1. Introduction

1.1. Background

The Invasive Non-Native Species Management Plan (INNSMP) has been prepared by RPS on behalf of Berwick Bank Wind Farm Limited (BBWFL), a wholly subsidiary of SSE Renewables (SSER) Limited, henceforth referred to as the Applicant to support the offshore Environmental Impact Assessment (EIA) Report for the Berwick Bank Wind Farm offshore infrastructure (hereafter referred to as ‘Proposed Development’).
This INNSMP has been developed taking into account feedback provided from consultees as part of the Scoping Opinion, where it was highlighted that management plans should be “adequate” to be used as mitigation measures where they are key to reducing impact. Table 1.1 Open ▸ provides a summary of the issues raised by stakeholders in relation to INNS.

Table 1.1: Issues Raised by Consultees in Relation to INNS

This plan will be updated and finalised before the start of construction following development of the final project design and in consultation with regulatory bodies and stakeholders such as MS-LOT, MSS, NatureScot and Scottish Environment Protection Agency (SEPA) on specific requirements for Invasive Non-Native Species (INNS) management measures.
The plan will be further updated prior to the commencement of the operation and maintenance and decommissioning phases.

1.2. Purpose of this Invasive Non-Native Species Management Plan

The legislation and guidance relating to INNS at a European Union (EU) and United Kingdom (UK) level include the following:

EU Regulation 11/43/2014 on the prevention and management of the introduction and spread of invasive alien species;
The Wildlife and Countryside Act 1981;
International Conversion for the Control and Management of Ships’ Ballast Water and Sediments (adopted in 2004););
The Merchant Shipping (Anti-Fouling Systems) Regulations 2009;
Resolution MEPC.207(62) 2011 Guidelines for the Control and Management of Ships Biofouling to Minimize the Transfer of Invasive Aquatic Species;
The Invasive Non-Native Species (Amendment etc.) (EU Exit) Regulations 2019;
The Animal Welfare and Invasive Non-Native Species (Amendment etc.) (EU Exit) Regulations 2020; and
Marine Biosecurity Planning. Guidance for Producing Site and Operation-based Plans for Preventing the Introduction of Non-Native Species (Payne et al., 2014).
1. In Scotland, INNS are covered by Section 14 of the Wildlife and Countryside Act 1981. This regulation was amended in 2012 when the INNS section of the Wildlife and Natural Environment (Scotland) Act 2011 came into force.
2. In 2012, the Scottish Government published the Code of Practice on Non-Native Species (Scottish Government, 2012), which sets out a framework of responsibilities for bodies with powers relating to INNS. The Code provides practical guidance on how Developers should act responsibly and within the law to ensure that INNS do not cause harm to the marine environment. This Code focuses on a three-tiered approach, including prevention, rapid response and control and containment.
3. Furthermore, Scottish Government (2020), which aims to protect and restore biodiversity, supporting healthier ecosystems, recognises INNS as a “significant threat to our marine biodiversity and industries such as aquaculture”. It also highlights the need to “implement a rapid-response framework to prevent colonisation of new invasive species in Scotland’s seas and islands“, as they represent a significant threat to marine biodiversity (Scottish Government, 2020).
4. The purpose of this INNSMP is to provide guidance for all activities relating to the marine environment (seaward of Mean High Water Springs (MHWS). This INNSMP will be followed during all phases of the Proposed Development (construction, operation and maintenance and decommissioning) and during vessel operations, to prevent and/or reduce the risk of introducing and/or spreading INNS into the waters of the Proposed Development. To do this, the methodology described in Payne et al. (2014) has been followed.
5. The Great Britain Invasive Non-Native Species Strategy (HM Government, 2015) describes the following tiered approach to managing INNS:
prevention;
early detections, surveillance, monitoring and rapid response; and
long term management and control.
1. HM Government (2015) places a strong emphasis on prevention, thus this INNSMP focuses on providing tools to aid prevention of introducing and/or spreading INNS.
2. This INNSMP is a ‘live’ document which will be finalised prior to construction of the Proposed Development and then further updated throughout the lifetime of the Proposed Development as described in section 5.7.2.

