13. Shipping and Navigation

13.1. Introduction

1. This chapter of the Offshore Environmental Impact Assessment Report (EIA) Report presents the assessment of the likely significant effects of the Berwick Bank Wind Farm offshore infrastructure which is the subject of this application (hereafter referred to as the “Proposed Development”) on shipping and navigation. Specifically, this chapter considers the likely significant effects of the Proposed Development seaward of Mean High Water Springs (MHWS) during the construction, operation and maintenance, and decommissioning phases.
2. Likely significant effect is a term used in both the “EIA Regulations” and the Habitat Regulations. Reference to likely significant effect in this Offshore EIA Report refers to “likely significant effect” as used by the “EIA Regulations”. This Offshore EIA Report is accompanied by a Report to Inform Appropriate Assessment (RIAA) which uses the term as defined by the Habitats Regulations Appraisal (HRA) Regulations.
3. The assessment presented is informed by the following technical chapters:

• volume 1, chapter 3: Project Description;
• volume 1, chapter 5: Stakeholder Engagement and Consultation;
• volume 1, chapter 6: Environmental Impact Assessment Methodology;
• volume 2, chapter 12: Commercial Fisheries;
• volume 2, chapter 14: Aviation, Military and Communications; and
• volume 2, chapter 17: Infrastructure and Other Users.
  4. This chapter summarises information contained within the Navigational Risk Assessment (NRA) (see volume 3, appendix 13.1) which, as required by the Maritime and Coastguard Agency’s (MCA), is informed by Marine Guidance Note (MGN) 654 (MCA, 2021) including the undertaking of a Formal Safety Assessment (FSA). The FSA has been translated into the methodology for assessment of effects outlined in section 13.9.

13.2. Purpose of this Chapter

5. The primary purpose of the Offshore EIA Report is outlined in volume 1, chapter 1. It is intended that the Offshore EIA Report will provide the Scottish Ministers, statutory and non-statutory stakeholders with sufficient information to determine the likely significant effects of the Proposed Development on the receiving environment.
6. In particular, this Shipping and Navigation EIA Report chapter:

• presents the existing environmental baseline established from desk studies, site-specific surveys and consultation with stakeholders;
• identifies any assumptions and limitations encountered in compiling the environmental information;
• presents the likely significant impacts on shipping and navigation arising from the Proposed Development and reaches a conclusion on the likely significant effects on shipping and navigation based on the information gathered and the analysis and assessments undertaken; and
• highlights any necessary monitoring and/or mitigation measures which recommended to prevent, minimise, reduce or offset the likely significant adverse environmental effects of the Proposed Development on shipping and navigation.

13.3. Study Areas

7. A 10 nm buffer has been applied around the Proposed Development array area (the ‘Proposed Development array area shipping and navigation study area’) as shown in Figure 13.1   Open ▸ . This study area has been defined to provide local context to the analysis of risks by capturing the relevant routes and vessel traffic movements within, and in proximity to, the Proposed Development array area. A 10 nm study area has been used within the majority of United Kingdom (UK) offshore wind farm NRAs and is suitable for collection of Radio Detection and Ranging (radar) data.
8. A 2 nm buffer has been applied around the Proposed Development export cable corridor (the ‘Proposed Development export cable corridor shipping and navigation study area’) as shown in Figure 13.1   Open ▸ . Again, this study area has been defined to capture relevant receptors and their movements within, and in proximity to, the Proposed Development export cable corridor. The Proposed Development export cable corridor shipping and navigation study area covers the Proposed Development export cable corridor area between Mean Low Water Springs (MLWS) at the shoreline and the boundary of the Proposed Development array area (i.e. offshore areas only).
9. Both shipping and navigation study areas have been agreed with key stakeholders, including the MCA, Northern Lighthouse Board (NLB) and Forth Ports, as part of discussions on survey methodology (see 08 July 2020, 10 June 2020 and 12 June 2020 entries in Table 13.5   Open ▸ , respectively).

