1. Introduction
1.1. Introduction
- Berwick Bank Wind Farm Limited (BBWFL) is a wholly owned subsidiary of SSE Renewables Limited and will hereafter be referred to as ‘the Applicant’. The Applicant is developing the Berwick Bank Wind Farm (hereafter referred to as ‘the Project’).
- The Project is a proposed offshore wind farm located in the outer Firth of Forth and Firth of Tay, approximately 37.8 km east of the Scottish Borders coastline (St. Abb’s Head) and 47.6 km to the East Lothian coastline (see Figure 1.1 Open ▸ ).The Project is comprised of both the offshore and onshore infrastructure required to generate and transmit electricity from the Proposed Development array area to a Scottish Power Energy Networks (SPEN) 400 kV Grid Substation located at Branxton, south-west of Torness Power station. The offshore export cables will make landfall on the East Lothian coast, specifically at Skateraw.
- The offshore components of the Project (hereafter referred to as the ‘Proposed Development’) include the offshore wind farm (the wind turbines, their foundations and associated inter-array cabling), together with associated transmission infrastructure including Offshore Substation Platforms (OSPs)/Offshore convertor station platforms, their foundations and the offshore export cables and cable protection.
- The consents, licences and permissions which will be sought by the Applicant for the Project include:
- a Section 36 consent under the Electricity Act 1989 for an offshore generating station in the Scottish offshore region (12-200 nm) where generating capacity exceeds 50 megawatts (MW);
- Marine Licences under the Marine (Scotland) Act 2010 (0 to 12 nm) and Marine and Coastal Access Act 2009 (MCAA) (Scottish waters beyond 12 nm) for the following:
– generating station (wind turbines, wind turbine foundations and inter-array cables);
– transmission infrastructure (Offshore substation platforms (OSPs)/Offshore convertor station platforms, interconnector cables, offshore export cables and cable protection); and
- planning permission under the Town and Country Planning (Scotland) Act 1997 (as amended) for Project infrastructure landward of Mean Low Water Springs (MLWS).
- The Environmental Impact Assessment (EIA) Directive (2011/92/EU, as amended by Directive 2014/52/EU) has traditionally directed the assessment of effects of certain public and private projects on the environment in Scotland. Following the United Kingdom’s (UK’s) departure from the European Union (EU), EU-derived legislation continues to have effect in domestic law under the European Union (Withdrawal) Act 2018. For the purpose of this chapter (and throughout this offshore EIA Report), where legislation has been amended (for example, by EU Exit Amendment Regulations), following an initial acknowledgement of the amending legislation, the legislation is not referred to as amended.
- This Offshore Environmental Impact Assessment Report (EIA Report) has therefore been prepared by the Applicant in accordance with the traditional suite of implementing legislation in Scotland to accompany the above listed applications for consent. Volume 1, chapter 2 describes the policy and legislative background to the Proposed Development, including required consents and licences and EU Exit related changes therefore this has not been re-iterated here.
- This chapter introduces the Proposed Development, summarises the consents and/or licences that are required for the proposed works, and outlines the content of the Offshore EIA Report. The Applicant has prepared a separate Berwick Bank Wind Farm Onshore EIA Report (SSER, 2022a) which provides a description of the onshore elements of the Project landward of MLWS and will support the onshore consent and licence applications.
1.2. Project Overview
1.2.1. Firth of Forth Zone Round 3 Wind Farms
Firth of Forth Zone
- The Round 3 offshore wind development programme was instigated by The Crown Estate (TCE) in 2008. Suitable areas for the development of offshore wind were assessed through a statutory process of Strategic Environmental Assessment (SEA) undertaken by the Department of Energy and Climate Change (DECC), now Department for Business, Energy and Industrial Strategy (BEIS).
- As part of a competitive tender, Seagreen Wind Energy Limited (SWEL) was awarded the exclusive rights to the development of the Firth of Forth Zone by TCE in 2010. The subsequent Zone Development Agreement (ZDA) between SWEL and TCE provides the potential for the development of several offshore wind farms. Subsequently in 2019, the Firth of Forth ZDA was terminated, with the Agreement for Leases (AfLs) now agreed with the Crown Estate Scotland (CES) for Seagreen and the Proposed Development.
