5.2. No Alternative Solutions Case: Step 1 – The Core Objectives

59. The need for the Array is demonstrated comprehensively in the Planning and Need Statement. In short, offshore wind must be deployed urgently, starting as soon as possible, and at scale.
60. Against this backdrop, the project objectives for the Array are set out in Table 5.1   Open ▸ . These core project objectives respond to the environmental, decarbonisation, regulatory, market and economic factors.

Table 5.1: Ossian Project Objectives

5.3. No Alternative Solutions Case: Step 2 – Do Nothing

61. The “do nothing” scenario would comprise not proceeding with the Array, and the loss of up to 3.6GW of offshore wind generation capacity. A “do nothing” scenario would not meet any of the Array core project objectives and can be discounted on that basis, for the reasons set out below.
62. If the Array does not proceed, a significant area of seabed (the site boundary located within the E1 Plan Option (PO) Area identified in the Sectoral Marine Plan (SMP)) will not be utilised for renewable energy generation, at least in the foreseeable future. The E1 PO Area was identified in the SMP and subsequent ScotWind leasing round as suitable, hence was made available, for large-scale offshore floating wind development in Scottish offshore waters. If the Array is not consented and constructed the area of seabed secured through the ScotWind leasing process would not be developed in the near-term (if at all).
63. The Applicant’s expertise in developing offshore wind in Scottish waters allows for deployment, at scale, of floating offshore wind in Scottish offshore waters, which is essential in meeting Scotland’s and the UK’s path to net zero.
64. One of the key Array objectives, which would not be achieved under the “do nothing” scenario, is to support the Scottish and UK Governments’ decarbonisation targets by development a floating offshore windfarm at a large scale to generate low carbon electricity within the early 2030s. The Array will make an essential contribution to increasing Scottish low-carbon energy supply. Maximising the generating capacity of the Array will provide the greatest possible support to Scotland to achieve its legally binding net zero commitment by 2045, and to the UK to achieve the same by 2050. As detailed in the Array Planning & Need Statement, the cumulative capacity of consented or submitted projects is unlikely to be of sufficient scale to meet the required capacity growth in renewable energy delivery without the successful delivery of a significant capacity of floating offshore wind, of which the Array is a key contributor. Not delivering the Array poses a significant threat to the UK’s plans to deliver net zero by 2050. Therefore, projects forming part of the ScotWind round must be delivered if Scotland’s net zero commitments are to remain within reach. Not developing the Array would be contrary to achieving Scotland and the UK’s net zero goals as well as failing to achieve any of the Array objectives.
65. The Planning & Need Statement also sets out that National Grid Electricity System Operator (ESO)’s Future Energy Scenarios (2023) predicts the need for between 97 GW and 115 GW of offshore wind capacity in the UK by 2050 to reach net zero. National Grid’s TEC Register[3] shows that in the UK, the capacity of offshore wind farms either already operational or in construction was 17.6 GW with a further 113.6 GW at scoping stage. Scottish offshore wind farm sites comprise approximately one third of this capacity.
66. Scottish Renewables recommended a 30% MW attrition rate in their 2018 “An industry view of the Draft Sectoral Marine Plan for Offshore Wind” to reflect the more challenging conditions in Scottish offshore waters relative to the rest of the UK, particularly regarding water depth, ground conditions and grid charges[4]. More recently, analysis by National Grid ESO shows that only 30-40% of projects in the queue go on to deliver to the National Grid[5]. The Applicant has produced a table of the attrition rates of UK leasing rounds, which shows on average substantially higher attrition rates in the three most recent leasing rounds in which projects have started construction ( Table 5.2   Open ▸ ). 

