Offshore wind energy - draft updated Sectoral Marine Plan 2025: consultation

Plan Adoption and Implementation

Implementation Considerations

The following sets out considerations for the implementation of the draft updated SMP-OWE. This covers varying aspects of implementation, including stakeholder engagement, project level considerations, transmission infrastructure, radar, and the storage, construction and maintenance of devices.

Stakeholder Engagement

The Scottish Government will continue to undertake proportionate stakeholder engagement at a strategic level on an ad-hoc basis to support the successful implementation of the draft updated SMP-OWE. This engagement will make use of existing forums or platforms where possible and will seek to raise awareness of the planning process, conclusions of the plan level assessments and any mitigation, compensatory or monitoring measures which have been put in place.

At the project level, developers will be required to undertake the necessary community and stakeholder engagement as part of the licensing and consenting processes. Developers should follow applicable best practice guidance, such as the Marine Directorate Licensing Operations Team’s (MD-LOT) Marine Licensing and Consenting Guidance for Offshore Renewable Energy Projects. Engagement should also be undertaken in line with relevant national planning principles or policies. The NMP (2015) stipulates that early and effective engagement should be undertaken with the general public and all interested stakeholders to facilitate planning and consenting processes (General Planning Principle 18).

Project Level Considerations

Proposals for offshore wind development are subject to the standard leasing, marine licensing and section 36 consenting processes, including project level environmental and other assessment. As part of improving the licensing and consenting process, MD-LOT has updated its guidance for offshore renewable energy projects on marine licensing and consenting requirements. The draft updated SMP-OWE can support the decision making on individual licence and consent applications, but should not be considered as pre-determining those decisions, and is just one material consideration that exists alongside others.

Project level assessment, such as EIA, HRA and MPA assessment, will benefit from certainty regarding project details including technology type (floating/fixed, size and generating capacity of turbines), location and scale to be deployed within a particular Option Area, which is currently not available at the plan level. Project level assessment will identify any appropriate mitigation measures to reduce, avoid or offset any potential adverse impacts and, where possible, maximise positive effects.

Discussions with statutory nature conservation bodies or other regulators will identify the relevant best practice guidance to be adhered to (during all phases of development) and the methodologies and data to be utilised in any impact assessments.

There is a legal requirement for consideration of whether a project could affect protected European sites. Where needed, individual projects should undergo HRA, regardless of whether it has been subject to an overall HRA as part of the updated SMP-OWE. Where likely significant effects on any European terrestrial site(s) or European marine site(s) cannot be excluded, the competent authority will be required to undertake a project level Appropriate Assessment. A derogations case may therefore be put forward for each individual project which has a negative Appropriate Assessment result. However, there is no legal requirement for results of the plan level and project level Appropriate Assessments to align or depend on each other.

When determining applications for marine licences, section 36 consents and licences to disturb European Protected Species or basking sharks, Scottish Ministers must consider the effect on MPAs. If it is determined during the further project specific assessment that it is not possible to avoid hindering the achievement of the conservation objectives of an NCMPA then, in accordance with section 126(7) of the Marine and Coastal Access Act 2009, there will be a need to consider if: there are other means of proceeding with development which would create a substantially lower risk of hindering the achievement of those objectives; the benefit to the public of proceeding with the development clearly outweighs the risk of damage to the environment that will be created by proceeding with it; and the developer will undertake, or make arrangements for the undertaking of, measures of equivalent environmental benefit to the damage.

Certain marine licence or section 36 consent projects require an Environmental Impact Assessment under the relevant EIA Regulations.

Transmission Infrastructure

The UK Government is responsible for policy relating to strategic network planning and electricity network connections. These tasks are carried out by NESO and regulated by the Office for Gas and Electricity Markets (Ofgem). In addition, the legislation for and regulation of electricity and networks, which includes private wire purchase power agreements, are reserved to the UK Government and the regulator, Ofgem. Therefore, the draft updated SMP-OWE does not provide a planning framework for electricity network connections.

