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Blue Seas - Green Energy A Sectoral Marine Plan for Offshore Wind Energy in Scottish Territorial Waters Part A The Plan

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1. Introduction

1.1 Blue Seas - Green Energy - the Sectoral Marine Plan for Offshore Wind Energy in Scottish Territorial Waters is the strategic planning document for the development of offshore wind energy in Scottish Territorial Waters. It contains proposals for development at the regional level up to 2020, 2030 and into the longer term.

Strategic Aims

1.1.1 The Plan is based on strategic aims which are applicable across its geographical scope. These are:

  • Maximise the contribution that offshore wind energy makes to renewable energy generation in Scotland;
  • Maximise opportunities for economic development, investment and employment;
  • Minimise adverse effects on people, other economic sectors and the environment; and
  • Deliver offshore wind while complementing other forms of marine energy generation.

1.1.2 This Plan is an integral part of a series of initiatives which include:

  • Scotland's Offshore Wind Industry Route Map,
  • The National Renewables Infrastructure Plan ( N-RIP), and
  • Securing the Benefits from Scotland's Next Energy Revolution

1.1.3 These initiatives have been put in place to help facilitate green energy development in the marine environment. Additionally this Plan seeks to deliver Scottish Ministers' policies for green energy, thereby helping to meet our carbon reduction targets 5. The Plan underpins the promotion of economic development and competitiveness for Scotland and has been built using environmental and socio-economic assessments and consultation, both public and sectoral, as marine plan making tools.

The Benefits

1.1.4 Scotland has considerable potential for offshore renewable energy developments. Estimates indicate that Scotland has up to 25% of Europe's offshore wind potential 6.

1.1.5 From an environmental perspective, this Plan recognises offshore wind as an integral element in Scotland's contribution towards action on climate change. Emissions of green house gases (ghgs) should reduce through a shift from the use of carbon based fossil fuels to the production of cleaner and greener energy. Scotland surpassed green energy targets for 2010 and we are on track to also exceed EU, UK and our own higher targets for green energy and carbon emission reductions by 2020, 2050 and beyond.

1.1.6 The large scale development of offshore wind also represents one of the biggest opportunities for sustainable economic growth in Scotland for a generation. Offshore wind developments within Scottish Territorial Waters and Offshore Waters could result in projected investment in Scotland of approximately £7.1bn over the next decade and the creation of upwards of 28,000 direct jobs in Scotland by 2020 7. The Plan recognises that ports and harbours present viable locations to service the associated construction and maintenance activities. Scotland is also well placed to capture one third of the total UK supply chain market, potentially securing an additional £100bn of investment 8. Scottish research institutions provide a base of academic excellence for delivering technological advancements and technology transfer and are also well placed to benefit from the creation of this new industry around Scotland.

1.1.7 The development of offshore wind will also make a significant contribution to energy security as it will enable the supply and generation of energy within and for Scotland. There is potential to deliver around 5 Giga Watts ( GW) of offshore wind energy within Scottish Territorial Waters plus the potential to generate 4.8 GW of electricity for two Round 3 sites in Scottish Offshore Waters, before 2020. There is significant additional opportunity within Scottish Territorial Waters through the consideration of the medium term areas of search. As further assessment work is progressed, there may be potential to progress sites within these areas for delivery in the short or early medium term. In addition, there is significant opportunity for further offshore wind development within the Scottish Offshore Waters in both the short and medium terms. However, the pursuit of renewable energy in Scottish Territorial Waters should be balanced to ensure the health and diversity of the marine environment and the ability of people to profit from and enjoy the marine environment.

The Challenges

1.1.8 Development should be both sustainable and seek to accommodate public and community views. This Plan identifies national and regional issues for offshore wind development. It also recognises the role Marine Licensing will play and highlights environmental, socio-economic and public concern issues which will require further consideration as the Plan is progressed. These issues have been identified through the application of a set of strategic marine planning tools. Project level assessments will be informed by Strategic Environmental and Socio-Economic Assessments, Habitats Regulations Appraisal and the responses to the significant consultation on the draft Plan. A Consultation Analysis Report with Addendum was produced to document the views of people, communities, sectors, statutory and non statutory environmental bodies, industry bodies, coastal forums and Local Government Planning Authorities. This allowed for Ministers to be fully informed of the issues arising from consultation. The Consultation Analysis Report and Addendum have been published 9.

