Offshore wind energy: draft sectoral marine plan

1. Introduction

The Scottish Government is committed to ensuring secure, reliable and affordable energy supplies, within the context of long-term decarbonisation of energy generation. The continued growth of the renewable energy sector in Scotland is an essential feature of the future clean energy system and a potential key driver of economic growth. As a nation with an abundance of renewable energy resources, opportunities exist not only to meet domestic needs, but also to export low carbon energy to the rest of UK and Europe.

To date, Scotland has seen a significant amount of offshore wind energy activity, with eight offshore wind farms (including two floating wind farms) having received consent and a further six currently operational, equating to a total generating capacity of just over 5 GW. Our first Sectoral Marine Plan for Offshore Wind Energy (Blue Seas Green Energy) ("the 2011 Plan") was adopted in 2011,^[2] with draft wind, wave and tidal plans subsequently produced in 2013.^[3]

Figure 1 Current and planned offshore energy generation, DPOs and draft Plan regions

Three of the six short-term option sites identified in the 2011 Plan have progressed to consenting (Beatrice, Inch Cape and Neart na Gaoithe), with Beatrice Offshore Wind Farm becoming operational in 2019 with an installed capacity of 588 MW. As part of the 3^rd UK Offshore Wind Farm Leasing Round, two Round 3 sites are being progressed in Scottish Waters - the Firth of Forth Offshore Wind Zone and the Moray Firth Offshore Wind Zone.

Recent technological, policy, regulatory and market developments, such as the commitments outlined in the UK Offshore Wind Sector Deal,^[4] the development of new technologies suitable for deployment in deeper water and the aspirations established in recent climate change legislation, however, have presented the opportunity for Scottish Ministers' to undertake a new strategic planning process. This planning process will ensure that the spatial strategy is in place to support the forthcoming CES ScotWind leasing round and enable the continued successful development of commercial-scale offshore wind. This draft Plan builds upon the work undertaken in 2011 and 2013 and encompasses deep water sites, as well as sites more suitable for the deployment of traditional fixed-bottom technologies.

Offshore wind energy has the potential to play a pivotal role in Scotland's energy system over the coming decades. As the amount of planned and constructed offshore wind development increases, however, opportunities to install offshore windfarms closer to shore and/or in shallower waters will decrease, resulting in the need to explore opportunities to develop sites located further offshore and/or in deeper waters. These types of development pose new technical and financial constraints which will need to be overcome, however, Scotland has natural advantages in terms of a combination of high wind speeds and availability of deep water sites, which help to address these challenges. The development of deep water wind also provides an opportunity to further develop offshore wind supply chains and to lever existing infrastructure and supply chain capabilities from the offshore oil and gas industry and creating the requisite conditions to position Scotland as a world leader in deep water wind technologies.

1.1 Purpose and vision

The Plan aims to identify the most sustainable plan options for the future development of commercial-scale offshore wind energy in Scotland, including deep water wind technologies and covers both Scottish inshore and offshore waters (extending out to the Exclusive Economic Zone limit).

This Plan seeks to contribute to the achievement of Scottish and UK energy and climate change policy objectives and targets, through the provision of a spatial strategy to inform the seabed leasing process for commercial offshore wind energy in Scottish waters, which;

• Minimises the potential adverse effects on other marine users, economic sectors and the environment resulting from further commercial-scale offshore wind development; and
• Maximises opportunities for economic development, investment and employment in Scotland, by identifying new opportunities for commercial-scale offshore wind development, including deeper water wind technologies.

This Plan has been developed to ensure consistency with the objectives and principles set out within Scotland's National Marine Plan (2015) and the UK Marine Policy Statement (2011).

For the purposes of the draft Plan and Sustainability Appraisal, commercial-scale offshore wind projects are defined as projects capable of generating more than 100 MW of electricity. This definition of 'commercial-scale' originated from historic leasing rounds for projects in Scottish Waters, in which the term 'commercial-scale' was considered to apply to projects with a generating capacity of over 100 MW of electricity.

