Marine licensing and consenting: offshore renewable energy projects
Guidance for offshore renewable energy projects on marine licensing and consenting requirements that are administered by the Marine Directorate – Licensing Operations Team (MD-LOT) on behalf of Scottish Ministers.
Mitigation and monitoring plans
This section provides guidance on mitigation and monitoring plans which are usually required to be submitted as part of an application or at the ‘post-consent’ stage of the section 36 and marine licensing process. The plans cover the mitigation or monitoring of effects from the construction and/or operation of offshore renewable energy generating stations and transmission infrastructure.
This guidance does not cover advice on what is required in relation to decommissioning. MD-LOT should be contacted directly for advice in respect of decommissioning.
Terminology and language used in plans relating to commitments on what is to be implemented, and when, should be clear. Such commitments can include descriptions of what actions would be implemented under different scenarios. Where there is lack of clarity on commitments made, it is unlikely that the particular plan would be approved. In such cases, amendments may be required, which could delay process, or alterations may be mandated through conditions.
In some cases, applicants may choose to apply for marine licences for the construction of the generating station and construction of transmission infrastructure separately. In such cases mitigation and monitoring plans will be required to cover each application or licence condition. Applicants should consider whether separate plans for each application or licence condition would be the most efficient administrative approach, in particular, if there are specific mitigation measures and/or monitoring to be carried out during the operational phase. This will ensure clarity on the requirements on each licensee where the transmission infrastructure is transferred to a new licensee, for example, during the operational phase.
Where possible, all mitigation and monitoring plans required should be submitted with an appropriate level of detail at the application stage, subject to the below expectations. In cases where further detail is required after a marine licence or section 36 consent has been granted, licence or consent conditions can require the submission of a plan that then must be approved by the Scottish Ministers before all or part of the activity permitted can begin. Such plans are referred to as ‘post-consent plans’.
Certain, more standardised, plans, and in particular those which are less reliant on details of exact project parameters, should be submitted as part of the application. This improves efficiency and overall administrative timeframes, ensures that public and stakeholder consultation on an application is based on the fullest possible level of detail and ensures the best and most efficient use of information in the determination of applications. Such plans should contain sufficient information at the application stage and should not require an update and approval process after consents and licences have been granted, prior to construction starting. In order to demonstrate commitments and reduce future administration, plans should not be marked as ‘draft’ or ‘outline’, but should have clear version management.
From 1 April 2025, the following plans should be submitted with applications:
Fisheries Mitigation, Monitoring and Communication Plan
The Fisheries Mitigation, Monitoring and Communication Plan (previously known as the Fisheries Management and Mitigation Strategy) has been re-named to clarify and better reflect its purpose.
The Fisheries Mitigation, Monitoring and Communication Plan (in this section referred to as “the plan”) describes the mitigation, monitoring and communication that will be put in place by a licensee or consent holder to avoid or minimise the adverse effects of a project on commercial fisheries.
The plan should be submitted at the application stage and contain sufficient information for stakeholders to make informed representations and the regulator to determine an application. It should not be submitted on the basis that further updates and the associated post-consent approval processes will be required prior to construction starting (after marine licences and section 36 consents have been granted). However, should updates be required, relevant conditions would allow plans to be updated as required.
Terminology and language used should be clear on commitments of what will be implemented and timelines for implementation. Such commitments can include information on what would be implemented under different scenarios which may arise. Where there is lack of clarity on commitments it is unlikely that the plan will be approved. In such cases, amendments may be required which could delay process or alterations may be mandated through conditions.
Prospective applicants should consult all relevant fisheries stakeholders on the content of the plan throughout the pre-application stage. All efforts should be made to agree the Fisheries Mitigation, Monitoring and Communication Plan with those interests. Consultation may be carried out at the same time as pre-application engagement on other aspects of a project, for example on the Environmental Impact Assessment.
The plan should cover all the phases of a project that the licence or consent application relates to. For offshore renewable energy, licence and consent applications usually relate to the construction and operational phases. Where decommissioning requires a separate marine licence, a separate Fisheries Mitigation, Monitoring and Communication Plan may be required at that time.
If marine licences for the construction of the generating station and construction of transmission infrastructure are applied for separately, a Fisheries Mitigation, Monitoring and Communication Plan will be required to cover each activity. Prospective applicants should consider if a separate plan for each licence application would be the most efficient administrative approach, in particular if there are specific mitigation measures and/or monitoring to be carried out during the operational phase. This will ensure clarity on the requirements upon each licensee where a marine licence for transmission infrastructure is transferred to a new licensee during the operational phase.
The plan should not include any information on financial arrangements as this cannot be considered in, or controlled by, marine licensing or section 36 consenting.
The plan should be in accordance with Scotland’s National Marine Plan. National Marine Plan objectives and policies should be considered during the drafting of the plan. In particular fisheries policies (e.g. FISHERIES 2 and FISHERIES 3), such as the requirement to involve, and try to gain agreement with, the local fishing interests in the development of the plan (called ‘strategy’ in National Marine Plan policy) and policies on what could be included in the plan.
The plan should contain information specific to commercial fisheries and fish stocks. Mitigation, monitoring and communication required for the safety of navigation will be covered by other plans and conditions. The Maritime and Coastguard Agency and the Northern Lighthouse Board are consultees on the safety of navigation.
