1. Introduction

1.1. Purpose

This outline Marine Pollution Contingency Plan (MPCP) provides the pollution response arrangements for the offshore infrastructure associated with the Ossian Offshore Wind Farm (hereafter referred to as “the Array”) during the construction and operation and maintenance phases.
The overall purpose of this MPCP is to provide a list of procedures to safeguard the marine environment and respond to any potential accidental pollution event during the above phases of the Array. The procedures for safeguarding the marine environment during the decommissioning phase will be provided in a separate MPCP once the final decommissioning plan and methodologies are developed.
This MPCP document represents best practice for pollution preparedness, and it is widely regarded within industry as best practice to have an MPCP in place where there is a risk of pollution, even when this is considered to be a low risk.
Where a marine pollution incident is part of a wider emergency such as a fire or explosion, reference should also be made to the Emergency Response Co-operation Plan (ERCoP), which will be produced post consent.

The Array is an offshore wind farm off the east coast of Scotland, approximately 80 km south-east of Aberdeen from the nearest point (see Figure 1.1 Open ▸ ).
The Array parameters have been selected from the Project Design Envelope (PDE) as assessed in the Array EIA Report. The Array will consist of the following:

up to 265 floating wind turbines (each comprising a tower section, nacelle, hub and three rotor blades) and associated floating foundations;
mooring and anchoring systems for each floating foundation;
connectors and ancillaries for mooring and anchoring systems, including buoyancy elements and clump weights;
up to six large Offshore Substation Platforms (OSPs), or up to three large OSPs and up to 12 small OSPs with fixed jacket foundations
scour protection per foundation for wind turbine anchoring systems;
scour protection for small and large OSP fixed foundations as required;
a network of dynamic/static inter-array cabling linking the individual floating wind turbines to each other and OSPs, and interconnector cables between OSPs (approximately 1,261 km of inter-array cabling and 236 km of interconnector cabling); and
discrete condition monitoring equipment (such as sensors, cameras, dataloggers etc.), as required for safe and efficient operation of the Array infrastructure.

Figure 1.1 Open ▸ : Location of the Array

This MPCP is an annex to the Array Environmental Management Plan (EMP) which covers measures to protect personnel and the marine environment relating to the marine works that will be undertaken as part of the Array (up to Mean High Water Springs (MHWS)) during the construction and operation and maintenance phases.
The MPCP provides the following information and guidelines to aid a response to an accidental release of pollutants into the marine environment resulting from activities associated with the Array:

a risk assessment of the potential pollution sources and the likelihood of an accidental release (section 4.2); and
oil spill response procedures and actions (section 5.1).

The information and guidelines presented in this outline MPCP will be reviewed in consultation with the Maritime and Coastguard Agency (MCA), Marine Directorate - Licencing Operations Team (MD-LOT) and Scottish Environment Protection Agency (SEPA) and will be re-submitted as a final draft prior to commencement of construction.
All personnel and Contractors (including any sub-contractors) involved in the Array will be required to comply with this MPCP and will be provided with a copy of the MPCP and will be familiarised with the content, including roles and responsibilities, through toolbox talks.
All vessel Contractors associated with the Array will also be expected to implement their own Ship-board Oil Pollution Emergency Plans (SOPEPs) (if applicable under the International Convention for the Prevention of Pollution from Ships (MARPOL) Convention (IMO, 2019) or their vessel specific spill plans in the event of an accidental marine pollution incident. This also applies to port side activities, with port authorities responsible for implementing specific spill/pollution plans.

Table 1.1 Open ▸ will summarise the conditions included in the Marine Licence(s) (under the Marine and Coastal Access Act 2009) (MCAA) and Section 36 Consent in relation to marine pollution.

The Applicant will refine the MPCP before commencing construction and review this plan on an annual basis thereafter, or after significant legislative or procedural changes that would require updates to be made to this MPCP.
In addition, the MPCP will be further refined in preparation for the operation and maintenance phase of the Array.