Scottish Ministers are the licensing authority for the construction of subsea cables through marine licensing.

The ‘Pathway to 2030’ Holistic Network Design (HND) published by NESO sets out the requirements for electricity transmission network infrastructure to support the large-scale delivery of renewable electricity across Great Britain as we transition to net zero, including 10.7 GW of ScotWind capacity. NESO’s Holistic Network Design Follow Up Exercise (HND-FUE) (also known as the tCSNP2) ‘Beyond 2030’ report recommends the need for additional offshore and onshore network infrastructure to connect the remaining ScotWind capacity to the grid. Supplementary work to the HND-FUE undertaken by NESO, the ‘Beyond 2030: INTOG’, recommends how to connect a collection of in scope INTOG projects to the onshore electricity network. NESO are undertaking a review of tCSNP2 which is anticipated to be published ahead of the draft SSEP. For those looking to read across this plan and the above NESO reports, Annex E will help readers correctly identify projects when looking across the various documents.

The UK Government has an ambition of achieving a clean power system by 2030 (CP2030). NESO was formally commissioned to provide independent analysis on how this can be achieved, across energy supply, demand, and networks requirements. In 2024, NESO released their analysis and the UK Government released their Clean Power 2030 Action Plan.

NESO has put forward a ‘First Ready, First Needed, First Connected’ proposal, also referred to as TMO4+, to reform the network connection process.^[9] NESO considered how the reformed connections proposals (TMO4+) could align with and operationalise CP2030 and consulted on these proposals and the methodology that would support them. Ofgem published their decision on 15 April 2025 and it is expected they will be implemented in 2025.

As set out in the INTOG IPF^[10], TOG projects should deliver electricity to decarbonise the operation of oil and gas assets as their primary purpose. Projects may pursue alternative uses of excess generated energy, such as hydrogen conversion or supply to the grid, but these must be additional to the primary purpose above.

The draft updated SMP-OWE considers, at a high-level, potential cumulative and in-combination impacts of transmission infrastructure. As it does not provide a planning framework for electricity network connections, it does not assess these impacts directly. However, NESO is carrying out environmental assessments on the HND Implementation Plan incorporating an HRA, Marine Conservation Zone (MCZ) Assessment and SEA^[11]. Specifically, the planned offshore transmission infrastructure outlined in the HND and HND-FUE, some of which is encompassed in the UK Government’s CP2030 Action Plan, are considered as part of the potential cumulative or in-combination impacts in the assessments for the draft updated SMP-OWE. Recent changes made through NESO’s Detailed Network Design (DND) process have not been considered as part of the cumulative and in-combination assessments for the draft updated SMP-OWE. For TOG projects, a high-level assessment was undertaken for potential private wire connections to offshore installations. A generic assessment of intra-array cables and possible substation connections was carried out for each OA, and it was assumed that these will be located within the OA boundary.

Where possible, coordination and cooperation between developers is encouraged in relation to the project level planning and development of export cables.

Radar

Offshore wind turbines have the potential to cause radar interference if they are located within the “line of sight” of a radar system. This is a known safety issue to both the civilian aviation and defence sectors.

The full costs of the long-term radar mitigation solutions, as identified by the Ministry of Defence’s Programme Njord will be delivered by Government. The funding requirement is therefore removed from offshore wind developers.

This funding commitment covers the first four radar sites required to support the delivery of the UK offshore wind pipeline: Buchan, Brizlee Wood, Neatishead and Saxton Wold. Additional funding will be considered, if required.

Storage, Construction and Maintenance of Devices

Areas of seabed for the storage, construction, and maintenance of offshore wind devices will be required to support the delivery and operation of Scotland’s offshore wind ambition. A high-level assessment of potential environmental, social and economic impacts of temporary storage has been undertaken for the draft updated SMP-OWE, and the results can be found in the accompanying SEA, HRA AAIR, and SEIA.

