1 Aims, Scope and Format of the Road Map

1.1 Background and Aims

Phase 2 of the former Firth of Forth Zone includes Berwick Bank Wind Farm for which consents and licences (as set out below) are being sought. This Project includes both the offshore wind turbine generators (hereafter referred to as wind turbines) and associated offshore infrastructure, as well as onshore grid connection and associated infrastructure.

The Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map covers assessment in relation to the Berwick Bank Wind Farm, seaward of Mean High Water Springs (MHWS). This Road Map does not consider onshore impacts of onshore infrastructure (landward of MHWS). Consent and licence applications for the onshore and offshore components of the Project are being submitted separately. The offshore components of the Project are hereafter referred to as ‘The Proposed Development’.

Key components of the Proposed Development include:

wind turbines;
wind turbine foundations;
inter-array cables;
offshore substation platforms (OSP)/Offshore convertor station platforms; and
offshore export cables.

The Proposed Development requires the following consents, licences and permissions:

a Section 36 consent under the Electricity Act 1989;
a marine licence under the Marine and Coastal Access Act (MCAA) 2009;
a marine licence under the Marine (Scotland) Act 2010 for the part of the offshore export cables which is within 12 nautical miles (nm) of the coast; and
planning permission under the Town and Country Planning (Scotland) Act 1997 for all infrastructure located landward of Mean Low Water Springs (MLWS) and seaward of MHWS.

The aim of this Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map is to support reached agreement with key stakeholders on the information provided by SSE Renewables (hereafter referred to as “the Applicant”) in relation to benthic subtidal and intertidal ecology, fish and shellfish ecology and physical processes Environmental Impact Assessment (EIA) and the Report to Inform the Appropriate Assessment (RIAA), as part of the Section 36 Consent Application and Marine Licence Applications for the Proposed Development. This Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map documents discussions and agreements between the Applicant and the key stakeholders listed in section 2.

This Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map seeks to ensure that the information supplied in the consent Applications listed above is compliant with the requirements of the following regulations, hereafter referred to as the EIA Regulations:

Section 36 consent application: The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017;
marine licence application: The Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and The Marine Works (Environmental Impact Assessment) Regulations 2007; and
a planning application: The Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017.
As well as the following regulations, hereafter referred to as the Habitats Regulations:
the Conservation (Natural Habitats &c.) Regulations 1994 (as amended);
the Conservation of Habitats and Species Regulations 2017 (as amended)[1]; and
the Conservation of Offshore Marine Habitats and Species Regulations 2017 (as amended)1 (which apply to marine licences and Section 36 applications within the Scottish Offshore region.

As part of engagement in the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map process, it was envisaged that the Applicant and key stakeholders would:

provide information in a timely manner;
be transparent and consistent in provision of advice;
provide effective involvement in the stakeholder engagement process;
aim to adhere to the programme of meetings set out in this Road Map (see section 3); and
seek to identify any issues or additional data requirements as early as possible.
The Applicant sought to provide this Road Map as an accurate record of meetings held, discussions undertaken and points of agreement relating to the offshore EIA and Habitats Regulations Appraisal (HRA) benthic ecology, fish and shellfish and physical processes assessments.

Engagement with regard to the Habitats Regulations Appraisal (HRA) process focused primarily on benthic ecology and fish and shellfish, however it was acknowledged there may be overlap of physical processes aspects such as physical processes modelling.

1.2 Scope

The Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map was used as a tool to facilitate early and on-going engagement with key stakeholders, throughout the pre-application phase of the Proposed Development up to the point of Application submission. This included consultation on the developing baseline characterisation, including approaches to data collection for benthic subtidal and intertidal ecology, underwater noise modelling for fish ecology, physical processes modelling, assessment of significance, and development of the final application documentation. This Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map was a ‘live’ document which was used to reach and record points of agreement, for example on scoping impacts out of the EIA, RIAA and Marine Protected Area (MPA) assessment, and agreeing the level of assessment that were presented for impacts scoped in to the EIARIAA and MPA assessment, so that the focus in the assessment documents in support of the Application are on likely significant effects as defined by the EIA Regulations, and Likely Significant Effects (LSE) as defined by European caselaw associated with the Habitat Directive.

The Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map sought to agree the following as a minimum, however additional points of agreement/discussion were required, and these were discussed with key stakeholders and documented within this Road Map:

present evidence base (including site-specific subtidal and intertidal surveys);
baseline datasets;
baseline characterisation (including key marine fish and diadromous fish species and habitats);
impacts and receptors to scoped in/out of the Offshore EIA Report;
HRA screening including agreeing the relevant sites, receptors and phases to be screened into the RIAA;
assessment of effects approach (including sensitivity of receptors, method of quantifying impacts and approach to hydrodynamic and hydro-sedimentary modelling);
MPA assessment; and
initial findings of assessments of effects, appropriate mitigation and monitoring.

For all the above, the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map sought to record key areas of agreement and/or outstanding points of discussion.

1.3 Format

Figure 1.1 Open ▸ outlines the key stages of the offshore EIA and HRA processes, and how the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map proposed to facilitate engagement during key stages. The first stage of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map process was to agree the aims, scope and format of the Road Map, and the proposed timetable for engagement as set-out in this document.

The remainder of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map is set out as follows:

section 2: identifies the key statutory stakeholders to the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map;
section 3: outlines the proposed benthic ecology, fish and shellfish ecology and physical processes offshore EIA programme, and the benthic ecology and fish and shellfish ecology HRA programmes for the Proposed Development. It includes a record of meetings that have taken place in relation to the benthic ecology, fish and shellfish ecology and physical processes offshore EIA and the benthic ecology and fish and shellfish ecology HRA assessments;
section 4: provides a summary of discussions, areas of agreement and areas of outstanding discussion in relation to the benthic ecology, fish and shellfish ecology and physical processes offshore EIA and the benthic ecology and fish and shellfish ecology HRA assessments. The aim has been to have as few issues as possible with outstanding discussion at the point of Application submission; and
section 5: summarises the position (agreement/areas of outstanding discussion) at the point of Application submission.

Figure 1.1: Key Stages of the Proposed Development

2 Key Stakeholders

It was proposed that the aims of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map would be achieved through engagement with the following key statutory stakeholders:

Marine Scotland Licencing and Operations Team (MS-LOT);
Marine Scotland Science (MSS);
NatureScot; and
Joint Nature Conservation Committee (JNCC).

The aforementioned key stakeholders attended all the meeting held except for JNCC that attended the meetings three and four only.

Table 2.1 Open ▸ sets out the remit, role in the offshore EIA/HRA processes and the key contact for each of the stakeholders listed above.

Table 2.1: Remit, Role and Contact for Key Stakeholders Associated with the Benthic Ecology, Fish and Shellfish Ecology and Marine Processes EIA and HRA Road Map

3 Programme

3.1 Benthic Ecology, Fish and Shellfish Ecology and Physical Processes EIA programme, and Benthic Ecology and Fish and Shellfish Ecology HRA programme for the Proposed Development

Table 3.1 Open ▸ below sets out the programme for key stages of the pre-application process in relation to the Berwick Bank Wind Farm.

Table 3.1: Offshore EIA and HRA Project Programme for the Proposed Development

3.2 Programme of Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map Meeting

Table 3.2 Open ▸ sets out the programme of stakeholder meetings in relation to key aspects of the benthic ecology, fish and shellfish ecology and physical processes technical assessments. These were scheduled to take place at key points of the pre-application phase and were in line with the key deliverables set out in Table 3.1: and the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map process. The meetings listed in are also listed within Figure 1.1 Open ▸ . All meetings were held via conference calls unless otherwise specified. This was due to COVID-19 pandemic restrictions throughout the pre-Application phase.

The Applicant has presented an overview of the consenting and Road Map process and the points of discussion that have taken place as part of this Road Map. In addition, an Audit Document for Post-Scoping Discussions has also been provided in volume 3, appendix 5.1, summarising key points of advice received subsequent to receipt of the Berwick Bank Scoping Opinion in February 2022, and how these have been addressed in the Application documents.

