8. No Alternative Solutions CASE: Step 4 - Comparative Analysis

293. In this case, Steps 1 – 3 have not identified any feasible alternative solutions to The Proposed Development which require to be assessed. Accordingly, Step 4 is not required.
294. It follows that there are no feasible alternatives to The Proposed Development.

9. Summary of Part B: No Alternative Solutions

296. An exhaustive design and mitigation process underpins the PDE for The Proposed Development.
297. Sections 6 and 7 above address the range of potential alternatives considered by the Applicant in determining the PDE for the Proposed Development. A total of eight potential alternative solutions have been considered but discounted for the reasons set out in PART B above, as summarised in Table 16   Open ▸ below.
298. This demonstrates to the Scottish Ministers that there are no feasible alternative solutions to The Proposed Development.
299. This overall conclusion reflects the need for and benefits of The Proposed Development as described in section 3 of this Report, which include:

• An estimated 4.1GW, delivering enough low-carbon electricity to power more than 5 million homes each year, starting from 2026.
• A substantial near-term (2020s) contribution to decarbonisation, offsetting millions of tonnes of CO2 emissions per annum from 2026.
• The Proposed Development is the only Scottish offshore wind project of significant scale which is proposed to commission between 2025 and 2030[77], which can “plug the gap” between Scottish CfD AR3 developments and ScotWind developments.
• Significant contribution to energy security of supply and affordability: if developed at its full technically achievable capacity, The Proposed Development would provide enough energy to replace 19% of Russian gas imports to the UK.
• Low cost to consumer owing to efficiencies from large scale, location closer to shore in shallower waters and use of proven fixed foundation technology
  300. The Proposed Development is an essential part of the future Scottish and UK generation mix.

 Table 16 Summary of potential alternative options discounted for The Proposed Development.

Part C: Imperative Reasons for Overriding Public Interest

10. Introduction to IROPI

10.1. Overview

301. This PART C of this Report provides the evidence which demonstrates that the Scottish Ministers can be satisfied that there are IROPI to authorise The Proposed Development.
302. It is concluded that there is a compelling case that The Proposed Development must be carried out for IROPI, which are fundamental to achieve Scottish and UK Governments’ legal commitments and policy objectives.
303. The IROPI case is supported by and draws in particular upon the following documents which accompany the different planning applications for the Project:

• Statement of Need;
• Offshore Planning Statement;
• Offshore EIA: Socio-economics Chapter (Volume 2 Chapter 18);
• Onshore EIA: Socio-economics Chapter (Volume 2 Chapter 13); and
• Socio-Economics and Tourism Technical Report (Volume 3 Appendix 18.1).

10.2. Approach to Stage 3B: IROPI

304. The Habitats Regulations provide that the Scottish Ministers may agree to The Proposed Development if “satisfied” that it “must be carried out for imperative reasons of overriding public interest (which…may be of a social or economic nature)…”[79]
305. It is important to note in this case that the RIAA does not identify any AEOI in respect of priority habitat types or species.
306. However, as a barometer, it is helpful to note that where a priority habitat or species is adversely affected, the Habitats Regulations provide that “reasons relating to human health, public safety or beneficial consequences of primary importance to the environment” can constitute IROPI of greater importance than the nature conservation objective of protecting priority habitats/ species.
307. Beyond the above, the Habitats Regulations do not define the scope or nature of IROPI that may be relied upon, and it is necessary to consider the limited case law, EC opinions, guidance, and previous decisions, so far as relevant.

