Offshore wind policy statement: consultation analysis

Appendix 2: Other comments

Q1: Does the current pipeline and level of activity in the offshore wind sector in Scotland provide a sufficient platform upon which to build the greater contribution required to achieve our climate change goals?

Support for OWPS

• One acknowledged the importance of the Climate Change Act in signalling Scotland's ambitions for offshore wind to the international market.
• One respondent discussed the SG's regulation of conditions applicable to Tier 1-3 contractors and sub-contractors and called for greater employment opportunities for Scottish workers. They suggested that depending on imported workers would impinge the achievement of the minimum target of 8GW.

Ambition in targets

• A suggestion that Scotland should be aiming for a 40 to 45% share of the UK target which would require deployment of 30 – 35 GW by 2050, requiring an increase in deployment of projects.

Action to meet workforce and supply chain development goals

Singular comments on this theme included:

• The creation of a local content clause in planning applications to provide guarantees for employment opportunities in development, production, and manufacturing within local communities. The same respondent encourages the SG to consider planning applications including environmental and local content clauses on top of the existing Environmental Statement required and the application of significant weighting during the contract procurement process.

• Arguing that a mechanism in the CfD would reflect total value added to the Scottish supply chain and therefore promote local investment.
• Implored the SG to seek diversification of other, experienced companies and new technologies including commercial scale floating wind, to reduce costs and offer associated opportunities to develop the local supply chain.
• The NURTM provided a detailed response urging the SG to: define the offshore wind supply chain to include all vessels engaged from planning to decommissioning; extend collective bargaining and a supply chain wage floor of the real Living Wage of £9.30 per hour as part of the Supply Chain Development Statement required by Crown Estate Scotland's ScotWind Leasing process and as a condition of membership of offshore wind clusters such as DeepWind and Forth & Tay; and, to commit to build the offshore wind skills base by training and employing Scottish workers across the offshore wind supply chain, including shipping support services with an aim for 100% Scottish or UK 'content' in these contracts.
• A suggestion the SG should take a holistic view, especially considering the COVID-19 pandemic, to include fishing in renewables planning.
• One respondent urged the SG to assure a revenue stabilisation mechanism.

Actions to meet goals in relation to infrastructure and planning

• A need to develop and increase electricity storage for Scotland was discussed, while also considering exports to other UK jurisdictions and Europe.
• For wind farms built solely for producing green hydrogen via electrolysis.

General comments about Scotland's renewables sector

Singular comments included calls for: the clearance of projects within migratory lanes; that the SG should return investment on fossil fuels instead; that the current pipeline and level of activity are insufficient to meet climate change goals; and for further investment and effort in environmental monitoring and research to understand the risks to the expansion of offshore wind.

Other comments

Comments not related to the themes above included:

• Two calls for the SG to consider moving to a model of public ownership or control.
• Crown Estate Scotland welcomed the coordinated approach of consulting on the two plans simultaneously and called for further development of policy hierarchy within offshore wind. One respondent advocated coordination between Marine Scotland and CES on the location of existing cable infrastructure.
• One described a rolling site award process enabling 10GW of new development opportunities into the pipeline every two years from 2020 to 2030 with the opportunity to extend, alongside an adequately resourced consenting process.

Q2: Do you believe that the 2030 visions and aspirations described above are sufficiently ambitious?

Calls for more ambitious targets

• A suggested increase to 10-15GW, but acknowledging this would depend on the capacity of developers among other factors. They suggested that outlining this increased target in the vision would provide an appropriate basis to work from.
• One respondent suggested 20-30GW by 2045.
• One other respondent's view was that Scotland should aim for 40% to 45% of the proposed 75GW by 2050, which would be 30GW-35GW.