Figure 13.1: Shipping and Navigation Study Areas

13.4. Policy and Legislative Context

10. Policy and legislation on renewable energy infrastructure is presented in volume 1, chapter 2 of the Offshore EIA Report. Policy and legislation specifically in relation to shipping and navigation, is contained in:

• United Nations Convention on the Law of the Sea (UNCLOS) (United Nations (UN), 1982);
• Convention on the International Regulations for Preventing Collisions at Sea (COLREGs) (International Maritime Organization (IMO), 1972/77);
• Safety of Life at Sea (SOLAS) Chapter V (IMO, 1974);
• UK Marine Policy Statement (Her Majesty’s Government (HM Government), 2011); and
• Scotland’s National Marine Plan (Scottish Government, 2015).

A summary of the legislative provisions relevant to shipping and navigation are provided in Table 13.1   Open ▸ , with other relevant policy provisions set out in Table 13.2   Open ▸ . These are summarised here with further detail presented in volume 3, appendix 13.1.

Table 13.1: Summary of Legislation Relevant to Shipping and Navigation

Table 13.2: Summary of UK Marine Policy Statement Relevant to Shipping and Navigation

13.5. Consultation

11. The Project has facilitated early engagement with stakeholders and subsequent engagement throughout the pre-application phase of the Proposed Development. The consultation process ensured that the focus in the EIA submission documents is on likely significant environmental effects as defined by the EIA Regulations but that the NRA follows the MCAs required guidance and methodology.
12. A summary of the key issues raised during consultation activities undertaken to date specific to shipping and navigation is presented in Table 13.3   Open ▸ , together with how these issues have been considered in the production of this Shipping and Navigation Offshore EIA Report chapter. Further detail is presented within Section 4 of the NRA.
13. The Shipping and Navigation Road Map (up to date at the point of Application) is presented as volume 3, appendix 13.2 and documents meetings and discussion points. At the request of MS-LOT an audit document (the Berwick Bank Wind Farm Audit Document for Post-Scoping Discussions (volume 3, appendix 5.1) has been produced and submitted alongside the application to summarise discussions on key issues, post-receipt of the Berwick Bank Wind Farm Scoping Opinion (MS-LOT, 2022).

Table 13.3: Summary of Key Consultation of Relevance to Shipping and Navigation

13.6. Methodology to Inform Baseline

13.6.1.              Desktop Study

14. Information on shipping and navigation within the shipping and navigation study areas was collected through a detailed desktop review of existing studies and datasets. These are summarised in Table 13.4   Open ▸ , with the most up to date available datasets used wherever possible with some datasets restricted by the availability of information from the providing organisation (i.e. Marine Accident Investigation Branch (MAIB) data which is not released immediately due to ongoing accident investigations).

Table 13.4: Summary of Key Desktop Reports

13.6.2.              Site-Specific Surveys

15. To inform the Shipping and Navigation Offshore EIA Report chapter, site-specific surveys were undertaken, as agreed with the MCA, NLB and Forth Ports (see 09 June 2020, 10 June 2020 and 12 June 2020 entries in Table 13.3   Open ▸ , respectively). A summary of the surveys undertaken to inform the shipping and navigation assessment of effects are outlined in Table 13.5   Open ▸ , noting that the winter 2021 and summer 2022 vessel traffic surveys are the primary sources used for characterising vessel traffic movements within and in proximity to the Proposed Development array area.

Table 13.5: Summary of Site-Specific Survey Data

13.7. Baseline Environment

13.7.1.              Overview of Baseline Environment

Navigational features

16. A plot of navigational features in proximity to the Proposed Development is presented in Figure 13.2   Open ▸ . Details of the key navigational features are provided in Table 13.6   Open ▸ .