Table 3.2: Programme for Stakeholder Engagement: Benthic Ecology, Fish and Shellfish Ecology and Physical Processes

3.3 Record of Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map Meetings

Table 3.3 Open ▸ records the meetings that have taken place, the attendees and the key discussion points in relation to the benthic ecology, fish and shellfish ecology and physical processes offshore EIA, and the benthic ecology and fish and shellfish ecology offshore HRA assessments. This table (and link to reference material) was updated after each meeting and circulated to all attendees as a record of the meeting and the key points of discussion. Table 3.3 Open ▸ does not record full minutes, however a meeting minute reference is provided for each meeting in this table and meeting minutes have been circulated following each meeting.

Table 3.3: Record of Benthic Ecology, Fish and Shellfish Ecology and Marine Processes Meetings Undertaken as part of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map

4 Record of Discussions

This section of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map documents discussions and areas of agreement and outstanding discussion points following each meeting as set out in section 3. Further details on key aspects of discussion are provided in meeting notes.

The following subsections record associated discussion:

evidence base (including site-specific subtidal and intertidal surveys) - section 4.1;
baseline datasets - section 4.1;
baseline characterisation (including key marine fish and diadromous fish species and habitats) - section 4.1;
impacts and receptors to be scoped in/out of the Offshore EIA Report - section 4.1;
developments to be screened into the Cumulative Effects Assessment (CEA) - section 4.1;
HRA screening including agreeing the relevant sites, receptors and impact pathways to be screened into the RIAA - section 4.1;
approach to assessment of effects (including sensitivity of receptors, method of quantifying impacts and approach to hydrodynamic and hydro-sedimentary modelling – section 4.2;
MPA assessment – section 4.2;
physical processes modelling approach – section 4.2;
initial findings of assessment of effects, appropriate mitigation and monitoring – section 4.3; and
initials findings of MPA assessment – section 4.3.

4.1 Receptors, Key Impacts and Data Sources

This section aims to document and agree key areas of agreement and outstanding discussion points associated with the benthic ecology, fish and shellfish ecology and physical processes baseline for the Berwick Bank Wind Farm offshore EIA, HRA and MPA assessment. These include the following:

evidence base (including site-specific subtidal and intertidal surveys);
baseline datasets;
baseline characterisation (including key marine fish and diadromous fish species and habitats);
impacts and receptors to be scoped in/out of the Offshore EIA Report;
developments to be screened into the CEA; and
HRA screening including agreeing the relevant sites, receptors and impact pathways to be screened into the RIAA.
Table 4.1 Open ▸ summarises the points of discussion, areas of agreement and outstanding agreements in relation to the benthic ecology, fish and shellfish ecology and physical processes baselines for the Proposed Development.

Table 4.1: Summary of Discussion and Agreed Position on Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Baseline Data for EIA and HRA

4.1.1 Additional Detail on Key Discussions

4.1.1.1 Benthic ecology scoping of receptors and impacts

Benthic Seabed Habitats:

No Annex I stony/rocky reef in Proposed Development array area nor Annex I Sabellaria spinulosa reef observed although individuals S. spinulosa present. No Modiolus modiolus beds recorded, although individual M. modiolus present.

Benthic Ecology Scope of Impacts:

No sediment contamination levels exceeding AL1/AL2 and Canadian Threshold Effect Levels (TEL) except five stations, therefore impact suggested to be scoped out by the Applicant.

