Niobe Exploration Well Environmental Statement
DECC Reference Number: W/4171/2014
November 2014 Version A
Niobe Exploration Well Environmental Statement W/4171/2014
INFORMATION PAGE
Project name Niobe Exploration Well (12/27-KA)
DECC Project Reference W/4171/2014
Type of project Exploration drilling
Undertaker names Suncor Energy UK Ltd
Suncor Energy UK Ltd 28B Albyn Place Address Aberdeen AB10 1YL
Suncor Energy UK Ltd 49.5% Licensees/ Owners Working Interest Trap Oil Ltd. 28.0% Norwegian Energy Company UK Limited 22.5%
To drill an exploration well in Block 12/27 in order to fully evaluate the Niobe prospect for hydrocarbon-bearing potential. The Niobe Exploration Well will be drilled during Q2/ Q3 2015 from a jack-up drilling rig. The primary objectives of the Niobe Exploration Well are to: Short description Establish the presence of productive, hydrocarbon bearing reservoirs in the primary target, Upper Jurassic Burns sandstones. Determine the economic viability of the hydrocarbon volumes entrapped within the structure through the identification of reservoir properties of the primary target.
Anticipated commencement of works Q2 2015
Date and reference number of any earlier Environmental Statements/ Not Applicable Permits related to this project Significant environmental impacts None identified
Statement prepared by BMT Cordah Limited and Suncor Energy UK Ltd
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CONTENTS
ABBREVIATIONS vii GLOSSARY xi NON-TECHNICAL SUMMARY xv 1.0 INTRODUCTION ...... 1-1 1.1 Purpose of the Environmental Statement ...... 1-2 1.2 Scope of the Environmental Assessment ...... 1-3 1.3 Structure of the Environmental Statement ...... 1-4 2.0 METHODOLOGY ...... 2-1 3.0 PROJECT DESCRIPTION ...... 3-1 3.1 Background and Location ...... 3-1 3.2 Project Options ...... 3-1 3.3 Drilling schedule ...... 3-4 3.4 Drilling Rig ...... 3-4 3.5 Well Design ...... 3-6 3.6 Mud System ...... 3-8 3.7 Drill Cuttings ...... 3-8 3.8 Cement System...... 3-9 3.9 Well Control ...... 3-9 3.10 Well Logging 3-10 3.11 Well Abandonment 3-10 4.0 ENVIRONMENTAL SETTING AND DESCRIPTION ...... 4-1 4.1 Data Sources ...... 4-2 4.2 Physical Environment ...... 4-4 4.3 Biological Environment ...... 4-16 4.4 Offshore Conservation Areas ...... 4-33 4.5 Socioeconomic Environment ...... 4-38 4.6 Summary of Environmental Sensitivities ...... 4-50 5.0 CONSULTATIONS ...... 5-1 5.1 Purpose and Method ...... 5-1 5.2 Concerns and Issues ...... 5-1
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6.0 ENVIRONMENTAL RISK ASSESSMENT ...... 6-1 6.1 Risk Assessment Methodology ...... 6-1 6.2 Risk Assessment Findings ...... 6-4 6.3 Summary of Risk Assessment ...... 6-5 7.0 INTERACTION WITH OTHER USERS OF THE MARINE ENVIRONMENT ...... 7-1 7.1 Regulatory Context ...... 7-1 7.2 Basis for Assessment ...... 7-1 7.3 Sources of Potential Impacts ...... 7-1 7.4 Impact on Sensitive Receptors ...... 7-2 7.5 Cumulative and Transboundary Effects ...... 7-4 7.6 Consultee Concerns ...... 7-4 7.7 Mitigation Measures ...... 7-5 7.8 Conclusions ...... 7-5 8.0 LOCALISED DISTURBANCE TO THE SEABED ARISING FROM THE DRILLING AND INSTALLATION ACTIVITIES ...... 8-1 8.1 Regulatory Context ...... 8-1 8.2 Basis for Assessment ...... 8-1 8.3 Sources of Potential Impact ...... 8-1 8.4 Impact on Sensitive Receptors ...... 8-2 8.5 Cumulative and Transboundary Impacts ...... 8-4 8.6 Consultee Concerns ...... 8-4 8.7 Mitigation Measures ...... 8-4 8.8 Conclusions ...... 8-5 9.0 ATMOSPHERIC EMISSIONS ...... 9-1 9.1 Regulatory Context ...... 9-1 9.2 Basis for Assessment ...... 9-1 9.3 Sources of Potential Impact ...... 9-2 9.4 Impact on Sensitive Receptors ...... 9-4 9.5 Cumulative and Transboundary Impacts ...... 9-7 9.6 Consultee Concerns ...... 9-7 9.7 Mitigation Measures ...... 9-8 9.8 Conclusions ...... 9-8
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10.0 DISCHARGES TO SEA ...... 10-1 10.1 Regulatory Context ...... 10-1 10.2 Basis of Assessment ...... 10-1 10.3 Sources of Potential Impact ...... 10-1 10.4 Impact on Sensitive Receptors ...... 10-3 10.5 Cumulative and Transboundary Impacts ...... 10-5 10.6 Consultee Concerns ...... 10-5 10.7 Mitigation Measures ...... 10-6 10.8 Conclusions ...... 10-6 11.0 PHYSICAL INTERACTIONS BETWEEN VESSELS AND SEALS ...... 11-1 11.1 Regulatory Context ...... 11-1 11.2 Basis for Assessment ...... 11-1 11.3 Sources of Potential Impact ...... 11-1 11.4 Impact to Sensitive Receptors ...... 11-1 11.5 Cumulative and Transboundary Impacts ...... 11-2 11.6 Consultee Concerns ...... 11-2 11.7 Mitigation Measures ...... 11-2 11.8 Conclusions ...... 11-3 12.0 UNDERWATER NOISE ...... 12-1 12.1 Regulatory Context ...... 12-1 12.2 Basis of Assessment ...... 12-2 12.3 Characteristics of Noise Sources ...... 12-2 12.4 Species which may be Affected by Underwater Noise ...... 12-3 12.5 Cumulative and Transboundary Impacts ...... 12-5 12.6 Mitigation...... 12-6 12.7 Conclusions ...... 12-6 13.0 ACCIDENTAL HYDROCARBON RELEASE ...... 13-1 13.1 Likely Magnitude and Duration ...... 13-1 13.2 Behaviour of Oil at Sea ...... 13-2 13.3 Oil Spill Modelling for the Niobe Exploration Well ...... 13-4 13.4 Impact on Sensitive Receptors ...... 13-13 13.5 Transboundary and Cumulative Impacts ...... 13-15 13.6 Consultee Concerns ...... 13-16
