Offshore wind energy - draft updated sectoral marine plan 2025: consultation analysis report

1 Executive Summary

1.1 Introduction to the consultation

1.1.1 This Consultation Analysis Report summarises the responses to the public consultation on the draft updated Sectoral Marine Plan for Offshore Wind Energy (SMP-OWE) ^[1] (hereafter referred to as the draft updated Plan). The purpose of the draft updated Plan is to enable the sustainable development of offshore wind energy in Scottish waters, by balancing economic, social and environmental objectives through a systems-led assessment process that engages a range of stakeholders and is underpinned by evidence.

1.1.2 The draft updated Plan sets out an integrated spatial planning framework for both the ScotWind and Innovation and Targeted Oil and Gas (INTOG) leasing rounds alongside consideration of additional capacity (up to 1 gigawatt (GW)) for Test and Demonstration (T&D) projects. The total generation capacity considered by the draft updated Plan and associated assessments is 37.4 GW across 32 Option Areas. This includes known planned capacity increases to ScotWind projects following Option Agreement award, as of the time of assessment (September 2024).

1.1.3 The consultation ran for a period of 12 weeks from 30 May 2025 to 22 August 2025. The consultation contained 19 questions, 10 on the draft updated Plan and a further nine questions on the associated plan-level assessments. The consultation questions were primarily qualitative with unique (free text) responses, though questions 1, 6, 9 and 11 included multiple choice response options. In total 304 responses to the consultation were received and analysed, with 70 responses from organisations and 234 from individual members of the public. There were a small number of duplicate responses, from different respondents (with different names and emails). These have been treated as individual responses as they do not distort the overall analysis. Topic modelling was completed to identify the main themes addressed in the responses to each question.

1.2 Overarching themes

Consultation Process

1.2.1 Many respondents welcomed the opportunity to participate in the consultation process, recognising it as a valuable forum to share insights and concerns regarding the draft updated Plan. This engagement was seen as an important step in ensuring transparency, accountability, and the incorporation of varied perspectives into wider sectoral marine planning. Several respondents emphasised that ongoing dialogue and responsiveness to stakeholder input will be essential for refining the updated Plan and achieving robust, balanced outcomes for all sectors involved.

General Objections to Offshore Wind

1.2.2 A number of respondents objected to offshore wind in principle due to its potential environmental impact as well as effects on fisheries, tourism and local communities. Respondents mentioned concerns such as disruption to traditional fishing grounds, threats to local livelihoods, and changes in marine ecosystems. There was also concern about the effect on tourism and local communities, particularly island and coastal, related to visual, noise and construction impacts.

Option Area-Specific Concerns

1.2.3 More than half of the respondents, mainly individuals, raised specific opposition to the N4 Option Area. Particular concerns were raised about the proximity of the development to the coastline, as well as more generally the potential impacts on fisheries, tourism and community cohesion, and how traditional ways of life and local culture were addressed within the assessments. There was a perceived lack of consultation with island communities that respondents stated should be more locally accessible and tailored to their concerns. These issues will be further addressed through the finalisation of the Island Communities Impact Assessment, which will be published alongside an adopted final Plan.

Plan Approaches and Mitigations

1.2.4 Concerns from the offshore wind sector were raised regarding the view that overly precautionary approaches had been applied to the supporting assessments, indicating the need to establish differing scales of information required for plan-level versus project-level assessment. Comments were also raised on the need for clarity on any future mitigation measures, indicating that a standardised, consistent and transparent approach was crucial to streamline delivery.

1.3 Summary responses by question

Question 1: Do you agree that up to 1 Gigawatt (GW) of Test and Demonstration projects should be included within the scope of the updated Plan?

1.3.1 211 responses were received for the multiple choice component of question 1. 53 respondents answered ‘Yes’, 97 respondents answered ‘No’, and 62 respondents answered ‘Don’t Know’.

1.3.2 124 respondents answered the free text component of question 1. The free text responses highlighted the importance of including 1 GW of (T&D) capacity in the draft updated Plan for de-risking technologies and enabling T&D deployment, but raised concerns about the potential prioritisation of new T&D projects over existing ScotWind and INTOG projects and the potential for increased grid connection queues and environmental compensation complexities.

Question 2: Do you have any comments on how the benefits of offshore wind development could be maximised? If referring to development within a certain region, please specify.

1.3.3 194 respondents answered Question 2. Opportunities for job creation, supply chain growth, and regional regeneration were highlighted. Key themes included community ownership, infrastructure investment, and predictable policy frameworks. Respondents also mentioned the potential for nature-positive design and prioritisation of projects that enhance marine and coastal environments. Concerns were raised about tourism, fishing, environmental, and cost-of-living impacts. Opposition to the N4 Option Area was raised in responses from highland and island communities who felt excluded from benefits.

Question 3: Do you have any comments on how social impacts could be mitigated?

