Offshore wind policy statement: consultation analysis

1. The current position

This chapter presents an analysis of responses to questions 1, 2 and 3 which relate to the current position of offshore wind in Scotland.

A sufficient platform

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?

Two fifths of respondents (19/48) answered 'no', one fifth (10/48) answered; 'yes', and the remainder (19/48) did not answer the question. Over three quarters of respondents (37 out of 48) provided explanatory comments, which form the basis of analysis set out below.

Support for the policy statement

A major theme across responses was recognition of the importance of the OWPS in delivering climate change goals. Most respondents welcomed the policy statement, believing it would contribute to national targets. For example, two respondents commented on Scotland's current performance in the offshore wind industry; suggesting the OWPS was bold, ambitious, and necessary to achieve Net Zero by 2045 targets. In this discussion two respondents also voiced support for the Sectoral Marine Plan.

Action to meet goals in relation to infrastructure and planning

An equally prevalent theme was further actions or issues for the Scottish Government (SG) to address to achieve Scotland's climate change goals. Key concerns were around infrastructure and planning, including grid capacity. For example, discussions included a need to augment grid capacity to utilise the full potential of offshore wind. A few respondents called for grid reinforcements as a holistic approach to facilitate investment.

Further seabed leasing rounds, or additional leasing of seabed rights, were described as necessary for the SG is to achieve the target of deriving at least 50% of Scotland's total energy needs from renewable sources by 2030. A need for improved transmission networks and changes to charging regimes were also described.

Some commented on the value of offshore floating wind, arguing that it would be essential in realising climate change goals, and the SG was urged to consider alternative technologies in addition to offshore wind, such as clean baseload generation and new nuclear technologies. The importance of streamlining consenting and Contracts for Difference (CfD) awards was discussed, as well as calls for CfD auction rounds to facilitate earlier deployment of offshore wind. Finally, there were a few comments urging the SG to develop and deploy blue and green hydrogen.

Calls for more ambitious targets

A common theme was calls for more ambition from the SG. Specifically, there were suggestions to raise the targets above the stated 8GW of offshore wind in Scotland by 2030 and 30 to 35GW by 2045. Many described Scotland's current capacity and argued that achieving net-zero emissions would require an increase in renewable power generation. Some respondents noted they welcomed the targets set by the UK Government (40GW by 2030) and suggested that the current pipeline in Scotland would not be sufficient in achieving targets. A few respondents called for targets in Scotland to align with the Committee on Climate Change targets of 75GW in the UK by 2050.

Action to meet workforce and supply chain development goals

A few respondents discussed offshore wind as an economic opportunity for Scotland but suggested the current pipeline would result in minimal benefits for Scottish workers. They called for training for Scottish workers to ensure projects can be delivered locally.

Meeting climate change goals and considering the wider environmental context

The key role for offshore wind in achieving Net Zero by 2045 was commented on by some respondents. A few respondents described particular environmental issues for the SG to consider, such as the protection of marine animals and biodiversity.

General comments about Scotland's renewables sector

There were some general comments about Scotland's renewables sector; most focused on the need to expand growth in all renewable sectors to meet the climate change goals.

Actions around mitigating the impact to wildlife

A few organisations signposted the SG to potential actions to mitigate the impact of the development of offshore wind on wildlife or the marine environment.

Suggestions that the current activity is insufficient to meet climate change goals

Some respondents requested a significant increase in the planned deployment of offshore wind and linked this to the opportunity to realise commercial scale floating wind projects. These views are discussed in more detail in question 11.

References to the Sectoral Marine Plan (SMP)

There were a few mentions of the SMP. For example, some encouraged the SG to continue considering the SMP alongside the OWPS, taking a holistic view.

Calls for more clarity

A small number of respondents called for more clarity in the final OWPS in relation to; challenges associated with connection and system costs, process for the Iterative Plan Review, future leasing rounds, project-level consideration of derogations under imperative reasons for overriding public interest (IROPI), and a clearer approach to key policy areas such as planning, environmental assessment, supply chain, networks and innovation.

Visions and Aspirations

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

One fifth of respondents 10/48 answered 'yes' to this question, almost two fifths 17/48 answered 'no', and the remainder 21/48 did not answer the question. Over three quarters of respondents (38) provided explanatory comments in response to this question.

Calls for higher deployment targets

Most prevalent across comments were calls for more ambitious targets for offshore wind, specifically increasing them above the 8GW by 2030. These views are described in more detail in the discussion of question 11, which asked respondents to describe their preferred deployment rate.

A demand for greater ambition

The second most prevalent theme was a call for the SG to go further and create a more ambitious vision to realise the targets set out in the OWPS. Most of these comments were focussed on the environment; respondents would like to see more ambition to ensure offshore wind development is sustainably managed to conserve and protect the marine environment, landscape and seascape while meeting the outlined targets.