Table 5.2: Attrition Rates for UK Leasing Rounds

67. Therefore offshore wind projections need to be read and pursued in the knowledge that there is attrition during project development. Not all proposed offshore wind projects reach commercial operation, and some do so at reduced scale, or later than planned. Therefore, consenting a much larger offshore wind capacity than provided for in the various targets, as quickly as possible, is necessary to meet Net Zero
68. After accounting for anticipated attrition, it is clear that the delivery of substantial Scottish offshore wind is necessary for Scotland and the UK to meet its net zero legal obligations.
69. Other key Ossian objectives include security of supply, to lead a step-change for industry by deploying floating technology at large scale and kick-starting the floating technology industry, and to facilitate socio-economic development specifically within the floating wind sector. Ossian will become one of the largest floating wind farm projects globally, providing several GW of low-carbon electricity for the consumer through deployment of floating turbines at scale. This will make a significant contribution towards the Scottish and UK Governments’ net zero targets, whilst enabling the development of a home-grown market for industrial-scale floating wind technology.
70. Further, because electricity generated by floating offshore wind is not dependent on input fuels, the price of the electricity generated at Ossian, will provide a shield for electricity consumers against volatile international fuel markets.
71. In the absence of the Array, it will be substantially more difficult for the Scottish and UK Governments to achieve their offshore wind, particularly floating offshore wind, targets, and the floating industry will not be kick-started by the roll-out of such a large floating wind development. Therefore, Scottish and UK supply chain opportunities would also be missed.
72. Thus, the no-Array scenario would substantially hinder decarbonisation, security of supply and would not deliver the economic benefits of kick-starting a floating wind industry.
73. The importance of the decarbonisation, energy security and economic benefits objectives mean that no viable floating Offshore Wind Farm projects should be passed over in the development process. It is not compatible with a climate emergency to “do nothing”.
74. It is notable that the recent Derogation Case in respect of the Green Volt Offshore Wind Farm accords with this approach, with the Scottish Ministers finding that the “do nothing” approach would remove the risk of impacts to the qualifying features of designated sites but would not be consistent with the emissions reductions requirements of the Climate Change (Scotland) Act 2009 to mitigate the effects of climate change, and “in addition, the Scottish Ministers consider that taking a ‘do nothing’ approach would hinder meeting the ambitions set out in the British Energy Security Strategy. The Scottish Ministers do not consider the ‘do nothing approach’ to be a feasible alternative solution.”
75. In summary, this alternative would fail to meet all the Ossian core project objectives, as set out in Table 5.3   Open ▸ .
76. For these reasons, the “do nothing” option is discounted and does not form an alternative solution to the Array.

Table 5.3: Performance of “Do Nothing” Scenario Against Array Objectives

5.4. No Alternative Solutions Case: Step 3 – Identify Any Feasible Alternatives

5.4.1. Scope of Alternatives Considered

77. The approach to the identification of feasible alternative solutions in this section is informed by the guidance and previous Offshore Wind Farm derogation cases as well as the core objectives for the Array ( Table 5.1   Open ▸ ).
78. The “do nothing” option has been considered and discounted at Step 2 above.
79. Consistent with Defra guidance (2012 and 2021) and the consented English and Scottish Offshore Wind Farm HRA derogation decisions to date, the consideration of feasible alternative solutions is limited to alternative offshore wind farm projects, locations and designs. Alternative (non-Offshore Wind Farm) forms of energy generation would not meet the Ossian core project objectives and would not support fundamental Scottish and UK Government policy aims as articulated in the Planning and Need Statement. Therefore, the scope for consideration of potentially feasible alternative solutions is as follows:

• Alternative array locations not within the UK Renewable Energy Zone (REZ);
• Alternative array locations within the UK REZ, excluding the SMP PO Areas and ScotWind Leasing Round; and
• Alternative array locations within the SMP PO Areas and the ScotWind Leasing Rounds
• Alternative scale: array size, turbine layout and number within constraints of the E1 PO Area; and
• Alternative design: turbines, layout and minimum lower tip height.

80. Each of the above is considered in turn below, in the context of the Array project objectives and with regards to their financial, legal and technical feasibility.

5.4.2. Alternative Array Locations Not in the UK REZ

81. Scotland and the UK have legal obligations in relation to carbon emissions reductions to achieve net zero, and corresponding policy aims in respect of the deployment of renewable energy generation and energy security. Similarly, other international and EU countries have their own emission reduction and renewable energy targets, and security of energy supply aims.
82. Sites outside of the UK REZ have not been claimed by the UK under the Energy Act 2004 for exploitation for energy production, are not subject to CES or TCE offshore wind leasing rounds and are not available to the Applicant. Moreover, such sites are required for other EU member states and countries to achieve their own respective targets pursuant to the Paris Agreement in respect of climate change and renewable energy, and to ensure their own security of energy supply. Therefore, it is considered unlikely any such site would be made available for an Offshore Wind Farm to connect to the GB network.
83. For the above reasons alternative sites for offshore wind farms outside the UK REZ would provide no contribution to:

• Scottish and UK 2045/2050 net zero targets (Array objective 1); or
• Energy security of supply in UK (Array objective 2);

84. This alternative would also fail to meet the remaining Ossian core project objectives, as set out in Table 5.4   Open ▸ .

Table 5.4: Performance of Alternative Array Locations not in the UK REZ Against the Array Objectives

85. It is therefore concluded that locations outside the UK REZ cannot reasonably be considered a feasible alternative solution to the Array.
86. It is noted that a similar conclusion was reached by the Secretary of State in previous English Offshore Wind Farm HRA derogation cases. For example, the Secretary of State’s HRA for East Anglia ONE North states [underlining added]:
87. “Although the UK is party to international treaties and conventions in relation to climate change and renewable energy, according to the principle of subsidiarity and its legally binding commitments under those treaties and conventions, the UK has its own specific legal obligations and targets in relation to carbon emission reductions and renewable energy generation. Other international and EU countries similarly have their own (different) binding targets. Sites outside the UK are required for other countries to achieve their own respective targets in respect of climate change and renewable energy.”

