Hebrides. We would also recommend a buffer zone around these
areas to ensure that feeding seabirds are adequately protected.
In addition, important seamounts that have been mapped within
14 degrees west should also be excluded, e.g. Anton Dorn and Hebrides
Terrace Seamounts.
22. The area west of Shetland has significant
data gaps. The data on seabirds is old and limited in geographic
and seasonal scope. The seabirds at sea data was collected opportunistically
onboard petroleum industry vessels, and therefore focuses on locations
of interest for the industry, rather than systematic seabird surveys.
Furthermore, seasonal weather conditions also restrict the coverage
of the European Seabirds at Sea database.
23. The risk assessments carried out west
of Shetland will need to be rigorous and must fully consider the
much more extreme nature of this environment, compared with the
bulk of industry experience in the North Sea. These risk assessments
should include the modelling and assessment of the effects of
oil spills on seabirds and their associated colonies.
24. The supply chain from petroleum resources
west of Shetland to the nearest coastal depot will be a long one.
Therefore, focusing on the most environmentally and carbon friendly
methods of exploiting the reserves and maintaining the infrastructure
will be important.
March 2009
14 Pollock, C. & Barton, C. 2006. An analysis of
ESAS seabird surveys in UK waters to highlight gaps in coverage.
Report to the DTI by Cork Ecology Back
| 
