5.4. Step 4 – Biosecurity Control Measures

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

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

Any man-made structure to be used for the Array 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 5.4.3.

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 Array will be included in this section.

All vessels to be used at the Array 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.

Implementation of these measures will be ensured by a requirement for all contractors to comply with this INNSMP by the Applicant.

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.

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 Array. 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.

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

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.

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 MD-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.