5.4.3. Alternative Array Locations Outside the SMP Option Areas and ScotWind Leasing Round

                        Overview

88. This section considers the potential for alternative array sites in Scottish waters and the wider UK REZ, excluding the SMP PO Areas and ScotWind Leasing Round sites (in which the Array is located).

                        Legal Feasibility – Available Sites

89. TCE and CES own or exercise exclusive rights to manage the leasing of and exploitation of the seabed for offshore wind development within UK territorial waters and, through the Energy Act 2004, the wider UK REZ. TCE/CES make areas of seabed available for offshore wind development selectively in successive offshore leasing rounds, usually several years apart.
90. As noted above, in recent offshore wind farm HRA derogation decisions the Secretary of State has concluded that sites outside of areas secured by the respective applicant do not represent alternative locations. For example, again taking the HRA for East Anglia ONE North as an example:
91. “The site selection for all offshore wind proposals in the UK is controlled by TCE  leasing process. Sites not within the areas identified by TCE leasing process or outside of that which the Applicant has secured (the southern East Anglia Zone) are not legally available, and therefore do not represent alternative locations.”
92. The Applicant also notes the comments of the Scottish Ministers in their recent Appropriate Assessment made in respect of the Green Volt Offshore Wind Farm:
93. “The Scottish Ministers are aware that some of the Company’s objectives for the Project are set within the mechanisms for promoting the development of offshore wind and INTOG projects, notably Crown Estate Scotland’s exclusivity agreements in relation to the areas of the seabed to be developed. The Scottish Ministers note the Company’s reference to the Buzzard oil and gas platform complex but have not constrained themselves to solely assessing those alternatives that could be delivered by the Company. The Scottish Ministers however note that any alternative must be economically feasible for the Company (although it is acknowledged that higher cost alternatives to the Project can be considered) and allow it to fulfil the terms of its exclusivity agreement with Crown Estate Scotland.”
94. Outside of ScotWind, other areas of seabed are not available to the Applicant and are not feasible alternative solutions on that basis. However there are many additional reasons to discount other locations / leasing rounds as alternatives, as set out in the following sections.
95. The Applicant notes its comments above outlining the attrition rate applicable for UK offshore wind projects.

                        Future Offshore Wind Leasing Rounds

96. CES concluded the ScotWind leasing round (discussed in more detail in the following section of this Derogation Case) and the Innovation and Targeted Oil and Gas Decarbonisation (INTOG) leasing round. TCE is currently managing the leasing tender process for the future Celtic Sea (Round 5) leasing round.
97. Outside of Celtic Sea and INTOG, any future alternative location to replace the Array would depend on a fresh site leasing process being initiated by TCE and CES. There is no prospect of that in the short term.
98. When and where (or indeed if) any further areas of the seabed may be offered by either CES or TCE is unknown and a matter of speculation. At this stage, the availability of alternative locations outside of current TCE/CES leasing rounds is theoretical (as well as legally unavailable – see above) and can be discounted on that basis. Therefore, any parts of the UK REZ not currently the subject of an offshore wind farm leasing round do not constitute feasible alternative solutions.
99. Future locations released via future offshore leasing rounds can additionally be discounted on timing grounds. In the UK, the time between an announcement of a new leasing round and an offshore windfarm becoming operational can be more than 15 years. An example comes from TCE’s Round 3. The first public announcement for this leasing round was made by TCE in 2008, however as of 2024 turbines at some Round 3 projects are still being erected, and some planned projects are yet to initiate construction ( Table 5.2   Open ▸ ).
100. Even if an optimistic assumption is made that such timescales could be condensed by 1/3rd (e.g. assuming ten years from the announcement of a new leasing round to project becoming operational), a fresh offshore wind farm leasing round announced in 2025 would not deliver substantial additional installed offshore capacity within the early 2030s. Indeed, the current Round 5 in the Celtic Sea, which was first announced in 2020, is programmed to deliver by 2035[6]. 
101. These timescales are compounded by the allocation of grid connection dates, as demonstrated by Figure 5.1   Open ▸ , which demonstrates that there are several GWs of capacity in the pipeline that do not yet have an allocated connection date. The grid connection position for any future leasing rounds is entirely unclear.

Figure 5.1  Scottish Offshore Wind Capacity Pipeline

102. The huge scale of Scotland and UK targets for offshore wind and the statutory requirement to achieve net zero carbon emissions by 2045 (Scotland) and 2050 (UK) and prevalence of offshore environmental and technical constraints mean that lost capacity at the scale of Ossian cannot be expected to be offset by other future uninitiated leasing rounds, even on the most optimistic of outlooks.
103. For the reasons set out above, it is concluded that alternative locations outside areas / sites currently identified for leasing either by CES or TCE are not alternative solutions to the Array.

