Thanet Extension 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.

Thanet Extension Offshore Wind Farm

Received 12 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. This includes maintaining our obligations under The United Nations Convention of the Law of the Sea.

In the early stages, MCA raised concerns regarding extent of the red line boundary to the west, and requested that specific impacts were thoroughly assessed in the Navigation Risk Assessment (NRA). Vattenfall have considered these issues in line with our guidance MGN 543, and our published risk assessment methodology. The NRA deems the increase in risk to be tolerable; that pilot boarding is still feasible, the increase in vessel routing is not significant, that vessels will be constrained and that these issues are manageable. The NRA also states that the increase in risk is further mitigated by a reduction of the redline boundary, as submitted in the application for consent.

The MCA does not accept that the increase in risk is tolerable with the current proposed redline boundary, considering the collective impact and the resultant changes that will be required in an already highly complex area for navigation. There will be more pressure on pilots, additional burden on the PLA within their VTS jurisdiction, operational implications, and more pressure on mariners with a reduction of available sea space on the western extent. The MCA’s view is that the reduction to the redline boundary was not to the extent we were expecting in response to the concerns raised during the pre-application consultation, and we cannot conclude that the risks are reduced to ALARP with the risk controls identified in the NRA.

The MCA strongly recommends that Vattenfall reconsider the western boundary, and we would welcome the opportunity to discuss further options with Vattenfall until such time the risk is considered to be acceptable by MCA and its stakeholders. The MCA must take into account the significant concerns raised by our stakeholder regarding this extension, and we support the representation submitted by the SUNK VTS User Group, which includes representatives of both Navigation Safety Branch at MCA and HM Coastguard.