Marine Just Transition - UK and international comparator countries: literature review

2. A literature review on international marine just transition oriented policies

2.1. Executive Summary

This literature review investigates the existing policy practices on marine just transition in an international context, specifically focusing on marine renewables and fisheries. This literature review seeks to enhance understanding and consider learning opportunities from international marine just transition oriented practices.

The literature review seeks to answer the following questions:

1. What just transition oriented policies on marine renewables and fisheries have been implemented internationally in countries similar to Scotland?

2. What were the strengths and weaknesses of these policies from the perspective of the Scottish Government’s just transition strategy?

3. How can the learnings from these policies be applied in Scotland?

2.1.1. Key findings

• Scotland is considered by some academics as one of the leading countries in offshore renewables development which limits the learning opportunities from other countries with similar marine spaces.
• The most common just transition oriented policies identified in the international literature include community benefits, community ownership and compensation measures from offshore renewables; local action groups for fisheries; and multi-use and co-location in marine spatial planning.
• In the context of offshore renewables, a just transition is conceptualised around the distribution of benefits from renewable energy developments and the mitigation of negative impacts on other marine users, especially fishers.
• Just transition for fisheries includes better recognition of small-scale fisheries and improved access to decision-making processes.
• The policies identified from the international literature with the greatest learning potential for Scotland is community ownership of offshore wind with strong potential to learn from domestic onshore and international offshore practices.
• All marine sectors are deeply intertwined as a result of sharing the same marine space and one sector cannot be considered in separation from the others.
• There are lots of evidence gaps as a result of the nascent nature of the marine renewables sector; a general lack of research into co-location, wave energy and tidal energy; and a lack of literature evaluating current policy practices.

2.2. Introduction

This literature review investigates the existing policy practices on the topic of a marine just transition in an international context, specifically focusing on marine renewables and fisheries. This literature review seeks to enhance understanding and consider learning opportunities from international marine just transition oriented practices. This literature review builds on the definitions outlined in the domestic literature review (see 1.2. Introduction).

2.2.1. Report structure

This report, the second of the two literature reviews presented here, consists of two sections. The first section sets out the methodology of the literature review, including research questions and aims, and the search parameters. The second section is divided into marine sectors with sub-sections on each just transition oriented policy identified in the context of each respective sector. These include offshore wind, tidal and wave energy, fisheries and marine spatial planning. The sub-sections will discuss how the policy practices relate to a just transition, highlight good practices, and, when relevant, discuss what Scotland could learn from international practices.

2.3. Methodology

This section of the report addresses the methodological approach applied in conducting this literature review.

2.3.1. Literature review aim and research questions

The aim of the international literature review was to identify and evaluate marine just transition policies on marine renewables and fisheries that have been implemented internationally in countries similar to Scotland, to see what Scotland could learn from them.

The literature review research questions included:

1. What just transition oriented policies on marine renewables and fisheries have been implemented internationally in countries similar to Scotland?

2. What were the strengths and weaknesses of these policies from the perspective of the Scottish Government’s just transition strategy?

3. How can the learnings from these policies be applied in Scotland?

2.3.2. Literature review parameters

The initial parameters were refined after initial literature searches had been conducted. This was due to the area of marine just transition being a new concept and the initial searches being highly exploratory to understand the scope of the literature. Due to the large scope of international literature on marine just transition (see 2.3.5. Literature search for details), the parameters were narrowed down to the following:

• Academic literature
• Grey literature including reports and publications by international agencies, national and regional government agencies, and NGOs
• Literature focused on marine renewables (offshore wind, wave and tidal energy) and fisheries
• Countries with a comparable international context (see 2.3.3. Choice of international comparators)
• Literature published in English

The review excluded:

• Academic literature with limited analysis of marine policies (e.g. theory and methodology driven papers, papers focused on public perceptions, and publications with a normative focus)
• Academic publications with limited peer-review processes (e.g. theses below PhD level)
• Unpublished governmental policy documents

The publication dates were not limited, but they were taken into consideration when evaluating policies.

2.3.3. Choice of international comparators

The selection of international comparators was based on several factors. First, due to the strong interlinks between marine renewables and the fishing industry, the selection of comparison countries was led by the development stage of the marine renewables industry to enable a comparison between countries with similar marine spaces. Secondly, factors including economy size, and language were considered.

• The North Sea countries with well-established offshore renewable industries (Denmark, Germany, The Netherlands and Belgium) were chosen as initial points of comparison.
• Norway and Sweden were added to the comparison - despite the nascent nature of their offshore renewables industries - on the basis of the size of their economies.
• Canada has been used as a comparator country in the context of wave and tidal energy due to the stage of the development of the industry and literature available in English.

2.3.4. Limitations

A variety of limitations to this research are apparent:

• While generic search terms (see Appendix 1) were used to identify initial literature, the literature searches were also shaped by the pre-existing assumptions of areas of interest that may be linked with a marine just transition. As such, there was some bias in identifying literature and topics – some relevant topics may have had little mention within the literature found because of the search terms used. For example, marine protected areas were not included in the search terms.
• As the initial literature searches led to a high volume of relevant literature, the scope of the international literature review had to be narrowed down to specific topics. Offshore renewables and fisheries were identified as the most popular topics in initial literature searches and were therefore the primary focus. As such, this review was not able to cover other areas of the international marine just transition literature, such as coastal management and coastal communities.
• The ability of the literature review to effectively address research questions on strengths and weaknesses of international policies and their applicability to Scotland was heavily limited by linguistic barriers. Most of the comparator countries were not English-speaking which led to a limited number of publications, both academic and grey, being available in English. As a result, the literature review has various gaps in coverage. It is also recognised that some of the international policies may be outdated due to lack of up-to-date literature available in English.
• While the comparator countries were selected using the method outlined in the section above, the wider context of Scotland’s devolution settlement with the UK should be considered in any comparisons drawn, as in some instances the Scottish Government does not have the power to change policies.
• This literature review covers a wide range of literature including published reports or policy documents (academic, government and NGO), as outlined earlier in this methodology chapter. There may be more up-to-date information than is available in the literature which is yet to have been published or made publicly available, and so this information is not included here. This should be taken into consideration when reading the findings of this report.
• Finally, the nascent nature of some of the marine sectors and policy practices set limitations for the review. Due to the recent implementation of many of the marine policies, there was often little to no literature identified that evaluates the effectiveness of and learning from these policy practices. Consultation with experts on comparator countries would have been required to fully understand the impacts and nuances of most presented policies but there was not scope to do this in this exercise.

