Project Update Meeting
See Attached

bp EnBW - anon.

The Inspectorate attended an online Steering Group for the Morgan Generation Assets and Mona Offshore Wind Projects.
Please see attached.

Morgan and Mona Steering Group - anon.

Project Update Meeting - Please see attached
Please see attached

bp/EnBW - anon.

The Inspectorate attended an online Steering Group for the Morgan Generation Assets and Mona Offshore Wind Projects. The meeting provided a project update, details of an updated methodology for the Habitats Regulations Assessment (HRA), and an overview of key responses to the recent statutory consultation. The Applicant also outlined its proposed approach to the cumulative effects assessment (CEA) for the Morgan Generation project and requested any comments on the approach.
The Inspectorate advised that the CEA is undertaken on the basis of applicable worst case scenarios for the Proposed Development and other development, taking into account the information available at the time of assessment. The Inspectorate confirmed it had no further comments on the CEA at this stage.

Morgan and Mona Steering Group - anon.

For the Attention of Developers and The Planning Inspectorate In response to the current notices for the proposed projects listed below, I am pleased to submit this objection to the developers. This is also addressed to the Planning Inspectorate for their attention and response, regarding the application of the principles of the Rochdale Envelope. My concerns relate to the geographical extent of the proposed wind farms and the adverse impact on navigation. -Mona Statutory Notice -Morgan Offshore Generation Assets Statutory Notice -Morecambe Offshore Generation Assets Statutory Notice -Morgan and Morecambe Transmission Assets Adverse Impacts on Navigation My objection regarding the adverse impacts of the above proposed developments on navigation refers in particular to the Isle of Man's lifeline ferry services. The Planning Inspectorate's website for Morgan Offshore Generation Assets, 10 October 2022, records the following communication from the Maritime and Coastguard Agency. ''... I want to raise an early concern that (1) the three projects present concerns to safe navigation in the area and (2) I believe that separate planning applications would not provide a full representation of the impacts because of the risks they present cumulatively which probably most concern the MCA and other navigational stakeholders.'' The documents for the current proposals appear to show that the geographical extents of the schemes have not materially changed since the MCA expressed their concerns. Despite communications between the shipping interests and developers, I understand that the boundaries for the areas proposed for development remain a matter of concern for shipping operators, including the Isle of Man Steam Packet Company. Geographical Extent of Proposed Wind Farms Past experience shows that it is legitimate and reasonable to question the derivation of the geographical extent of the licence areas and of the actual development areas to be occupied by each of the proposed wind farms. The Crown Estate appears to define the licence areas with scant regard for navigation, and expects developers to thrash it out themselves. For example, the former (and subsequently abandoned) Rhiannon offshore wind farm licence area extended into and obstructed the established defined separated shipping lanes round Anglesey. Also, the Estate's defining Mona and Morgan as contiguous would clearly have resulted in a very major obstacle to navigation. The licence development areas are not set in stone, for example as demonstrated by the developer proposing to adopt less than the full licence area for development of Mona. A Request For More Information on Wind farm Extent and Layout Currently, there is free navigation over the whole area of the proposed wind farms. The custodian of the sea bed, the Crown Estate, has issued licences intended to allow developers to close off areas of the seas surface to navigation. Yet, it is the shipping interests who have been expected to justify their requirements for safe navigation. For an equitable balance between wind farms and shipping operation, it is now appropriate and not unreasonable to request that the developers justify the development areas actually needed. It is not adequate that they make reference to the development areas as ''maximum.'' Development of Wind Farms Proposals It appears that the geographical extents for licence and development were based initially on nominal capacity densities (MW/km^2) for which there is extensive data for the British Isles and Europe. Subsequently, with the increasing data now available, the developers should now be able to provide more detail of their design parameters and proposals. Unfortunately, past experience elsewhere was that developers claimed that there were too many variables under consideration. Was their reluctance to provide details until as late as possible intended to put objectors at a disadvantage? Even though the developers may not have finalised design, it is reasonable to expect that they are now able to address and resolve fundamental inputs such as turbine specific power and Irish Sea wind data. Thus, they are able to narrow down their choices and become much more specific as to the actual layout pattern and area required. For example, the documents state the minimum number (higher power) and maximum number (lower power) of wind turbines in each development, which indicates the chosen range of turbine capacities