Calls for more ambitious visions and aspirations

• One outlined four goals they implored SOWEC to include in its 2030 aspirations and visions. They requested the consideration of UN Sustainable Development Goals and European Commission Precautionary Principles in the visions.
• Another welcomed the vision but noted the new 2045 emissions target would require a faster pace of emissions reduction by this date. They also felt a longer-term target with increased capacity would be necessary.
• One respondent argued more ambition this would accelerate Scotland's ability to meet targets while enabling competitiveness in international markets and promoting economies of scale. They suggested these targets should be regularly reviewed, and revised if necessary, to keep Scotland on track to decarbonise and to take account of changing market circumstances.

Expressions of support for the visions

• Singular comments included support for: the targets of 8GW by 2030 and the 10GW potential outlined in the Draft SMP; the seabed leasing selection criteria adapted by Crown Estate Scotland for ScotWind; and, the focus on sites with deeper water and the discussion around floating wind.
• One commented it would decarbonise Scotland's economy through offering affordable electricity and energy.

Expressions of support with calls to action

• One respondent commented that there would need to be support at a policy level for the visions to be viable. Another supported the visions but noted there the need to consider the consequences to the environment and fishing industry.

Calls for specific timelines in relation to planning

• Singular suggestions included: that the ScotWind leasing process would need to be delivered quickly and efficiently to meet targets; that new projects from leasing rounds beyond 2020 would be unlikely to contribute to achieving targets until the project timeline is significantly shortened; and, that ambitions and visions should be outlined up to 2045 as this would provide clarity about aligning with other policies.

Collaboration between industry and the Scottish Government

• A respondent described the importance of floating wind being cost-competitive with other technologies, including offshore wind, by 2030 and suggested this could be achieved by utilising existing expertise in fixed offshore wind and the competence and experience from the oil and gas sector.
• Another gave a detailed response proposing the creation of a publicly owned energy company. This response is discussed in the analysis of question 3. They suggested the creation of this company will require collaboration with the Scottish National Investment Bank to deliver an industrial policy for the offshore wind sector.

Other comments

Other singular comments not in the above themes included:

• That the targets suggested in the vision were too ambitious too be met.
• A suggestion that the vision should consider offshore wind farms built solely to produce hydrogen.
• A recommendation that the OWPS is condensed into an outline vision for the future of offshore wind in Scotland and that issues requiring further consideration are set out in an accompanying "road map" outlining how the vision will be delivered.
• Dissatisfaction with SG's consideration of the UK's Carbon Capture, Storage and Leak (CCS-LEAK) plans.

Q3: What actions do you believe should be taken by the Scottish Government, UK Government and agencies in order to realise the full potential of Scotland's offshore wind sector?

CfD

One highlighted opportunities for promoting the development of green hydrogen through the CfD regime, suggesting this would create further revenue. Another suggested fixed deep water (50+meter) sites should also be considered as eligible to support development in challenging locations that could be delivered by fixed, floating or hybrid solutions.

Supporting the Scottish supply chain

• One trade union urged the SG to use the ScotWind Leasing process to reinforce commitments by developers and supply chain companies to recognise domestic trade unions, including those organising seafarers. They would like to see the Real Living Wage as the legal baseline for pay in the supply chain for all fixed and floating offshore wind farms in Scottish waters. One energy company stated that they supported the Scottish supply chain already and would continue to do so.
• Another respondent highlighted benefits of focusing on the region around Aberdeen as having potential to contribute significantly to export ambitions.

Exploring and amending regulations

• One respondent highlighted the necessity of a consistent approach to environmental assessment across the UK, particularly in relation to ornithology, to ensure Scotland's ability to compete in the market.
• Scottish Renewables called for departments and delivery bodies in Scotland and across the UK to be appropriately resourced to support the Government's ambitions and to deliver within an appropriate timescale. They suggested engagement would be required from Scottish Natural Heritage (SNH), the Scottish Environmental Protection Agency (SEPA), Marine Scotland, Local Planning Authorities (LPAs) and Heads of Planning Scotland (HoPS).
• One highlighted the current barriers to investing in renewable electricity generation across the north of Scotland; Transmission Network Use of System (TNUoS) and called for this to be reviewed.
• Another stressed that the regulator should support the continuation of uncertainty mechanisms as these are important to protect consumers from unnecessary investment and to meet net zero targets.

