4.2 Consultation Responses
- Various responses have been received from stakeholders during consultation undertaken during the NRA process, either during conference calls, via email correspondence or through the Ossian Array Scoping Opinion (Marine Directorate – Licensing and Operations Team (MD-LOT), 2023). The key points and where they have been addressed in the NRA or volume 2, chapter 13 are summarised in Table 4.1. Points raised in the Hazard Workshop are presented separately in Section 4.3.3.
Table 4.1: Summary of Key Points Raised During Consultation
Stakeholder | Form of Correspondence | Point Raised | Response and Where Addressed in the NRA |
|---|---|---|---|
Ossian Array Scoping Opinion | |||
NLB | Scoping Opinion | “Northern Lighthouse Board note the inclusion of Section 7.2 – Shipping and Navigation, within the report, with particular reference to 7.2.7, where you confirm your intention to comply with MGN 654 covering shipping and navigational risk assessment and further in section 7.2.11, where you confirm that this will lead to the development of a Navigational Risk Assessment and that you will consult with the NLB further in relation to your intended development of a Lighting and Marking Plan (LMP) and Navigational Safety Plan (NSP).” | An NRA has been produced as required, including a completed MGN 654 checklist in Appendix A. NLB will be consulted on the Lighting and Marking Plan (LMP) and Navigational Safety Plan (NSP). |
NLB | Scoping Opinion | “NLB also note the inclusion of Cumulative Effects (Section 7.2.8) within this chapter, and the factors upon which other cumulative projects will be screened in or out of the assessment.” | The NRA includes cumulative assessment of routeing in section 14, with hazards assessed in volume 2, chapter 13. |
NLB | Scoping Opinion | “NLB have no objection to the content of the Scoping Report, and have no further suggestions for additional content.” | Methodology and assessment are as per the Array EIA Scoping Report (Ossian OWFL, 2023) (see section 3). |
RYA Scotland | Scoping Opinion | “Do you agree with the data sources, including project-specific surveys, to be used to characterise the shipping and navigation baseline within the NRA and Array EIA? The data to be used for recreational craft are adequate. The requirements for MGN 654 will have to be met but no additional data are needed even though only a proportion of recreational vessels transmit an AIS signal and recreational vessels can be difficult to spot on radar. It should be assumed that a small number of vessels will pass through the site each year. Clearly Shipping and Navigation should be scoped in to the EIA. RYA Scotland would like to contribute to the Navigational Risk Assessment.” | RYA Scotland has been consulted as part of the NRA process, with relevant input captured in the Hazard Workshop. The data used is as set out in the Array EIA Scoping Report (Ossian OWFL, 2023) (see section 5). |
RYA Scotland | Scoping Opinion | “Do you agree that all potential impacts (hazards and associated risks) have been identified for shipping and navigation? An additional risk is the failure of Aids to Navigation marking the devices. There have been several cases where lights or AIS transmissions have failed on wind farms off the coast of Scotland and it has taken several days to replace them due to adverse weather. Mitigation might include the use of virtual AtNs.” | The Array will comply with the relevant IALA requirements, including with regards to aid to navigation availability. The NLB have been consulted during the NRA process and lighting and marking will be agreed with NLB post-consent. An outline Aids to Navigation (AtoN) Management Plan is provided in volume 4, appendix 26, annex A. |
RYA Scotland | Scoping Opinion | “Do you agree with the proposed approach to assessment? Yes.” | Noted. Approach is as per the Array EIA Scoping Report (Ossian OWFL, 2023) (see section 3). |
RYA Scotland | Scoping Opinion | “Do you agree with the approach to screening other developments in or out of the cumulative assessment? Yes.” | Noted. Approach is as per the Array EIA Scoping Report (Ossian OWFL, 2023) (see section 3.3). |
RYA Scotland | Scoping Opinion |
“Do you have any additional comments relating to the use of floating technology specifically and potential associated additional mitigation options (e.g., operational safety zones) in relation to navigational safety impacts? From experience with existing floating wind farms we cannot see that the risks are significantly different from conventional schemes. A little depends on where the anchor chains are connected but we see no reason for operational safety zones and would be opposed to them being granted. I feel that creating safety zones by itself is not mitigation. It only becomes mitigation when the zone is actively enforced. Most recreational sailors will keep well clear off wind turbines, as they would when passing a ship at anchor.”
| The Applicant will determine which safety zones will be applied for post-consent in consultation with key stakeholders including RYA Scotland. The Array application will include procedures by which the safety zones will be monitored and enforced where necessary.
