19.2 Summary of Cumulative Risk Assessment
To avoid replication of text the cumulative risk assessment (assessment of effects) has been undertaken in volume 2, chapter 13 in line with EIA requirements but does follow the FSA methodology. The following sections however summarise the output of the cumulative risk assessment and any additional mitigation measures required.
Table 19.2 Open ▸ summarises the output of the risk assessment undertaken with consideration of the embedded mitigation measures outlined in section 17. Any additional mitigation measures required above those outlined in section 17 are also summarised.
Table 19.2 Summary of Outputs of Cumulative Risk Assessment
20 Through Life Safety Management
20.1 Quality, Health, Safety and Environment
Quality, Health, Safety and Environment (QHSE) documentation including a Safety Management System (SMS) will be in place for the Project and will be continually updated throughout the development process. The following subsections provide an overview of this documentation and how it will be maintained and reviewed with reference, where required, to specific marine documentation.
Monitoring, reviewing, and auditing will be carried out on all procedures and activities and feedback actively sought. Any designated person (identified in QHSE documentation), managers, and supervisors are to maintain continuous monitoring of all marine operations and determine if all required procedures and processes are being correctly implemented.
20.2 Incident Reporting
After any incidents, including near misses, an incident report form will be completed in line with the Project QHSE documentation. This will then be assessed for relevant outcomes and reviewed for possible changes required to operations.
The Applicant will maintain records of investigation and analyse incidents in order to:
- Determine underlying deficiencies and other factors that may be causing or contributing to the occurrence of incidents;
- Identify the need for corrective action;
- Identify opportunities for preventative action;
- Identify opportunities for continual improvement; and
- Communicate the results of such investigations.
All investigations shall be performed in a timely manner.
A database (lessons learnt) of all marine incidents will be developed. It will include the outcomes of investigations and any resulting actions. The Applicant will promote awareness of their potential occurrence and provide information to assist monitoring, inspection and auditing of documentation.
When appropriate, the designated person (noted within the Emergency Response Cooperation Plan (ERCoP)) should inform the MCA of any exercise or incidents including any implications on emergency response. If required, the MCA should be invited to take part in incident debriefs.
20.3 Review of Documentation
The Applicant will be responsible for reviewing and updating all documentation including the risk assessments, ERCoP, SMS and, if required, will convene a review panel of stakeholders to quantify risk.
Reviews of the risk register should be made after any of the following occurrences:
- Changes to the development, conditions of operation and prior to decommissioning;
- Planned reviews; and
- Following an incident or exercise.
A review of potential risks should be carried out annually. A review of the response charts should be undertaken annually to ensure that response procedures are up to date and should include any amendments from audits, incident reports and identified deficiencies.
20.4 Inspection of Resources
All vessels, facilities, and equipment necessary for marine operations are to be subject to appropriate inspection and testing to determine fitness for purpose and availability in relation to their performance standards. This will include monitoring and inspection of all aids to navigation to determine compliance with the performance standards specified by NLB.
20.5 Audit Performance
Auditing and performance review are the final steps in QHSE management systems. The feedback loop enables an organisation to reinforce, maintain and develop its ability to reduce risks to the fullest extent, and to ensure the continued effectiveness of the system. The Applicant will carry out audits and periodically evaluate the efficiency of the marine safety documentation.
The audits and possible corrective actions should be undertaken in accordance with standard procedures and results of the audits and reviews should be brought to the attention of all personnel having responsibility in the area involved.
20.6 Safety Management System
The Applicant will manage the risk associated with the activities undertaken at the Proposed Development. An integrated SMS, which ensures that the safety and environmental risks of those activities are ALARP, will be established. This includes the use of remote monitoring and switching for aids to navigation to ensure that if a light is faulty a quick fix can be instigated, which will allow IALA availability requirements to be met.
20.7 Cable Monitoring
The subsea cable routes will be subject to periodic inspection post-construction to monitor the cable protection, including burial depths. Maintenance of the protection will be undertaken as necessary.
If exposed cables or ineffective protection measures are identified during post-construction monitoring, these would be promulgated to relevant sea users including via Notice to Mariners and Kingfisher Bulletins. Where immediate risk was observed, the Applicant would also employ additional temporary measures (such as a guard vessel or temporary buoyage) until such time as the risk was permanently mitigated.