Whilst the Plan only seeks to identify DPOs suitable for the development of commercial-scale offshore wind, the Scottish Government remains committed to considering opportunities for local, small-scale and innovative offshore wind development within Scottish waters. It is recommended that early and proactive engagement takes place with Crown Estate Scotland, Marine Scotland and other stakeholders (as appropriate) to discuss any such proposals.

Given the increase in turbine size and output in recent years, Scottish Ministers wish to consider whether the 100 MW threshold should be raised, in order to facilitate the development of new and innovative test and demonstration projects capable of generating more than 100 MW of electricity. We are seeking views on the 100 MW threshold as part of the consultation on the draft Plan (please see further the consultation questions included at section 8). Such test and demonstration projects often have different planning considerations and we would therefore encourage early engagement regarding these types of projects with Marine Scotland, CES and other stakeholders.

1.2 The draft Plan

This draft Plan identifies 17 Draft Plan Options ("DPOs"), split across five regions (see Figure 2), which are capable of generating several GW of renewable energy. The potential impacts of the DPOs are assessed in the Sustainability Appraisal, Strategic Environmental Assessment, Habitats Regulations Appraisal and Socio Economic Impact Assessment, which have been published for consultation along with this draft Plan. Further information about these impact assessments is outlined at section 3 below.

There are, of course, uncertainties regarding the timing, type and scale of future development within the DPOs identified and these factors are beyond the control of the Plan. There may be project-level technical, environmental and economic constraints which could limit the scale and timing of development within each DPO. Further, development may be taken forward in some regions and DPOs in preference to others. The draft Plan, therefore, has been prepared and assessed using low, medium and high regional and national deployment scenarios (for further details, see section 3.1), to reflect this uncertainty. During the planning process, the higher deployment scenario was increased from 8 GW to 10 GW, reflecting the outputs of the Opportunity and Constraint analysis, anticipated future demand and market appetite for further development. The SEA also recognises that, at present, limiting the scale of development under the Plan to 10 GW is required to reduce or offset the potential environmental effects of development. This figure is still higher than the Scottish Offshore Wind Energy Council's ("SOWEC") goal to deliver at least 8 GW of offshore wind in Scottish waters by 2030.^[5]

Figure 2 Draft Plan Options (2019)

1.3 The final Plan

Following consultation on the draft Plan, the final Plan will be prepared and presented for approval by the Scottish Ministers'. In the event that substantial changes are required as a result of this consultation process, further assessment and consultation may be required. A Post Adoption Statement, outlining any changes made to the draft Plan, will be published with the final Plan.

It should be noted that the final Plan will not provide decisions on the proposed development and management of Plan Options. The Plan articulates the Scottish Government's strategic vision and objectives for future commercial-scale offshore wind development and articulates the spatial framework to inform the CES leasing process. The Plan will guide the relevant consenting bodies when making decisions on individual licence and consent applications, but should not be considered as pre-determining those decision-making processes.

In addition, the final adopted Plan will be subject to iterative plan review, as set out below at section 5.3, which will ensure that the Plan remains reflective of current scientific understanding and knowledge, as well as the wider regulatory and policy context. It is currently anticipated that the final Plan will be reviewed and updated to reflect and inform the spatial requirements for any further leasing round(s) from CES.

1.4 Crown Estate Scotland seabed leasing ("ScotWind")

In November 2017, Crown Estate Scotland ("CES") announced its intention to run a further leasing round for commercial-scale offshore wind energy projects in Scottish waters. The final Plan will provide the spatial framework for this leasing round, by identifying which Plan Options are available for leasing.

The ScotWind leasing process is expected to commence following the publication of this draft Plan with Option Agreements to be concluded between CES and offshore wind developers after the Plan is adopted. For further detail regarding the relationship with the ScotWind leasing process, please see below at section 3.1. and Figure 7.

