3.4.5.    Recommended Safe Passing Distances and Aids to Navigation

Safety zones, recommended safe passing distances and Notice to Mariners

  1. It is standard practice during the construction and operation of an offshore development to communicate with other mariners of safe clearance distances around construction, installation, maintenance and decommissioning activities.

Statutory safety zones

  1. The legal mechanism for establishing statutory safety zones is discussed in volume 1, chapter 2. The following safety zones will be recommended for the Proposed Development:
  • temporary (or rolling) 500 m safety zones surrounding the location of all fixed (surface piercing) structures where work is being undertaken by a construction vessel;
  • 50 m safety zones around all surface structures until commissioning where construction work is not active; and
  • 500 m around any structure where major maintenance is ongoing (major maintenance- works are defined within the Electricity (Offshore Generating Stations)(Safety Zones) (Application Procedures and Controls of Access) Regulations 2007.
    1. Statutory decommissioning safety zones will be applied for during the decommissioning phase as appropriate and are not expected to exceed the standard 500 m.

Recommended safe passing distances

  1. Recommended safe passing distances may also be used during the construction, operation and maintenance and decommissioning phases to ensure the safety of third party vessels. These will be communicated via Notice to Mariners (NtMs) during all phases of the Proposed Development.

Aids to navigation

  1. The lighting and marking of wind turbines and OSPs/Offshore convertor station platforms to aid navigation will be defined post consent in consultation with the Northern Lighthouse Board (NLB), Marine and Coastguard Agency (MCA), the Civil Aviation Authority (CAA) and the Ministry of Defence (MoD).
  2. Throughout the lifetime of the Proposed Development, marine aids to navigation will be provided in accordance with the requirements of the NLB, MCA and adherence to Civil Aviation Publication (CAP) 393 Article 223 (Civil Aviation Authority (CAA), 2016), unless otherwise agreed. All navigational aids associated with the Proposed Development will be suitably monitored and maintained to ensure the relevant CAA availability targets are met.

3.5. Operation and Maintenance Phase

3.5.1.    Methodology

  1. The overall operation and maintenance strategy will be finalised once the operation and maintenance base location and technical specification of the Proposed Development are known, including wind turbine type, electrical export option and final project layout.
  2. This section, therefore, provides a description of the reasonably foreseeable planned and unplanned maintenance activities at the Proposed Development.
  3. Table 3.30   Open ▸ provides a list of all operation and maintenance activities planned for the Proposed Development.
  4. The offshore operation and maintenance will be both preventative and corrective. The operation and maintenance strategy will include an onshore (harbour based) operation and maintenance base, supported by a SOV and/or Crew Transfer Vessel (CTV) logistics strategy. This will be developed at a later stage once further detail is confirmed for the Proposed Development
Table 3.30:
Design Envelope: Operation and Maintenance Activities

Table 3.30: Design Envelope: Operation and Maintenance Activities

3.5.2.    Operation and Maintenance Vessels

  1. The maximum design scenario for operation and maintenance vessel requirements for the Proposed Development are presented in Table 3.31   Open ▸ .

 

Table 3.31:
Design Envelope: Vessels Required During the Operation and Maintenance Activities

Table 3.31: Design Envelope: Vessels Required During the Operation and Maintenance Activities

 

3.6. Health and Safety

  1. All elements of the Proposed Development will be risk assessed according to the relevant government guidance as well as the Applicant’s internal best practice. These risk assessments will then form the basis of the methods and safety mitigations put in place across the life of the Proposed Development.
  2. The Applicant has a focus on employee safety and its QHSE policy ensures that the Applicant’s wind farms are safe by design and that the processes and procedures are adhered to. There is a clearly defined safety culture in place in order to avoid incidents and accidents.
  3. There will be constant controls to ensure that the safety measures are observed and followed and the Applicant has built a safe workplace for its employees and contractors.
  4. The focus on QHSE is intended to ensure that everyone feels safe, in a highly controlled and safety-driven environment. This is the Applicant’s first priority for the Proposed Development. It is done by closely monitoring all matters relating to health and safety on all wind farms operated by the Applicant.

3.7. Waste Management

  1. Waste will be generated as a result of the Proposed Development, with most of the waste expected to be generated during the construction and decommissioning phases.
  2. Procedures for handling waste materials will be described in a Site Waste Management Plan (SWMP). The SWMP will describe and quantifies the waste types arising from the Proposed Development activities and how these will be managed (dispose, reuse, recycle or recover). The SWMP will also provide information on the management arrangements for the identified waste types and management facilities in the vicinity of the Proposed Development.
  3. The SWMP will be provided prior to construction when further detailed design information becomes available.