Relevant commercial fisheries guidance includes:
- Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) Best Practice Guidance for Offshore Renewables Developments: Recommendations for Fisheries Liaison
- Collaborative Offshore Wind Research into the Environment (COWRIE) Options and Opportunities for Marine Fisheries Mitigation Associated with Windfarms
- Scottish Government Assessing fisheries displacement by other licensed marine activities: good practice guidance
- Scottish Government Offshore windfarms - monitoring impacts on the commercial fishing industry: good practice guidance
- ScotMER publications
- Scottish Government National Marine Plan
The Fisheries Mitigation, Monitoring and Communication Plan should include the following information:
Summary of impacts
To meet National Marine Plan policies, a summary of the impacts on commercial fisheries and fish and shellfish stocks should be provided. The impacts on commercial fisheries should include both socio-economic impacts and impacts on environmental sustainability.
Information should be provided on each commercial fishery that is affected; on the activities which impact those commercial fisheries (e.g. likely vessel transits, wind turbine or cable construction or presence etc.); and at which phase of a project (construction, operation or decommissioning).
A summary of, or reference to, relevant conclusions of the EIA Report can be given.
A summary of how the Fisheries Mitigation, Monitoring and Communication Plan relates to any commitments in the EIA Report should also be provided.
Mitigation
The plan should describe the mitigation which will be put in place to avoid or minimise the adverse impacts on commercial fisheries. Mitigation measures should be reasonable and proportionate to the adverse effects. If an EIA concludes there to be no significant adverse effects, mitigation measures to address smaller scale, but locally significant, effects may still be required as part of the marine licensing process and to meet policy requirements of Scotland’s National Marine Plan.
Mitigation includes any measures to avoid, prevent, reduce or offset adverse impacts on commercial fisheries and fish stocks.
Mitigation measures should be targeted at each commercial fishery where adverse impacts have been identified.
All mitigation options should be considered, and preferred options informed by the relevant commercial fisheries stakeholders at the pre-application stage.
Mitigation through the design of the generating station or transmission infrastructure to avoid or minimise impact on commercial fisheries can be included. Detailed designs do not have to be provided but any commitments to design principles can be described (e.g. approach to wind farm layout, approach to cable routes e.g. chosen to maximise cable burial, design of cable protection etc).
The plan should also describe what remedial actions will be taken to address any differences between project design and as-built parameters, for example where cable protection is not in accordance with project design.
Other mitigation measures, for example those set out in the Collaborative Offshore Wind Research into the Environment (COWRIE) Options and Opportunities for Marine Fisheries Mitigation Associated with Windfarms should be considered for inclusion in the plan. These include:
- measures to enhance stocks of targeted species and/or associated habitats
- research into species of fisheries or aquaculture interest
- measures to support existing fishing activities
- measures to develop new fisheries opportunities or other non-fisheries opportunities
As the location of construction and operation ports may not be known at the time of application, vessel transit routes and vessel anchoring areas should not be presented in the Fisheries Mitigation, Monitoring and Communication Plan but will be set out in the Vessel Management Plan that is likely to be required post-consent. However, agreement of transit routes to and from construction and operation bases to the generating station or transmission infrastructure and on anchoring areas for vessels associated with construction and operation may be identified as mitigation and described in the Vessel Management Plan. Agreement should be reached between commercial fisheries stakeholders and licensees, with the aim of minimising interference with commercial fishing activity.
Proposals for the adaptation of mitigation should be described and linked to the relevant monitoring (described in monitoring section) of effectiveness of mitigation.
Timescales for the implementation of mitigation measures should be provided. Timescales can be described as relative to certain stages (e.g. number of months after the commencement of construction) exact dates do not have to be given.
Monitoring
The plan should confirm if any monitoring of commercial fisheries will be carried out and the purpose of any monitoring.This could include monitoring of a project’s effects on certain fisheries or of the effectiveness of fisheries related mitigation and how this supports any adaptive management.
Monitoring proposals may include post-construction surveys to identify that any proposed design details have been achieved once construction has been completed. If post-construction surveys are proposed, details should be provided. A description of how the results of any survey feeds back to any remedial actions that will be taken if the survey identifies any as-built details that are not within the proposed design parameters should be given (if required reference can be made to any description in the mitigation section).
Timescales for monitoring and reporting should be provided. Timescales can be described as relative to certain stages (e.g. number of months after the commencement of construction) exact dates do not have to be given.
Communication
Information on how the licensee will communicate with commercial fisheries stakeholders should be provided. It should provide information on what will be communicated, how and when, and may include for example:
- use of Company Fishing Liaison Officers (CFLOs) and Fishing Industry Representatives (FIRs) with details of the remit of these roles, what will be communicated and how
- details of how certain information will be provided in e.g. locations of cable protection, format information will be provided in, when it will be provided and how and it will be provided
- regular updates on website and / or emails to identified contacts, with details on what type of information would be communicated and how this would be distributed e.g. through relevant fishing federations or associations, CFLOs and FIRs
- communication with a project marine coordination centre, with information on when this may be required and how contact details will be shared
- Seafish Kingfisher Bulletin service, with details on what type of information would be communicated
- FishSafe, with details on what type of information would be communicated
- UKHO Radio Navigation Warnings with details on what type of information would be communicated
- UKHO Notice to Mariners with details on what type of information would be communicated
- Port Notice to Mariners within limits of a Harbour Authority, with details on what type of information would be communicated
- Local Notification with details on what type of information would be communicated
- how relevant persons, e.g. contractors, working for the licensee will be made aware of, and follow, the communication plan
The plan provided with the marine licence and section 36 application should not provide personal information e.g. details of individuals such as names and contact numbers. It should provide enough information to clarify how communication will take place, e.g. job titles or places of work that should be contacted, where contacts details will be held or how they will be shared. It will be the responsibility of the licensee to hold personal details required in accordance with data protection legislation.
