Tier 1

There were two Tier 1 projects identified with potential for in-combination effects associated with this impact:

Proposed offshore export cable corridor(s); and
Berwick Bank Offshore Wind Farm ( Table 6.77 Open ▸ ).

Currently, there is no EIA Report available for the Proposed offshore export cable corridor(s), though construction is likely to be of medium duration, with noise being intermittent. Although there is no information on construction activities associated with the Proposed offshore export cable corridor(s), it is not expected that piling will be included in the project description (as this is a cable project). As such, noise impacts which have the potential to affect prey species are expected to be limited to UXO clearance operations during site preparation. While there is no site-specific information on these impacts, it is expected they would be similar to those assessed for the project alone (i.e. minor significance, see volume 2, chapter 9 of the EIA Report).
The Berwick Bank Offshore Wind Farm underwater noise assessment considered effects (including mortality, injury and behavioural effects) on a similar range of fish and shellfish receptors as the Array alone (volume 2, chapter 9 of the Array EIA Report). The Berwick Bank assessment predicted that injurious effects on fish would be limited in extent and behavioural effects would occur across a wider area of up to tens of kilometres (SSE Renewables, 2022b). The effects would be temporary, reversible and would not result in significant effects on fish and shellfish receptors (SSE Renewables, 2022b). In the marine mammal assessment for the Berwick Bank EIA, changes in prey availability was therefore concluded to be of minor adverse significance for all species (SSE Renewables, 2022c).
The construction of the Array, and of Berwick Bank Offshore Wind Farm, will coincide for only two years (2031 and 2032). Furthermore, due to the large distance between the projects (56.84 km), there is limited potential for noise contours to interact. Given that UXO clearance is typically undertaken at the beginning of the construction phase, there is likely to be no temporal overlap in UXO clearance associated with the Array and Berwick Bank Offshore Wind Farm (where the construction phase is currently anticipated as 2025 to 2032 ( Table 6.57 Open ▸ ).
It is likely that the Tier 1 projects will involve similar designed in mitigation as the Array ( Table 6.43 Open ▸ ), such as piling soft starts and low order UXO disposal. These will reduce the risk of injury to prey fish species in the immediate vicinity of piling or UXO operations, either by allowing some species/individuals to flee the area before noise levels reach a level at which injury may occur, and/or by limiting the total amount of noise energy entering the environment.
With respect to indirect effects on marine mammals, no additional in-combination effects due to changes in prey availability are predicted (with no significant cumulative effects predicted for fish and shellfish species in the EIA Report). As discussed in the alone assessment (section 6.3.4), all marine mammals in this assessment are considered to be generalist opportunistic feeders and are thus not reliant on a single prey species. Given that marine mammals are wide-ranging in nature with the ability to exploit numerous food sources, there would be a variety of prey species available for marine mammal foraging.

Tier 2

In addition to the Tier 1 projects, there were three Tier 2 projects identified with potential for in-combination effects associated with this impact:

Morven Offshore Wind Farm;
Cenos Offshore Wind Farm; and
Salamander Offshore Wind Farm ( Table 6.77 Open ▸ ).

Currently, only Scoping Reports are available for the Tier 2 projects, though piling activities during their construction phases are expected to be similar in nature as that of the Array. Although information on hammer energies and piling durations are not available for the Tier 2 projects, the potential impact is likely to be of medium duration, with noise being intermittent during the construction phase. As detailed in Table 6.57 Open ▸ , the construction phase of the Morven Offshore Wind Farm is anticipated to largely overlap temporally with that of the Array, however dates are currently unavailable for the other two Tier 2 projects.
It is likely that the Tier 2 projects will involve similar designed in mitigation as the Array ( Table 6.43 Open ▸ ), such as piling soft starts and low order UXO disposal. These will reduce the risk of injury to prey fish species in the immediate vicinity of piling or UXO operations, either by allowing some species/individuals to flee the area before noise levels reach a level at which injury may occur, and/or by limiting the total amount of noise energy entering the environment.
Within the fish and shellfish ecology CEA (volume 2, chapter 9 of the Array EIA Report), cumulative effects from underwater noise were assessed as being of minor adverse significance for all fish and shellfish receptors in the Tier 2 assessment. With respect to indirect effects on marine mammals, no additional in-combination effects due to changes in prey availability are predicted (as no significant cumulative effects predicted for fish and shellfish in the EIA Report). As discussed in the alone assessment (section 6.3.4), all marine mammals in this assessment are considered to be generalist opportunistic feeders and are thus not reliant on a single prey species. Given that marine mammals are wide-ranging and highly mobile in nature with the ability to exploit numerous food sources, there would be a variety of prey species available for marine mammal foraging.

