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

This response is written on behalf of the Sunk User Group, and endorsed by the Chairperson, representatives of HMCG and the Vessel Traffic Services Policy Steering Group (VTS PSG). This VTSPSG was established by the MCA to help meet the United Kingdom’s obligations under SOLAS Chapter V Reg. 12 and the EU Traffic Monitoring Directive.
The Sunk User Group is a principal stakeholder forum chaired by MCA, to ensure co-operation between relevant key stakeholders for the safe and efficient operation of the Sunk Vessel Traffic Services (VTS). This Forum concluded at its meeting on 25th July 2018 that the significant concerns raised by its stakeholders remain, despite the mitigation proposed in the Navigation Risk Assessment (NRA) and the reduction in the red line boundary.
The forums’ opinion on the recent alterations to the red line boundary is extant in the understanding that it has not addressed the issue. Whilst it is understood that the NRA mentions only a limited impact to traffic routing, it is evident that the traffic passing between the windfarm and the Kent coast will be squeezed further to the west. The sea-room for pilot boarding and landing at the NE Spit will be significantly reduced, forcing more vessels to use the Tongue, which will also be forced to be relocated further out to the north east. This will further impact on pilotage transfer times and piloted voyage times and in worse weather will reduce the availability of the pilot stations altogether.
There is also concern regarding the required 500m safety zones around windfarms, further reducing navigable sea room, unless Vattenfall do not place any turbines within 500m of the red line boundary.
The forum agrees that the current NRA is not detailed enough and do not believe this to be a true reflection of the operations within the area. This is particularly evident in the pilotage study which appears to have been completed in sterile conditions, using experienced pilots and not unfamiliar overseas Masters’, as is the clear risk to navigation within the area.
The current NRA relies heavily on the others to change their operation to fit with the development, particularly with regards to buoyage, pilotage, communications and traffic. It is felt that this will put extra pressure on coordination on the movement of ships and efficiency of operation, which could impact safety within the area.
Previous mitigation methods included a Marine Coordination Centre, which Vattenfall have since removed. The forum is not certain that the risk to navigation is suitably mitigated following the removal of this, however it was never determined who would coordinate the traffic. It also appears that the recommended watch of radar and CCTV during construction and decommissioning by Vattenfall would be limited due to the lack of coverage over other vessels.
In conclusion, the current NRA does not appear to have suitably mitigated the risks with regards to current or anticipated future traffic to the area.