Figure 13.2: Navigational Features in Proximity to the Proposed Development

Table 13.6: Details of Key Navigational Features

Vessel traffic movements

17. A plot of vessel traffic survey data from the winter 2021 survey recorded within the Proposed Development array area shipping and navigation study area, colour coded by vessel type, is presented in Figure 13.3   Open ▸ . Following this, the vessel traffic survey data from the summer 2022 survey is presented in Figure 13.4   Open ▸ . A number of the vessel tracks recorded were classified as temporary (non-routine), such as the tracks of the survey vessel, other non-routeing survey vessels and vessels associated with the construction of NnG. These have therefore been excluded to ensure the analysis is not skewed and gives a fair representation of standard vessel traffic movements in the area.
18. For the summer survey period (August 2022), there was an average of 14 unique vessels per day recorded within the Proposed Development array area shipping and navigation study area, and six unique vessels per day within the Proposed Development array area itself. The main vessel types were tankers (34% within the Proposed Development array area shipping and navigation study area), cargo vessels (30%) and commercial fishing vessels (18%).
19. For the winter survey period (January 2021), there was an average of 16 unique vessels per day recorded within the Proposed Development array area shipping and navigation study area, and six unique vessels per day within the Proposed Development array area itself. The main vessel types were cargo vessels (36% within the Proposed Development array area shipping and navigation study area), tankers (32%) and commercial fishing vessels (16%).
20. Passenger vessels were not present in the vessel traffic survey data. However, from an analysis of long-term vessel traffic data, an average of one unique passenger vessel every two days was recorded within the Proposed Development array area shipping and navigation study area. This discrepancy is attributed to the COVID-19 pandemic has had a substantial effect on shipping movements globally and was confirmed by Forth Ports during consultation.
21. Main commercial routes have been identified using the principles set out in MGN 654 (MCA, 2021) and based on the vessel traffic survey data, long-term vessel traffic data and consultation feedback. A total of 15 main commercial routes were identified within the Proposed Development array area shipping and navigation study area. A plot of the main commercial routes and corresponding 90th percentiles within the Proposed Development array area shipping and navigation study area is presented in Figure 13.5   Open ▸ . A description of each route is provided in Table 13.7   Open ▸ . It is noted that the start and end locations stated are based on the most common destinations transmitted via AIS by vessels on those routes.

Table 13.7: Description of Main Commercial Routes

22. From the vessel traffic survey data, there was an average of two to three unique commercial fishing vessels per day recorded within the Proposed Development array area shipping and navigation study area. Of these, 97% were recorded via AIS with 3% recorded via radar. VMS data indicates that the highest density areas for fishing activity are to the north of the Proposed Development array area.
23. From the vessel traffic survey data, only three unique recreational vessels were recorded within the Proposed Development array area shipping and navigation study area throughout the surveys. All three were recorded via AIS. The RYA Coastal Atlas of Recreational Boating (RYA, 2019) indicates a higher density of recreational activity towards the coast and Firth of Forth, with spare activity at the Proposed Development array area. Based on consultation feedback and the long-term vessel traffic data, there is estimated to be an average of two to three unique recreational vessels per day within the Proposed Development array area shipping and navigation study area.
24. A plot of vessel traffic data recorded within the Proposed Development export cable corridor shipping and navigation study area, colour coded by vessel type, is presented in Figure 13.6   Open ▸ . A number of the vessel tracks recorded were classified as temporary (non-routine), such as the tracks of non-routeing survey vessels and vessels associated with the construction of NnG. These have therefore been excluded to ensure the analysis is not skewed and gives a fair representation of standard vessel traffic movements in the area.
25. For the summer period (July 2020), there was an average of 24 unique vessels per day recorded within the Proposed Development export cable corridor shipping and navigation study area, and 21 unique vessels per day within the Proposed Development export cable corridor itself. The main vessel types were commercial fishing vessels (32% within the Proposed Development export cable corridor shipping and navigation study area), tankers (27%) and cargo vessels (25%).

Figure 13.3: Vessel Traffic Survey Data within Proposed Development Array Area Shipping and Navigation Study Area (14 Days, Winter 2021)

Figure 13.4: Vessel Traffic Survey Data within Proposed Development Array Area Shipping and Navigation Study Area (14 Days, Summer 2022)

Figure 13.5: Main Commercial Routes and 90th Percentiles within Proposed Development Array Area Shipping and Navigation Study Area

Figure 13.6: Vessel Traffic Survey Data within Proposed Development Export Cable Corridor Shipping and Navigation Study Area (28 Days, 2021/22)

26. For the winter period (January 2021), there was an average of 18 unique vessels per day recorded within the Proposed Development export cable corridor shipping and navigation study area, and 17 unique vessels per day within the Proposed Development export cable corridor itself. The main vessel types were tankers (36% within the Proposed Development export cable corridor shipping and navigation study area), cargo vessels (30%) and commercial fishing vessels (22%).
27. Passenger vessels were not present in the vessel traffic data. However, from an analysis of Anatec’s in-house ShipRoutes database, a route operated by passenger vessels is known to cross the Proposed Development export cable corridor with an average of approximately one vessel every three to four days. This discrepancy is attributed to the COVID-19 pandemic and was confirmed by Forth Ports during consultation.
28. The RYA Scotland noted that the RYA Coastal Atlas is the highest quality dataset available for recreational vessel movements for which the COVID-19 pandemic has had a large effect. The RYA Coastal Atlas of Recreational Boating (RYA, 2019) (see section 13.7.1) has therefore been used to inform the baseline characterisation of recreational vessel movements with additional consultation also undertaken with recreational clubs within the wider Forth area.

