4. Site Selection and Consideration of Alternatives

4.1. Introduction and Overview

1. This chapter of the Offshore Environmental Impact Assessment (EIA) Report provides a description of the site selection process and the alternatives considered, from award of the Firth of Forth Zone (awarded as part of The Crown Estate’s (TCE’s) 3rd Offshore Wind Leasing Round) through to final design and definition of the offshore components of the Berwick Bank Wind Farm hereafter referred to as the ‘Project’ (with the offshore components seaward of Mean High Water Springs (MHWS) hereafter referred to as the ‘Proposed Development’).
2. This chapter has been prepared in accordance with Schedule 4(2) of the EIA Regulations (as amended) (see volume 1, chapter 2), requiring information to be provided in the Offshore EIA Report on “the reasonable alternatives (for example in terms of project design, technology, location, size and scale) studied by the developer, which are relevant to the proposed development and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects”.
3. As outlined above there is a requirement under the EIA Regulations for all projects, as part of the consent application process, to provide information on the options considered and process used to inform selection of the application version of the proposed development.
4. The Firth of Forth Zone was awarded to SSER and Fluor in 2010 as part of TCE 3rd Offshore Wind Leasing Round (Round 3). Following zone award, SSER commenced a number of studies as part of the Zonal Appraisal and Planning (ZAP) process to identify areas within the zone to be taken forward for development. Development of the areas would be completed in three phases:

• phase 1: northern area;
• phase 2: south-eastern area; and
• phase 3: south-western area.
  5. Phase 1, the northern area was subsequently taken forward for development as Seagreen Alpha Offshore Wind Farm (Project Alpha) and Project Bravo Offshore Wind Farm (Project Bravo) projects. Although consented by the Scottish Ministers in 2014, the consents were subject to legal challenge, which upheld the grant of the consents in November 2017. In 2018 these projects were combined into one project (Seagreen 1). In 2019, amendments were made to the Seagreen 1 project boundary creating the projects now referred to as Seagreen 1 and Seagreen 1A Project.
  6. Having received consent for Project Alpha and Project Bravo in October 2014, a decision was taken by SSER to undertaken further studies (technical and environmental) as part of an internal Project Identification and Approval (PIA) process to determine the potential for developing the remaining two areas within the Firth of Forth Zone. At the time (2014) these areas were referred to as Seagreen Charlie (south-eastern Area) and Seagreen Delta (south-western Area). In 2018, following the creation of Seagreen 1, these remaining areas were renamed Seagreen 2 and Seagreen 3 respectively. The PIA process concluded that both remaining areas should be taken forward for development. The areas were renamed again, with accompanying boundary modification in 2020 from Seagreen 2 and 3 to Berwick Bank and Marr Bank respectively. An Offshore EIA Scoping Report was submitted for Berwick Bank in 2020 (SSER, 2020a).
  7. In response to advice received from stakeholders to the 2020 Berwick Bank Wind Farm Offshore Scoping Report (SSER, 2020a), the Applicant started to explore options to combine Marr Bank and Berwick Bank into one single project (the ‘Berwick Bank Wind Farm’).

4.1.2.   Creating the BerwIck Bank Wind Farm Project

8. The decision to explore an option for combining the two projects was also influenced by the Scottish Government’s declaration of a global climate emergency and setting targets for achieving net zero by 2045 (Scottish Government, 2019a).
9. It was determined, through ongoing stakeholder engagement following receipt of the 2020 Berwick Bank Scoping Opinion (MSLOT, 2021) and analysis of environmental data, that developing the remaining area within the Firth of Forth Zone as one single project would enable the Applicant to make a significant contribution towards accelerating decarbonisation and meeting Scotland’s targets for net zero by enabling delivery of up to 4.1 GW by the early 2030s.
10. Delivery of up to 4.1 GW will enable the Project to make a meaningful and timely contribution to decarbonisation and security of energy supply in both Scotland and the United Kingdom (UK), while significantly contributing to lower bills for consumers throughout its operational life, thereby addressing all important aspects of existing and emerging Scottish Government and UK Government policy.
11. The urgent need for the Project is encompassed by six clear policy objectives:

• Decarbonisation: The Project is capable of delivering significant quantities of low-carbon electricity from as early as the late 2020s. Making a significant contribution to both the Scottish target of achieving Net Zero by 2045 and the UK target for achieving Net Zero by 2050. This is in line with the UK’s Committee on Climate Change (CCC)’s recent identification of the need for urgent action to increase the pace of decarbonisation in the Great Britain (GB) electricity sector.
• Wind generated electricity: Greater energy generation from offshore wind is critical for both the reduction of electricity related emissions, as well as providing a timely contribution to a substantial increase in electricity demand due to electrification of transport, heat and industrial demand. The Project would make a significant contribution to delivering Scotland’s ambitions for 11 GW of offshore wind capacity to be in operation in Scottish waters by 2030 (Scottish Government, 2020b) and UK targets of 50 GW of offshore wind by 2030 as set in the British Energy Security Strategy (HM Government 2022). This increase of 10 GW on the 40 GW by 2030 target established by the Ten Point Plan (HM Government, 2020a) and committed to in the UK Offshore Wind Sector Deal (BEIS 2019) reflects finds from National Grid Electricity Systems Operator (NGESO) Future Energy Scenarios (FES) which details that to achieve Net Zero targets, offshore wind capacities will be required at 40 – 51 GW in 2030, at 84 – 91 GW in 2040, and at 89 – 110 GW by 2050 (National Grid, 2021a). In every scenario, a pathway to Net Zero includes a significant increase of offshore wind capacity beyond that predicated in the Sector Deal. The increased target also builds on the UK Climate Change Committee (CCC)’s 2019 Report (CCC, 2019), where they advise that consistently strong deployment of low-carbon generation in the lead up to 2050 will be required to meet Net Zero, including “…at least 75GW of offshore wind.”
• Resilience of electricity system: The Project will make a significant contribution to the UK’s energy security from the late 2020s. By being connected at the transmission system level, Berwick Bank will play an important role in the resilience of the GB electricity system from an adequacy and system operation perspective. As part of a diverse generation mix, the Project will also contribute to the improved stability of capacity utilisations among renewable generators.
• At scale: The Project, with a maximum generating capacity of 4.1 GW is a substantial infrastructure asset capable of delivering significant quantities of low carbon electricity in a short period of time (by early 2030s). The Project is expected to provide enough green electricity to power more than 5 million UK homes. By maximising the capacity of generation in the wind-rich, accessible and technically deliverable proposed location, is to the benefit of all GB consumers, and the Scottish offshore wind industry generally.
• Competitive: The highly competitive Contract for Difference (CfD) allocation in 2022 specifically accelerated the deployment of offshore wind, with costs falling by two thirds in the last five years. The Project, one of the last remaining fixed bottom offshore wind sites in Scotland and the UK, would therefore provide competitive and non-volatile (to fuel price fluctuations) renewable electricity compared to conventional low-carbon generation, both in GB and more widely.
  12. The single Berwick Bank Wind Farm project also provided the Applicant with an opportunity to mitigate and manage potential environmental risks through increased flexibility and coordination across the Project. This included a 9% reduction on the total array area of the Project which was achieved by refining the boundary that resulted when the Berwick Bank and Marr Bank projects were combined.
  13. The Applicant also completed a number of engineering and technical studies to identify measures that could be incorporated into the design of the Project to further reduce potential environmental effects of the single Berwick Bank Wind Farm Project. These designed in measures include increasing the minimum blade tip clearance from 22 m Lowest Astronomical Tide (LAT) to 37 m LAT, increasing minimum and maximum wind turbine parameters included in the Project Design Envelope (PDE) such that fewer wind turbines would be required to deliver 4.1 GW capacity, and refining foundation options by removing floating wind turbines and monopile foundation structures.

4.1.3.   Boundary Change

14. Following submission of a Scoping Report for the single project (Berwick Bank Wind Farm) in October 2021 (SSER, 2021a), the Applicant continued to explore options to further reduce potential effects on key receptors. In May 2022, the Applicant took the decision to reduce the boundary of the Berwick Bank Wind Farm to avoid areas identified as potentially relevant to ornithological receptors and to reduce the extent to which the site overlaps with the Firth of Forth Banks Complex Nature Conservation Marine Protected Area (ncMPA). The boundary change also reduces potential effects on other receptors such as shipping and navigation and commercial fisheries and increases the buffer between other projects in the area (Seagreen 1, Seagreen 1A Project, Inch Cape and Neart Na Gaoithe (NnG) Offshore Wind Farms).
15. The boundary change resulted in a further 23% reduction in the total area of the Berwick Bank Wind Farm site. The maximum capacity of the site, however, remained unchanged.
16. Further detail on the approach taken to combining the Marr Bank and Berwick Bank Projects in 2021 and the subsequent 2022 boundary change is provided in section 4.9.