Implementation of Mitigation Measures

The potential for negative environmental and socio-economic impacts has been identified at both plan and project level. Impacts should be considered and addressed in the order of the mitigation hierarchy, meaning to first avoid or prevent, then minimise or reduce, and then restore, compensate or offset. It is likely that implementation of mitigation measures will be key to ensuring that any potential negative environmental, social or economic impacts associated with the development within identified OAs or of any future T&D sites are avoided or minimised as far as practicable. Where impacts to a protected site are identified, the relevant legislative processes should be followed.

Mitigation measures are proposed at both plan level and project level to avoid and minimise the potential negative effects of draft updated Plan implementation and to promote potential beneficial effects. Additional detail is provided in the individual assessments. Proposed plan level mitigations identified through the assessment process may not necessarily apply to all projects. Mitigation measures may be implemented through a variety of mechanisms including but not limited to Government policy changes, strategic research programmes, developer-led action and licensing and consenting processes.

Proposed plan level mitigation measures in relation to avoiding, minimising or offsetting potential environmental impacts include but is not limited to:

• In replacement of the IPR process, any further planning to inform future leasing rounds should be based on robust analysis of the future environmental and socio-economic potential for future offshore wind development;
• Collaboration between governmental bodies, non-governmental organisations

(NGOs) and industry, through existing research partnerships to establish a consistent and comprehensive evidence base;

• Strategic research to understand the extent and potential impact of Plan implementation on Nathusius’ bats, to be undertaken through existing research initiatives;
• Identification of plan level compensatory measures for bird collision and displacement risks, subject to the conclusions of the HRA AA and Ministerial determination;
• Development of strategic compensation policy to support project level HRA considerations, subject to the conclusions of the HRA AA and Ministerial determination;
• Implementation of a Marine Recovery Fund in Scotland is being considered as a mechanism to facilitate the delivery of strategic compensation measures under the Habitats Regulations, if required;
• Encouragement of nature-positive offshore wind development where possible to help meet targets for the Scottish marine environment as set out in Scotland’s Biodiversity Strategy to 2045; and
• A requirement on all developers to ‘optimise’ infrastructure layout associated with the OAs to minimise potential adverse effects on protected features (e.g. excluding or relocating turbines that contribute most to bird collision risk).

Measures to be implemented at the project level have been identified in relation to minimising potential environmental effects and potential impacts to other marine sectors. Robust and proportionate assessments and associated consent applications are expected to be carried out at a project level for each OA. These assessments may identify further project specific impacts, which in turn may require further mitigation measures to be implemented.

Proposed mitigation measures identified in relation to avoiding or minimising environmental effects, to be implemented at the project level, where relevant, include:

• Requiring spatial planning or micro-siting within OAs to reduce effects on relevant environmental receptors;
• Requiring project level assessments to identify and mitigate project specific effects;
• Compliance with project level mitigation identified in the SEA, HRA and NCMPA assessment reports;
• Appropriate consultation with national and local statutory and public stakeholders;
• Modification of project specific turbine technology, array design and/or layout to minimise environmental effects (e.g. selection of smaller turbines in areas of higher sensitivity to visual effects);
• Best practice methodologies and technologies, as well as appropriate management planning, should be used to minimise potential significant effects during installation;
• Preparation and implementation of a decommissioning programme, detailing how a developer intends to remove the installation when it comes to the end of its useful life and how the costs of doing so will be funded. This programme should include a base case of all infrastructure being removed, alongside any alternatives that the operator proposes, backed up by evidence and reasoning for the preferred option; and
• Minimising use of cable protection measures by maximising burial in sediment and minimising overall length of cable where possible. Any required cable protection should be implemented and monitored throughout the lifespan of a project.