Emergency response resources and historical maritime incidents

29. A plot of emergency response resources in proximity to the Proposed Development is presented in Figure 13.7   Open ▸ . Details of the emergency response resources are provided in Table 13.8   Open ▸ .

Table 13.8: Details of Emergency Response Resources

30. A plot of the locations of accidents, injuries and hazardous incidents reported to the MAIB within the Proposed Development array area shipping and navigation study area between 2010 and 2019 is presented in Figure 13.7   Open ▸ Similar analysis within the Proposed Development export cable corridor shipping and navigation study area is provided in Section 9.5 of the NRA (volume 3, appendix 13.1).
31. An average of one incident every three years was reported to the MAIB within the Proposed Development array area shipping and navigation study area between 2010 and 2019. Incidents occurred inshore, north or south of the Proposed Development array area with no incidents reported within or offshore of the Proposed Development array area. One incident each of machinery failure, loss of control, and an accident to person were recorded.
32. A review of older MAIB incident data (2000 to 2009) indicates an average of one incident every two to three years. Therefore, there is a decreasing trend of MAIB reported incidents within the Proposed Development array area shipping and navigation study area over time.

Figure 13.7: Emergency Response Resources and MAIB Incident Data within Proposed Development Shipping and Navigation Study Areas (2010 to 2019)

33. An average of one unique incident per year was responded to by the RNLI within the Proposed Development array area shipping and navigation study area between 2010 and 2019. One incident occurred within the Proposed Development array area itself, involving an ‘other recreational’ vessel which was in trouble. All other incidents occurred inshore of the Proposed Development array area.

13.7.2.              Future Baseline Scenario

34. The EIA Regulations ((The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, The Marine Works (Environmental Impact Assessment) Regulations 2007, The Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and The Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017)), require that a “a description of the relevant aspects of the current state of the environment (baseline scenario) and an outline of the likely evolution thereof without development as far as natural changes from the baseline scenario can be assessed with reasonable effort, on the basis of the availability of environmental information and scientific knowledge” is included within the Offshore EIA Report.
35. In the event that the Proposed Development does not come forward, an assessment of the future baseline conditions has been carried out and is described within this section.
36. In relation to the current baseline, it is anticipated that, as with NnG and Seagreen, commercial vessel traffic will navigate around Inch Cape when construction commences. It is assumed that alternative routes will typically maintain a minimum mean distance of 1 nm from future wind farm structures in line with industry experience.
37. In terms of changes to vessel traffic volumes, two independent scenarios of potential growth in commercial vessel movements of 10% and 20% are estimated. These are considered conservative assumptions given that from consultation with Forth Ports there are no terminal or berth changes are planned which may affect vessel traffic in the future. Additionally, there are no commercial ferry routes planned, although it has been indicated in consultation that once Aberdeen South Harbour is operational there could be an increase in cruise traffic through the region.
38. For commercial fishing vessel activity, there is uncertainty associated with long-term predictions given the limited reliable information on future trends upon which any firm assumptions can be made. Therefore, to ensure a conservative approach, 10% and 20% growth scenarios in commercial fishing vessel movements have been estimated.
39. For recreational vessel activity, there are no major developments which will increase the level of activity in the region. Therefore, to ensure a conservative approach, 10% and 20% growth scenarios in recreational vessel movements have been estimated.

13.7.3.              Data Limitations and Assumptions

Automatic Identification System data

40. It is assumed that vessels under an obligation to broadcast information via AIS have done so, across all vessel traffic datasets. It has also been assumed that the details broadcast via AIS (such as vessel type and dimensions) are accurate unless clear evidence to the contrary was identified. It is not anticipated that the comprehensiveness of the AIS data compromises the assessment.

