Norfolk Vanguard

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.

Norfolk Vanguard

Received 14 September 2018
From Maritime and Coastguard Agency

Representation

The MCA’s remit for Offshore Renewable Energy Installations (OREIs) 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.

Vattenfall has undertaken a detailed Navigation Risk Assessment (NRA) in accordance with MCA guidance (MGN 543 and its supporting annexes, and risk assessment methodology), and we are satisfied that all aspects of the NRA have been adequately addressed, including the traffic surveys. However, there are still aspects of the project that will need to be discussed beyond consent, and concerns which will need to be addressed and agreed with MCA, as follows:

Layout Design
The turbine layout design will require MCA approval prior to construction to minimise the risks to surface vessels, including rescue boats, and search and rescue aircraft operating within the site. As such, MCA will seek to ensure all structures are aligned in straight rows and columns with a minimum of two lines of orientation.

We are concerned about the scale of the development in combination with multiple windfarms in the Southern North Sea (East Anglia Three, Norfolk Vanguard East and West and Norfolk Boreas), and the turbine layout and orientation must be discussed and agreed with MCA at the earliest opportunity. We are pleased to hear that continued dialogue is in place with the developers of East Anglia Three.

We note that the NRA considers ‘worst case scenario’ with just one line of orientation, however MCA’s preference is for at least two for the purposes of safe navigation for surface vessels, and search and rescue capabilities. We will also require turbines to be in straight lines but understand that micro-siting is likely necessary. The next step is commitment to an agreed set of design principles, which should be included or referred to as part of the DCO.

Deep Water Routes
An assessment of the DWRs relative to Norfolk Vanguard is presented in section 17, most notably the DR1 LightBuoy Deep Water Route (DWR), and the West Friesland DWR. We are content that the corridor is compliant with the MCA requirements.

Transboundary issues have been considered, and the Dutch authorities and relevant Dutch stakeholders have been consulted.

Marking and Lighting
MCA will seek to ensure the turbine numbering system follows a ‘spreadsheet’ principle and is consistent with other windfarms in the area. All lighting and marking arrangements will need to be agreed with MCA and Trinity House.

Emergency Response & Co-operation Plans
A SAR checklist will need to be completed in agreement with MCA before construction starts. This will include the requirement for an approved Emergency Response Co-operation Plans (ERCOP). This will be included as a formal condition of the DCO.

Construction scenarios
We would expect to see some form of linear progression of the construction programme avoiding disparate construction sites across the development area, and the DCO needs to include the requirement for an agreed construction plan to be in place ahead of any works commencing.

Mooring Arrangements:
It is noted that floating wind turbines are being considered. Further details are required on the anchor and line spread, monitoring during construction and operation, recovery of turbines and Third Party Verification. Reference should be made to recent guidance on regulatory expectations developed by MCA and HSE.

Hydrographic Surveys
Section 28.5 Hydrographic Surveys states that “As required by MGN 543, detailed and accurate hydrographic surveys will be undertaken periodically at agreed intervals. The applicants are reminded that the final data supplied as a digital full density data set, and the report of survey, should be submitted to the MCA Hydrography Manager and the UK Hydrographic Office. This information is yet to be submitted and failure to report the survey or conduct it to Order 1a might invalidate the NRA if it was deemed not fit for purpose

Cable Routes
Export cable routes, cable burial protection index and cable protection are issues that are yet to be fully developed. However due cognisance needs to address cable burial or protection and any consented cable protection works must ensure existing and future safe navigation is not compromised. The MCA would accept a maximum of 5% reduction in surrounding depth referenced to Chart Datum.

Safety Zones
The requirement and use of safety zones as detailed in the application is noted and supported.

Conclusion
A Statement of Common Ground is yet to be agreed and we would like to see this progressed as soon as possible to address the above issues.