Beatrice Offshore Wind Farm - SSE...

Beatrice Offshore

Wind Farm

Draft Offshore Decommissioning Programme

September 2015

Beatrice Decommissioning Programme

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Table of Contents

Abbreviations and Definitions............................................................................................ 6

1 Introduction.............................................................................................................. 9

1.1 Background .................................................................................................. 9

1.2 Consent Conditions ..................................................................................... 9

1.3 Structure of this DP .................................................................................... 10

2 Executive Summary ............................................................................................... 11

3 Background Information ....................................................................................... 15

3.1 The Development ....................................................................................... 15

3.2 Physical Environment ................................................................................ 17

3.3 Biological Environment ............................................................................. 19

3.4 Human Environment .................................................................................. 20

3.5 Nature Conservation Designations ........................................................... 22

4 Description of Items to be Decommissioned ....................................................... 26

4.1 Layout of the Development ....................................................................... 26

4.2 Development Elements to be Decommissioned ...................................... 28

5 Description of Proposed Decommissioning Measures....................................... 34

5.1 Introduction ................................................................................................ 34

5.2 Decommissioning Options ........................................................................ 34

5.3 Guiding Principles ...................................................................................... 35

5.4 Proposed Decommissioning Process ...................................................... 37

5.5 Waste Management and Residual Value of Recovered Materials ........... 43

5.6 Lighting and Marking ................................................................................. 44

6 Environmental Impact Assessment...................................................................... 45

7 Consultation with Interested Parties .................................................................... 46

8 Costs ...................................................................................................................... 47

9 Financial Security .................................................................................................. 48

10 Schedule ................................................................................................................ 49

11 Project Management and Verification .................................................................. 50

12 Seabed Clearance .................................................................................................. 51

13 Restoration of the Site .......................................................................................... 52

14 Post-decommissioning Monitoring, Maintenance and Management of the Site 53

15 Supporting Studies ................................................................................................ 54

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16 References ............................................................................................................. 55

Appendix A - Beatrice Offshore Wind Farm ES and SEIS .............................................. 57

Appendix B (confidential) - Beatrice Offshore Wind Farm Financial Security

Information ........................................................................................................................ 58

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Abbreviations and Definitions

Term Description

AC Alternating Current.

BATNEEC Best Available Technology Not entailing Excessive Economical Costs.

BOWL Beatrice Offshore Windfarm Limited (Company Number SC350248) and

having its registered office at Inveralmond House, 200 Dunkeld Road,

Perth, PH1 3AQ.

BMAPA British Marine Aggregate Producers Association.

BPEO Best Practicable Environmental Option.

CCC Climate Change Capital Ltd.

CD Chart Datum.

CDM Construction (Design and Management).

S36 Consent The written consent granted by the Scottish Ministers under Section 36

of the Electricity Act 1989, on 19 March 2014.

Consent

Conditions

The terms that are imposed on BOWL under the S36 or Marine Licence

Consent that must be fulfilled throughout the period that the Consent is

valid.

CoS Chamber of Shipping.

DECC Department of Energy and Climate Change.

Development The Wind Farm and the OfTW.

DP The decommissioning programme; to be submitted by the Company to

the Secretary of State under section 105(2) of the Energy Act 2004 (as

amended).

EIA Environmental Impact Assessment.

EC Birds

Directive

Directive 2009/147/EC on the conservation of wild birds

EC Habitats

Directive

Directive 92/43/EEC of 21 May 1992 on the conservation of natural

habitats and of wild fauna and flora

ES The Environmental Statement submitted to the Scottish Ministers by the

Company on 23 April 2012 as part of the Application as defined above.

GRE Glass-fibre Reinforced Epoxy.

HMR Helicopter Main Route.

HSE Health, Safety and Environment.

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Term Description

IMO International Maritime Organisation.

JNCC Joint Nature Conservation Committee.

Marine Licences The written consents granted by the Scottish Ministers under Section

20(1) of the Marine (Scotland) Act 2010, dated 2 September 2014.

MCA Maritime and Coastguard Agency.

MoD Ministry of Defence.

MS-LOT Marine Scotland Licensing Operations Team.

MW Megawatt.

NERL NATS (En Route) plc.

NLB Northern Lighthouse Board.

NM Nautical Mile.

NtM Notices to Mariners.

O&M Operation and Maintenance.

OfTW The Offshore Transmission Works. The OfTW includes the transmission

cable required to connect the Wind Farm to the Onshore Transmission

Works. This covers the OTMs and the cable route from the OTMs to

the landfall west of Portgordon on the Moray coast.

OfTW corridor The area within which the OfTW cable is to be located as presented in

the ES and SEIS.

OfTW cable The cable connecting the OTMs to the landfall site.

OnTW The onshore transmission works from landfall, consisting of onshore

buried export cables to the onshore substation and connection to the

National Grid network.

OSPAR

(Convention)

The Convention for the Protection of the Marine Environment of the

North-East Atlantic.

OTM Offshore Transformer Module means an alternating current (AC)

offshore substation platform which is a standalone modular unit that

utilises the same substructure and foundation design as a wind turbine

generator.

PEXA Practice and Exercise Areas.

PMF Priority Marine Feature.

ppt Parts per thousand.

PSR Primary Surveillance Radar.

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Term Description

RAF Royal Air Force.

RSPB Royal Society for the Protection of Birds.

RYA Royal Yachting Association.

SAC Special Area of Conservation, protected sites classified in accordance

with the EC Habitats Directive.

SEIS Supplementary Environmental Information Statement submitted to the

Scottish Ministers by the Company on 29 May 2013 as part of the

Application as defined above.

SEPA Scottish Environment Protection Agency.

SFF Scottish Fishermen’s Federation.

SFPA Scottish Fisheries Protection Agency.

SHE-T Scottish Hydro Electric Transmission Limited.

SNH Scottish Natural Heritage.

SoS Secretary of State.

SPA Special Protection Area, protected sites classified in accordance with

the EC Birds Directive.

TCE The Crown Estate.

The Wind Farm The offshore array development as assessed in the ES including wind

turbines, their foundations, inter-array cabling and meteorological

masts.

UKHO United Kingdom Hydrographic Office.

UNCLOS United Nations Convention of Law on the Sea.

WDC Whale and Dolphin Conservation.

WMP Waste Management Plan.

WTG Wind Turbine Generator.

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1 Introduction

1.1 Background

1.1.1 The Development received consent under Section 36 of the Electricity Act 1989 from

the Scottish Ministers on 19 March 2014 (the S36 Consent) and was issued two Marine

Licences from the Scottish Ministers, for the Wind Farm and associated Offshore

Transmission Works (OfTW), on 2 September 2014 (the Marine Licences). The

Development is scheduled to commence construction in 2017.

1.1.2 The purpose of this Decommissioning Programme (DP) is to satisfy the requirement

for a programme for decommissioning to be submitted to the Secretary of State (SoS)

for the Department of Energy and Climate Change (DECC) for approval, in consultation

with the Scottish Ministers, prior to the start of construction.

1.1.3 Beatrice Offshore Wind Farm Limited (BOWL) is the partnership formed between SSE

Renewables (50%), Repsol Nuevas Energias UK (25%) and Copenhagen

Infrastructure Partners (25%).

1.2 Consent Conditions

1.2.1 On 15 October 2014 a notice was issued to BOWL on behalf of the SoS for DECC in

exercise of his powers under Section 105(2) of the Energy Act 2004 requiring, prior to

the commencement of construction, the submission of a programme for

decommissioning the relevant objects specified in Schedule 1 of the notice, namely:

Renewable energy installation, including foundations, pipelines, any electric

lines and cables (including those between the installation and the Mean Low

Water Mark), installed specifically for use with or connected to use with the

Beatrice Offshore Wind Farm electricity generating station.

1.2.2 This DP has been produced in accordance with the Section 105(2) notice.

1.2.3 Submission of this DP for approval by the SoS for DECC will also satisfy the

requirements of Condition 3 of the S36 Consent and Condition 3.2.2.2 of the OfTW

Marine Licence, as set out in Table 1.1 below.

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Table 1.1 – Relevant S36 Consent and OfTW Marine Licence consent conditions

Consent Document

Condition Reference

Condition Text

Section 36 Consent

Condition 3

“Where the Secretary of State has, following consultation with the Scottish Ministers, given notice requiring the Company to submit to the Secretary of State a Decommissioning Programme, pursuant to section 105(2) and (5) of the Energy Act 2004, then construction may not begin on the site of the Development until after the Company has submitted to the Secretary of State a Decommissioning Programme in compliance with that notice.

