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

2 Introduction

2.1 Purpose of the Consultation Analysis Report

2.1.1 The purpose of this Consultation Analysis Report is to summarise the responses to the consultation on the draft updated Sectoral Marine Plan for Offshore Wind Energy (hereafter referred to as the draft updated Plan). The consultation ran for a period of 12 weeks from 30 May to 22 August 2025.

2.1.2 This report has been prepared by ABPmer and Arup on behalf of Scottish Government and provides an independent analysis of responses to the public consultation on the draft updated Plan.

2.2 Background to the draft updated Plan

2.2.1 The path to net zero presents significant opportunities for Scotland, as a leader in offshore wind development, achievable by providing a stable, consistent and predictable enabling environment.

2.2.2 Since 2020, Scotland’s offshore wind development pipeline has grown significantly. Scotland currently has 10 operational windfarms, one under construction, and a substantial portfolio of projects under development^[2].

2.2.3 Scotland’s established sectoral marine planning process for offshore wind energy provides all marine users and decision-makers with clarity on the opportunities and constraints with regard to the sustainable deployment of offshore wind energy. The SMP-OWE (2020) was adopted by Scottish Ministers in October 2020^[3], following public consultation from December 2019 to March 2020^[4]. The SMP-OWE (2020) identified 15 spatial Plan Option areas within Scottish waters suitable for the sustainable development of commercial-scale offshore wind projects (>100 megawatts (MW)), with a planned total generation capacity of up to 10 GW.

2.2.4 These 15 Plan Options were subsequently utilised by Crown Estate Scotland (CES) to inform the ScotWind leasing round, which awarded Option Agreements to 20 offshore wind projects in 2022, with a total planned generation capacity of approximately 27 GW.

2.2.5 Following the ScotWind leasing round, Scottish Ministers concluded that the SMP-OWE (2020) needed to be updated as part of the Iterative Plan Review^[5] to consider the potential opportunities and constraints associated with the increased generating capacities awarded for the ScotWind Option Agreements.

2.2.6 Further to this, CES ran the INTOG leasing round in 2023, which was aligned with the spatial parameters set out in the INTOG Initial Plan Framework^[6].

2.2.7 INTOG consists of two distinct elements:

• IN – small scale, innovative projects of less than 100 MW; and
• TOG – specifically designed for offshore wind projects which target the electrification of oil and gas installations and reduce the carbon emissions associated with oil and gas production.

2.2.8 Through the INTOG leasing round a further 12 projects, including five innovation (IN) projects and seven targeted oil and gas (TOG) projects, were awarded Exclusivity Agreements with a proposed total capacity of 5.5 GW.

2.2.9 The draft updated Plan sets out an integrated planning framework for both the ScotWind and INTOG leasing rounds alongside consideration of additional capacity (up to 1 GW) for (T&D) projects (see Figure 5, Appendix C for Option Area locations). The inclusion of consideration for T&D aids in future-proofing the draft updated Plan in order to avoid further iterations. It does not constitute a new seabed leasing round but recognises that there may be a need for additional testing for new and emerging technologies on an ad hoc basis to be considered by CES based on levels of demand.

2.2.10 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).

2.2.11 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.

2.2.12 The aims of the draft updated Plan are to:

• Provide a strategic spatial framework for offshore wind development in Scottish waters;
• Assess the potential national and regional level opportunities and constraints, including potential in-combination and cumulative impacts, resulting from offshore wind development with a generating capacity of up to 37.4 GW;
• Strategically consider the impacts of storage, construction and maintenance of devices (commonly referred to as ‘wet storage’);
• Consider the in-combination impacts from the development of arrays with the outcomes of the National Energy System Operator’s (NESO’s) network design process;
• Support economic and investment opportunities of offshore wind and the competitive local supply chain opportunities in Scotland; and
• Support efficient and streamlined consenting and licensing decision-making for offshore wind development in Scotland.

2.2.13 The core objectives of the draft updated Plan are:

• To maximise the delivery of low carbon electricity from offshore wind farms in Scottish waters in support of the Scottish Government’s target to cut greenhouse gas emissions to net zero by 2045 and to do so by maximising the delivery of CES’s ScotWind and INTOG leasing rounds between now and 2035;
• To support the export of electricity to the electricity grid to help realise Scottish commitments for offshore wind and security of electricity supply;
• To support innovative offshore wind technologies including the deployment of small-scale and short-term T&D projects to reduce technological barriers across the industry;
• To facilitate offshore wind developments to deliver the decarbonisation of oil and gas infrastructure operations in Scottish waters; and
• To optimise generation and export capacity within the constraints of available Scottish sites and onshore and offshore transmission infrastructure.

2.2.14 In order to understand the sustainability of the draft updated Plan, a Sustainability Appraisal (SA)^[7] was undertaken. Individual assessments were prepared in line with the relevant legislation. The appraisal comprised the following elements, which were included as part of the consultation:

• Strategic Environmental Assessment Environmental Report (SEA)^[8];
• Social and Economic Impact Assessment (SEIA)^[9];
• Habitat Regulations Appraisal: Appropriate Assessment Information Report (HRA AAIR)^[10];
• Nature Conservation Marine Protected Area Assessment (NCMPA Assessment)^[11];
• Focused Partial Business Regulatory and Impact Assessment (BRIA)^[12];
• Partial Islands Communities Impact Assessment (ICIA)^[13];

2.2.15 Regional Locational Guidance (RLG)^[14] was also prepared and published, outlining the baseline data and information used in the planning and assessment process.

2.2.16 Further information on the wider objectives and aims of the plan, its policy context, further background and information on the sectoral marine planning process is presented in the draft updated Plan document itself^[15].

2.3 The consultation

2.3.1 The draft updated Plan and associated plan-level assessments were published for consultation on 30 May 2025. The consultation ran until 22 August 2025, for a total of 12 weeks.

2.3.2 The purpose of the consultation was to collect and understand the views of individuals and organisations on the potential impacts and opportunities of offshore wind deployment across Scotland as well as on the implementation of the updated Plan.

2.3.3 A Statement of Public Participation^[16] was published prior to the start of the consultation in May 2025 to set out how and when Scottish Government planned to engage with stakeholders and the public, as well as how views and opinions gathered during the consultation period would be used to inform the finalisation of the updated Plan.

2.3.4 The Scottish Government is committed to a thorough and inclusive consultation process enabling engagement with users of the shared marine space to listen to and understand their views and feedback. Consultation on the draft updated Plan followed both the National Standards for Community Engagement^[17] and the Government Consultation Principles^[18].

2.3.5 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.

2.3.6 The draft updated Plan and supporting documents were made publicly available on the Scottish Government website. The consultation was supported by a series of 20 consultation events held during June to August 2025, comprising 17 in-person events held across Scotland and three online events. Further details regarding these events are provided in Appendix C of this report.

2.3.7 As outlined in the Statement of Public Participation, only written responses submitted online, as hard copies at in-person events, by email or by post, with a completed Respondent Information Form, are considered as part of this analysis.

2.3.8 Where respondents have agreed to have their response published, these can be viewed online at Draft Updated Sectoral Marine Plan for Offshore Wind Energy - Scottish Government consultations - Citizen Space.