Further information on communication with commercial fishers can be found in Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) Best Practice Guidance for Offshore Renewables Developments: Recommendations for Fisheries Liaison.
Summary of stakeholder engagement
A summary of the stakeholder engagement that was carried out in relation to the Fisheries Mitigation, Monitoring and Communication Plan should be given. This should include:
- information on the type of engagement that was carried out and when it was carried out
- information on how stakeholder views informed mitigation measures, any monitoring or communication plans. Where stakeholder views did not affect a change reasons for this should be given
- reasons for any divergence of views between the parties should be fully explained in circumstances where it does not prove possible to agree the plan with all interests
Written Scheme of Investigation and Protocol for Archaeological Discoveries
The Written Scheme of Investigation and Protocol for Archaeological Discoveries describes the measures that will be put in place to avoid or minimise the adverse effects of the project on marine archaeology and historic environment.
The Written Scheme of Investigation and Protocol for Archaeological Discoveries should contain sufficient information at the application stage. They should not require an update and approval process prior to construction starting (after marine licences and section 36 consents have been granted).
Licence or consent conditions will allow plans to be updated as required throughout the operational life of the infrastructure e.g. as may be required for any adaptive management measures.
Terminology and language used should be clear on commitments of what will be implemented and timelines for implementation. For example stating what will happen rather than ‘may’ or ‘might’ happen. It is unlikely that a Written Scheme of Investigation and Protocol for Archaeological Discoveries will be approved where there is lack of clarity on commitments.
Historic Environment Scotland should be consulted on the content of the Written Scheme of Investigation and Protocol for Archaeological Discoveries at the pre-application stage. This may be carried out at the same time as pre-application engagement on other aspects of a project, for example on the Environmental Impact Assessment.
The Written Scheme of Investigation and Protocol for Archaeological Discoveries should cover all the phases of a project that the licence or consent application relates to. For offshore renewable energy, licence and consent applications usually relate to the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the decommissioning application.
If separate marine licences are applied for (for the generating station and the transmission infrastructure) a Written Scheme of Investigation and Protocol for Archaeological Discoveries will be required for each licence application. Applicants should consider if a separate plan is required for each licence application, in particular if there are mitigation measures and/or monitoring that will be carried out at the operational phase. This will ensure clarity on the requirements of each licensee if the transmission infrastructure is transferred to a new licensee (for the operational phase).
The relevant stakeholders can provide information on the most up to date guidance, key guidance includes:
- The Crown Estate Archaeological written schemes of investigation for offshore wind farm projects
- The Crown Estate Protocol for archaeological discoveries: Offshore Renewables Projects
- Scottish Government National Marine Plan
The Written Scheme of Investigation should describe the mitigation measures and monitoring required for marine archaeology. Timescales for the implementation of any mitigation, monitoring and reporting should be provided. Timescales can be described as relative to certain stages (e.g. number of months after the commencement of construction) exact dates do not have to be given.
A summary of how the Written Scheme of Investigation and Protocol for Archaeological Discoveries relates to any commitments in the EIA Report should also be provided.
Marine Pollution Contingency Plan for offshore renewable energy
The Marine Pollution Contingency Plan describes the measures that will be put in place to respond to accidental pollution incidents.
The Marine Pollution Contingency Plan should contain sufficient information at the application stage. It should not require an update and approval process prior to construction starting (after marine licences and section 36 consents have been granted).
Licence or consent conditions will allow plans to be updated as required throughout the operational life of the infrastructure e.g. as may be required for any adaptive management measures.
Terminology and language used should be clear on commitments of what will be implemented and timelines for implementation. For example stating what will happen rather than ‘may’ or ‘might’ happen. It is unlikely that a Marine Pollution Contingency Plan will be approved where there is lack of clarity on commitments.
The Maritime and Coastguard Agency should be consulted on the content of the marine pollution contingency plan at the pre-application stage. This may be carried out at the same time as pre-application engagement on other aspects of a project, for example on the Environmental Impact Assessment.
The Marine Pollution Contingency Plan should cover all the phases of a project that the licence or consent application relates to. For offshore renewable energy, licence and consent applications usually relate to the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the decommissioning application.
If separate marine licences are applied for (for the generating station and the transmission infrastructure) a Marine Pollution Contingency Plan will be required for each licence application. Applicants should consider if a separate plan is required for each licence application, in particular if there are mitigation measures and/or monitoring that will be carried out at the operational phase. This will ensure clarity on the requirements of each licensee if the transmission infrastructure is transferred to a new licensee (for the operational phase).
Guidance on what the marine pollution contingency plan should include can be found in MCA Marine Guidance Note 654 Annex 5 Offshore Renewable Energy Installations: Requirements, guidance and operational considerations for SAR and Emergency Response.