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13.7 Proposed Mitigation Measures ...... 13-16 13.8 Conclusions ...... 13-17 14.0 SUMMARY OF IMPACTS AND MITIGATION MEASURES ...... 14-1 15.0 ENVIRONMENTAL MANAGEMENT ...... 15-1 15.1 Environmental Principles and Policy ...... 15-1 15.2 Suncor Corporate Standards ...... 15-1 15.3 Environmental Management System ...... 15-3 15.4 Niobe Exploration Well Commitments ...... 15-4 16.0 REFERENCES 16-1
APPENDICES: A – Summary of Relevant Petroleum and Environmental Legislation B – Justification of Low Environmental Risks C – Atmospheric Emissions Calculations D – Coastal Environmental Sensitivities
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ABBREVIATIONS
Abbreviation Meaning
2-D Two-Dimensional 3-D Three-Dimensional ACA Action Co-ordinating Authority AEA Association of European Airlines AIS Automatic Identification System ALARP As Low As Reasonably Practicable AP Alpha Platform API American Petroleum Institute AWAC Acoustic Wave and Current Ba Barium BERR Department for Business, Enterprise and Regulatory Reform BOP Blow Out Preventer BOWL Beatrice Offshore Windfarm Limited CaCl Calcium Chloride Cd Cadmium CD Chart Datum CEFAS Centre for Environment, Fisheries and Aquaculture Science
CH4 Methane CMACS Centre for Marine & Coastal Studies CO Carbon monoxide
CO2 Carbon dioxide CoP Cessation of Production Cr Chromium cSAC Candidate Site of Community Importance Cu Copper d days Db Decibels DECC Department for Energy and Climate Change Defra Department for Food and Rural Affairs DP Dynamic Positioning DPM Diesel Particulate Matter DTI Department of Trade and Industry DWT Deadweight Tonnage EBS Environmental Baseline Survey EC European Community ECE Environmentally Critical Element EDA Eastern Development Area EEMS Environmental Emissions Monitoring System EHS Environmental, Health and Safety EIA Environmental Impact Assessment EMS Environmental Management System
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EPS European Protected Species ERSC Emergency Response Service Centre ES Environmental Statement EU European Union EUNIS European Nature Information Service ft feet GEBCO General Bathymetric Chart of the Oceans GHG Greenhouse Gas g/ m2 Grams per square metre g/ m2/ year Grams per square metre per year (g)S Slightly gravelly sand GWP Global Warming Potential h hours Hg Mercury HR High Resolution HSE Health and Safety Executive Hz Hertz ICES International Council for the Exploration of the Sea IoP Institute of Petroleum IPCC Intergovernmental Panel on Climate Change ISQG Interim Sediment Quality Guidelines ITOPF International Tanker Owners Pollution Federation JNCC Joint Nature Conservation Committee KCl Potassium Chloride kHz Kilohertz km Kilometres Km2 Squared kilometres LAT Lowest Astronomical Tide LTOBM Low Toxicity Oil Based Mud LWD Logging While Drilling µm Micro metre(s) m Metre(s) m2 Squared metres m3 Cubic metres MARPOL (Convention) International Convention for the Prevention of Pollution from Ships MCAA Marine and Coastal Access Act Mg Milligrams Mg/l Milligrams per litre mm millimetres MMO Marine Mammal Observer MOD Ministry Of Defence MORL Moray Offshore Renewables Limited μPa micopascal
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MPA Marine Protected Area m/s Metres per second MSA Marine Scotland Act MSF Marine Safety Forum MSL Mean Sea Level MW MegaWatts MWD Measurement While Drilling NaCl Sodium Chloride NGO Non-Governmental Organisation Ni Nickel nm Nautical miles NMHC Non-methane Hydrocarbon
N2O Nitrous oxide NOAA National Oceanographic and Atmospheric Administration NOx Oxides of nitrogen NORBRIT Norway-UK Joint Contingency Plan NRC National Research Council NSTF North Sea Task Force NWEA North West European Area
