3. Part II: Environmental Impacts and Control Measures
3.1. Environmental Impacts and Control Measures
- In this section of the EMP, commitments stated in the Offshore EIA report will be translated into an appropriate format allowing their practical implementation by Contractors and Subcontractors. This follows IEMA Practitioner Guide, which states that “the overall objective of an EMP is to provide a continuous link or ‘bridge’ between the design phase of a Proposed Development, conditions attached to consents, Proposed Development construction, and into the operational phase” (IEMA, 2008).
- The complete list of enhancement, mitigation and monitoring commitments is provided in volume 3, appendix 6.2 as a Commitments Register. As the Commitments Register is developed from the commitments made within the Offshore EIA Report and in compliance with consent conditions, adherence to the EMP and accompanying annexes, will ensure compliance with the consents awarded for the Proposed Development in relation to environmental considerations.
3.2. Management of Key Environmental Aspects and Compliance Obligations
3.2.1. Marine Species
- In the event of a wildlife incident occurring as a result of activity associated with the Proposed Development (e.g. injury to a marine mammal, or an observed fish or bird mortality), the incident will be reported to the Applicant Environmental Manager or Applicant ECoW as soon as possible. Details of the activity being undertaken, pictures and weather conditions are the minimum information to be provided. The Applicant Environment Manager or Applicant ECoW will follow up with the relevant regulatory authority, where appropriate. The approach to management and mitigation of potential impacts on marine mammals is provided in the MMMP (volume 4, appendix 23).
3.2.2. Marine Archaeology
- The procedures to be followed on discovering any marine archaeology during the construction and operation and maintenance phases of the Proposed Development are set out in the WSI and PAD (annex D to this EMP).
3.2.3. Others Marine User
- The approach to management and mitigation of potential impacts on other marine users is described in volume 3, appendix 6.2. and provided in the following plans:
- FMMS (volume 4, appendix 24);
- NSVMP (volume 4, appendix 25);
- ANMP (volume 4, appendix 26); and
- LMP (volume 4, appendix 27).
- Some of the specific measures adopted by these plans are:
- the adoption of advisory safety zones;
- appropriate notification of activities to other marine users;
- a clear process of marine coordination of all vessels and vessel activity;
- appropriate marking and lighting of vessels;
- appropriate marking and lighting of the Proposed Development; and
- vessel transit planning, commercial fisheries relations and management of commercial fisheries interactions.
3.2.4. Marine Pollution Prevention and Contingency Planning
- The measures to be adopted to minimise the impacts from the release of pollutants from construction and operation and maintenance phases of the Proposed Development are set out in the MPCP (annex A to this EMP).
3.2.5. Invasive Non-Native Species
- The measures to be adopted for the management of marine Invasive Non-Native Species (INNS) during construction and operation and maintenance phases of the Proposed Development are set out in the INNSMP (annex B to this EMP).
3.2.6. Waste management
- A Waste Management Plan (WMP) is required by all Contractors and Subcontractors setting out details of all waste management procedures for their activities and details of expected waste arisings and following procedures for waste management. The following aspects are expected to be a minimum requirement for the WMP:
- analysis of the waste arisings/material surpluses;
- specific waste management objectives for the Proposed Development;
- methods proposed for prevention, reuse and recycling of wastes;
- material handling procedures; and
- proposals for education of workforce and plan dissemination programme.
- Some of the key responsibilities of the Contractors and Subcontractors addressed in the WMP are expected to include:
- complying with all relevant legislative and Offshore EIA report requirements and seek mandatory permits and licences regarding waste management;
- providing a waste reduction toolbox talk to all personnel to increase awareness of recycling and waste reduction, and make sure the requirements of the WMP are understood;
- handling waste materials and refuses to limit the damage and disturbance as much as possible;
- sorting all waste in their specific suitably labelled secure container;
- checking the contents of the site waste and recycling containers on a weekly basis;
- reducing waste through reduction, recycling or waste elimination measures when feasible;
- storing and returning all relevant waste to shore and disposing of it according to the legal waste management framework; and
- agreeing with the principles of the Basel Convention of 1989 to avoid hazardous waste being unfairly exported to developing countries.
- The WMP must be provided to the Applicant for approval prior to commencement of the activities.
- The WMP will be updated for the operation and maintenance phase of the Proposed Development.
4. References
Institute of Environmental Management and Assessment (IEMA) (2008). Environmental Management Plans, Best Practice Series, Volume 12, December 2008.
Scottish Government (2019). The Electricity Act 1989 (as Amended), The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 (As Amended), Decision Notice for the Section 36 Consent for the Construction and Operation of the Moray West Offshore Wind Farm, approximately 22.5km Southeast from the Caithness Coastline. June 2019.
Scottish Government, (2022). The Energy Act 2004 Decommissioning of Offshore Installations and Decommissioning of Offshore Renewable Energy Installations in Scottish waters