The Marine Pollution Contingency Plan provided with the application should not provide personal information e.g. details of individuals such as names and contact numbers. It should provide enough information to clarify how processes will be implemented, e.g. job titles or places of work that should be contacted. It will be the responsibility of the licensee to hold personal contact details in accordance with data protection legislation. Licence and consent conditions may require contact details to be shared with the relevant authorities.
A summary of how the Marine Pollution Contingency Plan relates to any commitments in the EIA Report should also be provided.
Invasive Non-Native Species Mitigation Plan
The Invasive Non-Native Species Mitigation Plan describes the mitigation measures including any monitoring that will be put in place to avoid or minimise the risk of introducing or spreading marine invasive non-native species.
The Invasive Non-Native Species Mitigation Plan should contain sufficient information at the application stage. It should not require an update and approval process prior to construction starting (after marine licences and section 36 consents have been granted).
Licence or consent conditions will allow plans to be updated as required throughout the operational life of the infrastructure e.g. as may be required for any adaptive management measures.
Terminology and language used should be clear on commitments of what will be implemented and timelines for implementation. For example stating what will happen rather than ‘may’ or ‘might’ happen. It is unlikely that an Invasive Non-Native Species Mitigation Plan will be approved where there is lack of clarity on commitments.
Prospective applicants should consult NatureScot on the content of the Invasive Non-Native Species Mitigation Plan at the pre-application stage. This may be carried out at the same time as pre-application engagement on other aspects of a project, for example on the Environmental Impact Assessment.
The Invasive Non-Native Species Mitigation Plan should cover all the phases of a project that the licence or consent application relates to. For offshore renewable energy, licence and consent applications usually relate to the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the decommissioning application.
If separate marine licences are applied for (for the generating station and the transmission infrastructure) an Invasive Non-Native Species Mitigation Plan will be required for each licence application. Applicants should consider if a separate plan is required for each licence application, in particular if there are mitigation measures and/or monitoring that will be carried out at the operational phase. This will ensure clarity on the requirements of each licensee if the transmission infrastructure is transferred to a new licensee (for the operational phase).
Timescales for the implementation of any mitigation, monitoring and reporting should be provided. Timescales can be described as relative to certain stages (e.g. number of months after the commencement of construction) exact dates do not have to be given.
A summary of how the Invasive Non-Native Species Mitigation Plan relates to any commitments in the EIA Report should also be provided.
The relevant stakeholders can provide information on the most up to date guidance, key guidance includes:
- NatureScot Marine non-native species
- NatureScot 2014 Marine Biosecurity Planning
- GB non-native species secretariat
- MCA MGN 675 The merchant shipping (control and management of ships' ballast water and sediments) regulations 2022
- IMO RESOLUTION MEPC.378(80) (adopted on 7 July 2023) 2023 GUIDELINES FOR THE CONTROL AND MANAGEMENT OF SHIPS' BIOFOULING TO MINIMIZE THE TRANSFER OF INVASIVE AQUATIC SPECIES
- MCA MGN 398 Amendment 1: The merchant shipping (anti-fouling systems) regulations 2024
- Scottish Government National Marine Plan
Post-consent plans
It is likely that detail to complete the following, more standardised plans, may not be available at the application stage. If information is not available at the application stage, consents or marine licences can include conditions that require the following plans to be submitted and approved prior to construction starting. Stakeholders may be consulted during the approval process of such plans. Other plans may also be required depending on project specific requirements.
Any information provided to meet a licence or consent condition must:
- meet all the requirements of the condition
- be within the parameters of all licence or consent conditions
- be within the parameters of what has already been assessed in the application and EIA (or other assessments e.g. HRA, MPA)
If the information submitted does not meet the above requirements, amendments or variation of the marine licence or section 36 consent may be required. This subsequent approval may be assessed through the EIA multistage process.
Development Specification and Layout Plan (including Design Statement if required)
Development Specification and Layout Plans describe the project and provide information on the location and detail of what is to be built. They include all infrastructure covered by any marine licence or section 36 consent. Information on environmental and technical constraints may also be included to demonstrate any constraints on the location of infrastructure.
Development Specification and Layout Plans may include information on:
- generators (wind turbines, wave, tidal)
- inter-array cables and inter-connector cables
- offshore substation platforms and other transmission assets
- export cables
- meteorological masts
- foundation scour protection
- cable protection
- any other infrastructure
Information should be provided in a suitable format which may include pdf, excel spreadsheet and GIS.
To ensure the accessibility of the information for marine users and stakeholders, coordinates must be provided in latitude and longitude World Geodetic System 1984 (WGS84) degrees, decimal minutes (to three decimal places) format XX°X.XXX’N XXX°X.XXX’W or E.
Examples of information that may be required for offshore wind generating stations and transmission infrastructure can be seen below.
Description of project
The project description should include details and representative drawings of key structures and any designed in mitigation that is described in the application and EIA report e.g.