4.1.4.   Grid Connections

17. The Applicant has three signed grid connection agreements with the network operator (National Grid Electricity System Operator (NGESO)). Two agreements are for connection at a point close to the existing Branxton cable sealing end compound in East Lothian, around 8 km south west of Dunbar on the East Lothian coast (hereafter referred to as the Branxton connection), with a third additional connection at Blyth, Northumberland (hereafter referred to as the Cambois connection).
18. The Branxton grid connections were first secured in 2011. Subsequently, the identification and selection of the onshore components of the Project (substation location, onshore cable routes and landfall) and the Proposed Development export cable corridor linked to the Branxton connection location have formed an integral component of the overall Project definition and refinement of the final Proposed Development boundary. The approach taken to the identification, assessment and selection of the preferred landfall and offshore export cable corridor is discussed in sections 4.10 to 4.12.
19. The third additional connection agreement (Cambois connection) was confirmed in June 2022 following NGESO’s Holistic Network Review (results published July 2022). The Cambois connection provides an earlier connection date than a third connection location in the Branxton area, therefore enabling the Project to reach full generating capacity (4.1 GW) by early 2030’s. As outlined in section 4.1.2, this earlier connection is critical to enabling the Project to make a significant and timely contribution towards Scottish and UK Government targets for decarbonisation, security of supply and reducing the costs of electricity.
20. The export cables and landfall infrastructure for the Cambois connection are being consented separately and have been considered cumulatively with the Proposed Development as part of this application.
21. The evolution of the Berwick Bank Wind Farm from award of the Firth of Forth Zone to the definition of the final Project (basis of this application) is illustrated in Figure 4.1   Open ▸ below. Further detail on this process is provided in sections 4.5 to 4.9.

Figure 4.1: Approach to Site Selection and Project Definition

4.2. Project Objectives

22. The approach taken to initial site selection and subsequent refinement of the Proposed Development boundary has been underpinned by overarching objectives for the Project. These objectives are presented in Table 4.1   Open ▸ .

Table 4.1: Project Objectives

4.3. Assessing the ‘Do Nothing’ Scenario

23. A ‘do nothing’ scenario is a projection of the existing baseline to show what changes, if any, would take place if the project did not go ahead. The following section considers the ‘do nothing’ scenario in the context of the Project objectives set out above in particular in relation to tackling climate change, ensuring UK security of supply and the current cost-of-living crisis linked to the increasing cost of electricity.
24. In accordance with the EIA Regulations, an assessment of the future baseline under the ‘do nothing’ scenario has been completed for all technical topics (see volume 2, chapters 7 to 21).
25. For the Proposed Development, one of the key risks with the ‘do nothing’ scenario is being unable to contribute to addressing the climate change emergency and the need for rapid decarbonisation. Climate change is the defining challenge of our time. Human-induced global warming has reached approximately 1 ºC above pre-industrial levels and without a significant and rapid decline in carbon emissions across all sectors, global warming is not likely to be contained (IPCC, 2021).
26. The 6th and most recent Intergovernmental Panel on Climate Change (IPCC) Synthesis Report published in 2022 presents a narrowing window to mitigate and the reduce the probability of the most catastrophic events that could result from anthropogenic climate change and are forecast to have far-reaching negative effects on human populations globally. It also states that every ton of carbon dioxide (CO₂) emitted increases global warming and that the more rapidly decarbonisation is achieved noticeable reductions in the rate of climate change will likely be observed.
27. Any delay in reducing carbon emissions today results in greater carbon emissions to the atmosphere, higher global temperature rises and an increased level of and speed of action required to halt impacts. A rise in global temperatures above 1.5°C has potential to cause irreversible climate change, the potential for widespread loss of life and severe damage to livelihoods. Yet greenhouse gases projected at a global scale (using Nationally Determined Contributions (NDCs)) are now set to exceed 1.5°C by 2030 and look increasingly likely to exceed 2°C after 2030 (IPCC 2021). Therefore, any delays incurred now, make the challenge significantly more difficult for the years ahead.
28. As such, Scotland, and the wider UK, have declared, in common with many other countries, that we face a global “climate change emergency”. By definition, an emergency is a grave situation that demands an urgent response and legal obligations have been committed to as follows:

• International: the United Nations Framework Convention on Climate Change led Paris Agreement (2015);
• UK: the Climate Change Act 2008 (as amended) and Glasgow Climate Pact (2021) (including Scotland and UK); and
• Scotland: Climate Change (Scotland) Act 2009 and the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019.
  29. These legal instruments provide the commitments to become carbon neutral (i.e. to reach “Net Zero” by the middle of the 21st century internationally, by 2045 in Scotland and 2050 in the UK) with interim targets. However, review by the Committee on Climate Change (CCC) has reported that the UK is not currently on track to meet the fourth (2023-2027) or fifth (2028-2032) carbon budgets and requires more challenging measures (CCC 2020; CCC undated).
  30. The CCC has also warned that many of our plants and animals will undergo severe and catastrophic decline by the end of the century if temperatures continue to rise (CCC undated).
  31. Scottish and UK waters are facing an increase in sea surface temperature. The rate of increases is varied geographically, but between 1985 and 2009, the average rate of increase in Scottish waters has been greater than 0.2 °C per decade, with the south-east of Scotland having a higher rate of 0.5°C per decade (Marine Scotland, 2011). A study completed over a longer period of time showed Scottish waters (coastal and oceanic) have warmed by between 0.05 °C and 0.07 °C per decade, calculated across the period 1870 – 2016 (Hughes et al., 2018).
  32. Climate change is considered to be one of the primary causes of the declines in seabird populations in the UK and for the growing number of red-listed species (Daunt and Mitchell, 2013; Daunt et al., 2017; Eaton et al., 2015; McDonald et al., 2015; OSPAR, 2017a, b; Mitchell et al., 2018a, b). Previous seabird reviews (e.g. Daunt and Mitchell, 2013; Daunt et al., 2017) have described how climate may affect seabird populations via two main processes: indirect effects via changes in food supply, and direct effects such as mortality from extreme weather.
  33. The Royal Society for the Protection of Birds (RSPB) has also widely reported evidence that wildlife in the UK, including seabirds, are already facing a more challenging time due to the climate change that has occurred to date; and that the situation will, for the most part, likely get worse (RSPB, 2017). A key finding is that climate change has been linked with an 87% decline in breeding kittiwakes on Orkney and Shetland, and by 96% at St Kilda since 2000 (RSPB, 2017).
  34. Ocean acidification, which is linked to climate change, is the result of oceans absorbing atmospheric CO2 that is released into the water cycle. This causes chemical changes and altering pH levels, making water more acidic (NOAA.gov, 2020). Research has shown that ocean acidification is already resulting in impacts on marine life and that again, this will continue to get worse (Government Office for Science, 2017). In conjunction with other environmental stresses due to climate change, ocean acidification puts at risk many valuable marine species, habitats and ecosystems. As well as this, crucial ecosystem services such as fisheries, shoreline protection and aquaculture will be at severe risk (Doney et al., 2020).
  35. Research has shown that in the future, the shift in temperature will continue to push fish populations poleward to colder areas, reducing numbers in the UK (Pinnegar et al., 2017). As a result, climate change is threatening the continued success of commercial fisheries which provide food and employment within both the UK and Scottish context (Townhill et al., 2019).
  36. The reduction in fish populations has adverse consequences for ornithological and marine mammal receptors as well. Populations of sandeel species (including lesser sandeel Ammodytes tobianus and Raitt’s sandeel Ammodytes marinus) are one of many fish species that will be impacted due to a rise in sea temperature. The abundance of sandeels is sensitive to the rising sea temperatures (Van Deurs et al., 2011). These fish are essential prey items for a number of seabirds and marine mammals (MacDonald et al., 2018) in the North Sea as well as larger fish species (such as cod Gadus morhua and sea trout Salmo trutta). Current temperatures could result in a 10% decrease in large and small copepods which are a key prey species of sandeels, which is likely to reduce sandeel abundance due to lack of prey availability leading to starvation mortality (MacDonald et al., 2018).
  37. Rapid decarbonisation is critical to tackling the climate emergency and the cost-of-living crisis by reducing Scotland and the UK’s reliance on natural gas. The Project is within one of the few remaining areas in Scottish waters where fixed bottom offshore wind can be delivered at scale and crucially, connect to the grid network in timescales that are essential for not just achieving but accelerating Scotland’s and the UK’s path to net zero and realising Scotland’s ambitions for 11 GW offshore wind connected to the grid by 2030 as set out in the Scottish Government’s Sectoral Marine Plan (SMP) for Offshore Wind (Scottish Government, 2020b).
  38. The urgent need that the Proposed Development addresses is encompassed by clear requirements which would not be met in a ‘do nothing’ scenario as summarised in Table 4.2   Open ▸ .

Table 4.2: Consideration of the Do Nothing Scenario in the Context of the Project Objectives

4.4. Approach to Site Selection and Project Definition and Refinement

39. The approach taken to site selection and project definition and refinement is illustrated in Figure 4.1   Open ▸ . This involved a number of stages as summarised below.

• stage 1 – Firth of Forth Zone Identification and Award;
• stage 2 – ZAP;
• stage 3 – PIA Process; and
• stage 4 – Development of the Proposed Development.
  40. These stages are discussed in sections 4.5 to 4.9 respectively.
  41. The identification and selection of the preferred landfall location and Proposed Development export cable corridor formed an integral component of the overall Project definition and refinement of the final Proposed Development boundary. The approach taken to the identification, assessment and down selection of the preferred landfall and offshore export cable corridor is discussed in sections 4.10 to 4.11.

4.5. Stage 1: Firth of Forth Zone Identification and Award (2008 - 2010)

42. In 2010 TCE awarded seabed rights to over 32 GW capacity across nine Round 3 offshore wind zones in UK waters beyond 12 nm ( Figure 4.2   Open ▸ ). This included the Firth of Forth Zone, which is one of only two zones in Scottish waters. The other Round 3 zone is the Moray Firth.
43. The zones were identified, and refined, by TCE through a systematic process of analysis and assessment of spatial data included in their Marine Resource Geographical Information Systems (GIS) System (MaRS) (TCE, 2012).
44. In total, during 2008/2009, TCE completed three iterations of its three-stage approach to the delineation of the Round 3 Zones outlined below.