Tier 3

In addition to the Tier 1 and Tier 2 projects, there were seven Tier 3 projects identified with potential for in-combination effects associated with this impact:

Morven Offshore Export Cable Corridor(s);
Bellrock Offshore Wind Farm;
Bowdun Offshore Wind Farm;
Campion Offshore Wind Farm;
Cedar Offshore Wind Farm;
Flora Floating Wind Farm;
Aspen Offshore Wind Farm ( Table 6.77 Open ▸ ).

Tier 3 projects are in a pre-application phase and no EIA Scoping Report, EIA Report, or HRA documentation are available to inform a quantitative assessment. Therefore, a qualitative assessment is provided below.
As these are Tier 3 projects, there are no Scoping Reports in the public domain. Therefore, there is no information available on the potential impact that these Tier 3 projects will have on prey fish species, although piling activities during the construction phase are expected to be similar in nature as that of the Array. Whilst information on hammer energies and piling durations are not available for the Tier 3 projects, the potential impact is likely to be of medium duration, with noise being intermittent during the construction phase.
The maximum duration of the offshore construction phase for the Array is up to eight years (2031 to 2038). There is currently no information available on the various Tier 3 projects; therefore, a precautionary assumption has been made that these may have overlapping piling phases with the Array ( Table 6.57 Open ▸ ). Therefore, there may be minimal temporal overlap between the construction activities of the Array and that of the Tier 3 projects, and thus, reduced potential for in-combination effects associated with this impact.
It is likely that the Tier 3 projects will involve similar designed in mitigation as the Array ( Table 6.43 Open ▸ ), such as piling soft starts and low order UXO disposal. These will reduce the risk of injury to prey fish species in the immediate vicinity of piling or UXO operations, either by allowing some species/individuals to flee the area before noise levels reach a level at which injury may occur, and/or by limiting the total amount of noise energy entering the environment.
Within the fish and shellfish ecology CEA (volume 2, chapter 9 of the Array EIA Report), cumulative effects from underwater noise were assessed as being of minor adverse significance for all fish and shellfish receptors in the Tier 3 assessment. With respect to indirect effects on marine mammals, no additional in-combination effects due to changes in prey availability are predicted (as no significant cumulative effects predicted for fish and shellfish in the EIA Report). As discussed in the alone assessment (section 6.3.4), all marine mammals in this assessment are considered to be generalist opportunistic feeders and are thus not reliant on a single prey species. Given that marine mammals are wide-ranging and mobile in nature with the ability to exploit numerous food sources, there would be a variety of prey species available for marine mammal foraging.

Construction phase

Berwickshire and North Northumberland Coast SAC

Grey seal

Tier 1

The results of the underwater noise modelling for the Array alone suggest that prey species may be impacted due to underwater noise up to tens of kilometres from the site boundary (volume 2, chapter 9 of the EIA Report). Similarly, ranges of injury and disturbance to prey species from piling and UXO clearance at Berwick Bank were predicted to be limited in extent, with behavioural effects potentially occurring over a wider area of up to tens of kilometres (SSE Renewables, 2022b). Although there is no information on construction activities associated with the Proposed offshore export cable corridor(s), it is expected they would be similar to those assessed for the project alone (i.e. minor significance, see volume 2, chapter 9 of the EIA Report). Therefore, underwater noise only has the potential to impact prey species over a relatively small area in terms of the regional marine mammal study area as a whole.
As detailed in the assessment on the Array alone (section 6.3.4), the availability of wider suitable foraging habitat across the regional marine mammal study area suggests that grey seals would not be impacted by any localised and intermittent changes in prey availability associated with the Array in-combination with the Tier 1 projects. It is expected that the grey seal population would be able to tolerate the effect without any potential impact on reproduction and survival rates.
Overall, this potential impact is not predicted to result in adverse effects (i.e. disruption to foraging) for the grey seal feature of this SAC as a result of the Array in-combination with the Tier 1 projects.

