Page 380 - Alderney Regional Environmental Assessment of Renewable Energy: Environmental Report
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Alderney
Regional Environmental Assessment of Renewable Energy:
Environmental Report
Stakeholder
Comment
Action (Including Clarification
Sought/Received, if Applicable)
Section(s) in
REA
traffic and transport) and provide further detail on
the likely scope of the investigations required,
including sources of information/data; survey
requirements; potential impacts and mitigating
actions; and potential monitoring requirements. It
is therefore considered that the draft REA has
followed UK best practice throughout both the
marine and land-side topics of the assessment.
In conclusion, though the REA seems to meet
the requirements of Strategic Environmental
Assessment (SEA Directive 2001/42/EC),
excepting the caveats imposed by the
requirement to define the document as an
REA, the Trust has serious concerns as to how
the consultant reconciles the local context at
various levels with the standard SEA/REA
approach. Therefore we would ask the
Commission for a clear definition as to 'best
practice' and that they consider the
implications of the points made above, prior to
approving the final document.
See above comments.
UK Maritime and Coastguard
Agency
(received 28-11-2013)
Overall the document captures the key areas
of concern from a navigation and shipping
perspective, although specific project detail
remains limited, which will of course have to be
populated with detailed Navigation Risk
Assessment (NRA) data in accordance with
the requirements laid down in MGN 371.
Point Noted. Reference to MGN 371 included
more clearly in the Mitigation Table.
7.3.2.13
The document makes numerous references to
exclusion zones as mitigation measures.
'Exclusion Zones' are designed as temporary
measures used in emergency response
situations and can only be invoked and
retracted by UK SOSREP.
Exclusion Zone replaced with with ‘Safety Zone’
where applicable.
ploads/attachment_data/file/80785/safety_zones.
pdf
7.3.2.1
7.3.2.4
7.3.2.5
7.3.2.6
7.3.2.11
7.3.2.13
7.3.2.6 indicates that 50m safety zones should
be implemented around operational turbines.
DECC guidance indicates that operational
safety zones can be applied for, but needs to
be supported by a detailed justification. The
point being made is that operational safety
zones cannot be assumed as default
mitigation. The current paper plays heavily on
the safety zone approach, making assumptions
in regard to mitigation, some modification to
this approach will be required for the project
specific NRA's
The DECC guidance has been incorporated into
the text and a reference added linking to:
ploads/attachment_data/file/80785/safety_zones.
pdf
Wording changes made to elaborate on safety
zones during construction, operation and
decommissioning phases.
7.3.2.6
Under keel Clearance will need to be fully
explored within project NRA's, a guidance
paper is available from the MCA which
addresses how to take this forward,
The NOREL working paper on Under Keel
Clearance has been incorporated within the
Collision Risk Section 7.3.2.1. A reinforcing
statement about Navigation Risk Assessment has
been added.
7.3.2.1
Within 7.3.2.4 states there is a small risk from
the hazard created by the moorings, taking
account of the comment above, this statement
is considered erroneous
The objective of section 7.3.2.4 is to identify the
hazard of snagging vessel lines with renewable
devices in an emergency situation (when a vessel
cannot move under its own power and therefore
anchors). The text has been modified to make
this point more clearly.
7.3.2.4
Interpretation of mitigation ie charting and
marking makes significant assumptions about
the mariner both accessing and accounting for
this data, many of the users within the area will
be leisure craft, greater physical mitigation
measures will be required before assumptions
can be made with regard to mitigation as
stated.
Mitigation (Table 38) reviewed, considering the
recreational mariner. The optional use of guard
boats added where appropriate.
7.3.2.12
Table 38
One comment on report structure, the figures
are contained at the end of the document with
an annex, this makes reading time consuming
The point is noted, on this occasion, the style of
report uses Figures at the end of the documents.
R/4001/7
A.16
R.2129