Phase 1
- In 2011, Phase 1 within the former Firth of Forth Zone included the development of two offshore wind farms known at the time as Seagreen Alpha and Seagreen Bravo (or Project Alpha and Project Bravo). Located around 27 km from the Angus coastline ( Figure 1.2 Open ▸ ), each project had a total maximum installed capacity of 525 MW (Seagreen Wind Energy, 2018). Offshore consent for both projects (collectively comprising 150 wind turbines and a cable corridor in to Carnoustie, connecting to a substation at Tealing) was received in October 2014 from Scottish Ministers. Consent was confirmed in November 2017 following a legal challenge by the Royal Society for the Protection of Birds (RSPB).
- In August 2018, SWEL varied the existing section 36 consents for Seagreen Alpha and Seagreen Bravo. This variation removed the capacity limits set for each project; the capacities were combined allowing for the development of a single, optimised project within the same sea area. This project (hereafter referred to as ‘Seagreen’) comprises of the two consented sites for Seagreen Alpha and Seagreen Bravo. A 15 year Contract for Difference (CfD) was awarded in September 2019 for 42% of the total project capacity (454 MW) and Seagreen reached financial close in June 2020.
- Seagreen was consented with permission to install 150 wind turbines. These 150 wind turbines are allocated to two sub projects to facilitate connections to the grid at different locations: ‘Seagreen 1’ refers to the installation of 114 wind turbines that will connect to the grid at Tealing (via the cable route to Carnoustie); ’Seagreen 1A Project” refers to the other 36 wind turbines that will connect to the grid at Cockenzie via a new cable route (the ‘Seagreen 1A Export Cable Corridor’).
- Pre-campaign surveys of the Seagreen offshore site took place from March to September 2021 and seabed preparation activities commenced in August 2021. Construction works at the export cable landfall commenced in May 2021 and construction at the offshore wind farm site commenced in September 2021. Construction will occur in two stages. Stage 1 will cover installation of up to 114 wind turbines on suction bucket caisson foundations and installation of the first OSP, and Stage 2 will cover installation of up to 36 wind turbines and installation of the second OSP.
Phase 2: Berwick Bank Wind Farm
- Phase 2 of the former Firth of Forth Zone includes the development of the Berwick Bank Wind Farm Proposal and the superseded Marr Bank Wind Farm Proposal. The 2020 Berwick Bank proposal was previously named ‘Seagreen 2’ and Marr Bank Wind Farm was previously named ‘Seagreen 3’. Volume 1, chapter 4 provides further detail on this.
- The Proposed Development boundary was established through review of both engineering and environmental constraints, including stakeholder feedback following stakeholder engagement throughout the pre-application phase.
- Further details on the site selection and consideration of alternatives to the Proposed Development are provided in volume 1, chapter 4.
- In May 2022, the Applicant changed the boundary of the Proposed Development. These changes to the Proposed Development boundary are largely focused on the west and northern areas of the Proposed Development array area and equate to a reduction in area of approximately 23% from the boundary presented in the Berwick Bank Wind Farm Offshore Scoping Report (SSER, 2021a). Marine Scotland Licensing and Operations Team (MS-LOT) confirmed at a meeting with the Applicant on 21 March 2022 that the Proposed Development did not need to be rescoped. The Applicant has undertaken a review of all application documents (technical reports and assessment chapters), drafted prior to these changes to ensure these reports continue to be relevant to the current proposal.
- A detailed project description for the Proposed Development is presented in volume 1, chapter 3.
- Key components of the Proposed Development include:
- wind turbines, including foundations and support structures;
- inter-array cables;
- interconnector cables;
- OSPs/Offshore convertor station platforms; and
- offshore export cables.
