Sectoral marine plan - offshore wind for innovation and targeted oil and gas decarbonisation: initial plan framework

8 Key Issues by Sector

Energy – individual project and total capacity limits.

8.1 A number of responses (15) raised questions or expressed concerns about the use of 100MW as maximum limit for projects looking to progress under the Innovation category. Requests to raise the limit generally suggested an increase to 300 – 350MW, with some noting that capacity in general is unhelpful as a limiting factor as it is the negative impact that should create the limit.

8.2 Reasons for the suggested increase include the potential for the current limit to introduce an unfair competitive disadvantage for projects that may wish to compete for Contracts for Difference (CfD), lack of access to investment when compared to other projects of a larger size, a potential lack of assets as manufacturers may be focused on larger opportunities, and the general increase in turbine generation capacity meaning that fewer turbines are required to reach 100MW.

8.3 This coincides with requests to generally increase the "Innovation" total capacity limit from 500MW to 1000MW. Few responses suggested anything beyond 1000MW.

8.4 Conversely, five responses were provided indicating that an increase to the 100MW threshold introduces risks, not only to this planning process but also to delivery of ScotWind projects. This was presented as the potential to add to cumulative impact in regions already facing constraints and the possibility for projects under this planning process to progress ahead of ScotWind projects introducing uncertainties that were not a factor in the ScotWind planning and application process. These concerns reflect the fact that the areas designated for innovation projects are closer to shore and often adjacent to ScotWind areas. Additionally there was a suggestion that 100MW is sufficient to test and deploy new technologies as opposed to a larger scale mechanism to deliver "pre-commercial" or early-commercial scale projects.

8.5 Whilst both views present valid arguments, it has been determined that the 100MW limit for innovation category projects will not be raised under this IPF. The Targeted Oil and Gas component of the planning process offers significant opportunity for pre-commercial scale projects to progress in Scottish waters with the advantages that a larger scale of project carries. The innovation category of this planning process is not designed to allow for pre-commercial projects to progress. Whilst the value of these types of project is certainly clear, the innovation category should be used to test and deploy new technology, methodologies and other novel measures according to CES criteria.

8.6 In addition, much of the potential development area on the north east and east of Scotland remains under ornithological constraint, as demonstrated in the SMP-OWE. This planning process has introduced areas where no development will be permitted, based largely on this constraint but not exclusively. Should the 100MW limit be raised it may be necessary to increase those exclusions to the point where even viable 100MW projects could not gain access to the grid, forcing development of innovation scale projects into more difficult development areas that would be counter to the notion of test and demonstration of new technology.

Energy – Planning, Leasing and Consenting Timeline

8.7 One of the key considerations of the INTOG planning process has been the need to allow for projects to progress at pace whilst ensuring a plan-led approach can provide fair and detailed strategic level assessment. Responses have noted that the timeline from project inception through planning, leasing and ultimately consenting, if not quick, may negatively impact the financial viability of projects and could hinder net zero commitments with regard to the use of offshore wind to decarbonise Oil and Gas installations.

8.8 This planning process has been designed to allow projects to gain exclusivity over an area of seabed much earlier than has previously been possible. This is enabled through an earlier leasing process by CES where exclusivity will be offered to successful projects that meet both the planning and leasing criteria before the final INTOG Plan is adopted. This provides security over a project location so that consent applications can progress with certainty that, should the location remain in the adopted Plan, subject to assessment and consultation, the project will be able to progress to full option. As such, no change has been made to the Initial Plan Framework timeline following consultation.

Energy – other issues

8.9 Other Energy sector responses included;

• The need for local supply chain opportunities flowing from INTOG;
• Emphasising the potential resource implications of an additional consenting process alongside ScotWind and seeking assurances that regulators and Statutory Nature Conservation Bodies will be able to meet demand;
• Wider consideration of grid and cable locations/planning;
• Potential spatial overlap of offshore wind with Carbon Capture Usage and Storage (CCUS) opportunities – both existing projects and future potential;
• A general request for future offshore wind opportunities following INTOG and ScotWind;
• Priority should be given to assessing ScotWind applications over INTOG projects.

8.10 Whilst these concerns and comments are noted they have not resulted in material changes to the Initial Plan Framework nor planning specifications, with the exception of consideration of CCUS where the Areas of Search E-b has been modified to remove an identified overlap with monitoring requirements for the Acorn CCUS project, which already has an Option Agreement and where a larger areas NE-e has been removed due to both fisheries and CCUS constraint.

Commercial Fisheries – key issues

8.11 Commercial fisheries groups who responded to the Plan Specification and Context Report consultation highlighted key concerns around future offshore wind planning and development so recently after the adoption of the SMP-OWE and ongoing ScotWind leasing process.

8.12 Particularly, concerns were raised about the large areas off the west coast of Shetland, both in terms of proximity to shore and overlap with fishing grounds at the western edges of the Areas of Search.

8.13 Furthermore, the addition of offshore wind developments in the sea may (and this is more likely where floating technology is employed) result in a displacement of fishing effort into other regions, with implications both in terms of increased competition for space and potential environmental impact.