1.1.9 From an economic perspective, Scotland has to compete with the rest of Europe and globally to maximise its share of the renewable energy market. This Plan represents an early opportunity to identify key strategic issues and potential mitigation measures in order to help avoid unnecessary delays in the later stages of the development process when tackling such issues could prove more challenging. As a consequence, this should contribute to the competitiveness of Scotland as a location for offshore wind development as it will be made it clear to developers and supply chain companies where development is possible, at what overall timescales, what the main challenges will be and where and what further opportunities Scotland can provide.

Key Legislative and Regulatory Drivers

1.2 The key legislative and regulatory drivers for the development of offshore wind in Scotland are associated with:

  • Marine Planning;
  • Mitigating Climate Change through Green Energy; and
  • Environmental Assessment and Marine Licensing

Marine Planning

1.2.1 A regulatory system for Marine Planning was introduced at the UK level through the Marine and Coastal Access Act 2009. This requires that marine plans are prepared for the UK marine area (0 to 200 nautical miles). The devolved administrations (the Scottish Government, the Welsh Assembly Government and the Northern Ireland Executive) have jurisdiction over marine planning matters from 0 to 12 nautical miles. In accordance with the 2009 Act, the UK Government and devolved administrations have prepared a joint Marine Policy Statement ( MPS). The MPS provides the framework for preparing Marine Plans and decision-making in relation to the marine environment, and establishes policies and objectives for specific sectors and activities.

Fig.1 Marine Planning Legislative and Policy Framework

Fig.1 Marine Planning Legislative and Policy Framework

1.2.2 In Scotland, the new legislative and management framework for the marine environment is established by the Marine (Scotland) Act 2010. As previously noted, the Scottish Government has jurisdiction over marine planning matters from 0 to 12 miles from the coast. For the purposes of marine planning, the marine area from 12 to 200 miles from the coast (Scottish Offshore Waters) is executively devolved to the Scottish Ministers. The Marine (Scotland) Act 2010 allows for a system of regional marine planning to be developed for Scottish waters. The Regional Plans will be directed by the objectives and policies of the National Marine Plan.

1.2.3 The Sectoral Marine Plan for Offshore Wind in Scottish Territorial Waters will be integrated into and inform this emerging marine planning framework. The requirement to develop the Plan is not a statutory provision of related marine legislation. The Plan is intended to complement both the National and Regional Marine Plans through the provision of relevant information and assessment for specific areas of marine planning. It will also be complemented by Regional Locational Guidance which will provide more prescriptive information for developments in relation to the potential for development in marine areas of resource acknowledging environmental and sectoral constraints.

Climate Change and Energy

1.2.4 Climate change and the requirement for alternative sources of energy 10 are important drivers for the Plan. The Climate Change (Scotland) Act 2010 establishes a long-term framework to cut greenhouse gas emissions by at least 80% below 1990 levels by 2050, with an interim target of 42% by 2020. In addition, the Scottish Government has made a commitment to generating 20% of energy demand, incorporating 80% of electricity consumption from renewable sources, by 2020.

Environmental Assessment

1.2.5 The Offshore Wind Plan was subject to the requirements of the Environmental Assessment (Scotland) Act 2005 11. This legislation requires the Scottish Government to carry out Strategic Environmental Assessment ( SEA) of its Plans, Programmes and Strategies that could generate potential significant environmental effects. The SEA has played a prominent role in the development of the Plan by identifying key environmental receptors, mitigation measures and providing an early indication of issues to be addressed at the project level.

The Development of Options

1.3 The Offshore Wind Sectoral Marine Plan contains options for development at the regional level to 2020 and beyond. These options are classed as:

  • Short-term Sites - up to 2020
  • Medium-term Areas - up to 2030

Fig.2 (below) contains a map of the initial sites and areas

The Short-Term Sites

1.3.1 The seabed within Scottish Territorial Waters is part of the Crown Estate. The Crown Estate Commissioners ( CEC) are the commercial manager of the seabed within UK and Scottish Territorial Waters. CEC has the responsibility for awarding sea bed leases and Exclusivity Agreements for offshore wind sites. Developers proposing to take forward offshore wind development have to secure a sea bed lease.

