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

Annex C. Summary of Individual Assessments

Strategic Environmental Assessment (SEA)

The SEA aims to ensure that decision-making and consultation on the draft updated Plan are informed by relevant environmental information. It identifies the likely significant environmental impacts of the draft updated Plan and proposes reasonable alternatives. It provides a high-level assessment of potential environmental effects that are likely to result from the development of offshore wind OAs and T&D projects that comprise the draft updated Plan. The SEA identifies the individual and overall (cumulative) effects of the draft updated Plan on various SEA topics that have been scoped into the assessment. The assessment also considers the effects of development on a series of key statements (SEA objectives). These objectives reflect the scope of the assessment as well as the environmental protection objectives from relevant legislation.

The development of the draft updated Plan has been an iterative process that has considered reasonable alternatives at each of the three stages of the assessment. This includes: reviewing the potential environmental effects associated with a range of alternative offshore wind and transmission technologies; applying the potential environmental effects identified in the first stage to the individual OAs within each region, as these different areas themselves constitute reasonable alternatives; and determining the potential cumulative environmental effects associated with differing scales of development (lower, central and higher development scenarios) in multiple alternative OAs at a regional and national level, and also in-combination with other plans and projects.

The SEA assessed each OA against several impact pathways that were scoped into the assessment. Based on the assessment, the key potentially significant environmental effects that arise from the implementation of the draft updated Plan include:

• Loss and/or damage of protected habitats;
• Effects on marine mammals and bird species, including potential mortality/injury, 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);
• Effects on historic environment features and their settings (W1 and N4 only); and
• Potential benefits in supporting the decarbonisation of the energy sector and the establishment of a secure energy supply in the UK.

Areas of key concern, and the issues most likely to constrain development from an environmental viewpoint are the collision or displacement risk of birds, navigational risk and potential significant effects on landscapes and seascapes for developments located within 30 km of inhabited shorelines.

Regional cumulative effects include potential for adverse effects on protected habitats, migratory and resident bird populations, marine mammals, and navigation. At a national scale, all of the OAs are individually recognised as having potentially significant (i.e. above minor) adverse effects. The majority of effects, however, will not have a cumulative effect at a national scale beyond that identified in the individual site or regional assessments. The exception to this is the potential for moderate to major adverse effects on both resident and migratory bird populations due to collision or displacement. In addition, the development of the OAs at a national scale has the potential to have significant beneficial cumulative effects in terms of supporting a diverse and decarbonised energy sector and also contributing to a secure energy supply.

The SEA also identifies mitigation measures that are required to avoid or minimise any significant adverse effects and highlights opportunities for enhancements of beneficial effects. Both plan and project level mitigation measures that have been identified and may be implemented are detailed in the SEA ER.

Recognising the uncertainty that still remains about the precise design, technology, method and/or timescale for the development projects, comprehensive project level assessment will still be required for these developments against these specific details and the baseline environment at that location.

Habitats Regulations Appraisal (HRA)

The HRA process for the draft updated Plan has been undertaken as a sequence of discrete stages in accordance with established guidance for conducting plan level HRA that was produced by NatureScot (formerly Scottish Natural Heritage) in 2015.

The Habitats Regulations cover inshore waters up to 12 NM and offshore zones up to 200 NM. These regulations ensure the protection and management of European sites, including SACs and SPAs. The regulations also consider Ramsar Sites and sites that are proposed for future inclusion in the European site network.

Under the Habitats Regulations, where a plan or project is not directly connected with or necessary for the management of European sites, and where the possibility of a ‘Likely Significant Effect’ (LSE) on these sites cannot be excluded, either alone or in combination with other plans or projects, an AA should be undertaken.

As the Competent Authority, the Scottish Government's Offshore Wind Directorate is responsible for producing a formal AA record that assesses the impact of the draft updated Plan on these sites in fulfilment of the Habitats Regulations obligations. The formal AA record needs to determine whether there will be an AEOI at any European/Ramsar (Protected) site. The HRA AAIR, will be used to inform the formal AA record. The HRA AAIR presents the initial findings of the strategic HRA process. It reviews the impacts of the draft updated Plan based on the OAs and proposed levels of GW capacity for potential offshore windfarm development.

