Scottish Seabird Centre objects to 'highly damaging' Berwick Bank plan

Boasting as many as 307 wind turbines, the SSE Renewables wind farm is expected to create enough energy to power Scotland’s homes twice over.

However, with the site lying 47.6 km offshore of the East Lothian coastline and 37.8 km from the Scottish Borders coastline at St Abbs, it could harm internationally important breeding seabird colonies, the SSC warned. 

READ MORE: This could soon be biggest offshore wind farm in the world - and it's off Scotland

The Firth of Forth is home to Bass Rock which supports the world’s largest colony of northern gannets but also forms an important seabird migration route. 

Particular concerns were raised about black-legged kittiwakes, common guillemots, razorbills and Atlantic puffins.

Chief executive of the centre Susan Davies said a site further offshore would be less damaging to the wildlife. 

“Climate change is one of the most pressing issues that needs addressed today and marine renewables are an essential strand of the plan to reduce our reliance on fossil fuels for energy and to achieve net-zero," she said.

"However, we are also facing a nature crisis and we must ensure that green energy is secured in ways which do not contribute further to nature loss."

The proposal overlaps with the Outer Firth of Forth and St Andrews Bay Complex Special Protection Area.

Ms Davies added: "Rather than find a less damaging location, for example further offshore, for their development, SSE Renewables have forged ahead with their proposals.

"This flies in the face of all their environmental data pointing to this being one of the most damaging places to site an offshore windfarm in Scotland – both directly and in combination with other developments already consented.

"The evidence presented by the developer predicts that the development will lead to significant annual adult mortality losses of black-legged kittiwakes, common guillemots, razorbills and Atlantic puffin.”

READ MORE: Offshore wind farms: Are we combatting climate change at the expense of our wildlife?

Kittiwakes (Image: Susan Davies)

In 2022, the prospective wind farm was forced to reduce the massive area it encompassed to, among other factors, reduce its expected impact on seabirds in the area.  

However, as it stands the structure will still occupy land spanning across 845 sq km.  

The SSC called for the Crown Estate Scotland’s ScotWind leasing process to be overhauled as the framework is "leading business directly into conflict in areas that are already clearly environmentally constrained".

Chair of the organisation Stuart Housden said: "The leasing process for the seabed for marine renewable developments needs to be overhauled and be better informed by a strategic assessment of the environmental capacity that exists.

"It makes no sense to offer leases in areas that are clearly environmentally constrained at a time when nature is in crisis."

As part of their proposal, developers also propose a strategic compensation measure of closing the sandeel fisheries - a decision which lies with the Scottish Government.

Many seabirds have been suffering due to a decline of sandeels through climate change and overfishing but the SSC claimed the policy was a "smokescreen". 

Mr Housden said: “Better spatial management of fisheries, at levels that are sustainable and allow stocks to recover, is supported by the Scottish Seabird Centre as it brings benefits for our coastal communities reliant on fishing for their livelihoods and for nature.

"Sandeel fishery closure is however a strategic policy decision and should not be used as a smokescreen for consenting a development that is highly damaging to many seabirds at a population level.”

“Other compensatory measures proposed including small scale biosecurity action in the north-west of Scotland and kittiwake cliff ledges and a warden at Dunbar castle, illustrate just how tokenistic some of SSE Renewable’s compensation proposals are.”

The National Trust for Scotland, RSPB Scotland and Members of the Scottish Environment Link Marine Task Force have also recently lodged objections with Marine Scotland.

The charity says it stands ready to continue working with marine renewable developers to try to ensure that developments do not cause environmental harm.

Alex Meredith, SSE Renewables’ Berwick Bank project director, said: “We are aware of the Scottish Seabird Centre’s comments and views on our proposals, and whilst we understandably disagree with their position on Berwick Bank Wind Farm, we are grateful for the lengthy and meaningful engagement we have had to date.

“The offshore wind industry is absolutely critical to ensuring we prevent the worst possible impacts of climate change, which is arguably the biggest single danger to Scottish seabirds.

"Projects at the scale and ambition of Berwick Bank, can ensure Scotland is a world leader in offshore wind, but we must avoid delay and we must seek to deliver for both climate and nature. This should not be a trade-off." 

The project director emphasised that a number of planning decisions have been made specifically to protect wildlife. 

He added: “The Berwick Bank site was awarded to SSE in 2012. The location of the site has therefore been known for over a decade and to suggest we deliver this project somewhere else is not a realistic proposal.  

"What we have sought to achieve through the meticulous work we have undertaken over the last ten years has been developing Berwick Bank as a world leading renewable energy Project, not only in its scale but in its environmentally sensitive design and nature positive compensation measures.  

“In particular, following consultation with key stakeholder bodies, such as the RSPB and Scottish Seabird Centre, we have amended our designs to reduce as much as possible any potential risks to Scottish seabirds. This includes reducing our overall offshore area by approximately one-third and increasing the overall height of our turbines to provide an additional gap to help seabirds - particularly Kittiwake - navigate our site, this is in addition to our turbines being spaced a minimum of 1km apart. Our modelling following these changes showed a dramatic improvement in terms of minimising risk to seabirds.

“Where our models forecast potential effects on seabird populations, we have proposed strategic measures to allow those colonies to thrive. Specifically, we have shown that if we can secure the closure of sandeel fisheries in UK waters as part of the Berwick Bank approval (a move advocated for recently by Sir David Attenborough) not only can we deliver Berwick Bank, but we could also see the population of various species of Scottish seabirds increase by many thousands. It is a huge potential win-win for the climate and nature.

“We have advocated for these closures and are ready to go with implementing and monitoring these plans, but we need Scottish Government support to make this happen.

“Berwick Bank Wind Farm provides a unique opportunity to make a significant positive impact to both the nature and climate crises we are all facing. We have been working on this site for over a decade and the result is a world-leading project. We have submitted our planning application and whilst we will always continue to work constructively with stakeholders we want to now move forward urgently with action and delivery for the climate and our iconic Scottish seabirds.”