A Balancing Exercise

308. In terms of the nature of the exercise, the IROPI stage involves a balance of interests between the conservation objectives of the European site affected and the reasons for the project proceeding, and the competent authority must be satisfied that the balance weighs in favour of the latter[80].
309. This has been confirmed by the ECJ in several cases, for example in C‑43/10 (2012):

“An interest capable of justifying, for the purposes of Article 6(4) of Directive 92/43, the implementation of a plan or project must be both ‘public’ and ‘overriding’, which means that it must be of such an importance that it can be weighed against that directive’s objective of the conservation of natural habitats and wild fauna, including birds, and flora”[81]

310. In C-239/04[82], in his Opinion, Advocate General Kokott put it this way:

“The necessity of striking a balance result in particular from the concept of “override”, but also from the word “imperative”. Reasons of public interest can imperatively override the protection of a site only when greater importance attaches to them. This too has its equivalent in the test of proportionality, since under that principle the disadvantages caused must not be disproportionate to the aims pursued."

The Components of IROPI

311. The components of IROPI which inform this balancing exercise are explored in MN 2000 (2018) and Defra (2012). Drawing from those, the following principles can be distilled:

• Public Interest

–      The interest(s) served must be a public interest rather than a solely private interest. However, a private interest can coincide with delivery of a public objective and projects developed by private bodies can be authorised if public interests are served.

• Long-term

–      The public interest would normally (but not always) be long-term; short-term interests are less likely to be overriding because the conservation objectives of the Habitats and Birds Directives / Habitats Regulations are long term interests.

• Imperative

–      There should be urgency to the objective(s) and its or their achievement should be "indispensable" (MN 2000) or "essential" (Defra). In practical terms, according to MN 2000, this may be demonstrated if the objective falls within a framework for one or more of the following:

• actions or policies aiming to protect fundamental values for citizens' life (health, safety, environment);
• fundamental policies for the State and the Society; or
• activities of an economic or social nature, fulfilling specific obligations of public service.

–      Defra (2012) similarly advises that national policy and other documents setting out government policy may provide important context for the competent authority when considering whether there are IROPI and that projects which enact or contribute towards national plans or policies are more likely to imbue a high level of public interest.

• Overriding

–      The public interest of proceeding with a project must outweigh the public interest of conservation of the relevant European site(s). The recent DTA guidance (2021a: in draft) considers this in the context of offshore windfarms, expanding on EC and Defra guidance as follows:

• Climate change: “considerable weight should be given to their contributions to limiting climate change in accordance with the objectives of [climate change targets]” and “wind farm proposals deliver a national scale public interest on the grounds of energy security and supply as well as beneficial consequences of primary importance to the environment in respect of climate change”;
• Likely outcome: “it is highly unlikely that the public interest served by delivery of offshore wind proposals will not override the conservation interest (…but there may be exceptional circumstances where the imperative reasons of overriding public interest test cannot be passed)”.
  312. In this context it is also relevant and important to note recent developments within the EU. In late November 2022, the European Council agreed a draft Regulation to adopt a EC proposal for a framework to accelerate the permitting and deployment of renewable energy projects throughout the EU[83]. The draft Regulation is expected to be formally adopted, without substantial amendments, at the next extraordinary energy Council, which is expected to occur by mid-December 2022.
  313. The purpose of accelerating the permit-granting process immediately is to support the deployment of technologies that contribute to EU overall energy security and, at the same time, have a low environmental impact. In this context, one of the measures (Article 2) is a new presumption that deployment of renewable energy generating stations (and related grid infrastructure) is generally a matter of overriding public interest:

“planning, construction and operation of plants and installations for the production of energy from renewable sources, and their connection to the grid and the related grid itself and storage assets shall be presumed as being in the overriding public interest and serving public health and safety when balancing legal interests in the individual cases for the purposes of Articles 6(4) and 16(1)(c) of Directive 92/43/EEC [Habitats Directive], Article 4(7) of Directive 2000/60/EC [Water Framework Directive] and Article 9(1)(a) of Directive 2009/147/EC [Birds Directive]”.

314. Recital 8 of the draft Regulation explains that the presumption “…reflects the important role that renewable energy can play in the decarbonisation of the Union’s energy system, in offering immediate solutions to replace fossil-fuel based energy and in addressing the aggravated situation in the market”.