Collaborative working with industry

Singular comments on this theme included:

• Suggestions for the development of an industrial plan for floating wind through collaborating with the industry sector and for the SG to lead collaboration which should include offshore wind developers, CCUS and Hydrogen developers, CES and regulators (OFGEM and the OGA). One went further to request joint studies from the OFGEM and OGA to investigate possible synergies and highlighted early barriers to co-location. They suggested a specific area which has been signposted to the SG for consideration.

• A call to work with Ofgem and BEIS create a new approach to the development of grid infrastructure to integrate offshore wind into the energy system.
• Crown Estate Scotland requested close working with the SG to oversee the Offshore Renewable Energy Catapult (OREC) to contribute to overcoming the challenges associated with offshore wind connection and system costs in Scotland. They called for practical action on this topic detailed in the final Policy Statement.
• An Energy Company requested collaboration with stakeholders to reduce barriers to project delivery. They highlighted this would include examining the location of existing and consented infrastructure to ensure this is considered and mitigated during survey and design work for future leasing sites.

Regular seabed leasing

• One called for the SG to realise the full potential of the sector by concluding the ScotWind leasing process to offer a fresh pipeline of development opportunities.
• Crown Estate Scotland outlined their plans for the leasing process. This has been signposted to the SG for consideration.

Collaborative working with environment and marine stakeholders

• One called for a fundamental review of the approach to developing and constructing offshore grids. Another suggested an impact assessment could be achieved by conducting studies with shared responsibilities from stakeholders, and by setting out a plan for a derogation process.

Decarbonisation

• One welcomed the Ofgem decarbonisation programme action plan. Another would like to see the SG develop a carbon calculator for offshore wind.

Specific UK government actions

• One asked for consideration of differentiating between fixed bed and floating wind in the CfD process with a separate strike price for floating.
• One outlined ways the SG can support the UK Government in achieving cost reduction and scale. These involved collaborating to develop a competitive market framework, planning and leasing processes around all UK jurisdictions should allow for commercial floating wind sites, looking to identify joint investments in infrastructure when developing floating wind.
• One energy supplier encouraged the UK Government to undertake assess whether policy and market design is fit for purpose via the Energy White Paper due in 2020, and urged the SG to collaborate with the UK Government on this.

Wildlife concerns

• One call for ensuring constructions are 50km away from migratory bird lanes.
• Instead of the current presumption that all installations and structures are removed at the end of their operational life, one respondent would like the SG to assess on a case by case basis what decommissioning options would deliver the best outcomes for the marine environment and wildlife.
• One environmental charity/campaign group outlined ways in which the developmental process would continue to contribute negative environmental impacts. They suggested that more manufacturing work should take place in Scotland to minimise the impact and that integrating environmental costs at procurement stage could contribute to mitigating these.
• One call for the SG to develop clearer processes if derogations are required at the Plan and Project level, and how this will apply across all UK jurisdictions where the same species may be affected.
• One respondent left a detailed response outlining a series of actions for the SG to consider when expanding offshore wind capacity in Scottish waters to avoid important areas for wildlife.

Capitalising on existing expertise

• A few respondents suggested that the SG should further consider capitalising on existing expertise. In most cases this was in relation to floating wind.
• One respondent suggested that cost reductions for floating wind can be achieved by tapping into skills already present. Another suggested there would need to be sufficient knowledge and expertise present within key stakeholders like; SNH, SEPA, LPA's and HoPS. Another wished for the SG to recognise Aberdeen as a key resource for Scotland when considering trade development and local investment.

Public ownership/control

• One suggested that central to this would be the role of a publicly owned energy company and the Scottish National Investment Bank, outlining these need to have a focus on climate change and a Just Transition. Another would also like to see more government intervention, suggesting financial support and an application of statutory powers to facilitate the growth of local supply chains, investment, and mandate research and development.