1.3. Document Structure

This INNSMP has the following structure:

section 2 – Project background and consents;
section 3 – Roles and Responsibilities
section 4 – INNSMP methodology;
section 5 – Proposed Development INNSMP; and
section 6 – Useful sources of information.

2. Project Background and Consents

2.1. Project Characteristics

The Proposed Development is an offshore wind farm located in the outer Firth of Forth and Firth of Tay, approximately 37.8 km east of the Scottish Borders coastline (St. Abb’s Head) and 47.6 km to the East Lothian coastline (see Figure 2.1 Open ▸ ).
The Proposed Development parameters have been selected from the Project Design Envelope (PDE) as assessed in the Offshore EIA Report. The Proposed Development will consist of the following:

up to 307 wind turbine foundations (piled/suction caisson jackets) attached to the seabed, plus ancillary equipment such as J-tubes;
up to 307 wind turbines;
up to ten Offshore Substation Platforms (OSPs)/Offshore convertor station platforms and associated foundations (piled/suction caisson jackets) attached to the seabed, plus ancillary equipment such as J-tubes;
up to ten OSPs/Offshore convertor station platforms topsides housing electrical infrastructure (for the purpose of this report, the term OSP/Offshore convertor station platform is used to refer collectively to the platform structure and the topside equipment);
a network of inter-array cabling and interconnector cabling between the ten OSPs/Offshore convertor station platforms;
up to eight offshore export cables utilising the consented Proposed Development export cable corridor; and
scour protection and cable protection.
1. The wind turbines will be connected to each other by a network of inter-array cables, also connecting into the OSPs/Offshore convertor station platforms. The offshore export cables will transfer the electricity from the OSPs/Offshore convertor station platforms to the Skateraw landfall, where they will connect to the onshore infrastructure.

Figure 2.1: Location of the Proposed Development

2.2. Linkages with Other Consents management Plans

The INNSMP is consistent as far as possible with other relevant consent management plans prepared for the Proposed Development, which are set out in Table 2.1 Open ▸ .

Table 2.1: Linkages with Other Consents Management Plans

3. Roles and Responsibilities

Table 3.1 Open ▸ provides a list of the roles and responsibilities in relation to this INNSMP.

Table 3.1: Roles and Responsibilities in Relation to the INNSMP

4. Invasive Non-Native Species Management Plan Methodology

The following sections describe the process of creating the INNSMP following best practice guidance (Payne et al., 2014) and information provided in the Code of Practice on Non-Native Species (Scottish Government, 2020). A stepwise approach has been taken as detailed below, to accurately assess the risk of INNS in relation to the Proposed Development.

4.2. Step 1 – Understanding Your Site

The following parameters should be considered when understanding the Proposed Development site as part of the INNSMP development:

salinity of the site;
presence of any man-made structures; and
whether INNS are present within/on site.
1. The presence/absence of INNS is directly linked to the salinity of the site, as the majority of marine flora and fauna are unable to survive in freshwater due to osmoregulatory effects (Evans, 1980). The more freshwater enters the site, the lower the risk of INNS due to inhospitable conditions; conversely a greater risk is present for a full marine site.
2. The risk of INNS establishment is also increased by the presence of man-made structures. Information regarding any periods of slow or stationary works or climatic conditions that may increase biosecurity risk should be included.
3. If INNS have been recorded onsite, the focus of the INNSMP should be reducing the risk of introducing new INNS and the prevention of spreading existing INNS to other sites. In this case, a precautionary approach should be followed, even if no INNS are present at the site.
4. Based on this, a site can be categorised as either a low risk or significant risk site, depending on the risk of INNS introduction and spreading. Table 4.1 Open ▸ provides an example of this approach.