O3 Ozone OBM Oil Based Mud OBS Optical Backscatter Sensor OEMS Operational Excellence Management System OGUK Oil and Gas- United Kingdom OPEP Oil Pollution Emergency Plan OPOL Oil Pollution Operators Liability (fund) OPPC Oil Pollution Prevention and Control OSCAR Oil Spill Contingency and Response OSP Offshore Substation Platform OSPAR Oslo Paris Convention OSPRAG Oil Spill Prevention and Response Advisory Group OSRL Oil Spill Response Limited OVI Offshore Vulnerability Index OWF Offshore Wind Farm PAH Polycyclic Aromatic Hydrocarbon P&A Plug and Abandon PCPT Piezocone Penetration Test PEL Probable Effect Level PETS Portal Environmental Tracking System ppt Parts per thousand PM Particulate Matter pMPA Possible Marine Protected Area PTS Permanent Threshold Shift Q Quarter rms Root mean square
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S Sand SAC Special Area of Conservation SAST Seabirds At Sea Team SCANS Small Cetaceans in the European Atlantic and North Seas scf/ stb Standard cubic feet per stock tank barrel SCI Site of Community Importance SEA Strategic Environmental Assessment Sg Sandy gravel SMRU Sea Mammal Research Unit SNCB Statutory Nature Conservation Body SNH Scottish Natural Heritage SOx Oxides of sulphur Sp. Species SPA Special Protected Area SPL Sound Pressure Level SSSI Site of Special Scientific Interest THC Total Hydrocarbons TTS Temporary Threshold Shift UK United Kingdom UKCS United Kingdom Continental Shelf UKDMAP United Kingdom Digital Marine Atlas UKOOA United Kingdom Offshore Operators Association UTM Universal Transverse Mercator VOC Volatile Organic Compound VSP Vertical Seismic Profiling WBM Water Based Mud WDA Western Development Area WTG Wind Turbine Generator WWF World Wildlife Fund Zn Zinc
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GLOSSARY
Annex I Legislation protecting certain habitats. Annex II Legislation protecting certain organisms. Annulus The space between two concentric circles on a plane. Bathymetry Bathymetry is the study of underwater depth of lake or ocean floors. Benthic fauna Organisms that live on, near, or in the bottom sediments of the seabed. Benthos See ‘Benthic Fauna’. Bioavaliability The degree to which a substance becomes available to an organism. Biotope A habitat with which a specific biological community is associated A North Sea acreage sub-division measuring approximately 10km x 20km Block forming part of a quadrant, e.g. Block 21/05 is the 5th block of Quadrant 21. System of valves connected to the wellhead while drilling, which can be Blow-out preventer closed over the wellhead to prevent uncontrolled, sometimes explosive release of hydrocarbons from the wellbore. Centre for Environment, The government agency which approves chemicals for offshore Fisheries and Aquaculture use(amongst other functions). Science A class of mollusc characterised by bilateral body symmetry, reduction and Cephalopods internalisation of the shell and modification of the foot into tentacles. Examples include squid, cuttlefish, octopus and nautilus. Cetaceans Aquatic mammals: whales, dolphins and porpoises. The area of the continental shelf sea-bed that lies below the zone of periodic Circalittoral tidal exposure. Small crustaceans whose adult stage usually includes a single eye in the Copepods center of the head. The free living marine species form a vital part of many marine food webs. Crude oil Unprocessed naturally occurring oil. Decommissioning Removal of a rig from active status. The zone that is the part of the sea or ocean (or deep lake) comprising the Demersal water column that is near to (and is significantly affected by) the seabed. A diverse group of eukaryotic algae that often have two protruding flagellae Dinoflagellates used for propelling and directing the cell. An agent added to a suspension to improve the separation of particles. Dispersants added to spilled oil can help the oil break up into smaller Dispersant droplets, increasing the exposed surface area and increasing the rate of degradation. A Mixture of chemicals pumped into a drilling rig chiefly as a lubricant for the Drilling muds bit and shaft. Historically the regulatory authority for the offshore oil and gas industry, this DTI agency has been dissolved and its energy-related responsibilities now fall to DECC. A system of sensors and thrusters on a vessel which allows it to maintain Dynamic Positioning position using satellite telemetry to adjust thrusters’ direction and power. A particular part of an ecological environment in which a particular plant or Ecological niche animal species prospers. The physical environment and associated organisms that interact in a given Ecosystem area. There is no defined size for an ecosystem. Environmental Impact A process to identify and assess the impacts associated with a particular Assessment activity, plan or project. Environmental A formal system which ensures that a company has control of its Management System environmental performance.