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MCA | Scoping Opinion | “The Environmental Impact Report should supply detail on the possible impact on navigational issues for both commercial and recreational craft, specifically: • Collision Risk. • Navigational Safety. • Visual intrusion and noise. • Risk Management and Emergency response. • Marking and lighting of site and information to mariners. • Effect on small craft navigational and communication equipment. • The risk to drifting recreational craft in adverse weather or tidal conditions. • The likely squeeze of small craft into the routes of larger commercial vessels.” | The listed hazards have all been assessed in section 16 and volume 2, chapter 13. Mitigations are discussed in section 18.1. |
MCA | Scoping Opinion | “The development area carries a moderate amount of traffic with several important commercial shipping routes to/from UK ports and the North Sea. Attention needs to be paid to routing, particularly in heavy weather so that vessels can continue to make safe passage without large-scale deviations. The likely cumulative and in combination effects on shipping routes should be considered for this project. It should consider the proximity to other wind farm developments, other infrastructure, and the impact on safe navigable sea room.” | Routes pre wind farm have been assessed in section 11, routes post wind farm have been assessed in section 13.4.2, routeing in adverse weather has been assessed in section 11.3 and routeing on a cumulative basis has been assessed in section 14. |
MCA | Scoping Opinion | “A Navigational Risk Assessment will need to be submitted in accordance with MGN 654.This NRA should be accompanied by a detailed MGN 654 Checklist which can be found at https://www.gov.uk/guidance/offshore-renewable-energy-installations-impact-on-shipping” | An NRA has been produced as required, including a completed MGN 654 checklist presented in Appendix A. |
MCA | Scoping Opinion | “A vessel traffic survey will be undertaken to the standard of MGN 654 – at least 28 days which is to include seasonal data (two x 14-day surveys) collected from a vessel-based survey using AIS, radar and visual observations to capture all vessels navigating in the study area. We understand from the information presented in table 7.5 and paragraph 523 that in addition to the preliminary assessment of 28 days (13 – 26 January 2022 and 08 – 21 July 2022) of Automatic Identification System (AIS) data, a dedicated survey vessel located on-site in December 2022 carried out a traffic survey to the standard required in MGN 654. This data will be updated further once the project-specific summer vessel traffic survey has been completed in 2023.” | The NRA has assessed vessel traffic survey data that is fully compliant with MGN 654 in section 10, in addition to 12 months of AIS in Appendix E. |
MCA | Scoping Opinion |
“The Development Specification and Layout Plan referred to in Chapter 7.2.5, paragraph 533 and table 2.1 in Annex 2 will require MCA approval prior to construction to minimise the risks to surface vessels, including rescue boats, and Search and Rescue aircraft operating within the site. Any additional navigation safety and/or Search and Rescue requirements, as per MGN 654 Annex 5, will be agreed at the approval stage.”
| The Applicant will ensure full MGN 654 compliance, including in relation to layout and the Search and Rescue (SAR) checklist (see section 18.1). |
MCA | Scoping Opinion | “We note in Chapter 4.3.7, para 198 that Cumulative Effects Assessment will be carried out. As highlighted in paragraph 200, the proximity to other offshore wind farms in particular the proposed Morven and Bell Rock offshore wind farms will need to be fully considered, with an appropriate assessment of the distances between OREI boundaries and shipping routes as per MGN 654.” | Cumulative routeing has been assessed in section 14, with the assessment including account of Morven and Bellrock Offshore Wind Farms. The assessment has considered consultation undertaken with the MCA on distances to other projects as discussed within the relevant rows of this table. |
MCA | Scoping Opinion |
“It is noted that this scoping report concentrates on the array area only. However, attention should still be paid to cabling routes and where appropriate burial depth for which a Burial Protection Index study should be completed and subject to the traffic volumes, an anchor penetration study may be necessary. If cable protection measures are required e.g., rock bags or concrete mattresses, the MCA would be willing to accept a 5% reduction in surrounding depths referenced to Chart Datum. This will be particularly relevant where depths are decreasing towards shore and potential impacts on navigable water increase, such as at the HDD location.”