Details will be included in full within the assessment of cable burial and protection document, to be produced post-consent.
20.8 Hydrographic Surveys
As required by annex 4 of MGN 654, detailed and accurate hydrographic surveys will be undertaken periodically at intervals agreed with the MCA.
20.9 Decommissioning Plan
A Decommissioning Plan will be developed post consent. With regards to hazards to shipping and navigation, this will also include consideration of the scenario where upon decommissioning and completion of removal operations, an obstruction is left on-site (attributable to the Proposed Development) which is considered to be a danger to navigation and which it has not proved possible to remove. Such an obstruction may require marking until such time as it is either removed or no longer considered a danger to navigation, the continuing cost of which would need to be met by the Applicant.
21 Summary
This NRA has determined the hazards to shipping and navigation users associated with the Project based upon quantitative and qualitative elements including available datasets and consultation. These hazards have been fed into the risk assessment for shipping and navigation within volume 2, chapter 13.
21.1 Consultation
The NRA process has included consultation with stakeholders of relevance to shipping and navigation. This has included consideration of the outputs of the scoping process, direct liaison with key stakeholders (both statutory and non-statutory), outreach to Regular Operators of the area, and two Hazard Workshops. Stakeholders consulted include:
- MCA;
- NLB;
- UK Chamber of Shipping;
- RYA Scotland;
- CA;
- Forth Yacht Clubs Association;
- Evergas;
- HAV Shipping;
- North Star Shipping;
- FMA including representation of SFF;
- RNLI;
- Forth Ports;
- Intrada;
- Regional Inshore Fisheries Group;
- Scottish Whitefish Producers Association;
- FIR for ‘Borders to Cove, ‘Port Seton’, and ‘Montrose and Arbroath’;
- INEOS; and
- Shell.
21.2 Existing Environment
21.2.1 Navigational Features
Key navigational features in the area include the nearby NnG and Seagreen offshore wind farms which are both under construction at the time of writing. The closest port or harbour is Arbroath Harbour, located approximately 23 nm to the north-west, on the Angus coast; however, the major ports in the area in terms of traffic volumes are located within the Firth of Forth. There are 10 charted wrecks located within the Proposed Development array area.
The closest anchorage location to the Proposed Development is the designated anchorage off Dunbar located approximately 3.5 nm to the west of the Skateraw landfall location.
21.2.2 Maritime Incidents
A review of recent incident data from the MAIB and RNLI indicates an average of one to two incidents per year within the Proposed Development array area shipping and navigation study area. The MAIB dataset indicates that incident frequency for the most recent ten years available (2010 to 2019) has decreased over that observed in the previous ten years (2000 to 2009).
21.2.3 Vessel Traffic Movements
Based on the 28 days of vessel traffic data collected via on-site surveys, there was an average of approximately 14 unique vessels per day recorded within the Proposed Development array area shipping and navigation study area. The most common vessel types recorded were cargo vessels, tankers, and commercial fishing vessels.
A total of 14 main commercial routes were identified based on the vessel traffic data studied, with the busiest of these used by one to two vessels a day.
21.3 Future Case Vessel Traffic
Of the 14 main routes identified, it is anticipated that seven will deviate as a result of the Proposed Development array area. The largest percentage increase in terms of overall change in route length was to Routes 5 and 14, with a 0.8% increase. The largest change on an absolute basis was to Route 14, with a 26.0 nm increase; however, this is a transatlantic route, and as such this represented a small change on a relative percentage basis.
21.4 Collision and Allision Risk Modelling
The NRA process included quantitative modelling of the change in allision and collision frequency as a result of the Proposed Development, with consideration given to future cases in terms of potential future traffic increases.
It was estimated that the return period of a vessel being involved in a collision post wind farm was 1,031 years assuming base case traffic levels. This represents a 14% increase in collision frequency compared to the pre wind farm base case result.
The powered allision return period post wind farm was estimated at 6,581 years assuming base case traffic levels. The corresponding drifting allision return period post wind farm was estimated at 12,999 years. The fishing vessel allision return period was estimated at 5.1 years.
21.5 Risk Statement
Based on the findings of the NRA in terms of potential hazards and associated risks, the following hazards listed in Table 18.1 Open ▸ (project in isolation) and Table 19.2 Open ▸ (cumulative) have been assessed in volume 2, chapter 13.