- The Proposed Development’s array area overlaps the large-scale morphological banks ‘Marr Bank’ and ‘Berwick Bank’ ( Figure 1.3 Open ▸ ). A maximum of 307 wind turbines will be installed in the Proposed Development array area, with either suction caisson jacket or piled jacket foundations proposed for the wind turbine foundations. There will also be up to ten OSPs/Offshore convertor station platforms installed with piled jackets or suction caisson jackets for the platform foundations. The wind turbines will connect to each other and to the OSPs/Offshore convertor station platforms via subsea inter-array cables, and the OSPs/Offshore convertor station platforms will be connected to other OSPs/Offshore convertor station platforms via interconnector cables.
- Up to eight offshore export cables will connect the OSPs/Offshore convertor station platforms to the landfall on the East Lothian coast, at Skateraw Harbour (hereafter referred to as the ‘Skateraw Landfall’)’. Once the cables make landfall, they will connect to the onshore substation/converter station, and then onto the grid connection point at Branxton, located south-west of Torness Power Station. This grid connection at Branxton will comprise a new 400 kV substation developed by SPEN.
- At this stage, the overall capacity for the Proposed Development is not defined as this relies on the number and capacity of the wind turbines installed, within the parameters of the Project design envelope defined for this assessment (however, the Project will have a capacity of more than 50 MW). Likewise, detailed site investigation works will improve understanding of the extent of the area for development and the most suitable locations for wind turbines. This will enable development capacity and site boundaries to be refined and confirmed prior to construction.
- In July 2022, National Grid Electricity Systems Operator (NGESO) announced as part of its Holistic Network Review, that the Applicant has signed an agreement for an additional grid connection at Blyth, Northumberland (referred to as the Cambois connection). Necessary consents for the Cambois connection (including marine licences) will be applied for separately once further development work has been undertaken on this export cable corridor route and landfall. These applications will be supported by an EIA and HRA. The Cambois connection has been included as a cumulative project for the purposes of the offshore EIA and assessed based on the information presented in the Cambois connection Scoping Report submitted in October 2022 (SSER, 2022e).
- The construction activities associated with the Proposed Development are anticipated to commence in 2025 and will last for up to 96 months. The decommissioning process is likely to follow a similar programme to construction, in a reverse manner. The Applicant has a 50 year AfL with CES and therefore, the Applicant is seeking a 35 year consent period to allow the wind farm to continue operating should the lifespan of the wind turbines allow.
1.3. Application for Consent
1.3.1. The Applicant
- The Applicant is a leading developer, owner and operator of renewable energy across the UK and Ireland, with a portfolio of around 4 GW of onshore wind, offshore wind and hydro. Part of the FTSE-listed SSE plc, its strategy is to drive the transition to a net zero future through the world class development, construction and operation of renewable energy assets.
- The Applicant is currently constructing on of the world’s largest offshore wind energy project, the 3.6 GW Dogger Bank Wind Farm in the North Sea, which is a joint venture with Equinor and Eni, as well as Scotland’s largest and the world's deepest fixed bottom offshore site, the 1.1 GW Seagreen Offshore Wind Farm in the Firth of Forth, a joint venture with Total Energies.
- When complete, Dogger Bank and Seagreen will help power millions of UK homes and businesses and drive the transition to Net Zero carbon emissions. These assets will join The Applicant’s existing operational offshore wind portfolio which consists of 487 MW across two offshore joint venture sites, Beatrice and Greater Gabbard, both of which are operated on behalf of asset partners.
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1.3.2. The offshore EIA consultant
- RPS Energy Consultants Ltd (hereafter referred to as ‘RPS’) were appointed by the Applicant to lead the production of the Offshore EIA Report. RPS is a founding member of the Institute of Environmental Management and Assessment (IEMA) and is a registrant of the IEMA Quality Mark scheme.