Tier 2

The Tier 2 assessment, presented in paragraphs 939 et seq., concluded that in-combination effects are unlikely to occur. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect for this potential impact associated with the Tier 2 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 2 projects will not have an adverse effect on the integrity of the grey seal feature of this SAC.

Tier 3

The Tier 3 assessment, presented in paragraphs 943 et seq., highlighted that it was not possible to undertake any meaningful in-combination assessment for the nine Tier 3 projects identified for this impact. This was due to the lack of publicly available information surrounding piling and UXO clearance parameters. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect for this potential impact associated with the Tier 3 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 3 projects will not have an adverse effect on the integrity of the grey seal feature of this SAC.

Conclusion

Adverse effects on the qualifying Annex II marine mammal features of the Berwickshire and North Northumberland Coast SAC which undermine the conservation objectives of the SAC will not occur as a result of in-combination changes in prey availability during the construction phase. Potential effects from this activity on the relevant conservation objectives (as presented in in section 6.2.1) are discussed in turn below in Table 6.78 Open ▸ .

Table 6.78: Conclusions Against the Conservation Objectives of the Berwickshire and North Northumberland Coast SAC from Changes in Prey Availability during the Construction Phase of the Array In-Combination with other Plans and Projects

Feature	Conservation Objectives (Natural England, 2020)	Conclusion
Grey seal	The extent and distribution of qualifying natural habitat and habitats of the qualifying species are maintained	There is no pathway for potential impact between changes in prey availability and the extent, distribution, structure and function of habitats and supporting processes of grey seal. Overall, this impact, associated with the Array in-combination with other plans and projects, will not prevent these conservation objectives from being maintained.
	The structure and function of the habitats of the qualifying species are maintained
	The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely are maintained
	The populations of each of the qualifying species are maintained	Impacts to prey species are predicted to be insignificant, and grey seal expected to adapt and recover quickly. Further, due to the availability of wide foraging habitat in the regional marine mammal study area, and the wide foraging nature of grey seals (up to and over 100 km (SCOS, 2023), this species is likely to be tolerant to localised changes in prey availability As such there is a negligible risk of disruption of foraging activities of grey seal. Therefore, changes in prey availability associated with underwater noise in the construction phase of the Array in-combination with other plans and projects will not affect the survivability and reproductive potential of grey seal within the SAC. Similarly, changes in prey availability will not significantly disturb the species. As such, and with additional consideration of the designed in measures, changes in prey availability are not predicted to prevent the population or distribution of grey seal within the site from being maintained.
	The distribution of qualifying species within the site are maintained

It can be concluded, beyond reasonable scientific doubt, that there is no risk of an adverse effect on the integrity of the Berwickshire and North Northumberland Coast SAC as a result of changes in prey availability in the construction phase of the Array in-combination with other plans and projects.

