Consultation on UK Offshore Energy Strategic Environmental

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					Offshore Energy SEA Consultation                                              RYA House
The Department of Energy and Climate Change                                   Ensign Way, Hamble
4th Floor Atholl House                                                        Southampton SO31 4YA
                                                                              United Kingdom
86-88 Guild Street
Aberdeen AB11 6AR                                                             Tel +44 (0) 23 8060 4100
                                                                              Fax +44 (0) 23 8060 4299
                                                                              Direct tel: +44 (0)23 8060 4222
                                                                              Direct fax: +44 (0)23 8060 4294

06 April 2009

Dear Sir

Consultation on UK Offshore Energy Strategic Environmental Assessment. Future
Leasing for Offshore Wind Farms and Licensing for Offshore Oil & Gas and Gas
Storage - Environmental Report, January 2009
We refer to the Department’s consultation in relation to the above. We set out below our comments
on the Environmental Report.

The RYA is the national body for all forms of recreational and competitive boating. It represents
dinghy and yacht racing, motor and sail cruising, RIBs and sportsboats, powerboat racing,
windsurfing, inland cruising and personal watercraft. The RYA manages the British sailing team and
Great Britain was the top sailing nation at the 2000, 2004 and 2008 Olympic Games.

The RYA is recognised by all government offices as being the negotiating body for the activities it
represents. The RYA currently has over 100,000 personal members, the majority of whom choose to
go afloat for purely recreational non-competitive pleasure on coastal and inland waters. There are an
estimated further 500,000 boat owners nationally who are members of over 1,500 RYA affiliated
clubs and class associations.

The RYA also sets and maintains an international standard for recreational boat training through a
network of over 2,200 RYA Recognised Training Centres in 20 countries. On average, approximately
160,000 people per year complete RYA training courses. RYA training courses form the basis for the
small craft training of lifeboat crews, police officers and the Royal Navy and are also adopted as a
template for training in many other countries throughout the world.

The RYA welcomes this opportunity to comment on the Environmental Report.

1   General comments
    1. The SEA covers the development of offshore wind energy, offshore oil and gas extraction and
       gas storage. Of primary concern to the RYA is the development of offshore wind energy. Our
       concerns with these developments can be summarised as follows:
         Navigational safety: Collision risk; Risk management and emergency response; Marking
          and lighting; Effect on small craft navigational and communication equipment; Weather
         Location: Loss of cruising routes; Squeeze into commercial routes; Effect on sailing and
          racing areas; Cumulative effects; Visual intrusion and noise
         End of life: Dereliction; Decommissioning
         Consultation

    2. We would encourage future reports to be consistent in their terminology and refer to
       distances at sea in nautical miles and fractions of nautical miles and navigational speed
       accordingly should be measured in knots. Reference to kilometres, if required, should follow
       the nautical miles in brackets. Depths and heights should be measured in metres.

2   Site Selection
    1. It is our belief that in order to achieve the objectives as set out in the SEA, there are areas of
       the identified zones that would not be able to be developed. Objectives of specific relevance
       to the RYA are:

               Balance other UK responses and activities (including recreation) with the need to
                develop offshore energy resources

               Safety of navigation

    2. The report highlights that due to the scale of the proposed development an issue previously
       considered minor may result in a major impact. In addition, commercial and recreational
       navigation previously not in conflict may be brought into direct conflict with associated
       safety implications as a result of the developments. We would support that all future
       developments fully consider the cumulative effects of their site. Navigation is considered a
       key spatial issue and free unconstrained navigation routes are vital to the UK and a
       requirement in both territorial and EEZ under UNCLOS. The report recognises the need to
       minimise any increase to the risk of collision and vessel passage time through route deviation
       which clearly has its own implications in terms of carbon emissions.

