marine licensing signposts roger may marine scotland, marine laboratory, aberdeen
TRANSCRIPT
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Marine Licensing Signposts
Roger MayMarine Scotland, Marine Laboratory, Aberdeen
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Today’s presentation- Signposts
• Decommissioning• MCA SAR• New SPA and SAC
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Decommissioning• Issue decommissioning of renewables is not covered
fully by current legislation
• Decommissioning of offshore renewable energy installations under the Energy Act 2004
• The key decommissioning provisions in the Energy Act 2004 (Sections 105 to 114) are explained in Annex B. Broadly speaking, the Secretary of State may require a person who is responsible for an offshore renewable energy installation to prepare a costed decommissioning programme and ensure that it is (eventually) carried out. The Secretary of State can approve, modify or reject a programme, including any financial security provisions which the responsible person proposes to provide. The Secretary of State is required to review the programme from time to time.
• used (or will be used or have been used) for purposes connected with the production of energy from water or winds; and
• b) permanently rest on, or are permanently attached to, the bed of the waters; and
• c) are not connected with dry land by a permanent structure providing access at all times for all purposes.
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Decommissioning Scotland
• Projects outside definition:-• Limpet • Siadar• EMEC nursery sites?• Samsung- Methil• SOLWAY Tidal Lagoon hence need to change legislation
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What LOT is working on• Licences issued have been for deposit and maintenance of structures.
Conditions require final removal but do not consent it. Therefore need another licence to remove.
• Licenced removal of Open Hydro
• Working on Draft Marine Licence of Limpet• Draft Marine Licence for removal APL Oyster at EMEC• Draft Voith at EMEC• Robin Rigg remove two turbines and construct 2 new. Operation and
maintenance or decommissioning?)
• Issues legacy- reassign partial assets to EMEC with responsibility for decommissioning maintained. Assets remaining are defined in the removal licence and the licence can then be transferred.
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MSLOT
• Working with DECC and TCE to ensure works are appropriately bonded.
• Working at EMEC to include assessment of decommissioning in the marine licence for deposit through joint consultation
at the licensing stage.• This will allow us to include a better link to decommissioning in our licences
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MAC Search and Rescue• Issue SAR assessments had not taken place
during the application process.• Issue with windfarms Oct 2014• Letter to industry including wave and tide Jan
2015
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Issues to Note
• Layouts need to be informed to MCA SAR very early in the process – before Geo Tech survey decisions.
• MCA noting increasing SAR risks and cumulative effects.
• MCA taking a more strategic view of wind farms as SAR problem.
• Adjacent wind farms need more careful analysis and may require aligned layouts.
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Issues to Note
• Spacing between turbines for SAR helicopters.• Helicopter Airspace gap between adjacent
wind farms.• Other mitigation requirements may be needed
(AIS, radar, VHF DSC and Voice radio, real time weather).
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Considerations
• Common alignment • Safe distance• Track spacing• High density boundary
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Consent Methodology
• Complex and involves a number of government departments
with a variety of perspectives
• Historically emphasis has been on position and plan view of
development
• Positioning of individual structures just as important
• In future MCA needs be consulted much earlier and before
any investment on geotech work
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Way ahead
• Working with developers on a case-by-case basis.
• MCA open to compromise as understanding develops
• MCA needs to be engaged much earlier in consent process –
discussions with DECC ongoing
• MCA guidance material (MGN 371 etc.) to be revised
• Bristow developing simulator model for training/assessment
• Helicopter doctrine and procedures to be developed
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MS LOT - SAR
• Consented projects have provided layouts for assessment to MCA
• With new projects can an assessment take place during consent?
• Yes if fixed Design and Layout –Hywind.• No for most projects with design not complete –
requires consent condition that the assessment must be done and approved by MCA post consent (added risk).
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New SPAs and SACs
• How and when is it appropriate to take new SPA and SAC into account
Rochdale envelope + Rochdale envelope + Rochdale EnvelopeIndividual development Other Developments management objectives New SAC SPA
Assessment =
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New proposed SPAs
Timing• Consultation end July
2015• Designation likely end
2015
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New Proposed SAC for Harbour Porpoise
• Consented developments have other drivers (CfD) which require closure on identified risks
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Marine Scotland
• For new protected areas our policy is to look at protected areas once they have reached the proposed stage (at the point of consultation)
• For projects already consented we are looking at carrying out shadow appropriate assessments and have been discussing with SNCB to review these.
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Conclusions• Marine Scotland is working with DECC and TCE to ensure suitable
safeguards in place to ensure renewable developments are decommissioned at end of life.
• Marine Scotland is working with developers and MCA to resolve issues of SAR assessment on consented projects and to include in assessment in new projects.
• Marine Scotland is working to address immediate concerns on new SPA/SAC of consented projects with respect to shadow assessments and is ensuring that new projects will take into account.
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end
• Contacts:-• Marine Scotland – Licensing Operations Team• Marine Laboratory • 375 Victoria Road Aberdeen AB11 9DB• Direct Line +44 (0)1224 285579• Fax +44 (0) 1224295524• [email protected]• Web
http://www.scotland.gov.uk/Topics/marine/Licensing/marine/Applications