• Stage 1: Identification and removal of areas identified as being unsuitable for offshore wind due to:

–           The presence of one or more exclusions to development (e.g. activity, development or area of seabed which had either been granted future permission or is leased or licensed for another purpose or activity); or

–           Due to technical conditions or external interests such as excessive water depths or an International Maritime Organisation (IMO) shipping lane. These datasets are detailed in Table 4.3   Open ▸ and were mapped as areas or locations to be avoided.

• Stage 2: Evaluation of remaining areas of seabed to determine suitability based on restrictions present. Restrictions were defined as an activity, development or interest which should be considered when planning the proposed activity or development but may not preclude development. Features represented by these layers were weighted and scored to provide a representation of the potential interests and possible constraints.
• Stage 3: Outputs from the national scale mapping and modelling then reviewed against other detailed review datasets to check for consistency: Review datasets included information and data which were unsuitable for national analysis and spatial mapping but which could, however, be used to inform decisions about the zones. These layers were considered outside of the actual modelling process.
  45. During each iteration, the outputs from the modelling were discussed with key stakeholders. Taking into account feedback from engagement with stakeholders and refinements applied to the mapped data, spatial analysis and review of other datasets, the number of zones identified were reduced from 11 to nine across the three iterations.
  46. The MaRS GIS datasets used to inform the identification of the Round 3 zones are summarised in Table 4.3   Open ▸ .

Table 4.3: MaRS Datasets Used to Inform Identification of Round 3 Zones (TCE, 2012)

47. The approach taken by the TCE was to identify zones for offshore wind projects within the broader geographical areas identified by the Offshore Energy Strategic Environment Assessment (OESEA) (DECC, 2009b) as having potential opportunity for offshore wind. The OESEA was completed in two parts: OESEA 1 and OESEA 2 (in 2009 and 2011, respectively). OESEA 1 focussed on creating additional offshore wind and oil and gas capacity (TCE, 2012). OESEA 2 (DECC, 2011) reiterated the offshore wind development recommendations within the OESEA 1, expanding on requirements towards developers to provide project level evidence-based approaches to development with a focus on identifying potential impacts on marine mammals and fish. OESEA 2 concluded that prospective developable areas were not restricted but that offshore wind projects should be designed to reduce impacts on other users of the sea, on protected and conservation areas and on environmentally sensitive coastal locations.

Figure 4.2: TCE Round 3 Offshore Wind Farm Zones

4.6. Stage 2 – Zone Appraisal Process (2010 to 2012)

48. The ZAP process was used to identify sites for individual projects within the Firth of Forth Zone. This was a discretionary, non-statutory process recommended by TCE (TCE, 2012), the aim of which was to:

• optimise the development opportunity by identifying the most technical and environmentally suitable development sites within the Firth of Forth Zone;
• promote stakeholder engagement at a strategic level to inform the long-term development strategy; and
• consider cumulative impacts across the former Firth of Forth Zone, particularly in relation to other offshore wind farm developments.
  49. The ZAP process involved more detailed mapping and analysis of a range of environmental and technical constraints within, and surrounding, the Firth of Forth Zone.
  50. Data considered in the ZAP process included:
• water depths (UK Hydrographic Office (UKHO) bathymetry dataset) and seabed conditions;
• wind speed and metocean conditions (Met office 10-year wind dataset);
• nature conservation designations SPAs, SACs, SSSIs and Important Bird Areas (IBAs);
• ornithological data (data from 24 months of boat based surveys (2009 to 2011) covering the entire Firth of Forth Zone, sightings data from TCE aerial surveys (2009/2010), SPA bird tracking studies (2010);
• benthic and intertidal ecology data;
• fisheries spawning and nursery grounds (Centre for Environment, Fisheries and Aquaculture Science (CEFAS) mapped data);
• marine mammals including cetaceans and seals (18 months boat-based survey sightings 2009 to 2011 for the entire Firth of Forth Zone and sightings data from TCE aerial surveys (2009/2010));
• fisheries activity (Marine Scotland data);
• shipping and navigation — Automated Identification System (AIS) data and radar surveys (summer and winter 2010 to 2011 completed by the Forth and Tay Offshore Wind Developers Group (FTOWDG);
• seascape and landscape – landscape designations and protected areas;
• marine archaeology and cultural heritage;
• aviation and telecommunications issues, including civil and military aspects;
• oil and gas infrastructure;
• emergency services; and
• cables and pipelines.
  51. As discussed in section 4.1, the outcome from the ZAP process was the division of the Firth of Forth Zone into three areas which would be developed in phases. These areas are summarised in Table 4.4   Open ▸ and illustrated in Figure 4.3   Open ▸ .