A further two respondents would like to see a greater focus for Scotland to compete internationally. One suggested that by limiting its ambition, Scotland could miss out on the social and economic benefits of increased deployment across the UK.

Support for the visions and ambitions described in the policy statement

Many respondents voiced support for the 2030 visions and aspirations, which they described as 'realistic', 'sufficient', 'a huge opportunity', 'ambitious' and 'world-leading'. Some of these comments were general in nature and discussed the OWPS as a whole. Others supported specific elements of the aspirations, as presented in Appendix 1.

Scotland's potential gains from offshore wind were described by a few respondents. They observed the potential for increasing capacity in the local supply chain, job creation, export potential and the ability for Scotland to compete on an international scale.

Expressions of support with calls for action

Another common theme was actions to realise the visions and aspirations. A small number of respondents observed the visions would need to have appropriate action and implementation, but did not describe accompanying actions. Others did specify actions for the SG, for example a few suggested achievement of the visions would require infrastructure development and improvement.

Calls for specific timelines in relation to planning

Some respondents urged the SG to create clear timelines to ensure that the visions and aspirations can be realised. Linked to this, a small number called for the timely deployment of new projects. They stressed that appropriate and sufficient planning would be necessary to achieve targets.

Collaboration between industry and the Scottish Government

Some suggested that collaboration with industry would be essential to realising the visions and aspirations. For example, one respondent from the wider energy industry explained the importance in relation to the construction of sites due to the Draft Plan Option (DPO) areas currently available having constraints. Another would like collaboration to identify accessible sites for development. There were a few additional calls for an accompanying plan from the SG to outline how it plans to work alongside industry and stakeholders.

Welcoming the Scottish Offshore Wind Energy Council (SOWEC)

A small number of respondents described their support for the creation of SOWEC. These responses highlighted the benefits of having the council such as:

• providing coordination capabilities,
• accelerating the development of the offshore wind industry,
• providing a focus on not only achieving the targets but on wider related goals such as local manufacturing and supply chain.

Aligning with the SMP

Some respondents stressed that alignment with the Sectoral Marine Plan would be important to achieve the visions. Two respondents made a similar observation that if the SMP did not align, the SG would create a siloed approach to offshore wind planning. Another respondent welcomed the target around building knowledge and accessibility. They felt that there were knowledge gaps within the SMP regarding impact of identified risks and the effectiveness of corresponding mitigation measures.

Actions

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

There were 45 responses to question three. This question received the most responses of all the consultation questions, indicating this area was a key interest for stakeholders.

Contracts for Difference

Most prevalent in responses to this question were comments about the Contracts for Difference (CfD) mechanism. Many of these called for a move to annual CfD auctions. It was suggested this would support the ambitions laid out in the OWPS while providing security and certainty for offshore wind developers and supply chain in reaching those targets. A few respondents noted that increasing auctions would reduce pressure on consenting timeframes and smooth out the delivery pipeline.

Many of these respondents also discussed floating wind in relation to amending the CfD mechanism, which is reserved to and operated on behalf of the UK Government. For example, a few suggested that the CfD should include a minimum quota for floating wind projects to offer certainty for the emerging floating wind industry. A small number of respondents stated their support for the proposals contained in the consultation about adapting CfD mechanisms particularly, offering floating wind its own 'pot'.

Supporting the Scottish supply chain

Another major theme centred on supporting local supply chains. Respondents urged the SG to ensure that work is not exported overseas. They argued this would maximise the benefits to the Scottish economy and offer employment opportunities within Scotland. Some specific points followed these general comments and these are outlined below.

A few trade unions provided similar responses which focused on the workforce. They urged the SG to develop a robust 'just transition' framework to support skilled workers' transitions to new jobs in the low carbon sector. There was also a request for a requirement on developers to contain a minimum quota for work, both employees and development, taking place in the UK.

Another point from trade unions was the request for requiring offshore wind developers to sign up to the Fair Work Framework as a condition of receiving CfDs and any other public funding.

Two respondents, both independent developers, requested a balance in favour of independent developers in the initial ScotWind leasing round. They described ways in which these types of developers offer positive outcomes for supply chains, for example, high local content and socio-economic enablers. A few suggested supply chain obligations should be careful and realistic so as not to impose too heavily on developers.

Regulations

Several responses focused on regulations. For example, some respondents suggested that regulations and policies should promote equity for all jurisdictions in the UK to ensure that Scotland is able to fairly compete in the offshore wind market. Two observed the importance of SG regulatory alignment with elsewhere in the UK.