| MGN 654 requirements will be fully complied with, including in relation to underkeel clearance. A Burial Protection Index study will be completed, and an anchoring penetration study if required, post-consent. See section 18.1. |
MCA | Scoping Opinion | “In Chapter 7.2.5, paragraph 533 compliance with regulatory expectations on moorings for floating wind and marine devices (HSE and MCA, 2017) is identified as a designed in mitigation measure for floating infrastructure. This guidance should be followed, and a Third-Party Verification of mooring arrangements will be required.” | The requirements of the Regulatory Expectations will be followed, and Third-Party Verification (TPV) of all mooring and anchoring arrangements will be completed (see section 2). |
MCA | Scoping Opinion | “Particular consideration will need to be given to the implications of the site size and location on SAR resources and Emergency Response Co-operation Plans (ERCoP). The report must recognise the level of radar surveillance, AIS and shore-based VHF radio coverage and give due consideration for appropriate mitigation such as radar, AIS receivers and in-field, Marine Band VHF radio communications aerial(s) (VHF voice with Digital Selective Calling (DSC)). A SAR checklist will also need to be completed in consultation with MCA, as per MGN 654 Annex 5 SAR requirements.” | The Array will comply with MGN 654 requirements including in relation to the completion of a SAR checklist (see section 18.1). |
MCA | Scoping Opinion | “MGN 654 Annex 4 requires that hydrographic surveys should fulfil the requirements of the International Hydrographic Organisation (IHO) Order 1a standard, with the final data supplied as a digital full density data set, and survey report to the MCA Hydrography Manager. Failure to report the survey or conduct it to Order 1a might invalidate the Navigational Risk Assessment if it was deemed not fit for purpose.”
| Hydrographic surveys will be undertaken post-consent as per MGN 654. |
MCA | Scoping Opinion | “It is noted that the use of HVAC and HVDC transmission infrastructure is not discussed in this report. We would however like to remind the applicant when considering this that in the case of HVDC installation, consideration must be given to the effect of electromagnetic deviation on ships' compasses. The MCA would be willing to accept a three-degree deviation for 95% of the cable route. For the remaining 5% of the cable route no more than five degrees will be attained. If an HVDC cable is being used, we would expect the applicant to do a desk based compass deviation study based on the specifications of the cable lay proposed and assess the effect of EMF on ship’s compasses. MCA may request for a deviation survey post the cable being laid; this will confirm conformity with the consent condition. The developer should then provide this data to UKHO via a hydrographic note (H102), as they may want a precautionary notation on the appropriate Admiralty Charts (actions at a later stage depending upon the desk-based study and post installation deviation survey).” | This NRA does not consider the Proposed offshore export cable(s). Potential electromagnetic field (EMF) effects associated with other infrastructure are considered in section 12.6. |
MCA | Scoping Opinion | “Chapter 7.2.10, Scoping Questions to Consultees: 1- Do you agree with the data sources, including project-specific surveys, to be used to characterise the shipping and navigation baseline within the NRA and Array EIA? Yes. 2- Do you agree that all potential impacts (hazards and associated risks) have been identified for shipping and navigation? Yes 3- Do you agree with the proposed approach to assessment? Yes 4- Do you agree with the approach to screening other developments in or out of the cumulative assessment? Yes. 5- Do you have any additional comments relating to the use of floating technology specifically and potential associated additional mitigation options (e.g., operational safety zones) in relation to navigational safety impacts? None. On the understanding that the Shipping and Navigation aspects are undertaken in accordance with MGN 654 and its annexes, along with a completed MGN checklist, MCA is likely to be content with the approach.” | Noted. Approach is as per the Array EIA Scoping Report (Ossian OWFL, 2023) (see section 3). |
Cruising Association | Scoping Opinion |
“The area chosen for the Ossian OWF is not in an area which has a high concentration of recreational boats so the array will not have a big impact either during construction or when operational. However, there will be some traffic north and south along the coast and a small amount of traffic across the North Sea to Denmark, Norway and Sweden, all mostly in the summer months, perhaps as boats make for the Baltic Sea which is a popular cruising area. It should be borne in mind that sailing boats do not necessarily follow direct routes, depending on wind direction.”