Other comments

• There were several other singular responses or calls to action that did not align with a common theme. The calls for action asked; that the SG needed to act urgently to ensure that the publicly owned energy company and the Scottish National Investment Bank are established to deliver an industrial policy. Another call to action was that the offshore wind sector and for the final OWPS considers ongoing policy development related to Scottish infrastructure development by the Infrastructure Commission for Scotland, the work associated with developing National Planning Framework 4 or Ofgem's Decarbonisation Action Plan.
• Two respondents called for clarity; one in relation to the SG's priority areas for innovation in the final Policy Statement to help ensure that activities can be targeted accordingly, in alignment with government priorities. The other would welcome clarity on the process for the HRA in respect of derogations, and the role of the Advisory Group. Another respondent called for evidence-based assessments to allow robust conclusions under HRA's to be made.
• One suggested wind power, both onshore and offshore, is given consideration in the final OWPS particularly regarding its relationship to infrastructure plans for related sectors such as heat and transport.
• A final comment was calling the SG to reject Carbon Capture Storage and Leak (CCS-LEAK) projects such as Acorn at St Fergus.

Q4: What are the key regulatory and cost challenges facing the offshore wind sector?

Comments made by two respondents included:

• Calls for workforce protection: one noting construction should take place in Scotland for the benefit of Scottish workers, and a detailed response for review by the SG discussing employment conditions and immigration
• Requests for appropriate, effective, and creative use of the existing regulatory regime for development and protection of the marine environment i.e. the marine planning regime through the Marine (Scotland) Act 2010.
• Demand for shallower water sites.

Three responses included detailed discussions around specific points which have been signposted to the SG for review. These covered consenting and leasing, Anticipatory Network Investment and a reference to the RenewableUK OCLG Barriers to Growth working group.

Singular comments around challenges included: the need to develop a pipeline of projects to encourage investment in technology; uncertainty on timelines for the consenting process; the need to ensure sufficient ports and harbours are available to support the development of the supply chain; a comment around the industry citing cost challenges as a reason why they should use international rather than domestic supply chains; the need to ensure any drive to cut costs does not lead to a deterioration of health and safety standards; the cost to the UK in terms of expertise and economic benefit when projects are completed overseas; and, the need for storage solutions.

Other individual comments suggesting actions included: a call for the SG to support the fisheries sub-group within SOWEC to complement the work of Marine Scotland; a call to eliminate subsidies for wind power; and, a detailed response related to decommissioning and recycling costs.

Q5: What more can the sector and other key stakeholders do to tackle these?

Points mentioned by two respondents included encouraging the co-ordination of UK wide or cross-sectoral initiatives to avoid any duplication of effort and support for Ofgem's Decarbonisation Action Plan.

Other singular comments included: a call to invest in Bifab; a suggested focus on integrated energy system models; support for SOWEC and the Offshore Wind Sector Deal; the challenge of developing a pipeline for floating offshore; a suggestion that mapping of existing and consented transmission infrastructure on constraint maps so this can be identified at the early stages of a development; and, a call for strategic cabling and grid connections. Referring to the consultation question, one stated that it was a matter for the Government, not the sector to tackle the issues facing the sector.

Q6: What should the key Scottish priorities be in relation to Air Defence Radar, and towards radar mitigation more generally?

Other comments included:

• Two requests that the SG complements regulatory evolution at Westminster through the Scottish planning system.
• Two related to cost: that the cost for a long-term solution are shared by developers and Government departments and that the solution needs to be low cost
• One noting the impact on birds needs to be considered in relation to radar.

Q7: What more can the Scottish Government do, working with industry and other stakeholders, to address 'knowledge gaps' in environmental assessments for potential offshore wind developments?

Comments provided by two respondents included:

• Steps which could be taken to identify, review and update knowledge gaps relating to the ecological impacts of offshore wind.
• Specific comments on funding; one that adequate funding should be available and another that developers should be obliged to carry out and fund work to fill knowledge gaps which are identified.