- generators (wind turbines, wave, tidal), offshore substation platforms, including information on foundation and/or mooring types
- type of foundation scour protection
- inter-array cables, inter-connector cables, export cables including information on cable arrangements
- type of cable protection
- meteorological masts
- any other infrastructure
- any nature inclusive design features
Suitably scaled charts showing:
- identification/numbering of each structure (e.g. wind turbine generators, offshore substation platforms, meteorological masts, cables)
- location of the centre point of each structure (e.g. wind turbine generators, offshore substation platforms, meteorological masts). For floating structures this should be the centre point of each floating platform and the location of each mooring.
- location and length of cables (inter-array cables, inter-connector cables, export cables). This should show Crown Estate Scotland lease area and refined cable corridor.
- information on spacing of structures. For wind turbine spacing this should include blade tip to blade tip information.
- seabed conditions and bathymetry
- environmental and other constraints including designated sites (e.g. SAC, SPA, MPA), priority marine features, archaeological exclusion zones, sites of archaeological potential, anchorage areas, other existing infrastructure
Table(s) providing the following information:
- identification/numbering of each structure (e.g. wind turbine generators, offshore substation platforms, meteorological masts, cables)
- coordinates of the centre point of each structure (e.g. wind turbine generators, offshore substation platforms, meteorological masts). For floating structures this should be the centre point of each floating platform and the coordinates of each mooring.
- coordinates and length of cables and cable corridors including crown estate lease corridor and refined corridor
- confirmed foundation type/mooring type for each structure (.g. wind turbine generators, offshore substation platforms, meteorological masts)
- height to the highest point of all structures (measured above Lowest Astronomical Tide, Highest Astronomical Tide, Mean High Water Springs and Mean Sea Level). For wind turbine generators this should be the height to the highest point of the blade tip.
- height to the lowest point of the blade tip for wind turbine generators (measured above Lowest Astronomical Tide, Highest Astronomical Tide and Mean High Water Springs)
- height to hub for wind turbine generators measured to the centreline of the generator shaft (measured above Lowest Astronomical Tide, Highest Astronomical Tide and Mean High Water Springs)
- rotor diameter and maximum rotation speed for each wind turbine generator
- generating output of each generator
- generating output for the whole project
- cable identification/numbering
- coordinates and length of cable corridors including crown estate lease corridor and refined corridor
Design Statement
Where seascape, landscape character and visual impact has been scoped in to an EIA and is assessed in the EIA Report, a Design Statement, based on the Development Specification and Layout Plan, will be required. The Design Statement must include representative day and night visualisations of the finalised design and layout from key viewpoints. It must be signed off by at least one qualified landscape architect.
The purpose of a Design Statement is to demonstrate how the design and layout has reduced adverse impacts on seascape and landscape character and visual impact. A summary of, or reference to, relevant conclusions of the EIA Report can be given.
Navigation Safety Plan
Navigation Safety Plans describe the measures that will be put in place to avoid or reduce the adverse effects of the project on civilian and military marine navigation.
Navigation Safety Plans should cover all the phases of a project that the marine licence or section 36 consent relates to. For offshore renewable energy projects, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence, all information required for the decommissioning activities will be submitted at the time of the decommissioning related applications, and this may include a new or updated Navigation Safety Plan.
Licensees and consent-holders should engage with the Maritime and Coastguard Agency, Northern Lighthouse Board and the Ministry of Defence on the content of the Navigation Safety Plan prior to submitting the plan for approval.
Navigation Safety Plans should demonstrate how the requirements of MCA MGN 654 Safety of Navigation: Offshore Renewable Energy Installations (OREIs) – Guidance on UK Navigational Practice, Safety and Emergency Response will be met, including a description of risk mitigation measures and any monitoring/surveys that will be carried out. Where projects relate to the construction and operation of floating structures, Navigation Safety Plans should demonstrate that the requirements of the MCA and HSE Regulatory expectations on moorings for floating wind and marine devices will be met.
A summary of how the Navigation Safety Plan relates to any commitments in the application, EIA Report and any licence or consent conditions should also be provided.
The Maritime and Coastguard Agency, Northern Lighthouse Board and the Ministry of Defence can provide information on the most up to date guidance. Relevant guidance includes:
Lighting and Marking Plan
Lighting and Marking Plans describe the lighting and marking that will be put in place to reduce the adverse effects of a project on civilian and military marine navigation, search and rescue and civilian and military aviation.
Lighting and Marking Plans should cover all the phases of a project that the licence or consent relates to and include information on temporary and permanent lighting and marking. For offshore renewable energy projects, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence, all information required for the decommissioning activities will be submitted at the time of the decommissioning related applications, which may include a new or updated Lighting and Marking Plan.
Licensees and consent-holders should engage the Northern Lighthouse Board, Maritime and Coastguard Agency, Ministry of Defence, Civil Aviation Authority, NATS En-route and any relevant aerodrome operator prior to submitting the Lighting and Marking plan for approval.
The Lighting and Marking Plan must demonstrate how relevant requirements and guidance have been considered and must describe the following
- lighting, marking and aids to navigation for civilian and military marine navigation
- lighting and marking for search and rescue
- lighting and marking for civilian and military aviation
- a summary of how the Lighting and Marking Plan relates to any commitments in the application, EIA Report and any licence or consent conditions should also be provided
The relevant stakeholders can provide information on the most up to date guidance. Relevant guidance includes:
- International Association of Marine Aids to Navigation and Lighthouse Authorities Guideline G1162 The marking of offshore man-made structures
- MCA MGN 654 Safety of Navigation: Offshore Renewable Energy Installations (OREIs) – Guidance on UK Navigational Practice, Safety and Emergency Response
- MCA Offshore renewable energy installations: impact on shipping
- The Air Navigation Order 2016
- CAA CAP 764 Policy and Guidelines on Wind Turbines
- CAA CAP 393 Regulations made under powers in the Civil Aviation Act 1982 and the Air Navigation Order 2016
Cable Plan
Cable Plans describe the measures that will be put in place to avoid or reduce the adverse effects of a project on civilian and military marine navigation. It may also include measures to mitigate the adverse effects of electromagnetic fields on other receptors.