4.1.1.2 Physical processes evidence base

Monitoring/Field Data:

Berwick Bank surveys: geophysical and metocean (Fugro 2020a, 2020b);
Seagreen Alpha/Bravo surveys: geophysical and metocean (Fugro 2012);
EMODnet: bathymetry and seabed sediment;
MEDIN – bathymetric data;
Centre for Environment, Fisheries and Aquaculture Science (Cefas): salinity, temperature and turbidity;
British Oceanographic Data Centre (BODC): metocean;
United Kingdom Hydrographic Office (UKHO): tidal data;

Reports/Studies:

Baseline Characteristics: Dynamic Coast, Ramsay & Brampton (2009), Forth & Tay offshore wind farms (Inch Cape, Neart na Gaoithe, Seagreen);
Designations & Marine Activities: JNCC & MSS mapping resources;

Models/Simulated Data

Berwick Bank Wind Farm model: tidal current, wave climate, littoral current (sediment transport), particle tracking (sediment releases); and
Model Forcing/Scoping: ECMWF, Met Office, Scottish Shelf Model, Seagreen, models cited in studies.

4.1.1.3 Fish and shellfish ecology baseline characterisation

General habitat and fish assemblage data:

Marine Scotland NMPi maps;
EIA characterisation surveys for Seagreen Alpha/Bravo, Inch Cape and Neart na Gaoithe Offshore Wind Farms;
EMODnet seabed habitats; and
Biotope mapping (benthic ecology).

Fish spawning and nursery:

Cefas spawning and nursery grounds (Ellis et al. (2012), Coull et al. (1998));
Sandeels – site specific data; Latto et al. (2013);
Herring – site specific data; Reach et al. (2013); and
International Council for the Exploration of the Sea (ICES) programme of International Herring Larval Surveys (IHLS) in the North Sea (2007 - 2016);

Diadromous fish:

Fish and shellfish ecology assessment for Seagreen 1 (Seagreen, 2018); and
Rod catch data.

4.1.1.4 Fish and shellfish ecology IEFS (*PMFs)

Marine Fish: plaice Pleuronectes platessa, lemon sole Microstomus kitt, other flatfish species, cod* Gadus morhua, haddock Melanogrammus aeglefinus, whiting* Merlangius merlangus, saithe* Pollachius virens, other demersal species, lesser sandeel* Ammodytes tobianus, raitt’s sandeel* Ammodytes marinus, herring* Clupea harengus, mackerel* Scomber scombrus, sprat Sprattus sprattus, basking shark* Cetorhinus maximus, tope Galeorhinus galeus, spurdog* Squalus acanthias, common skate* Dipturus batis, rays
Shellfish IEF: edible crab Cancer pagurus, Norway lobster Nephrops norvegicus, European lobster Homarus gammarus, king scallop Pecten maximus, velvet swimming carb Necora puber, other crustaceans, freshwater pearl mussel Margaritifera margaritifera.
Diadromous Fish IEF: sea trout* Salmo trutta, European eel* Anguilla anguilla, sea lamprey* Petromyzon marinus, river lamprey* Lampetra fluviatilis, twaite shad Alosa fallax, allis shad Alosa alosa, Atlantic salmon Salmo salar, sparling/European smelt* Osmerus eperlanus.

4.1.1.5 Berwickshire and North Northumberland SAC identified and screened for consideration of LSE

Site features:

large shallow inlets and bays;
mudflats and sandflats not covered by seawater at low tide;
reefs; and
submerged or partially submerged sea caves.

Closest distance to:

Proposed Development array area – 34.67 km; and
Proposed Development export cable corridor – 4.12 km.

4.1.1.6 Sites designated for Annex II diadromous fish

For sea and river lamprey:

Tweed Estuary SAC (46.5 km to Proposed Development array area/29 km to Proposed Development export cable corridor).

For Atlantic salmon and freshwater pearl mussel:

River South Esk SAC (51.4 km to Proposed Development array area/76.5 km to Proposed Development export cable corridor); and
River Dee SAC (79.8 km to Proposed Development array area/106.6 km to Proposed Development export cable corridor).

For Atlantic salmon, sea lamprey and river lamprey:

River Tweed SAC (51.6 km to Proposed Development array area/34.1 km to Proposed Development export cable corridor);
River Tay SAC (87.2 km to Proposed Development array area/102.7 km to Proposed Development export cable corridor);and
River Teith SAC (148.1 km to Proposed Development array area/113.8 km to Proposed Development export cable corridor).