| Recreational vessel traffic has been captured and assessed in section 10.3.5. |
Cruising Association | Scoping Opinion | “We have some concerns that when new arrays are being planned not enough consideration is given to the interaction with existing arrays of those being earmarked for the future. Each new array displaces larger commercial and fishing vessels which can result in increased concentration of traffic between arrays. This can present an increased hazard for small craft who do not wish to pass through the arrays. It would be good if these issues of interaction could be considered in more detail”. | Cumulative assessment has been undertaken in section 14. Hazards to small craft have been assessed in section 16. |
Cruising Association | Scoping Opinion | “We consider it important that vessels have the right of passage through arrays both during their construction and when they are operational (subject of course to the guidance given in the MCA MGN 372 Amendment 1 (M+F)) so we would not want to see any objections raised to this. In fact, given the point above regarding the concentration of traffic between arrays it can sometimes be safer for small craft to traverse an array I [sic] order to avoid shipping channels.” | Hazards to small craft have been assessed in section 16. |
Cruising Association | Scoping Opinion | “When considering the density of traffic passing through the area proposed for the array the analysis should not depend on AIS data for small craft. Many still do not carry AIS and many that do only receive and do not transmit their position. There are no numbers available to quantify this but my guess is that it would be prudent to assume that less than 20% transmit.”
| The vessel traffic survey data assessed in section 10 accounts for non-AIS traffic. |
UK CoS | Scoping Opinion | “The list of documentation looks broadly as expected to assess the shipping and navigation impact, however should also include Scotland’s National Marine Plan and its policies and Scotland’s Sectoral Marine Plan for Offshore Wind Energy and its policies.” | All relevant policy has been considered including Scotland’s National Marine Plan and Sectoral Marine Plan. |
UK CoS | Scoping Opinion | “Yes the 10nm study area is an accepted standard. The Chamber recommends a wider routeing study area of 50nm, which may be included as part of the wider cumulative impact assessment to consider routeing impacts of the proposed development in combination with other developments.” | A 50 nm study area has been used for cumulative assessment in section 14. |
UK CoS | Scoping Opinion | “The Chamber would recommend in addition to the MGN 654 compliant 2 x 14 day periods of vessel traffic data, additional AIS only data for a prolonged period to assist with analysis of seasonal variation and weather routeing which may be get picked up from only the short survey period.
This is widely available and commonplace for large proposed developments such as Ossian.” | Twelve months of AIS data has been assessed in Appendix E. |
UK CoS | Scoping Opinion | “The Chamber would expect to see inclusion of all the embedded mitigation measures as a minimum.” | The embedded mitigation measures will be implemented and are discussed in section 18.1. |
UK CoS | Scoping Opinion | “The receptors and impacts are broadly as one would expect for a fixed turbine development, however there are some additional receptors for floating which have are not yet considered.
What will be the construction phase of the build out? Will wet storage be required for turbines not at station? What is the navigational risk for these?” | Associated hazards are considered in section 16, based on worst-case parameters including in relation to construction, which includes consideration of wet storage. The location of the final integration and marshalling port is currently unknown. The Applicant is currently developing a fabrication, delivery and integration strategy and engaging with a number of port and harbour operators to identify an optimised approach. In the absence of an integration and marshalling yard it is not possible, at this stage, to consider the potential site-specific impacts on relevant receptors. Enabling works, including integration, and marshalling activities, required within the final integration port to cover turbine pre-commissioning, testing and storage (if required) will be covered by the consenting requirements applying to them (including any requirements for environmental assessment) and will be managed by the port or harbour authority with support where appropriate from the Applicant. The Array construction programme will be managed to reduce the requirement for storage of integrated pre-commissioned turbines within port. A stock of floating foundations will be accumulated, and mooring lines and cables would be installed within the Array in advance of turbine integration. The Applicant aims to minimise any wet storage requirements by towing integrated turbines to their final location within the Array as soon as they are ready, subject to suitable weather conditions for transfer.