Proposed mitigation measures identified in relation to avoiding or minimising impacts to other marine sectors, to be implemented at the project level, include:

• Engaging early and meaningfully with other sectors, including fisheries and individual skippers, to ensure site design and layout facilitates continuation of other activities within arrays where practicable, and to ensure cable routing minimises potential impacts to other sectors;
• Utilising turbine foundations that minimise spatial footprint;
• Designing arrays according to relevant guidance to reduce constraints on shipping and aviation where necessary;
• Ensuring cables are buried to sufficient depth, or use of fishing-friendly cable protection to minimise snagging risks; and
• Utilising smaller turbines in important tourism areas, and restricting storage, construction and maintenance of devices in key areas to reduce visual impacts.

Development of any future potential T&D sites should be undertaken in line with the following mitigation measures, to avoid significant environmental effects and reduce negative economic impacts. In line with the outlined parameters for T&D sites, generating capacity is limited to a maximum of 1,000 MW across Scottish waters, 200 MW per sectoral planning region and 100 MW per individual project. T&D sites should not be located within identified OAs or within the boundaries of MPAs.

Further mitigation measures for the sustainable development of T&D sites include:

• T&D sites will be located at specific distance requirements from any protected areas (e.g. >5 km from seal haul out sites), SPA/SAC/Ramsar sites and qualifying features;
• T&D sites will avoid co-locating with offshore infrastructure, key shipping routes and anchorage areas, and higher density fishing areas;
• Spatial planning of T&D sites should take account of other sectors and the potential cumulative impacts with OAs. This should also include in-combination impacts with other offshore wind farms and MPA management measures;
• T&D sites should be located beyond 15 km from the coastline where that avoids significant seascape and visual effects, and impacts on coastal receptors;
• Pre-application Consultation Reports and proportionate project level assessments will be expected for T&D sites and associated export cable routes to ensure significant adverse effects are appropriately considered, and to document engagement undertaken; and
• T&D sites should be developed in accordance with any relevant project level mitigation identified in the plan level SEA, HRA, SEIA and NCMPA assessment.

Monitoring

There is a statutory requirement for the responsible authority to monitor significant environment effects of the implementation of the updated Plan, as set out in Section 17 of the Environmental Assessment of Plans and Programmes Regulations 2004. The regulations require this to be undertaken with the purpose of identifying unforeseen adverse effects at an early stage and being able to undertake appropriate remedial action. Significant environmental effects identified by the SEA (Section 5) include:

• Loss and/or damage of protected habitats;
• Effects on marine mammals and bird species, including potential collision mortality, displacement or barrier effects;
• Effects on landscape and coastal character and also on visual receptors;
• Effects on navigational safety;
• Effects on population and human health arising from noise, vibration, light and shadow flicker effects (N4 only);
• Effects on soil and water quality receptors as a result of changes in the hydrodynamic and sediment regime (N4 only); and
• Effects on historic environment features and their settings (W1 and N4 only).

Various key features will have the potential to be significantly affected as a result of the updated SMP-OWE and will therefore require monitoring at the plan and project level.

Project Level Monitoring

Projects can be required to undertake post-consent monitoring to validate the conclusions of project level assessments and to test the effectiveness of any mitigation measures put in place.

Plan Level Monitoring

In order to monitor and mitigate any significant adverse environmental effects of implementing the updated SMP-OWE, a plan level monitoring programme has been recommended through the SEA. This monitoring programme would aim to monitor significant environment effects of the implementation of the updated Plan and confirm if proposed mitigation measures set out have been implemented. The SEA suggests that the monitoring programme could be informed by resources available at project, regional and national level, existing licensing authority reporting tools, pre- and post-consent documentation, and outputs of strategic research programmes.

It has been noted that various indicators could be identified and proposed within the SEA post-adoption statement, aiming to draw upon existing monitoring regimes, where possible. These could include utilising information on significant environmental adverse effects that have been identified across project level assessments that fall under the draft updated Plan, and the related project level mitigation measures being implemented to avoid and/or reduce these significant adverse effects of individual projects.