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the capacity of a habitat or organism to respond positively or negatively to Environmental sensitivity environmental change. A report setting out the findings of an assessment of a project’s Environmental Statement environmental impacts. Epifauna Fauna inhabiting the surface of rocks, sediment or other fauna/flora. Body made up of commissioners from each EU country, responsible for European Commission representing the common European interest, with the power to instigate and apply changes in European law to all EU countries. European protected Species that are listed in Annex IV of the habitats directive, and are species therefore protected from harm or disturbance by European law. Fauna Animal life. Flora Plant life. Density expressed as a ratio of the weight of a specified volume of a gas/oil gravity substance to the weight of an equal volume of another standard substance. i.e. Fresh water / air The measuring and mapping of depths, tides, and currents of a body of Hydrography water. Infauna Fauna that lives within sediments. Log The collection of data on the characteristics of a well. A government consultee and a lead marine management organisation in Scotland, bringing together the functions of the Scottish Fisheries Protection Marine Scotland Agency (Marine Scotland Compliance) and the Scottish Government Marine Directorate. Motile Organisms that are able to propel themselves from one place to another. Multiphase Hydrocarbons Hydrocarbons in more than one state, i.e. Iiquid and gas An environment that is different from the surrounding area and that requires Niche the organisms exploiting it to be specialised in ways not generally found in the surrounding area. Admiralty Notice to Mariners contain all the corrections, alterations and amendments for the UK Hydrographic Office worldwide series of Admiralty Notice to Mariners Charts and Publications, published weekly as booklets, which are dispatched directly from the UKHO. Organic Compounds Containing Carbon and Hydrogen. Any water in the sea that is not close to the bottom or near to the shore. Pelagic Marine animals that live in the water column of coastal, ocean and lake waters, but not on the bottom of the sea or the lake. Phytoplankton Planktonic organisms that obtain energy through photosynthesis. Pills are slugs of chemical which are applied at the same density as the Pill mud, and are sent downhole to the location of the drilling problem. The collection of small or microscopic organisms, including algae and protozoans, that float or drift in great numbers in fresh or salt water, Plankton especially at or near the surface, and serve as food for fish and other larger organisms. The combination of the probability of an event and a measure of the Risk consequence. Salinity The salt content, in this case of a body of water. Sedentary Organisms that are essentially fixed in one location, and unable to move. A soft, clay-like sedimentary rock, made up of thin layers. Some shales of Shale lower-carboniferous age are oil bearing. Separation of a body of water into two or more distinct layers due to Stratification differences in density or temperature. Sublittoral The area between the low water line and the edge of the continental shelf.
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In this context, any surface which could provide a habitat for an organism to Substrate live, i.e., a rock outcropping or area of sand. A rise in water level above that expected due to tidal effects alone; the Surge primary causes are wind action and low atmospheric pressure. Top-hole sections The first drilling section. Topography The surface features of the seabed. In this context, animals that tend to move through areas rather than stay in a Transient given area for a long period of time. UK/Norway median line The North Sea divide between UK and Norwegian waters. United Kingdom Continental shelf. Waters in which the UK Government has UKCS jurisdiction over oil and gas activity. A theoretical column through a body of water from the surface to the Water column sediments. This concept can be helpful when considering the different processes that occur at different depths. Broadly defined as heterotrophic (deriving energy from organic matter) Zooplankton planktonic organisms, although some protozoan zooplankton species can derive energy both from sunlight and by feeding on organic matter.
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NON-TECHNICAL SUMMARY This non-technical summary outlines the findings of the environmental impact assessment conducted by Suncor Energy UK Limited (Suncor), Trap Oil Limited and Norwegian Energy Company UK Limited for the drilling of the Niobe Exploration Well. The Niobe Exploration well is located in Block 12/27 of the United Kingdom Continental Shelf in the Outer Moray Firth (Figure i).
Figure i: Location of the proposed Niobe Exploration Well in the Outer Moray Firth
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Introduction Suncor is the operator of Block 12/27, under Licence P1889, with a 49% working interest in the licence. Trap Oil Limited and Norwegian Energy Company UK Limited have the remaining interests (28% and 22.5% respectively). As operator, Suncor has ultimate responsibility for the proposed exploration drilling operations. Responsibilities for any commitments included in the Environmental Statement are assigned to Suncor. An Environmental Statement is required by legislation for drilling operations where the location of a well is in proximity to specifically sensitive environmental areas. Following an informal consultation with the Department of Energy and Climate Change (DECC) in July 2014, Suncor were advised that an Environmental Statement would be legally required before the Niobe Exploration Well could be drilled, based on the following: other developments (such as wind farms) operating or proposed in the area; the Outer Moray Firth is an environmentally sensitive area; the Niobe Exploration Well is located close to land: o 40 km from the Caithness coastline; and o 45 km from the Moray coastline; liability/ scrutiny DECC have regarding the drilling operation; and public interest in the proposed exploration drilling operation in the Outer Moray Firth. During the course of this environmental impact assessment Suncor have consulted with the relevant stakeholders whom may have an interest in the proposed drilling operations. Any concerns or comments raised during the consultations have been included and addressed within the Environmental Statement.