Relevant Examples of IROPI Decisions

315. It is also helpful to examine previous UK OWF projects where the HRA Derogation Provisions have been relied upon. IROPI have been established in the context of five recent decisions to authorise OWFs in the North Sea: Hornsea Three, Norfolk Vanguard, Norfolk Boreas, East Anglia ONE NORTH and East Anglia TWO.
316. Given its location within the North Sea and predicted impacts on similar SPA qualifying species (albeit different SPAs), these five previous OWF derogation cases (see Table 6   Open ▸ ) are highly relevant to The Proposed Development.
317. In each case, the SofS considered that the public benefit served by the OWF was “essential and urgent”[84]. The SofS’s conclusions were predicated upon ‘the principal and essential benefit of the Development as a significant contribution to limiting the extent of climate change in accordance with the objectives of the Climate Change Act 2008. The consequences of not achieving those objectives would be severely deleterious to societies across the globe, including the UK, to human health, to social and economic interests and to the environment.”
318. In each case, the SofS found that the Government’s “strategy for decarbonisation to achieve this commitment relies on contributions from all sectors delivered through multiple individual projects implemented by the private sector”.
319. In each case, the SofS accepted that “decarbonisation will lead to a substantially increased demand for electricity as other power sources are at least partially phased out or transformed. Simultaneously the supply of electricity must decarbonise. This will require the establishment of a reliable and secure mix of low-carbon electricity sources, including large-scale development of offshore wind generation”.
320. In each case, the SofS concluded that: “Offshore wind generation schemes can only be developed through the mechanism put in place by The Crown Estate for leasing areas of the seabed in a structured and timely way. Projects, like the Development, which make a significant contribution to meeting the target capacity in the timeframe required are therefore both necessary and urgent”.
321. While the IROPI balancing exercise in each case will turn on its own specific factors, it is established as a matter of principle that the long-term public interests served by the deployment of OWF projects are urgent and imperative and can be overriding in the context of impacts on SPAs in the North Sea.

10.3. Content and Structure

322. Drawing on the principles distilled from guidance as set out above, the information to demonstrate IROPI is structured as detailed below:

11. IROPI Case: Step 1 – Imperative Reasons

11.1. Introduction

323. The imperative reasons that justify The Project are considered in this Section under two headings:

• human health, public safety and beneficial consequences of primary importance to the environment
• socio-economic benefits.

11.2. Health, Safety and Beneficial EnvironmEntal Consequences

324. The imperative reasons that justify The Project primarily flow from and are consequent upon the need case summarised in Section 3.1 of this Report, which is predicated upon the critical near-term contribution The Project would make to the key pillars of climate and energy policy and security of energy supply. These are “reasons relating to human health, public safety or beneficial consequences of primary importance to the environment” which constitute IROPI.

Security of Energy Supply and Affordability

325. For the reasons set out in Section 3.3 above, reducing our dependency on foreign hydrocarbons is an imperative for security of supply, electricity cost and fuel poverty avoidance reasons.
326. The ECJ confirmed in 2019[85] that ensuring the security of the electricity supply constitutes an IROPI. The ECJ has held that security of energy supply in the EU is one of the fundamental objectives of EU policy in the field of energy. The ECJ went further, saying that, in any event “the objective of ensuring the security of electricity supply in a Member State at all times constitutes an imperative reason of overriding public interest, within the meaning of that provision”[86] [emphasis added].
327. As noted by the UK government in the BESS the imperative to ensure security of energy supply has been compounded by Russia’s invasion of Ukraine. This has had a direct impact on the affordability of energy in the UK. The BESS describes this on page 5:

“European gas prices soared by more than 200% last year and coal prices increased by more than 100%. This record rise in global energy prices has led to an unavoidable increase in the cost of living in the UK, as we use gas both to generate electricity, and to heat the majority of our 28 million homes.”