                        Active Crown Estate Offshore Wind Farm Leasing Rounds

                        Overview

104. CES and TCE leasing rounds completed or underway comprise TCE Rounds 1 (2000), 2 (2003), 3 (2010) and 4 (2021); the two extension rounds (2010 and 2017), the Scottish Territorial water round (2009), ScotWind (2022), INTOG (2023) and the latest Round 5 in the Celtic Sea (expected 2025)). The Array is located within the SMP E1 PO Area, a region identified and made available by CES during the ScotWind Leasing Round.
105. Operational / existing offshore wind farm projects from Rounds 1, 2 and 3, the TCE Extensions Round (2010) and the Scottish Territorial Waters rounds have already been fully or largely developed and form part of the existing baseline of offshore wind farm installed capacity. They do not provide additional installed capacity (as an alternative to the Array) that is required to achieve current Scottish and UK Offshore Wind Farm capacity targets. Accordingly, they can be discounted as alternatives to the Array.
106. TCE Project Listings lists 1.9 GW of built offshore wind in Scotland, with a further 4.1 GW of consented and/or committed projects which are currently scheduled to deliver before 2025. These projects include Neart na Gaoithe (0.4 GW), Seagreen Phase 1 (1.1 GW), Inch Cape (1.1 GW), Moray West (0.9 GW) and Seagreen Phase 1A (0.5 GW).

                        TCE Extension Round 2017

107. Seven extension sites in English and Welsh waters were awarded in 2017 with a total combined capacity of 2.85 GW. The following observations are made:

• It would be necessary for all seven extension projects to be delivered to their maximum anticipated capacity, and even then their combined maximum capacity would offset just ~80% of the capacity of the Array.
• None of the TCE Extension 2017 round projects utilise floating turbine technology. Therefore, the TCE Extension Round 2017 projects would not achieve the Array core project objectives 3 (driving down the cost of floating wind to achieve the lowest viable cost of low carbon electricity for the UK consumer that can be delivered at scale), 4 (generate renewable power on seabed at greater depths), 5 (leading the step-change for industry by deploying floating technology at a large scale), or 6 (facilitating socio-economic development within the floating wind sector).
• None of the TCE Extension Round 2017 projects contribute to Scottish domestic decarbonisation targets.

108. It has been concluded in previous Sections of this Report that “do nothing” (i.e. the no Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of the TCE Extensions Round (2017) does not alter that conclusion.
109. For all these reasons, reliance on TCE Extensions Round (2017) projects (alone or in aggregate) is not an alternative solution to Ossian.

                        TCE Round 4 Sites

110. Six Round 4 projects in English and Welsh waters were selected in February 2021 with a total estimated combined capacity of 7,980 MW. None of the projects use floating turbine technology. Five of the six projects have proposed total capacities of 1,500 MW, with the remainder proposing a total capacity of 480 MW[7]. TCE concluded signing Agreements for Lease with the Round 4 developers in January 2023.
111. The following observations are made:

• The Applicant does not hold any development rights in any Round 4 sites. None of the Round 4 sites are available to the Applicant.
• The maximum individual project size is set at 1.5GW and no individual project progressed via Round 4 would make the same contribution as the Array.
• None of the TCE Round 4 projects utilise floating turbine technology. Therefore the Round 4 projects would not achieve the Array core project objectives 3 (driving down the cost of floating wind to achieve the lowest viable cost of low carbon electricity for the UK consumer that can be delivered at scale), 4 (generate renewable power on seabed at greater depths), 5 (leading the step-change for industry by deploying floating technology at a large scale), or 6 (facilitating socio-economic development within the floating wind sector).
• None of the TCE Extension Round 2017 projects contribute to Scottish domestic decarbonisation targets.

112. It has been concluded in previous Sections of this Report that “do nothing” (i.e. the no Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of the Round 4 sites does not alter that conclusion.
113. For all these reasons, it is concluded that reliance on Round 4 projects (alone or in aggregate) is not an alternative solution to the Array.

                        Celtic Sea Floating Offshore Wind Farm Round

114. TCE is currently inviting tenders for a leasing round for floating wind projects in the Celtic Sea. The Celtic Sea round is intended to provide up to 4.5GW of floating wind energy capacity by 2035 across three project development areas. Each project development area has a maximum potential energy generation capacity of 1.5 GW.
115. The tender process is currently underway, with auction outcomes and the award of Agreements for Lease expected from Summer 2025.
116. The following observations are made:

• Grid connection dates for the Celtic Sea projects are currently indicative, pending the outcome of the HNDFUE exercise. Further to the grid connection timescales information provided above ( Figure 5.1   Open ▸ ) there is already several GW of capacity in the pipeline with no connection date. The grid connection dates for the Celtic Sea projects are yet to be clarified, and are likely to be in the early to mid-2030s at the earliest.
• The maximum individual project size is set at 1.5 GW and no individual project progressed via the Celtic Sea round would make the same contribution as the Array. All Celtic Sea projects will need to come forward to match (and surpass) the contribution made by the Array. However factoring in a conservative attrition rate of 30%, the Celtic Sea projects may only deliver 3.15 GW.
• Celtic Sea projects will not contribute to Scotland’s domestic decarbonisation targets.

