Why we’re objecting to the Berwick Bank windfarm

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.

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.