Table 4.4: Evolution of Project Boundaries and Names within the Firth of Forth Zone from 2010 to 2020

Figure 4.3: Evolution of Project Boundaries and Names in the Firth of Forth Zone from 2010 to 2020

4.7. Environmental Information relevant to Further Development within the Firth of Forth Zone

4.7.1.   Marine Scotland - Licensing and Operations Team Appropriate Assessment of the Forth and Tay Projects 2014

52. In 2014, Marine Scotland – Licensing and Operations Team (MS-LOT) (on behalf of Scottish Ministers as the Competent Authority) undertook an Appropriate Assessment of the Forth and Tay offshore wind farm development applications (Neart na Gaoithe (NnG), Inch Cape and Seagreen Project Alpha and Project Bravo (now referred to as Seagreen 1 and Seagreen 1A Project) Offshore Wind Farms) to determine whether there was potential for these developments, alone or in combination, to have an adverse effect on the integrity of any European protected site (SACs and SPAs).
53. MS-LOT concluded that the Forth and Tay developments would not adversely affect the European sites considered, either alone or in combination with other plans or projects, provided that certain planning conditions outlined in the Appropriate Assessment are complied with. The European protected sites considered in the Appropriate Assessment are shown in Figure 4.5   Open ▸ and listed in Table 4.5   Open ▸ .

Table 4.5: European Protected Sites (Natura Sites) Included in the MS-LOT Appropriate Assessment

Figure 4.4 European Protected Sites (Natura Sites) Included in the MS-LOT Appropriate Assessment

4.7.2.   Identification and designation of new nature conservation sites

54. MS-LOT’s Appropriate Assessment considered European sites which were proposed or classified at the time of the assessment (2014). Following consent of the Forth and Tay developments, a suite of new potential/proposed SPAs (pSPAs) were identified by the Scottish Government, designed to protect marine foraging areas of designated seabird breeding colonies. In October 2016, following a period of review of the scientific basis of, and the conservation objectives for these sites by the Statutory Nature Conservation Bodies (SNCBs), the Scottish Government announced a public consultation on a suite of new marine SPAs, which includes the Outer Firth of Forth and St. Andrews Bay Complex SPA. The sites were classified as SPAs in December 2020 (JNCC, 2022). The Outer Firth of Forth and St. Andrews Bay Complex SPA includes part of the Wee Bankie within the Firth of Forth Zone and is classified for both wintering seabirds, and breeding seabirds foraging at sea.
55. Between 2015 and 2019, the UK and Scottish Governments, in accordance with the EU Habitats Directive, progressed with the identification and designation of SACs for harbour porpoise Phocoena phocoena in UK waters. A number of potential SACs for harbour porpoise were identified, including locations in the outer Moray Firth, the west coast of Scotland and the Southern North Sea. The Inner Hebrides and the Minches SAC was designated in 2016, followed by designation of the Southern North Sea (SNS) SAC in 2019 along with the Bristol Channel Approaches, North Channel, West Wales Marine and North Anglesey Marine SACs.
56. In additional to the designations of additional SPAs and SACs, the Marine (Scotland) Act 2010 and the Marine and Coastal Access Act 2009 include provisions for the designation of Nature Conservation Marine Protected Areas (ncMPAs) in Scottish waters. These ncMPAs contribute to the wider network of marine SACs, SPAs and Ramsar sites, collective referred to as Marine Protected Areas (MPAs).
57. Since 2013, the Scottish Government has added 42 MPAs to the network, including 31 ncMPAs. The ncMPAs include the Firth of Forth Banks Complex ncMPA which is partially located within the Firth of Forth Zone. The site was designated in 2014 and includes the Berwick, Scalp and Montrose Banks and the Wee Bankie shelf banks and mounds.

4.8. Stage 3 – Project Identification and Approval Process (2017 to 2020)

58. In 2017, SSER commenced its PIA Process, the aim of which was to build upon information gathered during the ZAP to identify potential future sites for development within the remaining Firth of Forth Zone (areas identified initially as Phases 2 and 3). The PIA process involved the following:

• identification of areas largely beyond the foraging range of key seabird species;
• review and analysis of available boat based ornithology survey results;
• review and analysis of 2010 and 2011 metocean survey data acquired across the entire Firth of Forth Zone by Seagreen;
• review and analysis of 2012 nearshore measurements and wavebuoy data;
• consideration of other conservation interests (including new nature conservation designations - Firth of Forth and St. Andrews Bay Complex SPA, Firth of Forth Banks Complex NCMPA and SNS SAC) to determine extent and nature of potential interactions with these designations);
• analysis of water depths; and
• consideration of separation distance from Seagreen 1, Seagreen 1A Project and adjacent Scottish territorial waters projects.
  59. The outcome from the 2017 PIA process was the identification of two separate 1 GW projects within Phases 2 and 3 (Seagreen Charlie and Seagreen Delta respectively). The 1 GW capacity for each project was based on a project design that minimised environmental effects whist still enabling zero carbon energy production. Each project comprised up to 100 wind turbines, with a nominal generating capacity of 8 MW to 10 MW. At this time this was considered realistic in terms of technological development (offshore fixed wind).
  60. Having established that there is potential for further development of the Firth of Forth Zone and that this development would make a significant contribution to the renewable energy targets set by the Scottish and UK Governments, the PIA process was progressed further to better understand key environmental sensitivities in the two areas and explore options for further reducing any potential adverse effects.
  61. In 2018, SSER carried out analysis on the boat based ornithological survey data obtained for the Firth of Forth Zone, and ornithological data from the other Forth and Tay projects. From this analysis it emerged that there is potential for areas of ornithologically sensitivity to overlap the Phase 3 part of the Firth of Forth Zone (referred to as Seagreen Delta at the time, prior to becoming Seagreen 3 in 2018 and then Marr Bank in 2020).
  62. A review of the available biological ornithological ‘headroom’[1] for key seabird species at the designated breeding colonies identified in the 2014 Appropriate Assessment was then undertaken to determine the potential capacity for development in this part of the Firth of Forth Zone, taking into account these ornithological sensitivities. It was concluded that, on the basis of the published review of collision avoidance rates (BTO, 2014), sufficient ‘headroom’ was potentially available for further offshore wind farm development in the Forth and Tay region.
  63. Having identified the potential for ornithological headroom, the PIA was further progressed to take into account advances in wind turbine technology which had started to be identified as being effective in reducing potential impacts on key seabird species. These advances include the deployment of fewer, larger wind turbines (e.g. wind turbines with capacity of more than 10 MW) to deliver the same project capacity and the ability to increase the minimum sea level to blade tip clearance (air gap) from the standard 22 m towards 30 m or more.
  64. Whilst progressing the PIA, all three of the Forth and Tay projects applied to vary their Section 36 consents to use fewer, larger wind turbines capable of generating the same capacity as the consented designs, reducing potential impacts on ornithology. These variations are summarised below.

Table 4.6: Forth and Tay Offshore Wind Projects – Section 36 Consent Variations 2018/2019

65. MS-LOT undertook an Appropriate Assessment for each of the three developments in late 2018. For each project it was concluded in the Appropriate Assessment that there would be a reduction in the predicted collision impacts due to the use of fewer larger wind turbines. MS-LOT also acknowledge that the Appropriate Assessments are considered to be highly precautionary. This is on the basis that the 2018 worst case scenario (WCS) for the Appropriate Assessment was based on the 2018 Seagreen design in-combination with the 2014 consented designs for Inch Cape and NnG Offshore Wind Farms, neither of which (based on the varied consents for these projects) will be constructed. It is therefore deduced that if all 2018 designs had been considered in the in-combination assessment, effects would be substantially reduced.
66. Furthermore, the seabird collision avoidance study undertaken at Thanet offshore wind farm lends support to the view that the avoidance rates used in the 2018 applications are also likely to be highly precautionary (Skov et al, 2018). The research at Thanet also provided valuable information on bird flight speeds. Skov et al. (2018) offers species-specific empirical data on flight speeds from a large number of individual birds. The EIA Report for the Optimised Seagreen Project (Seagreen, 2018) estimated that using the flight speeds recorded at Thanet would reduce gannet collisions by 6%.
67. As such, considerable headroom in the region has already been released through the revised Forth and Tay consents, with further potential headroom available from current and ongoing empirical research designed to reduce uncertainty in ornithology assessments, and from as-built versus consented designs outside of the Forth and Tay region (OWEC, 2021).

4.8.2.   Identification of Marr Bank and Berwick Bank Projects (2020)

68. Having confirmed that there is ornithological headroom available within the Firth of Forth Zone, SSER took the decision to progress development of the Phase 2 and 3 areas. Following a number of internal boundary reviews and project iterations it was determined that the two projects identified within these Phase 2 and 3 areas (Seagreen 2 and 3) would be renamed Berwick Bank and Marr Bank respectively.
69. In August 2020, an Offshore EIA Scoping Report (SSER, 2020a) was submitted to MS-LOT for an offshore wind farm project within the Phase 2 area (2020 Berwick Bank). Although the Phase 3 area (Marr Bank) was also being progressed it was at an earlier stage of development.

4.9. Stage 4 – Developing the Berwick Bank Wind Farm (2021 to 2022)

70. The stages in the development of the Project and refinement of the Proposed Development from submission of the 2020 Berwick Bank Wind Farm Offshore EIA Scoping Report in August 2020 to finalisation of the Proposed Development boundary included in this application (May 2022) are summarised in Table 4.7   Open ▸ . Note this does not include information on the grid connections, which are discussed in sections 4.10 to 4.12.