2.3.5. Literature search

Initial literature searches were conducted by Scottish Government researchers and a Scottish Government librarian. Literature searches were conducted in four different databases using the same search terms (see Appendix 1). The databases included The Knowledge Network, The Scottish Government Library resources (Knowledge and Exchange), Google Scholar and Google. The searches in databases were continued until two pages of irrelevant results was exceeded.

The term “just transition” is not widely used in marine sectors nor the literature. However, there are no known alternative terms in place. Due to this, a wide range of search terms were used to capture relevant literature. The initial searches were highly exploratory in order to gain a better understanding of the scope of literature in the field. As a result of a high volume of relevant literature identified through initial searches, the scope of searches was narrowed down to focus on marine renewables and fisheries to enable the review to be completed in the time available. This decision was made because the bulk of literature that emerged in the initial searches covered these topics. This decision also reflected Scottish Government policy priorities. The focus of the literature was further narrowed down to countries with comparable international contexts to Scotland (see 2.3.3. Choice of international comparators). Additional literature was added to the analysis through snowballing, where additional sources are selected from the reference lists of those found in initial searches.

2.4. Findings

The findings presented below have been divided into sectors, with each sub-section consisting of a marine just transition oriented policy (e.g. a policy that helps to ensure more just impacts on marine sectors and coastal communities), and learnings from these where relevant and available. Examples of good practice and innovative policies have been highlighted as case studies where appropriate. While the following findings have been divided into sectors, this division is made for practical purposes and it is highly artificial. In reality, all of these sectors are deeply intertwined as a result of sharing the same marine space and one sector cannot be considered in separation from the others.

2.4.1. Offshore wind

Offshore wind leads to a range of positive and negative impacts on coastal communities and marine sectors, which have been discussed already in the domestic review (see 1.4.2.1 Impacts of offshore renewable development on coastal communities and marine sectors).

The policies most commonly discussed in the international literature that aim to address negative impacts and support benefits of offshore wind developments on marine sectors and coastal communities include community benefits, community ownership and fisheries compensation. As stated by Herrera Anchustegui (2021), these practices can help to bring a sense of justice to communities that are impacted by energy developments through the distribution of benefits from offshore wind and citizen participation in energy development. In addition to benefitting local communities, some sources highlight that these measures can also increase local support for offshore renewables (Kerres et al., 2020; Lange et al., 2018).

Some of the sources consulted in the international literature on offshore wind have identified the UK as one of the leaders in the offshore renewables industry (Ramos et al., 2021) and both the UK and Scotland are commonly used as a reference point for other countries in the literature particularly in areas such as community benefits schemes and progressive just transition policies (eg. Gallaher et al., 2023; O'Hanlon and Cummins, 2020; Proimakis et al., 2021; Sangiuliano and Mastrantonis, 2017). Because of this, the learning opportunities from other countries who may be perceived to be further behind in the development of offshore renewables than Scotland and the UK, are limited.

2.4.1.1. Community benefits schemes

General information about community benefit schemes are outlined in the domestic review above (see 1.4.3.2. Community benefits). Scotland follows a similar community benefit model to the comparison countries (see box below) with voluntary community benefit schemes delivered by the project developer (see Scottish Government, 2018b). Further details of the UK’s experience of community benefits can be found in 1.4.3.2. Community benefits. The main exceptions to this model are Germany, where community benefits are distributed by federal states through tax revenue (Rudolph et al., 2015), and Denmark that has two mandatory offshore community benefit schemes that include payments for municipalities and neighbouring communities (Herrera Anchustegui, 2021; Regen, 2022). In Denmark, the “Green pool scheme” consists of a singular payment to hosting municipalities by the project developer, while the “VE-Bonus scheme” includes yearly payments to neighbouring communities of the development (Herrera Anchustegui, 2021; Regen, 2022).

Community benefit policies in international comparator countries

Scotland

Voluntary offshore community benefit schemes (Scottish Government, 2018b; Herrera Anchustegui, 2021).

The Highland Council has specific community benefit policies that guide the benefits from developers and regulate how the benefit payments from offshore wind are distributed (Rudolph et al., 2015; The Highland Council, 2013).

Denmark

Mandatory offshore community benefit schemes:

2008 - 2018: Community fund set up by the state for beneficiary communities defined by distance (DKK 0.004 per KWh for 22,000 hours at peak load);

2020 onwards: 1) VE Bonus scheme: Yearly payments to neighbours by the project developers – eligibility and amount determined by the Danish Energy Agency; 2) Green pool scheme: One-time payment to hosting municipalities by project developer (DKK 115,000 per MW) (Herrera Anchustegui, 2021; Regen, 2022).

The Netherlands

Voluntary offshore community benefit scheme commonly defined by distance.

Project developer sets up the community fund (Herrera Anchustegui, 2021).

Germany

Community benefits through tax revenue distribution (Rudolph et al., 2015).

In theory, 70% of the tax income is distributed to the community where the windfarm is located and 30% to the community where the headquarters of the developer is situated (Rudolph et al., 2015). However, due to offshore wind developments being located outside municipalities, the beneficiary communities are defined by coastal federal states (Rudolph et al., 2015).