1.3.4 194 respondents answered Question 3. Key themes included strong support for early, transparent, and community-led engagement, fair economic benefit sharing, and investment in housing, transport, and local infrastructure. Concerns focused on offshore wind proximity to residential areas, especially for the N4 Option Area, and impacts on cultural identity and mental health. Respondents also called for support for traditional industries like fishing through compensation, skills development, and local ownership.

Question 4: Do you have any comments on how economic impacts could be mitigated?

1.3.5 181 respondents answered Question 4. Key concerns included potential irreversible harm to tourism, especially in the Western Isles due to the N4 Option Area, and threats to commercial fishing viability. While some respondents advocated for mitigation strategies and community-led economic models, others remained sceptical about their effectiveness. In contrast, the offshore wind sector argued that there is no robust evidence of negative impacts on tourism and that impacts to fisheries have been overstated. The sector emphasised the importance of fair, proportionate impact assessments and facilitating sectoral coexistence.

Question 5: Do you have any comments on how environmental impacts could be mitigated?

1.3.6 A total of 240 respondents answered Question 5. Key themes included calls for clearer plan-level guidance, legally binding and enforceable mitigation measures, strategic site selection to avoid sensitive habitats, and comprehensive cumulative impact assessments. Specific mitigation suggestions included noise restrictions, marine mammal protections, EMF reduction, and full decommissioning. Some respondents advocated for community-led projects.

Question 6: Do you think the monitoring of environmental impacts of the draft Plan should be overseen by existing expert groups, or should a new expert advisory group be established for this purpose?

1.3.7 184 responses answered the multiple choice component of Question 6, with 144 responses from individuals and 40 responses from organisations. 33 answered ‘Existing group(s)’, 94 respondents answered ‘New group(s)’ and 57 respondents answered ‘Don’t Know’.

1.3.8 The free-text section had 155 responses. The responses highlighted support for existing expert groups, although some had concern about potential conflicts of interest or bias. There were also calls for independent oversight and inclusion of local communities, as well as comments on transparency, funding, and enforcement.

Question 7: Do you have any comments on the proposed changes to the SMP-OWE governance structure?

1.3.9 137 respondents answered Question 7. While some supported continuing the SMP-OWE Steering Group, others raised concerns about unclear membership and lack of local representation. Respondents called for inclusive, transparent governance with independent oversight and devolved authority. Environmental monitoring was seen as essential, with demands for independent expertise, strong enforcement, and public reporting to ensure ecological accountability.

Question 8: Do you have any suggestions for how evidence should be shared and/or fed into strategic research programmes?

1.3.10 146 respondents answered Question 8. Key themes included calls for open and transparent access to data, centralised sharing platforms, and standardised protocols. Respondents, particularly individuals, emphasised the need for independent oversight to ensure objectivity, while organisations supported collaborative platforms like the Scottish Marine Energy Research programme (ScotMER) and Offshore Wind Industry Council (OWIC). There was widespread support for integrating environmental, socio-economic, and community-based evidence into strategic research, with many advocating for the inclusion of local knowledge and lived experience to inform policy and planning.

Question 9: Do you agree with the approach proposed to remove the iterative plan review process and replace it with the stated evidence and future planning proposals?

1.3.11 165 respondents answered the multiple choice component of Question 9. Of these, 34 answered ‘Yes’, 51 answered ‘No’, and 80 answered ‘Don’t Know’.

1.3.12 111 respondents answered the free text component of Question 9. Many respondents opposed removing the Iterative Plan Review (IPR), citing its role in accountability, responsiveness to evidence, and environmental oversight. Suggestions included periodic reviews tied to industry milestones. Supporters of the new approach stressed the need for transparent criteria to avoid uncertainty. Across views, respondents emphasised the importance of stakeholder engagement, accessible information, and robust monitoring to address cumulative impacts on marine life, fisheries, and communities.

Question 10: If you have any further comments or points that you think should be taken into account in the plan, please provide those below.

1.3.13 141 respondents answered Question 10. Key themes included concern over poor community engagement, with calls for more inclusive, transparent consultation. Respondents stressed the need for stronger environmental safeguards, cumulative impact assessments, and continuous monitoring. Socio-economic concerns focused on fisheries, wellbeing, and cultural identity, with mixed views on offshore wind. Opposition to the N4 Option Area was common. Organisations emphasised a need for clearer policy, strategic planning, innovation, collaboration, and regular review to meet renewable energy goals.

Question 11: A policy review has identified that no aspects of the draft plan will impact on children's rights. Do you agree with these findings?

1.3.14 A total of 169 responses were received for the multiple choice component of Question 11. 49 answered ‘Yes’, 73 answered ‘No’, and 47 answered ‘Don’t Know’.

1.3.15 146 respondents answered the free text component of question 11. While most respondents did not identify direct impacts on children’s rights, a number of responses raised issues that could impact on children’s prospects or wellbeing. Issues included threats to traditional industries, biodiversity, and cultural heritage. Others saw benefits in cleaner energy but stressed the need for inclusive consultation and safeguards. Several responses emphasised protecting community interests, especially those of children and families, in planning and decision-making.