Vessel traffic data for Proposed Development export cable corridor

41. Since the vessel traffic data for the Proposed Development export cable corridor consists of AIS only, the data has limitations associated with non-AIS targets. However, the MCA and NLB were content with the methodology for vessel traffic data collection for the Proposed Development export cable corridor shipping and navigation study area (see Table 13.3   Open ▸ ) which includes consideration of additional data sources such as Anatec’s ShipRoutes database, VMS data, the UK Coastal Atlas of Recreational Boating (RYA, 2019) and consultation feedback. With these additional datasets incorporated, the characterisation of vessel traffic movements for the Proposed Development export cable corridor shipping and navigation study area is considered to be suitably comprehensive and adequate for the assessment.

COVID-19 pandemic

42. It is widely accepted that the COVID-19 pandemic has had a substantial effect on shipping movements globally. Therefore, the vessel traffic survey data collected in winter 2021 may be influenced by the pandemic. However, in line with best practices, the Applicant has agreed the approach to data collection with relevant stakeholders, including the MCA. This includes the use of long-term vessel traffic data predating the COVID-19 pandemic to validate the vessel traffic survey data. With this dataset incorporated, the characterisation of vessel traffic movements for the Proposed Development array area shipping and navigation study area is considered to be suitably comprehensive and adequate for the assessment.

Historical incident data

43. Although all UK commercial vessels are required to report incidents to the MAIB, this is not mandatory for non-UK vessels unless they are in a UK port, within territorial waters or carrying passengers to a UK port. There are also no requirements for non-commercial recreational craft to report incidents to the MAIB. Nevertheless, the MAIB incident database is considered to be a suitable source for the characterisation of historical incidents and adequate for the assessment.
44. The RNLI incident data cannot be considered comprehensive of all incidents in the shipping and navigation study areas. Although hoax and false alarms are excluded, any incident to which a RNLI resource was not mobilised has not been accounted for in this dataset. Nevertheless, the RNLI incident data is considered to be a suitable source for the characterisation of historical incidents and adequate for the assessment.

Admiralty charts

45. The Admiralty Charts published by the UKHO are updated periodically, and therefore the information shown may not reflect the real-time features within the region with total accuracy. Taking into account consultation undertaken, the characterisation of navigational features is considered to be suitably comprehensive and adequate for the assessment. For aids to navigation, only those charted and considered key to establishing the shipping and navigation baseline are shown.

13.8. Key Parameters for Assessment

13.8.1.              Maximum Design Scenario

46. The maximum design scenarios identified in Table 13.9   Open ▸ have been selected as those having the potential to result in the greatest effect on an identified receptor or receptor group. These scenarios have been selected from the details provided in volume 1, chapter 3 of the Offshore EIA Report. Effects of greater adverse significance are not predicted to arise should any other development scenario, based on details within the Project Design Envelope (e.g. different infrastructure layout), to that assessed here, be taken forward in the final design scheme.

Table 13.9: Maximum Design Scenario Considered for the Assessment of Potential Impacts on Shipping and Navigation

13.8.2.              Impacts Scoped out of the Assessment

47. The Shipping and Navigation Road Map (see volume 3, appendix 13.2) has been used to facilitate stakeholder engagement on topics to be scoped out of the assessment.
48. On the basis of the baseline environment and the project description outlined in volume 1, chapter 3 of the Offshore EIA Report, one impact is proposed to be scoped out of the assessment for shipping and navigation. This has been agreed with key stakeholders through consultation as discussed in volume 1, chapter 5. The impact scoped out is outlined, together with a justification for scoping it out, in Table 13.10   Open ▸ .
49. Where discussions with consultees relevant to shipping and navigation took place after the publication of the Berwick Bank Wind Farm Scoping Opinion (MS-LOT, 2022), these are audited in the Audit Document for Post-Scoping Discussions (volume 3, appendix 5.1).