Uncertainties exist around the projects that will proceed through to completion, including the final details of these projects. There are also uncertainties around the future impacts from other plans and projects. Although these uncertainties exist, a high level of certainty is required under the Habitats Regulations that there will be no AEOI on any Protected site. The HRA for the draft updated Plan takes account of these issues and, where required, has identified relevant mitigation measures to accompany the draft updated Plan.

To assess the effects of the draft updated Plan on Protected sites, a staged approach has been adopted, this included:

• Pre-screening report: Sets out the evidence base and the proposed methods to be applied for the subsequent screening/scoping and assessment stages of the HRA work. The pre-screening phase identified an initial list of 649 Protected sites for which there could be an LSE as a result of the draft updated Plan;
• Screening: A secondary sifting process to identify those sites for which there is the potential for LSE. A precautionary approach has been adopted to the assessment, as required, in order to ensure that no relevant sites are excluded; A total of 167 Protected sites were identified that needed to be considered within the HRA AAIR for the draft updated Plan; and
• Appropriate Assessment stage of the HRA AAIR: Review of the potential impacts on marine habitats, birds, and mammals, in-combination effects and mitigation measures.

With the application of mitigation measures (project level and plan level) the assessment concluded that there will be no AEOI from the draft updated Plan alone or in-combination with other plans and projects on habitat and marine mammal features.

The assessment concluded an AEOI on seabird features from the draft updated Plan alone and in-combination with other projects. Key to these conclusions were the risk of effects on protected bird features from collision and displacement impacts. While the adoption of plan level mitigation and the legal requirement for project level HRA was acknowledged, the conclusion of AEOI from the draft updated Plan in relation to bird features remained.

While the HRA AAIR has been necessarily qualitative in the assessment; given the extensive evidence available through recent OWF assessments in Scottish waters, the conclusion of AEOI is confidently determined against the draft updated Plan (alone and in-combination), even though quantified impacts at Protected sites were unavailable to inform the HRA AAIR.

Impact modelling was carried out for birds and marine mammal features. Although the outputs from these models were unavailable within the time constraints of the HRA AAIR, finalisation of the modelling will be completed in 2025 and be used to inform the formal AA record carried out by OWD.

The conclusion of the integrity test made within the HRA AAIR is in advance of formal judgement (formal AA Record) made by OWD, in consultation with NatureScot. Thus, the conclusions of the HRA AAIR do not pre-empt the formal AA record decision.

In the event that the conclusions of the formal AA judgement are in line with the HRA AAIR, the draft updated Plan can only then be adopted if the competent authority is satisfied there are no alternative solutions, and it is necessary for IROPI. Additionally, it is considered that Scottish Ministers will need to ensure the implementation of compensatory measures under the Habitats Regulations, to enable adoption of the draft updated Plan

Given the existing uncertainties around the impacts to seabirds from offshore wind development (e.g. collision risk) and the efficacy of compensatory measures, an adaptive approach will be required. As data emerges, such as through monitoring or targeted research, the measures can be adapted, as appropriate, or new measures implemented.

Social and Economic Impact Assessment (SEIA)

The SEIA identifies and assesses the potential economic and social effects of implementation of the draft updated SMP-OWE on other marine sectors and the lives and circumstances of people, their families and their communities. Potential impacts are assessed site-by-site and are presented at a regional and national (cumulative) level.

The cumulative negative impact considers the potential cost and gross value added (GVA) impacts across all sectors from each OA added together. The cumulative positive impact considers the increased spend in the offshore wind supply chain and number of direct jobs created in any one year. The in-combination assessment considers the potential negative impacts of the draft updated SMP-OWE together with existing and planned offshore wind farms in Scottish waters, proposed fisheries management measures, and NESO’s HND and HND-FUE for offshore transmission infrastructure.