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UK CoS | Scoping Opinion | “Floating platforms are inherently mobile assets and the greater movement of them will increase the range of impacts that a project has. Platforms will be towed to/from the array area, construction base or wet storage sites and may encounter other traffic or activities whilst on route.” | Associated hazards are considered in section 16. |
UK CoS | Scoping Opinion | “What will be the O&M phase, will it carried out at the array area or is there a need to bring the turbines into more sheltered locations?” | Routine maintenance will be carried out with the wind turbine in-situ. Wind turbines would be removed from stations and towed to an operation and maintenance port facility for any major component replacements, or similar. Lighting and marking will consider this, with mitigations agreed with the NLB. |
UK CoS | Scoping Opinion | “In addition, vessel displacement leading to deviation, longer journey time and other environmental/economic impacts besides additional collision risk should be considered and does not present appear.” | See volume 2, chapter 18. |
UK CoS | Scoping Opinion | “The Chamber agrees that no potential impacts should be scoped out.” | Impacts have been assessed as per the Array EIA Scoping Report (Ossian OWFL, 2023); see section 16.
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UK CoS | Scoping Opinion | “The Chamber does not agree that the following should be scoped out of the Construction and Decommissioning phase as there will still be an impact. Whilst the impact will be less than during the O&M phase it will nevertheless still be present particularly when the developments are half built/decommissioned: • Loss of station; • Interference with navigation, communications, and position-fixing equipment • Reduction of SAR capability.” | These hazards are considered for all phases in section 16. |
UK CoS | Scoping Opinion | “The Chamber agrees that cumulative and transboundary impacts need to be considered and is satisfied with a 50nm study area.” | Cumulative and transboundary impacts have been assessed using a 50 nm study area in section 14. |
UK CoS | Scoping Opinion | “Do you agree with the proposed assessment approach and list of planned consultees? Yes” | The assessment approach undertaken (see section 3) and the consultees (see section 4) are as per the Array EIA Scoping Report. |
Marine Directorate - Licensing Operations Team (MD-LOT) | Scoping Opinion | “The Scottish Ministers are content with the study area identified in Section 7.2.2 of the Scoping Report however note the representation from UKCoS which recommends a wider routeing study area of 50 nautical miles when considering the cumulative impact assessment with regards to routeing impacts in combination with other developments.” | A 50 nm study area has been used for cumulative assessment in section 14. |
MD-LOT | Scoping Opinion | “With regards to the shipping and navigation baseline, in line with the representation from the MCA, the Scottish Ministers are content that that the two separate 14 day periods of Automatic Identification System (“AIS”) data set out in the Scoping Report meets the standard MGN 654, however highlight the advice from UKCoS that additional AIS data over a prolonged period is obtained to assist with analysis of seasonal variation and weather routeing should be considered in the EIA Report. The Scottish Ministers advise that the Developer must engage further with the MCA and UKCoS to reach a suitable agreement on the provision of AIS data and document the rationale for the final approach within the EIA Report. Additionally, the Scottish Ministers highlight the representation from the CA regarding the limitations of AIS data for smaller craft which should be taken into consideration in the EIA Report.”
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Data sources were agreed with the MCA, NLB and UK CoS in consultation.
The project has collected non-AIS data as required under MGN 654, with this data assessed in section 10. Twelve months of AIS data has been assessed in Appendix E.
Adverse weather routeing has been assessed in section 11.3.
Consultation with recreational representatives has also been undertaken to ensure the baseline data is validated.