328. The urgency for an electricity system which is self-reliant and not reliant on fossil fuels is enormous to protect consumers from high and volatile energy prices, and to reduce opportunities for destructive geopolitical intrusion into national electricity supplies and economics. The energy security and affordability benefits associated with developing electricity supplies which are not dependent on volatile international markets and are located within the UK’s national boundaries are more important than ever.
329. With the prospect of providing 4.1GW of renewable electricity commencing in large part during the 2020s, there are IROPI justifying The Project on grounds of energy security alone.

Climate Change Risks

330. As set out in Section 3.1 of this Report above, human-induced global warming has already reached approximately 1ºC above pre-industrial levels and the impacts of climate change are global in scope and unprecedented in human existence (IPCC, 2021).
331. Climate change poses a risk to the health and safety of Scottish and UK citizens. The gravity of this risk has been made plain in recent reports by the IPCC and UK CCC. The IPCC’s AR6 Report underscores the gravity of the risk to the environment and consequently to humans and all life.
332. AR6 Report (part 1)[87] provided new estimates of the chances of crossing the global warming level at 1.5°C in the next decade. It concludes that, without immediate, rapid, and large-scale reductions in GHG, limiting warming close to 1.5°C or even 2°C will be beyond reach. The UN Secretary General described the AR6 Report as a “Code Red for humanity”.
333. AR6 Report (part 2)[88] was accompanied by a press release which described a narrowing window for action to address the threat to human wellbeing:

“The scientific evidence is unequivocal: climate change is a threat to human wellbeing and the health of the planet. Any further delay in concerted global action will miss a brief and rapidly closing window to secure a liveable future.”

334. AR6 Report (part 3)[89] confirms the harmful and permanent consequences of failing to limit the rise of global temperatures. The press release highlights that the “next two years are critical” (page 1) and that, limiting warming to around 1.5°C, would require “global greenhouse gas emissions to peak before 2025 at the latest, and be reduced by 43% by 2030” (page 2)
335. The key message from the AR6 Report is that humanity is not on track to limit warming and action to ensure deep reductions in CO2 and other GHG emissions must occur this decade and next.  
336. Action to address climate change is an imperative because the consequences of climate change include extreme weather events (flooding, heat waves and droughts), species extinctions and ecosystems collapse. These all threaten the health, safety, and environment of citizens in Scotland and the UK, for example by hindering food production, water resources and putting lives and settlements at risk. The climate stability that has enabled humans to prosper is now at risk.
337. The most recent UK climate change risk assessment published by the UK’s CCC Third Climate Change Risk Assessment, highlights 61 risks and opportunities resulting from climate change, as summarised in Table 17   Open ▸ . The Project will contribute to tackling the climate change risks identified.
338. As can be seen from Table 17   Open ▸ , the risk is not only to humans. There has been a significant long-term warming trend (by around 2°C) in the North Sea over the past century, which is significantly faster than the rate of warming of global oceans (Cefas, 2020). Our understanding of the effects of warming on the physical processes and ecology of the North Sea continues to advance.

Table 17 Risks identified in the CCRA3 Technical Report (CCC, 2021)

339. Although Scotland and the wider UK are leading decarbonisation efforts around the world, as described in section 3 of this Report above, their respective legal commitments of achieving Net Zero by 2045 and 2050 respectively are not yet assured.
340. For the reasons set out in Section 3 of this Report, a massive increase in energy generation from offshore wind is important to reduce electricity-related emissions and provide a timely next-step contribution this decade to a future generation portfolio which can support the massive increase in electricity demand.
341. As noted earlier, in previous OWF decisions, the SofS has recognised that the consequences of not taking action to seek to limit the extent of climate change would be “severely deleterious to societies across the globe, to human health, to social and economic interests and to the environment”.
342. The Project is aligned with and serves to implement fundamental Government policy and state aims and would make a very substantial contribution to meeting the target capacity in the timeframe required (i.e. by 2030). It follows that The Project is both necessary and urgent and is justified by IROPI based on delivery of beneficial consequences of primary importance to the environment, and for human health and public safety.