Southern North Sea SAC

Harbour porpoise

Tier 1

The results of the underwater noise modelling for the Array alone suggest that prey species may be impacted due to underwater noise up to tens of kilometres from the site boundary (volume 2, chapter 9 of the EIA Report). Similarly, ranges of injury and disturbance to prey species from piling and UXO clearance at Berwick Bank were predicted to be limited in extent, with behavioural effects potentially occurring over a wider area of up to tens of kilometres (SSE Renewables, 2022b). Although there is no information on construction activities associated with the Proposed offshore export cable corridor(s), it is expected they would be similar to those assessed for the project alone (i.e. minor significance, see volume 2, chapter 9 of the EIA Report). Therefore, underwater noise only has the potential to impact prey species over a relatively small area in terms of the regional marine mammal study area as a whole.
As detailed in the assessment on the Array alone (section 6.3.4), the availability of wider suitable foraging habitat across the regional marine mammal study area and the generalist feeding habits of harbour porpoise suggests that individuals would not be impacted by any localised and intermittent changes in prey availability associated with the Array in-combination with the Tier 1 projects. It is expected that the harbour porpoise population would be able to tolerate the effect without any potential impact on reproduction and survival rates.
Overall, this potential impact is not predicted to result in adverse effects (i.e. disruption to foraging) for the harbour porpoise feature of this SAC as a result of the Array in-combination with the Tier 1 projects.

Tier 2

The Tier 2 assessment, presented in paragraphs 939 et seq., concluded that in-combination effects are unlikely to occur. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect for this potential impact associated with the Tier 2 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 2 projects will not have an adverse effect on the integrity of the harbour porpoise feature of this SAC.

Tier 3

The Tier 3 assessment, presented in paragraphs 943 et seq., highlighted that it was not possible to undertake any meaningful in-combination assessment for the nine Tier 3 projects identified for this impact. This was due to the lack of publicly available information surrounding piling and UXO clearance parameters. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect for this potential impact associated with the Tier 3 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 3 projects will not have an adverse effect on the integrity of the harbour porpoise feature of this SAC.

Conclusion

Adverse effects on the qualifying Annex II marine mammal features of the Southern North Sea SAC which undermine the conservation objectives of the SAC will not occur as a result of in-combination changes in prey availability during the construction phase. Potential effects from this activity on the relevant conservation objectives (as presented in section 6.2.2) are discussed in turn below in Table 6.79 Open ▸ .

Table 6.79: Conclusions Against the Conservation Objectives of the Southern North Sea SAC from Changes in Prey Availability during the Construction Phase of the Array In-Combination with other Plans and Projects

Feature	Conservation Objectives (JNCC and Natural England, 2019)	Conclusion
Harbour porpoise	1. Harbour porpoise is a viable component of the site	In-combination impacts to prey species are predicted to be insignificant, and harbour porpoise are expected to adapt and recover quickly. This is due to their generalist feeding strategy, highly mobile nature, and wide distributional range. As such there is a negligible risk of disruption of foraging activities of harbour porpoise. Therefore, changes in prey availability associated with underwater noise in the construction phase of the Array in-combination with other plans and projects will not affect the survivability and reproductive potential of harbour porpoise within the SAC and they will remain a viable component of the site. Similarly, changes in prey availability will not significantly disturb the species. As such, and with additional consideration of the designed in measures, changes in prey availability are not predicted to impact the population from being able to maintain itself as a viable component of the site or cause significant disturbance to harbour porpoise.
	2. There is no significant disturbance of the species
	3. The condition of supporting habitats and processes, and the availability of prey is maintained	There is no pathway for potential impact between changes in prey availability and the habitats and supporting processes of harbour porpoise. There were no significant adverse impacts predicted for fish and shellfish species in the Berwick Bank EIA (SSE Renewables, 2022b) or the Array alone (see volume 2, chapter 9 of the Array EIA Report). There was insufficient publicly available information on the impacts of the other Tier 1, 2, and 3 projects on prey fish species. However, due to the availability of wide foraging habitat in the regional marine mammal study area, this species is likely to be tolerant to localised changes in prey availability. Therefore, this impact, associated with the Array in-combination with other plans and projects, will not prevent this conservation objective from being maintained.

It can be concluded, beyond reasonable scientific doubt, that there is no risk of an adverse effect on the integrity of the Southern North Sea SAC as a result of changes in prey availability in the construction phase of the Array in-combination with other plans and projects.

