Anatec was commissioned by SSE Renewables Developments (UK) Limited (“SSE Renewables” (SSER)) to undertake a Navigational Risk Assessment (NRA) for the proposed Berwick Bank Wind Farm (hereafter the ‘Project’). The NRA has been undertaken with respect to the offshore components of the Project (hereafter, the ‘Proposed Development’) comprising the Proposed Development array area and the Proposed Development export cable corridor. This NRA presents information on the Proposed Development relative to the existing and estimated future navigational activity and forms an annex to volume 2, chapter 13 of the offshore Environmental Impact Assessment (EIA) Report.
2 Guidance and Legislation
As part of the EIA Directive (2011/92/European Union (EU), as amended by Directive 2014/52/EU) (which remains applicable following EU Exit), an EIA Report is required to support the application for the Section 36 consent for the Project. The MCA require that, as part of the EIA Report, an NRA is undertaken to “inform the shipping and navigation chapter of the EIA Report” (MCA, 2021).
2.2 Primary Guidance
The primary guidance documents used during the assessment are the following:
- 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); and
- Revised Guidelines for FSA for Use in the Rule-Making Process (International Maritime Organization (IMO), 2018).
MGN 654 highlights issues that shall be considered when assessing the potential effect on navigational safety from offshore renewable energy developments proposed in United Kingdom (UK) internal waters, territorial sea or Renewable Energy Zones (REZ).
MGN 654 includes several annexes including the Methodology for Assessing the Marine Navigational Safety & Emergency Response Risks of Offshore Renewable Energy Installations (OREI) which the MCA require to be used as a template for preparing NRAs. The methodology is centred on risk management and requires a submission that shows that sufficient controls are, or will be, in place for the assessed risk to be judged as broadly acceptable or tolerable with mitigation (see section 3.2). In both volume 2, chapter 13 and the NRA, the base and future case levels of risk have been identified as well as the mitigation measures required to ensure the future case remains broadly acceptable, or tolerable with mitigation.
2.3 Other Guidance
Other guidance documents used during the assessment include:
- 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) Recommendation O-139 on The Marking of Man-Made Offshore Structures (IALA, 2021 (a));
- IALA Guidance G1162 The Marking of Offshore Man-Made Structures (IALA, 2021 (b)); and
- The Royal Yachting Association’s (RYA) Position on Offshore Renewable Energy Developments: Paper 1 (of 4) – Wind Energy (RYA, 2019).
2.4 Lessons Learnt
There is considerable benefit for the Applicant in the sharing of lessons learnt within the offshore industry. The NRA, and in particular the risk assessment undertaken in volume 2, chapter 13, includes general consideration for lessons learnt and expert opinion from previous offshore wind farm developments and other sea users, capitalising upon the UK’s position as a leading generator of offshore wind power.
Data sources for lessons learnt include the following:
- Sharing the Wind – Recreational Boating in the Offshore Wind Strategic Areas (RYA and CA, 2004);
- Results of the Electromagnetic Investigations (MCA and QinetiQ, 2004);
- Offshore Wind Farm Helicopter Search and Rescue Trials Undertaken at the North Hoyle Wind Farm (MCA, 2005);
- Interference to Radar Imagery from Offshore Wind Farms (Port of London Authority (PLA),2005);
- Navigational Risk Assessment Phase 1 Offshore Wind Farms Project Alpha and Project Bravo (Anatec, 2012);
- Regional Cumulative Shipping and Navigational Review – Outer Firth of Forth and Tay Wind Farm Developments (Anatec, 2012);
- Strategic Assessment of Impacts on Navigation of Shipping and Related Effects on Other Marine Activities Arising from the Development of Offshore Wind Farms in the UK Renewable Energy Zone (REZ) (Anatec and The Crown Estate (TCE), 2012);
- Offshore Wind and Marine Energy Health and Safety Guidelines (RenewableUK, 2014);
- Influence of UK Offshore Wind Farm Installation on Commercial Vessel Navigation: A Review of Evidence (Anatec, 2016);
- Navigational Risk Assessment Addendum (Appendix 12A) (Anatec, 2018); and
- G+ Global Offshore Wind Health & Safety Organisation 2020 Incident Data Report (G+, 2021).