Table 4.1: Example of Low and Significant Risk Sites (Payne et al., 2014)

4.3. Step 2 – Understand How INNS can be Introduced or Spread to Your Site

In addition to understanding the site characteristics, the structures present on site and any INNS already present in the site, consideration must be given to how INNS can be introduced to the site.
This step should be iterative and revisited when the INNSMP is due for review (see section 5.7.2).
Table 4.2 Open ▸ provides an example of the type of questions to consider when creating an INNSMP.

Table 4.2: Example of Questions and Risk to Consider Whilst Creating an INNSMP (Payne et al., 2014)

The greatest risk of introducing INNS to the site is when a vessel (particularly slow moving vessels), equipment or stock arrives at the site from another country, region or water body, with similar environmental conditions (e.g. seawater temperature and salinity) while it is covered in biofouling (i.e. anything more than a thin, green ‘slime’ coating for vessel hulls) or contains additional algae or animals.
Another main risk is introducing INNS from the arrival of a vessel with biofouling on the hull, for example, which comes from a site known for the presence of INNS.
For the purposes of this assessment, any activity that falls within the ‘Low’ category in Table 4.2 Open ▸ is assessed as ‘Low’ Risk. Any activity that falls within the ‘Medium’ or ‘High’ categories is assessed as ‘Significant’ Risk, as ‘Significant’ is considered as any risk above low on a “low, moderate, high, severe” scale.

4.4. Step 3 – Identifying Activities which Risk Introduction Of Non-native Species

The next step is to identify the main activities which take place at the site or as part of the operation/event, particularly those that could lead to the introduction and/or release of marine INNS at the site.
The activities which carry almost no risk at all, such as those taking place in areas which are never in contact with sea water, do not need to be covered by this plan. However, always err on the side of caution, considering all activities which take place in or around the water and include both vessels and structures.
A list of example activities which carry a risk of introduction and/or releasing INNS is provided in Payne et al. (2014). These are not directly related with offshore renewables, but applicable ones include:

use of construction barge and slow moving vessels;
using vessels from locations outside local water body;
removal of old structures/equipment;
cleaning of hull and associated structures; and
maintenance of equipment and vessels.
1. When identifying activities, there are two possible approaches to follow, as described below. In general, the in-depth approach is recommended.

4.4.2. Simple Approach

This approach aims to list all the activities which take place on the site, or which make up the operation/event that may carry a significant risk of introduction and/or releasing INNS. This list is then taken to Step 4 to develop control measures.

4.4.3. In-Depth Approach

This technique helps the Applicant to better understand the risk of introducing and/or spreading INNS associated with each proposed activity. It also provides guidance on the development of biosecurity control measures as well as where and when to apply them. This approach has been developed from the Hazard Analysis and Critical Control Point (HACCP) and is further described in Annex B of Payne et al. (2014).
This approach consists of the following steps:

Step 1 – List Site Activities: a list of all activities which have a reasonable risk of leading to the introduction of INNS is compiled.
Step 2 – Describe Activities: a brief description of activities is provided based on “who, what, when, where, why and how”.
Step 3 – Split Activities into Task: activities are subdivided into tasks, which are then briefly described.
Step 4 - Establish Critical Control Points and Control Measures: the following is included for each task identified:

– risk;

– justification;

– critical control point;

– control measure; and

– who will carry out the control measure.

Step 5 – Develop an Action Plan: Based on the control measures developed in Step 4, an action plan is completed, setting out who will carry out the control measure, what they will do and when.

4.5. Step 4 – Biosecurity Control Measures

As part of this step, biosecurity control measures are identified. It is important that these measures are effective, simple, realistic and can be easily translated into instructions to others.
These measures must also take into account how much control the Applicant has over the site and its activities. Control measures help the Applicant to meet their legal requirement described in section 1.2, to take ‘reasonable steps’ to prevent the introduction of INNS.
To make the control measures effective, it is worth thinking about:

who will carry out the action;
what they will be doing to reduce the risk of introducing INNS;
where will the control measure be applied; and
when will the control measure be applied (i.e. at what stage in a process).
1. A list of example control measures can be found within Payne et al. (2014), many of which are included in the INNSMP (see section 5.4). Where possible, biosecurity measures should be included in the design stage of a new development and aim to ‘design out’ any possible significant risk of introducing or spreading INNS.