Table 13.10: Impact Scoped Out of the Assessment for Shipping and Navigation (Tick Confirms the Impact is Scoped Out)

13.9. Methodology for Assessment of Effects

13.9.1.              Overview

50. The shipping and navigation assessment of effects has followed the FSA methodology since this is the internationally recognised approach for assessing the impact to shipping and navigation receptors, and is the approach required under the MCA’s methodology (Annex 1 of MGN 654). The following guidance documents have been considered:

• MGN 654 (Merchant and Fishing) Safety of Navigation: Offshore Renewable Energy Installations (OREIs) – Guidance on UK Navigational Practice, Safety and Emergency Response and its annexes (MCA, 2021);
• MGN 372 (Merchant and Fishing) Offshore Renewable Energy Installations (OREI) Guidance to Mariners Operating in the Vicinity of UK OREIs (MCA, 2008);
• International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA) O-139 on The Marking of Man-Made Offshore Structures (IALA, 2021 (a));
• IALA G1162 The Marking of Offshore Man-Made Structures (IALA, 2021 (b)); and
• The Royal Yacht Association’s (RYA) Position on Offshore Renewable Energy Developments: Paper 1 (of 4) – Wind Energy (RYA, 2019).

13.9.2.              Criteria For Assessment of Effects

51. The criteria for determining the significance of effects are derived from a two-stage process that considers the severity of consequence and frequency of occurrence. This section describes the criteria applied in this chapter to assign values to each of these two factors.
52. The criteria for defining severity of consequence in this chapter are outlined in Table 13.11   Open ▸ . For the level of assistance required to manage environmental damage, the tiers indicated relate to the incident response matrix provided in the National Contingency Plan (MCA, 2014).

Table 13.11: Definition of Terms Relating to the Severity of Consequence

53. The criteria for defining frequency of occurrence in this chapter are outlined in Table 13.12   Open ▸ .

Table 13.12: Definition of Terms Relating to the Frequency of Occurrence

54. The significance of the effect upon shipping and navigation is determined by correlating the severity of consequence and frequency of occurrence. The particular method employed for this assessment is presented in Table 13.13   Open ▸ .
55. For the purposes of this assessment:

• a level of residual effect of unacceptable will be considered a ‘significant’ effect in terms of the EIA Regulations; and
• a level of residual effect of broadly acceptable or tolerable will be considered ‘not significant’ in terms of the EIA Regulations.
  56. Effects of Unacceptable significance are therefore considered important in the decision-making process, whilst effects of Broadly Acceptable or Tolerable significance warrant little, if any, weight in the decision-making process.

Table 13.13: Matrix Used for the Assessment of the Significance of the Effect

57. Additionally, differences in terminology between this chapter (which uses EIA terminology) and the NRA (which uses FSA terminology) are summarised in Table 13.14   Open ▸ .

Table 13.14: Summary of Differences in Terminology Between EIA and NRA

13.10. Measures Adopted as part of the Proposed Development

58. As part of the Project design process, a number of measures have been proposed to reduce the potential for impacts on shipping and navigation (see Table 13.15   Open ▸ ). As there is a commitment to implementing these measures, they are considered inherently part of the design of the Proposed Development and have therefore been considered in the assessment presented in section 13.11 (i.e. the determination of magnitude and therefore significance assumes implementation of these measures). These measures are considered standard industry practice for this type of development.

Table 13.15: Designed In Measures Adopted as Part of the Proposed Development

13.11. Assessment of Significance

59. The potential effects arising from the construction, operation and maintenance and decommissioning phases of the Proposed Development are listed in Table 13.9   Open ▸ , along with the maximum design scenario against which each impact has been assessed. An assessment of the likely significance of the effects of the Proposed Development on shipping and navigation receptors caused by each identified impact is given below.

Vessel Displacement

Construction Phase

Severity of Consequence

60. Anticipated deviations for the main commercial routes identified from the vessel traffic data have been defined. The full methodology for main route deviations is provided in Section 15.5.1 of the NRA, with deviations established in line with industry experience and consultation feedback. For Shipping and Navigation, reference is made to ‘Seagreen’ (the collective 150 consented wind turbines that will be installed for Seagreen 1 and Seagreen Project 1A). This is on the basis Seagreen Project 1A is captured within the displacement footprint of Seagreen 1, which invalidates the need to distinguish the sub-projects. Although there will be no restrictions on entry into the buoyed construction area, other than active construction or pre-commissioning safety zones, based on experience at previously under construction offshore wind farms (including the nearby NnG and Seagreen), it is anticipated that commercial vessels will choose not to navigate internally within the buoyed construction area.
61. An illustration of the anticipated shift in the mean positions of the main commercial routes within the Proposed Development array area shipping and navigation study area for the maximum adverse scenario is presented in Figure 13.8   Open ▸ . For the displaced routes, the increase in distance from the pre wind farm scenario is detailed in Table 13.16   Open ▸ .