Reason: To ensure that a decommissioning plan is submitted to the Secretary of State where the Secretary of State has, following consultation with the Scottish Ministers, so required before any construction commences.”

OfTW Marine Licence

Condition 3.2.2.2

“Where the Secretary of State has, following consultation with the Licensing Authority, given notice requiring the Licensee to submit to the Secretary of State a DP, pursuant to section 105(2) and (5) of the Energy Act 2004, then construction may not begin on the Site of the Works until after the Licensee has submitted to the Secretary of State a DP in compliance with that notice.”

1.3 Structure of this DP

1.3.1 This document is divided into the sections summarised in Table 1.2 and follows the

structure set out in the DECC guidance (DECC, 2011).

Table 1.2 – Summary of DP contents

Section Summary of Content

1 Introduction Background to the Development including the companies that are party to the programme and their ownership status, and consent requirements relevant to this DP.

2 Executive summary A summary highlighting the essential features of the proposed DP.

3 Background information Relevant background information including the layout of the Development and confirmation of items to be decommissioned; and, a summary of environmental conditions across the site.

4 Description of items to be decommissioned

A full description of all items associated with the generating station to be decommissioned.

5 Description of proposed decommissioning measures

An overview of the proposed approach to decommissioning the Development, including: an overview of the process; details of items to be left in situ; and, waste management.

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Section Summary of Content

6 Environmental Impact Assessment

Details of the EIA that was prepared for the Development and its consideration of decommissioning activities.

7 Consultations with interested parties

The consultation process undertaken to support development and finalisation of the DP.

8 Costs An overall cost estimate of the proposed decommissioning measures.

9 Financial security Details of the financial security which the companies that are party to the programme propose to provide.

10 Schedule Details of the proposed decommissioning time-scale.

11 Project management and verification

Information on how BOWL will manage the implementation of the DP.

12 Sea-bed clearance Information relating to BOWL's proposals confirming that, following decommissioning, the site has been cleared, including information on site surveys and schedules.

13 Restoration of the site Description of how BOWL intends to restore the site as far as reasonably practicable, to the condition that it was in prior to construction of the installation.

14 Post-decommissioning monitoring, maintenance and management of the site

Details of the post decommissioning monitoring/activities that will be required, given that BOWL is not proposing to fully remove all infrastructure.

15 Supporting studies Details of supporting studies that have been used to inform the DP.

2 Executive Summary

2.1.1 The Beatrice Offshore Wind Farm is a joint venture project between SSE Renewables,

Repsol Nuevas Energias UK and Copenhagen Infrastructure Partners. Together they

form the partnership Beatrice Offshore Wind Farm Limited (BOWL).

2.1.2 The Development received consent under Section 36 of the Electricity Act 1989 from

the Scottish Ministers on 19 March 2014 (the S36 Consent) and was issued two Marine

Licences from the Scottish Ministers, for the Wind Farm and associated Offshore

Transmission Works (OfTW), on 2 September 2014 (the Marine Licences). The

Development is scheduled to commence construction in 2017.

2.1.3 The project is seeking to develop the Beatrice Offshore Wind Farm, located in the

Outer Moray Firth on the north-western point of the Smith Bank, approximately 13.5

km from the Caithness coastline. The Development is comprised of 84 wind turbine

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generators (WTGs), with a rated generating capacity of 7 Megawatts (MW) each, and

will therefore generate a maximum capacity of 588 MW. Two alternating current (AC)

Offshore Transformer Modules (OTMs) (offshore substation platforms) will collect the

generated electricity and convert the electricity from 33kV to 220kV for transmission to

shore by two subsea export cables, totalling approximately 130 km in length. Inter-

array cables will connect the wind turbines in strings, the strings of wind turbines to the

OTMs, and inter-connect the OTMs.

2.1.4 Following consent a notice was issued by the Secretary of State (SoS) on 15 October

2014, following consultation with the Scottish Ministers, giving notice requiring BOWL

to submit to the SoS a Decommissioning Programme (DP), pursuant to section 105(2)

and (5) of the Energy Act 2004, prior to construction of the Development being allowed

to commence.

2.1.5 The proposed measures set out in this draft DP adhere to the existing UK and

international legislation and guidance notes and have regard to decommissioning best

practice. Methods outlined are presented based on currently available technology. It is

expected that by the time of decommissioning, significant technological changes may

result in different approaches to decommissioning activities and such changes will be

reflected in future revisions of the draft DP.

2.1.6 The DP details the methods associated with the future end of life decommissioning of

the Development. It has been prepared on the basis of known site characteristics and

consent conditions. The DP is informed and supported by the Environmental

Statement (ES) and Supplementary Environmental Information Statement (SEIS)

prepared for the Development. These documents were submitted as part of the

applications for consent in April 2012 (ES) and May 2013 (SEIS). The ES and SEIS

provide detailed analysis of the baseline physical, biological and human environment,

and present an assessment of the likely significant effects of the Development on the

receiving environment, taking into account decommissioning provisions that are

consistent with those presented in this document. Electronic copies of the ES and

SEIS can be accessed online, via the link given in Appendix A to this document.

2.1.7 In advance of decommissioning, the Environmental Impact Assessment (EIA) will be

reviewed to assess the potential impacts that may arise and are not covered in the

initial EIA process and subsequent reviews. At this point, a decision will be made by

BOWL, in consultation with the statutory authorities, as to whether a more detailed

assessment of the likely significant effects of decommissioning is required.

2.1.8 A summary of the proposals for decommissioning the offshore components of the

Development are outlined below:

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Development Component Proposed Decommissioning Measure

Wind Turbines Complete removal from site.

Wind Turbine Support Structures

Entire jacket structure removed; pin pile foundations cut off at or below the seabed and cut sections removed from site.

OTMs (topsides) Complete removal from site.

OTM Support Structures Entire jacket structure removed; pin pile foundations cut off at or below the seabed and cut sections removed from site.

Cables (marine export) Cut off and left in situ buried in the seabed.

Cables (inter-array) Cut off and left in situ buried in the seabed.

2.1.9 In considering appropriate decommissioning provisions BOWL has sought to adhere

to the following key principles as set out in DECC guidance (DECC, 2011) on

decommissioning offshore renewable energy installations under the Energy Act 2004,

namely:

Best Practicable Environmental Option (BPEO), which is the option with the

most benefit or least damage to the environment as a whole at an acceptable

cost. This involves balancing the reduction in environmental risk with

practicality and cost of reducing the risk;

Consideration of the rights and needs of legitimate users of the sea;

Safety of surface and subsurface navigation; and

Health, Safety and Environment (HSE) considerations.

2.1.10 This document also provides a strategy for dealing with the decommissioned

components. This will include recovered steel, copper and glass fibre composites. The

proposed strategy will be to re-use and recycle as much material as possible.

2.1.11 The Development has an anticipated operational period of 25 years following final

commissioning, and in the absence of re-powering, decommissioning would be

required at the end of the operational period. The final schedule of decommissioning

works will be determined once the DP has been reviewed by BOWL two years prior to

the end of the operational period (approximately year 23 of operation). The timing of

the review ensures that the project is sufficiently close to the commencement of

decommissioning for the information, methods and legislation to be up to date at the

point of decommissioning. It also allows sufficient time for any necessary assessments

to be undertaken or consents to be obtained.

2.1.12 BOWL’s approach to consultation on this DP follows the guidance set out in the DECC

guidance (DECC, 2011) and is in accordance with the requirements of the Energy Act

2004.

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2.1.13 A cost estimate for the DP has been derived based on the equipment and personnel

requirements and the duration of the works. Financial security has been carefully

considered to ensure that the liability will be met and an approach to this has been set

out for DECC approval.

2.1.14 This DP is considered sufficient to meet the requirements set out under Section 105 of

the Energy Act 2004; the submission of this DP for formal approval by DECC is also

considered sufficient to satisfy the S36 Consent Condition 3 and Condition 3.2.2.2 of

the OfTW Marine Licence.

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3 Background Information

3.1 The Development

3.1.1 The Development comprises the Wind Farm and the OfTW.

3.1.2 The site is located in the Outer Moray Firth on the north-western point of the Smith

Bank, approximately 13.5 km from the Caithness coastline. The Wind Farm site is

approximately 19 km in length and 9 km in width at the maximum extents, covering an

area of approximately 131.5 km2.

3.1.3 The export cable route corridor within which the two export cables will be installed is

approximately 65 km in length and varies between 575 m and 1054 m in width running

between the Wind Farm site and Mean High Water Spring (MHWS) at the landfall point.