8.14 It was also noted that inshore fisheries data depicting activity are limited or dated.

8.15 A review of fisheries data has been undertaken and modifications to Areas of Search have taken place to help rectify some of the larger concerns (WoS-a, WoS-b and NE-e). This results in a reduction of the Areas of Search to remove primary overlaps in fishing effort west of Shetland and at NE-b where fisheries and CCUS constraints have collectively modified the area. It is useful to clarify that whilst the Areas of Search are very large, even compared to the SMP-OWE Plan Options, a much smaller area of seabed is required to deliver the intentions of this plan. Given the nature of Targeted Oil and Gas projects, which will likely require projects to be proposed and agreed between offshore wind developer and oil and gas operators, limiting the initial Areas of Search too much would result in restricting development opportunities arbitrarily. However, the areas required to deliver 4GW under our planning and assessment assumptions of 5MW/km² is around 800km², significantly smaller than the areas shown in this Initial Plan Framework. Whilst Option Agreements will be larger than the 800km², as suggested above, this is managed through the implementation of a spatial and generation cap and may further reduce through project planning and consenting.

8.16 Even without reduction, these areas would be significantly smaller than the Areas of Search. Project level work on Environmental Impact Assessments will also involve extensive engagement with fishermen where they are affected to mitigate the impact on their operations as far as possible.

8.17 Displacement of fishing effort from one location into another is a key consideration of the planning process. In addition to the modifications outlined above, there has been careful consideration of fishing activity and overlap across the Opportunity and Constraint analysis and identification of the Areas of Search. This precautionary approach should minimise the impact on commercial fisheries but cannot, at this stage, rule it out entirely. All projects proposed within the Areas themselves, and successfully approved for exclusivity by CES, will then be subject to a full Sustainability Appraisal as outlined above. Commercial fisheries groups/representatives will be invited on to those assessment steering groups to help shape the methodologies to allow these issues, amongst others, to be examined.

8.18 With regard to inshore fisheries data, this comment is noted and is a priority of separate work within Marine Scotland. ScotMap, a previous voluntary survey of inshore fisheries activity, has been reused in this planning process, acknowledging that the data is now dated and that some features of the data and levels of fishing effort may be incorrect. All of the Targeted Oil and Gas projects must be located in the Areas of Search identified in the Initial Plan Framework and will therefore be a greater distance offshore. Innovation scale projects can be located outside of the areas marked for exclusions and so could be closer to shore, particularly on the west coast. However, in total, these projects cannot exceed 500MW and individually they should not exceed 100MW. These specifications have been identified, in part, to help minimise negative impact whilst leaving options to develop new opportunities. Projects awarded exclusivity will be assessed through the planning and/or consenting process.

Environmental/NGO – Key Issues

8.19 Responses from the E-NGOs, or those who provided responses relating to environmental concerns, focused on a wide range of issues. Those include:

• Welcoming exclusion zones and questions about the extent of those areas.
• Understanding the carbon footprint of delivering these developments.
• Potential impact of electromagnetic fields on various species.
• Concerns over mobile species and those with connectivity to protected sites and also more potential for cross-border connectivity if projects are located farther from shore.
• Lack of historic environmental data at the initial stages and recommendation to include those data in the final plan.
• Potential for projects to reach into Arctic Monitoring & Assessment Programme (AMAP) areas, which may require consideration of different sensitivities.

8.20 Many of these issues highlight some of the later considerations that will be addressed throughout the next phases of the planning development. Unlike previous planning exercises, the Areas of Search will not be refined further at this stage. Once more precise project locations are identified by CES leasing process, those locations and projects will be subject to the Sustainability Appraisal where more detailed environmental and socio-economic assessments will be completed. These assessments will allow for consideration of impacts in a more specific way. However, some modifications have been made to the Areas of Search and to the exclusions based on feedback provided, with particular reference to consideration of bird data.

General comments

8.21 In addition to the key issues raised by the sectors above, there were additional responses and questions that do not so easily fit those categories.

8.22 Those related to clarifications on the planning process and timeline, which are addressed above in this Initial Plan Framework, whilst questions relating to the nature and requirements of the CES Leasing process are addressed in the associated INTOG leasing documentation.

8.23 Additionally, many questions related to the impact and shape of the final Plan, such as: consideration of the wider carbon footprint; assessment of decommissioning; wider transboundary impacts; and cumulative impacts. These will be addressed through the next stages of the Plan.

8.24 Several questions - such as those related to incentives, the CES leasing criteria, further decarbonisation of Oil and Gas installations beyond the extraction phase, the impact and timeline of Contracts for Difference auctions - are beyond the scope of the Sectoral Marine Plan.

8.25 It is worth highlighting that many questions related to cable infrastructure, grid connections and coordinated delivery of connections. While the INTOG planning process has at this stage not identified cable corridors, given the uncertainty of project locations, the Scottish Government is actively engaged in the Offshore Network Transmission Review (OTNR) to ensure Scottish interests and projects located in Scotland are recognised in that process. It is the Scottish Government's intention to complete a spatial plan for grid that will encompass known projects.