4.1.2 Summary Statement of Final Position

The lists of receptors, impacts and relevant sites to be scoped in/out of the offshore EIA report assessment and screened in/out of the offshore RIAA, as well as the evidence base and baseline characterisation, followed the suggestions from the Applicant in Table 4.1 Open ▸ with the inclusion of the following advice from the stakeholders. These have been agreed by the Applicant during Road Map Meetings:

kelp forests to be considered as an IEF in the benthic ecology technical report and offshore EIA chapter (volume 3, appendix 8.1 and volume 2, chapter 8 respectively);
micro-siting considered as a designed in measure in the offshore EIA benthic ecology chapter (volume 2, chapter 8);
FeAST used to inform the sensitivity assessment of the receptor;
impact of EMFs from subsea cabling scoped in the offshore EIA benthic ecology chapter (volume 2, chapter 8);
only the Firth of Forth Banks Complex ncMPA requires to be considered in the MPA assessment;
cumulative effects to be considered in the MPA assessment;
the list of in IEFs and PMFs from section 4.1.1.4, without sparling and river lamprey, are to be considered in the offshore EIA fish and shellfish ecology chapter (volume 2, chapter 9).

4.2 Data Analyses, Sensitivity of Relevant Receptors and Approach to Modelling

This section aims to document and agree key elements of the benthic ecology, fish and shellfish, and physical processes data analysis for the Proposed Development offshore EIA and HRA. These include the following:

approach to assessment of effects (including sensitivity of receptors, method of quantifying impacts and approach to hydrodynamic and hydro-sedimentary modelling); and
approach to MPA assessment.
Table 4.2 Open ▸ summarises the points of discussion, areas of agreement and areas of outstanding discussion in relation to the benthic ecology, fish and shellfish ecology and physical processes baseline data analysis for the Proposed Development.

Table 4.2: Summary of Discussion and Agreed Position on Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Data Analysis

4.2.1 Additional Details on Key Discussions

The construction phase is expected to last approximately 8 years. The operation and maintenance phase is 35 years long. Decommission is expected to have similar impacts as the construction phase.

4.2.1.1 General approach to assessment of effects

Benthic ecology and fish and shellfish ecology:

Following the Chartered Institute of Ecology and Environmental Management (CIEEM) Guidelines for EcIA in the UK and Ireland (CIEEM, 2019) and Environmental Protection Agency (EPA) Guidelines on the Information to be Contained in EIA Reports (EPA, 2017), the approach is summarised as follow:

identify the IEFs;
define the magnitude of the impact (based on the maximum design scenario which is determined by the PDE);
define the sensitivity of receptors (considering vulnerability, recoverability and value using the MarESA (benthic ecology only) and FeAST tool, scientific literature and results from other offshore wind farm monitoring programme); and
conclusion of significance in EIA terms based on the assessment matrix (magnitude x sensitivity).

CEA for benthic ecology, fish and shellfish, and physical processes:

the CEA for benthic ecology and physical processes will take into account the impact associated with the Proposed Development together with other relevant plans, projects and activities (i.e. other offshore wind farm projects, aggregate extraction/disposal areas); and
CEA will consider other plans, projects and activities within two tidal excursions (~20 km) of the Proposed Development.

4.2.1.2 MPA assessment

The MPA assessment will:

be a stand-alone report accompanying the Offshore EIA Report;
consider whether there is, or may be, a significant risk of the Proposed Development hindering the achievement of the conservation objectives of the ncMPA; and
draw on the output of other technical chapters such as physical processes, benthic ecology, fish and shellfish and marine mammals.