It leaves the south of the Wind Farm site and follows the northern boundary of the

Moray Firth Round 3 Zone, passing through the Western Development Area of the

Moray Firth Round 3 Zone towards the landfall at Portgordon on the Moray coastline.

3.1.4 Figure 3.1 shows the site location, boundaries and cable route to shore.


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3.1.5 The Development comprises 84 wind turbines, each with a rated generating capacity

of 7 Megawatts (MW), and will therefore generate a maximum capacity of 588 MW.

3.1.6 The substructure for the wind turbines will comprise a jacket made up of a tubular steel

lattice structure with 4 legs. Each substructure will be fixed to the sea bed using four

pin piled foundations.

3.1.7 Two alternating current (AC) substation platforms, referred to as offshore transformer

modules (OTMs), a form of offshore substation platform, will collect the generated

electricity and convert the electricity from 33kV to 220kV for transmission to shore via

two subsea export cables, totalling approximately 130 km in length. The support

structures for the OTMs will be identical to those used for the wind turbines.

3.1.8 A network of circa 170 to 190 km 33 kV inter-array buried, subsea cables will connect

strings of wind turbines together and will connect the wind turbines to the OTMs; an

interconnector cable will connect the two OTMs.

3.1.9 No meteorological monitoring masts (met masts) will be installed, although metocean

buoys may be deployed within the site.

3.2 Physical Environment

3.2.1 A range of surveys have been completed by BOWL to establish the physical

characteristics of the Development site. These studies informed the EIA for the

Development, are reported as part of the ES and SEIS, and form the basis for this

section of the DP. The following sections provide sufficient information to inform

consideration of the decommissioning provisions.

Metocean Characteristics

3.2.2 The Wind Farm site has the following metocean characteristics, as summarised in

Table 3.1 below.

Table 3.1 - Metocean Characteristics of the Wind Farm site

Estimated Average Mean Wind Speed Approximately 10 metres per second (m/s) at 110 m above LAT

Water Depth Range 35 – 68 m Chart Datum (CD)

Mean Surface Temperature 11°C (summer)

6°C (winter)

Surface Salinity Range 34.5-35 parts per thousand (ppt)

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Topography and Bathymetry

3.2.3 The Wind Farm site is located on the Smith Bank, a submerged bathymetric high in

the Outer Moray Firth. Water depths across the Wind Farm site range between 35 and

55 metres below chart datum.

3.2.4 From the Wind Farm, the middle section of the OfTW cable route also passes through

central parts of the Outer Moray Firth with water depths varying from 50 m below Chart

Datum (CD) at the edge of Smith Bank to 100 m CD in a deepwater channel that runs

parallel to the southern Moray Firth coastline. Water depths then shoal gradually to the

shoreline and cable landfall in Spey Bay.

Geological Characteristics

3.2.5 The main body of Smith Bank is relict and stable, comprising bedrock overlain by

poorly sorted stiff clay till sediments, with a variably thick veneer of (occasionally shelly)

marine sands and gravels. Sidescan sonar data indicate a predominance of granular

surface sediments across the Development site, except in the shallowest parts near

the crest of Smith Bank, where the underlying till is largely exposed with little sediment

veneer.

3.2.6 Seabed sediments in the Outer Moray Firth area are broadly characterised as sandy

or gravelly sandy material. The grain size of the sand fractions is generally finer than

on Smith Bank.

Tidal Processes

3.2.7 Smith Bank is exposed to semi-diurnal tidal forcing. The mean neap tidal range is 1.4

m, the mean spring tidal range is 2.8 m, and the maximum (astronomical) tidal range

is 4 m. The tidal current axis is aligned approximately north by north east (ebb) by

south by south west (flood). Peak tidal current speeds over Smith Bank are generally

0.25 ms-1 during mean neap tides and 0.50 ms-1 during mean spring tides. Spatial

gradients in tidal current speed result in a weak residual transport directed south west

or south, into the Moray Firth.

3.2.8 Non-tidal surges are known to occur in the Moray Firth, caused by the influence of

strong winds and atmospheric pressure gradients associated with storms over the

North Sea. Non-tidal surges can cause instantaneous water levels to be up to 1 m

above or below the predicted value. Tidal surges also induce a surge current, which

will be directed into the Moray Firth. The magnitude of this current will vary depending

upon the scale and timing of the surge, but an extreme event may modify normal tidal

currents by the order of 1 ms-1. In this area the magnitude of surge currents is

predicted to decrease rapidly with distance into the Moray Firth and so the north

eastern end of the Wind Farm site will experience the greatest effects.

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Wave Regime

3.2.9 Smith Bank is exposed to wave action on a regular basis. Winds blowing from

directions from south by southeast, clockwise through to north, are only able to act

upon the water surface over a relatively limited distance within the confines of the

Moray Firth. Hence waves from these directions are typically more limited in height

and period. Winds and hence waves (but of a limited height) most frequently occur

from the south west.

3.2.10 Much larger waves are observed to come from other directions that have much longer

fetches into the North Sea. Over such long distances, distant storms can also drive

long period swell waves into the Moray Firth that do not necessarily rely on further local

wind input.

3.3 Biological Environment

Benthic Environment

3.3.1 The seabed at the Wind Farm site is dominated by sands and gravels. The most

extensive benthic community occurs in medium sands with low gravel content. A range

of biotopes exists across the Development Site, the SS.SCS.ICS.MoeVen1 (hereafter

referred to as MoeVen) biotope, a Scottish Priority Marine Feature (PMF) was located

within the Wind Farm site. As identified within the ES, this was a new record of this

biotope in deeper waters2 (i.e., waters of up to 50 m).

Fish and Shellfish Ecology

3.3.2 The principal shellfish species caught within the area in which the Wind Farm site is

located are king scallop, Nephrops, edible crab and squid. Haddock, herring, monkfish

and whiting account for the majority of the fish landings. Spawning and nursery

grounds have been defined for a number of species, including cod, herring, lemon sole,

Nephrops, plaice, sandeel, sprat and whiting, within and in the vicinity of the

Development. Elasmobranch and diadromous fish species potentially use areas within

or in the vicinity of the Development.

Marine Mammals

3.3.3 A range of marine mammal species are present within the Moray Firth, with harbour

porpoise, harbour seal, and grey seal being the most numerous and widespread

recorded across the Wind Farm site during baseline surveys for the EIA. Minke whale

were also recorded regularly within the Wind Farm site but in much lower abundance

and only during the summer months. Distribution maps for bottlenose dolphin, a year-

round resident, showed that individuals mainly occurred within the inner reaches of the

Moray Firth and along the south coast, including near the Portgordon landfall location

1 Moerella spp. with venerid bivalves in infralittoral gravelly sand. 2 The MoeVen biotope is more typically found in waters depths of less than 20 m.

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in Spey Bay. The most abundant species found within this southern area were

bottlenose dolphin, harbour porpoise, and minke whale.

Ornithology

3.3.4 The seabird breeding colonies around the Moray Firth are host to internationally

important populations of several species. Thirteen species of seabird and four species

of wildfowl were identified from survey data as potential sensitive receptors, namely:

Fulmar, Sooty shearwater, Shag, Gannet, Arctic skua, Great skua, Kittiwake, Great

black backed gull, Herring gull, Arctic tern, Guillemot, Razorbill, Puffin, Pink footed

goose, Greylag goose, Barnacle goose and Whooper Swan.

3.4 Human Environment

Marine Archaeology

3.4.1 The Wind Farm site itself is known to have been largely restricted in the past to glacial

and marine conditions; therefore never becoming terrestrialised within the last 12,000

years. Relative sea level change in the area, combined with glacial isostatic uplift, has

meant that the Outer Moray Firth has remained either under ice sheets or submerged

by the North Sea since the last glacial period. This means that there have been no

opportunities for terrestrial deposits of palaeo-environmental interest, such as peats,

to develop.

3.4.2 There are no recorded wrecks or features identified within the Wind Farm site, but

several recorded wreck locations were identified within the export cable corridor and

the Outer Study Area (1 km buffer from the transmission corridor boundary), with a

number of potential targets of cultural heritage interest identified from the geophysical

data.

Offshore Wind Farms

3.4.3 The Moray Firth Round 3 Zone is located adjacent to the east of the Wind Farm site.

To the southwest, at a distance of approximately 11 km, lie the two existing Beatrice

demonstrator turbines. The Beatrice complex is linked to the mainland via a 132/33

kV seabed power cable making landfall at Dunbeath.