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MD-LOT | Scoping Opinion | “Table 7.7 of the Scoping Report summarises the potential impacts on shipping and navigation for each phase of the Proposed Development. The Scottish Ministers agree with the impacts scoped into the EIA Report, however the Developer is directed to the advice from the UKCoS that loss of station, interference with navigation, communications and positioning-fixing equipment and reduction of SAR capability should be scoped into the EIA Report during construction and decommissioning phases in addition to operation and maintenance. The UKCoS also identifies additional receptors in respect of floating offshore wind which the Scottish Ministers advise should be scoped into the EIA Report. Additionally, for the avoidance of doubt, the Developer must ensure that each of the possible impacts on navigational issues, including routing and effects on shipping, outlined in the MCA representation are addressed within the EIA Report. Finally, the Scottish Ministers highlight the RYA representation around failure of Aids to Navigation marking the devices which should be fully addressed in the EIA Report.” | These impacts are considered for all phases of the Array in section 16. An outline AtoN Management Plan is provided in volume 4, appendix 26, annex A. |
MD-LOT | Scoping Opinion | “With regards to approach to assessment, the Scottish Ministers confirm that, in line with NLB and MCA representations, the Developer will be required to submit a Navigational Risk Assessment in accordance with MGN 654, accompanied by a detailed MGN 654 checklist. Hydrographic surveys should fulfil the requirements set out in Annex 4 of MGN 654. In addition, the Scottish Ministers direct the Developer to the representation from the UKCoS and advise that the additional documentation highlighted should be considered when assessing the impact on shipping and navigation from the Proposed Development.” | An NRA has been produced as required, including a completed MGN 654 checklist in Appendix A.
Hydrographic surveys will be completed post-consent as required.
The referenced documents have been considered in volume 2, chapter 13. |
MD-LOT | Scoping Opinion | “The Scottish Ministers also highlight the MCA representation regarding SAR, Emergency Response Co-operation Plans, levels of radar surveillance, AIS and shore-based VHF radio coverage. The Scottish Ministers advise that the MCA representation must be fully addressed within the EIA Report and that a SAR checklist must be completed by the Developer in consultation with the MCA.” | A SAR checklist will be agreed with the MCA post-consent (see section 18.1). |
MD-LOT | Scoping Opinion | “Representation from the CA notes the preference of smaller craft to traverse wind farm arrays throughout all stages of its development due to the reduced risk from traversing busy shipping channels and that sailing boats don’t necessarily follow direct routes – this should be taken into consideration in the EIA Report.” | Hazards to small craft have been assessed in section 16. |
MD-LOT | Scoping Opinion | “With regards to cabling routes and cable burial, the Scottish Ministers advise that a Burial Protection Index should be completed and, subject to the traffic volumes, an anchor penetration study may be necessary. The Scottish Ministers advise that this should be fully addressed in the EIA Report and highlight the MCA advice on a maximum 5% reduction in surrounding depth referenced to Chart Datum if cable protection measures are required.” | MGN 654 requirements will be fully complied with including in relation to underkeel clearance. A Burial Protection Index study will be completed, and an anchoring penetration study if required, post-consent. See section 18.1. |
MD-LOT | Scoping Opinion | “With regards to the proposed mitigation in Section 7.2.5 of the Scoping Report, the Scottish Ministers highlight the representation from the RYA regarding its objection to operational safety zones, which should be taken into consideration when finalising the proposed designed in measures. In line with the representation from the MCA, the Developer should note that compliance with regulatory expectations for floating infrastructure, as stated in Section 7.2.5, is required and Third-Party Verification of the mooring arrangements will also be required.” | The project will determine safety zones to be applied for post-consent in consultation with key stakeholders including RYA Scotland. The Array application will include procedures by which the safety zones will be monitored and enforced. See section 18.1.
The requirements of the Regulatory Expectations will be followed, and a TPV of mooring arrangements will be undertaken. See section 2. |
MD-LOT | Scoping Opinion | “With regard to potential cumulative effects summarised in Section 7.2.8 of the Scoping Report, the Scottish Ministers are broadly content with the approach proposed and highlight the MCA requirement for an appropriate assessment of the distances between the neighbouring offshore renewable project boundaries and shipping routes in line with MGN Standard 654 which must be addressed in the EIA Report. In addition, the Scottish Ministers highlight the Cruising Association representation regarding increased concentration of traffic and advise that this must be fully considered in the EIA Report.” | Cumulative routeing has been assessed in section 14, with the assessment considering consultation undertaken with the MCA on distances to other projects as discussed within the relevant rows of this table.
