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22 May 2023

Why we’re objecting to the Berwick Bank windfarm

Written by Rebecca Millar
A group of razorbills (that look a little like thin penguins!) sit on a rock, with the sea in the background.
Berwick Bank windfarm is expected to reduce the seabird population – including razorbills – by 40,606 birds over the course of 20 years.
Whilst supportive of offshore wind generation, we believe it must be sited in the right places. Given the probable impact on seabirds, a proposed windfarm off St Abb’s Head is not in the right place.

When we launched our 10-year Nature, Beauty & Heritage for Everyone strategy in 2022, we committed to speak up for heritage that doesn’t have a voice. We have put that commitment into practice in our recent objection to a proposed windfarm at Berwick Bank, off Scotland’s east coast.

SSE Renewables, the developer, have predicted a far higher seabird mortality for the Berwick Bank windfarm than for other UK windfarms, where the impacts are already considered to be high. As an example, kittiwake mortalities are predicted to be seven times higher than those predicted for the Hornsea Three windfarm. With seabirds around the coast of Britain already facing grave threats, such as avian flu and dwindling food sources, it’s unacceptable to place additional pressures on the colonies likely to be impacted by Berwick Bank.

Our objection to this proposal certainly doesn’t mean that the National Trust for Scotland is opposed to offshore wind energy generation. The planet is in a climate crisis, and we must all take action to reverse this, including investing in renewable energy generation. Our charity has already supported renewable energy generation schemes on Canna and Fair Isle; more widely, we support Scottish Government commitments to offshore wind energy generation.

However, climate action should not come at the expense of our natural heritage. Support for offshore wind generation – from society, government, industry and others – should be in tandem with protecting the natural environment. This belief underpins our objection to SSE Renewable’s proposal to build the Berwick Bank offshore windfarm off the East Lothian coast. The proposal was submitted to Marine Scotland (the body responsible for assessing applications) in April 2023. Marine Scotland is currently assessing the application and representations made by third parties. Our objection was supported by the National Trust.

Alongside other organisations, including Scottish Environment LINK, the Scottish Seabird Centre and the RSPB, we are concerned that the location of the offshore windfarm at Berwick Bank would cause severe environmental damage. We are calling for SSE Renewables to look at other sites where the impact on marine life will be lower and where effective compensation measures can be delivered to mitigate any environmental damage.

Read the full objection

White waves crash into the rocks along a rugged coastline.

As stated above, one of our primary concerns is the impact on seabirds, including those that nest at St Abb’s Head National Nature Reserve, one of the special places in our care. St Abb’s Head NNR is home to internationally important seabird colonies, including guillemots, kittiwakes, razorbills and shags. The proposed development will also affect the internationally protected Outer Firth of Forth and St Andrews Bay Complex Special Protection Area (designated for the protection of 21 seabird and waterbird species), as well as the Farne Islands Special Protection Area. The latter is managed by the National Trust.

There are over 1 million seabirds at places in the care of the National Trust for Scotland, and we take extremely seriously our responsibility to protect them and help them flourish. After two years of avian flu and with ever-decreasing food sources, the UK’s seabirds are already in a precarious state; colonies could be devastated if they are faced with additional pressures. Offshore windfarms can increase seabird mortality in a number of ways, including collision with turbines, cutting off foraging grounds, and through the displacement of migration routes and nesting grounds. In total, across all the Special Protection Areas analysed by the application, Berwick Bank is expected to reduce the seabird population by 40,606 seabirds – chiefly made up of puffins, kittiwakes, guillemots and razorbills – over the course of 20 years.

These predicted seabird mortalities at Berwick Bank are very high, certainly higher than other offshore windfarms. In addition, we also have strong concerns over the accuracy of the approach used in the Berwick Bank application to identify the impact on seabirds. Because of this, we feel bound to speak up against the application.

We also have concerns that the impact on the seascape, visitor experience and special qualities at St Abb’s Head NNR has not been adequately assessed. These factors all contribute not only to visitor numbers at St Abb’s Head but to the wider tourism economy. Moreover, we believe that projected employment figures for the windfarm could be an over-estimation, meaning that the supposed economic benefits of this development could also be overstated.

A third concern we have is that fisheries are experiencing a squeeze on the areas they can fish in. This proposal may shut off important fishing grounds for lower-impact fisheries.

SSE Renewables have proposed a number of compensation measures to mitigate Berwick Bank’s impact, recognising that the level of impact is much greater than would usually be allowed in a Special Protection Area. However, we strongly disagree that any of the proposed compensation measures will effectively mitigate the impacts or offer additional benefit, which is a key requirement for the application to be successful. SSE Renewables have failed to understand and address the causes of low seabird numbers and breeding rates, meaning that the compensation measures will not successfully increase seabird populations. We also contest how achievable the compensation measures are.

An aerial view of the rocky cliffs and the sea at St Abb's Head. A small town can be seen in one of the coves in the distance.

For all these reasons, we strongly believe the application should be rejected. But only in this location. We hope that SSE Renewables will be able to identify a better site for the offshore windfarm, potentially further out to sea. A new site should be chosen where the impact on our precious seabirds, valuable landscapes, tourism economy and lower-impact fisheries will be much lower and where opportunities exist to create impactful, additional compensation measures.

Our charity will continue to liaise with other like-minded organisations to try to make this happen. We will also continue to develop our own vision for what our marine environment should look like in the future, so that it works for everyone who uses and relies on the sea, as well as the nature and wildlife that lives in and around it.

Our Strategy

Our new strategy – Nature, Beauty & Heritage for Everyone – provides a framework for the future of the National Trust for Scotland as we look towards our centenary in 2031.