Oil and Gas Exploration and Related Activities

3.4.4 There are two producing oil fields, named ‘Beatrice’ and ‘Jacky’, located to the

southwest of the Wind Farm Site. The key structures within these areas include the

Beatrice Alpha, Bravo and Charlie platforms and the Jacky platform. Oil is exported via

a 66 km long 16 inch (0.4 m) pipeline from the Beatrice Alpha complex to a shore

terminal at Nigg in the Cromarty Firth.

Subsea Cables

3.4.5 The SHEFA-2 fibre-optic telecommunications cable runs from the Faroe Islands to

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Banff in Moray. It runs north to south, to the east of the Wind Farm site.

3.4.6 The route of the transmission cable proposed by Scottish Hydro Electric Transmission

Limited (SHE-T) for a Caithness-Moray link will pass to the east of the Wind Farm

site. This SHE-T cable makes landfall directly to the east of the BOWL cable having

run parallel with BOWL for approximately 5km prior to reaching the shore.

Ports and Harbours

3.4.7 There are a number of ports and harbours located within the Moray Firth and

surrounding area. These include the important fishing ports of Wick off the north east

coast and Buckie Harbour on the south coast and the sheltered deepwater commercial

ports and harbours of Inverness and the Cromarty Firth located at the head of the

Moray Firth.

3.4.8 There are also a number of smaller, former fishing harbours, that have been

redeveloped as small marinas and these include Banff, Whitehills, Lossiemouth and

Findhorn on the south coast of the Moray Firth and Helmsdale on the north coast. The

area has direct links with the Caledonian Canal (Inverness).

Shipping Activities

3.4.9 Shipping in the vicinity of the Development includes commercial shipping, fishing and

recreational yachting.

3.4.10 The Wind Farm site is located in an area of low commercial ship density, with the

nearest main ship route passing 5 nautical miles (NM) north by northeast of the Wind

Farm site boundary - the route used by ships heading to and from the Pentland Firth.

3.4.11 The export cable route is also located in area of low commercial ship density with the

nearest main shipping route crossing the cable route approximately 3.5 NM north of

the Moray coast (associated with Inverness and Cromarty Firth). Vessels are known

to anchor in the Moray Firth during adverse sea and weather conditions.

Commercial Fishing

3.4.12 Scallop dredging is recorded throughout the Moray Firth, including on the Smith Bank

and in inshore areas along the Caithness and Moray coasts but there is limited activity

recorded within the Wind Farm site. There is additionally whitefish and squid fishing

activity in the vicinity of the Wind Farm site, although the majority of activity by vessels

targeting these fisheries occurs outwith the Wind Farm site.

3.4.13 The export cable route transects fisheries for Nephrops in the southern Moray Firth,

scallop grounds in both the offshore and inshore areas, seasonal squid grounds and

creel grounds for lobster and crab in the inshore section of the cable route.

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Aviation

3.4.14 The Wind Farm is visible to the primary surveillance radar (PSR) at RAF Lossiemouth

and the NATS (En Route) plc (NERL) PSR at Allanshill. The Wind Farm is located in

the vicinity of and directly beneath helicopter main route (HMR) X-RAY which routes

between Aberdeen and Wick, and the helicopter approaches to helidecks on platforms

in the Beatrice and Jacky oil fields.

Military Interests

3.4.15 Military Practice and Exercise Area (PEXA) charts, produced by the UK Hydrographic

Office, identify the military activity zones within the Moray Firth area. PEXAs are used

for various military practice activities by the Royal Navy, the Army, the Royal Air Force

(RAF) and the Ministry of Defence (MoD). Firing Practice Areas D807 and D809 are

the closest areas (1 NM east and 2.6 NM south of the Wind Farm site) and the

proposed OfTW corridor passes through Firing Practice Area D807. Tain RAF

Bombing Range is located approximately 19 NM southwest.

3.5 Nature Conservation Designations

3.5.1 The closest European designations to the Wind Farm are located at a distance of 16.5

km and 37 km respectively, and are the Caithness Cliffs Special Protection Area (SPA)

and the Moray Firth Special Area of Conservation (SAC), which are designated for the

conservation of breeding bird interests, and for sub tidal sandbanks and the bottlenose

dolphin respectively.

3.5.2 Information on European designated sites considered in the Appropriate Assessment

undertaken during the consenting of the Development is provided in Table 3.2. The

location of those sites in closest proximity to the Wind Farm are shown in Figure 3.2.

Table 3.2 – European designated sites considered in Appropriate Assessment

Site Qualifying Features

Moray Firth SAC Bottlenose dolphin

Subtidal sandbanks

Dornoch Firth and Morrich More SAC

Common (harbour) seal

Otter

Atlantic salt meadows

Coastal dune heathland*

Dune grassland*

Dunes with juniper thickets*

Estuaries

Glasswort and other annuals colonising mud and sand

Humid dune slacks

Intertidal mudflats and sandflats

Lime-deficient dune heathland with crowberry*

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Reefs

Shifting dunes

Shifting dunes with marram

Subtidal sandbanks

(* indicates priority habitat)

Berriedale and Langwell Waters SAC

Atlantic salmon

River Evelix SAC Freshwater pearl mussel

River Moriston SAC Atlantic salmon

Freshwater pearl mussel

River Oykel SAC

Atlantic salmon


River Spey SAC

Atlantic salmon

Sea lamprey


Otter

River Thurso SAC Atlantic salmon

River Borgie SAC Atlantic salmon


Otter

River Dee SAC

Atlantic salmon


Otter

River Naver SAC

Atlantic salmon


East Caithness Cliffs SPA Cormorant (breeding)

Fulmar (breeding)

Great black-backed gull (breeding)

Guillemot (breeding)

Herring gull (breeding)

Kittiwake (breeding)

Peregrine (breeding)

Puffin (breeding)

Razorbill (breeding)

Shag (breeding)

Seabird assemblage (breeding)

North Caithness Cliffs SPA Fulmar (breeding)




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Puffin (breeding)

Razorbill (breeding)


Hoy SPA Arctic skua (breeding)

Fulmar (breeding)

Great black-backed gull (breeding)

Great skua (breeding)




Puffin (breeding)

Red-throated diver (breeding)



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4 Description of Items to be Decommissioned

4.1 Layout of the Development

4.1.1 Figure 4.1 shows the layout of the Development wind turbines and OTMs (the export

cable route corridor is shown in Figure 3.1 above).

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4.2 Development Elements to be Decommissioned

4.2.1 The following elements of the Development will be decommissioned. Further details of

the decommissioning process, including the decommissioning method for each of the

major components, are set out in Section 5.

Wind Turbines

4.2.2 Horizontal axis wind turbines will be used which are made up of three main external

components as follows.

Rotor – comprised of the blades, hub, spinner and spinner bracket;

Nacelle - housing the electrical generator, the control electronics and gearbox,

adjustable speed drive or continuously variable transmission; and

Structural support - includes the tower and rotor yaw mechanism which allows the

wind turbine rotor to turn against the wind.

4.2.3 The main components to be decommissioned are summarised in Table 4.1.

Table 4.1 - Summary of wind turbine components to be decommissioned

Component Number Key dimensions

Wind turbine tower sections

84 towers in 3 sections Hub height:110 m above Lowest Astronomical Tide (LAT)

Total tower height: 85 m (approx.)

Tower diameter (base): 6 m

Tower diameter (top): 4.145 m

Wind turbine nacelles

84 Siemens 7MW nacelles

Size: 20.6 m (l) x 9 m (h) x 9.1 m (w)

Wind turbine blades

84 x 3 rotor blades Blade length: 75 m (154 m rotor diameter)

Wind Turbine Support Structures (Foundations and Substructures)

4.2.4 The wind turbine foundations will be comprised of four steel pin piles per structure,

which will be attached by grouted connection to a jacket substructure.

4.2.5 The jacket substructures and pin piles will vary in length depending on seabed

conditions and water depth. The pin piles will have a diameter of 2.2 m and have a

length of circa 35 - 60 m.

4.2.6 The jacket substructure will be of tubular steel lattice design with four legs. Transition

pieces will be mounted on the jacket substructures during fabrication and will form the

point of connection between the wind turbine tower to the support structure.

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4.2.7 The main components to be decommissioned are summarised in Table 4.2.