Project Summary The Niobe Exploration Well is to be drilled to determine the reservoir thickness, and the quality and pressure of any hydrocarbon accumulations detected within the reservoir. Suncor propose to drill the exploration well from a jack-up drilling rig. Drilling is expected to commence between Q2 and Q3 2015, continuing for a period of up to 45 days. The jack-up drilling rig will be towed to location using a maximum of three tugs. The vessel will maintain its station by means of three legs jacked-down onto the seabed. In addition there will be a standby vessel and dedicated supply vessel used throughout the drilling operations with a statutory 500 m safety zone established around the drilling rig. The design for the Niobe Exploration Well will be as simple as possible and will use proven industry practice. In addition, Suncor will use knowledge gained from wells previously drilled in the area. Suncor propose to drill the Niobe Exploration Well in four sections, with no geological sidetrack planned. The top sections of the well will be drilled using water-based muds. Mud and cuttings from these top sections will be discharged directly to the seabed. Low toxicity oil-based muds will be used to drill the remaining sections of the well, to enable the well to be
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drilled efficiently given geological conditions. The low toxicity oil-based mud and cuttings will be recovered on the drilling rig and will be taken to shore for treatment and disposal. No well test will be conducted and the well will be plugged and abandoned in accordance with Oil and Gas UK Guidelines on the Suspension and Abandonment of wells.
Environmental Sensitivities The Niobe Exploration Well is situated in the Outer Moray Firth on the edge of the Smith Bank. The hydrodynamics, meteorological, geological and biological characteristics at this area are well known and consistent with the wider area of the Outer Moray Firth. A summary of the environmental sensitivities in the vicinity of the Niobe Exploration Well are presented in Table i.
Table i: Summary of environmental conditions and sensitivities in the vicinity of the proposed Niobe Exploration Well. Physical environment Bathymetry: The seabed at the Niobe Exploration Well is typically flat with no adjacent large scale features. The water depth at the well location is 53.0 m LAT (55.0 m MSL) Hydrodynamics: Benign tidal conditions, with dominant waves and winds originating from the North Sea. Salinity and Temperature: The water column is prone to stratification in the summer due to solar heating. Sediments type and features: The surficial seabed is predominately composed of sand sized sediments with shell components. Gravel sized sediment is also present at certain locations. Surface sediments are variable loose to very dense shelly sand to a depth of <1 m. Occasional bands of whole shells and shell fragments interspersed with bands of sandy sediment and areas of cobble or small boulders also occur. Between 1 and 41m below the seabed, the sediments consist of very soft clay. The seabed at the proposed well location is predominantly flat, and seabed features indicate a low-energy regime with sediments dominated primarily by shelly sand material overlaying very soft mud and clay. Chemical environment Seabed chemistry: No evidence of significant contamination from prior drilling activity has been detected in the seabed sediments at the well location, with hydrocarbon concentrations within background values. Biological environment Plankton: Plankton community and seasonality is typical for the Outer Moray Firth Benthic Fauna: Seabed surveys undertaken in support of the Environmental Statement found that visible fauna were sparse Although sparse, the communities of organisms living within and on the seabed sediments are fairly typical of the area and the wider central North Sea, consisting of Polychaete worms, Arthropoda, Bryozoa, Chordata and Mollusca. Biological surveys of the area indicate the presence of bivalve siphons potentially belonging to the ocean quahog (Arctica islandica). Although is the ocean quahog are listed on the OSPAR list of threatened or declining species, they are wide spread and present in large numbers within the Moray Firth. Habitats Directive: Annex I Habitats: No offshore Annex I habitats have been found at the location of the Niobe Exploration Well. Habitats Directive: Annex II Species: All four species have been identified offshore at the location of the Niobe Exploration Well.
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Designated Marine Protected Areas: Two sites have been designated as MPA’s: Noss Head and East of Caithness Cliffs. The conservation features are the horse mussel bed and Black Gannet population, respectively. Finfish and shellfish populations: The area is nursery grounds for anglerfish, blue whiting, cod, European hake, haddock, herring, lemon sole, ling, mackerel, Nephrops, plaice, sandeel, spotted ray, sprat, spurdog, thornback ray and whiting. The proposed well location is within the spawning grounds for cod (January to April), lemon sole (April to September), Nephrops (all year), plaice (January to March), sandeel (November to February), sprat (May to September) and whiting (February to June). Seabirds: Vulnerability is very high for the entire year; A number of seabird species are listed as interest features in designated sites (SPA) within the Moray Firth: Fulmar, Shag, Cormorant, Peregrine, Kittiwake, Herring Gull, Great Black–backed Gull, Guillemot, Razorbill and Puffin. Marine Mammals: Most sensitive periods are April through to September and November. Species present: bottlenose dolphin, fin whale, harbour porpoise, humpback whale, killer whale, long finned pilot whale, minke whale, white-beaked dolphin, harbour seal and harbour seal. Other Users of the Sea: Users of the sea within the area of the proposed well are mainly associated with oil and gas exploration and development, shipping and commercial fishing.
