16.10 Reduction in Search and Rescue Capability

16.10.1 Construction Phase

  1. The construction phase will lead to an increased level of vessels and personnel in the area over baseline levels. On this basis there may be an increase in the number of incidents requiring emergency response over baseline rates.
  2. Up to 7,902 return trips from construction vessels (including site preparation) may be made throughout the construction phase and will include vessels which are RAM. The presence of project vessels will increase the likelihood of an incident, with the potential to diminish emergency response capability.
  3. Baseline incident rates are considered low in the area based on the data studied, with an average of less than one incident per year indicated within the MAIB, RNLI and helicopter taskings datasets. It is also noted that to date, there have only been 13 reported allision or collision incidents associated with offshore wind farms in the UK (see section 9.6.1). While it should be considered that this only covers allisions and collisions, it is still not anticipated that the construction phase would notably increase the observed baseline incident rates.
  4. Any on-site project vessels and resources associated with the construction phase will form additional resource to respond to any incidents in the area in liaison with the MCA, both in terms of incidents associated with construction (i.e. self-help resources), but also incidents occurring outside of the Array to third‑party vessels.
  5. As required under MGN 654, the Applicant will produce and submit an ERCoP to the MCA detailing how they would cooperate and assist in the event of an incident including consideration of additional project resources that will be available (e.g. project vessels associated with construction). The initial ERCoP will specifically cover the construction phase.
  6. The most likely consequence is a delay caused emergency response request but without notable impact on the operation. As a worst case the delay could lead to PLL

16.10.1.1               Frequency of Occurrence

  1. The frequency of occurrence is considered to be remote based on consideration of the historical incident data and the embedded mitigation in place including compliance with MGN 654.

16.10.1.2               Severity of Consequence

  1. The severity of consequence is considered to be serious.

16.10.1.3               Significance of Risk

  1. Overall, the severity of consequence is deemed to be serious and the frequency of occurrence is considered to be remote. The risk will therefore be of tolerable significance.

16.10.1.4               Additional Mitigation and Residual Risk

  1. No additional shipping and navigation mitigation is considered necessary because the likely risk in the absence of further mitigation (beyond the embedded mitigation measures outlined in section 18.1) is ALARP and not significant in EIA terms.

16.10.2 Operation and Maintenance Phase

  1. The operation and maintenance phase will lead to an increased level of vessels and personnel in the area over baseline levels, however it is likely to be less than during the construction phase (when more vessels will be present and more activity being undertaken). On this basis there may be an increase in the number of incidents requiring emergency response over baseline rates, albeit likely at lower rates than during the construction phase.
  2. As per the equivalent construction phase discussion, baseline incident rates are considered low in the area, and it is considered unlikely that incident rates will rise notably based on the study of allision and collision incidents that have occurred at other UK offshore wind farms (see section 9.6.1).
  3. Any on-site project vessels and resources associated with the operation and maintenance phase will form additional resource to respond to any incidents in the area in liaison with the MCA, both in terms of incidents associated with the ongoing operation and maintenance (i.e. self help resources), but also incidents occurring outside of the Array to third‑party vessels.
  4. As required under MGN 654 (MCA, 2021), the Applicant will produce and submit an ERCoP to the MCA for approval detailing how they would cooperate and assist in the event of an incident including consideration of additional project resources that will be available (e.g. project vessels associated with operation and maintenance). The ERCoP will be updated on a regular basis as required by the MCA, and this will include the transfer of the construction phase ERCoP into the operation and maintenance phase ERCoP in advance of the completion of construction. The Applicant will also agree a SAR checklist with the MCA post consent, which will set out the required mitigations of relevance to SAR that will be implemented.
  5. To maintain suitable SAR access, the final layout of structures will be agreed with the MCA post consent. This will include application of the SAR layout requirements within MGN 654 (MCA, 2021), noting that there may also be a need for use of Helicopter Refuge Areas given the size of the site boundary. The consideration of MGN 654 in addition to agreement of the layout positions with the MCA will maintain suitable SAR access.
  6. The most likely consequence is a delay caused emergency response request but without notable impact on the operation. As a worst case the delay could lead to PLL.

16.10.2.1               Frequency of Occurrence

  1. The frequency of occurrence is considered to be remote based on consideration of the historical incident data and the embedded mitigation in place including compliance with MGN 654.

16.10.2.2               Severity of Consequence

  1. The severity of consequence is considered to be serious.

16.10.2.3               Significance of Risk

  1. Overall, the severity of consequence is deemed to be serious and the frequency of occurrence is considered to be remote. The risk will, therefore, be of tolerable significance.

16.10.2.4               Additional Mitigation and Residual Risk

  1. No additional shipping and navigation mitigation is considered necessary because the likely risk in the absence of further mitigation (beyond the embedded mitigation measures outlined in section 18.1) is ALARP and not significant in EIA terms.

16.10.3 Decommissioning Phase

  1. Since the methods used to remove infrastructure are expected to be similar to those used for installation, this impact is expected to be similar in nature to the equivalent construction phase impact. In particular, a buoyed decommissioning area analogous to the buoyed construction area will be in place and it is anticipated that third-party vessels would be unlikely to enter on a regular basis.
  2. This also includes the assumption that the vessels on site associated with decommissioning will form additional resource to respond to any incidents in the area in liaison with the MCA, both in terms of incidents associated with the projects (i.e. self help resources), but also incidents occurring outside of the Array to third party vessels.
  3. As required under MGN 654 (MCA, 2021), the Applicant will produce and submit an ERCoP to the MCA detailing how they would cooperate and assist in the event of an incident including consideration of additional project resources that will be available (e.g. project vessels associated with decommissioning). The ERCoP will be updated on a regular basis as required by the MCA, and this will include an update prior to decommissioning.
  4. The most likely consequence is a delay caused emergency response request but without notable impact on the operation. As a worst case the delay could lead to PLL.

16.10.3.1               Frequency of Occurrence

  1. The frequency of occurrence is considered to be remote based on consideration of the historical incident data and the embedded mitigation in place including compliance with MGN 654.

16.10.3.2               Severity of Consequence

  1. The severity of consequence is considered to be serious.

16.10.3.3               Significance of Risk

  1. Overall, the severity of consequence is deemed to be serious and the frequency of occurrence is considered to be remote. The risk will, therefore, be of tolerable significance.

16.10.3.4               Additional Mitigation and Residual Risk

  1. No additional shipping and navigation mitigation is considered necessary because the likely risk in the absence of further mitigation (beyond the embedded mitigation measures outlined in section 18.1) is ALARP and not significant in EIA terms.