NatureScot and JNCC requested to see the extent of impacted area for each protected feature, as well as the percentage from the overall ncMPA and each component part of the ncMPA. They requested to see this for each component of the proposed development (e.g. foundations, inter-array/interconnector cabling, export cabling, scour/cable protection), individually and in combination with Seagreen (Seagreen 1 & 1A). They also requested to better understand the extent to which each feature could be protected by the proposed 50 m safety exclusion zone around each wind turbine foundation. From this, they can better evaluate the context of such protection, against the extent that is predicted to be disturbed and permanently lost through the proposed development. The Applicant provided further detail for each of the maximum design scenarios for the assessments presented in the main body of the report to enable calculations to be followed and replicated by the Statutory Nature Conservation Bodies (SNCBs). These changes are actioned for both the project alone assessment and the assessment considering Berwick Bank Wind Farm in combination with Seagreen and Seagreen 1A (including the Seagreen 1A Export Cable Corridor).

The Applicant highlighted that the final wind farm layout is still to be determined and will be informed by more detailed geophysical/geotechnical studies, and engineering design work. The MPA assessment has been based on a series of maximum design scenario related to the proportion of infrastructure that could be installed within the MPA. A map showing the indicative wind turbine layout for the largest wind turbine option (which represents the maximum design scenario for long term habitat loss) is included in the MPA assessment Report, but the Applicant would emphasise that this is only an indicative layout.

4.2.1.3 Long term versus permanent terminology

Habitat lost beneath the wind turbines is considered by the stakeholders to be a long term impact. An effect is permanent to most species if it doesn’t resolve within its lifetime. As to effects following decommissioning, the sediments will recover, however, even if structures are removed, the impact would be permanent. There is also no guarantee that they can be removed. Attempts to remove the mattress can result in significant levels of disturbance. As this cannot be predicted, it should be considered on precautionary basis as a permanent footprint. Although long term may be described as not infinite but persevering in the ecological sense, if the impact is temporary, it was advised to be described as ‘disturbance’, whereas for permanent impacts, to be described as ‘loss’.

4.2.1.4 Modelling approach to physical processes

The material is taken from the peak of the sand waves and running them into the troughs in order to perform the simulation modelling. Dredged materials are not relocated off site but along the route and within the Proposed Development array area.

Sand waves

Dynamically active:

The physical processes assessment modelled different scenarios (specific tides, waves & storm events) to examine the potential for change and determined that the physical processes underpinning the marine environment would be maintained with little change after the project was built. This modelling can also be used to indicate sediment transport patterns for particular scenarios, however, the study was not designed or intended to examine the detailed sand wave mobility and longer-term morphology. Sand wave mobility and migration studies usually involve a combination of multiple geophysical surveys (i.e. current and historic) recorded over a reasonably long period, sometimes supplemented with very high resolution computational modelling. Such an assessment would be much more focussed than the comparative modelling implemented within the context of an EIA. However, the baseline modelled scenarios undertaken for the offshore EIA do indicate seabed sediment activity. Similarly, a study of bedform migration undertaken using historic geophysical surveys within the Seagreen 1 development area (Wallingford, 2012) also indicated that seabed sediments are mobile and prone to accretion although the underlying bedforms were stable. Thus, from the limited amount of available data the Applicant suggests that sand wave recovery would be expected to occur gradually over a period of several years. Evidence for other industries and regions suggests that sand based sediments can recover over shorter periods. For example, Newell et al. (2004) reports recovery times of months to one or two years. However, the Applicant's commitment to pre and post construction monitoring will provide important information on this hypothesis both in terms of the recovery of the MPA features but also in terms of providing a more robust dataset relating to the impact of offshore developments in areas of sand waves and seabed features more generally.

Risk of re-exposure of cables:

The Project Design Envelope (PDE) prescribes the provision of cable and scour protection and defines the required cable burial depths to account for coastal recession. The cable installation strategy will be designed to avoid free spanning (i.e. through the derivation of seabed clearance parameters and, armouring). The risk of cable exposure is therefore managed through project design (as with the justification of the scour protection depths/extents etc.). These parameters were precautionary and have been developed based on experience. A full cable burial risk assessment (CBRA) will be developed with the aim of avoiding areas of extensive sand waves where they are present along the offshore export cable route, and if this cannot be achieved, by setting a burial depth that will prevent any de-burial of the cable over the lifetime of the project whilst maintaining the electrical integrity of the cable.