Table 4.2 - Summary of support structure components to be decommissioned

Component Number Key dimensions

Foundation piles 86 x 4 piles

(84 wind turbine foundations plus 2 OTM foundations)

Pile diameter: 2.2 m

Pile length: variable estimated 35 to 60 m

Jacket Substructure (including flanged wind turbine/jacket transition piece connection)

86 four leg jacket structures

(84 wind turbine foundations plus 2 OTM foundations)

Height: variable circa 57 to 77 m

Size at seabed (pile centre to pile centre): 24 m x 24 m

Grouted pile connection

86 x 4 jacket leg connections

-

4.2.8 An illustration of a tubular jacket substructure is provided in Figure 4.2.

Figure 4.2 – Wind turbine and OTM support structure – example of a tubular jacket

substructure

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Offshore Transformer Modules and Foundations

4.2.9 Two OTMs will be installed to collect the generated electricity and convert the electricity

from 33kV to 220kV for transmission to shore by the two export cables.

4.2.10 The OTMs comprise two elements: the topside and the support structure. The main

components to be decommissioned are summarised in Table 4.3. The OTM support

structure will be as described for the wind turbines above and summarised in Table

4.2.

4.2.11 An illustration of a typical indicative OTM is provided in Figure 4.3.

Table 4.3 – Summary of OTM components to be decommissioned

Component Description Key dimensions

OTM Two OTMs comprising:

Two jacket substructures; and

Two OTM topside modules

Jacket substructures: see Table 4.2

OTM topside size: 33 m (l) x 19.2 m (w) x 9 m (h)

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Figure 4.3 - Example of an OTM top-side layout installed on a jacket structure and arrangements

of topsides and cable deck

Inter-array Cables

4.2.12 The inter-array cables are the cables which connect the wind turbines to each other

and to the OTMs. The main components to be decommissioned are summarised in

Table 4.4.

4.2.13 It is BOWL’s preferred option to bury the inter-array cables. It is therefore not currently

anticipated that cable protection material will be needed. Only close fitting mechanical

protection between the seabed and J-tubes is anticipated. The exception to this would

be where the intended depth of cover (i.e. the thickness of material on top of the cable

after installation) is not achieved during installation.

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Table 4.4 – Summary of inter-array cabling to be decommissioned

Component Description Image Key dimensions

Inter-array cabling 3-core 33kV armoured submarine cable consisting of:

42 No. Type 1 (indicative cross-sectional area of 630mm2);

48 No. Type 2 (indicative cross-sectional area of 400mm2).

Example 3 core cable

Up to 170 - 190km in total length

Offshore Transmission Works - Export Cables

4.2.14 Two HVAC export power cables will connect to the OTMs and will run to the cable

landfall point west of Portgordon where they will connect with the onshore transmission

works. The main components to be decommissioned are summarised in Table 4.5.

Table 4.5 – Summary of inter-array cabling to be decommissioned

Component Description Image Key

dimensions

Export cables From offshore array to landfall (approx. 65 km length):

One armoured submarine 3-core 220kV cable per circuit (two circuits) consisting of aluminium conductors with a cross-sectional area of 1200mm2.

At landfall, under beach (approx. 1 km length):

One armoured submarine 3-core 220kV cable per circuit (two circuits) consisting of copper conductors with a cross-sectional area of 1600mm2.

Example 3 core cable

Up to130km in total length (for two cables combined)

Metocean Buoys

4.2.15 Up to three metocean buoys may be anchored to the seabed within the Wind Farm

area to gather data on the wave and tidal regime throughout the lifetime of the

Development.

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Scour Protection

4.2.16 No scour or cable protection measures are proposed for use within the Wind Farm site

to protect the Wind Farm structures or the inter-array cables (noting the possible need

for some mechanical protection where cables approach the jacket J-tubes or where

burial is not achieved).

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5 Description of Proposed Decommissioning Measures

5.1 Introduction

5.1.1 This section provides an overview of the decommissioning options available and sets

out the proposed approach to the decommissioning of the Development as described

in Section 4 above.

5.2 Decommissioning Options

5.2.1 BOWL have considered alternative options for the decommissioning of the

Development; a brief summary of the options is set out below. When making a final

decision on the approach to decommissioning towards the end of the lifetime of the

Development, BOWL will take into consideration the Best Practicable Environmental

Option (BPEO), commercial viability and HSE risks.

5.2.2 The current option for the decommissioning is set out in Section 5.4. However a

number of other options may be considered as set out immediately below.

Decommissioning and construction of a new wind farm

5.2.3 For this scenario the assumption has been made that wind energy is still economically

attractive in 2044 and the technical integrity of the Wind Farm is declining. If this were

the case, installing new and better technology may be more profitable than increasing

the Operation and Maintenance (O&M) effort for a few extra years of running time on

the existing Wind Farm. Under such a scenario, the existing Wind Farm would be

decommissioned (following the process set out under Section 5.4 below) and a new

wind farm erected (with all appropriate consents having been obtained beforehand).

Re-powering

5.2.4 In this scenario it is assumed that wind energy is still economically attractive in 2044,

the technical integrity of the wind turbines is declining but the electrical infrastructure

and possibly the foundations remain sound. If electrical infrastructure is installed

properly its lifetime could be up to 50 years, whilst experience from the oil and gas

industry indicates that the lifetime of foundations can also be extended outside the

design specifications.

5.2.5 By closely monitoring the structural integrity of the asset, it could be possible to re-use

these parts of the system in a re-powering of the Wind Farm – that is fitting new wind

turbines to the existing foundation and electrical systems.

Step-down

5.2.6 This scenario assumes it is not profitable to invest in new technology but that most

wind turbines will continue to perform sufficiently beyond the design lifetime of 25

years. Under this scenario, the Wind Farm would be decommissioned through a

controlled step-down. In this case wind turbines would be gradually shut down as their

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technical integrity declined. A decommissioning campaign would most likely be

undertaken when the complete Wind Farm was shut down, but could also be done

stepwise if this was found to be more cost effective or if the prevailing regulatory regime

required this approach.

5.3 Guiding Principles

5.3.1 Whatever the alternative chosen, the decommissioning process will be in line with the

following principles:

BPEO, which is the option with the most benefit or least damage to the

environment as a whole at an acceptable cost. This involves balancing

the reduction in environmental risk with practicality and cost of reducing

the risk;

Consideration of the rights and needs of legitimate users of the sea;

Safety of surface and subsurface navigation; and

HSE considerations.

5.3.2 In accordance with DECC Guidance the choice of BPEO should be informed by an

EIA. The EIA used to inform this DP is the one prepared in support of application for

consent, which is reported in the ES and SEIS dated 2012 and 2013 respectively. The

information relating to decommissioning in the ES and SEIS will be reviewed if the final

decommissioning methods and programme are substantially different from those

detailed within this DP. If necessary, more detailed assessment will be undertaken to

accompany the application(s) for Marine Licence(s) which will be required for

decommissioning of the Development.

5.3.3 In considering the proposed DP for the Development, BOWL will seek solutions for

each offshore element of the Wind Farm that seek to follow the principles described in

Table 5.1.

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Table 5.1 - Guiding principles in considering the proposed decommissioning programme for

the Wind Farm

Guiding Principle Comments

No harm to people BOWL is committed to adhering to the highest standards for

health and safety throughout the lifecycle of the project. BOWL

seek to promote safe practices and minimise risk in the

development and implementation of decommissioning solutions.

Consider the rights

and needs of

legitimate users of

the sea

BOWL respects the rights and needs of other users of the

sea. Decommissioning activities will seek to minimise the impact

on stakeholders and emphasis will be placed on clear, open

communication.

Minimise

environmental impact

The BPEO, at the time of considering the precise

decommissioning procedure, will be chosen in order to minimise

impact on the environment at an acceptable cost.

Promote sustainable

development

In decommissioning, BOWL will seek to ensure that, as far as is

reasonably practicable, future generations do not suffer from a

diminished environment or from a compromised ability to make

use of marine resources.

Adhere to the

Polluter Pays

Principle

BOWL's decommissioning and waste management provisions

acknowledge our responsibility to incur the costs associated with

our impact on the environment.

Maximise re-use of

m aterials

BOWL is committed to maximising the re-use of waste materials

and pays full regard to the 'waste hierarchy'.

Ensure commercial

viability

In order that commercial viability is maintained, the BATNEEC

(Best Available Technique not Entailing Excessive Cost)

decommissioning solutions will be sought.

Ensure practical

integrity

Solutions that are necessary to achieve one or more of the above

objectives must be practicable.