1.5 National and Regional Marine Plans

The Plan has also been developed in accordance with the strategic aims of the National Marine Plan (2015), which addresses the potential for interactions between renewable energy development and other marine users (including, but limited to, recreational users, commercial fishers, other construction works, shipping traffic, ports and harbours).

Regional marine plans are currently in the process of being prepared within those Scottish Marine Regions where there is an established Regional Marine Planning Partnership. The planning competence of these Regional Marine Planning Partnerships extends out to 12 nautical miles. Regional marine plans are required to be developed in accordance with the National Marine Plan (unless relevant considerations indicate otherwise) and will be required to take into account the Plan Options identified via the sectoral marine planning process, as well as co-ordination with the CES leasing regime and any relevant grid requirements and initiatives. Figure 3 shows the DPOs in relation to the Scottish Marine Regions.

Figure 3 Draft Plan Options and Scottish Marine Regions

1.6 Scottish Offshore Wind Policy

As set out in the Government's Programme for Scotland 2019-20, we will continue to work hard to make Scotland an attractive place to invest in offshore wind energy developments, and will take further steps this year to provide clarity and certainty across the sector.

The draft Scottish Offshore Wind Energy Policy Statement^[6] sets out our ambition to capitalise on the potential that offshore wind development can bring to Scotland and the role this technology could play in meeting our commitment to reach net zero by 2045. The Policy Statement builds on the ambitions outlined in Scotland's Energy Strategy^[7], published in December 2017, which set out the 2050 vision for energy in Scotland, including generation and energy usage targets and strategic priorities for action. The Plan will form a key component of the implementation of the Offshore Wind Policy Statement, by identifying suitable areas for further offshore wind deployment and identifying a pipeline of potential projects for the industry and supply chain. The draft Scottish Offshore Wind Energy Policy Statement is currently subject to consultation and is anticipated to be finalised in 2020.

The UK Sector Deal targets the generation of 30 GW of offshore wind energy by 2030 and commits to key enabling actions, such as certainty regarding future Contracts for Difference ("CfD") rounds, investment in the UK supply chain and a commitment by the renewables sector to increase UK supply chain content to 60% by 2030 (including increases at the capital expenditure phase). The Scottish Government played a key role in the development of the UK Sector Deal, to ensure that Scotland is well placed to gain long-term benefits as the delivery of the deal progresses.

Following the Offshore Wind Supply Chain Summit, held on 2 May 2019 and chaired by the Finance Secretary and the Energy Minister, the Scottish Government set out its intention to explore the levers and regulatory instruments at the disposal of Ministers to increase local content in projects. Whilst Scottish Ministers remain open to industry efforts to increase local content in projects, they have been clear that they will do everything within their devolved competence to secure an equitable economic return for the Scottish supply chain.

SOWEC has set out the scale of ambition necessary if Scotland is to meet its share of the UK Sector Deal's targets with scale and pace. SOWEC believes that the sector in Scotland should seek to deliver at least 8 GW of offshore wind in Scottish waters by 2030 and increase the number of offshore wind jobs in Scotland to more than 6,000, a 75% increase on 2019 figures. The draft Plan is reflective of the scale and ambition of SOWEC's vision and recommendations and any further recommendations made by SOWEC will be considered during the finalisation of the Plan.

1.7 Wider context

The Plan development process has taken into account wider policies and priorities relating to climate change, lowering carbon emissions and promoting green energy to ensure that the Plan supports the delivery of our national and international obligations. The process has also taken into consideration the potential economic, social and environmental impacts of offshore wind energy and has been undertaken in accordance with relevant Scottish, UK and EU legislation. A brief overview of the wider legislative and policy context is provided in Figure 4.