The SEIA methodology has built on previous studies and has followed wider guidance on impact assessment including Scottish Government guidance on Business and Regulatory Impact Assessment and HM Treasury’s Green Book methodology. The approach applied is primarily desk-based and involved defining scenarios; identifying relevant marine activities and interaction pathways; establishing a baseline for marine activities and assessing negative and positive impacts, knock-on social impacts, and cumulative and combined impacts.

Impacts on commercial shipping (associated with diversion and increased steaming costs) make up a large proportion of the total potential cost impacts and occur across all OAs. Impacts on power interconnectors (associated with diversion of routes) and water sports (associated with displacement) are significant for individual OAs, with smaller impacts on tourism, telecom cables and recreational boating identified across Scotland. Impacts on commercial fisheries show relatively high impacts on direct GVA for a number of OAs, particularly in the North East and Shetland regions.

The positive impacts on the supply chain are reported by region and nationally. The GVA impacts vary considerably across the regions due to the amount of development that is expected and the retention rates that have been applied. Retention is expected to be greatest in the East and North East, but all regions see growth in their supply chains over project timescales. Highest overall levels of positive GVA impacts are also seen in the East and North East. Maximum positive GVA impacts in any one year are also greatest in the East and North East. Employment impacts are given as the maximum number of Full-time Equivalent (FTEs) created in any one year – as with GVA, the highest number is seen in the East and North East regions.

Potential knock-on social impacts are also assessed regionally and nationally, and are organised by impacts on communities of place, practice and interest. Positive impacts which may be experienced include job creation and access to higher-skilled roles or training opportunities. Employment and training benefits may be significant, potentially offsetting job loss concerns, with income benefits varying by region. Communities of place may see long-term positive impacts on facilities and possible flood risk reduction as a result of increased spend and re-development in certain areas. Negative impacts associated with service demand increases, visual impacts and increased noise levels may also be experienced.

Nature Conservation Marine Protected Area (NCMPA) Assessment

An NCMPA assessment has been undertaken and an NCMPA assessment report has been prepared as best practice. This provides Scottish Ministers with the information to support their duties in relation to MPAs in Scottish inshore (territorial) and offshore waters

The NCMPA assessment of the draft updated Plan has been undertaken as a high-level desk-based assessment, reflecting the broad and national scope of the draft updated Plan, and has been based on the best available evidence, drawing on a range of sources and data. The outcomes of the assessment have been reported in individual assessment tables for each of the four NCMPAs screened into the assessment. These individual assessment tables ensure a transparent and consistent process is followed, and a clear audit is provided of the conclusions for each site.

The four NCMPAs that have been screened into the assessment are as follows:

• Norwegian Boundary Sediment Plain NCMPA;
• Turbot Bank NCMPA;
• Firth of Forth Banks Complex NCMPA; and
• East of Gannet and Montrose Fields NCMPA.

An assessment of the impacts of the draft updated Plan activities on each of these NCMPAs and protected features both alone and in-combination with others plans and projects has been undertaken, taking account of the relevant conservation objectives and management advice for these features.

Provided that the project level mitigation measures identified are secured and implemented, the draft updated Plan activities will not significantly hinder the achievement of the conservation objectives of Turbot Bank NCMPA and Firth of Forth Banks Complex NCMPA.

The draft updated Plan activities have the potential to significantly hinder the achievement of the conservation objectives of East of Gannet and Montrose Fields NCMPA and Norwegian Boundary Sediment Plain NCMPA. This is because it is considered unlikely or not possible to avoid the protected features. Specific project level mitigation measures have been suggested to reduce the risk of significantly hindering the achievement of the conservation objectives.

