Tidal Industry Seal Project: Managing the Consenting Risk of Harbour Seal Collision in the Scottish Tidal Energy Industry

Edwards, E.; Davies, I.; Gerich, G.; Green, M.; Leaver, D.; McKie, J.; McLean, A.; Munro, P.; Murray, J.; Smith, K. (2025). Tidal Industry Seal Project: Managing the Consenting Risk of Harbour Seal Collision in the Scottish Tidal Energy Industry (Report No. A-101011-S00-A-REPT-001). Report by Xodus Group. Report for Crown Estate Scotland.

@techreport{Edwards-2025-2083533,
author = {Edwards, E and Davies, I and Gerich, G and Green, M and Leaver, D and McKie, J and McLean, A and Munro, P and Murray, J and Smith, K},
title = {Tidal Industry Seal Project: Managing the Consenting Risk of Harbour Seal Collision in the Scottish Tidal Energy Industry},
institution = {Xodus Group},
year = {2025},
month = {may},
number = {A-101011-S00-A-REPT-001},
url = {https://www.emec.org.uk/projects/ocean-energy-projects/environmental-monitoring/tidal-industry-seal-project/},
keywords = {Marine Energy, Tidal, Avoidance, Collision, Marine Mammals, Pinnipeds},
}

Export Citation to BibTex

TY - RPRT
TI - Tidal Industry Seal Project: Managing the Consenting Risk of Harbour Seal Collision in the Scottish Tidal Energy Industry
AU - Edwards, E
AU - Davies, I
AU - Gerich, G
AU - Green, M
AU - Leaver, D
AU - McKie, J
AU - McLean, A
AU - Munro, P
AU - Murray, J
AU - Smith, K
AB - IntroductionThe Tidal Industry Seal Project (TISP) addresses the critical consenting challenges faced by Scotland's tidal stream energy industry, particularly concerning the declining harbour seal population. The urgency of resolving these challenges is driven by the escalating demand for clean, renewable energy and the need for energy security while balancing the conservation of a protected species. The Pentland Firth and Orkney Waters (PFOW) region, with its powerful tidal currents, holds substantial potential for tidal stream energy, which is crucial for the UK's renewable energy future.Tidal Energy Potential and Developments The PFOW region is renowned for its tidal energy resources, attracting significant investment in the European Marine Energy Centre and pioneering project developments. Notable projects include MeyGen, the world's largest tidal stream array, and innovations by companies like Nova Innovation and Orbital Marine Power. These projects have demonstrated the viability of tidal power generation, contributing significantly to renewable electricity production.Environmental and Regulatory Challenges A key challenge for tidal energy development is securing environmental consent, particularly concerning the risk of collision between turbine blades and marine fauna, including harbour seals. The decline of the harbour seal population in the PFOW region complicates consenting processes. Despite extensive monitoring, there is no concrete evidence of turbine-seal collisions, but regulatory concerns persist due to the vulnerability of this regional population.Governmental Policy and Support National and regional policies support tidal energy development, emphasizing sustainable marine economy and climate change mitigation. Recent policy documents reinforce the commitment to renewable energy and the transition to a net-zero economy. However, the consenting process remains complex, requiring comprehensive environmental assessments and effective risk mitigation strategies.Industry Collaboration and the TISP Initiative Leading industry stakeholders, including EMEC, MeyGen, Orbital Marine, and Nova Innovation, have launched the TISP to address consenting challenges. The project aims to facilitate consenting of utility-scale tidal turbine arrays while ensuring environmental stewardship. The report examines the effectiveness of current collision risk models, regulatory frameworks, and potential solutions, including regional strategic ecosystem monitoring and proportionate compensation mechanisms.RecommendationsTowards the end of this report (Section 9.8), TISP have set out a series of recommendations that should be considered, commencing immediately. These are summarised here:Collaboration and engagement on next stepsRoundtable discussion to be arranged: Convene a roundtable with key stakeholders to discuss the report's outputs during Q2 2025.Develop a roadmap to reduce risk: A high-level, collaborative, strategic plan for the industry, introducing the steps needed to enable further tidal stream energy development.Regional Advisory Group to be established: PFOW developers to form a group for regional/strategic environmental assessment and monitoring.Collaborative cumulative effects assessment: PFOW developers to conduct cumulative effects assessment in a collaborative way. A fit-for-purpose policy and regulatory framework Policy review: Scottish Government to review policy frameworks and regulatory processes to support tidal stream energy development.Strategic planning resources: Scottish Government to allocate resources for strategic planning of tidal stream energy.Seal management: Review the management of seal populations and consider alternative approaches to assessment of significant effects.Evidence gaps: Review ScotMER evidence map prioritisation through tidal stream industry representation in expert groups to reflect industry research needs.Application of up-to-date methodologies and use of best available evidence in environmental assessment Collision evidence and risk assessment tools: Review and update NatureScot guidance on collision risk assessment based on current evidence.Expert opinion: Questions relating to tidal energy to be put to SCOS via regulator and advisers.Proportionate and feasible monitoringReview scope of future monitoring: Conduct testing and validation of new monitoring technologies; assess scalability and cost-effectiveness of these methods; continue collaboration to share insights and data.Strategic monitoring and research: Collaborative planning of strategic monitoring and researchEcological enhancement and compensation Ecological enhancement and compensatory measures: Conduct feasibility study on ecological enhancement and compensatory measures for harbour seal impacts, with due consideration given to plan-level compensation.Project-level recommendationsConsent applications: Include collision risk estimates and consider presenting alternatives to PBR, such as population viability counterfactual assessments, in Section 36 applicationsDerogation cases: Include derogation cases in applications interacting with Sanday SAC.PBR assessment: Consider the most appropriate assessment unit (population) for PBR assessment, e.g. the wider Scottish harbour seal populationPlanning acceptability: Consider compensatory measures for planning acceptability of developments.ConclusionUnlocking the full potential of tidal stream energy is imperative for securing a resilient, sustainable energy future for Scotland and the UK. This TISP report highlights the need for a streamlined, science-led regulatory framework that balances environmental protection while enabling industry development. Resolving consenting challenges is crucial to avoid stagnation and ensure the growth of this vital renewable energy sector.
DA - 2025/05//
PY - 2025
SP - 158
PB - Xodus Group
SN - A-101011-S00-A-REPT-001
UR - https://www.emec.org.uk/projects/ocean-energy-projects/environmental-monitoring/tidal-industry-seal-project/
LA - English
KW - Marine Energy
KW - Tidal
KW - Avoidance
KW - Collision
KW - Marine Mammals
KW - Pinnipeds
ER -