and rotor sizes. It would be misleading to suggest that there are too many variables to be more specific at this stage, as some variables cancel each other. For example, the area required for development is largely independent of rotor size (diameter). (The turbine power generated is proportional to the square of the rotor diameter. The wind turbine spacing is expressed as a multiple of rotor diameter, and thus the density of wind turbines is inversely proportional to the square of the rotor diameter. Thus to obtain the power capacity per unit area, the turbine power is multiplied by the density, and the diameters squared cancel out.) Application of Rochdale Envelope. The Rochdale Envelope (National Infrastructure Planning Advice Note 9) allows a degree of flexibility to address uncertainties. For offshore wind farms it notes (para 4.5) that these may include type and number of turbines. Para 4.12 refers to ''robust worst case scenario(s), '' which for offshore wind farms presumably includes overall geographical area for development. Notwithstanding this 'flexibility,' it now appears reasonable to request the developers to justify the actual development areas which they need. To give one specific example, what is the justification for the northern-most corner of Morgan to project apparently unnecessarily into the Douglas - Heysham shipping route?
Dear Mr. Pennington, Thank you for your email. I apologise for the delay in reply. The proposed applications above are currently at the Pre-application stage of the Planning Act 2008 process. Further information about the process can be found in the link below to the National Infrastructure Planning website: [attachment 1] The Planning Inspectorate is unable to consider representations about the merits of any application until it has been submitted and accepted for Examination. As the applications have not yet been formally submitted to the Planning Inspectorate. Your first point of contact should be the developer and we would encourage you to contact them directly: Morgan Offshore Wind Farm Generation Assets Website for consultation: [attachment 2] Email: [email protected] Telephone: 0800 915 2493 (Option 1) Mona Offshore Wind Farm Email: [email protected] Telephone: 0800 860 6263 Morecambe Offshore Wind Farm Generation Assets Email: [email protected] Telephone: 01224 548642 Morgan and Morecambe Offshore Wind Farms Transmission Assets Email: [email protected] Telephone: 0800 915 2493 (Option 3) It is important that the developer is made aware of your comments at the Pre-application stage to enable them to consider the points raised before finalising their proposals and submitting the application. Should the applications be accepted for Examination you will be able to register as an Interested Party on each project by submitting a relevant representation. This must be submitted on the ‘Registration and Relevant Representation form’ which will be made available on each project webpage of the National Infrastructure Planning website at the appropriate time. Further information about registering as an Interested Party can be found in the Planning Inspectorate’s ‘Advice Note 8.2: How to register to participate in an Examination’ which can be found here: [attachment 3] Shipping and navigation have been identified as aspects to be assessed in the environmental statements of all of the above projects and will be part of the evidence that each Examining Authority will consider during the Examination of each project. We will consider appropriate locations for hearings for each project once each application has been accepted for Examination. You may find it helpful to subscribe to receive email notifications for key events that occur after an application has been submitted to the Planning Inspectorate. You can do that on each project page of the National Infrastructure Planning website.

John Pennington

The Inspectorate attended an online Steering Group for the Morgan Generation Assets and Mona Offshore Wind Projects. The meeting provided further details on the site selection, baseline survey progress and ornithological Habitats Regulations Assessment (HRA) assessment methodology. The Inspectorate provided the advice noted below.
• The Inspectorate noted that in previous offshore wind farm examinations there have been extensive discussions on ornithological assessment methodology, including displacement and mortality rates and apportioning figures. It advised that these be agreed with Natural Resources Wales (NRW) and Natural England (NE) as early as possible in pre-application stage to reduce the risk of them leading to potential Examination issues. If agreement cannot be reached, the Inspectorate advised the Applicant to submit alternative versions of the assessment using the parameters preferred by each party as it is probable that this would otherwise be sought during an Examination. • The Inspectorate would expect any impact pathway taken forward to appropriate assessment to be considered in light of conservation objectives, in line with the requirements of the Regulations. However, the Inspectorate accepts, in principle, that the level of detail required may vary depending on the European site/qualifying feature/impact pathway. It is sensible to seek a proportionate approach to the assessment. • The Inspectorate recommends that the Applicant includes within their application a demonstrable agreement with NRW/NE that the ornithological surveys adequately took into account the potential effects of Highly Pathogenic Avian Influenza on the baseline populations.