3.8. Decommissioning Phase

  1. Under Section 105 of the Energy Act 2004 (as amended), developers of offshore renewable energy projects are required to prepare a decommissioning programme for approval by Scottish Ministers. A Section 105 notice is issued to developers by the regulator after consent or marine licence has been issued for the given development. Developers are then required to submit a detailed plan for the decommissioning works, including anticipated costs and financial securities. The plan will consider industry practice, guidance and legislation relating to decommissioning at that time. The plan will be consulted on with relevant stakeholders and will be made publicly available. MS-LOT will further consult on the plan, the costs and financial securities prior to seeking ministerial approval. The decommissioning plan and programme will be updated during the Proposed Development’s lifespan to take account of changing practice and new technologies.
  2. At the end of the operational lifetime of the Proposed Development, it is anticipated that all structures above the seabed or ground level will be completely removed were this be feasible and practicable. This will be kept under review depending on current legislation and guidance requirements, best practice and other options may be required including cutting structures below the seabed. A similar approach will be taken for cables and associated infrastructure with the aim for removal subject to existing guidance, best practice and consideration of environmental conditions and sensitivities. However, there is also potential for repowering, as explained in section 3.9.
  3. The decommissioning sequence will generally be the reverse of the construction sequence and involve similar types and numbers of vessels and equipment. The CES AfLs for the Proposed Development require that the Project is decommissioned at the end of its lifetime.

3.8.1.    Offshore Decommisioning

Wind turbines

  1. Wind turbines will be removed by reversing the methods used to install them.

Foundations

  1. Piled foundations are likely to be cut at an agreed depth below the seabed using pile cutting devices, depending on seabed mobility, and removed. Suction caisson foundations will be fully removed.
  2. As the decommissioning programme will be updated during the Project lifespan, it may be decided, closer to the time of decommissioning, that removal will result in greater environmental impacts than leaving components in situ.

Scour protection

  1. Draft decommissioning guidance (Scottish Government, 2019) assumes a default requirement for full removal of installations, including scour protection and offshore cables. It also states, “Exceptions will be considered on a case by case basis and the case must be put forward as part of the decommissioning programme, taking on board environmental conditions, the balance of risk, cost and technological capabilities at that time”.
  2. It is proposed that scour protection will be removed where possible and appropriate to do so, noting this will depend on the type of scour protection used and condition of said protection at the time of removal. As explained in paragraph 148, this approach will be reviewed at the time of decommissioning following the most up to date and best available guidance. For the purpose of this Offshore EIA Report, the most adverse scenario has been assessed for each topic.

Offshore export cables

  1. It is proposed that offshore export cables will be removed where possible and appropriate to do so. This approach will be reviewed at the time of decommissioning following the most up to date and best available guidance. For the purpose of this Offshore EIA Report, the most adverse scenario has been assessed for each topic.

3.9. Repowering

  1. Removal of all structures on the seabed as part of offshore decommissioning is standard procedure for a sector such as oil and gas where a non-renewable resource is being exploited. However, for offshore renewables, consideration may be given to repowering as an alternative – particularly as it is unlikely that the need for the power generated will disappear at the time of decommissioning.
  2. Although CES leases for the Proposed Development will be for 50 years, the operational life of the Proposed Development is likely to be 35 years. During this time, there will be a requirement for upkeep and maintenance of the Project. Such maintenance is discussed in section 3.5.
  3. If there are changes in technology, it may be desirable to ‘repower’ the Proposed Development at or near the end of its design life (i.e. reconstruct and replace wind turbines and/or foundations with those of a different specification or design). If the specifications and designs of the new wind turbines and/or foundations fell outside of the maximum design scenario or if the impacts of constructing, operation and maintenance and decommissioning the wind turbines and/or foundations were to fall outside those considered by this Offshore EIA Report, repowering would require further consent (and potentially an EIA) and is therefore outside of the scope of this document. At this time, it is not expected that repowering would require any removal of existing or installation of new offshore cables.