    3. We are fully supportive of Recommendation 2 (a) and (e) in the report that states: Offshore
       wind farms should aim to minimise the disruption, economic loss and safety risks to other
       users of the sea and for the UK as a whole there should be a presumption against
       development which impinges on major commercial navigation routes, significant increase in
       collision risk or causes appreciably longer transit times and results in significant detriment to
       tourism, recreation and quality of life.

    4. The proposed development for offshore wind is considerable. An area of 10,000km2 could be
       occupied by 5000 turbines. Whilst we understand that the actual developments will only take
       up part of the identified ‘zones’, at this stage we have to assume that developers would
       attempt to maximise single development in each zone and it is unclear as to which zones at
       present would be favoured.

    5. The extent of the project has resulted in the report concluding that there will be a significant
       environmental effect, including a significant effect on other users of the sea. We are
       encouraged that the report sees this significant effect on navigation. As a result, the report
       concludes that the bulk of the generation capacity should be away from the coast, generally
       outside the 12nm. The RYA is extremely supportive of this conclusion and feels that much of
       the potential risk to recreational craft posed by such large scale development will be avoided
       by keeping development beyond 12nm. We should also like to emphasise as stated in the
       report, that 12nm is the minimum distance from the coast that is found in other European
    6. We do acknowledge that there may be some scope for development within the 12nm buffer
       but this would be based on more work. We assume that this would be in areas lightly used by
       navigation (commercial and recreational) as well as for other reasons.

    7. We are supportive of the statement that IMO routing measures and MCA advice on ‘siting
       not recommended’ will be taken into account and for general development guidance on
       OREI’s, developers should refer to MGN 371.

3   Data on recreational boating
    1. The SEA states that it intends to consider the environmental implications of the plan which
       includes interactions with ‘other users of the sea’. Navigation is included in ‘other users of
       the sea’ and we are pleased to see that the report does identify ‘yachting’ as a specific
       activity. It should however, be emphasised that whilst 4 weeks of AIS data has been collected
       for the SEA this method will not pick up the majority of recreational craft which are not
       required to carry an AIS transponder. We are pleased to see the RYA Atlas of Recreational
       Boating has however been used to identify recreational routes, sailing and racing areas. We
       enclose a copy of the Atlas for reference. Further copies can be requested from the RYA and
       we would expect this information to be used in specific site selection.

    2. The Atlas is an important source of information for recreational boating activity as it gives a
       comprehensive picture of an informal activity that is difficult to accurately monitor.
       Recreational and commercial navigation differ in many ways and the understanding that
       recreational navigation avoids the main shipping routes on the basis of safety is of
       paramount importance when planning for offshore wind developments often requiring space
       to be retained outside commercial shipping lanes for recreational routes. In addition it
       should be understood that sailing yachts will not necessarily follow a direct line between A
       and B, their line of travel depends on the direction of the wind on the day.

4   Navigating around wind farms
    1. We note that the understanding of wakes between turbines is likely to result in an increased
       distance between turbines as well as between wind farms. 0.5 nm (850m) between the
       turbines in rows, 0.7 nm (1200m) between rows and 3nm (5km) between farms. The report
       also states that vast majority of recreational vessels would not be excluded from the wind
       farm development areas. On the basis of the above figures and in favourable conditions, a
       mariner would be happy to transit a wind farm area and we would not expect them to be
       excluded from the site. However, in unfavourable conditions which must be planned for, the
       mariner may opt to avoid the site all together in which case extending the time at sea and
       increase the risk to their safety in these adverse conditions.

    2. Deviation of routes should include recreational vessels and it should be noted that in
       unfavourable conditions, recreational vessels may well avoid these developments increasing
       travel time. 5 knots speed is generally used for average passage planning.

    3. We have developed what we regard as a safe rotor clearance height for the majority of
       recreational craft at 22m above MHWS. We note that the report states this clearance should
       be adhered to unless there is proof that a lower level carries no added risk. We would not
       support a proposal where this height is reduced. It should be noted that as vessels increase
       in size and technology improves, mast height is likely to increase, not decrease. This factor
       alone should preclude the consideration of a lower level.