1.3.3. Application and Associated Documentation
- Separate consents, licences and permissions for the offshore (seaward of Mean High Water Springs (MHWS)) and onshore (landward of MLWS) infrastructure of the Project are being sought. The consents, licences and permissions which will be sought by the Applicant for the Project include those listed in paragraph 4 above. An overview of the offshore application documentation is provided in Table 1.1 Open ▸ . The onshore elements of the Project (landward of MLWS) and the onshore application documentation are discussed within the Berwick Bank Wind Farm Onshore EIA Report (SSER, 2022a).
- Further detail of the consents, licences and permissions and their associated policy and legislation for the Proposed Development is presented in volume 1, chapter 2.
1.3.4. Environmental Impact Assessment
Offshore and onshore EIA
- The Applicant has prepared separate Offshore and Onshore EIA Reports to support the separate consents, licences and permissions for the offshore (seaward of MHWS) and onshore (landward of MLWS) infrastructure of the Project. The Offshore EIA Report provides a description of the offshore elements of the Project (the offshore Proposed Development) and its likely significant effects on environmental receptors seaward of MHWS. The offshore EIA Report also covers potential impacts of offshore infrastructure (seaward of MHWS) on onshore receptors (i.e. impacts from infrastructure seaward of MHWS on onshore cultural heritage receptors). The Onshore EIA Report provides a description of the onshore elements of the Project and its likely significant effects on the onshore environment (landward of MLWS). The scope of the Offshore EIA Report and Onshore EIA Report are illustrated in Figure 1.4 Open ▸ . The onshore elements of the Project are not considered further in this Offshore EIA Report, except where it has been necessary to address intertidal elements or other relevant inter-related effects. The onshore Proposed Development is assessed as a cumulative project with the offshore Proposed Development.
Purpose of the offshore EIA
- This Offshore EIA Report has been prepared by the Applicant to accompany applications for consent as detailed in paragraph 4, section 1.1. The Offshore EIA Report is required to fulfil the requirements of the following regulations (collectively referred to hereafter as the EIA Regulations):
- in respect to the Section 36 consent application: The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 (as amended by The Town and Country Planning and Electricity Works (EU Exit) (Scotland) (Miscellaneous Amendments) Regulations 2019); and
- in respect to the marine licence applications: The Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017 (as amended by The Marine Environment (EU Exit) (Scotland) (Amendment) Regulations 2019).
- The Offshore EIA Report provides a description of the Proposed Development and presents the environmental information which has been gathered in order to carry out an assessment of the likely significant environmental effects of the Proposed Development (seaward of MHWS) on the receiving environment.
- The Offshore EIA Report specifically:
- provides statutory and non-statutory consultees with technical information to facilitate understanding of the Proposed Development;
- presents the existing environmental baseline information, established from desktop studies, site-specific surveys and/or consultation;
- describes the EIA methodology used for the assessments;
- presents the potential environmental impacts arising from the Proposed Development, based on baseline information and data gathered, and the analysis and impact assessments completed as part of the EIA process;
- outlines any limitations encountered during the compilation of the environmental information, including where any data gaps or deficiencies exists, and the level of confidence in the information gathered;
- suggests designed in mitigation measures to avoid, prevent, reduce or, where possible, offset any identified significant adverse effects on the environment, and where appropriate, proposed monitoring arrangements to validate findings of the EIA Report. Where additional mitigation measures have been identified, the residual significance of effect has also been presented; and
- provides a description of the reasonable alternatives considered for the Proposed Development, and an indication of the main reasons for site-selection.
- The Non-Technical Summary (NTS) provides an overview, in non-technical language, of the findings of the Offshore EIA Report. Both the Offshore EIA Report and the NTS are available for download: https://www.berwickbank.com.
Scope of the assessment
- In August 2020, the Applicant submitted a 2020 Berwick Bank Wind Farm Offshore Scoping Report to MS-LOT to support a request for a formal Scoping Opinion from Scottish Ministers in relation to the 2020 Berwick Bank Wind Farm Offshore Scoping Report (SSER, 2020). The intention at this time was that the Marr Bank project would be scoped separately. The Scoping Opinion for the 2020 Berwick Bank project was received in March 2021, which helped inform the proposed scope of the current assessment for the Proposed Development and guided the Applicant in progressing with the Offshore EIA Report.
