2. Part I: Management, Implementation and Communication

2.1. Roles and Responsibilities

2.1.1. Overview

  1. This section outlines the roles and responsibilities of all the Applicant personnel, Contractors and Subcontractors in relation to this EMP.
  2. The Applicant personnel, Contractors and Subcontractors must comply with the requirements of the final EMP and all relevant associated documents. They key roles relevant to this EMP are described in sections 2.1.2 to 2.1.4.
  3. The key roles with specific roles relating to the EMP are:
  • the Applicant Environmental Manager;
  • the Independent Environmental Clerk of Works (ECoW);
  • the Applicant Stakeholder Engagement Manager (SEM);
  • the Applicant Package Managers;
  • the Contractor’s/Subcontractor’s Environmental Manager;
  • the Contractor’s Community Liaison Manager (CLM);
  • Archaeological Contractor;
  • Marine Mammal Observer (MMO2) (if required);
  • Fisheries Liaison Officer (FLO);
  • Offshore Fisheries Liaison Officer (OFLO) and;
  • Marine Coordinator.
  1. These roles will be further defined and agreed with MD-LOT prior to the commencement of construction activities.

2.1.2. The Applicant: Key Management Roles Relating to Environmental Management

                        The Applicant Environmental Manager

  1. An Environmental Manager has been appointed since the development stage by the Applicant and will be in place for the construction phase of the Array, to manage ongoing compliance with the final EMP and all supporting documents, including those listed in section 1.4. An Environmental Manager will also be appointed by the Applicant to cover the operation and maintenance phase of the Array. The Applicant’s appointed Environmental Manager will have overall responsibility for discharging consent conditions including managing the delivery of all consent plans including this EMP. The Applicant’s appointed Environmental Manager will be supported by Package Managers who will be responsible for the engineering work packages covering marine installation, wind turbines and transmission systems during construction. The Package Managers will have similar responsibilities as those of the Applicant Environmental Manager but focussed on their specific package/work streams.
  2. An Environmental Manager, together with a SEM, will be appointed by the Applicant and in place throughout construction and operation and maintenance phases.
  3. The key responsibilities of the Applicant Environmental Manager may include:
  • monitoring compliance of all environmental responsibilities included in the EMP and supporting documents (e.g. consent management plans) are fulfilled for the construction and operation and maintenance phase of the Array;
  • Appointment and management of the Independent Environmental Clerk of Work (ECoW);
  • monitoring compliance of the Contractors/Subcontractors with the implementation of the EMP and its requirements;
  • monitoring compliance with contractual requirements, e.g. environmental management issues are covered in progress meetings relating to the Array, together with inductions and training; and that any corrective actions arising from environmental audits are addressed; and
  • reporting to the Applicant Senior Management Team.
  1. The list of responsibilities for the Applicant’s appointed Project Manager will be further refined as part of any required updates to this EMP prior to commencement of construction.

                        The Independent Environmental Clerk of Works

  1. The Applicant will be required to appoint an independent ECoW. The ECoW will need to be appointed pre-construction in time to review and approve the draft consent management plans prior to submission to MD-LOT for approval and will be required to remain in post throughout construction and into operation and maintenance phase of the Array.
  2. The Applicant’s appointed ECoW will report directly to the Applicant’s appointed Environmental Manager and will work in cooperation with Contractors and Subcontractors. The Applicant’s ECoW will also be required to agree a communication strategy with MD-LOT. The Applicant ECoW will notify all Array staff when environmental issues arise as well as inform the regulators and their statutory stakeholders as required of any non-compliance with the EMP.
  3. Key responsibilities of the Applicant ECoW are expected to include, based on conditions in previous Section 36 Consents issued for Scottish offshore wind farm projects:
    • quality assurance of final draft versions of all consent management plans and programmes required under the Section 36 Consent.
    • monitoring and reporting of compliance with the consent conditions and all environmental mitigation and monitoring measures included in the application for the Array.
    • provision of on-going advice and guidance to the Applicant in relation to achieving compliance with consent conditions, including but not limited to conditions relating to the implementation of consent management plans.
    • provision of reports on quality assurance and the Applicant’s consent compliance to MD-LOT at timescales to be determined by MD-LOT.
    • induction and toolbox talks to onsite construction teams on environmental policy and procedures, including temporary stops and keeping a record of these.
    • monitoring that the Array is being constructed in accordance with the consent management plans and in compliance with all relevant regulations and legislation.
    • supporting the promotion of a positive culture of environmental awareness throughout the construction and operation and maintenance phases of the Array, including increasing awareness of environmental considerations.
    • reviewing and reporting incidents/near misses and reporting any changes in procedures as a result to MD-LOT.
    • agreement of a communication strategy with MD-LOT.
    • ensuring that all of the ECoW environmental responsibilities included in the EMP and supporting documents are fulfilled for the construction phase and, when required, for the operation and maintenance phase of the Array.
    • offering an environmental presence and undertaking on-site audits throughout the construction phase to supervise the fulfilment by the Contractor and Subcontractors of their responsibilities regarding the Array EIA Report, EMP and supporting environmental documentation;
    • attending project meetings and contributing on environmental matters when required; and
    • supporting the Applicant Environmental Manager in liaising with stakeholders.