Overall, the risk assessment concluded that there will be no significant risks arising from the Proposed Development in isolation with embedded mitigations in place during the construction, operation and maintenance or decommissioning phases.
The cumulative hazards assessed are as per the assessment of the Proposed Development in isolation and the cumulative risk assessment concluded that there will be no significant cumulative risks arising from the Proposed Development in combination with cumulative developments with embedded mitigations in place during the construction, operation and maintenance or decommissioning phases.
22 References
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Appendix A Marine Guidance Note 654 Checklist
The MGN 654 checklist can be divided into two distinct checklists, one considering the main MGN 654 guidance document and one considering the Methodology for Assessing Marine Navigational Safety and Emergency Response Risks of OREIs (MCA, 2021) which serves as Annex 1 to MGN 654.
The checklist for the main MGN 654 guidance document is presented in Table A.1. Following this, the checklist for the MCA’s methodology annex is presented in Table A.2. For both checklists, references to where the relevant information and/or assessment is provided in the NRA is given.
Table A.1 MGN 654 Checklist for Main Document
Issue | Compliance | Reference and Notes |
|---|---|---|
Site and Installation Co-ordinates. Developers are responsible for ensuring that formally agreed coordinates and subsequent variations of site perimeters and individual OREI structures are made available, on request, to interested parties at relevant project stages, including application for consent, development, array variation, operation and decommissioning. This should be supplied as authoritative GIS data, preferably in Environmental Systems Research Institute (ESRI) format. Metadata should facilitate the identification of the data creator, its date and purpose, and the geodetic datum used. For mariners’ use, appropriate data should also be provided with latitude and longitude coordinates in WGS84 (European Terrestrial Reference System 1989 (ETRS89)) datum. | ||
Traffic Survey. Includes: | ||
All vessel types | | Section 10: Vessel Traffic Movements All vessel types are considered with specific breakdowns by vessel type given for the Proposed Development array area (see section 10.1) and export cable corridor (see section 10.2) shipping and navigation study areas. |
At least 28 days duration, within either 12 or 24 months prior to submission of the ES. | | Section 5.2: Vessel Traffic Data Collection Methodology A total of 28 full days of vessel traffic survey data from July 2020 and January 2021 has been assessed within the Proposed Development array area and export cable corridor shipping and navigation study areas. |
Multiple data sources | | Section 5.2: Vessel Traffic Data Collection Methodology The vessel traffic survey data includes AIS, visual observations and radar for the summer and winter periods in order to ensure maximal coverage of vessels not broadcasting on AIS.
Section 5: Data Sources Additional data sources including the RYA Coastal Atlas, VMS, the long term AIS data and consultations input have also been considered. |
Seasonal variations | | Section 5.2: Vessel Traffic Data Collection Methodology A total of 28 full days of vessel traffic survey data from July 2020 and January 2021 has been assessed within the Proposed Development array area and export cable corridor shipping and navigation study areas.
Section 5: Data Sources Additional long term data sources including VMS and the long term AIS data have also been considered. |
MCA consultation | | Section 4: Consultation The MCA has been consulted as part of the NRA process including through the Hazard Workshop. |
General Lighthouse Authority (GLA) consultation | | Section 4: Consultation NLB has been consulted as part of the NRA process including through the Hazard Workshop. |
UK Chamber of Shipping consultation | | Section 4: Consultation The UK Chamber of Shipping has been consulted as part of the NRA process including through the Hazard Workshop. |
Recreational and fishing vessel consultation | | Section 4: Consultation The RYA, CA and FMA have been consulted as part of the NRA process including through the Hazard Workshop. |
Port and navigation authorities consultation, as appropriate | | Section 4: Consultation Forth Ports has been consulted as part of the NRA process including through the Hazard Workshop. |
Assessment of the cumulative and individual effects of (as appropriate): | ||
i. Proposed OREI site relative to areas used by any type of marine craft. | | Section 10: Vessel Traffic Movements Vessel traffic data in proximity to the Proposed Development has been analysed.