Cable Plans should cover all the phases of a project that the licence or consent relates to. For offshore renewable energy, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence, all information required for the decommissioning activities will be submitted at the time of the decommissioning related applications, which may include a new or updated Cable Plan.
Licensees and consent-holders should engage the Maritime and Coastguard Agency, Ministry of Defence, NatureScot and relevant fisheries stakeholders prior to submitting the Cable Plan for approval.
Cable Plans should include:
- technical specification of the cables
- desk based assessment of the effects of electromagnetic fields on navigation, considering attenuation, shielding, compass deviation and any other navigation systems
- mitigation measures that will be put in place to reduce any adverse effects identified where a desk-based assessment shows a greater than a three-degree compass deviation for 95% of the cable route and more than five-degree compass deviation for the remaining 5% of the cable route. This should include reducing the adverse effects of compass deviation on navigation or any other adverse effects identified on other navigation systems. Mitigation measures may include details of a compass deviation survey. Timing of surveys and reporting arrangements should be provided.
- information on the risk assessment carried out to identify cable protection measures
- locations and lengths of cable burial and burial depths,
- location and lengths of cable protection
- details of cable arrangements in any locations where cables are not buried or protected
- Methods and timetable for post-construction and operational surveys (including inspections, post-construction surveys) of the cables and any cable protection through its operational life. This should include measures to survey for and identify risks to legitimate users of the sea, including areas where physical cable protection is not within the parameters of those approved and where cable installation has created seabed obstructions (e.g. locations where cables have become exposed)
- identification of any cable protection that results in a reduction of navigable depth by 5% or greater referenced to Chart Datum. In the event that any area of cable protection results in a reduction of navigable depth by 5% or greater, details of any steps to be taken to ensure existing and future safe navigation is not compromised must be provided.
- measures to mitigate the adverse effects of electromagnetic fields on any other receptors e.g. diadromous fish
- a summary of data and stakeholder views that informed the final cable route
- a summary of how the Cable Plan relates to any commitments in the application, EIA Report and any licence conditions
The relevant stakeholders can provide information on the most up to date guidance. Relevant guidance includes:
Seabed Obstruction Mitigation Plan
Seabed Obstruction Mitigation Plans describe the measures to reduce risks to legitimate users of the sea based on the findings of cable surveys or inspections carried out at the post-construction stage and throughout the operational phase of a project. The plans describe any risks to legitimate users of the sea that have been found during the cable surveys or inspections and identify measures to reduce any risks. Such aspects include locations where cable protection does not meet the approved design parameters or any other obstructions created as a result of the cable construction.
Seabed Obstruction Mitigation Plans are to be submitted after the completion of post-construction surveys or inspections. The findings of the post-construction surveys or inspections help demonstrate that the cable construction, including cable protection, complies with the approved design parameters. If any areas are found not to meet the approved design parameters, or any other obstructions resulting from the construction activities are found, mitigation measures to reduce any risks to legitimate users of the sea must be identified.
Seabed Obstruction Mitigation Plans must be updated after the completion of any operational phase surveys or inspections where risks to legitimate users of the sea have been identified. The findings of the operational phase surveys or inspections help demonstrate that any risks to legitimate users of the sea that arise during the operational phase (e.g. exposure of cables) are identified and mitigation measures are put in place to reduce those risks.
Seabed Obstruction Mitigation Plans cover mitigation actions to be undertaken throughout the post- construction and operational phase of an offshore renewable energy project.
Licensees and consent-holders should engage relevant fisheries stakeholders prior to submitting the Seabed Obstruction Mitigation Plan for approval.
Seabed Obstruction Mitigation Plans include:
- findings of surveys or inspections carried out at the post-construction stage including whether any risks to legitimate users of the sea have been identified, and if so, how the findings have informed any mitigation measures. This should include a description of any risks identified such as locations of cable protection that do not meet the approved design parameters or any other project related obstructions.
- findings of surveys or inspections carried out during the operational phase where risks to legitimate users of the sea have been identified and how the findings have informed mitigation measures. This should include a description of risks identified such as locations of where cables have become exposed or any other obstructions identified.
- measures that will be implemented to reduce any risks identified. This should include measures for each location where approved design parameters have not been met or where other obstructions to legitimate users of the sea have been identified (e.g. locations where cables have become exposed).
- timescales for the implementation of any measures
Emergency Response Cooperation Plan
Emergency Response Cooperation Plans describe the measures that will be put in place to assist and enable search and rescue and other emergency response.
Emergency Response Cooperation Plans should cover all the phases of a project that the licence or consent relates to. For offshore renewable energy, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the decommissioning related applications which may include a new or updated Emergency Response Cooperation Plan.