                        The Applicant Stakeholder Engagement Manager

  1. The Applicant SEM will be in position throughout Array lifetime to facilitate engagement with the community. The Applicant SEM will cooperate with the CLM appointed by the Contractor.

2.1.3. Contractors and Subcontractors

  1. The Contractor and all Subcontractors will be contractually required to comply with the required good environmental practice stated in the Array EIA Report, EMP, and associated Consent Management Plans, and ensure their works are fulfilling the stated requirements.
  2. The Contractor, in liaison with the Applicant, will update the EMP as necessary during the construction phase of the Array.
  3. A Contractor’s Environmental Manager with relevant experience and expertise will be hired by the Contractor throughout each phase of the Array. The Contractor’s Environmental Manager will verify the correct implementation on the Array of the environmental design, control and mitigation measures outlined in the Array EIA Report, EMP and supporting consent documentation.
  4. A Contractors’ CLM will liaise with the community during the construction phase of the Array.
  5. All of the Applicant’s Contractors and their Subcontractors will ensure that their works are in line with the requirements of the Array EIA Report and EMP.
  6. Key responsibilities of the Contractors/Subcontractor include:
  • ensuring all environmental responsibilities in relation to the Contractor/Subcontractors included in the EMP and supporting documents are fulfilled for the duration of the Array;
  • ensuring adequate resources and processes are in place to ensure compliance with the EMP and manage the potential environmental impacts of their activities;
  • providing risk assessments and method statements (RAMS) that address the environmental aspects of all planned activities prior to these works commencing. These RAMS will be approved by the Applicant and the Contractor/Subcontractor should provide RAMS for approval at least two weeks prior to commencement of works. RAMS will include proposed mitigation measures required for any work or task to be undertaken;
  • implementing required environmental control measures as stated in the Array EIA Report, EMP and supporting environmental documentation;
  • reading, understanding and complying with any consent conditions related to their activities;
  • maintaining regular communication with the Applicant Environmental Manager and the Applicant ECoW, principally to report any environmental risks, incidents or queries as a priority;
  • providing collated data required by the Applicant Environmental Manager collected from environmental monitoring, together with performing inspections and environmental reporting;
  • ensuring sufficient training and induction of all their personnel before the start of any work on the Array;
  • ensuring the competency of all staff under their supervision and that their tasks are undertaken in line with the EMP; and
  • complying with relevant environmental legislation and undertake their duties in line with Array environmental policies, plans, procedures and rules for the Array.
  1. This EMP will provide the minimum standards for all Contractors and Subcontractors to comply with. Any additional control measure identified during the review of their activities needs to be specified in Contractor/Subcontractor RAMS.

                        Contractor’s Environmental Manager

  1. The Contractor’s Environmental Manager will be a full-time position from the start of the Array contract to ensure compliant implementation of site activities. The Contractor’s Environmental Manager requires a minimum of five years of relevant site experience.
  2. The key responsibilities of the Contractor’s Environmental Manager include:
  • ensuring all environmental responsibilities relating to the Contractor’s Environmental Manager, including those in the EMP and supporting documents are fulfilled for the duration of the relevant phases of the Array;
  • ensuring that sufficient resources and process are available to deliver/comply with the EMP and to manage potential environmental impacts;
  • reviewing and regularly refining the EMP and supporting environmental documentation during the construction phase of the Array while ensuring consistency of these documents with the Array EIA Report. This will include incorporation of any environmental requirements introduced through the consents process. Any revisions to the EMP or supporting environmental documentation require approval by the Applicant Environmental Manager;
  • undertaking environmental audits, inspections and reporting to ensure the construction activities adhere to the Array EIA Report, EMP and any supporting environmental documentation;
  • collating and conducting an environmental monitoring programme and collating relevant environmental reports and records. All reports, records and monitoring programme require the approval of the Applicant Environmental Manager;
  • promoting a positive environmental culture via training and engagement with site management and site operatives, and promoting increased environmental awareness;
  • ensuring timeous remediation/reporting relating to any environmental incidents/non-compliance;
  • communicating statutory requirements and good environmental practices stated in the EMP by planning toolbox talks. These should be based on-site activities and updated to reflect any reports of non-compliance. These responsibilities should be communicated to all relevant Contractors/Subcontractors outlined in this EMP;
  • supervising and monitoring the implementation of, and ongoing compliance with the EMP;
  • advising Contractors and Subcontractors on compliance with the EMP; and
  • introducing site staff to the environmental policy, procedures and requirements of the EMP.