Assessment of Potential Impacts A risk assessment was undertaken as part of the environmental impact assessment to identify the potential impacts and risks associated with drilling the proposed Niobe Exploration Well. No “high” environmental risks were identified, however, there were seven potential risks identified as having a “medium” environmental risk: interaction with other users of the marine environment; seabed disturbance; atmospheric emissions; discharges to sea; physical interactions between vessels and seals; underwater noise; and accidental hydrocarbon release.
Interaction with Other Users of the Marine Environment Although fishing effort in the area of the Niobe Exploration Well is relatively high, the fleet targeting the fisheries is nomadic in nature with wide ranging. The proposed drilling operations have the potential to restrict fishing vessels from an area of sea approximately 0.79 km2. These fishing restrictions will be temporary in nature, lasting for the duration of the drilling operations. Once the well has been plugged and abandoned, the drilling rig and vessels will depart from the well location leaving no permanent physical presence or obstruction on the seabed or sea surface. Consultations with statutory consultees raised concerns regarding cumulative impacts with the neighbouring wind farm developers. However, the proposed drilling activities will
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be completed several months before any construction work is anticipated to commence at these wind farm developments.
Seabed Disturbance The installation of the jack-up drilling rig will result in some localised disturbance to the seabed. Sediment analysis taken within the MORL wind farm (within which, the Niobe Exploration Well is situated) indicate that hydrocarbon and heavy metal concentrations are well below reported background concentrations for this region. There are no protected habitats or seabed communities in the vicinity of the proposed exploration well. Any seabed disturbance is expected to recover naturally through sediment redistribution and the immigration and reproduction of benthic (seabed) fauna. Based on the hydrography in the area and the small area of direct impact (approximately 0.0005 km2) along with the short term nature of the drilling operations, no significant impacts are anticipated.
Atmospheric Emissions Gaseous emissions will be released to the atmosphere during the proposed drilling operations from the consumption of diesel fuel by the supporting vessels and from the drilling rig, and helifuel from the helicopters. These gaseous emissions will cause short-term deterioration of local air quality around the point of discharge. The exposed offshore conditions at the proposed well location will promote the rapid dispersion of these emissions. The gaseous emissions are not expected to have a significant impact on any biological receptors in the proposed well area. From a global perspective, gaseous emissions have the potential to contribute to greenhouse gas emissions and climate change. An assessment quantifying the significant sources of emissions associated with the proposed drilling operations concluded that annually the proposed activities would generate approximately 4,500 tonnes CO2 equivalents, representing 0.03% of the overall annual offshore CO2 equivalent emissions. In this wider context, the atmospheric emissions generated during the proposed operations are not considered significant.
Discharges to Sea Drilling the Niobe Exploration Well will result in the discharge of water-based mud and cuttings to the seabed. All low toxicity oil-based muds and cuttings will be collected on the drilling rig and brought to shore for disposal at controlled disposal sites. The main environmental issues arising from the discharge of water-based muds and cuttings are the smothering of benthic fauna and seabed spawning grounds for sandeel. This may result in small scale localised mortality of some benthic organisms and temporary alteration to and loss of their benthic habitat. However this benthic habitat is likely to recover over time as a result of spreading and dispersion of the cuttings, re-working of the sediment by burrowing organisms and re- colonisation of cuttings by seabed benthic organisms typical of the wider Moray Firth area, such as polychaetes, bivalve molluscs and amphipods.
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As sandeel lay their eggs on sandy seabeds, their spawning habitat may potentially be covered by cuttings, resulting in mortality or disturbance. Although the sandy sediments at the proposed well location can potentially provide suitable habitat, the widespread distribution of sandeel over the Smith Bank would only mean a small fraction of the population would potentially be affected by the proposed drilling activity. Consequently there is unlikely to be a significant impact on the sandeel population. No Habitats Directive Annex I seabed habitats have been identified in the vicinity of the Niobe Exploration Well. The risk of impacts from discharged water-based mud and cuttings are therefore remote.
Physical Interactions Between Vessels and Seals In recent years it has become apparent that some marine mammals (seals in particular) are susceptible to impacts from direct interactions with vessels using dynamic positioning systems. There is the potential that some of the vessels associated with the installation of the drilling rig may utilise dynamic positioning systems to maintain their station. Analysis of the at sea distribution data indicates that the occurrence of grey seals is likely to be low, while harbour seal occurrence is likely to be moderate. Based on the information provided in Scottish Nature Conservation Body guidance documents, the Niobe Exploration Well would fall into a low risk category for both harbour and grey seals. The well is located 80 km northeast of the nearest harbour seal Special Area of Conservation and there are no grey seal Special Areas of Conservation in the Moray Firth. As a result, no significant impacts are anticipated from the proposed drilling activities and the populations of either of the two seal species.