4.6. Step 5 – Biosecurity Surveillance, Monitoring and Reporting Procedures

Early detection of INNS on the site is important as this increases the likelihood of successful containment and potential for full eradication. For this reason, all staff and other site users should be encouraged to report any unusual sightings to the biosecurity officer.
This step outlines those procedures to be followed in the event of discovering and positively identifying an INNS on site. As part of this process the following should be considered:

setting out who is responsible for surveillance and monitoring of the site; and
adding actions to encourage vessel owners who use the site to be vigilant and report any sightings of concern.

4.7. Contingency Plan

A contingency plan should be in place to deal with potential failure of the ‘prevention’ and ‘rapid response’ method identified in paragraph 10. This document should be short and be accessible to all staff, ensuring it provides a step by step action list.
The contingency plan will review the activities identified in this INNSMP with potential to introduce and/or spread INNS and derive actions to deal with a potential failure of the proposed control measures.

4.8. Monitoring and Review

Following completion of the INNSMP, a clear recording system (i.e. a logbook) should be put in place to accurately record the results of any checks or actions taken, and formal steps are put in place to quickly inform the biosecurity manager of potential INNS introduction.
A review date of site and operation plans will be in place to refine and update the INNSMP as required.

5. Proposed Development Invasive Non-Native Species Management Plan

5.1. Step 1 – Understanding Your Site

5.1.1. Environmental Conditions Affecting Biosecurity

The Proposed Development is located within the outer Firth of Forth and partially overlaps with the Firth of Forth Banks Complex Marine Protected Area (MPA).
Water depths at the Proposed Development range between 32.8 m and 68.5 m below Lowest Astronomical Tide (LAT), with an average seabed depth of 51 m below LAT. The Proposed Development has an average tidal range of 3.25 m, with the tidal current flowing to the south and ebbing to the north. Tidal flows are relatively weak, with tidal current speeds typically between 0.5 m/s and 0.6 m/s.
As the Proposed Development is in offshore waters and there are no freshwater run offs in the vicinity, salinity level is expected to be similar to that found in the wider North Sea marine environment.
The subtidal benthic ecology of the Proposed Development were shown to range from hard and coarse substrates, with rock in the nearshore area of the Proposed Development export cable corridor, with sandy sediments in the central section grading into more gravelly sands and areas of hard substrate farther offshore. Subtidal communities were dominated by annelids, molluscs and crustaceans.
In addition to this, there are no man-made structures within the Proposed Development array area, however, there are neighbouring wind farms under construction which may increase the risk of INNS. This section is for illustrative purposes only and will be further updated post consent.

5.1.2. Information Related to Any Slow or Stationary Periods or Climatic Condition which May Increase Biosecurity Risk

Information regarding the environmental conditions at the Proposed Development can be found in volume 2, chapter 7 of the Offshore EIA Report.
As described in paragraph 49, the Proposed Development experiences relatively weak tidal currents, which may increase the biosecurity risk, as there is potential for fouling organisms to easily colonise introduced substrates.

5.1.3. INNS at the Proposed Development

All Water Framework Directive (WFD) water bodies within 25 km of the Proposed Development are currently classified as High from freedom from INNS (volume 2, chapter 19).
No INNS have been recorded during site-specific surveys of the Proposed Development. If any were to be recorded in the area prior to finalising the plan, they would be included here, identifying the risk they pose to Scotland’s native species.
Furthermore, the latest post-construction monitoring data from the Beatrice Offshore Wind Farm (APEM, 2021) found no evidence for the presence of INNS on wind turbine foundations following the presence of installation vessels from international ports, which is evidence to suggest that the introduction of structures such as offshore wind turbine foundations into the benthic environment doesn’t necessarily lead to the spread of INNS in Scottish waters.