1.3.2 In 2009, CEC undertook the first stage of lease bidding and awarded Exclusivity Agreement awards for 10 sites 12:

  • Solway Firth
  • Wigtown Bay
  • Kintyre
  • Islay
  • Argyll Array
  • Beatrice
  • Inch Cape
  • Neart na Gaoithe
  • Forth Array, and
  • Bell Rock

1.3.3 The Exclusivity Agreements allow offshore wind energy developers to take the first step towards securing a commercial lease.

The Medium-Term Options (Areas of Search)

1.3.4 In response to the CEC leasing round and to support the sustainable delivery of the potential for offshore wind around Scotland, the Scottish Government made a commitment to produce a Strategic Environmental Assessment ( SEA) of the potential for offshore wind development in Scottish Territorial Waters, to include the 10 site options. The draft Plan was developed to accompany the Environment Report, and thereby ensure that those reviewing the assessment findings were clear about the emerging proposals.

Fig. 2 Short-term Sites and Medium Term Areas of Search (draft Plan)

Fig.2 (below) contains a map of the initial sites and areas

Constraint and Opportunity Mapping

1.3.5 In addition to the short term sites identified by CEC, the Scottish Government used consultants to undertake constraint and opportunity mapping in order to identify further medium term options, within which there could be further potential for development beyond 2020. As the map illustrates, a very significant amount of development potential exists within Scottish Territorial Waters.

1.3.6 The CEC marine spatial planning model, Marine Resource System ( MaRS), was used to identify options, by mapping environmental and technical constraints as well as resource opportunities. 30 medium term options (areas of search) were identified. These areas have been identified using MaRS as a scoping tool and were the least constrained areas with sufficient offshore wind resource.

1.3.7 The 30 medium term options were then subject to environmental assessment, using the strategic environmental objectives developed with the Consultation Authorities. 2 medium term options were not deemed suitable in SEA terms because of their proximity to 'Neolithic Orkney'. A further 2 were deemed unsuitable because of their proximity to St Kilda and one was deemed unsuitable because of its proximity to the Beaufort's Dyke munitions dump. The remaining 25 medium term options are considered to be areas of search for further development before 2030. The Scottish Government would not expect any of these options to be developed by 2020 but will seek to explore these options further, initially through constraint and opportunity sensitivity testing using the MaRS model. The Scottish Government will apply further more detailed marine planning techniques including regional locational guidance, in the same manner that we developed for marine renewables development in the Pentland Firth and Orkney Waters and under The Saltire Prize Programme, to steer future lease bidding and help with licensing procedures. It is possible that given the potential for offshore wind development in the medium term options that some of them could prove suitable for advancement in the short term or for early delivery in the medium term.

The Medium Term Areas of Search were identified on a regional basis as follows (see Fig.2):

  • East - E1
  • North East - NE1, NE2, NE3
  • North - N1, N4, N5, N6, N7, N
  • North West - NW2, NW4, NW5, NW6, NW7, NW8
  • West - W1, W2, W3, W4
  • South West - SW1, SW3, SW4, SW5, SW6

Plan Methodology

1.4 Strategic Environmental Assessment ( SEA) is a strategic tool for assessing the effects of plans on the environment at an early stage in the process. Habitats Regulations Appraisal is used to determine if there could be significant effects on Natura 2000 sites. To take into account social and economic considerations, a Socio-economic Assessment was also taken forward. The findings have been brought together, to provide a cross sectoral and holistic perspective. Together, they provide the main tools which can be applied to deliver a Marine Sectoral Plan and essentially constitute a Sustainability Appraisal approach to the development of the Plan, incorporating:

  • Strategic Environmental Assessment;
  • Habitats Regulations Appraisal;
  • Socio-economic Assessment; and
  • Consultation Analysis.

Fig.2 The Strategic Plan Making 'Tools'

Fig.2 The Strategic Plan Making 'Tools'

1.4.1 The consultation responses to the draft Plan proposals and the Environmental Report have been analysed and summarised 13. This analysis was used to inform the socio-economic assessment work. In addition, a representative cross sectoral advisory group was formed to ensure stakeholder involvement in the socio-economic assessment. The stakeholders included the relevant Planning Authorities, Scottish Fishermen's Federation and the Chamber of Shipping. In the case of the Habitats Regulation Appraisal the steering group consisted of Scottish Natural Heritage, Joint Nature Conservation Committee, Scottish Environment Link, Royal Society for the Protection of Birds, Whale and Dolphin Conservation Society, Crown Estate Commissioners, Scottish Renewables and the Scottish Government. This level of public, sectoral, statutory and environmental body representation and engagement within the Socio-economic Assessment and HRA combined with the extensive consultation on the SEA Environmental report and draft Plan has helped to ensure that appropriate consultation was undertaken within the plan development process to the Sectoral Marine Plan and Post Adoption Statement.