- In response to advice received from stakeholders on the 2020 Berwick Bank Wind Farm Scoping Report (SSER, 2020), the Applicant started to explore options to combine Marr Bank and Berwick Bank into one single project (the ‘Berwick Bank Wind Farm’). A request for a formal Scoping Opinion from Scottish Ministers in relation to the single project (Berwick Bank Wind Farm) was subsequently submitted to MS-LOT in October 2021. The Scoping Opinion for the Berwick Bank Wind Farm was received in February 2022 (MS-LOT, 2022).
- The Scoping Opinion for the Berwick Bank Wind Farm (MS-LOT, 2022) set out the proposed scope of the assessment and guided the Applicant in progressing with this Offshore EIA Report. As far as responses provided in relation to 2020 Berwick Bank are relevant to the Proposed Development, or the Applicant has been directed to refer to them, the Applicant has relied on these responses to guide the scope of this Offshore EIA Report. Such responses are categorised within the term “relevant consultation undertaken to date”.
- Based on the Scoping Opinion received and discussions with stakeholders, this Offshore EIA Report focuses on the following topic areas:
- Physical Processes;
- Subsea Noise;
- Benthic Subtidal and Intertidal Ecology;
- Fish and Shellfish Ecology;
- Marine Mammals;
- Offshore and Intertidal Ornithology;
- Commercial Fisheries;
- Shipping and Navigation;
- Aviation, Military and Communications;
- Seascape, Landscape, Visual Resources;
- Cultural Heritage;
- Infrastructure and Other Users;
- Offshore Socio-economics and Tourism;
- Major Accidents and Disasters; and
- Water Quality.
- An Effects on Climate Assessment (through greenhouse gas emissions), Climate Vulnerability Assessment and an assessment of In-Combination Climate Impacts (ICCI) have also been completed. The results of these are presented in a Technical Appendix, with results from the assessments used, where relevant, to inform the impacts assessments listed above.
- Throughout the offshore EIA process, the Applicant has undertaken extensive consultation with statutory and non-statutory stakeholders, and actively engaged with the public at Public Consultation Events. Details of the consultation with statutory and non-statutory stakeholders and public consultation events is presented in volume 1, chapter 5, together with a full list of stakeholders who were consulted. A summary of topic specific consultation is also provided in each topic chapter (see volume 2, chapters 7 to 21).
Structure of the Offshore EIA Report and offshore EIA consultant
- The Offshore EIA Report relates to those impacts and receptors associated with the offshore environment (seaward of MHWS), including potential impacts of offshore infrastructure on onshore and offshore receptors (i.e. impacts from infrastructure seaward of MHWS).
- The Offshore EIA Report is divided into four volumes:
- volume 1 – Introductory Chapters;
- volume 2 – Offshore EIA Report Technical Assessments;
- volume 3 – Offshore EIA Technical Reports; and
- volume 4 – Outline Management Plans.
- Table 1.2 Open ▸ provides a breakdown of the contents of each of the Offshore EIA Report volumes and the organisations that have contributed to them.
- Table 1.3 Open ▸ provides details on the qualifications and experience of the competent experts involved in the Offshore EIA Report.
1.4. References
Marine Scotland Licensing Operations Team (2022). Scoping Opinion for Berwick Bank Wind Farm. Available at: Scoping Opinion – Berwick Bank Offshore Wind Farm | Marine Scotland Information. Accessed: 24 February 2022.
SSE Renewables (2020). Berwick Bank Wind Farm: Offshore Scoping Report. Available at: https://www.sserenewables.com/media/0t5n05b4/berwick-bank-wind-farm-offshore-scoping-report.pdf
SSE Renewables (2021a). Berwick Bank Wind Farm Offshore Scoping Report. Available at: https://berwickbank-eia.com/offshore-scoping/
SSE Renewables (2022a). Berwick Bank Wind Farm Onshore EIA Report.
SSE Renewables (2022e). Cambois Connection Scoping Report.