5.2. Step 2 – Understand How INNS Can be Introduced or Spread to Your Site

5.2.1. Vessel/Equipment to be Used in the Proposed Development

An example of the vessels and equipment to be used at the Proposed Development is provided in Table 5.1 Open ▸ . This table also includes a risk indicator of the potential for INNS to be introduced to the Firth of Forth and surrounding areas as part of these activities. The risk indicator will be updated through professional judgment of the final project parameters, together with any INNS present in the area (section 5.1.3).

Table 5.1: Example Vessel and Foundation Types to be Used at the Proposed Development and/or Involved in the Operation and Maintenance and Decommissioning Phases

A detailed update of Table 5.1 Open ▸ will be completed once the exact specifications and origins of vessels are known upon appointment of a preferred vessel Contractor during the pre-construction phase.
The Offshore EIA Report has used a Maximum Design Scenario, based on the current available information, which includes the use of several vessels and/or foundation types for wind turbines and OSPs/Offshore convertor station platforms ( Table 5.1 Open ▸ ). As this is a ‘live’ document, once specific details of the wind turbines and OSPs/Offshore convertor station platforms, vessels and ancillary equipment are known, this document will be updated accordingly, assigning risk categories for specific infrastructure types as per the methodology set out in section 4.

5.3. Step 3 – Identifying Activities which Risk Introducing Non-Native Species

Table 5.2 Open ▸ provides an indicative list of activities in relation to the Proposed Development which may have a significant risk of introducing and/or spreading INNS. This table will be informed from the information in the final project design and from Step 2 (section 5.2).

Table 5.2: Site Activities Which Have a Significant Risk of Introducing and/or Spreading INNS

5.4. Step 4 – Biosecurity Control Measures

The following sections provide information on site-specific risks and control measures in relation to the Proposed Development.

5.4.2. Installation/Presence of Man-made Structures

Risk

This has been identified as one of the greatest risks of INNS introduction and/or spreading, as newly available surfaces at the Proposed Development (e.g. foundations) may be colonised by INNS in the first few weeks/months after installation.

Control measures

Any man-made structure to be used for the Proposed Development should be of terrestrial origin (i.e. not coming from another marine environment where it has been submerged or exposed to the sea). If there is a requirement for the structure to come from another marine environment, it will be allowed to fully dry to kill off any organisms that have attached and will be inspected prior to placement in the marine environment. This measure will occur port-side or on transit vessels.
It is also expected that any man-made structures will be painted with anti-fouling paint and marine growth will be removed as detailed in section 5.4.4.

5.4.3. Using Vessels From Outside of the Proposed Development

Risk

Vessels arriving from outside the east coast of Scotland and north-east coast of England area pose a significant risk of introducing INNS to the area, particularly those arriving from similar marine environments. Once construction contractors have been appointed, further information on the origin of vessels to be used in the Proposed Development will be included in this section.

Control measures

All vessels to be used at the Proposed Development during construction, operation and maintenance and decommissioning must follow International Management Organisation (IMO) (2012), and where applicable, to comply with IMO (2021), which includes the following standards:

ballast water exchange to be carried out at least 200 nm from the nearest land and in water at least 200 m in depth;
use of anti-fouling systems, which includes the use of coating systems, bio-fouling resistant materials and marine grown prevention systems; and
in-water inspection of ships and in-water cleaning and maintenance.
1. Implementation of these measures will be ensured by a requirement for all contractors to comply with this INNSMP by the Applicant.

5.4.4. Cleaning and Disposal of Biofouling From Structures During Operation and Maintenance activities and Decommissioning

Risk

There is potential for INNS to detach from subsea structures during routine maintenance activities such as jet washing. Where a risk that operation and maintenance activities may lead to spread of INNS has been identified, additional control measures may be required and will be included in this section.
INNS may remain attached to the surface of marine structures during decommissioning. If INNS were to be removed without due care and washed back into the surrounding marine environment during the decommissioning phase, there may be a risk of INNS spreading to areas where they weren’t initially present.