Strategic Environmental Assessment

1.4.2 SEA is intended to increase the consideration of environmental issues during decision making related to strategic documents such as plans, programmes and strategies. For the Sectoral Marine Plan, it has been used to test and comment on development proposals from a strategic perspective or, in the case of the medium term options, as a tool to identify strategic environmental constraints in order to steer future development. The process is applicable to strategic and, to some extent, regional level issues. It should not be used to pre-empt project level environmental assessment. As a result, the SEA findings and associated opinions arising from the consultation process have led to broad recommendations for the Plan as a whole. These findings can also, where appropriate, be used as a starting point for further more detailed data collection and environmental assessment, either for strategic review at a regional level or for project level assessment.

Habitats Regulations Appraisal

1.4.3 The SEA identified a number of potential effects from the draft Plan on Natura sites and their qualifying interests. To explore these issues further, The Scottish Government was required to undertake a Habitats Regulations Appraisal ( HRA) of the Plan to determine whether it would have a 'likely significant effect' on sites designated for their nature conservation interest at an international level. This requirement extended to Special Areas of Conservation ( SACs), Special Protection Areas ( SPAs) and Ramsar sites. The HRA was carried out for the short and medium term options identified within the Plan.

Socio-economic Assessment

1.4.4 The Scottish Government responded to the views that came forward in consultation workshops and written responses and commissioned an initial, high-level and strategic socio-economic assessment of the draft Plan. This study focused on the impacts of the short term options at the national and regional levels. Analyses of site-specific or local impacts were considered out of scope, as these would be more adequately addressed through project-level analyses. The project was managed by the Scottish Government with a wider project advisory group established to inform the project. This involved national and regional stakeholders from the offshore wind, fishing, shipping, ports & harbours and tourism sectors, as well as key planning authorities. Consultation with key stakeholders was undertaken during the study to develop a better understanding of potential impacts and develop key assumptions.

1.4.5 The study assessed the impact of short term option development in the North East, East, West, and South West regions of the draft Plan. As no short term options had been identified in the North and North West regions, these areas were not considered within the analysis.

1.4.6 The socio-economic assessment aimed to provide information and analysis on a range of relevant areas. It will be delivered in two constituent parts. The first part of the assessment considered the costs and benefits of the draft Plan on different marine sectors (such as commercial fisheries, tourism, and shipping) at both national and regional levels. The results of this part of the assessment are reported within the Plan and Post-Adoption Statement.

1.4.7 The assessment identified that the short term options were likely to impact on commercial fisheries, shipping & ports, recreational boating, recreational angling and tourism activities at regional and national levels. Evidence suggests that commercial fisheries would be adversely affected in each area where short term options are present, and that shipping & ports would be adversely affected in each area barring the North East region. Tourism and recreational angling impacts were likely to be adversely affected in West and South West regions. It is unlikely that there would be regional or national impacts on aquaculture, wave & tidal energy developments, cables & pipelines, or on surfing, windsurfing and kayaking, due to the absence of significant spatial conflict between these activities and the short term options.

1.4.8 The potential scale of the estimated impacts for any marine sectors affected by the short term options were quantified using scenarios. These costs are incurred once construction of the short term options begins, and continue to be incurred when they become operational. The range of estimated annual costs for each marine sector in each region resulting from the Low Impact to High Impact scenarios are shown in Table 1.