Table 4.7: Stages in the Development of the Proposed Development Boundary (not Including Grid Connections – See Sections 4.10 to 4.12 Below)

4.9.2.   Development of the Berwick Bank Wind Farm Project Boundary - 2021

71. In response to feedback received from stakeholders on the 2020 Berwick Bank Scoping Report (August 2020) (SSER, 2020a) advising that it would be preferable to combine the boundaries of the 2020 Berwick Bank and Marr Bank projects into one single project, the Applicant commenced a detailed site assessment and refinement study. This study (March 2021 to October 2021) focused specifically on the exploration of options for maximising capacity within the Berwick Bank Wind Farm boundary whist reducing potential effects on ornithology and other key receptors including the Firth of Forth Banks Complex NCMPA, shipping and navigation and commercial fisheries.
72. With regards to reducing effects on ornithology detailed analysis of a subset of the ornithological aerial survey data was undertaken to identify potential ‘hotspots’ for key species within the Berwick Bank Wind Farm boundary. Where possible, overlaps with these higher usage areas ‘hotspots’ were avoided or minimised. Consideration was also given to options to minimise potential barrier effects (including cumulatively with other Forth and Tay projects) for key species such as gannet.
73. Combining the 2020 Berwick Bank and Marr Bank boundaries to create the Berwick Bank Wind Farm boundary also provided the Applicant with an opportunity to:

• Reduce the overall footprint of the array area. The 2020 Berwick Bank array area was 775 km2 and the array area for Marr Bank was 666 km2 resulting in a combined the total area of 1,441 km2. Through refinements to avoid/reduce overlap with sensitive areas and features the resulting Berwick Bank Wind Farm array area was 1,314 km2 which is a reduction of 9%.
• Once combined, further boundary refinements were focused on the northern and north-eastern boundaries which overlap areas of higher ornithological activity including those which may be associated with feeding grounds.
• Refinements to northern and north-eastern boundaries also resulted in an increase in the buffer between the Berwick Bank Wind Farm and the other Forth and Tay projects in particular Inch Cape Offshore Wind Farm, Seagreen 1 and Seagreen 1A Project. This helped increase the area of open sea available for birds to pass through the area, therefore reducing potential barrier effects. The increase in buffer also helped reduced potential effects on shipping and navigation by increasing the area of sea available for vessels transiting between Berwick Bank and the adjacent wind farms.
  74. The 9% reduction in the resulting single Berwick Bank Wind Farm boundary also resulted in the avoidance of key nursery and spawning grounds for important prey species and commercial fisheries species including sandeel, mackerel Scomber scombrus, herring Clupea harengus and sprat Sprattus sprattus.
  75. Development of the Berwick Bank Wind Farm boundary was also informed by detailed engineering site suitability studies, including preliminary assessment of ground conditions for the installation of preferred foundation options (suction caissons and jackets). This was necessary to ensure suitability of ground conditions within the combined boundary including the associated consideration of the effects on the LCoE. The combined Project boundary was also sufficiently larger to allow for constraint sensitive design options to be built into the final Project Design.
  76. The site assessment and refinement study culminated in the submission of the Berwick Bank Wind Farm Offshore EIA Scoping Report (SSER, 2021a) to MS-LOT in October 2021.

4.9.3.   Berwick Bank Wind Farm Boundary Change (Proposed Development Boundary May 2022)

77. Following receipt of the Berwick Bank Wind Farm Scoping Opinion from MS-LOT on 04 February 2022 (MS-LOT, 2022), work progressed on the full EIA assessment, using assessment parameters as advised in the Scoping Opinion. During this work, an opportunity was identified which could potentially further reduce predicted impacts from the proposed development. In March 2022 a boundary review process was initiated by the Applicant to explore options for further reducing impacts, whilst meeting the Project’s overarching aims and objectives. This process concluded in late May 2022, resulting in a further 23% reduction of the array area (from 1,314 km2 to 1,010.2 km2). A comparison with the previous site boundary is shown in Figure 4.5   Open ▸ .
78. Furthermore, when compared to the size of the 2020 Berwick Bank boundary (775 km2) the final Proposed Development array area (post-boundary change) is only 34% larger, whereas the maximum generating capacity of the site has increased by 78.3% (4.1 GW compared to 2.3 GW in the 2020 Berwick Bank Offshore EIA Scoping Report (SSER, 2020a)).
79. Key environmental considerations influencing the boundary change are summarised in Table 4.8   Open ▸ .
80. Table 4.10   Open ▸ presents an evaluation of the environmental benefits linked to the boundary change and the associated PDE refinements.

Table 4.8: Environmental Considerations Influencing Key Boundary Changes

Figure 4.5: Influence of the Firth of Forth Banks Complex ncMPA and the Outer Firth of Forth and St Andrew’s Bay SPA on the Boundary Change

Table 4.9: Overview of Berwick Bank Wind Farm Boundary Changes and Project Design Refinements

Table 4.10: Comparison of Environmental Effects Associated with the Berwick Bank Wind Farm Boundary Changes and Project Design Refinements