Moray Firth SAC

Bottlenose dolphin

Tier 1

The results of the underwater noise modelling for the Array alone suggest that prey species may be impacted due to underwater noise up to tens of kilometres from the site boundary (volume 2, chapter 9 of the EIA Report). Similarly, ranges of injury and disturbance to prey species from piling and UXO clearance at Berwick Bank were predicted to be limited in extent, with behavioural effects potentially occurring over a wider area of up to tens of kilometres (SSE Renewables, 2022b). Although there is limited information on construction activities associated with the Proposed offshore export cable corridor(s), it is expected they would be similar to those assessed for the project alone (i.e. minor significance, see volume 2, chapter 9 of the EIA Report). Therefore, underwater noise only has the potential to impact prey species over a relatively small area in terms of the regional marine mammal study area as a whole.
As detailed in the assessment on the Array alone (section 6.3.4), the availability of wider suitable foraging habitat across the regional marine mammal study area and the generalist feeding habits of bottlenose dolphin suggests that individuals would not be impacted by any localised and intermittent changes in prey availability associated with the Array in-combination with the Tier 1 projects. It is expected that the bottlenose dolphin population would be able to tolerate the effect without any potential impact on reproduction and survival rates.
Overall, this potential impact is not predicted to result in adverse effects (i.e. disruption to foraging) for the bottlenose dolphin feature of this SAC as a result of the Array in-combination with the Tier 1 projects.

Tier 2

The Tier 2 assessment, presented in paragraphs 939 et seq., concluded that in-combination effects are unlikely to occur. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect for this potential impact associated with the Tier 2 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 2 projects will not have an adverse effect on the integrity of the bottlenose dolphin feature of this SAC.

Tier 3

The Tier 3 assessment, presented in paragraphs 943 et seq., highlighted that it was not possible to undertake any meaningful in-combination assessment for the nine Tier 3 projects identified for this impact. This was due to the lack of publicly available information surrounding piling and UXO clearance parameters. The CEA presented in the Array EIA Report (volume 2, chapter 10 of the Array EIA Report) concluded a minor significance of effect associated with the Tier 3 projects. Based on this, it is concluded that in-combination changes in prey availability associated with at the Array and the Tier 3 projects will not have an adverse effect on the integrity of the bottelenose dolphin feature of this SAC.

Conclusion

Adverse effects on the qualifying Annex II marine mammal features of the Moray Firth SAC which undermine the conservation objectives of the SAC will not occur as a result of in-combination changes in prey availability during the construction phase. Potential effects from this activity on the relevant conservation objectives (as presented in section 6.2.3) are discussed in turn below in Table 6.80 Open ▸ .

Table 6.80: Conclusions Against the Conservation Objectives of the Moray Firth SAC from Changes in Prey Availability during the Construction Phase of the Array In-Combination with other Plans and Projects

Feature	Conservation Objectives (NatureScot, 2021)	Conclusion
Bottlenose dolphin	2a. The population of bottlenose dolphin is a viable component of the site	In-combination impacts to prey species are predicted to be insignificant, and bottlenose dolphin are expected to adapt and recover quickly. As such there is a negligible risk of disruption of foraging activities of bottlenose dolphin. Therefore, changes in prey availability associated with underwater noise in the construction phase of the Array in-combination with other plans and projects will not affect the survivability and reproductive potential of this species within the SAC and they will remain a viable component of the site. Similarly, changes in prey availability will not significantly disturb bottlenose dolphin. This is due to their generalist feeding strategy and wide ranging nature. As such, and with additional consideration of the designed in measures, changes in prey availability are not predicted to impact the population from being able to maintain itself as a viable component of the site, impact the distribution, orcause significant disturbance to bottlenose dolphin.
2b. The distribution of bottlenose dolphin throughout the site is maintained by avoiding significant disturbance
2c. The supporting habitats and processes relevant to bottlenose dolphin and the availability of prey for bottlenose dolphin are maintained	There is no pathway for potential impact between changes in prey availability and the habitats and supporting processes of bottlenose dolphin. There were no significant adverse impacts predicted for fish and shellfish species in the Berwick Bank EIA (SSE Renewables, 2022b) or the Array alone (see volume 2, chapter 9 of the Array EIA Report). There was insufficient publicly available information on the impacts of the other Tier 1, 2, and 3 projects on prey fish species. However, due to the availability of wide foraging habitat in the regional marine mammal study area, this species is likely to be tolerant to localised changes in prey availability. Therefore, this impact, associated with the Array in-combination with other plans and projects, will not prevent this conservation objective from being maintained.