11.3. Socio-economic Benefits

Introduction

343. It is clear from the various policy documents addressed in the Applicant’s Statement of Need and Offshore Planning Statement that the Scottish Government plans to deliver on its Net Zero commitment by 2045 in a way that maximises the opportunities for Scottish industry to ensure a fair and just transition to clean energy.
344. The socio-economic impact of the Project is set out in Chapter 18 of the EIA Report (Volume 1), which refers to an economic impact study carried out by independent renewable energy consultants, BVG Associates (BVGA). It is also referenced in the Applicant’s Planning Statement. The following therefore provides a summary of the key findings.
345. The study carried out by independent renewable energy consultants, BVG Associates (BVGA), has shown that at peak construction in 2026 the Project could create around 4,650 direct, indirect and induced jobs in Scotland, and 9,300 in the UK – adding an estimated £8.3 billion to the UK economy as a whole over the life-time of the Project.
346. The Project is capable of providing substantial socio-economic benefits to the Scottish economy including facilitating confidence in the Scotland supply chain, growing a skilled workforce, improving Gross Value Added (GVA) and providing wider community benefits. A summary is set out below.

Employment

347. During manufacturing, construction, and installation activities, the assessment estimates that the Project would support around 4,800 jobs per annum and 6,000 total Full Time Employment (FTE) in Scotland under the Baseline UK Supply scenario (refer to Table 18.33 of the Offshore EIA Report, Volume 2, Chapter 18).
348. During development, manufacturing, construction, and installation activities, the Project will inevitably draw some of its labour from outside of a number of local economic development study areas. However, within the local study areas referenced in the assessment for this phase of development (Invergordon, Aberdeen, Dundee, and Leith), the potential employment is estimated to be approximately 1,100 total FTE years (direct employment) under the Baseline UK Supply scenario (refer to Table 18.33 of the Offshore EIA Report, Volume 2, Chapter 18).
349. In conclusion, there will be a material positive benefit for the offshore wind sector, with significant beneficial impacts on employment generally but especially during the construction phase.

Investment (GVA)

350. During manufacturing, construction, and installation activities, the SIA sets out that the Project has the potential to generate £360 million (maximum concurrent GVA) GVA per annum and £450 million in total GVA, at the Scotland national level. This is equivalent to 80% of the 2019 offshore wind sector GVA in Scotland (refer to Table 18.45 and 18.46 of the Offshore EIA Report, Volume 2, Chapter 18).
351. For the local study areas (Invergordon, Aberdeen, Dundee and Leith), this impact is £90 million GVA per annum and £90 million in total GVA (refer to Table 18.45 of the Offshore EIA Report, Volume 2, Chapter 18).
352. During operation and maintenance activities, the Project has the potential to generate between £76 million GVA per annum and £2,600 million in total over the whole operation and maintenance period at the Scotland national level (refer to Table 18.51 in the Offshore SIA – Chapter 18). This is equivalent to 16.9% of the 2019 offshore wind sector GVA in Scotland (refer to Table 18.52 of the Offshore EIA Report, Volume 2, Chapter 18).
353. For the local study areas (Aberdeen, Montrose, Dundee, Methil, Burntisland, Rosyth, Leith and support harbours), this impact is £34 million GVA per annum and £1,200 million in total (refer to Table 18.51 of the Offshore EIA Report, Volume 2, Chapter 18).