5.3.4 Taking into account the UK’s commitments under the United Nations Law of the Sea

(UNCLOS); International Maritime Organisation (IMO) standards and the work of the

Convention for the Protection of the Marine Environment of the North-East Atlantic

(OSPAR), BOWL’s starting assumption in establishing the decommissioning

requirements has been complete removal of all offshore components to shore for re-

use, recycling or incineration with energy recovery or disposal at a licensed site. This

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assumption has been assessed for all components against the key principles

presented above. In some instances this option has not been considered to be

appropriate and alternative options have been considered. These alternatives have

also been assessed according to the above principles and the optimum solution

selected.

5.3.5 The DECC guidance (DECC, 2011) notes there are some cases where it may be

possible to consider solutions other than complete removal. This includes where

foundations or structures are located below the level of the sea bed:-

Where an installation’s foundations extend some distance below the level of

the sea-bed, removing the whole of the foundations may not be the best

decommissioning option, given the potential impact of removal on the marine

environment, as well as the financial costs and technical challenges involved. In

these cases, the best solution might be for foundations to be cut below the

natural sea-bed level at such a depth to ensure that any remains are unlikely to

become uncovered. The appropriate depth would depend upon the prevailing

sea-bed conditions and currents. Contingency plans should be included in the

decommissioning programme, to describe the action proposed if the foundations

do become exposed.

5.3.6 The following sections on the approach to decommissioning identify those parts of the

Beatrice Development where BOWL propose that the infrastructure will therefore be

left in situ and provides an assessment of the decommissioning options in relation to

the guiding principles set out in Table 5.1, specifically in relation to:

Wind turbine and OTM foundations; and

Inter-array and export cables.

5.3.7 All work will follow the recommendations and requirements of the Construction (Design

and Management) (CDM) Regulations 2015 (or applicable regulations at the time the

work starts).

5.4 Proposed Decommissioning Process

Wind Turbines Generators

5.4.1 The wind turbines will be decommissioned in full. The removal of turbine components

including blades, nacelle, and tower and will be a reversal of the installation process.

5.4.2 The general methodology for carrying out wind turbine decommissioning will be:

De-energise wind turbines and isolate from the grid;

Mobilise suitable heavy lift vessels to site;

Remove turbine blades;

Removal of all tower/nacelle internal cables that connect the generator and transformer as well as related control and communication cables;

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Remove nacelle including the gearbox and generator;

Dismantle and remove turbine tower; and

Transportation of all components to an onshore facility for processing.

5.4.3 Once onshore, components are likely to be processed as follows:

All hazardous substances and fluids will be removed from the wind turbines (such as oil reservoirs and any hazardous materials and components). All such materials will then be disposed of in accordance with relevant regulations at the time of disposal;

All steel components will be sold for scrap to be recycled. This forms the bulk of the wind turbine structures; and

The wind turbine blades (fibreglass) will be disposed of in accordance with the relevant regulations in force at the time of decommissioning.

5.4.4 Table 5.2 provides an assessment of the wind turbine decommissioning process

against the guiding principles outlined in Table 5.1.

Table 5.2 - Assessment of proposed wind turbine decommissioning process against guiding

principles


No harm to people Safest option, involving standard procedures and minimal work

offshore.

Consider the rights

and needs of

legitimate users of the

sea

Complete removal of wind turbines considered best long term

solution. Appropriate notification and consultation prior to

temporary works to minimise disruption.

Minimise environmental

impact

Risk of spillage minimal as a result of all potential pollutants being

fully contained within the nacelle and nacelle being removed in a

single lift. All subsequent dismantling takes place onshore

thereby minimising potential for pollution incidents.

Promote sustainable

development

Wind turbines and support structures completely removed from

site ensures no ongoing environmental impacts and no restriction

on future use of marine resources.

Adhere to the

Polluter Pays

Principle

Entirely consistent with this principle – full removal and disposal.

Maximise re-use of

m aterials

All dismantling of individual major components (i.e. nacelle) to

take place onshore. Maximum potential for re-use or recycling.

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Ensure commercial

viability

Most commercially viable solution – minimal works offshore and

maximum potential for re-sale/re-use value from turbine

components with minimum residual risk.

Ensure practical

integrity

Known/tried and tested procedures and reduced risks due to

minimising of offshore activity.

Support Structures - Foundations and Substructures

5.4.5 The following sections set out the proposed decommissioning approach for the support

structures - piled foundation and jacket substructures.

Jackets (including transition pieces)

5.4.6 Decommissioning of a jacket structure will be the reverse of the installation process.

Following the separation of the jacket from the piles, the jacket will be lifted off the piles

by a heavy lift vessel and recovered and taken ashore for re-use or scrap recycling.

5.4.7 Table 5.3 provides an assessment of the jacket substructure decommissioning

process against the guiding principles outlined in Table 5.1.

Table 5.3 - Assessment of proposed jacket substructure decommissioning process against

guiding principles


No harm to people Heavy lift and removal to shore for disassembly minimises work

offshore.

Consider the rights

and needs of

legitimate users of

the sea

Complete removal of structure considered best long term solution.

Appropriate notification and consultation prior to temporary works to

minimise disruption.

Minimise

environmental

impact

Minimal risk of environmental impact arising from jacket lifting and

removal; subsequent dismantling or cutting would take place onshore

thereby minimising potential for environmental impacts at sea.

Promote

sustainable

development

Jacket substructures completely removed from site and ensures that

no ongoing environmental impacts and no restriction on future use of

marine resources.

Adhere to the

Polluter Pays

Principle

Entirely consistent with this principle – full removal and disposal.

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Maximise re-use of

m aterials

Any dismantling to take place onshore. Maximum potential for re-use

or recycling.

Ensure commercial

viability

Most commercially viable solution – minimal works offshore and

maximum potential for re-sale/re-use value with minimum residual risk.

Ensure practical

integrity

Known/tried and tested procedures and reduced risks due to

minimising of offshore activity.

Pin Pile Foundations

5.4.8 The proposed approach to the decommissioning of the pin pile foundations (wind

turbines and OTMs) is to cut off the piles at or below sea bed level. Currently, abrasive

diamond wire cutting is considered likely to be the preferred method for the cutting of

the piled foundations, but other methods may be preferred at the time of

decommissioning. The material cut off from the pin piles will be recovered and taken

ashore for scrap recycling.

5.4.1 Table 5.4 provides an assessment of the piled foundation decommissioning options


Table 5.4 – Assessment of piled foundation decommissioning options against guiding

principles

Criterion Complete removal of piled foundations

Cutting of piled foundations at or below seabed level

No harm to

people

Significant excavation required to

remove seabed material prior to pile

recovery. Excavation would need to

be undertaken by divers and hazards

to dive teams would be significant

due to the nature of the work involved

and duration of operations.

Fewer activities to be undertaken

over a shorter time period offshore,

minimising risk to personnel. Post

decommissioning site monitoring will

identify any unlikely exposure with

the result that safety risk is

insignificant (see Section 14).

Consider the

rights and

needs of

legitimate

users of the

sea

Disadvantages to other users of the

marine environment include

disruption over a longer time period

whilst the works are undertaken and

remaining scour holes associated

with excavation.

Negligible risk presented providing

adequate consultation and

notification, cutting is to a sufficient

depth, site is monitored post

decommissioning and any unlikely

exposure identified.

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Criterion Complete removal of piled foundations

Cutting of piled foundations at or below seabed level

Minimise

environmental

impact

Excavation pits over a wide area

causing potentially significant impact

to marine environment. Associated

dumping of excessive volume of

excavated waste material may be

required. Disturbance would take

place over long time period.

Considerably reduced works

footprint relative to complete

removal. Works would take place

over reduced time period and

involve less equipment. Seabed

recovery time shorter than complete

removal scenario.

Promote

sustainable

development

In the long term complete removal

affords maximum flexibility over use

of seabed, though considerable

impacts are likely over the whole site

in short to medium term

Providing remaining structures do

not become exposed most future

activities will not be affected.

Seabed recovery is considered

highly likely.

Adhere to

the Polluter

Pays Principle

Consistent in principle, assuming a

suitable disposal solution can be

found for the excavated waste

material and that the seabed can be

restored.

Consistent as far as is reasonably

practicable, all remains of piled

foundations to be suitably buried.

Maximise re-

use of

m aterials

Maximum amount of piled

foundations potentially available for

re-use.

Less foundation material available

for re-use relative to complete

removal.

Ensure

commercial

viability

Not considered commercially viable -

excavation and extreme lifting

involves major equipment

requirements over longer periods of

time.

Less expensive alternative to

complete removal, involving minimal

excavation and minimising

environmental impacts.