Other singular responses included:

• Calls for the SG to: urgently provide clarity on the potential for development on the DPOs currently under moratorium; "explore the potential for Scottish projects to follow the derogations route under the Habitats Regulations"; work with environmental charities; and work with trade unions to overcome issues relating to training for staff transferring from offshore oil and gas to offshore wind
• One called for the experience of those who already successfully conduct offshore environmental assessment to be harnessed.
• One highlighted that environmental protection may raise public trust in the industry.
• One suggested a committee with power to assess fines and/or criminal penalties.

Q8: What steps can be taken to improve interactions between offshore wind and other marine sectors?

Comments provided by two respondents included:

• The need for joint working on technical and operational solutions, including knowledge sharing. One provided a detailed response which has been signposted to the SG for review, suggesting best practice guidelines for knowledge exchange and collaboration.
• Comments related to interactions with the fishing industry. One highlighted the need to resolve issues such as abandoned fishing gear and mitigation measures for disruption to fishing. The other called for greater transparency in, and regulatory oversight of, consultations with the sector.

Other singular responses included:

• Calls for: a Marine Nature Fund to strengthen relationships between users; community support funds linked to specific offshore wind projects; and greater clarity about the interrelationships with terrestrial planning.
• A detailed comment calling for a detailed industrial plan to facilitate staff transitioning from oil and gas to offshore wind.
• A concern regarding the exclusion zones around floating turbines.

Q9: How could a competitive market framework that promotes the development of floating wind be developed whilst still retaining value for money for the consumer?

Two called for future marine spatial planning and leasing processes around the UK to allow for commercial floating wind sites to be made available, and one for a commitment to regular seabed leasing rounds that make available commercial floating wind sites.

Many of the other responses to this question called for specific actions. These included two calls for a more co-ordinated a regulated workforce supply chain which supports UK industry, and two calls for a specific target for floating wind for 2030 (one suggested 2GW).

Other singular responses included calls for: projects in +50m water depths to have the opportunity to bring forward hybrid solutions under any future regime to help offset the financing risk of large-scale floating projects; that consideration should be given to how CfD could be adapted to incentivise green hydrogen production; to secure a floating pipeline to encourage investment; investment in infrastructure; and support for offshore wind innovation in Scotland.

Q10: Considering the currently available literature and analysis, what do you consider a successful offshore wind industry in Scotland in the future would look like?

Less frequently expressed views on a successful offshore wind industry included:

• General comments, such as for offshore wind to maximise its supply of all sustainable energy for Scotland or to help meet energy demands.
• One respondent called for the creation of a North Sea Grid
• A suggestion from one respondent that there should be no wind farms at all, advocating for a focus on oil and gas instead.

Q11: What scale of deployment would you estimate or believe to represent a successful outcome, and why?

Less frequent comments in the discussion on rates of deployment for the offshore wind industry included:

• A suggestion from one respondent that there should be no wind farms deployment at all, advocating for a focus on oil and gas instead.
• Aberdeen City Council noted their support for the inclusion of the Draft Plan Options in the East and North East Zones.

Q12: What actions should industry and government take to address the issues described in this section and ensure the most positive future position for offshore wind in Scotland?

There was one suggestion that a holistic approach to the Regional Locational Guidelines would achieve the best result.

Q13: What areas of the Scottish supply chain do we excel at, and what could we do better?

The singular comments about the areas in which the supply chain excels were as follows:

• Existing infrastructure like cable laying, trenching, mooring and electrical controls.
• Logistics, emergency response plans, standards, health and safety and training.
• The subsea supply chain in relation to existing expertise created as a result of offshore O&G.
• That Aberdeen is seen as a centre for excellence internationally and this should continue with the deployment of hydrogen energy and its transport applications.
• One respondent specifically mentioned strengths in geotechnical and geophysical activity as well as oceanography and meteorology. Another highlighted innovations in foundations, cabling, interconnectors, production optimisation, data and communications, surveying, asset development and environmental mitigation.

Singular comments about where the supply chain can improve included:

• Meeting the demand for better ports for construction marshalling bases. Ensuring they are large and deep enough, with good infrastructure connections and located near other services to support construction requirements.
• Developing a hydrogen economy to ensure Scotland remains a leader in the deployments of hydrogen and its transport applications. This could be facilitated through the investment in producing hydrogen at offshore wind facilities.
• Manufacturing technology for surveying and maintaining light detection and ranging (LiDAR) as this is currently imported.