Supply Chain Capacity, Capability and Skills Development

354. The socio- economics and tourism local study area for the Project (Invergordon, Aberdeen, Montrose, Dundee, Methil, Burntisland, Rosyth, Leith and support harbours east of Leith) has benefitted significantly and will continue to benefit from three of SSER’s offshore wind farms: Seagreen 1 (under construction), Seagreen 1a (in development) both in the former Firth of Forth Zone; Beatrice (fully operation) in northeast Scotland.
355. SSER has an established presence in the Firth of Forth. The Project will benefit from Seagreen 1 (1,000 MW) within the former Firth of Forth Zone, the largest and deepest offshore wind farm in Scottish waters, developed by SSER in partnership with Total. SSER and Total have addressed the challenges of deploying offshore wind in deep waters and established a long-term supply chain and material employment prospects to the Scottish job market, including 400 Scottish construction jobs and 60 during operation and maintenance.
356. The SIA explains that the north Scotland local study area for The Project already benefits from SSER’s substantial development of Beatrice Offshore Wind Farm (588 MW), Scotland’s largest-ever private sector infrastructure investment at time of construction. This has contributed significant expenditure in Scotland including £10m on development and construction, £1.4bn on operational lifetime spend and has created 370 jobs. Of primary benefit to The Project is SSER’s investment of £20m for the renovation of Wick Harbour, as well as the Open4Business portal where local suppliers can register for contractual opportunities.
357. By seeking to maximise the capacity at The Project, it brings forward the important opportunity and potential for supply chain investment in Scotland to meet Scottish policy by supporting an expanding domestic market in Scotland-based support services in readiness for both ScotWind and international project support.
358. The Project will support the continued development of the Scotland and the wider UK’s offshore wind clusters, particularly those located near the development, through engagement with local business networks in order to increase supply chain participation. In addition to job generation and investment, The Project will also support the development of skills which the offshore wind industry needs to flourish. Building up to 4.1 GW of offshore wind capacity by 2030 in Scotland will support a significant number of skilled jobs.
359. The Applicant will develop an Outline Employment and Skills Plan which will include the plans to enhance the benefits available to the local and national economies. The Applicant will promote the opportunities for local economic benefit associated with The Project through promoting opportunities:

• for the involvement of local companies in the construction and operation supply chain (this will also be addressed in detail at local, regional and national level in the Supply Chain Plan (SCP) which is a requirement of the CfD process); and
• for local residents to access employment opportunities associated with the construction and operation of the wind farm.

11.4. Conclusions

360. With the potential to generate an estimated 4.1 GW, the Project will deliver a substantially sized single project with near-term contribution to national decarbonisation and energy security of supply objectives, whilst also delivering substantial socio-economic benefits.
361. In the previous OWF Decisions, the SofS has determined that the consequences of not contributing to the objective of limiting the extent of climate change would be “severely deleterious to societies across the globe, to human health, to social and economic interests and to the environment” (e.g. BEIS, 2020a: para 6.37). That conclusion applies equally in the context of The Project. Rapid decarbonisation of the energy sector not only provides beneficial consequences for the environment, it is essential for human health and public safety reasons.
362. Furthermore, as the ECJ has held[90], the security of the electricity supply constitutes an IROPI “at all times”, a position recently underlined by the proposed Council Regulation to introduce a presumption that renewable energy projects are “of overriding public interest and serving public health and safety”[91].
363. The imperative nature of the reasons applicable in this case flow from their urgency as well as their importance. The energy security of supply crises necessitates urgent action this decade. Similarly, the 2030 global ambition gap in relation to climate change mitigation will be closed only by bringing forward projects such as The Project which connect as much capacity as possible to as early as possible.
364. The imperative reasons to urgently deliver the Project are thus clear and demonstrable. The requirement to deliver significant volumes of renewable energy generating capacity is important not only to meet Scotland’s legally binding Net Zero commitment by 2045 and the UK’s by 2050, in response to the latest climate science but also to address the energy security of supply crisis which also constitutes a threat to human health and public safety. In turn, the size of the contribution expected from offshore wind by 2030, up to 11 GW in Scotland and 50 GW in the UK, demonstrates the scale and urgency of the task in hand.
365. In conclusion, The Project is justified for imperative reasons relating to human health, public safety and beneficial consequences of primary importance to the environment, and additionally by delivery of important socio-economic benefits in the form of investment and supply chain opportunities during the 2020s.