3.1 Formal Safety Assessment Methodology
A shipping and navigation user can only be affected by a hazard if there is a pathway through which a hazard can be transmitted between the source activity (cause) and the user. In cases where a user is exposed to a hazard, the overall severity of consequence to the user is determined. This process incorporates a degree of subjectivity. The assessments presented herein for shipping and navigation users have considered the following criteria:
- Baseline data and assessment;
- Expert opinion;
- Outputs of the Hazard Workshop;
- Level of stakeholder concern;
- Time and/or distance of any deviation;
- Number of transits of specific vessel and/or vessel type; and
- Lessons learnt from existing offshore developments.
With regards to commercial fishing vessels, the methodology and assessment considers hazards to commercial fishing vessels in transit. A separate methodology and assessment have been applied in volume 2, chapter 12 to consider hazards to commercial fishing vessels related to commercial fishing activity (rather than commercial fishing vessels in transit).
3.2 Formal Safety Assessment Process
The IMO Formal Safety Assessment (FSA) process (IMO, 2018) (the FSA process) as approved by the IMO in 2018 under Maritime Safety Committee (MSC) – Marine Environment Protection Committee (MEPC).2/circ. 12/Rev.2 has been applied to the risk assessment in volume 2, chapter 13 and is considered in this NRA.
The FSA process is a structured and systematic methodology based upon risk analysis and Cost Benefit Analysis (CBA) (if applicable) to reduce risks to As Low as Reasonably Practicable (ALARP). There are five basic steps within this process as illustrated in Figure 3.1 Open ▸ and summarised in the following list:
- Step 1 – identification of hazards (a list is produced of hazards prioritised by risk level specific to the problem under review);
- Step 2 – risk analysis (investigation of the causes and initiating events and consequences of the more important hazards identified in Step 1);
- Step 3 – risk control options (identification of measures to control and reduce the identified hazards);
- Step 4 – CBA (identification and comparison of the benefits and costs associated with the risk control options identified in Step 3); and
- Step 5 – recommendations for decision-making (defining of recommendations based upon the outputs of Steps 1 to 4).
A key tool used when undertaking an NRA is the Hazard Workshop which ensures that all risks are identified and qualified in agreement with relevant consultees prior to assessment within the Offshore EIA Report. Risks (and the determined qualification) are recorded via the hazard log which is presented in full in Appendix B.
Table 3.1 Open ▸ and Table 3.2 identify how the severity of consequence and the frequency of occurrence has been defined within the hazard log, respectively.
An aggregate of the severity of consequence (Table 3.1) and frequency of occurrence (Table 3.2) provide the level of risk for each hazard; the method for undertaking this aggregation is through use of a tolerability matrix, as presented in Table 3.3 Open ▸ . The risk of a hazard is defined as Broadly Acceptable (low risk), Tolerable (intermediate risk), or Unacceptable (high risk).
Once identified, the risk of a hazard is assessed to ensure it is ALARP. Further risk control measures may be required to further mitigate a hazard in accordance with the ALARP principle. Unacceptable risks are not considered to be ALARP.
Outputs of the hazard log have been used as evidence to support and refine the assessment undertaken in volume 2, chapter 13.
3.3 Cumulative Risk Assessment Methodology
The hazards identified in the FSA are also assessed for cumulative risks with other projects and proposed developments within the cumulative risk assessment. Given the varying type, status and location of developments, different scenarios have been considered in the cumulative risk assessment, which allocates developments into the scenarios depending upon the following criterion:
- Development status;
- Distance from the Proposed Development;
- Level of interaction with baseline traffic relevant to the Proposed Development;
- Level of concern raised during consultation; and
- Data confidence.
The scenarios and associated level of assessment undertaken for each, are summarised in Table 3.4 Open ▸ . Given the level of interest during consultation in the cumulative scenario, a detailed qualitative and quantitative (where applicable) approach to the cumulative risk assessment has been applied for each scenarios.
The maximum distance within which developments are considered for the cumulative risk assessment is 50 nm from the Proposed Development array area on the basis that there is not considered to be a direct pathway between the Proposed Development and any development beyond 50 nm from the Proposed Development array area. This distance is standard within NRAs and provides a good overview of cumulative traffic patterns.
