Marine licensing – unexploded ordnance clearance: application guidance

Categorisation of applications

Below is a summary of categories on how marine licence applications for UXO clearance may be considered and the level of mitigation that may be required. We have also provided some questions to support the applicant in determining which category their application best fits into.

Category A (preferred)

Proposed clearance

Clearance using a lower-noise tool proposed; robust evidence is available from both controlled testing and at-sea clearances to support claims that this method will result in reduced potential environmental effects when compared to high-order clearance.

Expected mitigation and monitoring

This category is anticipated to have the lowest potential environmental impact and therefore the lowest mitigation requirements. There should be sufficient information to support the specified tool as being within this category, providing confidence in the level of noise reduction predicted. In such a case, additional noise monitoring may not be needed. As a minimum, applicants should expect a pre-clearance search using marine mammal observers to be required.

Category B

Proposed clearance

Clearance using a lower-noise tool proposed; robust evidence available from controlled testing to support claims that this method will result in reduced environmental effects, however no or limited at-sea data available. 

Expected mitigation and monitoring

Tools in this category will have evidence from controlled testing providing confidence that noise levels will be reduced compared to high-order clearances, which is robust enough to facilitate use of the specified tool at sea. As a minimum, applicants should expect a pre-clearance search using marine mammal observers to be required, possibly supplemented with an Acoustic Deterrent Device (ADD).

Provided the evidence from controlled testing is robust, and the noise assessment predicts that injury  is unlikely to occur within ranges that can be mitigated using an ADD, noise abatement may not be required. Mitigation measures to cover potential high-order detonation will be required where a high-order detonation may occur and no robust evidence has been provided. Noise monitoring may be required to demonstrate that results obtained in the controlled testing transpose to in the field. Once sufficient evidence at sea is available, lower-noise tools in this category may be able to progress to category A.

Category C

Proposed clearance

Clearance using high-order detonation proposed under extraordinary circumstances; clear justification as to why this is the only option.   

Expected mitigation and monitoring

There may be extraordinary circumstances in which high-order clearance is the only viable option and it is clear that lower-noise methods cannot be attempted. Such circumstances might include those where the factors of the UXO or of its location (e.g. depth, level of degradation, shell thickness, etc.) far exceed the expected or demonstrated capabilities of any known lower-noise clearance tools such that any attempt to use such lower-noise tools would not be feasible.

The licence application should include a clear explanation as to why lower-noise methods cannot be attempted. Applicants should expect the maximum mitigation, including noise abatement where effective, to be required. An EPS licence to injure marine species and disturb marine species may also be required.  

Category D (avoid)

Proposed clearance

Clearance using high-order detonation proposed; insufficient justification as to why this is the only option proposed.   

Expected mitigation and monitoring

This application may be rejected pending further information.  

Category questions to support applicants

The following questions support the applicant in determining which category their application best fits into.

Section one: What method of clearance is proposed?

• if high order detonation is proposed, go to section two
• if low noise method is proposed, go to section three

Section two: Are there extraordinary circumstances in which high order detonation is the only viable option?

• if yes, you should expect the highest level of mitigation to be required (Category C)
• if no, you should expect the application to be rejected (Category D)

Section three: Is evidence from controlled testing provided? Does this demonstrate that the chosen clearance tool is effective?

• if yes, go to section four
• if no, do not proceed. Only tools with evidence showing their effectiveness during controlled testing should be used at sea

Section four: Is evidence from at-sea testing provided? Does this demonstrate that the chosen tool is effective?

• if yes, you should expect a low level of mitigation to be required (Category A)
• if no, you should expect additional mitigation to be required (Category B)

Go to section five.

Section five: Does the application include contingency usage of high-order detonation?

• if yes, you must discuss with the appropriate regulator and SNCB. You should expect a restricted number of contingencies to be agreed
• if no, you should proceed with the application