2. Summary of Designed-In Measures, Mitigation and Monitoring Included in the Array EIA Report

  1. Table 2.1   Open ▸ provides a summary of the mitigation measures identified in the Array EIA Report relevant to the MPCP.

 

Table 2.1:
Mitigation Measures Relevant to the MPCP

Table 2.1: Mitigation Measures Relevant to the MPCP

3. Roles and Responsibilities

3.1. The Applicant

  1. The Applicant will contractually require Contractors and Subcontractors to take responsibility for pollution events originating from the Array.

3.2. The Applicant Environmental Manager

  1. The Applicant Environmental Manager for each phase of the Array is responsible for the overall preparation and implementation of the MPCP, including the following duties:
  • preparing and maintaining the MPCP to an agreed schedule; and
  • ensuring Contractors develop MPCPs (which should include adequate pollution prevention and spill response procedures), and ensuring that these are reviewed to an agreed schedule and implemented throughout operations.
  1. The Applicant Environmental Manager will review and update the MPCP as necessary during the construction phase of the Array to include any new information. Furthermore, this MPCP will also be reviewed and amended after construction is completed, to make it applicable to the operation and maintenance phase of the Array.
  2. The Applicant will appoint an Environmental Clerk of Work (ECoW), Marine Coordinator and a dedicated Spill Response Contractor for the Array.
  3. Following completion of construction, the Applicant Environmental Manager will ensure the MPCP is reviewed and amended annually or after significant legislative or procedural changes that would require updates to be made to this MPCP, as necessary for the operation and maintenance phase of the Array.
  4. The Applicant Environmental Manager will review and update this MPCP as required and to the agreed schedule during the construction phase of the Array (e.g. to take into account any new information, that may become available).
  5. In the event of any oil or chemical spill to the marine environment, following the completion of remedial action, an internal meeting will be held to close out the incident and ensure any lessons are learnt, which will be led by the Applicant Environmental Manager.

3.3. The Environmental Clerk of Works

  1. The Applicant will be required to appoint an ECoW, whose main responsibilities will include:
  • quality Assurance and approval of the Applicants MPCP and ensuring compliance with consent conditions, the EMP and other relevant consent plans;
  • review and approve all updates and amendments to the MPCP made by the Environmental Manager during all phases of the Array;
  • inductions and toolbox talks to Contractors and Subcontractors to ensuring implementation of the MPCP in accordance with consent conditions;
  • managing ongoing Contractor spill response (through liaison with Contractor);
  • ensuring delivery and compliance with this MPCP, including named personnel, appropriate resourcing and required processes are in place;
  • ensuring delivery of this MPCP in compliance with consent conditions, the EMP and other relevant consent plans as well a relevant legislation and policy; and
  • notifying statutory bodies of a spill, such as MCA, MD-LOT and SEPA and any relevant local authorities.

3.4. Marine Coordinator

  1. A Marine Coordinator will be appointed by the Applicant before construction at the Array commences. As well as coordinating the day to day vessel activity at the Array, the Marine Coordinator will be the main point of contact should an emergency or pollution event occur.
  2. As such, the Marine Coordinator will assist with the ongoing response in the event of a pollution incident from a vessel or vessel related activity, ensuring close communication between the Applicant and relevant Contractors/Subcontractors.
  3. The Marine Coordinator will also oversee the pollution response and any required clean-up operations should a pollution event occur from an Array installation activity.

3.5. Contractor and Subcontractor

  1. Most of the construction and operation and maintenance activities at the Array will be carried out by Contractors and/or Subcontractors, thus the Applicant will contractually require they are familiar with this MPCP.
  2. Furthermore, each Contractor/Subcontractor will be expected to prepare their own MPCP before activities commence at the Array. The Contractor/Subcontractor MPCP will be expected to comply with this MPCP and also to prepare their own spill response arrangements, including reporting and response procedures that ‘bridge’ to this MPCP. Each Contractor/Subcontractor will be expected to maintain a spill risk register for all equipment to be used at the Array.
  3. The Contractor/Subcontractor MPCP will be expected to be submitted to and reviewed/approved by the Applicant before being implemented at the Array. Once approved, it is expected it will be subject to an appropriate six-monthly review/update cycle and re-approved by the Applicant following each updated prior to implementation.
  4. All Contractor/Subcontractors will be expected to ensure relevant personnel are trained in pollution prevention and response and that vessel contain appropriate pollution response equipment.
  5. All vessels working in the Array will be subject to the requirements of the Applicant Vessel Inspection Procedure. In addition to this all vessels under the control of the Contractor/Subcontractor will be expected to have a SOPEP or equivalent vessel-specific spill plan (i.e. for spills originating from a vessel or as a result of activities carried out by the Contractor/Subcontractor).
  6. The Applicant will contractually require the Marine Coordinator to be notified by the Contractor/Subcontractor of any pollution incidents at the Array, together with any proposed response procedures.

3.6. Spill Response Contractor

  1. An oil spill response Contractor must be in place before construction commences at the Array.
  2. During the construction phase, the ECoW and the oil spill response Contractor will be required to provide response capabilities in accordance with the maximum adverse scenario associated with the Contractor/Subcontractor scope of work.
  3. During the operation and maintenance phase, the ECoW and the oil response Contractor will provide response capabilities, coordinating as necessary with the Environmental Manager, in relation to the maintenance activities carried out at the Array.
  4. In the unlikely event of a Tier 2/3 spill occurring, the decision on whether to engage a Tier 2/3 Contractor will be made by the Applicant in consultation with the Maritime and Coastguard Agency (MCA) and MD‑LOT.

3.7. Maritime and Coastguard Agency

  1. The MCA is designated as the UK Competent Authority for counter pollution response at the national level and is the custodian of the National Contingency Plan (NCP) which includes arrangements for dealing with pollution, or the threat of pollution, from shipping and offshore installations. The national regime lays down no rigid criteria for NCP activation however it is considered very unlikely that the NCP will be activated for spills originating from activities related to the Array due to the relatively low risk of spills from offshore wind farm activities.