Belgium

No information available

Norway

Voluntary offshore community benefits scheme (Herrera Anchustegui, 2021).

Sweden

No information available

While a mandatory model can guarantee benefits to impacted communities, some of the evidence consulted in the international review suggests that the voluntary model provides flexibility and the option to tailor community benefits around community needs (Rudolph et al., 2015). The voluntary model has been suggested by one source to have a broader scope both geographically and through a greater variety of benefits (Herrera Anchustegui, 2021). However, as voluntary community benefits are project specific and there is a lack of literature evaluating different voluntary benefit schemes, it is difficult to draw conclusions on the success of the schemes. Scotland is regarded by some academics as one of the leading countries in community benefits from offshore renewable developments. Previous analytical work to compare the Scottish model to other offshore wind countries recommended maintaining the Scottish model of voluntary benefits due to its flexibility (Rudolph et al., 2015).

2.4.1.2. Community ownership

Community ownership of renewable energy generally refers to full or partial community ownership of an energy project. Community ownership can decentralise decision-making over processes surrounding energy production to local communities and increase citizen participation in the energy sector (Herrera Anchustegui, 2021; Hoicka et al., 2021; Standal et al., 2023). Community energy in the context of offshore wind refers specifically to energy projects where communities have partial ownership of offshore energy developments, due to the high financial risks and costs of offshore wind making full ownership difficult for communities.

Community ownership of offshore wind remains uncommon internationally, but there are some examples of voluntary shared ownership in the North Sea context (see box below). These include shareholding opportunities through cooperatives in The Netherlands, Denmark (see Middelgrunden case study below) and Belgium (Akerboom and van Tulder, 2019; Herrera Anchustegui, 2021; Schultz-Zehden et al., 2018; Wyns, 2023). In Germany, municipal utilities have traditionally had strong ties to the community and have become shareholders in offshore wind (Herrera Anchustegui, 2021; Richter, 2013). A mandatory community ownership scheme has been trialled in Denmark (see mandatory ownership case study below). However, no academic or grey literature was identified in the review that could provide an in-depth description of these cooperative models or evaluation of them.

Community ownership policies in international comparator countries

Scotland

No community ownership schemes. The potential for shared ownership of offshore wind is explored (Scottish Government, 2023b).

Denmark

Unsuccessful trial for mandatory community ownership scheme was conducted 2008 - 2020 (see case study below).

Currently have voluntary shareholding opportunities for offshore wind through cooperatives (Schultz-Zehden et al., 2018).

The Netherlands

Voluntary shareholding opportunities for offshore wind (Rudolph et al., 2015).

Germany

Voluntary joint community ownership for offshore wind through municipal utilities ownership and citizen participation (community buy-in) (Rudolph et al., 2015).

Belgium

Co-operatives that allow citizens to purchase shares of offshore wind developments (Wyns, 2023).

Norway

No information available

Sweden

No information available

The Middelgrunden windfarm

The Middelgrunden windfarm in Copenhagen, Denmark was developed in cooperation between the Middelgrunden Wind Turbine Cooperative and the local utility called Copenhagen Energy (Schultz-Zehden et al., 2018). All the investment costs were shared between the two parties and the parties own ten wind turbines each (Schultz-Zehden et al., 2018; Vikkelsø et al., 2003). The two owners collaborate, but the businesses are run separately (Vikkelsø et al., 2003).

The Middelgrunden Wind Turbine Cooperative has 40,500 shares and over 8000 co-owners (Vikkelsø et al., 2003). The co-owners primarily consist of individuals, but they also include unions, organisations, foundations and companies (Vikkelsø et al., 2003). The majority of the shares are owned by people living in Copenhagen or the surrounding municipalities as the initial sale of shares was limited to these groups (Vikkelsø et al., 2003). The cooperative was established as a partnership with joint and several liability (Vikkelsø et al., 2003). There are bylaws in place to prevent the partnership from contracting debt (Vikkelsø et al., 2003), therefore reducing risks for shareholders.

In the Danish model, votes in offshore cooperatives are limited to one per person, therefore being independent of the number of shares (Schultz-Zehden et al., 2018). Households commonly own 3 - 5 shares which is enough to cover electricity consumption for standard households (Schultz-Zehden et al., 2018).

Some sources consider Scotland to be one of the global leaders in onshore community energy (Fuentes González et al., 2019) and Scotland has existing policies for shared ownership in the context of onshore wind (eg. Scottish Government, 2019b). However, Scotland does not offer or require shared ownership opportunities for offshore wind developments (see 1.4.4.4.4. Promote community ownership). Community ownership is a mechanism to increase the acceptance of energy projects for hosting communities and increase the participation of local citizens in the energy transition (Herrera Anchustegui, 2021). Community ownership can also enable communities themselves to define who the beneficiaries of offshore wind are, which is not the case for community benefit schemes run by developers, where the developers decide beneficiaries (Rudolph et al., 2015). As such, the evidence considered in the international literature review suggests that community ownership of offshore wind developments can enable both local benefits and growth of the offshore wind industry.

Mandatory community ownership of offshore wind in Denmark

Denmark has a history of community ownership of offshore wind through cooperatives, which has enabled individuals and trade unions to purchase shares of offshore wind projects (Schultz-Zehden et al., 2018). Between 2008 and 2020, Denmark trialled a mandatory community ownership scheme for offshore wind (Herrera Anchustegui, 2021). Under this scheme, offshore wind developers were required to offer a minimum of 20% of the offshore windfarm for local communities and municipalities, giving priority to people in close proximity to the developments (Mendonça et al., 2009). It was only mandatory to offer this share to communities, not for communities to accept it (Danish Energy Agency, 2017).

The trial led to the establishment of offshore wind developments with shared ownership with communities. However, the trial was deemed unsuccessful on the basis that community ownership did not increase local support for offshore renewables (Herrera Anchustegui, 2021). With a limited amount of information being available in English, it is unclear whether other factors were taken into consideration in the cancellation of the scheme. Defining success solely on the basis of community acceptance ignores other benefits such as the justice implications that community ownership can enable for impacted communities.

