Berwick Bank Offshore Windfarm
An application for a 4.1GW offshore windfarm off the East Lothian and Fife Coast threatens some of our most important sites for seabirds.
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We need to move to low carbon energy rapidly to tackle climate change – itself a major threat to wildlife. RSPB Scotland however strongly believe we must achieve this transition in harmony with nature. This means putting renewable technology in the right places, rigorously assessing potential impacts, and monitoring the ongoing impacts of consented development so we can learn for the future.
Berwick Bank offshore wind farm is proposed to be located in a highly important area for wildlife, especially seabirds. Consequently, it is predicted to have severe impacts – the Applicant predicts adult annual mortality of thousands of Guillemots, hundreds of Kittiwakes and scores of Razorbills and Puffins. The magnitude of these impacts is so significant it could likely hinder the conservation of sites designated to protect these species. Because of this, it may only be permitted as an exception to the Habitats Regulations, and we do not consider the legal requirements for this to happen have been met.
Overall, we do not believe it is the right location for an offshore wind farm and consider other less damaging locations that would meet the same project objectives are likely available.
Why is it worth fighting for?
The Forth and Tay area is home to a fantastic abundance of wildlife. The area includes the world’s largest Northern Gannet colony at Bass Rock; Kittiwake colonies at Fowlsheugh to the north and St Abbs to the south; and Gannet, Kittiwake, Puffin, Guillemot, and Razorbill colonies on the Isle of May and other Forth Islands.
These populations make this region one of the best places in the UK for seabirds and it is duly protected by a wealth of nature conservation designations including national Sites of Special Scientific Interest (SSSI) and international Special Protection Areas (SPA) under the European Birds Directive. This development threatens species and protected sites.
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Our position
RSPB recognise that climate change is the greatest threat to nature and support the transition to renewable energy to help reduce greenhouse emissions. We consider that offshore wind has a part to play in a just transition away from Scotland’s dependence on fossil fuels. We support the principle of the development and agree that renewable electricity generation offshore has strong policy support.
The proposed development array area is 2km from the boundary of the Outer Firth of Forth and St Andrews Bay Complex Special Protection Area (SPA). This is one of the most diverse marine bird concentrations in Scotland and, during the breeding season, provides feeding grounds for a large assemblage of over 100,000 seabirds. It is also within foraging range of SPAs designated for their importance to breeding Northern Gannets (Morus bassanus), Atlantic Puffins (Fratercula arctica), Black-legged Kittiwakes (Rissa tridactyla), Razorbills (Alca torda) and Common Guillemots (Uria aalge). This includes the Forth Islands SPA (the location of Bass Rock – the largest gannetry in the world), Fowlsheugh SPA, and St. Abbs to Fast Castle SPA. SPAs are internationally important sites for birds and so subject to the highest level of protection.
As identified by the Applicant, the proposed array area itself contains important spawning and nursery habitat for sandeel and other forage fish species. Sandeel are a key prey species for several seabird species (including Puffin, Kittiwake, Razorbill and Guillemot) and large numbers of these species have been identified within the proposed development array area especially during the breeding season by the Applicant’s site surveys.
Offshore wind development located in significant and highly sensitive areas can have substantial adverse impacts on the natural environment, partially seabirds. Seabirds are relatively long-lived, and as a result, their populations are sensitive to small increases in adult mortality. Their survival and productivity rates can be impacted by offshore windfarms directly (i.e. collision) and indirectly (e.g. displacement from foraging areas and having to use more energy to reach feeding grounds). They are also already under severe pressure. Between 1986 to 2019 according to the Scottish biodiversity indicator the number of breeding seabirds in Scotland has declined by 49%. On top of this, seabirds have also been impacted by Highly Pathogenic Avian Influenza (HPAI) outbreaks. At some seabird colonies, such as the Northern Gannets at Bass Rock, this virus decimated breeding attempts in 2022.
The predicted impacts of Berwick Bank Offshore Wind Farm are extremely large. For Puffin at the Forth Islands SPA, in combination with other North Sea windfarms, after the 35-year lifetime the development, the population size of the SPA is expected to be between 7.4 and 12% lower that it would have been in the absence of the development. For Kittiwakes at St Abbs, after the life time of the development, the size of the SPA population is expected to be between 59 and 65.9 % lower than it would be in the absence of the development.
