Offshore wind is hugely important in our efforts to decarbonise our energy system and reach our net zero targets. As 2020 creeps away and we start the next decade, we are entering an exciting new phase for offshore wind. The target is to have 11 Gigawatts (GW) of operating capacity by 2030 - an increase of around 10GW from today’s installed operating capacity. The plans for this next wave of offshore wind deployment are set out in the new Scottish Sectoral Marine Plan for Offshore Wind Energy, and accompanying Policy Statement.
Whilst we are supportive of offshore wind, historically the siting of projects has primarily been led by developers bidding for exclusivity rights to an area of the seabed in which to place one or several arrays. The environmental impacts of each project on protected wildlife and habitats would then generally be considered in detail at the point of application. The new Scottish Sectoral Plan moves away from this. It instead has attempted to fully consider potential impacts from the outset and puts in place requirements to assess and mitigate these impacts at the strategic plan level. At RSPB Scotland, we consider this new approach to be good progress; we have the mechanism to act on climate change and meet our ambitious emissions target without deepening our biodiversity crisis.
Having been involved in the preparation of the new Sectoral Marine Plan and Policy Statement and having had some time to review the final publications, three key points come to mind:
This latter point, the impacts that offshore wind poses to seabirds, is something RSPB Scotland has long been focused on and anticipated would come to a head eventually. In 2015, we brought a legal challenge against the decision to consent four commercial scale windfarms in the Forth and Tay region as they were predicted to cause major cumulative impacts on kittiwake, gannet, puffins and other seabird colonies. A plan level assessment of impacts rather than looking at individual projects could have avoided this. Regretfully, the initial judgement in our favour was later overturned and we were not given permission to pursue the case further. Nevertheless, we welcome the recognition in the new Sectoral Marine Plan that Scotland’s breeding seabird colonies are approaching environmental limits and consider this to be good progress. Acknowledging a problem is the first step to tackling it. The plan level mitigation required to protect these fantastic seabirds and their habitats is a further positive. We’ve reached this point in no small part by the huge efforts of RSPB Scotland’s staff and that of our colleagues across the RSPB, who have tirelessly engaged with Scottish and UK governments, key agencies and the sector directly over the last 15 plus years.
So, what next? We have the plans for a vast amount of offshore wind energy generating capacity to be delivered strategically in Scotland’s seas. We have some understanding of the effects this could have on seabirds. But we’re still not clear on how we make sure it is delivered in a way that is sensitive to nature and leaves enough space for nature to thrive. To reconcile the challenge of expanding Scotland’s offshore wind and threats to nature, we recommend:
1. Addressing the challenge of cumulative impacts
Multiple projects place individual and cumulative pressures on our environment. As more projects come forward, these pressures add up and we need to consider how we address them.
Sadly, we are already starting to see the cumulative impacts of offshore wind requiring compensation. In England, compensation has recently been required for the added impacts the Hornsea 3 wind farm is predicted to cause on kittiwakes. The measures proposed have not however been tested and by the time we know whether or not they work, it could be too late for the birds they are intended to help. Despite the publication of the new Sectoral Marine Plan in Scotland, we are still concerned that compensation could be necessary in Scottish waters soon too. We do not wish to repeat the mistakes seen elsewhere and believe there needs to be urgent scientific investigation into compensation options to make sure we find solutions that will succeed if necessary.
We’re keen to understand whether further cross-sector collaboration is something that could be explored to address the challenges of cumulative impacts. We believe a Scottish Marine Environmental Enhancement Fund might be one way of achieving this and we’d welcome opportunity to be involved in discussions to navigate the challenges and address the impacts posed by the growth of offshore wind.
2. Investing in Certainty
There are currently huge knowledge gaps in our understanding of seabirds, the marine environment and the long-term impacts of offshore wind on our seabird populations. Together these result in high levels of uncertainty in decision-making. Put with further uncertainty over the scale of impacts that will occur over the lifetime of a project, and there’s a worry we’re gambling with the future of some of Scotland’s most impressive wildlife. We only have one chance to get it right. We need investment and research into the impacts of offshore wind equal to the scale of ambition of growth for the sector. We need to avoid, and avoid with certainty, long-term population scale impacts on Scotland’s wildlife.
3. Investing in Green Skills and Green Jobs
We’re being warned of a renewable technology planning logjam jeopardising our net zero targets. This is not a reason to reduce planning processes and procedures as doing so may have unintended negative consequence for the environment and biodiversity. Instead we need to expand the skills and capacities of the environmental and planning sector. This way can help meet our Scottish climate targets and, equally importantly, avoid biodiversity loss. The global COVID19 pandemic has rocked the country. As part of our recovery from the pandemic there is a great opportunity to secure further support for jobs in environmental planning, environmental assessment, research and monitoring as well as in technology and engineering.
We believe the best way to ensure future offshore wind development is carried out in harmony with nature is through a robust, evidence-based approach to strategic planning. This way we can ensure decisions on future deployment genuinely avoid damaging impacts on marine wildlife. With the development of the new Sectoral Marine Plan, we remain optimistic that we can integrate action on climate and nature so that it works for people, we achieve net zero, and wildlife thrives. We recognise there will be difficult decisions, compromises and balances to be made. But with the progress made so far, and if we address the challenges outlined above, we will be several steps closer to a comprehensive strategic approach to the delivery of offshore wind development.
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