Underwater Noise Underwater noise has the potential to affect marine mammals including cetaceans, several species of which are known to occur in the area. The drilling operations will generate underwater noise from for example; drilling operations, support vessels and helicopter operations. A detailed noise assessment was carried out for the survey work undertaken in support of the proposed Niobe Exploration Well, in accordance with to the Joint Nature Conservation Committee guidelines. The assessment indicated that marine mammals were unlikely to be significantly affected and there would be no injury from the associated noise sources. As the survey work assessment was based on noise sources classed as pulse noise and is expected to be far louder than the non-pulse noise associated with vessel noise, therefore significant impacts arising from the proposed drilling operations are not expected. Drilling and vessel noise is not predicted to cause more than minor disturbance to individual marine mammals. Noise generated by the support vessels and the drilling rig will contribute to the existing ambient noise already generated by fishing vessels, shipping and other oil and gas related vessel activity within the Moray Firth. However, the proposed drilling operations are unlikely to result in transboundary or global impacts.
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Accidental Hydrocarbon Release Accidental spills of hydrocarbons are recognised as potentially damaging to the environment, although accidental events that could cause large-scale spillage of oil are unlikely to occur. Suncor will ensure that appropriate measures are in place for all activities being undertaken during the drilling of the proposed exploration well to reduce the risk of hydrocarbon spills to as low as reasonably practicable. Oil spill modelling has been conducted for the potential worst case spill scenario at the Niobe Exploration Well, a well blow-out resulting in the catastrophic release of the oil inventory from a subsea well blow-out. In this unlikely scenario, modelling predicted that oil could potentially reach the Orkney Islands, Scottish mainland and Norwegian coastlines. The Environmental Statement identifies the coastal areas at risk and the predicted probability of beaching. Seabirds could also be affected by oil and diesel pollution through damage to feathers resulting in loss of mobility, buoyancy, insulation and waterproofing. Additionally, birds may be at risk from toxicity through ingestion (swallowing) of hydrocarbons and may face starvation through depletion of food sources. Seabird vulnerability to oil pollution within the well area is ‘very high’ all year round. Several marine mammal species occur regularly in the area of the Niobe Exploration Well, although only a few individuals are ever present at any one time. It is unlikely that the viability of any species would be impacted in the event of an accidental hydrocarbon spill associated with the Niobe Exploration Well. Fish species found within the area occur throughout the Moray Firth and the North Sea and no significant threat to fish populations from an accidental hydrocarbon spill would be expected. Although fisherman and other sea users may be impacted by an oil spill, the impacts will likely only last while there is oil on the sea surface, which may temporarily restrict access. It is unlikely that there will be any long term socioeconomic impacts on these industries. An accidental release of chemicals could result in a localised impact around the discharge point. All chemical use will have been approved and an offshore chemical permit issued before drilling operations commence. Suncor will prepare an Oil Pollution Emergency Plan to cover the operations associated with drilling the Niobe Exploration Well in accordance with current DECC guidelines. Suncor’s prevention measures, mitigation measures and contingency plans will consider all foreseeable spill risks to ensure that the spill risk is reduced to as low as reasonably practicable. The oil pollution emergency plan will ensure that an appropriate response is made to any spill in order to minimise any impact on the environment. A worst case release of crude from the total loss of inventory from the Niobe Exploration Well would be likely to have a transboundary impact. However, an incident of this magnitude would have a very low probability of occurrence.
Conclusions The Niobe Exploration Well is not expected to result in significant environmental effects. The proposed drilling operations are very limited in extent and short-term in nature.
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The controls on the proposed operations have been designed to ensure that robust environmental safeguards will be put in place and preventative measures have been designed to minimise any potential environmental risks. Suncor believe that the measures that will be taken to minimise the environmental effects associated with the drilling of the Niobe Exploration Well represent an appropriate balance between protecting the environment and securing the economic benefits of finding a viable hydrocarbon reservoir.
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1.0 INTRODUCTION This Environmental Statement (ES) by Suncor Energy UK Ltd (Suncor), Trap Oil Limited (Trap Oil) and Norwegian Energy UK Limited (NORECO) presents the findings of an environmental impact assessment (EIA) for the drilling of an exploration well (Niobe) in Block 12/27 of the United Kingdom Continental Shelf (UKCS) in the central North Sea (Figure 1.1).
Figure 1.1: Location of the proposed Niobe Exploration Well in the UKCS
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Under Licence P1889, Suncor is the Operator of Block 12/27 with a 49.5% working interest in the Licence. Trap Oil and NORECO have the remaining interests (28.0% and 22.5%, respectively) in the field. Although Suncor, Trap Oil and NORECO will be working together on the drilling of the Niobe Exploration Well, as operator Suncor has the ultimate responsibility for the drilling operations. For this reason the ES assigns responsibilities to Suncor for any commitments that are included in the ES.