2.1.4. Supporting Environmental Roles

                        Archaeological Contractor

  1. The Archaeological Contractor will be in post throughout the construction phase, and, if required, during the operation and maintenance phase, and will be the first person that the Applicant Environmental Manager will contact relating to archaeological matters. The roles and responsibilities associated with the Archaeological Contractor are outlined in the WSI and PAD.

                        MMO2

  1. A MMO2 may be in post throughout noisy activities during the construction period if required. These periods and the roles and responsibilities associated with the MMO2 are outlined in the MMMP. In addition, a Passive Acoustic Monitoring (PAM) operator/Acoustic Deterrent Device (ADD) operator may also be in place, if required, and their associated roles and responsibilities are also outlined in the MMMP.

                        Fisheries Liaison Officer

  1. The Applicant will be required to appoint a Fisheries Liaison Officer (FLO). The main responsibilities of the FLO will include:
  • acting as key point of contact for the Array for fisheries stakeholders;
  • identifying commercial vessels and skippers operating in areas relevant to the Array and potential interactions of the Array and associated activities with fishing operation within and around the Array;
  • liaising with fisheries stakeholders through regular meetings and maintaining a vessel database, including vessel descriptions, information on fishing techniques deployed, skipper’s issues and contact details;
  • preparing and circulating information and notices (e.g. notices to mariners) relevant to the Array and associated activities that might interact with fisheries stakeholders;
  • establishing and maintaining a sound working relationship with the fishing industry and communicating, on behalf of the Applicant;
  • identifying and communicating to the Applicant relevant fishermen’s concerns and sensitivities in regard to the activities of the Array; and
  • acting as an OFLO, when necessary.

                        Offshore Fisheries Liaison Officer

  1. OFLOs will be appointed onboard survey and construction vessels to communicate with fisheries stakeholders at sea where this is deemed to be required.
  2. Main responsibilities of the OFLO will include:
  • communicating regularly with the FLO and the Applicant and/or their Contractors/Subcontractors regarding fishing vessel activities around the Array;
  • informing the master’s and watch officers of survey and construction vessels of fishing activities (including gears and operation methods) in the area surrounding their vessel working zone(s) along with communicating with the vessel masters to provide relevant details of fishing vessels (e.g. location, operation, schedule of activities and advisory safety zones);
  • liaising with fishermen who may have static gear deployed in the vicinity of the Array as well as around the Array advisory safety zones and vessel transit routes; and
  • collaborating with vessel master’s to ensure compliance with relevant aspects of the FMMS.

                        Marine Coordinator

  1. A Marine Coordinator shall be appointed for the Array. The key responsibility of the Marine Coordinator will be the coordination of day-to-day vessel activity associated with the Array.
  2. Some of the main duties of the Marine Coordinator in relation to the EMP include:
  • coordinating daily activities of vessel on the Array;
  • supporting the fulfilment of the requirements outlined in the EMP and relevant Consent Management Plans particularly regarding:
  • informing and advising other vessels working in the area of a potential archaeological discovery;
  • assisting in the coordination and execution of the planned response to a pollution incident from a vessel or vessel associated activity and keeping the Applicant informed (see MPCP). Key roles that will be kept informed will be the Applicant Project Manager, the Applicant Environmental Manager, the Applicant ECoW and relevant Contractors/Subcontractors; and
  • supervising the planned response and any clean-up operation required in the event of a spill originating from an installation of the Array (see MPCP).

2.1.5. Contact Details

  1. An Array Contacts Sheet will be compiled prior to the commencement of construction at the Array and included as an annex to the EMP. This list will include contact details of all Applicant, Contractor/Subcontractor and relevant third parties. This list will be made available to the Array Team and will be regularly updated throughout the construction and operation and maintenance phases.
  2. As a minimum, the Contacts Sheet will include the following information:
  • company/organisation;
  • position;
  • name;
  • telephone/mobile number;
  • email address; and
  • office location.