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Abstract

Introduction
The Tidal Industry Seal Project (TISP) addresses the critical consenting challenges faced by Scotland's tidal stream energy industry, particularly concerning the declining harbour seal population. The urgency of resolving these challenges is driven by the escalating demand for clean, renewable energy and the need for energy security while balancing the conservation of a protected species. The Pentland Firth and Orkney Waters (PFOW) region, with its powerful tidal currents, holds substantial potential for tidal stream energy, which is crucial for the UK's renewable energy future.

Tidal Energy Potential and Developments
The PFOW region is renowned for its tidal energy resources, attracting significant investment in the European Marine Energy Centre and pioneering project developments. Notable projects include MeyGen, the world's largest tidal stream array, and innovations by companies like Nova Innovation and Orbital Marine Power. These projects have demonstrated the viability of tidal power generation, contributing significantly to renewable electricity production.

Environmental and Regulatory Challenges
A key challenge for tidal energy development is securing environmental consent, particularly concerning the risk of collision between turbine blades and marine fauna, including harbour seals. The decline of the harbour seal population in the PFOW region complicates consenting processes. Despite extensive monitoring, there is no concrete evidence of turbine-seal collisions, but regulatory concerns persist due to the vulnerability of this regional population.

Governmental Policy and Support
National and regional policies support tidal energy development, emphasizing sustainable marine economy and climate change mitigation. Recent policy documents reinforce the commitment to renewable energy and the transition to a net-zero economy. However, the consenting process remains complex, requiring comprehensive environmental assessments and effective risk mitigation strategies.

Industry Collaboration and the TISP Initiative
Leading industry stakeholders, including EMEC, MeyGen, Orbital Marine, and Nova Innovation, have launched the TISP to address consenting challenges. The project aims to facilitate consenting of utility-scale tidal turbine arrays while ensuring environmental stewardship. The report examines the effectiveness of current collision risk models, regulatory frameworks, and potential solutions, including regional strategic ecosystem monitoring and proportionate compensation mechanisms.

Recommendations
Towards the end of this report (Section 9.8), TISP have set out a series of recommendations that should be considered, commencing immediately. These are summarised here:

Collaboration and engagement on next steps

Roundtable discussion to be arranged: Convene a roundtable with key stakeholders to discuss the report's outputs during Q2 2025.
Develop a roadmap to reduce risk: A high-level, collaborative, strategic plan for the industry, introducing the steps needed to enable further tidal stream energy development.
Regional Advisory Group to be established: PFOW developers to form a group for regional/strategic environmental assessment and monitoring.
Collaborative cumulative effects assessment: PFOW developers to conduct cumulative effects assessment in a collaborative way.

A fit-for-purpose policy and regulatory framework

Policy review: Scottish Government to review policy frameworks and regulatory processes to support tidal stream energy development.
Strategic planning resources: Scottish Government to allocate resources for strategic planning of tidal stream energy.
Seal management: Review the management of seal populations and consider alternative approaches to assessment of significant effects.
Evidence gaps: Review ScotMER evidence map prioritisation through tidal stream industry representation in expert groups to reflect industry research needs.

Application of up-to-date methodologies and use of best available evidence in environmental assessment

Collision evidence and risk assessment tools: Review and update NatureScot guidance on collision risk assessment based on current evidence.
Expert opinion: Questions relating to tidal energy to be put to SCOS via regulator and advisers.

Proportionate and feasible monitoring

Review scope of future monitoring: Conduct testing and validation of new monitoring technologies; assess scalability and cost-effectiveness of these methods; continue collaboration to share insights and data.
Strategic monitoring and research: Collaborative planning of strategic monitoring and research

Ecological enhancement and compensation

Ecological enhancement and compensatory measures: Conduct feasibility study on ecological enhancement and compensatory measures for harbour seal impacts, with due consideration given to plan-level compensation.

Project-level recommendations

Consent applications: Include collision risk estimates and consider presenting alternatives to PBR, such as population viability counterfactual assessments, in Section 36 applications
Derogation cases: Include derogation cases in applications interacting with Sanday SAC.
PBR assessment: Consider the most appropriate assessment unit (population) for PBR assessment, e.g. the wider Scottish harbour seal population
Planning acceptability: Consider compensatory measures for planning acceptability of developments.

Conclusion
Unlocking the full potential of tidal stream energy is imperative for securing a resilient, sustainable energy future for Scotland and the UK. This TISP report highlights the need for a streamlined, science-led regulatory framework that balances environmental protection while enabling industry development. Resolving consenting challenges is crucial to avoid stagnation and ensure the growth of this vital renewable energy sector.