Q14: Where are the new areas that Scotland can develop and exploit a competitive supply chain advantage?

The singular themes in response to question 14 were as follows:

• Increasing manufacturing to capitalise fully in the fixed bottom market.
• A call to demonstrate new technologies for the floating wind market.
• The consideration of employment rights within the OWPS was called for by one respondent. They would like to see all trade unions included in the next SG summit and argued for recognition rights for supply chain operators, including the shipping, offshore technician, and contractor workforce.
• A request for further innovation in data processing and artificial intelligence in SUV's and autonomous vehicles.

Q15: What are the main challenges a company faces when tendering for a contract?

Challenges outlined by one respondent were:

• The short turnaround time at the early stages of a project to understand requirements before submitting a potentially complex response to a tender exercise.
• An issue relating to underwriting liabilities. This respondent would like to see bodies like UK Export Finance or the Scottish Investment Bank offer a service to help suppliers get to UK purchasing bodies.
• One respondent outlined their approach to maximising opportunity for timely and cost-effective delivery of projects; a 'supply chain alignment model'. They suggested it could be rolled out by all developers entering ScotWind and coordinated to ensure a structured programme of engagement between projects and local suppliers.

Q16: Subject to procurement law, what more should government and its agencies do to assist the supply chain secure contracts?

Suggestions outlined by one or two respondents included:

• Two respondents requested that whole life carbon costs should be included in the assessment of project tenders to give local suppliers an advantage.
• Encouragement for the SG to consider the socio-economic impact of tenders run by developers, ensuring they are held to account if benefits in tenders not be delivered.
• A call for more focus on lower tier supply chain capabilities.
• Ensuring universities teach students the skills necessary for the supply chain.
• A request for government to provide guarantees to companies with a 'weak balance sheet'.
• Guaranteeing that 80% of content in project work is derived from the UK.
• Consideration of how procurement will change because of EU Exit and how this will impact subsequent relations with trade partners.
• Adaption of the Offshore Wind Supply Chain Development Statement to include a regulation for Scottish workers to covered by collective bargaining agreements with UK trade unions in the Tier 1-3 contractor supply chains during all project phases.
• Offering flexibility in existing procurement strategies run by developers and reducing previous experience proof requirements was suggested to assist the supply chain.
• Introducing an assessment in leasing rounds of the carbon impacts of the manufacture, transport, and construction of all bids.

Q17: What are the key skills issues and gaps facing the sector over the coming years, in the short and medium term?

Singular comments included:

• A comment that the issue is not a skills gap but the lack of small business being allowed to tender and be awarded work.
• The difficulties of sourcing the right skills mix, especially in STEM and given the competition with other large infrastructure projects such as High Speed 2.
• A request to properly resource public bodies such as Scottish Natural Heritage and Marine Scotland.
• A call to end waivers from immigration rules provided to the industry by the UK Government for non-EEA crew to work on construction.
• One highlighting the recommendations in a report by Energy & Utility skills.
• One who expressed their belief that if jobs are created then the required skills will follow, and that any existing gaps are not seen as constraining future growth.

Q18: What more should government and the sector do to build on the progress made in recent years?

Comments provided by two respondents included:

• Suggestions to attract more young people to the industry, such as high-profile campaigns highlighting the potential for a lifetime career, apprenticeships and sector representatives pairing with educational organisations.
• Calls to support the development of local supply chains.
• Ensuring Scottish / UK firms have proper share of the supply chain.
• The need to promote opportunities and vacancies in the energy sector.
• Factoring in competition for skills with other industries such as water production and food and drink. Similarly, another commented on the need for a holistic approach across the education sector considering all economic activity in Scotland.