Table 1: Estimated annual costs to other marine users between Low and High Impact Scenarios (£m, Real Terms) 14

Sector

North East

East

South West

West

Total

Commercial Fisheries

£0.07m - £0.13m

£0.17m - £0.76m

£0.02m - £0.06m

£0.08m - £0.70m

£0.34m - £1.65m

Shipping and Ports

-

£0m - £1.55m

£0m - £0.01m

£0m - £0.03m

£0m - £1.59m

Recreational Boating

£0m - £0.00m

£0m - £0.01m

£0m - £0.01m

£0m - £0.01m

£0m - £0.03m

Recreational Angling

-

-

£0m - £0.42m

£0m - £0.80m

£0m - £1.22m

Tourism

-

-

£0m - £0.37m

£0m - £3.42m

£0m - £3.79m

Total

£0.07m - £0.13m

£0.17m - £2.32m

£0.02m - £0.87m

£0.08m - £4.96m

£0.34m - £8.28m

1.4.9 Costs are also assessed over the 50 year appraisal period, which reflects the estimated impacts over the potential lifetime of the Short Term option developments. The range of total estimated values for each marine sector in each region resulting from the Low Impact to High Impact scenarios over the 50 year appraisal period are shown in Table 2.

Table 2: Estimated total costs to other marine users between Low and High Impact Scenarios (£m, discounted over 50 years, rounded to nearest £m)

Sector

North East

East

South West

West

Total

Commercial Fisheries

£0m - £3m

£1m - £15m

£0m - £1m

£0m - £14m

£1m - £34m

Shipping and Ports

-

£0m - £31m

£0m

£0m - £1m

£0m - £31m

Recreational Boating

£0m - £0m

£0m - £0m

£0m - £0m

£0m - £0m

£0m - £1m

Recreational Angling

-

-

£0m - £8m

£0m - £17m

£0m - £25m

Tourism

-

-

£0m - £7m

£0m - £71m

£0m - £78m

Total

£0m - £3m

£1m - £46m

£0m - £16m

£0m - £103m

£1m - £169m

1.4.10 The findings suggest the range of potential impacts across the scenarios, with the total value of the impacts varying from around £1 million over 50 years in the Low Impact scenario to around £169 million over 50 years in the High Impact scenario. The largest impacts at a national scale are estimated to accrue to tourism, commercial fisheries, and shipping & ports. Impacts varied across regions, with the majority of estimated impacts accruing to West region. Commercial fisheries impacts mainly accrued in West and East regions. Shipping & ports impacts accrued mainly in East region, while tourism impacts accrued mainly in West region.

1.4.11 These costs may also result in some employment opportunities being lost in the affected marine sectors, compared to what would have happened in the absence of the short term options. When the costs associated with the High Impact scenario are isolated and applied to simple economic multipliers representing commercial fisheries, tourism and recreational sea angling, it is estimated that around 140 jobs per year are no longer supported in these sectors once the Short Term options are developed, compared to what was projected to happen in the absence of the short term options. Around 70 per cent of these jobs are in tourism, and around 14 per cent are in commercial fisheries. Around 80 per cent of employment impacts per annum occur in West region. These impacts are substantially lower in the Medium Impact and Low Impact scenarios.

1.4.12 These findings suggest that the overall impact of the short term options on other marine sectors would be relatively small at the national and regional scales. However, such impacts could be more significant at local levels. More precise estimates of impacts on other marine sectors would require site-specific analysis.

Consultation

1.4.13 Consultation with the public is an essential component of the SEA and plan making processes. Consultation analysis has brought forward issues which require further consideration within decision making. Many of the views raised during the consultation have been taken into account within the Plan itself, whilst others will need to be addressed within review and/or at the project level. Where gaps in knowledge continue to exist The Scottish Government will put in place strategic monitoring and research to fill these gaps and consider the findings within the 2 year review process. This will include information gaps identified by the socio-economic assessment, in addition to the SEA, HRA and the Plan itself. However, again it must be stressed that this work is not meant to cover developmental site issues or certain cumulative or in-combination effects which have to remain the responsibility of the developers.

Plan Implementation

Short-Term Options

1.5.1 The work undertaken at this stage has allowed the Plan to include some clear guidance on the level of acceptability of development at the regional level. Where options are included in the Plan, issues will still have to be addressed by the developer at the project level. Environmental Impact Assessment ( EIA) is the main tool to assess the impact of developments on the environment and identify some of the site specific mitigation issues to be addressed. The Plan has identified certain short term sites in certain regions as good candidates for future offshore wind development, subject to issues being resolved at the project level to include cumulative and in combination effects.