Feature

Conservation Objectives (NatureScot, 2021)

Conclusion

Bottlenose dolphin

2a. The population of bottlenose dolphin is a viable component of the site

In-combination impacts to prey species are predicted to be insignificant, and bottlenose dolphin are expected to adapt and recover quickly. As such there is a negligible risk of disruption of foraging activities of bottlenose dolphin. Therefore, changes in prey availability associated with underwater noise in the construction phase of the Array in-combination with other plans and projects will not affect the survivability and reproductive potential of this species within the SAC and they will remain a viable component of the site. Similarly, changes in prey availability will not significantly disturb bottlenose dolphin. This is due to their generalist feeding strategy and wide ranging nature. As such, and with additional consideration of the designed in measures, changes in prey availability are not predicted to impact the population from being able to maintain itself as a viable component of the site, impact the distribution, orcause significant disturbance to bottlenose dolphin.

2b. The distribution of bottlenose dolphin throughout the site is maintained by avoiding significant disturbance

2c. The supporting habitats and processes relevant to bottlenose dolphin and the availability of prey for bottlenose dolphin are maintained

There is no pathway for potential impact between changes in prey availability and the habitats and supporting processes of bottlenose dolphin. There were no significant adverse impacts predicted for fish and shellfish species in the Berwick Bank EIA (SSE Renewables, 2022b) or the Array alone (see volume 2, chapter 9 of the Array EIA Report). There was insufficient publicly available information on the impacts of the other Tier 1, 2, and 3 projects on prey fish species. However, due to the availability of wide foraging habitat in the regional marine mammal study area, this species is likely to be tolerant to localised changes in prey availability. Therefore, this impact, associated with the Array in-combination with other plans and projects, will not prevent this conservation objective from being maintained.

It can be concluded, beyond reasonable scientific doubt, that there is no risk of an adverse effect on the integrity of the Moray Firth SAC as a result of changes in prey availability in the construction phase of the Array in-combination with other plans and projects.

6.4.6. Entanglement

The LSE2 assessment during the HRA Stage One process identified that LSE2 could not be ruled out for entanglement in the operation and maintenance phase of the Array in-combination with other plans and projects. This relates to the following sites and relevant Annex II marine mammal features:

Berwickshire and North Northumberland Coast SAC;

– grey seal.

Southern North Sea SAC; and

– harbour porpoise.

Moray Firth SAC;

– bottlenose dolphin.

The MDS considered for this in-combination assessment is shown in Table 6.81 Open ▸ . The secondary mitigation measures are presented in Table 6.48 Open ▸ for the assessment of the Array alone. Fixed bottom projects were screened out of the in-combination assessment on the basis that there are no mooring lines or dynamic cabling in the water column that could present a risk of primary or secondary entanglement to marine mammals.

Table 6.81: MDS Considered for the Assessment of Potential Impacts to Annex II Marine Mammals due to Entanglement during the Operation and Maintenance Phase of the Array In-Combination with other Plans and Projects

Project Phase	Tier	MDS
Operation and maintenance phase	1	There were no Tier 1 projects identified within the 50 km search buffer for this impact.
2	There were no Tier 2 projects identified within the 50 km search buffer for this impact.
3	The MDS is as described above for the Array alone ( Table 6.47 Open ▸ ) assessed in-combination with operation and maintenance phases of the following projects within the 50 km search buffer: Bellrock Offshore Wind Farm; and Campion Offshore Wind Farm.

Project Phase

Tier

MDS

Operation and maintenance phase

There were no Tier 1 projects identified within the 50 km search buffer for this impact.

There were no Tier 2 projects identified within the 50 km search buffer for this impact.