Environmental impacts expected to be monitored at plan level include impacts on marine mammals, whereby strategic monitoring will be needed. Information on populations is likely to be available from Special Committee on Seals (SCOS) monitoring, Small Cetaceans in European Atlantic Waters and the North Sea (SCANS) projects, and UK Marine Strategy monitoring.

Another key feature expected to be monitored are birds, where there is likely to be a range of information including project level monitoring, regional monitoring and national monitoring. Project level and regional monitoring could potentially seek to understand both the impacts of offshore wind development (i.e., collision risk and displacement effects), and the benefits of any compensatory and nature positive measures. National monitoring could also seek to determine large scale trends in seabird populations, such as annual colony monitoring through the Seabird Monitoring Programme and periodic seabird censuses.

More detail on plan level monitoring will be provided in the post adoption statement and will be informed by further research and consultation responses.

Governance

A formal governance structure is required to support the implementation of the Plan. The proposed roles and responsibilities of groups involved are outlined below.

Scottish Ministers Roles and Responsibilities

• Responsible for approving and adopting the Plan
• Responsible for approving amendments and/or updates to the Plan
• Responsible for making decisions on applications for licences and consents required for the construction and operation of offshore wind projects
• The final decision-making power rests with Scottish Ministers

Offshore Wind Executive Board Roles and Responsibilities

• Considers advice and evidence received from the SMP-OWE Steering Group
• External advice may be sought as appropriate.
• To meet at least annually or more frequently if required

Updated SMP-OWE Steering Group Roles and Responsibilities

• To be approached, if needed, in the event of additional evidence being required to inform a planning decision
• To operate flexibly based on requirements Scottish Marine Energy Research programme

(ScotMER) Receptor Groups Roles and Responsibilities

• We will explore the role of the Scottish Marine Energy Research programme (ScotMER) in the delivery of monitoring of environmental effects and outcomes of environmental mitigation measures to deliver plan implementation

The groups established to support the governance of the previous SMP-OWE (2020) have been formally disbanded. Members of the disbanded Technical Advisory Group, Sectoral Evidence Group and Ornithological Working Group have been invited to sit on the updated SMP-OWE Steering Group. The role of the previous Sectoral Planning Programme Board has been adapted and now sits with the Offshore Wind Executive Board.

In relation to plan level monitoring it is suggested that existing receptor groups, such as those established for the ScotMER programme, could be utilised to oversee the monitoring of the environmental effects of plan implementation, and the success of any implemented mitigation measures. Alternatively, a new, tailored working group could be established comprising experts from across different relevant environmental fields.

Implementation of the plan will also be undertaken by MD-LOT, through consideration of the plan and associated assessment conclusions when making licensing and consenting decisions on individual projects. MD-LOT does not have a role in the formal governance of the plan.

Evidence

The draft updated SMP-OWE takes account of the latest evidence, at the time of plan preparation, in relation to environmental and socio-economic impacts. Evidence gathered throughout the plan development process has been used to inform the Opportunity and Constraint models, the assessments in the sustainability appraisal and the baseline and spatial data presented in the RLG. As the deployment of offshore wind energy expands, further survey and monitoring data and research will become available, which will be used to inform industry best practice and standards, including plan- and project- level impact assessment methodologies.

Existing strategic research programmes are undertaking work to address evidence and data gaps. It is anticipated that these programmes will continue to identify and address emerging evidence gaps to further reduce uncertainty in the planning, application and consenting decision making for offshore wind projects in Scottish waters.

Where significant environmental effects have been identified through project level EIA, developers can be required to gather and submit monitoring data to the licensing authority as part of their marine licence and/or section 36 consent conditions. The structure and process for gathering such data is directed by the licensing authority in consultation with the statutory nature conservation bodies (SNCBs), and can have wider relevance to ongoing strategic research programmes. It is expected that these research and monitoring outputs will inform any future planning process and feed into any relevant coordinated research programmes.