Question 12: Do you have any comments on the partial Business and Regulatory Impact Assessment?

1.3.16 110 respondents answered Question 12. Key themes included concerns about offshore wind’s disproportionate impact on local economies, especially fragile island areas, citing risks to tourism, property values, and fishing. Many criticised assessment impartiality and called for transparency and stronger community engagement. The offshore wind sector highlighted strategic value but urged better reflection of long-term investment. Other concerns included the oversimplification of the socio-economic analysis, consent uncertainty, and the need for local procurement and benefit sharing.

Question 13: Do you have any comments on the partial Island Communities Impact Assessment?

1.3.17 235 respondents answered Question 13. Many respondents from island communities felt the partial Island Communities Impact Assessment (ICIA) lacked depth and failed to reflect local realities. Concerns included cultural disruption, depopulation, and impacts on fishing, crofting, tourism, housing, and healthcare. Calls were made for tailored, island-specific assessments, equitable benefit sharing, and genuine partnership with communities throughout planning and implementation to protect traditional ways of life and local services.

Question 14: Do you have any comments on the Strategic Environmental Assessment Environmental Report?

1.3.18 144 respondents answered Question 14. Key themes included concerns on report structure, methodology, and baseline data adequacy. Respondents cited risks to ecosystems, fisheries, birdlife, and heritage. Responses noted the need to apply the mitigation hierarchy, but also for the realistic assessment of mitigation strategies, ensuring feasibility and proportionality. The importance of post-adoption reviews of baseline data, continued stakeholder engagement and a response framework were also mentioned.

Question 15: Do you have any comments on the Habitats Regulations Appraisal Appropriate Assessment Information Report?

1.3.19 87 respondents answered Question 15. Key themes included calls for transparency, proportionality, and evidence-based decisions in the HRA process. While the multi-stage approach was supported, offshore wind stakeholders raised concerns about precautionary assumptions and cost impacts. Respondents sought clearer Adverse Effect on Site Integrity (AEOSI) definitions, site-specific analysis, cumulative impact assessments, strategic compensation, and stronger links between plan- and project-level decisions, with more developer and community involvement.

Question 16: Do you have any comments on the Social and Economic Impact Assessment?

1.3.20 150 respondents answered Question 16. Key themes included recognition of economic opportunities, especially for northern and island communities, and the need for local benefits through jobs, infrastructure, and services. Concerns were raised about the generalised approached of Social and Economic Impact Assessment (SEIA), with calls for sub-regional analysis and meaningful engagement. Fisheries and tourism stakeholders questioned assumptions and outdated data, while broader concerns focused on transparency, evidence-based assessments, and stronger stakeholder involvement in shaping the SEIA.

Question 17: Do you have any comments on the Nature Conservation Marine Protected Area Assessment?

1.3.21 134 respondents answered Question 17. Key themes included concerns about the clarity and transparency of the assessment process, especially regarding cumulative effects and mitigation strategies. Respondents called for stronger links to conservation objectives, the use of accurate project footprints, and alignment with strategic compensation and nature recovery goals. Gaps in infrastructure planning, particularly grid connections, were noted. Support was expressed for site-specific, evidence-based mitigation, with calls for robust marine data, integration of initiatives like the Marine Recovery Fund, and greater stakeholder involvement.

Question 18: Do you have any comments on the Sustainability Appraisal report?

1.3.22 117 respondents answered Question 18. Key concerns centred on the Sustainability Appraisal (SA)’s limited influence in the planning process, seen as overly passive and focused on data collection without offering strategic direction. Respondents urged for the SA to deliver clearer recommendations, policy rationale, and thresholds to support sustainable development. They also called for stronger evidence, better data quality, and integration of environmental, social, and economic factors, alongside strategic baselines, statutory protections, and meaningful community engagement to inform decision-making.

Question 19: Do you have any comments on the Regional Locational Guidance?

1.3.23 121 respondents answered Question 19. Key themes included the integration and usability of the Regional Locational Guidance (RLG), with calls for better alignment with project boundaries, realistic deployment assumptions, and improved clarity for decision-makers. Concerns were raised about data transparency, outdated data and granularity. Ecological sensitivity, migratory routes, and cumulative impacts were also raised as areas of concern, alongside calls for statutory protections and more accurate, year-round data to support development in sensitive marine zones.

1.4 Next steps

1.4.1 The draft updated Plan will be revised, to take account of formal consultation responses and any additional supporting information that may be available. In the event that major changes are required to the draft updated Plan as a result of the consultation, further assessment and/or consultation may be required. This will result in revised timescales for final adoption and publication.

1.4.2 The updated Final Plan will then be prepared and presented for approval and adoption by Scottish Ministers. The updated Plan will be published along with relevant supporting information, as soon as possible thereafter. Final versions of the ICIA and BRIA will also be prepared following consideration of relevant consultation responses where required.

1.4.3 Following Plan adoption, a Strategic Environmental Assessment (SEA) Post-Adoption statement will be produced and published in line with the relevant Environmental Assessment legislative requirements.