1.5.2 In addition, The Scottish Government is aware of further opportunities for offshore wind energy development in both Scottish Territorial and Offshore Waters and is taking steps to accelerate the consideration of developer access to these opportunities. These opportunities will be explored through the extension of geographic scope of the Plan and application of marine planning techniques to consider constraints and opportunity. The Scottish Government will also work with CEC to consider developer appetite, and the timing of future lease bidding for Scottish waters out to the 200 nautical mile limit.

Medium Term Options (Areas of Search)

1.5.3 The medium term options were developed as future areas of search and will be subject to further assessment and refinement within the 2 year review process. The Scottish Government will also access further information using monitoring and research work taken forward under the respective SEA, HRA and Socio-economic Assessment review processes. For example, the MaRS scoping work will be revisited to reassess the proposed medium term areas of search and The Scottish Government will apply Regional Locational Guidance techniques within the refined options. In addition, sectoral and environmental bodies will be included in advisory groups and public consultation will take place on further findings when or if they are considered to have an effect on the Plan.

Marine Licensing

1.5.4 The Scottish Government has set up a new licensing system for certain developments and activities in the marine environment including offshore wind and marine renewable (wave and tidal) energy developments. The system, including the creation of a one stop shop for marine licensing, has a broad scope that will enable consistent decision-making on development and activities which take place at sea. Through the process of marine licensing and the conditions placed on consents/licences, The Scottish Government is seeking to promote economically and socially beneficial activity while minimising adverse effects on the environment, human health and other users of the sea. Licensing should also simplify the way we reconcile development and nature conservation at sea. The process of Marine Licensing should also be supported by relevant information and outcomes of processes including SEA, HRA and the designation of marine protected areas.

1.5.5 The inclusion of any sites or areas in the finalised Plan does not imply that licences or related consents will automatically be issued. Developers will be instructed to follow the statutory processes as laid down by the regulators. Now that the Plan has been adopted by the Scottish Ministers it will be taken into account by developers when applying for relevant statutory permissions such as consent under Section 36 of the Electricity Act 1989 and a Marine Licence under the Marine (Scotland) Act 2010. Considerable further work will be required to support decisions at this level, including environmental surveys and data collection, Environmental Impact Assessment ( EIA) and Habitats Regulations Appraisal ( HRA), which will include cumulative and in-combination effects. Further public engagement will form an integral part of the work at the project level which will also potentially include detailed socio-economic analysis at the project level.

Securing the Benefits

1.5.6 The Scottish Government is committed to ensuring that Scotland capitalises on the enormous potential presented by renewable energy and the low carbon sector. Scotland's wave, wind and tidal energies, and its carbon capture and storage potential, is of European significance. Exploiting these technologies in an environmentally sustainable way will enable Scotland to lead the world in the transition to a low carbon economy over the next four decades. This will help meet our wider objectives on climate change, generating substantial new economic activity, jobs and prosperity for Scotland.

1.5.7 The Scottish Government believes that Scotland's people should benefit from offshore renewable energy projects. Scotland, and its local communities, should receive a direct and lasting legacy from the exploitation of our natural resources. Proposals to maximise community benefit from renewables were published in a consultation paper "Securing the Benefits of Scotland's Next Energy Revolution" in November 2010. These included actions designed to empower communities and ensure that the public sector leads by example in delivering real and lasting benefits. In addition, the consultation discussed the important role of CEC in the development of offshore low carbon projects and more broadly as an administrator of public assets. The Scottish Government is of the view that the management and revenues of CEC in Scotland should be devolved, bringing control over the seabed within the remit of the Scottish Parliament.

1.5.8 The Plan will address the potential for regional development and outline key environmental and socio-economic issues for developer consideration. SEA, HRA, Socio-economic and consultation initiatives that have been pursued to develop a balanced and pragmatic Plan, which is flexible enough to accommodate further developer ambition in the future. It is recognised that there is significant potential for offshore wind development in Scottish Territorial and Offshore Waters out to the 200 nautical mile limit. The Plan therefore includes short term options which have issues to be overcome but are considered to be suitable for development by 2020. It is also recognised that there is significant potential to explore further. The Scottish Government has engaged in dialogue to take forward further lease bidding to accommodate developers ambitions to deliver green energy.

1.5.9 The remainder of this document is split into two sections. These are the key outcomes of the plan development process:

  • PART A - Sectoral Marine Plan for Offshore Wind Energy
  • PART B - Post-Adoption Statement