Section 19: Cumulative Risk Assessment The hazards due to the Proposed Development have been identified for each phase. |
ii. Numbers, types and sizes of vessels presently using such areas. | | Section 10: Vessel Traffic Movements Vessel traffic data in proximity to the Proposed Development has been analysed and includes breakdowns of daily vessel count, vessel type and vessel size. |
iii. Non-transit uses of the area, e.g. fishing, day cruising of leisure craft, racing, aggregate dredging, personal watercraft etc. | | Section 7: Navigational Features Section 7.7.3 confirms that there are no marine aggregate dredging areas in the region.
Section 10: Vessel Traffic Movements Non-transit users were identified in the vessel traffic survey data and included fishing vessels engaged in fishing activities. |
iv. Whether these areas contain transit routes used by coastal or deep-draught or international scheduled vessels on passage. | | Section 10: Vessel Traffic Movements Main routes have been identified using the principles set out in MGN 654 in proximity to the Proposed Development array area (see section 11.2), with these routes taking into account coastal, deep-draught and internationally scheduled vessels. |
v. Alignment and proximity of the site relative to adjacent shipping routes. | | Section 7: Navigational Features Section 7.7.1 identifies IMO routeing measures in proximity to the Proposed Development. |
vi. Whether the nearby area contains prescribed routeing schemes or precautionary areas. | | Section 7: Navigational Features Section 7.7.1 identifies IMO routeing measures in proximity to the Proposed Development and sections 7.5 and 7.7 identify precautionary areas such as anchorage military practice and exercise areas and foul and spoil grounds in proximity to the Proposed Development. |
vii. Proximity of the site to areas used for anchorage (charted or uncharted), safe haven, port approaches and pilot boarding or landing areas. | | Section 7: Navigational Features Section 7.4 identifies designated anchorage areas in proximity to the Proposed Development and section 7.2.1 identifies nearby ports. |
viii. Whether the site lies within the jurisdiction of a port and/or navigation authority. | | Section 7: Navigational Features Section 7.2.1 identifies nearby ports and port authority jurisdiction. |
ix. Proximity of the site to existing fishing grounds, or to routes used by fishing vessels to such grounds. | | Section 10: Vessel Traffic Movements Fishing vessel movements are considered within the Proposed Development array area (Section 10.1.2.3) and export cable corridor (Section 10.2.2.2) shipping and navigation study areas. |
x. Proximity of the site to offshore firing/bombing ranges and areas used for any marine military purposes. | | Section 7: Navigational Features Section 7.5 identifies military practice and exercise areas in proximity to the Proposed Development. |
xi. Proximity of the site to existing or proposed submarine cables or pipelines, offshore oil/gas platform, marine aggregate dredging, marine archaeological sites or wrecks, Marine Protected Area or other exploration/exploitation sites. | | Section 7: Navigational Features Section 7.7.6 identifies existing and proposed submarine cables and pipelines in proximity to the Proposed Development, section 7.7.2 identifies oil and gas features in proximity to the Proposed Development, section 7.7.7 identifies marine aggregate dredging areas in proximity to the Proposed Development, section 7.6 identifies charted wrecks in proximity to the Proposed Development and section 7.7.7 identifies MEHRAs in proximity to the Proposed Development. |
xii. Proximity of the site to existing or proposed OREI developments, in cooperation with other relevant developers, within each round of lease awards. | | Section 7: Navigational Features Section 7.1 identifies other offshore wind farm developments in proximity to the Proposed Development. |
xiii. Proximity of the site relative to any designated areas for the disposal of dredging spoil or other disposal grounds. | | Section 7: Navigational Features Section 7.7.4 identifies foul and spoil ground in proximity to the Proposed Development. |
xiv. Proximity of the site to aids to navigation and/or VTS in or adjacent to the area and any impact thereon. | | Section 7: Navigational Features Section 7.3 identifies aids to navigation in proximity to the Proposed Development. |
xv. Researched opinion using computer simulation techniques with respect to the displacement of traffic and, in particular, the creation of “choke points” in areas of high traffic density and nearby or consented OREI sites not yet constructed. | | Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area. |
xvi. With reference to xv. above, the number and type of incidents to vessels which have taken place in or near to the proposed site of the OREI to assess the likelihood of such events in the future and the potential impact of such a situation. | | Section 9: Emergency Response Historical vessel incident data published by the MAIB (section 9.5), RNLI (section 9.2) and DfT (section 9.1) in proximity to Proposed Development has been considered alongside historical offshore wind farm incident data throughout the UK (section 9.6). |
xvii. Proximity of the site to areas used for recreation which depend on specific features of the area. | | Section 10: Vessel Traffic Movements Non-transit users were identified in the vessel traffic survey data and included limited recreational activity. |
Predicted effect of OREI on traffic and interactive boundaries. Where appropriate, the following should be determined: | ||
a. The safe distance between a shipping route and OREI boundaries. | | Section 15: Future Case Vessel Traffic A methodology for post wind farm routeing is outlined and includes a minimum distance of 1 nm from offshore installations and wind turbine boundaries. |
b. The width of a corridor between sites or OREIs to allow safe passage of shipping. | | Section 19: Cumulative Risk Assessment Section 19.1 provides a justification for the gap between the Proposed Development array area and Inch Cape to ensure its presence does not result in a significant risk to navigational safety. |
OREI structures. The following should be determined: | ||
a. Whether any feature of the OREI, including auxiliary platforms outside the main generator site, mooring and anchoring systems, inter-device and export cabling could pose any type of difficulty or danger to vessels underway, performing normal operations, including fishing anchoring and emergency response. | | Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area.