Achieving Net Zero

The publication of the Intergovernmental Panel on Climate Change ("IPCC") report,^[8] outlined that the world would need to reach a point of 'net zero' GHG emission by 2050 in order to avoid "long lasting and irreversible changes" to the global climate. The subsequent Committee on Climate Change ("CCC") advice to UK, Scottish and Welsh governments,^[9] concluded that reaching the net zero target in the UK is largely achievable with known technologies, but that further policies and concerted action was required to reach this goal. The CCC Report highlighted that extensive electrification, particularly of transport and heating, would require a major expansion of renewable and other low-carbon power generation, leading to around a doubling of electricity demand. That would equate to around 75 GW of offshore wind in 2050, compared to 8 GW available currently and the 30 GW targeted by the UK Offshore Wind Sector Deal. The CCC Report also identified key actions and the role of the Scottish Just Transition Commission in ensuring a Just Transition to the low-carbon economy which is fair for all.

The CCC Report recommended a net-zero date of 2045 for Scotland, reflecting Scotland's greater relative capacity to remove emissions than the UK as a whole. In line with this advice, amendments were lodged to the Climate Change Bill, which raised the ambition of the 2030 and 2040 targets for emissions reductions to 70% and 90% respectively. The newly passed Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 implements some of the most stringent statutory targets in the world, with the aim of ending our contribution to climate change, definitively, within a generation. Future iterations of the Plan may need to plan accordingly to support these aspirations.

Figure 4 UK and Scottish policy and regulatory context

Future energy demand and grid capacity

Our energy demand and mix is changing rapidly and will continue to do so for the coming decades, as a result of factors such as; the need to reduce greenhouse gas emissions, the increased demand for low-carbon electricity for transport, ensuring security of energy supplies and tackling energy poverty.

The Future Energy Scenarios ("FES") 2019 report^[10] identifies that the commitment to net zero requires greater action in relation to electrification, energy efficiency and carbon capture than predicted in previous scenarios. Further significant offshore wind farm development will require further investment in and improvements to our electricity transmission and distribution systems, particularly for more remote areas, as well as measures to reduce barriers such as connection costs for generators.

For Scotland, National Grid scenarios suggest a total Scottish generating capacity of between 15 and 25 GW by 2035 (10-20 GW low carbon generation). With demand in Scotland not expected to exceed 4.7 GW by 2035, there is potential to export power south, out of Scotland into England, for significant periods of time.^[11] A number of projects are currently being undertaken to improve connectivity within Scotland and between Scotland and the rest of the UK, which will facilitate the export of electricity.

Marine Scotland are working closely with the Offshore Renewable Energy Catapult ("ORE Catapult") and transmission operators to explore opportunities regarding the grid network, including novel approaches and technology, to ensure that the necessary infrastructure is in place to facilitate further development.

The likely scale and location of future offshore wind development presents challenges around grid connection and costs for developers. Innovative approaches such as hybrid projects (where transmission infrastructure and assets are shared between projects), electricity conversion and battery storage could help to address these challenges. These approaches may offer potential cost and space savings, as well as potential reductions in environmental impacts, however, there are legal and regulatory barriers that would need to be addressed prior to deployment.^[12]

In addition, there exists the opportunity for further offshore development in Scottish waters to support the integration of the European offshore grid network. Whilst there are technical, regulatory and financial challenges to the integration of the offshore grid network, such a network could offer important socio-economic and environmental benefits to Scotland and other North Seas countries, whilst supporting the energy transition and decarbonisation of the energy sector. The European North Seas countries have been working together to facilitate the strategic, co-ordinated and cost-effective development of hybrid projects, with one project nearing commissioning.

The development of improved grid connectivity may also provide an opportunity for our islands to develop clean energy projects and interconnectors for Orkney and Shetland are currently at an early development stage. Recent research published by CES has explored how the integration of offshore renewables (including floating offshore wind, tidal and wave projects) into local energy systems can support the commercial viability of offshore projects, whilst benefitting local coastal communities.^[13]

We would therefore encourage developers considering these types of approaches and solutions to engage with Marine Scotland, CES, other developers and operators as early as possible in the process.