Singular comments included:

• Individual calls for: more early stage engagement between SG and communities; a reduction in the timescales of major offshore developments; the establishment of an 'excellence programme' bringing together the best individuals from offshore wind and other industries; and, public ownership, direction and control of the industry to ensure Scotland benefits from the transition to green energy.
• Challenges to building progress, such as cuts to education, the lack of a coordinated lifelong learning programme in the UK.
• Support for increasing gender diversity and BAME representation and a request that campaigns to address these issues are monitored for effectiveness.
• Creating a transparency platform where useful non-confidential information about offshore wind is uploaded for research or analysis – to promote best practice and improve cost-effectiveness.
• Three respondents provided a very similar comment which went beyond the scope of question 18 by highlighting other actions for Scottish Government. One respondent gave the same response to questions 17 and 19. These highlighted priority areas for innovation and cost reduction: disseminating lessons learned to the industry, increasing use of automation for inspection and repairs e.g. use of drones, minimising the use of material (steel and grout) on fixed bottom structures, and creating support structures and target groups for floating offshore wind to facilitate supply chain development.

Q19: What can Scotland learn from the approach taken in other countries around the world in this area? Are there examples of best practice you can share?

Two respondents commented on research: one asked the SG to take account of the findings of Vattenfall's European Offshore Wind Deployment Centre's (EOWDC) Research Programme, and from the St Abbs Research Station; the other argued for more research into this area so learnings could be promoted in the industry.

Singular comments included:

• Potential learnings from adult education provision in European countries.
• A call for the UK and Scottish Governments to urgently explore the potential to devolve CfD to Scotland.
• Highlighting other examples in UK industry where 'gold-plating' the workforce will add further cost and barriers to workforce mobility.
• A request to consider skills growth as a sector.

Q20: What can the Scottish Government most usefully and feasibly do to build on the innovation support previously and currently available?

Two respondents made specific comments in relation to collaboration in research. One suggested initiatives to de-risk their application and bridge the gap to commercial adoption. Another called for closer alignment between innovation activities in the oil and gas and offshore wind sector to ensure synergies can be realised to the benefit of both.

Two organisations based in Aberdeen asked the SG to recognise and support the OGTC as a 'technology bridge' between the O&G and offshore renewables sectors.

Singular responses to question 20 included:

• One respondent left the same detailed response to questions 20 and 21, where its two main points were highlighting a lack of long-term revenue payments for pre-commercial floating wind projects and an over-reliance on EU innovation support, access to which is under threat from EU Exit. This response has been signposted to the SG.
• One argued for the SG to enable SMEs to tender for projects. This respondent made the same call in questions 21 and 22.
• There was support for the SG's willingness to consider test and demonstration projects as providing a significant opportunity for Scotland's commercial position.
• One urged the SG to ensure appropriate recycling would take place after decommissioning, specifically to consider foundation types or designs that would facilitate removal or repowering.
• A suggestion for campaigns to raise awareness and understanding of the offshore wind industry with the public.
• One specifically called for investment in a building programme for foundations, jackets, turbines, and vessels.

Q21: How can we support technologies and developments which reach a viable stage between leasing rounds and Contract for Difference (CfD) auctions?

Two respondents recommended that the SG should consult with industry technology developers, including the OGTC, and suggested that a partnership approach could support development.

Singular comments were made in response to this question, including:

• A desire for the creation of a publicly backed developer, allowing innovation to flourish without the price guarantees and incentives needed for private sector firms.
• That the CfD framework is too rigid in its approach to development, urging the UK Government to recognise that a broader strategy emphasising innovation is necessary to achieve targets.
• Requests for oversight to ensure that key bodies do not monopolise investment, and to facilitate demonstration sites between leasing rounds.

Q22: Where respondents believe that scope remains for innovation in fixed offshore wind, what areas should be prioritised?