NatureScot and JNCC reiterated that any armouring of the cable through areas of sand waves/megaripples (whether at installation or in response to future re-exposure) could disrupt the hydrodynamics that underpin the ncMPA features. Therefore, the CBRA should not rely solely on armouring as an expected method of cable protection.

4.2.2 Summary Statement of Final Position

The approach to assessment of effects suggested by the Applicant for each effect were undertaken as agreed with the stakeholders as in Table 4.2 Open ▸ with regards to the following agreed points:

the FeAST tool was used, in addition to the Applicant’s proposed approach, for the assessment of the sensitivity of the fish and shellfish ecology receptors; and
further details and clear figures requested in Table 4.2 Open ▸ for the MPA assessment and for the physical processes assessment were provided in the respective chapters

4.3 Approach to EIA and HRA

This section aims to document and agree key topics associated with the realistic maximum design scenarios assessed in relation to the benthic ecology, fish and shellfish ecology and physical processes assessments for Proposed Development offshore EIA and HRA. These include the following:

initial findings of assessment of effects appropriate mitigation and monitoring; and
initial findings of the MPA assessment.
Table 4.3 Open ▸ summarises the points of discussion, areas of agreement and areas of outstanding agreements in relation to the approach to offshore EIA for the Proposed Development.

Table 4.3: Summary of Discussion and Agreed Position on Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Approach to EIA

4.3.1 Additional Details on Key Discussions

4.3.1.1 Boulder and sand waves clearance

The Applicant clarified that boulder and sand waves clearance is more a redistribution. Therefore, with physical processes maintained in the area, sand waves are predicted to recover together with associated sediments and benthic communities. PDE assumes that up to 20% of the offshore export cables and 30% of the inter-array cables will require sand wave clearance, and 20% of all cables that will require boulder clearance. Material is removed during this clearance and deposited along the seabed that will cause temporary habitat loss. The volume of the material to be cleared is assumed to be deposited over an area up to a depth of 0.5 m. This “mound” will likely disperse over time. As engineers are able to refine the final design parameters pre-construction, the habitat loss figures will change. Maximum design scenario assumed a dredging-disposal technique but could create a less intense construction plume with plough dredging. In addition, the deposition of the sand wave clearance material is assessed as temporary habitat loss rather than in the assessment of suspended sediments and sediment deposition because of the scale of the activity/depth of deposition.

4.3.1.2 Maximum design scenario used in the assessment of effects

Temporary habitat disturbance/loss (construction) – benthic ecology:

PDE assumes that up to 20% of the offshore export cables and 30% of the inter-array cables will require sand wave clearance and 20% of all cables that will require boulder clearance;
cable installation: 1,225 km of inter-array cables, 94 km of interconnector and 872 km of offshore export cables (total of 42,948,000 m2);
anchor footprint: 438,200 m2;
jack-up footprint: up to four jack-up locations per wind turbine and OSPs/Offshore convertor station platform; and
the deposition of the sand wave clearance material is assessed as temporary habitat loss rather than in the assessment of suspended sediments and sediment deposition because of the scale of the activity/depth of deposition.

Temporary habitat disturbance/loss (operation and maintenance) – benthic ecology:

cable repair and reburial (inter-array and interconnector 450,000 m2 for repair and 150,000 m2 for reburial) = 720,000 m2;
jack-up footprint (used for all component repairs) = 269,000 m2; and
total = 989,000 m2.

Long term habitat loss – benthic ecology:

cable protection (15% of each cable type) = 5,470,500 m2;
foundations and scour protection (179 wind turbines and ten OSP/Offshore convertor station platform foundations) = 2,265,776 m2; and
total = 7,798,856 m2.

Colonisation of hard structures – benthic ecology:

cable protection (15% of all cables) = 6,442,200 m2;
OSP/Offshore convertor station platform foundations and scour protection (ten OSP/Offshore convertor station platforms foundations, and associated scour protection);
wind turbine foundations and scour protection (307 wind turbine foundations); and
total = 10,198,971 m2.