The MDS is as described above for the Array alone ( Table 6.47 Open ▸ ) assessed in-combination with operation and maintenance phases of the following projects within the 50 km search buffer:

Bellrock Offshore Wind Farm; and
Campion Offshore Wind Farm.

In-combination assessment

There is the potential for in-combination impacts due to changes in prey availability in the construction phase of the Array and other plans and projects. For the purposes of this assessment, this potential impact has been assessed using the tiered approach outlined in section 4.6. The plans and projects screened into the in-combination assessment for this potential impact and their respective tiers are outlined in Table 6.81 Open ▸ .

Tier 1 and 2

There were no Tier 1 or Tier 2 projects identified with the potential for entanglement risk (i.e. floating offshore wind projects) within the 50 km search buffer.

Tier 3

There were two Tier 3 floating offshore wind projects identified within the 50 km buffer region with potential for in-combination effects associated with this impact:

Bellrock Offshore Wind Farm; and
Campion Offshore Wind Farm ( Table 6.81 Open ▸ ).

These Tier 3 projects are in a pre-application phase and no EIA Scoping Report, EIA Report, or HRA Documentation are available to inform a quantitative assessment. Therefore, a qualitative assessment is provided below.
As described in Table 6.48 Open ▸ for the Array alone, mooring lines and dynamic inter-array cables are likley to undergo routine inspections during the operation and maintenance phase, employing a risk-based adaptive management approach. All Tier 3 projects are located in excess of 50 km from the site boundary except for Bellrock, Bowdun, and Campion Offshore Wind Farms ( Figure 6.13 Open ▸ ). Of these projects only Bellrock and Campion Offshore Wind Farms are floating projects and may contribute to the cumulative impacts of entanglement. Only floating offshore wind farms have been considered in this in-combination assessment, as there is no risk of entanglement from fixed bottom wind farms (due to their lack of mooring lines).
The risks of entanglement from floating offshore wind farms are not fully understood (see paragraphs 700 et seq.) but the commitment of the Array to monitor and manage the risks ( Table 6.48 Open ▸ ) will reduce any potential contribution to in-combination effects with other projects. There are no published standard industry measures at the time of writing but should other wind projects adopt a similar 'monitor and manage' approach, it is likely that the potential for in-combination effects would be further reduced. Considering the implementation of these designed in measures during the operations and maintenance phase of the Array, the potential for in-combination effects resulting from entanglement is considered very unlikely.
The risk of entanglement due to presence of mooring lines and dynamic inter-array cables in the water column is predicted to be of very local spatial extent in the context of the geographic frame of reference. It is predicted that the potential impact will affect marine mammals directly in the case of both (rare) primary entanglement and secondary entanglement, however the risk of secondary entanglement is sufficiently reduced with the application of the designed in mitigation measures (routine surveys and removal of marine debris as required following inspection) and any population-level effects are highly unlikely ( Table 6.48 Open ▸ ). Based on this, it is concluded that in-combination entanglement associated with the Array and the Tier 3 projects will not have an adverse effect on the integrity of the marine mammal features of the SACs assessed in this Part of the RIAA.

Operation and maintenance phase

Berwickshire and North Northumberland Coast SAC

Grey seal

As detailed in paragraphs 974 et seq., there were only two Tier 3 projects identified for in-combination assessment associated with this impact: Bellrock and Campion Offshore Wind Farms. Due to the lack of publicly available information on these projects, only a qualitative assessment was provided. Based on the assessment in paragraphs 974 et seq., it has been concluded that population-level effects on the grey seal feature of this SAC are highly unlikely.

Conclusion

Adverse effects on the qualifying Annex II marine mammal features of the Berwickshire and North Northumberland Coast SAC which undermine the conservation objectives of the SAC will not occur as a result of in-combination entanglement during the operation and maintenance phase. Potential effects from this activity on the relevant conservation objectives (as presented in in section 6.2.1) are discussed in turn below in Table 6.82 Open ▸ .

