Hornsea Project Three Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Hornsea Project Three Offshore Wind Farm

Received 19 July 2018
From Maritime and Coastguard Agency

Representation

We intend to respond to the application for the Hornsea 3 Project to ensure the safety of navigation is maintained during construction, operation and decommissioning, with appropriate risk mitigation measures in place, and to ensure we are able to maintain our search and rescue obligations. We would therefore expect developments to be undertaken in accordance with Marine Guidance Note (MGN) 543 and its supporting annexes.

MCA’s remit for Offshore Renewable energy development is to ensure that the safety of navigation is preserved, and our Search and Rescue capability is maintained whilst progress is made towards government targets for renewable energy. This includes our obligations under The United Nations Convention on the Law of the Sea.

The Statement of Common Ground has not yet been agreed by MCA.
We remain concerned regarding the sighting of surface infrastructure anywhere within the 300m development corridor (+/- 150m from the centre line) which could be detrimental to navigation safety and SAR capabilities. This principle is considered beyond microsighting, and more a determination on layout design, and therefore the MCA does not find this reasonable. Straight lines of orientation without obstructions are by far the best way to provide for safe navigation of aircraft and vessels.

We are aware that the volume of commercial and recreational vessel activity in the area is low. However, we need to consider the vessels which find themselves in the vicinity of the windfarm in bad weather e.g. poor visibility, or in an emergency situation, the offshore support vessels, and the recreational vessels who do decide to transit the site.

Principle 8 - Infrastructure shall be sited within Development Lanes of up to 300m width whilst still maintaining Principle 2 along the length of the Development Lane. Infrastructure may then be sited at varying distances up to 150m from the centre line of that Development Lane.

The MCA considers this excessive and it will likely create surface infrastructure which are not in line and/or curved. A 300m lane of surface infrastructure which is not in line effectively creates a 300m corridor, which is not searchable. This could result in 23% of the development with no SAR coverage (300m every 1300m). This principle is not considered to be microsighting but part of a determination on layout design, and as a result the MCA does not find this reasonable.

Principle 11 - The position of Surface Infrastructure within a Perimeter Development Lane around the Hornsea Three Array Area or a Phase shall, so far as is practicable, be arranged in straight or curved lines (to a tolerance of ±150m) from the indicative boundary of the Hornsea Three Array Area or Phase whilst complying with Principles 1 and 2.

As per comment on principle 8, the tolerance of 150m is excessive and would lead to non-linear surface infrastructure, which may have an adverse impact on SAR and navigation safety.

We are concerned that the length of the lanes will be up to 22nm in length, which may take a SAR helicopter approximately 20 minutes to transit. Considering there is just one line of orientation, this would not allow a SAR aircraft to turn and manoeuvre down an adjacent lane, which is fundamental for SAR capabilities. In addition, the lack of a helicopter refuge area restricts access options. Annex 5 to MGN 543 states that these helicopter refuge areas may be required where developments are over 10nm in length.

The MCA therefore strongly recommended that an assessment be made into the feasibility of one perpendicular helicopter refuge area, half way along the development.