Further investigation into the impacts of this trial in Danish communities would be beneficial to understand whether Scotland could benefit from a mandatory shared ownership model for offshore wind.

It is possible that the lack of offshore wind community energy development is linked with the historical development of community ownership in Scotland. Scotland’s community energy landscape has historically focused on community development trusts (Harnmeijer et al., 2018) that present an ownership model where community energy projects are fully owned by community bodies (van Veelen, 2017). This is in contrast to countries such as Denmark and Germany that have a strong culture of co-operatives pre-dating offshore wind development (Mendonça et al., 2009; Nordic Energy Research, 2023). As shared equity is the dominant community energy model for offshore wind, countries with more extensive experience on co-operatives and shared ownership might have an advantage in applying their knowledge to offshore wind. However, the Scottish onshore community energy sector has seen a clear shift towards shared equity models (see Community Energy England, 2022) which gives potential to apply the sectoral knowledge to offshore wind.

2.4.1.3. Fisheries compensation

Compensation mechanisms exist as a way to mitigate harm that is caused by offshore wind development. There are a number of mandatory compensation schemes for different interest groups across the comparator countries (see box below), including fisheries and in some cases coastal communities. While compensation mechanisms have strong synergies with equal access to benefits from the marine environment, this differs to policies such as community benefits, in that compensation is a restorative practice, not proactive.

Fisheries compensation policies in international comparator countries

Scotland

Voluntary compensation for impacted fisheries (Withouck et al., 2023). The compensation is a last resort measure and the financial compensation may involve monetary payment to specific vessels or to a fisheries community fund (Withouck et al., 2023).

Denmark

Monetary and non-monetary compensations for fishers (Owusu Bonsu et al., 2024).

Negotiated compensations for fishers for documented permanent or temporal losses across offshore wind development life-cycle (based on logbook evidence from 2 - 10 years) (Owusu Bonsu et al., 2024). Includes compensation for lost time and cost of longer travel distances. Non-monetary compensation may include, for example, access to bottom trawling (Owusu Bonsu et al., 2024).

The Netherlands

Conditional compensation for fishers based on appeal on adverse effects from offshore if losses are beyond normal risk (Owusu Bonsu et al., 2024). Negotiated with the government (Owusu Bonsu et al., 2024).

Germany

No direct compensation for fishers (Owusu Bonsu et al., 2024).

5% of offshore licensing fees are directed to support fisheries (Owusu Bonsu et al., 2024).

Belgium

No compensation for fishers (Owusu Bonsu et al., 2024).

Norway

Mandatory compensation mechanism for impacted fishers (sole payment or annual payments) on the basis of economic losses due to seizure of grounds, lost fishing time due to travel distances, or damage to objects (Owusu Bonsu et al., 2024). Adopted from a compensation mechanism from oil and gas exploitation (Owusu Bonsu et al., 2024).

Sweden

Compensation for fisheries in areas of assumed loss of income. Negotiated between the developer and fishers (Owusu Bonsu et al., 2024).

The evidence from this literature review suggests that the most common recipient of compensation schemes regarding offshore wind are fisheries. The compensation schemes vary widely from monetary to non-monetary compensation, the evidence required for compensation, and whether the compensation is negotiated with the developer or the government. Monetary compensation measures for fishers are in place in Denmark, The Netherlands, Norway and Sweden (Owusu Bonsu et al., 2024). In Denmark and Norway, compensation is commonly based on adverse effects of offshore wind development leading to either temporary or permanent losses for fishers and it may also include compensation for lost fishing time or increased cost due to longer distances that fishers have to travel to access fishing grounds as a consequence of windfarms (Owusu Bonsu et al., 2024). In addition to monetary compensation, Denmark provides non-monetary measures that may include, for example, giving fishers exemptions to access bottom trawling along cable lines (Owusu Bonsu et al., 2024). Bottom trawling can cause damage to undersea cables (European MSP Platform, 2015) and is normally not allowed within 200 metres of cables in Denmark (Owusu Bonsu et al., 2024).

Due to the limited English language literature available on the topic, it is unclear what evidence is required for compensation in most countries. However, in Denmark logbook evidence from the last 2 -10 years is required for compensation, although this can create disadvantages for fishers with improper records (Owusu Bonsu et al., 2024). The requirement of logbook evidence is likely to lead to inequalities in the UK, where evidence of catches from the previous three years is required for compensation (Owusu Bonsu et al., 2024). Fisheries compensation in the context of the UK is discussed in 1.4.3.3. Fisheries Compensation. However, it must also be noted that in most of the comparator countries, safety zones around windfarms extend up to 500 metres, more considerably reducing areas available for fishing compared with the UK where these safety zones do not exist (see 2.4.4. Marine spatial planning). In comparison, the UK has not implemented mandatory safety zones around offshore windfarms and the developer posed safety zones are only 50 metres (Owusu Bonsu et al., 2024). More evidence of the international compensation schemes is required to effectively evaluate them. In terms of coastal communities, the only comparator country offering compensation is Denmark that has a mandatory compensation scheme for losses on residential property value as a result of offshore wind development (Herrera Anchustegui, 2021).

2.4.2. Wave and tidal energy

Offshore wind dominates marine renewable development, but there are other emerging marine technologies. While wave and tidal energy are still nascent industries (Proimakis et al., 2021, Ramos et al., 2021), their future development and expansion will need to consider similar social dimensions as offshore wind. These include inclusive stakeholder and community participation, community benefits and community ownership. Many academics highlight that Scotland is considered as one of the leading countries in tidal energy development (Carlson and Adams, 2020, Sangiuliano and Mastrantonis, 2017) which provides particularly good opportunities for the development of an innovative and internationally competitive sector.