117. It has been concluded in previous Sections of this Report that “do nothing” (i.e. the no Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of the Celtic Sea leasing round does not alter that conclusion.
118. For all these reasons, it is concluded that reliance on the Celtic Sea projects (alone or in aggregate) is not an alternative solution to the Array.

                        INTOG

119. The INTOG leasing round has been established to allow future OWFs to provide low carbon electricity to power oil and gas installation as well as alternative outputs such as hydrogen. Two types and scales of project are envisaged by CES:

• “IN” – small scale projects of less than 100 MW; and
• “TOG” – projects connected directly to oil and has infrastructure, to provide electricity and reduce the carbon emissions associated with production.

120. CES has set a maximum aggregate capacity limit that can be awarded exclusivity of 5.7 GW for TOG projects and 500 MW for IN projects. Therefore, the overall capacity of the INTOG leasing round is currently expected to be close to 6.2 GW.
121. The application window for INTOG closed on 18 November 2022. Option agreements are expected to be offered in 2024.
122. The following observations are made:

• Current data shows that 5.4GW of INTOG projects are listed on Crown Estate Scotland’s database. Of these, it is the Applicant’s understanding that nine projects (totalling 4.8GW) currently have no Transmission Entry Capacity (TEC). Three projects (GreenVolt, Salamander and Scaraben, totalling 600MW) have TEC, however those projects are of substantially smaller capacity than the Array (comprising 300 MW, 200 MW and 100 MW respectively compared to the Array’s up to 3.6 GW capacity).  The projects are therefore not on the same ‘large-scale’ as the Array (which is relevant to Array Objective 1).
• It is expected that many of the TOG projects will connect to an off-grid solution (i.e., an oil and gas installation), to facilitate the North Sea energy transition. Thus, in the case of these projects the intention is primarily to decarbonise oil and gas infrastructure.
• Even if some of the INTOG projects are brought forward as floating offshore wind farm projects, as per comments above the individual INTOG projects are not being delivered at the scale of the Array. Accordingly, it is unlikely that the INTOG round would achieve the Array objective 1 (developing a floating offshore windfarm at a large scale) or objective 5 (leading the step-change for industry by deploying floating technology at a large scale).

123. As set out above, historic data shows an average attrition rate of approximately 30% to 40% of OWF rounds. Therefore applying a precautionary attrition rate of 30% it can be anticipated that the INTOG Round will deliver 4.3 GW of power.
124. It has been concluded in previous sections of this document that “do nothing” (i.e. the no Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of the INTOG leasing round does not alter that conclusion.
125. For all these reasons, it is concluded that reliance on INTOG projects (alone or in aggregate) is not an alternative solution to the Array.

5.4.4. Repowering Existing Offshore Wind Farms

126. Most operational wind farms to date typically have an expected operational life span of between 20 years and 35 years (although TCE/CES leasing periods can be longer) before either decommissioning or repowering is considered.  To date, only Blyth Offshore Wind Farm has been decommissioned (in 2019, 41.5 MW). As wind turbine technology continues to evolve and the understanding of turbine condition and performance monitoring grows, offshore windfarm assets may be expected to operate for longer periods than originally anticipated. However, it is possible that some existing offshore windfarms will be repowered in the short to medium term.
127. The following observations are made:

• Not all existing offshore wind farms will necessarily repower[8].
• Many of the earlier offshore wind farms (Rounds 1 and 2) are closer to shore and larger/modern scale turbines may give rise to greater landscape and visual impacts, with additional consenting risk.
• Given all the above, it cannot be assumed that repowering will have a material additive effect in terms of increasing the baseline of installed offshore wind farms capacity, or that it would provide anything approaching the Array’s up to 3.6 GW of additional/new installed offshore wind farm capacity.
• While it could reasonably be assumed that consenting and development timescales will be shorter than for new ‘greenfield’ locations, that may be offset to some degree by downstream complexities around decommissioning old infrastructure and constructing the repowering infrastructure.
• It is unclear whether existing offshore wind farms would be offered continued or new grid connections, and when those connections would be able to come ‘online’ for delivering power to the grid. As set out in Figure 5.1   Open ▸ above there is substantial capacity of projects that have not yet been offered connection dates.
• Repowering of existing offshore windfarm projects will not achieve the Array project objectives: 1 (To support the Scottish and UK Governments’ decarbonisation and climate change targets by developing a floating offshore windfarm at a large scale to generate low carbon electricity in the early 2030’s); 3 (Driving down the cost of floating wind technology to achieve the lowest viable cost of low carbon energy for the UK consumer which can be delivered at scale); 4 (Deploying floating wind technology at scale to generate renewable, low-carbon electricity from deep locations); 5 (leading step change for the industry by deploying floating technology at scale) or 6 (Delivering project skills and employment for Scotland and UK and supporting investment in the Scottish economy through the supply chain).