When the impacts are allocated to SPA seabird colonies, the Applicant has identified that could result in an adverse effect on site integrity (AEoSI) at eight SPAs for Kittiwake, Guillemot, Puffin and Razorbill. We welcome this recognition, but we are mindful of the state of Scottish seabirds and the pressures they already face. These predicted SPA colony size as percentages in absence of the development do not account for secondary impacts from building on sandeel habitat and are additional to existing population declines and events such as HPAI. Kittiwake and Puffin are also red listed in the Birds of Conservation Concern and have been assessed as vulnerable to global extinction. Following analysis of the recommended approach, we consider potential for AEoSI cannot be excluded for Kittiwake, Gannet, Razorbill, Guillemot and Puffin at twelve SPAs.
An AEoSI means potential effects from the development that are also likely to prevent the achievement of an SPA’s conservation objectives and cannot be mitigated. These international sites are the most important sites for wildlife. They are legally required to be conserved and if necessary restored to favourable conservation status.
Under the Habitats Regulations, a project that would result in AEoSI cannot be permitted unless it can be demonstrated there are no less damaging alternative solutions, there are imperative reasons of overriding public interest (IROPI) for the project to go ahead, and ecological compensation to maintain the coherence of the UK/National Sites Network for the affected species can be secured.
Following a review of the application, RSPB Scotland do not consider the search for alternative solutions performed by the Applicant is adequate. It has dismissed Scotwind sites without proper assessment of whether they would meet the same objective as the proposed development and whether they would be less harmful.
We also do not believe that the proposed compensation measures are sufficient. There are evidence gaps around the colony compensation measures in terms of the species targeted, the feasibility of their implementation and their effectiveness. The proposed fisheries compensation measure to limit sandeel fishing are also problematic. The sandeel fisheries were closed in March 2024, a measure that we greatly welcomed. We view it as a vital mechanism to build resilience in seabird populations in the face of mounting pressure from food web disruption, offshore renewable energy development and HPAI. We do not consider it a mechanism to compensate for an additional pressure.
We were dismayed by the EU’s decision to trigger an arbitration process to seek some form of continued access to the sandeel fisheries. Katie-jo Luxton, the RSPB's director of conservation, said: “The EU’s decision to trigger an arbitration process over the UK’s sandeel fisheries closure flies in the face of its commitment to protect and restore marine ecosystems. It is a scandalous attempt to reverse a hard-won victory for under-pressure seabirds like Puffins and Kittiwakes, as well as the many other marine species that depend on sandeels.”
“We have seen devastating declines in seabird populations. Only last month, five new species were added to the UK Red list of highest conservation concern. Stealing the food from their mouths will not build resilience against the many pressures they face and the UK government must remain resolute in defence of these closures.”
Although the Applicant holds a lease to allow it to develop a windfarm at this location, RSPB Scotland do not believe this is the right location for this type of development. We recognise there is a need for renewable energy and have sympathy with the Applicant’s position. They have invested large resources, both time and financial, into thoroughly assessing modelling impacts. We greatly appreciate the work they have done to understand the site. This unfortunately does not however make the impacts acceptable.
Overall, it is a highly sensitive area in which to place a windfarm. Inevitably the magnitude of the predicted impacts reflects this. The sediments and other environmental aspects that make an area of sea a good nursery and spawning area for fish and foraging area for seabirds cannot be relocated. It is also not possible to relocate seabird breeding colonies. It is however possible to put an offshore windfarm development in a different location and there are alternative sites available where the same objective of this application would be met. We therefore must stand up for nature and object to the proposed development.
Timeline
November 2024 – The application is still under consideration.
End of October 2024 – The EU decided to request the establishment of an arbitration tribunal under the dispute settlement mechanism of the EU–UK Trade and Cooperation Agreement (TCA) concerning the United Kingdom’s decision to prohibit the fishing of sandeel.
March 2024 – The prohibition of the fishing of sandeel in the English waters of the North Sea and in all Scottish waters prevents EU vessels from operating this unsustainable fishery.
March 2024 – With partner organisations the National Trust for Scotland, the Scottish Seabird Centre, and the Scottish Wildlife Trust, RSPB Scotland writes to Gillian Martin MSP, urging the Scottish Government to reject the application - read the letter here - and watch a short film here.
November 2023 – RSPB Scotland respond to additional information submitted by applicant, maintaining our objection.
March 2023 – RSPB Scotland Object to the application.
January 2023 – The application for Berwick Bank Offshore Windfarm is submitted to Marine Scotland Licensing.
Further reading
Other useful websites
Application documentation is available here: Section 36 Consent - Berwick Bank Offshore Wind Farm - Firth of Forth | Marine Scotland Information
Scottish Environment Link Response: LINK response to Berwick Bank Offshore Wind Farm proposal - Scotlink
RSPB response to EU triggering an arbitration process: EU triggers arbitration process over UK’s sandeel fisheries closure