The international literature on wave and tidal energy is more limited in comparison to offshore wind due to the nascent stage of the industry. It is therefore important to learn from the successes of offshore wind in delivering positive impacts for stakeholders and impacted communities (Howell and Drake, 2012). Canada is used as a primary comparison point in this section due to the stage of the development of their marine renewables industry, and because they have a marine renewables policy landscape with strong just transition orientation.

2.4.2.1. Community benefits and ownership

Community benefits discussion in the context of wave and tidal energy has primarily focused on direct benefits such as skills development, employment, and financial benefits (Howell and Drake, 2012, Nova Scotia, 2014), rather than mechanisms such as community benefit funds. For example, in regional Canadian marine renewables policies, these benefits are not mandatory but a possible result of engagement processes, and they are discussed in relation to indigenous communities, rather than stakeholders in general (Nova Scotia, 2014). As such, the learning opportunities for community benefits for wave and tidal energy are more likely to come from existing community benefit practices, either from international offshore wind policies (see 2.4.1.1. Community benefits) or existing community benefit practices in Scotland (see Scottish Government, 2019b).

Community ownership of wave and tidal energy has remained limited. The relatively high cost of wave and tidal energy in comparison to more established forms of renewable energy is a major barrier for community ownership (Proimakis et al., 2021). Limited financing mechanisms for community-owned small-scale wave and tidal energy contribute to the lack of community ownership (Proimakis et al., 2021). While some support mechanisms for small-scale community tidal projects exist in Canada, the lack of consistency in the regulatory environment has compromised the growth of small-scale tidal energy (Carlson and Adams, 2020). Similar to community benefits, the learning opportunities for community ownership of marine renewables in Scotland are therefore more likely to come from existing community energy practices in Scotland (see Scottish Government, 2021b) or international examples of offshore wind (see 2.4.1. Offshore wind).

Practices of community participation vary both between countries and regionally. Progressive policies of community participation have been highlighted in the case study below on community engagement in tidal energy development in Nova Scotia, Canada.

Community engagement in tidal energy development in Nova Scotia, Canada

Canada is recognised as one of the leading countries in tidal energy (Marine Renewables Canada, 2018). Besides policy and support mechanisms at federal level, policy measures at provincial level play an important role in the development of marine renewables, including tidal energy (Marine Renewables Canada, 2018). Nova Scotia, in particular, has developed a number of just transition oriented policies and legislations related to both tidal energy and marine renewables in general. These include Nova Scotia Marine Renewable Energy Strategy (Nova Scotia, 2012a), Statement of Best Practices for In-Stream Tidal Energy Development & Operation (Nova Scotia, 2014) and Marine Renewable Energy Act 2015 (Nova Scotia, 2015a). In addition, the tidal energy engagement processes draw from existing policies and practices that incorporate ideas of a just transition (see Nova Scotia, 2015b; Nova Scotia, 2012b; Nova Scotia, 2010).

One of the key objectives of tidal development in Nova Scotia has been the inclusion of Indigenous people in marine renewables development (Nova Scotia, 2012a). Following the interest of Mi’kmaq (an indigenous community) to collaborate in the development of marine renewables, Nova Scotia has been seeking input from this community on marine renewables since 2006 (Nova Scotia, 2012a). This has involved inclusion of traditional ecological knowledge (TEK) in strategic environmental assessments; participation of community representatives in project liaison committees; funding for a Mi’kmaq specific renewable energy strategy; and developing plans for education and training opportunities for community members for the marine renewables sector (Marine Renewables Canada, 2018; Nova Scotia, 2012a). Furthermore, Nova Scotia has made a commitment to work with communities to develop opportunities to participate in energy development; build links between Mi’kmaqs’ renewable energy strategy and their participation in the industry; encourage industry engagement with the communities; and emphasise the role of TEK in all marine renewables development (Nova Scotia, 2012a). There are also requirements for utilising the local supply chain in marine renewables development (Proimakis et al., 2021). In general, public consultations on tidal and other marine renewables development are legally obligated in Nova Scotia (Nova Scotia, 2015a).

While no literature that addressed the implementation and effectiveness of these policies in Nova Scotia were identified, the community and stakeholder oriented marine policy landscape in Nova Scotia presents a good example of practice that could provide a more just marine energy transition in Scotland. The elements of engagement and collaboration strategies with Mi’kmaq in Nova Scotia could be applied to the context of communities impacted by tidal (and other) energy developments, especially rural and remote communities. Furthermore, when tidal energy progresses to commercial stage, Scotland could benefit from best practice guidance for delivering socio-economic benefits from the industry. This would be a natural follow-up of the existing practices in the Scottish renewable energy sector (see Scottish Government, 2019b).

2.4.3. Fisheries

Fisheries management is an important part of a marine just transition. However, globally fisheries face various challenges including competition for reduced marine space, controls on catch, a changing climate, and a lack of access to decision-making processes (see Carpenter and Kleinjans, 2017). While these issues are likely to affect a range of fisheries, the literature identifies small-scale fisheries as a particularly vulnerable group with less power and political recognition than large-scale fisheries (e.g. Bugeja-Said et al., 2022; Jentoft and Chuenpagdee, 2022; Linke et al., 2022). The injustices faced by small-scale fisheries are commonly discussed in relation to ‘blue justice’ internationally, a field of research that examines the impacts of the blue economy and blue growth in small-scale fisheries (Jentoft, 2022). According to Jentoft and Cheunpagdee (2022) blue growth, referring to sustainable economic growth in marine sectors, is increasing competition for marine space and resources and it is expected to have negative impacts on small-scale fisheries due to their vulnerability and lack of political recognition. Questions about how blue growth benefits small-scale fisheries, whose voices are heard and who gets to participate in processes are central to blue justice (Jentoft and Chuenpagdee, 2022).