Two responses were received on each of the following development issues:

• Streamlining fabrication to be developed by automated welding.
• Corrosion protection.
• New technology that safely lifts technicians onto wind turbine platforms.
• Requests for the SG to prioritise the automation of inspections and repairs. One suggested that this could link to the introduction of artificial intelligence and unmanned autonomous vehicles.
• Suggestions that deep-water technology should be supported as shallower and closer sites reduce. One also requested this innovation should follow the expertise of North Sea installation in the offshore O&G industry.
• That fixed projects are still in the early stages of development due to changing deployment conditions and market demands. Respondents requested continued innovation in this area and point out that innovation can mean improvement to current technology as well as new creation.
• For the SG to collaborate with the developers when considering innovation.

The other singular comments in relation to this question included requests for:

• CCTV monitoring to prevent harm to wildlife, specifically bat and bird populations.
• Innovation in digitization, robotics, and subsea engineering.
• The development and deployment of new technologies which enable large scale storage and integration of electricity.
• Synergies with the O&G sector supported by offering the transfer of skills and training of the workforce.
• Construction and installation optimisation.

Q23: What actions should be taken to address the key challenges facing the uptake of commercial scale floating in Scotland?

The comments received from two respondents are as follows:

• Offers of support for the SG in their suggestion of creating a floating wind specific CfD mechanism.
• Requests for the SG to create an environment around floating wind that reduces risk and creates more certainty, highlighting that clarity and communication about SG ambitions and targets including consenting and lease procedures and timescales.
• Specific requests for support for deep water hybrid projects. One suggested that this could enable more timely floating deployment by being built on the back of commercial financing products for fixed assets.
• Calls for future marine spatial planning and leasing processes to extend around the whole of the UK to allow for more commercial floating wind sites.

Comments in relation to Hydrogen received from two respondents were:

• The opportunity to store hydrogen offshore and onshore in depleted fields, to balance inter-seasonal demand variations.
• More research into the potential for Hydrogen's role in the transport sector. One called for the creation of demand for renewable hydrogen by encouraging new and existing users of hydrogen to switch to renewable hydrogen.

The other singular comments in relation to this question are as follows:

• A request that the SG facilitates large scale green hydrogen production. The respondent outlined this would ensure power can be exported from projects located from areas of best resources, not just those close to existing grid infrastructure.
• One trade union expressed that employment and training opportunities for Scottish workers on floating offshore wind projects should have recognition agreements with the relevant trade unions, including in the shipping supply chain.
• There was an observation that successful field demonstration would be vital in determining whether or not industry will be able to adopt particular technologies, both floating and fixed-bottom.
• An environmental/campaign group called for an ecological survey of deeper water sites to validate the final OWPS and offer clarity environmental impacts. They would also like the SG to lead in a monitoring and research programme to achieve the scale of deployment required and reduce costs for individual developers.
• A call for the SG to support SMEs in tendering for projects, especially those who specialise in offshore floating wind.
• One requested that commercial scale areas with the potential for future phases are made available for development.

Q24: What can be done, on the part of government and / or others, to strengthen and benefit from the synergies with a) hydrogen and b) the oil and gas sector?

Two respondents urged the SG to recognise and utilise the already established synergies present in Aberdeen. They offered examples of the synergies within both hydrogen and O&G in the local authority area which have been signposted to the SG for consideration.

Singular comments in relation to strengthening and benefitting from synergies in hydrogen:

• A request that sites should be assessed based on their suitability to support both wind and hydrogen operations.
• One highlighted an opportunity for diversifying Scotland's hydrogen output, suggesting the production through water electrolysis which is integrated into an offshore wind turbine installation and transported ashore via pipelines or ships.
• A suggestion that excess hydrogen could be sent abroad to help establish Scotland as an international supplier of hydrogen.
• The potential for harnessing hydrogen energy to heat Scottish homes, which could reduce the carbon footprint of the energy sector.

Singular comments in relation to strengthening and benefitting from synergies in O&G:

• One trade union urged the SG to consider the carbon imprint of hydrogen production. They gave examples of where this had not been done successfully.
• Requests for: the SG to make relevant areas of seabed available; links between offshore wind and O&G sectors are maintained through Offshore Renewable Energy Catapult and Oil and Gas Technology Centre; and, that publicly funded projects make their results openly available to facilitate knowledge exchange.