Hazards to recreational vessels have been assessed in section 16. |
Relevant Consultation to Date | |||
Aurora Offshore | Email correspondence (Response received 15 May 2023) | “Navigation within wind farms is something we avoid today, unless there is a clear fairway indicated on the ENC charts allowing us to do so. There are a few farms off Holland and Belgium where this is allowed. However, the wind farms today are mostly bottom-fixed and fairly dense.
Ossian is a floating field, and with a 1,000 m spacing distance – we would have no objections sailing internally within the array – as long as the ENC charts and sailing directions in the area allows it. When looking at the planned footprint of Ossian and our historical navigation tracks in the same area, it is clear to us that sailing within the array is something we would have to do in order to avoid additional voyage lengths. That is extra cost and extra emissions on behalf of our clients.” | Post wind farm routeing has been assessed in section 13.4.2, with deviation assessed in section 16. |
Scotline | Email correspondence (Responses received 09 May 2023 and 10 May 2023) |
“This will affect our vessel trading patterns due to reduction of sea room and on the passage from Inverness – Rochester, Inverness – Humber, Inverness – Thames and the reverse routes.”
“It all depends on weather and traffic density”.
| Post wind farm routeing has been assessed in section 13.4.2, with deviation assessed in section 16. Adverse weather routeing is assessed in section 11.3.
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Smyril Line | Email correspondence (Responses received 10 May 2023, 17 May 2023, 15 March 2014) | “I can see that the windmills themselves will [sic] have 1 nm apart. This will make your vessel able to navigate between the windmills in good weather conditions only. And for the north sea aera [sic] we often have very poor weather conditions. So, during winter times the vessel will have to sail around the wind farm. And then it also depends on the precise position of the wind mills themselves + the depth of underwater installations to say if the vessel will safely be able to pass between the windmills. Then as I understand the windmills will be floating units, this will have them shifting in position or? Thinking about currents, waves and wind. All these factors and most likely other factors too will have to be considered for us in a risk assessment during passage planning. Vessel safe navigation will always have highest priority. Just for general information, the Smyril Line Cargo Company currently is operating two RO-RO vessels that transit this aera [sic] 2 times every week all year round. Total of 4 transits for both vessels every week. Route net for both vessels is Faroe Islands-Island-Rotterdam. We have already sailed passed the wave and lidar buoys many times. In the Morven site and for the Pentland side just SE of Sule Skerry and Sule Stack where there are also wave and lidar buoys placed”
“I have looked at the coordinates in your system and I can say that the Ossian project will have no impact on vessel movements. The vessel will navigate as normal with no changes in route network. However, the Morven north and south, is right on your [sic] current routes. But when this project starts the vessel will sail in between the two wind farms and it will not be necessary to go inside the wind farms themselves. See acc . Where all our normal routes are in the chart as orange lines and the projects are the blue lines. Here you can see very clearly that for the Morven project, the vessel will only do a small change in the passage planning for the transit in between the wind farms. Little to no extra distance will be added to our routes as this project starts. These projects Bellrock – Ossian – Morven S N. Will have very minimal to no impact on the Smyril Line Cargo Company’s ships”
“For us to go between the Windmill parks or we have to adjust our route a bit to the west, is no big deal [sic].”
It “will not make any big different [sic].”
| Commercial route deviations are assessed in section 13.4.2. Adverse weather routeing is assessed in section 11.3. Cumulative routeing is assessed in section 14. |
Tidewater | Email correspondence (Responses received 4 May 2023 and 5 May 2023) | “Any vessels we would have in or around that area would generally be on transit and would navigate well clear of any works or they may be involved in any of those projects and would navigate according to the scope of work as required.”