Ensure

practical

integrity

Not a practical solution: Extreme risk

associated with heavy lift,

considerable excavation needed with

associated storage or disposal of

large volume of waste.

Standard procedures and

equipment.

Offshore Transformer Modules

5.4.2 The decommissioning of the OTMs will follow a similar method as described for the

wind turbines and turbine foundations.

5.4.3 The complete OTM topside structure will be removed in a single lift, taken by suitable

vessel to an onshore facility where the equipment and structure will be dismantled and

the constituent parts processed for re-use, recycling and/ or disposal.

5.4.4 Following the separation of the piles and the jacket, the jacket will be lifted off the piles

and recovered to land for re-use or recycling as scrap.

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5.4.5 Decommissioning of pin piles will involve cutting off the substructure below sea bed

level. The material cut off from the pin piles will be recovered to land for recycling as

scrap.

Inter-array and Export Cables

5.4.6 The proposed approach to the decommissioning of the buried, subsea inter-array and

export cables is to leave the cables in-situ having cut and sealed the ends of the cables

and ensured that the cut ends are securely buried below the seabed. Loose ends of

cable that remain from where the main cables are cut at the wind turbines and OTMs

will be recovered to shore for subsequent recycling.

5.4.7 Table 5.5 provides an assessment of the subsea cable decommissioning options


Table 5.5 – Assessment of buried subsea cable decommissioning options against guiding

principles

Criterion Complete removal Cutting below seabed

No harm to

people

Risk to personnel not considered

excessive.

Burial within the seabed does not

pose safety risks to marine users.

Post decommissioning site monitoring

will identify any unlikely exposure with

the result that safety risk is

insignificant (see Section 14).

Consider the

rights and needs

of legitimate

users of the sea

Removal affords maximum

flexibility over use of seabed.

No risk presented from leaving buried

cables in situ. Potential for extraction

activities limited only within a limited

corridor. Site is monitored post

decommissioning and any unlikely

exposure identified.

Minimise

environmental

impact

Given the considerable length of

cable and the need for jetting

techniques, removal would

cause disruption to the seabed

and benthic habitats.

Benign - no environmental impact

associated leaving buried cables in

situ.

Promote

sustainable

development

Disturbance of the seabed in the

short-medium term, although

complete removal would allow

flexibility over use of seabed in

the longer term.

Some future activities, e.g. extraction,

may be limited but only in a limited

corridor.

Adhere to the

Polluter Pays

Principle

Consistent, assuming suitable

disposal option is found for

surplus cable components.

Benign, no pollution risk from leaving

cables in-situ.

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Criterion Complete removal Cutting below seabed

Maximise re-use

of m aterials

Maximum material, e.g. copper,

potentially available for re-use.

No re-use possible if left in situ.

Ensure

commercial

viability

Extensive cost of removal. Limited cost involved with re- burial of

cable 'ends'.

Ensure practical

integrity

Possible to undertake but would

result in impacts on the seabed

environment.

N/A

5.5 Waste Management and Residual Value of Recovered Materials

5.5.1 BOWL is committed to maximising the re-use of waste materials and will give full

regard to the ‘waste hierarchy’ which suggests that re-use should be considered first,

followed by recycling, incineration with energy recovery and, lastly, disposal. In any

event, waste management will be carried out in accordance with all relevant legislation

and with any necessary disposal taking place at licensed facilities.

5.5.2 The proposed approach to disposal of the main components of the Wind Farm is set

out in Table 5.6 but is subject to evolution of technology, change in regulations and

demand for materials over the lifetime of the Development.

Table 5.6 – Proposed disposal route for main Wind Farm components

Waste Material Pre-treatment Re-use/ Recycle/ Disposal

Wind turbine support

structures (jacket

substructures and pin

piled foundations)

Establish available design life

at end of 25 years.

Re-use by repowering with

new/superior wind turbines or

other renewable generation

technology or dismantle and

recycle the recovered

material as much as

possible.

Steel from wind

turbine tower and

nacelle removed to

shore

Break down into

transportable size.

Recycle.

Copper from power

cables and

transformers

Strip cable from power

cables and transformers.

Recycle.

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Waste Material Pre-treatment Re-use/ Recycle/ Disposal

Glass-fibre Reinforced

Epoxy (GRE) from

wind turbine blades

Break down into

transportable size.

Disposal or recycle where

facilities exist.

Used lubricants from

wind turbine

Filter. Recycle.

Non-recyclable

materials and fluids

None. Incineration with energy

recovery or disposal via

landfill.

5.5.3 The final details of the DP will be confirmed prior to decommissioning to accommodate

changes in legislation, guidance and technology. As part of this process, appropriate

waste management regulations and guidelines will be reviewed. A Waste Management

Plan (WMP) will be prepared in advance of the commencement of decommissioning

to ensure that adequate time is allowed for the necessary provisions to be made with

regards to waste management.

5.6 Lighting and Marking

5.6.1 In accordance with the requirements of the Development S36 Consent and Marine

Licences, the appropriate marks and lights shall be exhibited during the

decommissioning of the Wind Farm.

5.6.2 In relation to aviation safety, the shape, colour and character of the lighting will be

compliant with the Air Navigation Order 2009 (or then current regulation or as

otherwise directed by the Civil Aviation Authority).

5.6.3 In relation to navigational safety, lights and markings will be discussed with the

Northern Lighthouse Board (NLB), in consultation with the Maritime and Coastguard

Agency (MCA). In particular, the NLB will be consulted prior to decommissioning to

specify any obstruction marking that may be required during the removal operations.

In the event that any obstruction is left on site that may be considered to present a

hazard to navigation the necessary marking specified by NLB shall be displayed.

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6 Environmental Impact Assessment

6.1.1 In support of the consent applications BOWL prepared an EIA for the Development as

reported in the ES dated April 2012, with further information provided via the SEIS

dated May 2013.

6.1.2 In complying with the requirements of the EIA Directive, a lifecycle approach was taken

in assessing the impacts of the Development and in seeking to mitigate and minimise

the effect of the works. In all instances a ‘worst case’, Rochdale Envelope approach

was taken to the assessment. The assessment of the impacts included the process of

decommissioning so far as it could be predicted at the time.

6.1.3 In consultation with MS-LOT, the information relating to decommissioning in the ES

and SEIS will be reviewed when the final details of the DP are confirmed prior to

decommissioning activities taking place. Subject to the results of this consultation, and

provided that there have not been substantial changes to the baseline environment

beyond those predicted in the ES/SEIS, to the legislative process or to the methods

proposed for decommissioning, it is not currently proposed to undertake a new EIA for

decommissioning.

6.1.4 Key criteria that will inform the decision as to the need for a new or updated EIA include

consideration of:

The understanding of the baseline environment at the time just prior to decommissioning, informed by the findings of the environmental monitoring of the development and engineering/ asset surveys such as cable burial monitoring;

A review of other marine use (fishing, navigation, etc.) with potential to be affected by decommissioning;

Amenities, the activities of communities and on future uses of the environment; and

Historic environment interests.

6.1.5 If required, then the decommissioning EIA would fill any information gaps in relation to

these issues and would also describe the measures envisaged to avoid, reduce and,

if possible, remedy any likely significant adverse impacts arising from the

decommissioning process.

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7 Consultation with Interested Parties

7.1.1 BOWL regards effective and open communication and consultation as essential

elements to the successful development of the Beatrice project. These principles have

been adopted during the development of the project and will be applied during the life

of the Development including the decommissioning phase of the project.

7.1.2 Section 105(7) of the Energy Act 2004 provides that a notice given under Section 105

may require the recipient of the notice to carry out consultation specified in the notice

before submitting a decommissioning programme.

7.1.3 The Section 105 notice issued to BOWL by DECC sets out those bodies to be

consulted on this draft DP. These are as follows:

Marine Scotland;

British Marine Aggregate Producers Association (BMAPA);

Chamber of Shipping (CoS);

Joint Nature Conservation Committee (JNCC);

Highland Council;

Historic Scotland;

Maritime and Coastguard Agency;

Moray Council;

Northern Lighthouse Board;

Royal Yachting Association (Scotland) (RYA);

Relevant harbour authorities (Aberdeen, Wick, Invergordon, Nigg, and

Buckie);

Scottish Environment Protection Agency (SEPA);

Scottish Fisherman’s Federation (SFF);

Marine Scotland Compliance (responsible for the duties formerly undertaken by the Scottish Fisheries Protection Agency (SFPA)); and

Scottish Natural Heritage (SNH).