Figure 13.8 Anticipated Main Commercial Routes Post Wind Farm within Proposed Development Array Area Shipping and Navigation Study Area

Table 13.16: Summary of Post Wind Farm Main Commercial Route Deviations within Proposed Development Array Area Shipping and Navigation Study Area

62. A deviation will be required for seven out of the 14 main commercial routes identified, with the level of deviation varying between a 0.2 nm decrease for Route 9 (due to the route being anticipated to make a slight turn to maintain distance to the western boundary of the Proposed Development array area) and a 26.0 nm increase for Route 14.
63. During consultation, the NLB indicated that there is an east-west route through the Proposed Development which may be of concern. This concern was also raised by the UK Chamber of Shipping and HAV Ship Management, a Regular Operator in the area. Route 5 is representative of such a transit (noting that it includes vessels operated by HAV Ship Management) and is estimated to require a deviation of 3.4 nm following the placement of the buoyed construction area. However, this represents only a 0.8% change in the total route length, with the route operating between Forth ports and Baltic ports.
64. Additionally, Evergas, a Regular Operator in the area, indicated that there is a particular impact on routeing of vessels coming from the north. Route 14 is representative of such a transit (noting that it includes vessels operated by Evergas) and is estimated to require a deviation of 26 nm following the placement of the buoyed construction area. However, this represents only a 0.8% change in the total route length, with the route operating between Forth ports and Pennsylvania (United States).
65. Based on experience at previously under construction offshore wind farms (including the nearby NnG and Seagreen), it is anticipated that commercial fishing vessels and recreational vessels will also choose not to navigate internally within the buoyed construction area on a regular basis, although there will be no restrictions on such transits. There is sufficient sea room around the Proposed Development array area (and buoyed construction area) to allow such small craft to navigate an alternative route. It is noted that during consultation, the Forth Yacht Clubs Association indicated that habitual coastal cruising routes for smaller recreational craft generally lie inshore of the Proposed Development array area and so will be unaffected.
66. Those vessels that deviate offshore of the Proposed Development array area (such as Routes 4 and 14) will be more exposed to adverse weather given the greater distance from the UK coast. However, there is sufficient available sea room to the south and east of the Proposed Development array area to ensure that a safe distance can be maintained from the buoyed construction area.
67. In terms of existing adverse weather routeing, no substantial alternative routeing was observed in the long-term vessel traffic data, including during periods where adverse weather was known to be present. This is reflected in Regular Operator consultation with North Star Shipping and HAV Ship Management indicating that no impact is foreseen. Intrada Ship Management, another Regular Operator in the area, noted that given their vessels carry deck cargoes there is a particular sensitivity to rolling and pitching and adequate sea room is necessary to ensure headings can be selected to minimise the effect of the weather and tidal direction. Additionally, Forth Ports have indicated that the region is known to experience significant bad weather with the FMA highlighting the Marr Bank as a particular hazard of note for large tankers navigating coastally in adverse weather.
68. For small craft, use of safe havens in adverse weather conditions was not observed within the vessel traffic survey data or long-term vessel traffic data.
69. The most likely consequences of the impact are increased journey times and distances leading to minor increases in emissions associated with increased fuel consumption. Although there is potential for the commercial consequence of disruption to schedules, the relatively low changes in total route length mean that it is likely that time losses can be made up through effective passage planning and increased speeds when in open seas. This will be assisted by the charting of the buoyed construction area and promulgation of information such as advisory safe passing distances which will allow vessels to passage plan the most safe and efficient route in advance. The maximum adverse scenario may include disruption to schedules, but this is considered highly unlikely given the international nature of routeing in the area and the ability to passage plan to minimise timing impacts.
70. The severity of consequence is therefore considered to be minor.