12. IROPI Case: Step 2 - Clear Public Interest

12.1. Facilitating Achievement of Fundamental State Aims

366. The Applicant is a private entity but there is a clear public interest served by The Project.
367. The drivers for offshore wind in general and for The Project specifically clearly stem from a suite of national and international law and policy (see Section 3 of this Report above) designed to serve fundamental public interests in dealing with the challenges and risks identified and summarised at IROPI Step 1 above. Those public interests, in short, are:

• Rapid decarbonisation to mitigate climate change
• Ensuring security of energy supply at affordable cost
  368. The strategy to harness Scotland’s and the UK’s offshore wind resource to produce renewable electricity can only be delivered through the private sector. All five previous OWF derogation decisions acknowledge this essential reality.
  369. Offshore wind is an important technology for low-carbon generation and the urgent need for large additional capacities of low-carbon generation to come on-stream is clear. The identification and development of offshore sites and the Round 3 Zones (including The Project) for that purpose is a fundamental national policy pursued within a clear framework, which seeks to protect the environment and human health from the consequences of energy supply shortages and climate change and promote public safety.
  370. As concluded earlier, without The Project, it is probable that delivery of multitude policies will fall short, including: the BESS, the Scottish Offshore Wind Policy Statement, the Sectoral Marine Plan for Offshore Wind, Scottish Energy Strategy, the UK Net Zero Strategy and UK Offshore Wind Sector Deal, as well as the targets set by the Climate Change (Scotland) Act 2009, Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, the (UK) Climate Change Act 2008 (as amended) and the Net Zero Strategy: Build back Greener.
  371. The Project can make a large, meaningful and timely contribution to decarbonisation and security of supply, while helping lower bills for consumers throughout its operational life, thereby addressing all important aspects of Scotland and the UK’s legal obligations and existing and emerging government policy.
  372. The interests that would be served by authorising The Project and therefore of a public nature.

13. IROPI Case: Step 3 - Long-term Interest

373. The public interests identified through IROPI Steps 1 and 2 above are long-term Scottish and UK interests.
374. The decarbonisation of society including the means of generating energy is a process that has been ongoing for decades and will continue for decades to come. The legal commitments to achieve Net Zero by 2045/2050 respectively are long term. However, Net Zero has to be maintained thereafter. It is not a temporary or fleeting interest, rather the objective is and must be a permanent condition whereby society is in better balance with the environment and is no longer contributing to climate change mechanisms. The transition to renewable energy is also a long-term public interest from an ecological standpoint.
375. Security of domestic energy supply, to ensure that the lights remain on is a continuous long-term obligation of every successive domestic and international Government. Energy supply security is a matter of long-term national interest and security against foreign powers.
376. The Project’s contribution to these objectives is itself long-term. It will be capable of providing 4.1GW of clean energy generation for around 35 years (possibly longer). It will contribute to Scotland and the UK's future low carbon energy mix beyond 2045 and beyond 2050.
377. The contribution of The Project is also strategically important, to ensuring continuity in the offshore wind sector. Large energy infrastructure projects have a long lead time and The Project is the only Scottish offshore wind project of significant scale which is proposed to commission between 2025 and 2030[92]. Therefore, The Project can “plug the gap” between Scottish CfD AR3 developments (coming online in the next three years) and ScotWind developments (coming on stream during the 2030s) and provide continuity for the supply chain. This lends greater long-term importance to The Project.
378. Finally, economic benefits through the creation of jobs, work-force upskilling and investment in supply chain are also expected from the construction, operation and maintenance of The Project. Such benefits live on beyond the immediate construction of the Project and can provide a long-lasting legacy (e.g. skilled workers who go on to work on successive OWF projects in the years and decades to come).