MPA assessment:

Temporary habitat disturbance/loss:

sand wave and boulder clearance 6,306,405 m2;
assuming clearance occur within a 25 m wide corridor within which the cables are subsequently buried;
sand wave and boulder clearance deposition 13,762,343 m2;
temporary habitat disturbance/loss from the placement of dredged material to a uniform thickness of 0.5 m as a result of sand wave clearance placed on the seabed within the Firth of Forth Banks Complex MPA;
cable installation 4,126,083 m2;
assumes a maximum of 31.33% of the total temporary habitat disturbance/loss from 612.5 km of inter-array cables, and 47 km of substation interconnector cables, as well as 13.08% of the total temporary habitat disturbance/loss from 872 km of offshore export cables, affecting a corridor of up to 15 m width;
jack-up events 397,270 m2;
assumes maximum of 31.33% of total temporary habitat disturbance/loss from jack-up placements within the Proposed Development array area and export cable corridor;
anchoring during cable installation 105,466 m2;
assumes maximum of 31.33% of total temporary habitat disturbance/loss from anchor placement across the Proposed Development array area and Proposed Development export cable corridor; and
total 24,697,555 m2 (equates to 1.32% of the total area of the MPA).

Underwater noise magnitude – fish and shellfish ecology:

installation of up to 179 piled jacket foundations: 1,432 piles;
maximum hammer energy of 4,000 kJ, but realistic max hammer energy 3,000 kJ;
up to 10 hours piling per pile (up to 8 hours for OSPs/Offshore convertor station platforms)
maximum number of days when piling may occur: 372 days;
up to 14 UXO clearances may be required – assumed 5% of detonations will be higher order (due to unsuccessful deflagration), with the remaining detonated by deflagration, or microsited around if possible; and
all other noise sources (e.g. cable installation, foundation drilling etc.) have much smaller injury ranges than predicted for piling operations.

4.3.2 Summary Statement of Final Position

The initial findings for the assessment of effects and the MPA assessment as presented by the Applicant in Table 4.3 Open ▸ were agreed by the stakeholders and maintained with regards to the following agreed points:

sand waves and boulder clearance maintained as temporary habitat disturbance/loss;
monitoring of sand waves recovery in the Firth of Forth Banks Complex MPA;
additional details regarding the workings of the values and for significance of impact from small impact footprint included in the MPA assessment;
impact of EMF on benthic invertebrates included in the MPA assessment;
calculation for determining the maximum design scenario for wind turbine and OSPs/Offshore convertor station platform included in the MPA assessment;
the use of percentage of suitable habitat that would be disturbed or permanently lost to assess the degree of mortality for ocean quahog in the MPA assessment; and
overall belief that conservations objectives of the Firth of Forth Banks Complex MPA are unlikely to be hindered.

5 Areas of Agreement and Outstanding Non-Alignment

Table 5.1 Open ▸ summarises the position following completion of the Road Map process for benthic ecology, fish and shellfish ecology and physical processes at the point of Application submission. This forms the basis of the offshore EIA and HRA assessments presented within the offshore EIA Report and RIAA for the Proposed Development.

Table 5.1: Areas of Agreement and Outstanding Non-Alignment Following Completion of the Road Map Process for Benthic Ecology, Fish and Shellfish Ecology and Physical Processes

6 Conclusion

The aim of the Benthic Ecology, Fish and Shellfish Ecology and Physical Processes Road Map was to ensure that the final consent Application submitted provides MS-LOT and its statutory advisors with sufficient information with which to make a determination. This document has set-out the meetings, agreements and areas of outstanding discussion that have been achieved in relation to the benthic ecology, fish and shellfish ecology and physical processes topics for the offshore EIA, and benthic ecology and fish and shellfish ecology topics for the offshore HRA.

7 References

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[1] By the Conservation of Habitats and Species Amendment (EU Exit) Regulations 2019