Section 18: Project in Isolation Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13, including hazards involving anchoring and emergency response. |
b. Clearances of fixed or floating wind turbine blades above the sea surface are not less than 22 m (above MHWS for fixed). Floating wind turbines allow for degrees of motion. | | Section 17: Embedded Mitigation Measures The minimum blade tip height is included in the maximum design scenario for wind turbines (see Table 18.1 Open ▸ ). |
c. Underwater devices: i. Changes to charted depth; ii. Maximum height above seabed; and iii. Under keel clearance. | | Section 6.6: Maximum Design Scenario Inter-array, interconnector and offshore export cables specifications are included in the maximum design scenario for cables (see Table 6.6 Open ▸ ). |
d. Whether structure block or hinder the view of other vessels or other navigational features. | | Section 13: Navigation, Communication and Position Fixing Equipment Hazards relating to the use of existing aids to navigation are considered (see section 0).
Section 19: Cumulative Risk Assessment Risks to non-transit users on vessels navigating through the gap between the Proposed Development array area and Inch Cape (and the detection of such vessels) has been considered (see section 19.1). |
The effects of tides, tidal streams and weather. It should be determined whether: | ||
a. Current maritime traffic flows and operations in the general area are affected by the depth of water in which the proposed installation is situated at various states of the tide, i.e. whether the installation could pose problems at high water which do not exist at low water conditions, and vice versa. | | Section 6.6: Maximum Design Scenario The range of water depths within the Proposed Development array area is provided in the maximum design scenario for the Proposed Development boundary (see Table 6.6 Open ▸ ).
Section 8: Meteorological Ocean Data Various states of the tide local to the Proposed Development are provided.
Section 10: Vessel Traffic Movements Vessel traffic data in proximity to the Proposed Development has been analysed.
Section 16: Collision and Allision Risk Modelling Collision and allision risk models take into account tidal conditions. |
b. The set and rate of the tidal stream, at any state of the tide, has a significant effect on vessels in the area of the OREI site. | | Section 8: Meteorological Ocean Data Various states of the tide local to the Proposed Development are provided.
Section 16: Collision and Allision Risk Modelling The collision and allision risk models take into account tidal conditions. |
c. The maximum rate tidal stream runs parallel to the major axis of the proposed site layout, and, if so, its effect. | | |
d. The set is across the major axis of the layout at any time, and, if so, at what rate. | | |
e. In general, whether engine failure or other circumstance could cause vessels to be set into danger by the tidal stream, including unpowered vessels and small, low speed craft. | | Section 8: Meteorological Ocean Data Various states of the tide local to the Proposed Development are provided and it is noted that hazards are not anticipated at high or low water only.
Section 16: Collision and Allision Risk Modelling The drifting allision risk model takes into account tidal conditions and assesses whether machinery failure could cause vessels to be set into danger. |
f. The structures themselves could cause changes in the set and rate of the tidal stream. | | Section 8: Meteorological Ocean Data No risks are anticipated. |
g. The structures in the tidal stream could be such as to produce siltation, deposition of sediment or scouring, affecting navigable water depths in the wind farm area or adjacent to the area. | | Section 19: Cumulative Risk Assessment Identifies the hazards due to the Proposed Development on shipping and navigation for each phase including in relation to changes in under keel clearance. |
h. The site, in normal, bad weather, or restricted visibility conditions, could present difficulties or dangers to craft, including sailing vessels, which might pass in close proximity to it. | | Section 8: Meteorological Ocean Data Weather and visibility data local to the Proposed Development is provided.