Table 6.82: Conclusions Against the Conservation Objectives of the Berwickshire and North Northumberland Coast SAC from Entanglement during the Operation and Maintenance Phase of the Array In-Combination with other Plans and Projects

Feature	Conservation Objectives (Natural England, 2020)	Conclusion
Grey seal	The extent and distribution of qualifying natural habitat and habitats of the qualifying species are maintained	There is no pathway for potential impact between in-combination entanglement and the extent, distribution, structure and function of habitats and the supporting processes of grey seal. Therefore, this potential impact will not prevent these conservation objectives from being maintained as a result of the Array in-combination with Tier 3 projects.
	The structure and function of the habitats of the qualifying species are maintained
	The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely are maintained
	The populations of each of the qualifying species are maintained	As concluded from the background literature reviewed in paragraphs 700 et seq., population-level effects on grey seal due to entanglement are not likely to occur. The, already low, but increased risk of entanglement associated with the Array in-combination with the Tier 3 projects will also not affect areas important for breeding and pupping within the SAC (which is 113.95 km away from the site boundary), and therefore grey seal will remain a viable component of the site. Further, as individuals typicaly remain within 20 km of the coast during the breeding season (pers. comm. NatureScot), the potential for individals to experience entanglement is further reduced during this key iife cycle stage (given the 113.95 km distance to the site boundary). Overall, including the implementation of designed in mitigation measures of regular inspections of mooring lines and dynamic cables, entanglement will not prevent the population or distribution of grey seal within the site from being maintained as a result of the Array in-combination with Tier 3 projects.
	The distribution of qualifying species within the site are maintained

It can be concluded, beyond reasonable scientific doubt, that there is no risk of an adverse effect on the integrity of the Berwickshire and North Northumberland Coast SAC as a result of entanglement during the operation and maintenance phase of the Array in-combination with other plans and projects.

Southern North Sea SAC

Harbour porpoise

As detailed in paragraphs 974 et seq., there were only two Tier 3 projects identified for in-combination assessment associated with this impact: Bellrock and Campion Offshore Wind Farms. Due to the lack of publicly available information on these projects, only a qualitative assessment was provided here. Based on the assessment in paragraphs 974 et seq., it has been concluded that population-level effects on the harbour porpoise feature of this SAC are highly unlikely.

Conclusion

Adverse effects on the qualifying Annex II marine mammal features of the Southern North Sea SAC which undermine the conservation objectives of the SAC will not occur as a result of in-combination entanglement during the operation and maintenance phase. Potential effects from this activity on the relevant conservation objectives (as presented in section 6.2.2) are discussed in turn below in Table 6.83 Open ▸ .

Table 6.83: Conclusions Against the Conservation Objectives of the Southern North Sea SAC from Entanglement during the Operation and Maintenance Phase of the Array In-Combination with other Plans and Projects

Feature	Conservation Objectives (JNCC and Natural England, 2019)	Conclusion
Harbour porpoise	1. Harbour porpoise is a viable component of the site	As concluded from the background literature reviewed in paragraphs 700 et seq., population-level effects on harbour porpoise due to entanglement are not likely to occur. The, already low, but increased risk of entanglement associated with the Array in-combination with the Tier 3 projects will also not affect areas important for breeding and calving within the SAC (which is 129.86 km away from the site boundary), and therefore harbour porpoise will remain a viable component of the site. Overall, including the implementation of designed in mitigation measures of regular inspections of mooring lines and dynamic cables, entanglement is not predicted to impact the population from being able to maintain itself as a viable component of the site or cause significant disturbance to the species.
	2. There is no significant disturbance of the species
	3. The condition of supporting habitats and processes, and the availability of prey is maintained	There is no pathway for potential impact between in-combination entanglement and the habitats, supporting processes, and prey species of harbour porpoise. Therefore, this potential impact will not prevent this conservation objective from being maintained as a result of the Array in-combination with Tier 3 projects.

It can be concluded, beyond reasonable scientific doubt, that there is no risk of an adverse effect on the integrity of the Southern North Sea SAC as a result of entanglement during the operation and maintenance phase of the Array in-combination with other plans and projects.

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