Frequency of Occurrence

71. The impact will be present throughout the construction phase which will last for up to eight years. The busiest main commercial route identified within the Proposed Development array area shipping and navigation study area for which an increased passage distance is required is Route 3, with an average of one to two vessels per day. In total, across all the routes for which an increased passage distance is required, there is an average of five vessels per day. Additionally, a proportion of the non-commercial vessel traffic may also be affected, noting that an average of one to two unique fishing vessels per day were recorded within the Proposed Development array area shipping and navigation study area throughout the vessel traffic surveys.
72. Therefore, it is anticipated that vessels will be exposed to the impact on a daily basis, particularly commercial vessels such as tankers and cargo vessels which constitute the majority of the vessel traffic, including those assigned to the main commercial routes.
73. The frequency of occurrence is therefore considered to be frequent.

Significance of the Effect

74. Overall, the severity of consequence is deemed to be minor and the frequency of occurrence is considered to be frequent. The effect will, therefore, be of tolerable adverse significance, which is not significant in EIA terms.

Secondary Mitigation and Residual Effect

75. No shipping and navigation mitigation is considered necessary because the likely effect in the absence of further mitigation (beyond the designed in measures outlined in Table 13.15   Open ▸ ) is not significant in EIA terms.

Operation and Maintenance Phase

Severity of Consequence

76. Based on experience at existing operational offshore wind farms, it is anticipated that commercial vessels will generally choose not to navigate internally within the Proposed Development array area. Therefore, the anticipated deviations for the main commercial routes defined for the construction phase (around the buoyed construction area) are directly applicable for the operation and maintenance phase, as presented in Figure 13.8   Open ▸ and detailed in Table 13.16   Open ▸ .
77. Since the size and location of the buoyed construction area and operational Proposed Development array area will be almost identical, the concerns raised during consultation outlined for the equivalent construction phase are directly applicable for the operation and maintenance phase. This includes the concerns relating to east-west and north-south routeing, which in both cases represents only a small percentage change in the total route length.
78. Based on experience at existing operational offshore wind farms, it is anticipated that commercial fishing vessels and recreational vessels may choose to navigate internally within the Proposed Development array area, particularly in favourable weather conditions. During consultation the CA noted that as offshore wind farms become more commonplace there is increasing comfort among recreational users with internal navigation.
79. The degree of comfort noted by the CA will be heightened by there being no restrictions on navigation internally within the Proposed Development array area other than any major maintenance safety zones. The minimum spacing between the Proposed Development wind turbines is 1,000 m which is large compared to many existing offshore wind farms, comparable to the minimum spacing which will exist at NnG (903 m) and Seagreen (996 m) once constructed, and comparable to the minimum spacing consented at Inch Cape (1,278 m). Furthermore, the wind turbines will likely be arranged in rows and columns with two lines of orientation[3] to further assist safe navigation by small craft. Comfort with internal navigation will likely increase throughout the lifetime of the Proposed Development. The final array layout will be agreed through the DSLP, which will include consultation with the MCA and NLB.
80. The same array layout benefits are also applicable to commercial fishing vessels. The Scottish Whitefish Producers Association have indicated that the minimum spacing between wind turbines may be insufficient to allow safe navigation, although given the points raised above the impact is not considered substantial. Effects on active fishing activity are considered in volume 2, chapter 12.
81. In relation to adverse weather routeing and use of safe havens, there are again no substantial concerns given the lack of such activities within the vessel traffic data. Forth Ports have indicated that the region is known to experience significant bad weather with the FMA highlighting the Marr Bank as a particular hazard of note for large tankers navigating coastally in adverse weather. However, the water depths associated with navigation over the Marr Bank are similar to those navigated in the pre wind farm scenario and therefore the additional impact is considered minimal.
82. The most likely consequences of the impact are as per the equivalent construction phase impact, namely increased journey times and distances leading to increased fuel consumption. Passage planning will be assisted by the charting of infrastructure associated with the Proposed Development and the promulgation of information. The maximum adverse scenario may include disruption to schedules, but this is considered highly unlikely given the international nature of routeing in the area and the ability to passage plan to minimise timing impacts. The severity of consequence is therefore considered to be minor.

Frequency of Occurrence

83. The impact will be present throughout the operation and maintenance phase which will last for up to 35 years. Since the anticipated deviations associated with the main commercial routes and the volumes of vessel traffic on such routes are the same as for the equivalent construction phase impact, it is again anticipated that vessels will be exposed to the impact on a daily basis.
84. The frequency of occurrence is therefore considered to be frequent.