An aggregate of the criterion can determine the relevant scenario(s) for each development. For example, if a development is located within 50 nm of the Proposed Development array area but does not impact a main commercial route passing within 1 nm of the Proposed Development array area and has low data confidence it may still be screened out of the cumulative risk assessment.
For offshore wind farms and in the context of shipping and navigation, the term ‘under construction’ indicates that offshore construction was ongoing at the time of the baseline being established and a buoyed construction area is present. The term ‘pre-construction’ indicates that a development has been consented and has a Contract for Difference (CfD) secured. The term ‘consented’ indicates that a development has been consented but does not have a CfD secured.
Projects meeting the assessment criteria are detailed in section 14.1.
3.4 Study Areas
3.4.1 Proposed Development Array Area
A 10 nm buffer has been applied around the Proposed Development array area (hereafter the ‘Proposed Development array area shipping and navigation study area’) as shown in Figure 3.2 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 UK offshore wind farm NRAs and is suitable for collection of radar data.
3.4.2 Proposed Development Export Cable Corridor
A 2 nm buffer has been applied around the Proposed Development export cable corridor (hereafter the ‘Proposed Development export cable corridor shipping and navigation study area’) as shown in Figure 3.2 Open ▸ . As with the Proposed Development array area shipping and navigation study area, this study area has been defined to capture relevant users and their movements within, and near, the Proposed Development export cable corridor. The Proposed Development export cable corridor shipping and navigation study area covers the area between the Mean Low Water Springs (MLWS) – marked on Figure 3.2 Open ▸ – and the boundary of the Proposed Development array area.
4.2 Consultation Responses
Various responses have been received from stakeholders during consultation undertaken in the NRA process including during the Hazard Workshop, other consultation meetings, via email correspondence and through the Scoping Opinion for the 2020 Berwick Bank (Marine Scotland – Licensing Operations Team (MS-LOT), 2021). The key points and where they have been addressed in the NRA or volume 2, chapter 13 are summarised in Table 4.1 Open ▸ .
4.3 Hazard Workshops
A key element of the consultation undertaken was the Hazard Workshops, meetings of local and national marine stakeholders to identify and discuss potential shipping and navigation hazards. Using the information gathered from the first Hazard Workshop, a hazard log was produced to be used as input into the risk assessment undertaken in volume 2, chapter 13. Using the information gathered from the second Hazard Workshop – following changes to the extent of the Proposed Development array area – the hazard log was updated.
This ensured that expert opinion and local knowledge was incorporated into the hazard identification process and that the hazard log was site-specific.
The first Hazard Workshop was held via teleconferencing (due to restrictions incurred by the COVID-19 pandemic) on 28 September 2021 and was attended by all of the organisations listed below:
- UK Chamber of Shipping;
- RYA Scotland;
- FMA including representation of SFF;
- Forth Ports;
- INEOS; and
Other Regular Operators were also given the opportunity to attend the first Hazard Workshop.
The second Hazard Workshop was held via teleconferencing on 27 July 2022 and was attended by all of the organisations listed below:
- UK Chamber of Shipping;
- RYA Scotland;
- FMA including representation of SFF;
- Forth Ports;
- Scottish Whitefish Producers Association;
- FIR for ‘Eyemouth to Cove’, ‘Port Seton’, and ‘Montrose and Arbroath’; and
- Royal Northumberland Yacht Club.
4.3.2 Hazard Workshop Process and Hazard Log
During the Hazard Workshops, key maritime hazards associated with the construction, operation and maintenance and decommissioning of the Proposed Development were identified and discussed. Where appropriate, hazards were considered by vessel type to ensure risk control options could be identified on a type-specific basis.
Following the first Hazard Workshop, the risks associated with the identified hazards were ranked in the hazard log based upon the discussions held during the workshop. Where appropriate, mitigation measures were identified, including any additional measures required to reduce the risks to ALARP. The hazard log was then provided to the Hazard Workshop attendees for comment.
Following the second Hazard Workshop, the hazard log was updated based on reconsideration of the previously identified hazards and associated risks during the workshop. The hazard log was again provided to the Hazard Workshop attendees for comment and their feedback incorporated into the NRA.
The hazard log has been used to inform the risk assessment undertaken in volume 2, chapter 13 and is presented in full in Appendix B.