128. It has been concluded in previous Sections of this Report that “do nothing” (i.e. the no Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of repowered offshore wind farms does not alter that conclusion.
129. For all these reasons, it is concluded that reliance on repowered offshore wind farms (alone or in aggregate) is not an alternative solution to the Array.

5.4.5. Summary and Conclusions

130. The analysis in this section demonstrates that the Array is critical to achieving Scottish and UK Government targets and there are no alternative offshore locations that constitute feasible alternative solutions to the Array.
131. This conclusion is reached on one or more of the following grounds and as summarised under Table 5.5   Open ▸ when comparing the other sites to the Array objectives. The Array will deliver up to 3.6 GW of floating renewable electricity and has a grid connection within the early 2030s. No other project considered in this section can achieve that large-scale floating renewable development in those timescales.
132. Other than Celtic Sea and INTOG, no other leasing round projects comprise floating wind technology. Compared to Celtic Sea and INTOG, the Array offers the floating development at scale with an early 2030s grid connection that can support the kick-starting of the floating sector and sustain that, to the benefit of Scottish and UK consumers, the floating supply chain, and the Scottish and UK economy.
133. When considering the challenging UK and Scottish decarbonisation and net zero targets and the typical attrition rate in offshore wind, it is clear that more offshore wind development is necessary to achieve these binding renewables targets.

Table 5.5: Performance of Alternative Array Locations outside SMP Option Areas and ScotWind Leasing Round Against Array Objectives

5.4.6. Alternative Array Locations Within the Sectoral Marine Plan Option Areas and the ScotWind Leasing Round

                        Overview

134. In November 2017, Crown Estate Scotland (CES) announced its intention to launch a leasing round for commercial scale offshore wind energy projects within Scottish waters (Scottish Government, 2020a). The SMP for Offshore Wind Energy provided the spatial framework for this leasing round through identification of which areas of seabed could be available for leasing by CES. The development of the SMP for Offshore Wind Energy began in 2018, with Draft Plan Options (DPOs) published in early 2019.
135. The first ScotWind Leasing Round was subsequently launched by CES in June 2020. In the ScotWind Leasing Round, developers were able to apply for the rights to build offshore wind farms in Scottish waters within specified lease areas initially based upon the DPOs as per the SMP. The final Plan Option (PO) Areas were published in October 2020.
136. In November 2020, the Applicant announced that they were in the process of preparing bids for PO Areas offered as part of the ScotWind Leasing Round (SSER, 2020).
137. Based on the lease areas put forward as part of the ScotWind Leasing Round, it was expected that up to 10 GW of new generating capacity would be built over the following ten years. The application window for registered applicants opened in January 2021 and closed in July 2021, with Option to Lease Agreements offered in January 2022.