    4. Marking, lighting and visibility of offshore wind farms has been standardised and Trinity
       House takes the lead on this. We liaise with Trinity House as to any concerns we may have
       and expect them to be fully consulted and continue to take the lead in this matter.

5   Identifying development
    1. On the basis of the SEA objectives, conclusions and recommendations and our above
       comments we would expect developments to:

           Balance other UK marine resources, including recreation with offshore energy resources
            and ensure safety of navigation is maintained

           Recognise that AIS is not representative of all vessels and as a result use the RYA Coastal
            Atlas to identify recreational boating activity

           Protect coastal navigation by maintaining a 12nm buffer from the coast

           Recognise that recreational craft avoid shipping (Coastal and international) routes so
            buffer areas between developments and shipping lanes should be planned in for small

           Maintain a minimum air draft of 22m above MHWS

           Not exclude recreational vessels from wind farm development areas

           Take specifications from Trinity House with regard to marking, lighting and visibility of
            offshore wind farm sites

6   Site specific comments
    1. Poole Bay: We do not see any part of this zone that could be safely developed. The zone is in
       a heavily used navigational area with vessels entering the Solent through the Needles
       Channel and heading towards or from the Eastern entrance to the Solent. In addition, vessels
       leave the coast at Poole, the Needles and Christchurch for France and the Channel Islands
       bisecting the zone in several places. High speed cross-channel ferries also cross this area.
       This area is a good example of recreational craft and commercial vessels being able to stay
       out of conflict. It is our belief that safety of navigation would be seriously compromised
       should any area be developed which would be contrary to the SEA objectives. Additionally,
       over half of the area lies within the 12nm buffer which again is contrary to the SEA

    2. SE Zone: This zone lies almost entirely within 12nm from the coast, and would appear to be
       of limited potential for development on the SEA’s own recommendations. From the
       recreational perspective again we can only see limited opportunity for development whilst
       ensuring navigational safety.

    3. East Anglia: There are several routes crossing the North Sea from UK ports to Holland,
       Belgium and France which should be safeguarded. However, there are parts of the zone that
       we believe could be safely developed.

    4. Linconshire coast: The area further offshore can be safely developed in terms of recreational
       boating, whilst the area closest to the shore is crossed by a number of routes, some of which
       would be adversely affected due to the existence of proposed Round 2 sites.

    5. Scotland: Both of the Scottish sites are crossed by coastal cruising routes which should be
       preserved. However we see that there may be some scope for development. The SEA should
       have taken into account the latest proposal from Crown Estate and the Scottish Government
       as the cumulative effects of the proposals within 12nm from Crown Estate and those in this
        SEA outside 12nm. There is a clear need here for integrating the planning for offshore

    6. North West: This zone impinges on the shipping lane as commercial vessels leave the Traffic
       Separation Scheme and approach Liverpool Bay. This will leave little or no area for
       recreational vessels that are navigating alongside the TSS and the shipping lane heading for
       the same destination. The zone is also crossed by numerous routes transitting between
       Wales, Ireland, England, Scotland and the Isle of Man. There may be some scope for
       development in such a large zone. Any prospective site must fully examine the recreational
       and commercial navigation use of the area.

    7. Severn Estuary: This site lies almost entirely within the 12nm zone and in a busy navigational
       area which would be contrary to the SEA’s recommendations. The site is crossed by
       numerous routes. We believe there is limited potential to develop this zone without
       adversely impacting recreational boating.

Please do not hesitate to contact me if you have any questions or queries arising from our response.
On behalf of the RYA, I would be pleased to be involved in any future consultations or discussions.
We would welcome early dialogue with all developers looking to exploit any of these areas.

Yours faithfully,

Dr. Susie Tomson
RYA Planning and Environmental Advisor

Encl: RYA’s UK Coastal Atlas of Recreational Boating