Business and Regulatory Impact Assessment (BRIA)

In line with Scottish Government best practice, a partial focused- BRIA was carried out to assess likely costs, benefits and risks of the updated draft SMP-OWE that impact the public, private, third sectors or regulators. The SEIA considers many of the same requirements set out in the BRIA guidance, and as part of the BRIA scoping process, a gap analysis was carried out to compare and identify considerations of impacts that required further assessment. Impacts to regulatory bodies and frameworks are not considered within the scope of the SEIA, therefore the partial “focused” BRIA concentrates only on the impacts to regulatory frameworks.

Benefits to updating the draft updated SMP-OWE include helping to streamline MD-LOT regulatory decision-making and application processing, providing an updated strategic framework for consideration when making licensing and consenting decisions on offshore wind energy applications. However, some of the costs of updating the draft updated SMP-OWE could include inconsistency by Scottish Ministers on making licensing and consenting decisions, whereby decisions made prior to the Plan being adopted could differ from those post-adoption of the draft updated Plan. This would be due to the availability of updated assessments which could influence decision making by Scottish Ministers, and the consideration of new evidence or data. Many other impacts were dependent on the timing of the delivery of the updated draft updated SMP-OWE and the level of impact on MD-LOT processes.

Island Communities Impact Assessment (ICIA)

In line with the requirements of Section 8 of the Islands (Scotland) Act 2018 an ICIA has been undertaken to better understand the potential differential impacts of the draft updated SMP-OWE on island communities across Scotland. This assessment has been informed by targeted engagement with relevant stakeholder organisations, previous consultation exercises and the wider plan level social and economic impact assessment.

It is considered likely that the development of OAs located close to island communities will have differential impacts on those communities. Issues of key concern relate to visual impacts from those sites closest to shore, and direct or indirect impacts to other sectors and activities, primarily tourism, recreation and fisheries. However, due to the close proximity of developments to certain island communities, there may also be additional localised opportunities for employment and supply chain benefits.

The ICIA report will be updated to account for responses to the public consultation and finalised to be published alongside the adoption of the draft updated SMP-OWE.

Child Rights and Wellbeing Impact Assessment (CRWIA)

In line with the recommendations of UNICEF and the UN Convention on the Rights of the Child (UNCRC), and under the UNCRC (Incorporation) (Scotland) Act 2024, the Scottish Government is carrying out a CRWIA. The UNCRC has 54 articles and 3 optional protocols that cover all aspects of a child’s life and set out the civil, political, economic, social and cultural rights.

The preparation of CRWIA is underway to help understand whether the updated SMP-OWE is compatible with the UNCRC requirements and what the anticipated impacts of the updated SMP-OWE are. The findings of the steps of the CRWIA will allow for the enhancement of potential impacts and mitigation of negative impacts in the adopted updated SMP-OWE.

Evidence from existing research and reports, such as the SEIA, indicate that no aspects of the updated SMP-OWE are relevant or will impact on children’s rights as the draft updated Plan sets the spatial parameters for offshore wind development and is expected to impact on industries rather than directly impact individuals. To further support the understanding and assessment of potential impacts of the updated SMP-OWE on children and young adults, with reference to the UNCRC, we are seeking your thoughts through this consultation.

Equalities Impact Assessment (EQIA)

A screening exercise for an Equalities Impact Assessment (EQIA) of the draft updated SMP-OWE was undertaken. No potential impacts on those with protected characteristics, as defined under the Equality Act 2010, are envisaged as a result of the publication of the draft updated SMP-OWE. It was therefore concluded that a full EQIA is not required for the development of the draft updated SMP-OWE, and a “No EQIA Required Declaration” has been completed.

Fairer Scotland Duty Assessment (FSDA)

Under the Fairer Scotland Duty, set out in Part 1 of the Equality Act 2010, Scottish Ministers are required to pay due regard to how they can reduce inequalities of outcome caused by socio-economic disadvantage when making strategic decisions. As the draft updated SMP-OWE is a strategic planning document, the Duty must be met throughout the Plan development. It is considered that by completing the plan level SEIA, the requirements of the Duty have been fulfilled. Further details can be found in the SEIA report.