This section discusses approaches which could aid a marine just transition for fisheries as identified in the literature, specifically focussing on the role of inclusive decision-making processes and fisheries local action groups (FLAGs). Fisheries policies that intersect with offshore wind are covered under offshore wind (see 2.4.1.3. Fisheries compensation) and marine spatial planning (see 2.4.4.1. Multi-use and co-location).

2.4.3.1. Inclusive decision-making processes

Sweden’s stakeholder inclusion practices in fisheries decision-making are extensive. These include active co-management practices with widespread use of consultations, and interactive stakeholder participation (Carpenter and Kleinjans, 2017). For example, the reform of the demersal quota system in response to changing European Union (EU) regulations was facilitated by fishers and NGOs (Carpenter and Kleinjans, 2017). This included extensive consultation with local fishers and collective deliberation on issues to legitimise new demersal quota management among fishers (Carpenter and Kleinjans, 2017). In the UK, numerous consultation practices are in place, but they are often undertaken through written consultation, which lack interaction and engagement with participants (Carpenter and Kleinjans, 2017). Discussions around engagement and participation in the UK are presented in 1.4.3.1. Engagement, participation and co-management and 1.4.4.1. Improve engagement and participation. Opportunities for participation in the UK exist through government driven partnerships, but the participation has been classed as functional rather than fully interactive (Leite and Pita, 2016). As such, Sweden provides an example of a more bottom-up approach to stakeholder participation.

2.4.3.2. Fisheries local action groups (FLAGs)

FLAGs are an area-based EU initiative seeking to increase employment and territorial cohesion in communities dependent on fishing and aquaculture through local initiatives (Bugeja-Said et al., 2022). FLAGs seek to ensure community involvement in local strategy development and they provide skills and advice for local actors (Budzich-Tabor, 2014). Some of their key activities include helping develop the local fishing sector, diversifying fisheries areas and natural resource conservation (Budzich-Tabor, 2014). In principle, FLAGs offer an opportunity to support small-scale fisheries (Linke et al., 2022). However, FLAGs practices are highly diverse across the EU and both budgets and the implementation of FLAGs vary between member states (Budzich-Tabor, 2014; Bugeja-Said et al., 2022). As a result, the outcomes of FLAGs for small-scale fisheries have varied between states and they have not always contributed to the interests of small-scale fishers (e.g. Bugeja-Said et al., 2022; Salmi et al., 2022).

The literature on FLAGs has had a limited focus in the comparator countries, thus limiting the opportunities for analysis. Sweden is commonly presented as an example of failed FLAGs implementation (e.g. Bugeja-Said et al., 2022; Salmi et al., 2022). While FLAGs have provided the first platform for dialogue for all fisheries stakeholders in some areas of Sweden (Budzich-Tabor, 2014), FLAGs have failed to contribute to the development of small-scale fisheries and the interests of small-scale fisheries are compromised by the interests of more organised and powerful sectors such as tourism and large-scale fisheries (Bugeja-Said et al., 2022; Salmi et al., 2022). This is due to the integration of FLAGs into the broader LEADER programme, an EU initiative supporting broader project development, that weakened the support for small-scale fisheries (Salmi et al., 2022). In Denmark, FLAGs have succeeded in new market innovation, niche product development, and job creation (Bugeja-Said et al., 2022). However, the institutional design of FLAGs does not explicitly consider the inclusion of small-scale fisheries, and small-scale fisheries are a minority in Danish FLAG boards and lack a real voice (Bugeja-Said et al., 2022).

The literature on comparator countries demonstrates limited success of FLAGs on supporting small-scale fisheries. However, the general literature on FLAGs suggests that they have been successfully implemented to benefit small-scale fisheries in Finland (Bugeja-Said et al., 2022; Salmi et al., 2022). This is nevertheless beyond the geographic scope of this literature review.

2.4.4. Marine spatial planning

Marine spatial planning, or marine planning, is an example in which many stakeholders can participate in managing the sea, which could aid a just transition. Marine spatial planning internationally has been recognised as a practice to support the growth of offshore renewables and creating synergies in marine spaces by supporting decision-making processes, involving stakeholders in planning, improving user compatibility and providing access to information (Quero García et al., 2019; Tsai et al., 2022). While marine spatial planning is not the focus of this literature review, literature on the topic emerged inevitably as a result of the competing interests over marine space, particularly in the context of increasing development of marine renewables in the North Sea. This section does not aim to provide an in-depth exploration of marine spatial planning in the context of all marine sectors. Rather, it explores the dimensions of marine spatial planning directly related to offshore renewables and fisheries. Marine spatial planning in the UK context is discussed in 1.4.3.1.1. Marine spatial planning.

The key marine spatial planning issues identified in the literature in the context of fisheries and renewable energy include: fair distribution of marine space, stakeholder participation in decision-making, and compensation measures for groups negatively impacted by marine spatial planning measures. This section focuses on multi-use and co-location as practices to mitigate negative impacts that the transition to net-zero in the marine environment can cause to other marine users. Communities of Practice (COP) are introduced as a possible alternative. Compensation measures have been covered under 2.4.1.3. Offshore wind.

2.4.4.1. Multi-use and co-location

Several different industries, including offshore wind, fisheries and aquaculture are competing over the use of the same marine space internationally (Douvere and Ehler, 2009; Knol-Kauffman et al., 2023; Stelzenmüller et al., 2016). Marine spatial planning approaches where multiple actors share access to the same marine areas are commonly referred to as multi-use or co-location strategies (Owusu Bonsu et al., 2024; Schupp et al., 2021; Steins et al., 2021). Details surrounding co-location, and the difficulties and benefits associated with such an approach, are provided in the domestic review, in 1.4.3.4. Co-location.