“I would imagine that North/South between Ossian and Seagreen[1] would be the route taken for vessels in transit providing it was safe to do so whilst keeping well clear of any hazards to navigation.” | Commercial route deviations are assessed in section 13.4.2. Cumulative routeing is assessed in section 14. |
Wilson Ship Management | Email correspondence (Responses received 15 May 2023 and 16 May 2023) | “Understand that our commercial division have given a general feedback at an earlier stage. At that time as minimal impact for Wilson. To be a bit more detailed, obviously we would ask our navigators to plan voyages around the area, not sailing in between, while transiting. While entering ports in the area, we would prefer sailing between cumulative arrays. Of other comments, given the additional network of cables etc at the seabed, and high-end equipment on the surface, I trust that plans for development of the area also include emergency preparedness in terms of towing/assist-vessels in case of loss of propulsion, drifting etc. There might be further limitations of performing emergency anchoring if needed. In addition, evaluate how to collect the seabed-cables in order to maximize the area around for possible emergency anchoring”.
“It will not be our preferred transit route through the area to the reduce the risk. Obviously I cannot guarantee that we will not use it (weather permitting etc), but based on our normal routes in the area, sailing through the Morven-Ossian-Bellrock will be limited while transiting in normal trade.” | Commercial route deviations are assessed in section 13.4.2. The risk related to interactions between anchors and subsea cables is assessed in section 16. |
MCA and NLB | Meeting on 20 June 2022 | Approach to NRA and data collection agreed.
Noted that the cumulative picture was important. | The approach to data collection, shipping and navigation study areas and NRA approach is as agreed with the MCA and NLB.
Cumulative assessment has been undertaken in sections 14 and 17. |
MCA | Meeting on 25 July 2023 | General discussions were held on the cumulative scenario, in particular around distances to nearby developments. | Associated assessment and summary of consultation is provided in section 14. |
MCA | Meeting on 25 July 2023 | MCA confirmed limited concern with use of HVDC interconnector cables in the Array in terms of potential EMF effects. | Potential EMF effects are assessed in section 12.6, with the assessment considering MCA consultation input. |
MCA | Meeting on 25 July 2023 | Confirmed content with study areas and data collection. | The approach to data collection, shipping and navigation study areas and NRA approach is as agreed with the MCA. |
UK CoS | Meeting on 31 July 2023 | Confirmed content with study areas and data collection. | The approach to data collection, shipping and navigation study areas and NRA approach is as agreed with the UK CoS. |
UK CoS | Meeting on 31 July 2023 | General discussions were held on the cumulative scenario, in particular around distances to nearby developments. | Associated assessment and summary of consultation is provided in section 14. |
NLB | Meeting on 28 August 2023 | Indicated preference for consistency in width of any navigable areas between wind farms. General discussions were held on the cumulative scenario, in particular around distances to nearby developments. | Associated assessment is provided in section 14. |
NLB | Meeting on 28 August 2023 | Noted that a scenario where a turbine with a marine light was towed away from the Array for maintenance would need further discussion in the LMP process. | Lighting and marking, in agreement with NLB, has been included as embedded mitigation (see section 18.1). |
NLB | Meeting on 28 August 2023 | Confirmed content with study areas and data collection. | The approach to data collection, shipping and navigation study areas and NRA approach is as agreed with the NLB. |
NLB, MCA and UK CoS | Meeting on the 10 October 2023 | General discussions were held on the cumulative scenario, in particular around distances to nearby developments. MCA and NLB confirmed content with the distance between the Array and the Bellrock array. | Considered in cumulative routeing assessment in section 14.2. |
NLB | Meeting on the 20 March 2024 | General discussions were held on the cumulative scenario, in particular cumulative routeing options for vessels. Agreed outputs of this NLB consultation include:
| Associated assessment is provided in section 14 which considers the output of the NLB consultation. |
UK CoS | Meeting on 23 April 2024 | General discussions around cumulative routeing options in the area. The UK CoS highlighted importance of maintaining optionality for vessel routeing within the region. | Associated assessment is provided in section 14 including cumulative routeing options available to vessels. |
MCA | Meeting on 02 May 2024 |
| Associated assessment is provided in section 14 which considers the output of the NLB consultation.
The MCA comment on sea room is noted, and final build out within the Array will be agreed with the MCA and NLB as part of the Development Specification and Layout Plan (DSLP) process, noting this will consider the most up to date cumulative picture at the time. |