Control measures

Where a risk has been identified that operation and maintenance activities may lead to the spread of INNS, control measures may be required to minimise the amount of biofouling material entering the marine environment at the Proposed Development. These may include collection and disposal of biofouling as per relevant Port Authority “Waste Management Plan”, use of appropriate anti-fouling coating systems and good maintenance of all equipment, including regularly assessing the need for cleaning and the condition of the anti-fouling coating system (IMO, 2012).
Material detached or removed from decommissioned subsea infrastructure should be taken away to be properly disposed of onshore, this is to prevent INNS entering the marine environment. Disposal of biofouling will be aligned with the relevant Port Authority ‘Waste Management Plan’.
All equipment, materials, machinery, Personal Protection Equipment (PPE) and vessels must be in a clean condition prior to their arrival on site.
All contractors will be required to comply with these measures by the Applicant through adherence to this INNSMP prior to mobilisation to site.

5.5. Step 5 – Biosecurity Surveillance, Monitoring and Reporting Procedures

This section will contain information about who is responsible for carrying certain INNS checks, as well and where and when these checks are to be completed by the Biosecurity Manager.

5.6. Contingency Plan

Table 5.3 Open ▸ lists the actions or stages of the contingency plan and who is responsible for each of them.

Table 5.3: Contingency Plan (Payne et al., 2014)

5.7. Monitoring and Review

5.7.1. Monitoring and Implementation of the Plan

Once this INNSMP has been agreed, a logbook will be developed to keep a clear record of any checks or actions taken and list the formal steps to ensure the biosecurity manager is quickly informed of any potential introduction of INNS.
Payne et al. (2014) provides examples of information to be recorded in the logbook. All records entered should be given a date and signed by the biosecurity manager.

5.7.2. Plan Review

This INNSMP will be reviewed regularly to make sure it stays up to date and relevant. It is proposed that this plan will be reviewed, as a minimum, every 12 months during the construction phase, but maybe more frequently depending on need, and as agreed with MS-LOT.
This INNSMP will be updated following completion of the construction phase and at the beginning of the operation and maintenance phase to ensure the plan is appropriate for the next phase of the development and the risks/activities associated with that next phase. During the operation and maintenance phase, the INNSMP will be updated regularly (as a minimum every 5 years). Prior to the decommissioning phase the INNSMP will be reviewed and updated to ensure all measures are appropriate and that any changes in the environment and risk of INNS (e.g. records of INNS on site) are reflected in the INNSMP.

6. Useful Sources of Information

The following is a list of useful information sources to inform this INNSMP:

IMO Guidelines for the control and management of ships biofouling to minimize the transfer of invasive aquatic species;
Scottish Invasive Species Initiative: Law on non-native species | Scottish Invasive Species Initiative; and
Scotland’s Environment: Invasive non-native species | Scotland's environment web.

7. References

Evans, D.H. (1980). Osmotic and ionic regulation by freshwater and marine fishes. In Environmental physiology of fishes (pp. 93-122). Springer, Boston, MA.

HM Government (2015). The Great Britain Invasive Non-native Species Strategy. Available at: The Great Britain Invasive Non-native Species Strategy (publishing.service.gov.uk). Accessed on: 19 May 2022.

IMO (2012). Guidelines for the Control and Management of Ships’ Biofouling to Minimize the Transfer of Invasive Aquatic Species 2012 Edition.

IMO (2021). International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM). Available at: International Convention - CP 557 (publishing.service.gov.uk). Accessed on: 09 May 2022.

Payne, R.D., Cook, E.J. and Macleod, A. (2014). Marine Biosecurity Planning. Guidance for Producing Site and Operation-based Plans for Preventing the Introduction of Non-Native Species. Available at: Guidance-Biosecurity-Planning.pdf (clydemarineplan.scot). Accessed on: 05 May 2022.

Scottish Government (2012). Code of Practice on Non-Native Species. Available at: Non-native species: code of practice - gov.scot (www.gov.scot). Accessed on: 16 May 2022.

Scottish Government (2020). 2020 Challenge for Scotland’s Biodiversity. Available at: Supporting documents - 2020 Challenge for Scotland's Biodiversity - gov.scot (www.gov.scot). Accessed on: 18 May 2022.