7.1.4 In addition, and in line with the requirements of the Section 105 notice, BOWL will

make the DP available by publishing the draft on the Project website.

7.1.5 At the time of decommissioning, BOWL will issue timely and efficient Notices to

Mariners (NtMs) and other navigational warnings of the position and nature of the

decommissioning activities taking place. Efforts will be made to ensure that this

information reaches mariners in the shipping and fishing industry as well as

recreational mariners. The UK Hydrographic Office will be notified as appropriate on

the progress and completion of the works.

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8 Costs

8.1.1 All required decommissioning cost information has been provided in confidence in


Information.

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9 Financial Security

9.1.1 All required financial security information has been provided in confidence in Appendix

B (confidential) - Beatrice Offshore Wind Farm Financial Security Information.

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10 Schedule

10.1.1 A full decommissioning schedule will be provided closer to the point of

decommissioning setting out the detailed programme of the proposed

decommissioning works for consultation with the relevant authorities.

10.1.2 At this stage it is proposed that decommissioning would commence at year 25 after

final commissioning of the Development, coinciding with the end of the design life of

the wind turbines (but noting the options set out in Section 5.2).

10.1.3 It is proposed that the full decommissioning of Development will take approximately 12

months to complete. Offshore decommissioning and onshore dismantling of the

decommissioned infrastructure would run in parallel.

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11 Project Management and Verification

11.1.1 BOWL intends to undertake internal reviews of the DP throughout the lifetime of the

project. Once the Development is nearing the end of its agreed 25 year consent

period, BOWL will initiate a final review of the DP and finalise the detail of the

decommissioning provisions. This will include project management arrangements, the

schedule, costs and the verification processes to ensure decommissioning is

completed. It is anticipated that the development of the final DP will occur in

approximately Year 23 after final commissioning of the Development.

11.1.2 Following completion of the decommissioning works, it is anticipated that a

Decommissioning Report will be submitted to the appropriate regulatory authorities. In

accordance with the DECC guidance (DECC, 2011) the decommissioning report will

include:

Confirmation that decommissioning has been carried out in accordance with the approved decommissioning programme or an explanation of any major variances from the programme;

Information on the outcome of decommissioning, including confirmation of sea-bed clearance;

Confirmation that appropriate bodies have been notified of removal and of any remains;

Confirmation that appropriate aids to navigation have been installed, where required, for any remains of installations which protrude above the sea-bed and are considered to be a danger to navigation; and

Information on the actual costs of decommissioning and an explanation of any major variances from forecast costs.

11.1.3 Once the report has been submitted to DECC, BOWL will endeavour to make it

publically available.

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12 Seabed Clearance

12.1.1 In line with the details provided above, BOWL is committed to covering the costs

required to decommission the Development and ensuring the seabed has been

cleared. Where necessary, upon completion of the decommissioning works a survey

will be undertaken to ensure that all debris has been removed. The survey will enable

identification and recovery of any debris located on the seabed which may have arisen

from activities related to the decommissioning process and which may pose a risk to

navigation. The process of collecting and presenting evidence that the site is cleared

is required to be independent of BOWL. BOWL proposes that an independent survey

company complete the surveys and that they report in parallel to both BOWL and

DECC. The results of these surveys will be issued to DECC for review and comment

and a copy of the results will be sent to MS-LOT.

12.1.2 The required survey area would be determined during the decommissioning phase of

the project, taking into account good practice at the time and the views of stakeholders.

It is anticipated that the survey area would focus around the renewable energy

installations i.e. the jacket substructure locations, as it is assumed that inter-array and

export cables will be left in-situ. BOWL is aware of the current 500 m survey radius

around any oil and gas installation as set out in best practice guidance for post-

decommissioning surveys. However, due to the smaller footprint of the Beatrice

installations BOWL proposes a smaller radius could be used, for example, 100 m

(based on the area within which decommissioning of each structure would occur and

within which jack up vessel would operate).

12.1.3 Analysis of any survey data gathered will also ensure that items for removal and

disposal relate only to the Development. Consultation with relevant stakeholders will

be conducted in the event that other anomalies of archaeological interest are identified

during sea bed clearance.

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13 Restoration of the Site

13.1.1 BOWL is committed to restoring the Development area, as far as is reasonably

practicable, to the condition that it was in prior to construction of the Wind Farm.

Consistent with the decommissioning provisions detailed above, the key restoration

work will relate to:

Ensuring that foundations are cut below seabed (wind turbines and OTMs) and are made safe and adequately covered; and

Ensuring that cable ends are adequately buried, or otherwise protected.

13.1.2 Further details on how the site will be restored will be provided in the updated DP

towards the end of the project’s life.

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14 Post-decommissioning Monitoring, Maintenance and Management of the

Site

14.1.1 Given that BOWL are not proposing to fully remove all of the Development

infrastructure, some post-decommissioning activities may be required to identify and

mitigate any unexpected risks to navigation or other users of the sea. This could be,

for example, as a result of foundations or cables becoming exposed through natural

sediment movement. The requirement for monitoring and the extent and approach

taken will be determined based on the scale of the remaining infrastructure, the risk of

exposure and the risk to marine users.

14.1.2 Where considered necessary, post-decommissioning monitoring surveys of the

seabed will be carried out following the completion of the decommissioning works.

Surveys are expected to comprise geophysical survey (such as swath bathymetry,

sidescan sonar and magnetometer). The results of these surveys will be issued to

DECC for review and comment and a copy of the results will be sent to MS-LOT.

14.1.3 If an obstruction appears above the seabed following decommissioning which is

attributable to the Development, it will be marked so as not to present a hazard to other

sea users. The navigational marking will remain in place until such time as the

obstruction is removed or no longer considered a hazard. The monitoring of the

obstruction will be built into any monitoring and maintenance programme.

14.1.4 Details of the post-decommissioning monitoring, maintenance and management will

be discussed with stakeholders close to the point of decommissioning.

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15 Supporting Studies

15.1.1 A link to electronic copies of the Beatrice Offshore Wind Farm ES and SEIS is provided

in Appendix A.

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16 References

Beatrice Offshore Wind Farm Environmental Statement, April 2012.

Beatrice Offshore Wind Farm Supplementary Environmental Information Statement,

May 2013.

Construction (Design and Management) (CDM) Regulations 2015; Available online

http://www.legislation.gov.uk/uksi/2015/51/contents/made [Accessed 21/08/2015]

Decommissioning of Offshore Renewable Energy Installations under the Energy Act

2004: Guidance notes for Industry, DECC, January 2011 (revised); Available online

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/80786/ore

i_guide.pdf [Accessed 21/08/2015]

Guidelines and Standards for the Removal of Offshore Installations and Structures on

the Continental Shelf and in the Exclusive Economic Zone, International Maritime

Organisation (IMO), 19th October 1989; Available online

http://www.imo.org/blast/blastDataHelper.asp?data_id=22503&filename=A672(16)E.pdf

[Accessed 21/08/2015]

Marine (Scotland) Act 2010; Available online

http://www.legislation.gov.uk/asp/2010/5/contents [Accessed 21/08/2015]

Marine Scotland. Appropriate Assessment for the Beatrice Offshore Windfarm.

Available online http://www.gov.scot/Resource/0044/00446505.pdf

OSPAR Convention for the Protection of the Marine Environment of the North East

Atlantic; Available online

http://www.ospar.org/html_documents/ospar/html/ospar_convention_e_updated_text_20

07.pdf [Accessed 21/08/2015]

The Conservation (Natural Habitats &c.) Regulations 1994 (as amended); Available

online http://www.legislation.gov.uk/uksi/1994/2716/contents/made [Accessed

21/08/2015]

The Energy Act 2004 (as amended); Available online

http://www.legislation.gov.uk/ukpga/2004/20/contents [Accessed 21/08/2015]

The Pollution Prevention and Control (Scotland) Regulations 2012; Available online

http://www.legislation.gov.uk/sdsi/2012/9780111018408/contents [Accessed

21/08/2015]

The Special Waste Regulations 1996 (as amended); Available online

http://www.legislation.gov.uk/uksi/1996/972/made [Accessed 21/08/2015]

United Nations Convention on the Law of the Sea (UNCLOS), 1982; Available online

http://www.un.org/depts/los/convention_agreements/texts/unclos/unclos_e.pdf

[Accessed 21/08/2015]

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Appendix A - Beatrice Offshore Wind Farm ES and SEIS

The ES and SEIS can be accessed online, under the ‘More Information’ menu on the

Beatrice project website at:

www.sse.com/beatrice

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