                        Sectoral Marine Plan – identification and development of Plan Option areas

138. The SMP for Offshore Wind Energy was published by the Scottish Government in October 2020. The SMP outlines a spatial strategy for commercial scale offshore wind development in Scotland and provides a strategic framework for the ScotWind Leasing Round (Scottish Government, 2020a) through the identification of 15 final PO Areas across four regions (West (W), North (N), North East (NE) and East (E)) for renewable energy generation, with a national limit on generating capacity of 10 GW.
139. An iterative process was followed to develop these final PO Areas. Firstly, initial Areas of Search (AoS) were identified and subsequently refined through two iterations of Opportunity and Constraint Analysis. The first iteration of Opportunity and Constraints Analysis, published as part of the AoS scoping report in 2018, built upon work undertaken by Marine Directorate – Science Evidence, Data and Digital (MD-SEDD; formerly Marine Scotland Science (MSS)) in 2011, and draft Regional Locational Guidance for potential deep water floating offshore wind test sites in 2014 (Scottish Government, 2018). The aim of this first iteration was to develop broad AoS which could be viable for offshore wind development and serve as a starting point in the development of PO Areas (Scottish Government, 2018).
140. This process resulted in the production of a map depicting broad AoS, showing varying degrees of constraint with higher levels of constraint typically located closer to shore and lower levels of constraint typically located further offshore. From this map, six broad AoS were identified. A refinement process was then carried out which considered the spatial extent of single-issue activities which included individual species fishing activity, combined shipping routes and marine nature protection designations. This resulted in 24 distinct AoS within the six broad AoS identified which were taken forward into the planning process of the SMP (Scottish Government, 2018).
141. In June and July 2018, Scottish Ministers consulted on the screening and scoping stages of the SMP. Following this, a third iteration of Opportunity and Constraints Analysis was undertaken to consider stakeholder responses received during Scoping consultation. Certain AoS were either removed or refined to avoid or incorporate certain areas of Scottish waters. Areas of seabed which were proposed by stakeholders via the Scoping consultation were also considered. Although a number of the areas proposed by stakeholders overlapped with existing AoS, some overlapped with areas with higher levels of constraint and some areas proposed were completely new areas. Following the review of this information, a number of areas were identified to move forward in the plan process, including some additional areas where there was significant stakeholder interest but also increased constraint (Scottish Government, 2020a).
142. Following the third iteration of Opportunity and Constraints Analysis, 22 revised AoS were brought forward to the SMP Project Board and Project Steering Groups for consideration and comment. Scottish Ministers then reviewed these, resulting in the selection of 17 revised AoS as DPOs (Scottish Government, 2020a).
143. The DPOs were subject to a Sustainability Appraisal process, comprising a Strategic Environmental Assessment (SEA), Habitats Regulations Appraisal (HRA) and Social and Economic Impact Assessment (SEIA), which examined cross-sectoral impacts of the DPOs to support sustainable development of renewable energy generation in Scottish waters. The Sustainability Appraisal was undertaken on a technology neutral basis, and the impacts of individual DPOs were assessed using a realistic maximum deployment scenario (in GW) for each DPO, equating to a proportion of the overall area of the DPO. The potential impacts were assessed at regional and national levels and used a range of deployment scenarios in order to assess a wide range of impacts.
144. The SEA provided broad recommendations on the DPOs from a strategic perspective and identified potential strategic environmental constraints to steer future development. The SEIA considered the adverse and beneficial socio-economic impacts of the SMP on a range of sectors.
145. The HRA was undertaken as it was identified that the possibility of likely significant effects on European site(s) from the SMP could not be excluded, either due to development within an individual DPO or in combination with other plans or projects (Scottish Government, 2020a). The HRA considered Special Areas of Conservation (SACs), candidate and possible SAC (cSACs and pSACs), Special Protected Areas (SPAs), proposed SPA (pSPAs), Sites of Community Importance (SCIs) and Ramsar sites (listed under the Ramsar Convention on Wetlands of International Importance), to identify sites where there is a potential for likely significant effects. A total of 468 European/Ramsar sites were identified within a 100 km screening buffer around the DPOs. An Appropriate Assessment was undertaken to determine whether there would be an adverse effect on integrity (AEOI) on any of the sites with reference to their conservation objectives (Scottish Government, 2019). It was concluded that development of offshore wind farm projects at DPOs E3, NE2, NE3, NE4, and NE5 could lead to an AEOI due to in-combination effects with other wind farm projects. The possibility that an AEOI from in-combination effects could also occur with other wind farm projects (including those already consented within the Moray region) if development at NE6 were to occur was also noted due to the increased risk to Kittiwake as a qualifying feature of the Troup, Pennan and Lion’s Heads SPA, however, this would be dependent upon NE4 and NE5 also being developed (Scottish Government, 2019).
146. The findings of the HRA have advised plan level and project level mitigation measures to avoid potential adverse impacts on site integrity. Plan level mitigation included classification of E3, NE2, NE3, NE4, NE5 and NE6 as being subject to high levels of ornithological constraint and development of these DPOs could only progress if sufficient scientific evidence could be provided to reduce the risk to an acceptable level (unless it can be determined that there are imperative reasons of overriding public interest that require development to proceed). In addition, project level mitigation for DPOs E1 and E2 was put forward, noting that regional level surveys should be carried out to address knowledge gaps regarding potential impacts arising from development of these DPOs (Scottish Government, 2020a; Scottish Government, 2019). 
147. Statutory consultation was held between 18 December 2019 and 25 March 2020 to seek feedback on the DPOs. A Consultation Analysis Report was produced to inform the Scottish Ministers’ decision on which DPOs to progress (Scottish Government, 2020b), following which, the SMP was published which identified the refined, final PO Areas (Scottish Government, 2020a). Of the 17 DPOs, 15 final PO Areas were identified.
148. The PO Areas and the SMP have been considered by the Applicant ahead of its identification of and successful bid for an area of seabed in the E1 PO Area, referred to during bid phase as ‘E1 East’. Further details of the Applicant’s selection process are set out in full in the Site Selection and Consideration of Alternatives (volume 1, chapter 4). In terms of a brief summary, the Applicant’s site selection and alternatives process identified the following key factors of the E1 East PO Area (see paragraph 154 for an explanation of the E1 East PO Area).
149. The Applicant considered, following review of metocean data and based on the Applicant’s significant experience in the offshore wind industry (Introduction (volume 1, chapter 1)), that the E1 East PO Area demonstrated the feasibility of designing, constructing and operating a floating offshore wind farm.
150. The E1 East PO Area does not overlap with any SACs or Nature Conservation Marine Protected Areas (NCMPAs) designated for benthic habitats or species, and there is generally limited diversity in the benthic species present in the E1 region.
151. The E1 East PO Area does not overlap with any existing or proposed designated sites. The E1 PO Area is located 40 km from the Firth of Forth Banks Complex NCMPA (designated for ocean quahog aggregations, offshore subtidal sands and gravels, shelf banks and mounds and moraines) and 115 km north-east of the Berwickshire and North Northumberland Coast SAC (designated for grey seal), therefore, any interaction between the E1 East PO Area and designated sites is considered to be negligible.
152. Potential impacts on fish species were determined to be limited.
153. Marine mammal species are known to be present in the E1 East PO Area, in lower densities in contrast to other more sensitive areas of the North Sea.
154. The E1 East PO Area is situated in an area of relatively low seabird density and away from seabird hotpots in the East region, during both breeding and non-breeding seasons. The E1 PO Area is located within the foraging range for limited key seabird colonies along the east coast of Scotland, and the distance from shore of the E1 PO Area further reduces ornithological constraints.
155. Commercial fishing activity within the E1 East PO Area was concluded to be negligible to very low in the western section, increasing from low to moderate activity towards the eastern boundary of the E1 East PO Area (i.e. east of the Array site boundary). In terms of commercial fishing constraints, consideration has been given to the areas identified by the Scottish Fishermen’s Federation (SFF) and Scottish White Fish Producers Association (SWFPA) as preferred for development (due to lower fishing density) and as a result the site boundary overlaps with three of these areas. The E1 East PO area was therefore selected to reduce interaction with commercial fishing activity and reduce the risk of any exclusion from key fishing grounds.
156. The Applicant has concluded that there are no feasible alternative sites within the SMP and ScotWind leasing area sites that meet the Array core project objectives. The conclusion is reached on the following key grounds:
157. The SMP identified other PO Areas but not the E1 PO Area as being subject to high levels of ornithological constraint. The PO Areas subject to high ornithological constraint identified in the SMP were PO Areas E3, NE2, NE3, NE4 and NE6. 
158. There will be project attrition in the years ahead and not all proposed ScotWind projects will progress on time, or at the full potential capacity. Some projects may not proceed at all. Indeed, analysis from National Grid[9] has shown that only 30-40% of projects in National Grid’s connection queue make it to fruition. For further details of the project attrition rate in offshore renewable energy development, please see section 3.7 of the Applicant’s Planning and Needs Statement.
159. Given the foraging range and behaviour of a number of the qualifying species of the affected SPAs, all possible locations for commercial scale OWFs within the Sectoral Marine Plan and ScotWind leasing areas have connectivity with one or more species from the SPAs. There is no location within the Sectoral Marine Plan and ScotWind leasing areas that could be developed without impacts on Scottish and/or UK SPAs. 
160. Only the E1 East PO Area is available to the Applicant; other ScotWind sites are leased to other developers.
161. The purpose of the remaining ScotWind projects is to provide additional capacity towards Scottish and UK renewables and offshore wind targets, and particularly in light of the attrition rate noted above, substantially more offshore wind capacity is required to meet legally binding net zero requirements. As noted above, the Planning & Need Statement also sets out that National Grid ESO’s Future Energy Scenarios (2023) predicts the need for between 97 and 115GW of offshore wind capacity in the UK by 2050 to reach net zero. National Grid’s TEC Register[10] shows that in the UK, the capacity of offshore wind farms either already operational or in construction was 17.6GW with a further 113.6GW at scoping stage. Scottish offshore wind farm sites comprise approximately one third of this capacity. After accounting for anticipated attrition, it is clear that the delivery of substantial Scottish offshore wind is necessary for Scotland and the UK to meet its net zero legal obligations.
162. It has been concluded in previous sections of this Report that “do nothing” (i.e. the no  Array scenario) is not an alternative solution and that Scottish and UK Offshore Wind Farm capacity targets will be substantially more difficult to achieve without the Array’s contribution. The existence of other ScotWind sites does not alter that conclusion.