Section 10: Vessel Traffic Movements Vessel traffic data in proximity to the Proposed Development has been analysed including recreational vessels.
Section 11: Adverse Weather Vessel Traffic Movements Alternative routeing used by Regular Operators during periods of adverse weather have been identified.
Section 19: Cumulative Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13 which is summarised in section 18. |
i. The structures could create problems in the area for vessels under sail, such as wind masking, turbulence or sheer. | | Section 19: Cumulative Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13. |
j. In general, taking into account the prevailing winds for the area, whether engine failure or other circumstances could cause vessels to drift into danger, particularly if in conjunction with a tidal set such as referred to above. | | Section 16: Collision and Allision Risk Modelling The drifting allision risk model takes into account weather and tidal conditions and assesses whether machinery failure could cause vessels to be set into danger. |
Assessment of access to and navigation within, or close to, an OREI. To determine the extent to which navigation would be feasible within the OREI site itself by assessing whether: | ||
a. Navigation within or close to the site would be safe: | ||
i. For all vessels. | | Section 4: Consultation Section 4.2 outlines Regular Operator consultation undertaken following the vessel traffic surveys.
Section 11: Adverse Weather Vessel Traffic Movements Alternative routeing used by Regular Operators during periods of adverse weather have been identified.
Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area and includes use of post wind farm routeing, as well as taking account of tidal and weather conditions.
Section 19: Cumulative Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13. |
ii. For specified vessel types, operations and/or sizes. | | |
iii. In all directions or areas. | | |
iv. In specified directions or areas. | | |
v. In specified tidal, weather or other conditions. | | |
b. Navigation in and/or near the site should be prohibited or restricted: | ||
i. For specified vessel types, operations and/or sizes. | | Section 13: Navigation, Communication and Position Fixing Equipment Potential hazards on navigation of the different communications and position fixing devices used in and around offshore wind farms are assessed.
Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area and includes use of post wind farm routeing which assumes commercial vessel traffic avoids the Proposed Development array area.
Section 19: Cumulative Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13.
Section 17: Embedded Mitigation Measures Outlines the embedded mitigation measures to be implemented to reduce the significance of risk of shipping and navigation hazards including the application for Safety Zones. |
ii. In respect of specific activities. | | |
iii. In all areas or directions. | | |
iv. Prohibited in specified areas or directions. | | |
v. In specified tidal or whether conditions. | | |
c. Where it is not feasible for vessels to access or navigate through the site it could cause navigational, safety or routeing problems for vessels operating in the area e.g. by preventing vessels from responding to calls for assistance from persons in distress. | | Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area and includes use of post wind farm routeing which assumes commercial vessel traffic avoids the array.
Section 19: Cumulative Risk Assessment Based upon the baseline data and consultation undertaken hazards have been identified and fed into the risk assessment undertaken in volume 2, chapter 13. |
d. Guidance on the calculation of safe distance of OREI boundaries from shipping routes has been considered. | | Section 15: Future Case Vessel Traffic The methodology applied when considering the safe distance at which main routes should be deviated around offshore installations has been described and includes consideration of the Shipping Route Template (see section 15.5.1). |
SAR, maritime assistance service, counter pollution and salvage incident response. | ||
The MCA, through HM Coastguard, is required to provide SAR and emergency response within the sea area occupied by all OREIs in UK waters. To ensure that such operations can be safely and effectively conducted, certain requirements must be met by developers and operators. | ||
a. An ERCoP will be developed for the construction, operation and decommissioning phases of the OREI. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including compliance with MGN 654, which requires the creation of an ERCoP. |
b. The MCA’s guidance document Offshore Renewable Energy Installations: Requirements, Guidance and Operational Considerations for Search and Rescue and Emergency Response (MCA, 2021) for the design, equipment and operation requirements will be followed. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including compliance with MGN 654, which requires the fulfilment of requirements in the stated guidance document. |
c. A SAR checklist will be completed to record discussions regarding the requirements, recommendations and considerations outlined in Annex 5 (to be agreed with MCA). | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including compliance with MGN 654, which expects the SAR checklist to be completed. |
Hydrography. In order to establish a baseline, confirm the safe navigable depth, monitor seabed mobility and to identify underwater hazards, detailed and accurate hydrographic surveys are included or acknowledged for the following stages and to MCA specifications: | ||