Morgan and Mona Steering Group - anon.

Project Update Meeting
Please see attached

BP/EnBW - anon.

How are the cumulative impacts of each wind farm (Morgan, Mona and Morecambe) to be taken into account, if each wind farm is considered separately?
With regard to your query about cumulative impacts, the Applicants for these projects have advised that they are going to undertake environmental impact assessments which will be reported in an environmental statement for each project. The environmental statement for each project will include an assessment of cumulative effects (as they are required to do by the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017). Each project will therefore have to provide an assessment of cumulative effects with other developments which it could interact with. Advice Note Seventeen on our website explains the general advice the Planning Inspectorate gives on undertaking cumulative effects assessment. The environmental statement for each project will be submitted as part of their applications for Development Consent Orders; if the application is accepted then the effects of each project, including the cumulative effects, will be part of the evidence that the Examining Authority (the panel of Inspector(s)) consider during the Examination of the project before making their recommendation to the Secretary of State. The Applicants for each project and for the Morgan and Morecambe Offshore Wind Farms Transmission Assets have each requested a scoping opinion from the Secretary of State. The scoping opinion provides advice on the topics and assessments which should be reported in the environmental statement. As part of the process of drafting the opinion, applicants submit a scoping report – shipping and navigation and effects on other sea users have been identified as aspects to be assessed in the environmental statements. The Planning Inspectorate which acts on behalf of the Secretary of State, is required to consult various bodies including the Maritime and Coastguard Agency, Trinity House, Natural Resources Wales and the Marine Management Organisation and to take their advice into account when drafting the scoping opinion. The advice from these bodies is appended to the scoping opinion. The process the Inspectorate go through when drafting the scoping opinion is described in more detail in Advice Notes Three and Seven on our website. Please note that this is separate from the statutory consultation process which applicants are required to undertake themselves. The environmental statements are required by the EIA Regulations referred to above to be based on the most recent scoping opinion, unless the project is materially different from the project described in the scoping report. You may find it of interest to read the scoping opinions and scoping reports (the scoping opinions may not make much sense unless read in conjunction with the scoping reports).

John Pennington

I am writing to raise a query on the potential examinations for the three offshore wind farm projects being proposed in the Irish Sea - Morgan, Morecambe and Mona. The three projects are currently working on their Navigation Risk Assessments (Hazard Identification workshops are being held next week) and whilst their applications to PINS are still a long way off, I wanted to raise an early concern that (1) the three projects present concerns to safe navigation in the area and (2) I believe that three separate planning examinations would not provide a full representation of the impacts because of the risks they present cumulatively which probably the most important concern for MCA and other navigational stakeholders. Is there scope within the examination/decision-making process for assessing the potential impacts of all three projects in one examination or does it confine us to three examinations?
It is for the Applicants to decide when to submit their applications, therefore with different submission dates and different applicants there is little scope for combined Examinations or hearing sessions. I would suggest you contact the Applicants and raise your concerns with them. As all three projects are in the pre-application stage the MCA have the opportunity to provide clear advice to the Applicants on how to assess cumulative effects robustly.

Maritime and Coastguard Agency - anon.

Project update meeting for Morgan and Morecambe Offshore Wind Farms
Please see attached.

Flotation Energy, Cobra, bp, EnBW - anon.

Project update meeting.
Please see attached.

BP/EnBW - anon.

Project update meeting for Morgan and Mona Offshore Wind Farms
Please see attached

BP/ EnBW - anon.

Morecambe and Morgan consent strategy - Update meeting
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Flotation Energy, Cobra, bp, EnBW - anon.

Inception Meeting
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bp / EnBW - anon.