Current international multi-use and co-location policies are strongly centred around offshore wind and fisheries (see boxes below), and the learning opportunities from international policy are thus strongly limited to these sectors. The boxes below provide details of policies in the UK and in international comparator countries on co-location and multi-use strategies. Co-location measures for fisheries during the installation stage of offshore wind follow similar patterns of 500m safety distance internationally (Owusu Bonsu et al., 2024). However, the co-location strategies post-installation vary widely between states, consisting of different implementations of safety zones, stakeholder access to these spaces, and the availability of compensation measures for fishers to mitigate the loss of income as a result of offshore developments. In comparison to the comparator countries, the literature reviewed suggests that the UK has very flexible policy measures for multi-use between offshore wind and fisheries. Co-location in the UK context is discussed in 1.4.3.4. Co-location and as a solution in 1.4.4.3. Encourage co-location. While it has been reported that some fishers avoid fishing in close proximity to windfarms due to safety risks and access to insurance (Chaji and Werner, 2023; Gray et al., 2016), there are no mandatory safe zones or gear regulations that are prevalent in many of the comparator countries. Furthermore, Schultz-Zehden et al., (2018) report that Scotland’s National Marine Plan encourages co-location between offshore wind and fisheries, where it makes good use of space (Scottish Government, 2015; Schultz-Zehden et al., 2018). As such, from the literature reviewed it appears that co-location in terms of access is encouraged more extensively in the UK in comparison to the comparator countries.

Offshore wind and fisheries co-location policies in international comparator countries

UK

Policy regimes support fishing within offshore windfarms (Schupp et al., 2021). No mandatory safety zones are implemented during operation, but the developer may apply for 50m safety zones around windfarm piles (Owusu Bonsu et al., 2024). Fishing is allowed on the basis of individual agreements with offshore developers (Owusu Bonsu et al., 2024).

Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) was set up to establish good relations for fishers and offshore wind (Tsai et al., 2022) and develop best practice for co-existence and mitigation for offshore renewables and fishing (Schultz-Zehden et al., 2018).

Denmark

No mandatory safety zones are implemented, but cable protection zones covering the windfarm and additional 200m around cables may be applied (Owusu Bonsu et al., 2024). Bottom trawling is allowed based on individual agreements (Owusu Bonsu et al., 2024).

The Netherlands

Area passports consisting of 500m safety zones around windfarms are implemented during operation (Owusu Bonsu et al., 2024). A 250m multi-use zone is implemented around monopiles and the sides of infield cables (Owusu Bonsu et al., 2024).

Access of boats is allowed in specific windfarms with strict requirements regarding size of the vessel, access hours, minimum distances of physical infrastructure, communication devices, and fishing gear regulations (see Schultz-Zehden et al., 2018)

Germany

150m safety zone from the outer buffer during operation (Owusu Bonsu et al., 2024). The transit of small fishing vessels is restricted in speed and subject to weather (Owusu Bonsu et al., 2024).

Belgium

Safety zones are implemented (Owusu Bonsu et al., 2024). Fishing within offshore wind developments is generally not allowed, with the exception of passive fishery in specific areas (Owusu Bonsu et al., 2024). Exceptions have been made for research purposes (Schultz-Zehden et al., 2018).

Norway

No defined safety zones are implemented, but up to 500m safety zones may be applied by the Norwegian Coastal Association (Owusu Bonsu et al., 2024). Fishing is allowed in cable areas (Owusu Bonsu et al., 2024).

Sweden

No mandatory safety zones are implemented, but the developer may apply for 50m safety zones around windfarm piles (Owusu Bonsu et al., 2024).

General multi-use strategies in international comparator countries

UK

Multi-use is part of national legislation and it happens at individual administrative decision level (Schultz-Zehden et al., 2018).

The UK Marine Policy Statement requires consideration for social and economic impacts of offshore wind of fishing and encourages co-existence strategies for offshore wind and other marine users (Schultz-Zehden et al., 2018).

Denmark

EU countries are required to develop marine spatial plans and consider opportunities for co-location (Schultz-Zehden et al., 2018). Multi-use is part of national legislation (Schultz-Zehden et al., 2018).

The Netherlands

EU countries are required to develop marine spatial plans and consider opportunities for co-location (Schultz-Zehden et al., 2018). Multi-use is part of national legislation and it happens at individual administrative decision level (Schultz-Zehden et al., 2018).

It is voluntary for offshore wind developers to allow multi-use (Steins et al., 2021). Multi-use is not compulsory or incentivised in the tendering process for offshore wind (Steins et al., 2021).

Communities of practice are used to support more inclusive MSP.

Germany

EU countries are required to develop marine spatial plans and consider opportunities for co-location (Schultz-Zehden et al., 2018). Multi-use is part of national legislation, but it happens at individual administrative decision level in the region of Mecklenburg-West Pomerania (Schultz-Zehden et al., 2018).

Under the German Marine Spatial Plan, different marine spatial users are given priority areas where uses that are not compatible with the priority are not permitted (Schupp et al., 2021). Priority areas for offshore wind are subject to strict safety regulations and exclude most other users (Schupp et al., 2021). Uses such as aquaculture are only allowed if they do not intervene with general maintenance of offshore wind (Schultz-Zehden et al., 2018). Fisheries do not have priority areas due to the changing fishing grounds and they are instead given special considerations in the priority areas of other users (Schupp et al., 2021).

Belgium

EU countries are required to develop marine spatial plans and consider opportunities for co-location (Schultz-Zehden et al., 2018). Multi-use is part of national legislation and it happens at individual administrative decision level (Schultz-Zehden et al., 2018).

Multi-use opportunities are identified through a zoning system that defines zones in which practices such as aquaculture can take place within offshore wind developments (Schultz-Zehden et al., 2018). Multi-use is subject to strict environmental conditions (Schultz-Zehden et al., 2018).

Norway

The ocean management system does not include cross-sectoral marine spatial planning beyond oil and gas (Knol-Kauffman et al., 2023).