Licensees and consent-holders should engage the Maritime and Coastguard Agency prior to submitting the Emergency Response Cooperation Plan for approval.
A summary of how the Emergency Response Cooperation Plan relates to any commitments in the application, EIA Report and any licence or consent conditions should also be provided.
The relevant stakeholders can provide information on the most up to date guidance, key guidance includes:
Radar Mitigation Plans
The Ministry of Defence, Civil Aviation Authority, NATS Enroute or any relevant aerodrome operators should be consulted on the requirements for any radar mitigation plans at the pre-application stage.
Radar Mitigation Plans should cover all the phases of a project that the licence or consent relates to. For offshore renewable energy, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the relevant decommissioning applications which may include new or updated Radar Mitigation Plans.
Vessel Management Plans
Vessel Management Plans describe the measures that will be put in place to avoid or reduce the adverse effects of the project on commercial fishing activity and ecological receptors.
Vessel Management Plans should cover all the phases of a project that the licence or consent relates to. For offshore renewable energy, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the relevant decommissioning applications which may include a new or updated Vessel Management Plan.
Licensees and consent-holders should engage all relevant fisheries stakeholders and NatureScot prior to submitting the Vessel Management Plan for approval.
Vessel Management Plans should include:
- a summary of the impacts of vessel activity on commercial fisheries and ecology. This should include a summary of the commercial fisheries and ecology that may be impacted by vessel activity. A summary of, or reference to, relevant conclusions of the application and EIA Report can be given.
- information on how any monitoring has informed or will inform vessel transit routes and anchoring areas
- vessel transit routes to and from ports involved during construction and operation to the site
- anchoring areas including lie-up or shelter areas
- detail of how vessels will be coordinated
- Information on the numbers of vessels and the frequency with which vessels will be required to transit between ports and the site
- how information on vessels and vessel activity will be communicated e.g. through notifications, use of a vessel report and construction programme and how it will be made available to relevant stakeholders
- details of how the licensee will ensure that all Masters of vessels will be made aware of and follow the Vessel Management Plan
- a summary of how the Vessel Management Plan relates to any commitments in the application, EIA Report, any HRA, any MPA assessment and any licence or consent conditions should be provided
Project Environmental Monitoring Plan
Project Environmental Monitoring Plans describe the monitoring of the environmental effects of a project and set out the purpose of all the environmental monitoring proposed by a consent-holder or licensee e.g. validating impact assessments, assessing effectiveness of mitigation measures, informing adaptation of mitigation measures.
Project Environmental Monitoring Plans should cover all the phases of a project that the licence or consent relates to. For offshore renewable energy, licences and consents usually cover the construction and operational phases. Where decommissioning requires a separate marine licence all information required for the decommissioning activities will be submitted at the time of the relevant decommissioning applications which may include a new or updated Project Environmental Monitoring Plan.
Licensees and consent-holders should engage NatureScot and any other relevant stakeholders prior to submitting the Project Environmental Monitoring Plan for approval.
Project Environmental Monitoring Plans should include information on:
- the purpose and objectives of the monitoring to be undertaken (e.g. validating impact assessments, assessing effectiveness of mitigation measures, informing adaptation of mitigation measures)
- which receptors and effects are to be monitored
- a description of how the results of the monitoring and any subsequent analysis will be used to the meet the objectives of the monitoring (for example, used to inform a proposal to adapt certain mitigation measures)
- the methods for monitoring and analysing data for each receptor/effect or reference to relevant existing survey or monitoring guidance that will be followed
- how all monitoring will be done in such a way as to ensure that the data collected allows useful and valid comparisons between different phases e.g. baseline, construction and operational phases
- a description of how data collected will be stored
- timescales for all monitoring proposed
- a description of how the results of the monitoring and analysis will be reported and timescales for reporting (timescales for monitoring and reporting can be described as relative to certain stages (e.g. number of months after the commencement of construction) exact dates do not have to be given)
- information on how the findings of the monitoring will be communicated
- a summary of how the Project Environmental Monitoring Plan relates to any commitments in the application, EIA Report and any licence or consent conditions should be provided
Construction method statement
Construction Method Statements describe the measures that will be put in place to avoid or reduce the adverse effects of the construction phase on the environment and legitimate users of the sea.
Construction Method Statements only cover the construction phase of renewable energy projects.
Licensees and consent-holders should engage NatureScot and the MCA prior to submitting the Construction Method Statement for approval.
The relevant stakeholders can provide information on the most up to date guidance.
Construction Method Statements should include methods of construction for all activities in the marine licence and all infrastructure in the section 36 consent. It should provide information on measures that will be implemented to avoid or reduce the impact of the construction phase on the environment. For example, it should include:
- information on phasing, timing and duration of construction activities and how information on phasing and timing, including updates to phasing and timing, will be communicated to stakeholders e.g. local notifications to local marine users, kingfisher bulletin, notice to mariners, construction programme available on website.
- information on methods of construction for all activities e.g.