Comments highlighted the higher transmission charges Scotland faces relative to projects located in the south of the UK, which place Scottish projects at a relative disadvantage. A few urged the SG to liaise with the offshore wind industry, network companies, environmental agencies, and other stakeholders to develop a transmission regime and provide suitable landing points for future connection developments to be viable.

Advocating for an effective and timely planning regime was suggested by some respondents. They called for consistent leasing, planning and consenting system leading to reduced timescales from development to deployment.

A small number called for the development of strategic export routes for new offshore wind power from Scotland, while supporting new approaches to network development and supporting new entrants to the market.

Collaborative working with industry

Some respondents commented on the need for collaborative working within industry stakeholders to maximise offshore wind potential. The primary call was for the SG to ensure a consistent and collaborative approach to identifying sites for development including suitable landing points for transmission, while protecting the marine environment.

Regular seabed leasing

Another prevalent theme was a suggested action for the SG and Crown Estate Scotland (CES) to ensure regular seabed leasing. There were calls to increase the scale and pace of deployment and provide clarity around the frequency of future ScotWind leasing rounds to maintain consistency in the supply chain. A few of these responses specifically called for leasing rounds every two years, supporting CES proposals, and of circa 10GW each. Other responses related to seabed leasing were as follows:

• A few respondents asked for a commitment to extend regular seabed leasing to 2050 to factor in the potential that all projects will not be developed successfully.
• There were a few calls for the identification and provision of a pipeline of new seabed sites for development through regular leasing rounds for offshore wind which would require a new approach to marine spatial planning.
• Two suggested the 10GW capacity cap creates a barrier to achieving ambitions. They called for clarity about how the cap impacted the leasing process.

Planning

There were multiple comments on the planning process, specifically on linking the SMP with the OWPS. Renewables UK's comments were echoed by other respondents; they reflected upon the introductory chapter of the consultation paper, where the Minister's intentions to make Scottish planning 'efficient and effective' were outlined. They highlighted that this will require a leasing, planning and consenting regime that is consistent and robust to ensure the right offshore construction projects are developed to reach and exceed the Scottish Offshore Wind Energy Council's (SOWEC) 8GW offshore wind target. A few respondents went further to call for clarity around how the roles of SOWEC and the SMP will be coordinated to ensure consistency.

Further to this, a few respondents suggested the planning process could also be made more effective through the Iterative Plan Review process which would allow more regular input from industry and stakeholders, and for the coordination of necessary research and survey work across DPO's. Another respondent suggested an increase in areas for development in the DPO areas in the SMP.

Another minor theme in these responses was that the marine planning process could be more aligned and integrated with the terrestrial planning process. One respondent suggested this could "enhance cooperation and sharing of resources, as well as addressing common issues such as habitat protection and grid connections."

Some respondents also warned the SG not to create an over precautionary framework for planning, suggesting that this would prevent the sustainable development of offshore wind at the rate that is necessary to reach net zero targets.

A few respondents noted uncertainty over cumulative ornithological impacts highlighted in the SMP as a potential barrier to development. They observed that many potential zones are subject to high ornithological constraint, significant additional research or survey work. It was suggested that addressing these constraints will be vital to providing sufficient pipeline for deployment in Scotland. Some respondents argued that ornithological impact assessments should be consistent across the UK. A few supported collaboration and knowledge sharing between Marine Scotland, Marine Scotland Science and BEIS to further explore a UK wide approach.

Collaborative working with environment and marine stakeholders

There were many calls for collaboration across sectors to safeguard the environment. In this discussion, a small number of respondents urged for a coordinated and collaborative approach to managing access and marine use for multiple sea users. They highlighted that the cross-sector consultation approach to SMP could lead to more robust resolutions, such as agreed common compensation policies. The SG's role in leading this approach while also overseeing the delivery of offshore wind deployment targets was described. Two called for a strategic level approach to Marine Spatial Planning and the Habitats Directive derogation process across all UK jurisdictions and within industry.

Decarbonisation

Some urged the SG to focus on the potential for Carbon Capture and Storage (CCS) and Hydrogen to achieve net zero. A small number left detailed comments explaining how these methods would work and why they are necessary. A few respondents called for the development of offshore grids in relation to decarbonisation. Views on offshore grids are explored in detail at analysis of responses to the following question.

Specific UK government actions

Specific actions for the UK government to take, primarily in relation to the CfD scheme, were shared by some respondents. For example, a few called for the UK Government to support Scotland's offshore wind sector by revising the scheme, providing yearly auctions, and providing separate allocations for offshore floating wind.

Address environmental / wildlife concerns

There were some comments encouraging the SG to address environmental and wildlife concerns. These themes were all singular responses and are outlined in Appendix 1.