New evidence, which may have arisen as a result of technological advances, scientific research, or project level assessment and monitoring (for example project post-consent surveying and monitoring (including of the effectiveness of mitigation measures)) is encouraged to be shared and fed into any relevant strategic research programmes. As this evidence becomes available, it is anticipated that it will inform any future plan and project level assessment accordingly and it is expected to inform consent applications, advice and decision-making.

Strategic Research Programmes

The ScotMER programme was established to improve the evidence base for how offshore renewables developments may potentially affect the natural environment, socio-economics, and other users of the sea. Where evidence gaps and uncertainties exist, the ScotMER programme seeks to address these where most needed through its seven receptor groups:

• Benthic;
• Diadromous fish;
• Fish and fisheries;
• Marine mammals;
• Ornithology;
• Physical processes; and
• Socio-economic.

Outputs from ScotMER projects are shared and built upon to maximise their impact, enabling government, regulators and industry to make informed decisions to support the sustainable development of offshore renewables in Scottish waters. ScotMER has a continuous process of updating and prioritising the list of evidence needs across environmental and socio-economic impacts through focused stakeholder groups and expert advice. Evidence needs are captured in ScotMER evidence maps which can be found on the Scottish Government website.

ScotMER has commissioned specific projects to support the development of the draft updated SMP-OWE to quantify impacts on birds and marine mammals. Further information including detail on latest research is available via the Scottish Government's Marine publications website.

In addition, a number of other collaborative research initiatives exist, whose outputs may inform any future planning and licensing processes, including (but not limited to):

• The Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR);
• Department for Energy Security and Net Zero (DESNZ) Offshore Energy SEA Research Programme;
• Joint Cetacean Data Programme;
• Offshore Renewables Joint Industry Programme;
• Offshore Wind Environmental Evidence Register (OWEER);
• Offshore Wind Evidence and Change Programme (OWEC);
• Offshore Renewable Energy (ORE) Catapult.

Future Planning

The updated SMP-OWE and its associated assessments will continue to provide the spatial framework to guide leasing and consenting for ScotWind, INTOG, and T&D projects. Lease agreements under the ScotWind and INTOG leasing rounds should only be made for areas of seabed identified and assessed in the draft updated SMP-OWE, in accordance with Scottish national marine planning policy. Leasing for up to 1 GW of T&D projects should be split evenly between the planning regions and can proceed through the leasing process on a case-by-case basis.

It is proposed that the updated SMP-OWE is not subject to iterative plan review. Under this proposal, no further iterations of the plan to cover ScotWind and INTOG sites are anticipated. As set out in the Evidence section above, new evidence, including the outputs of strategic research programmes, will inform any future assessment of impact, advice and decisions, accordingly. In addition, a plan level monitoring programme is proposed for the updated SMP-OWE in line with recommendations set out in the SEA Environmental Report to monitor the environmental effects of the implementation of the updated SMP-OWE and its proposed mitigation measures.

Any future commercial-scale leasing for offshore wind in Scotland is proposed to be subject to a new and distinct sectoral marine planning process. It is suggested that any further planning, to inform any future commercial-scale leasing, is based on a robust analysis of the future environmental and socio-economic potential for further offshore wind development in Scotland and in line with the Scottish Government’s policy ambitions. If deemed appropriate through such analysis, a new and distinct sectoral marine plan would guide the CES leasing process.

Overall, any future planning for further commercial-scale offshore wind leasing and development in Scotland will continue to be informed by any new and relevant information and research regarding the environmental, economic and social impacts, both positive and negative, of offshore wind and the effectiveness of any mitigation measures. It will continue to take account of current relevant plans and policies and identified future opportunities for the sector.

Final decision-making power regarding this updated Plan and any future marine plans for offshore wind energy will continue to rest with Scottish Ministers.