- seabed clearance
- wind turbine generators and foundations/moorings
- offshore substation platforms and foundations/moorings
- foundation scour protection
- inter-array cables
- export cables
- any other infrastructure e.g. meteorological masts, metocean buoys
- alternative construction methods that will be implemented in circumstance where the preferred method cannot be implemented e.g. due to seabed conditions or weather conditions
- Mitigation measures that will be put in place to reduce adverse impacts on the environment and legitimate users of the sea including measures to ensure the remediation, where practicable, of the seabed. If construction phase mitigation is detailed in any other plans then details of the mitigation and which plan it can be found in should be referenced e.g. Marine Pollution Contingency Plan, Navigation Safety Plan, Lighting and Marking Plan, Fisheries Mitigation, Monitoring and Communication Plan, Vessel Management Plan.
- a summary of how the Construction Method Statement relates to any commitments in the application, EIA Report and any licence or consent conditions
Piling noise mitigation plan
Piling Noise Mitigation Plans are required if piling is proposed as part of the construction method and describes the measures that will be put in place to reduce the adverse effects of piling noise on marine mammals and fish.
Piling Noise Mitigation Plans only cover the construction phase of the renewable energy projects.
Licensees and consent-holders should engage NatureScot prior to submitting the Piling Noise Mitigation Plan for approval.
The relevant stakeholders can provide information on the most up to date guidance, relevant guidance includes:
Piling Noise Mitigation Plans should demonstrate how the exposure to and/or the effects of underwater noise have been mitigated in relation to marine mammals and fish species. They should include:
- information on the species that may be affected by piling and how they may be affected. This should include a summary of spatial and temporal sensitivities. A summary of, or reference to, relevant conclusions of the application and EIA Report can be given
- summary of geotechnical conditions at all piling locations and how this may inform piling methods
- method of piling to be carried out at all locations
- seasonal piling strategy - timing of piling over the year
- spatial phasing of piling across the site
- potential combinations of seasonal and spatial piling schedule
- hammer sizes to be used across the site
- anticipated noise levels from pile-drilling/driving at all locations
- anticipated duration of piling to be carried out at all locations
- timing between different piling events
- potential for simultaneous piling locations
- maximum anticipated piling duration and frequency (e.g. percentage of the construction period over which piling would occur)
- maximum anticipated piling energy on a spatial and temporal basis
- The maximum anticipated hammer energy that may be used at different locations and what is the initial energy to be used for soft start at the same locations
- details of soft-start, initiation and ramp up for piling procedures and predicted piling energy required at each pile location
- any monitoring to be carried out during pile-driving
- details of any mitigation measures to avoid or reduce the adverse impacts of piling on the relevant species, including decision procedures such as Passive Acoustic Monitoring, Marine Mammal Observer, use of Acoustic Deterrent Devices and how any monitoring has/will inform mitigation
- a summary of how the Piling Noise Mitigation Plan relates to any commitments in the application, EIA Report and any licence or consent conditions
Construction traffic management plan
If a Construction Traffic Management Plan is required, the relevant roads authorities should be consulted on its content prior to submission for approval.
A Construction Traffic Management Plan is likely to be required if major offshore components associated with the construction of the offshore renewable energy generating station require any road and traffic mitigation measures including abnormal load transport by road.
Construction Traffic Management Plans only cover the construction phase of an offshore renewable energy generating station.
Where a Construction Traffic Management Plan is required, it should include information on measures proposed to mitigate the adverse impacts of construction related traffic and transport of major offshore components on the road network.
Operation and Maintenance Plan
Operation and Maintenance Plans describe measures that will be put in place to avoid or reduce the adverse effects of the operational phase on the environment and legitimate users of the sea.
Operation and Maintenance Plans cover the operational phase of an offshore renewable energy project.
Licensees and consent-holders should engage NatureScot, HES, The MCA, MOD, SFF and other relevant fisheries stakeholders prior to submitting the Operation and Maintenance Plan for approval.
Operation and Maintenance Plans should describe the operation and maintenance activities and the mitigation, any monitoring and communication (including any future consultation and reporting requirements) in place for those activities.
Operation and Maintenance Plans should include:
- a description of the operation and maintenance activities that will be carried out and information on the expected frequencies of each activity. This should include information on routine activities (e.g. cleaning, painting, replacement of machinery chemicals) and more significant maintenance activities (e.g. replacement of parts, emptying any bunded areas).
- a summary of the potential impacts of the operation and maintenance activities on human health, the environment and legitimate users of the sea. A summary of, or reference to, relevant conclusions of the application and EIA Report can be given.
- mitigation measures to avoid or reduce any adverse impacts of operation and maintenance activities on human health, the environment and legitimates users of the sea. If operational phase mitigation is detailed in any other plans then details of the mitigation and which plans it can be found in should be referenced e.g. Marine Pollution Contingency Plan, Navigation Safety Plan, Lighting and Marking Plan, Cable Plan, Fisheries Mitigation, Monitoring and Communication Plan, Vessel Management Plan.
- any monitoring that will be carried out during the operational phase. If operational phase monitoring is detailed in any other plans then this should be referenced e.g. Navigation Safety Plan, Project Environmental Monitoring Plan, Fisheries Mitigation, Monitoring and Communication Plan.
- communication plan. If operational phase communication is detailed in any other plans then details of the communication and which plans this can be found in should be referenced e.g. Navigation Safety Plan, Cable Plan, Fisheries Mitigation, Monitoring and Communication Plan, Project Environmental Monitoring Plan
- a summary of how the Operation and Maintenance Plan relates to any commitments in the application, EIA Report and any licence or consent conditions