i. Pre-construction: The proposed generating assets area and proposed cable route. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including compliance with MGN 654, which requires the specified hydrographic surveys to be completed. |
ii. On a pre-established periodicity during the life of the development. | | |
iii. Post construction: Cable route(s). | | |
iv. Post decommissioning of all or part of the development: the installed generating assets area and cable route. | | |
Communications, Radar and positioning systems. To provide researched opinion of a generic and, where appropriate, site specific nature concerning whether: | ||
a. The structures could produce radio interference such as shadowing, reflections or phase changes, and emissions with respect to any frequencies used for marine positioning, navigation and timing (PNT) or communications, including GMDSS and AIS, whether ship borne ashore or fitted to any of the proposed structures, to: | ||
i. Vessels operating at a safe navigational distance. | | Section 13: Navigation, Communication and Position Fixing Equipment Potential hazards on navigation of the different communications and position fixing devices used in and around offshore wind farms are assessed. |
ii. Vessels by the nature of their work necessarily operating at less than the safe navigational distance to the OREI, e.g. support vessels, survey vessels, SAR assets. | | |
iii. Vessels by the nature of their work necessarily operating within the OREI. | | |
b. The structures could produce radar reflections, blind spots, shadow areas or other adverse effects: | ||
i. Vessel to vessel | | Section 13: Navigation, Communication and Position Fixing Equipment Potential hazards on navigation of the different communications and position fixing devices used in and around offshore wind farms are assessed. |
ii. Vessel to shore | | |
iii. VTS radar to vessel | | |
iv. Racon to/from vessel | | |
c. The structures and generators might produce SONAR interference affecting fishing, industrial or military systems used in the area. | | Section 13: Navigation, Communication and Position Fixing Equipment Section 13.9 assesses the potential risk of SONAR interference due to the Proposed Development. |
d. The site might produce acoustic noise which could mask prescribed sound signals. | | Section 13: Navigation, Communication and Position Fixing Equipment Section 13.10 assesses the potential risk of noise due to the Proposed Development. |
e. Generators and the seabed cabling within the site onshore might produce EMFs affecting compasses and other navigation systems. | | Section 13: Navigation, Communication and Position Fixing Equipment Section 13.6 assesses the potential risk of electromagnetic interference due to the Proposed Development. |
Risk mitigation measures recommended for OREI during construction, operation and decommissioning. | ||
Mitigation and safety measures will be applied to the OREI development appropriate to the level and type of risk determined during the EIA. The specific measures to be employed will be selected in consultation with the MCA and will be listed in the developer’s ES. These will be consistent with international standards contained in, for example, Chapter V of SOLAS (IMO, 1974), and could include any or all of the following: | ||
i. Promulgation of information and warnings through notices to mariners and other appropriate MSI dissemination methods. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including the promulgation of information. |
ii. Continuous watch by multi-channel VHF, including DSC. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including marine coordination. |
iii. Safety Zones of appropriate configuration, extent and application to specified vessels[14]. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including use of Safety Zones. |
iv. Designation of the site as an area to be avoided (ATBA) | | Section 6: Project Design Envelope Relevant to Shipping and Navigation It is not planned to designate the Proposed Development array area as an ATBA (see section 6.1.1). |
v. Provision of aids to navigation as determined by the GLA. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including the provision of aids to navigation in accordance with Trinity House and MCA requirements. |
vi. Implementation of routeing measures within or near to the development. | | It is not planned to implement any new routeing measures within or near to the Proposed Development. |
vii. Monitoring by radar, AIS, Closed Circuit Television (CCTV) or other agreed means. | | Section 17: Embedded Mitigation Measures As required under MGN 654 (MCA, 2021) the Project will agree suitable site mitigation with the MCA. |
viii. Appropriate means for OREI operators to notify, and provide evidence of, the infringement of Safety Zones. | | Means for notifying and providing evidence of the infringement of Safety Zones will be provided in the Safety Zone Application, submitted post consent. |
ix. Creation of an ERCoP with the MCA’s SAR branch for the construction phase onwards. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including compliance with MGN 654, which requires the creation of an ERCoP. |
x. Use of guard vessels, where appropriate. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including the use of guard vessels. |
xi. Update NRAs every two years, e.g. at testing sites. | | Not applicable to the Proposed Development. |
xii. Device-specific or array-specific NRAs. | | Section 6.6: Maximum Design Scenario All offshore elements of the Proposed Development have been considered in this NRA including array area and export cable corridor (surface and subsea) infrastructure.
Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17 including a Cable Specification and Installation Plan undertaken prior to construction which will serve as additional assessment relating to shipping and navigation. |
xiii. Design of OREI structures to minimise risk to contacting vessels or craft. | | There is no additional risk posed to craft compared to previous offshore wind farms and so no additional measures are identified. |
xiv. Any other measures and procedures considered appropriate in consultation with other stakeholders. | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17. |
Table A.2 MGN 654 Annex 1 checklist
Item | Compliance | Comments |
|---|---|---|
A risk claim is included that is supported by a reasoned argument and evidence. | | The risk assessment undertaken in volume 2, chapter 13 provides a risk claim for a range of hazards identified in this NRA which is based on a number of inputs including (but not limited to) baseline data, expert opinion, outputs of the Hazard Workshop, stakeholder concerns and lessons learnt from existing offshore developments. |
Description of the marine environment. | | Section 7: Navigational Features Relevant navigational features in proximity to the Proposed Development have been described including (but not limited to) other offshore wind farm developments, oil and gas features, aids to navigation, submarine cables and pipelines, charted wrecks, IMO routeing measures, ports and MEHRAs.
Section 14: Cumulative and Transboundary Overview Potential future developments have been screened in to the cumulative risk assessment where a cumulative or in combination activity has been identified based upon the location and distance from the Proposed Development, including consideration of other offshore wind farms, oil and gas infrastructure and carbon capture infrastructure (surface piercing). Potential future developments have also been screened into the cumulative risk assessment where a concern has been raised during consultation. |
SAR overview and assessment. | | Section 9: Emergency Response Existing SAR resources in the outer Firth of Forth are summarised including the UK SAR operations contract, RNLI stations and assets and HMCG stations. The risk assessment undertaken in volume 2, chapter 13 includes an assessment of how activities associated with the Proposed Development may restrict emergency response capability of existing resources. |
Description of the OREI development and how it changes the marine environment. | | Section 6.6: Maximum Design Scenario The maximum extent of the Proposed Development for which any shipping and navigation hazards are assessed is provided including a description of the development boundaries, array area and export cable corridor infrastructure, construction phase programme and indicative vessel and helicopter numbers during the construction and operation and maintenance phases.
Section 15: Future Case Vessel Traffic Worst-case alternative routeing for commercial traffic has been considered. |
Analysis of the vessel traffic, including base case and future traffic densities and types. | | Section 10: Vessel Traffic Movements Vessel traffic data in proximity to the Proposed Development has been analysed.
Section 15: Future Case Vessel Traffic Future vessel traffic levels have been considered, broken down as increases in traffic associated with ports, commercial fishing vessel activity, recreational vessel activity and traffic associated with the Proposed Development operations. Additionally, worst case alternative routeing for commercial traffic has been considered. |
Status of the hazard log:
| | Section 3: Navigational Risk Assessment Methodology A tolerability matrix has been defined to determine the tolerability/significance of risks (see section 3.2.1).
Appendix B: Hazard Log The complete hazard log is presented and includes a description of the hazards considered, possible causes, consequences (most likely and worst case) and relevant embedded mitigation measures. Using this information, each hazard is then ranked in terms of frequency of occurrence and severity of consequence to give a tolerability/significance level. |
NRA:
| | Section 2: Guidance and Legislation MGN 654 and the IMO’s FSA guidelines are the primary guidance documents used during the assessment with MGN 372 also used.
Section 16: Collision and Allision Risk Modelling Collision and allision risk modelling has been undertaken for the Proposed Development array area with the results outlined numerically and graphically (where appropriate). |
Risk control log | | Section 17: Embedded Mitigation Measures Embedded mitigation measures have been proposed and are summarised in section 17. The risk assessment undertaken in volume 2, chapter 13 outlines the relevant embedded mitigation measures for each risk assessed. |