                        Conclusions on Alternative Sites within the Sectoral Marine Plan Option Areas and the ScotWind Leasing Round

163. The preceding sections demonstrates that the final site boundary for the Array was the result of an iterative, careful and exhaustive process, one that supports the conclusion that there are no feasible alternative locations remaining within the SMP and ScotWind leasing round POs open to the Array that meet the project objectives. This conclusion is reached on the following key grounds as summarised under Table 5.6   Open ▸ when comparing the other sites to the Array objectives:
164. Only the E1 East PO Area is available to the Applicant; other ScotWind sites are leased to other developers.
165. The purpose of the remaining ScotWind projects is to provide additional capacity towards Scottish and UK renewables and offshore wind targets, and particularly in light of the attrition rate noted above, substantially more offshore wind capacity is required to meet legally binding net zero requirements.
166. Given the foraging range and behaviour of a number of the qualifying species of the affected SPAs, all possible locations for commercial scale OWFs within the Sectoral Marine Plan and ScotWind leasing areas have connectivity with one or more species from the SPAs. There is no location within the Sectoral Marine Plan and ScotWind leasing areas that could be developed without impacts on Scottish and/or UK SPAs. However, it should be noted that the SMP identified other PO Areas as being subject to high levels of ornithological constraint, but this did not include the E1 PO Area.

Table 5.6: Performance of Alternative Array Locations within the SMP Plan Option and ScotWind Leasing Round Site Areas against Array Objectives