3.10. Designed in Measures

  1. The PDE includes a number of designed in measures which have been included in the Proposed Development and are committed to be delivered by the Applicant as part of the Proposed Development.
  2. Table 3.32   Open ▸ describes the designed in measures included for the Proposed Development. These measures are integrated into the description of the Proposed Development and have therefore been considered in the assessments presented in volume 2, chapters 7 to 21.
Table 3.32:
Designed In Measures for the Proposed Development

Table 3.32: Designed In Measures for the Proposed Development

3.11. Residues, Emissions and Waste

  1. The EIA Regulations require a description of the anticipated residues and emissions and wastes arising from the Proposed Development and a description of the likely significant effects resulting from the emission of pollutants, noise, vibration, light, heat and radiation, the creation of nuisances, and the disposal and recovery of waste. Table 3.33   Open ▸ outlines these requirements and where these are addressed in the Offshore EIA Report.

 

Table 3.33:
Residues and Emissions

Table 3.33: Residues and Emissions

 

3.12. Natural Resources

  1. Similarly, the EIA Regulations require a description of the anticipated likely significant effects resulting from the use of natural resources. Table 3.34   Open ▸ outlines these requirements and where these are addressed in the Offshore EIA Report.

 

Table 3.34:
Natural Resources

Table 3.34: Natural Resources

 

3.13. Risk of Major Accidents and Natural Disasters

  1. The risk of major accidents and natural disasters which could arise from the Proposed Development activities has been assessed within volume 2, chapter 21 of this Offshore EIA Report.

3.14. References

Civil Aviation Authority (2016). CAP 393 – Air Navigation: The Order and the Regulations. Available at: CAP393REFERENCE_ONLY.pdf (caa.co.uk). Accessed on: 13 September 2021.

Civil Aviation Authority (2016). CAP 764 - CAA Policy and Guidelines on Wind Turbines (Version 6, February 2016). Available at: https://publicapps.caa.co.uk/docs/33/CAP764%20Issue6%20FINAL%20Feb.pdf. Accessed on: 12 November 2021.

The Crown Estate (2014). Protocol for Archaeological Discoveries: Offshore Renewables Projects. Published by Wessex Archaeology, Salisbury, on behalf of The Crown Estate.

EPA (2017). Guidelines on the information to be contained in Environmental Impact Assessment Reports, Draft August 2017. Available at: EPA_EIAR_Guidelines.pdf. Accessed on: 27 August 2021.

JNCC (2017). JNCC guidelines for minimising the risk of injury to marine mammals from geophysical surveys.

Scottish Government (2019). Decommissioning of Offshore Renewable Energy Installations in Scottish Waters or in the Scottish Part of the Renewable Energy Zone under the Energy Act 2004. Guidance note for industry (in Scotland). Draft for Consultation November 2019. Available at: Decommissioning of Offshore Renewable Energy Installations in Scottish Waters or in the Scottish Part of the Renewable Energy Zone under the Energy Act 2004: Guidance notes for industry (in Scotland) (www.gov.scot). Accessed on: 27 October 2021.

Scottish Government (2013). Planning Advice Note 1/2013: Environmental Impact Assessment. Available at: Planning Advice Note 1/2013: Environmental Impact Assessment - gov.scot (www.gov.scot). Accessed on: 12 September 2021.

Scottish Government (2022). Guidance for applicants on using the design envelope for applications under section 36 of the Electricity Act 1989. Available at: Electricity Act 1989 - section 36 applications: guidance for applicants on using the design envelope - gov.scot (www.gov.scot). Accessed on: 07 June 2022.

SSER (2021a). Berwick Bank Wind Farm Offshore Scoping Report. Available at: https://berwickbank-eia.com/offshore-scoping/

SSER (2022a). Berwick Bank Wind Farm Onshore EIA Report.

SSER (2022e). Cambois connection Scoping Report.

 

 

[1] Consent is not sought in this Application for SPEN Grid Substation and overhead connections.

[2] The maximum design envelope defines the maximum range of design parameters. For the EIA, the Applicant has discerned the maximum impacts that could occur within the range of the design parameters for given receptor groups - referred to as the “maximum design scenario”

 

[3] based upon 179 x 4 legged jacket foundations required for the largest proposed wind turbines 

[4] based upon 179 x 4 legged jacket foundations required for the largest proposed wind turbines 

[5] Maximum anchor footprint for the wind farm is calculated using the anchor footprint times the number of anchor drops likely to be required across the while wind farm.

[6] Note: up to two pins may be required for the larger wind turbine specifications (e.g. 24 MW). In the event these wind turbines are selected, fewer would be required. Accordingly, this calculation accounts for up to 179 larger specification wind turbines (requiring a maximum of two pins per leg).