Sweden

EU countries are required to develop marine spatial plans and consider opportunities for co-location (Schultz-Zehden et al., 2018). Multi-use is part of national legislation and it happens at individual administrative decision level (Schultz-Zehden et al., 2018).

2.4.4.2. Communities of Practice (COP)

Traditional marine spatial planning has been criticised in the literature due to a perceived lack of meaningful participation from all relevant stakeholders (Steins et al., 2021; Stelzenmüller et al., 2016). The power imbalances, particularly in the context of small-scale fisheries and renewable energy, have been highlighted alongside questions of who participates, who makes decisions, and who benefits from marine spatial planning (Stalmokaitė et al., 2023; Stelzenmüller et al., 2016). All three questions are important to deliver a just transition in partnership with those impacted by the marine energy transition. A complementary practice to marine spatial planning has been adopted in The Netherlands through developing Communities of Practice (see case study), which bring together stakeholders working in the area of multi-use pilots.

Communities of Practice in The Netherlands

As a result of various competing interests for the use of scarce marine space, the Ministry of Agriculture, Nature and Food Quality in The Netherlands initiated a Dutch Community of Practice North Sea (COPNS) as a way to share experiences of multi-use in marine space, learn from each other and stimulate the development of multi-use pilots (Steins et al., 2021). The COPNS was a community of policymakers and practitioners and focused specifically on balancing the spatial needs of offshore wind, conservation and marine food production (Steins et al., 2021). The meetings were tailored around government interest in their North Sea 2030 strategy.

COPNS were seen as an opportunity to encourage cooperation between stakeholders by creating a positive environment to address practical challenges related to the expansion of offshore wind, develop relationships between stakeholders and gain experience in marine multi-use (Steins et al., 2021). In contrast to traditional marine spatial planning, COP are seen as providing a more participatory platform to encourage cooperation in marine space by involving a variety of stakeholders including government representatives, researchers, NGOs and businesses (Government of The Netherlands, 2022, Steins et al., 2021).

With a limited amount of literature in English, evidence gaps exist surrounding COPNS and the impacts that the policy had on marine spatial planning in The Netherlands. COPs offer an opportunity to engage with different interest groups in the marine space and can be formatted around government or community leadership depending on the objectives of the COP. With COPs already being integrated in Scotland’s marine science and innovation strategy (see Scottish Government, 2024l), these could be utilised for the delivery of COPs in other topics related to a marine just transition.

2.4.5. Other sectors

Other sectors and topics that were identified as relevant for a marine just transition during the initial literature search included:

• Coastal communities and coastal management
• Blue economy
• Marine protected areas and conservation
• Aquaculture
• Fossil fuels (including workers and carbon capture and storage)
• Ports and shipping

Whilst these sectors are all relevant to the context of a marine just transition, they received different levels of coverage in the literature. Besides offshore renewables and fisheries that were the focus of this literature review, coastal communities emerged as a key topic in initial literature searches. The secondary themes consisted of marine spatial planning, blue economy, MPA and conservation, aquaculture and, fossil fuels (including workers and carbon capture and storage), and ports and shipping. The division between the sectors is highly artificial and made for the sake of practicality. In reality, these sectors and topics are strongly interlinked and rarely addressed in isolation from one another. Evidence gaps exist surrounding understanding how the remaining sectors interlink with a marine just transition in the sectors covered in this literature review.

2.5. Conclusion

This literature review has investigated the existing policy practices on marine just transition in an international context, specifically focusing on marine renewable energy and fisheries. It has identified existing international just transition oriented policy practices, their relationship with the objectives of the Scottish Government’s just transition strategy, and highlighted international policy practices that Scotland could learn from.

It was discovered that despite the large amount of existing international just transition oriented literature, there is a limited amount of literature that specifically addressed policy practices. This is likely a result of one or more of the following factors: nascent industries with limited policies in place, emerging policy practices with limited evidence of their success, policy evaluations written in the native languages of the comparator countries, and/or a lack of evaluative research in general.

The key findings of this review of evidence from international comparators are:

• Scotland is perceived to be one of the leading countries in offshore renewables development which limits the learning opportunities from other countries with similar marine spaces.
• Key just transition policies in the international context include community benefits, community ownership and compensation measures from offshore renewables; local action groups for fisheries; and multi-use and co-location in marine spatial planning.
• All marine sectors are deeply intertwined as a result of sharing the same marine space and one sector cannot be considered in separation from the others.
• Offshore wind
  • In the context of offshore renewables, a just transition is strongly centered around the distribution of benefits from renewable energy developments and the mitigation of negative impacts on other marine users.
  • Scotland is perceived by some academics to have advanced community benefit policies for offshore wind and the literature reviewed recommends maintaining the current model over alternative international examples.
  • Other nations have more experience with offshore energy community ownership, and there is strong potential to learn from both international offshore and domestic onshore practices.
  • Compensation measures from offshore developments are most commonly in place for fisheries, but there is a lack of evidence on best practices.
• Wave and tidal energy
  • There are limited examples of existing just transition oriented policies on wave and tidal energy, although the need for these policies is recognised.
  • Best practice can be learned from Canada with extensive policies on local participation and stakeholder engagement.
• Fisheries
  • Just transition for fisheries include better access to decision-making processes and community involvement.
  • While all fisheries are facing challenges, small-scale fisheries are identified as a particularly vulnerable group.
  • Best learning opportunities for Scotland in fisheries are inclusive stakeholder engagement in decision-making.
  • Fisheries local action groups support area-based development for fishers but the international examples have had limited success in contributing to the interest of small-scale fisheries.
• Marine Spatial Planning
  • Multi-use and co-location practices could be useful tools to accommodate for increasing competition in the marine space but there are evidence gaps with regards to the data, technology, policy, regulatory frameworks and incentives to deliver them.
  • The focus of multi-use is primarily on offshore wind and fisheries, with the UK demonstrating more flexible arrangements than most of the comparator countries.