1.1 Purpose of the Environmental Statement This ES provides the means of submitting to the regulatory authority (the Department of Energy and Climate Change (DECC), statutory consultees, non-government organisations (NGOs) and the wider public the findings of an assessment of the likely effects on the environment of the activities proposed during the proposed exploration drilling activities. The submission of an ES to DECC is a legal requirement for wells that are located: less than 40 km from a UK coastline, where there is a sensitivity (e.g. coastal Special Area of Conservation (SAC), Special Protected Area (SPA) or Site of Special Scientific Interest (SSSI), which may be significantly impacted by the proposed drilling activity; within 10 km of an offshore SAC or SPA in a location where DECC does not have sufficient information on the likely impacts or there is likely to be a significant impact from the proposed drilling activity; within 10 km of large or long-lived biological feature which may be significantly affected by the proposed drilling activity; in the presence of known archaeological features or other heritage features potentially subject to damage or physical disturbance by the proposed drilling operations; and within 10 km of an international boundary where there is likely to be a significant impact or where another member state has requested to participate in the procedure. In addition, the proposed drilling operations may also: occur during a seasonal period of sensitivity, including the presence of seabirds, marine mammals or fish with 20 km; and may significantly affect: o herring or sandeel spawning grounds; o important fisheries (such as Nephrops); and o navigational interests. Following an informal consultation with DECC in July 2014. Suncor were advised that an ES would be legally required before the Niobe Exploration Well can be drilled, based on the following: other developments (such as wind farms) in the area; environmental sensitivities in the area; proximity of the Niobe Exploration Well to shore. The Niobe Exploration Well is located:
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o 40 km from the Caithness coastline; and o 45 km from the Moray coastline (Troup, Pennan and Lion’s Heads); liability/ scrutiny DECC have regarding the drilling operation; and public interest in the proposed drilling operation and its locality. In addition to the ES, Suncor will submit the relevant permit applications and consents to DECC to support the Niobe drilling operations. An EIA is an important management tool used by Suncor to ensure that environmental considerations are incorporated into their project-planning and decision-making. At the heart of the EIA is a cause and effects process that comprises five main stages: 1. Characterisation of the receiving environment; 2. Identification of potential environmental impacts associated with the project; 3. Assessment of the significance of potential impacts from the planned drilling activities. 4. Assessment of the significance of potential impacts from accidental or unplanned events; and 5. Development of controls to eliminate or reduce the severity of impacts, and plans to avoid or reduce the likelihood of accidental or unplanned events. In conducting the EIA, consideration was given to potential local, regional, cumulative and transboundary effects from offshore drilling operations. The EIA is an evaluation process which enables those responsible for the project, other interested parties (referred to as stakeholders) and the statutory authorities to understand the significant environmental impacts and risks (potential impacts), the methods of managing risk, and the benefits that are likely to occur. This allows the stakeholders to contribute to the decisions that are taken about the project. The EIA also helps those responsible for the project to understand the environment in which the project occurs and to select the plans, programmes, designs, technologies, management practices, contractors and personnel that are appropriate for the project.
1.2 Scope of the Environmental Assessment The scope of the Niobe ES encompasses Suncor’s plan to drill an exploration well during 2015 in Block 12/27, located approximately 40 km from the nearest UK coastline and 245 km west of the UK/ Norwegian median line. Water depth at the well location is approximately 55 m. Suncor plan to drill the Niobe Exploration Well in Q2/ Q3 from a jack-up drilling rig. The EIA covers all of the elements described above and has been carried out in line with the requirements of the: Offshore Petroleum Production and Pipe-lines (Assessment of Environmental Effects) Regulations 1999 (as amended); Offshore Chemicals Regulations 2002 (as amended); Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (as amended);
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Department of Energy and Climate Change (DECC) Guidance Notes 2011; and Suncor’s Environmental, Health and Safety (EHS) Policy. Appendix A summarises the environmental legislation for oil and gas drilling projects, and Suncor’s EHS Policy statement is presented in Section 13.
1.3 Structure of the Environmental Statement The ES is laid out under the following sections: Non-Technical Summary: An Executive Summary presented in non-technical language. Section 1 Introduction: An outline of the drilling programme, the purpose and scope of the EIA, and structure of the ES. Section 2 Methodology: A description of the methods used to complete the EIA. Section 3 Project Description: A brief description of the selected drilling programme for the Niobe Exploration Well (including an overview of the various drilling alternatives/ options) and an overview of decommissioning. Section 4 Environmental Baseline Description: A description of the current status of the physical and biological offshore environment of the Niobe area, including in particular the components that may be affected (climate, air, water, seabed, flora, fauna and human activities). This section also describes the social and economic uses and features of the environment. Section 5 Consultations: A summary of the consultations that were held for the Niobe Exploration Well with the statutory and non-statutory stakeholders, along with the issues raised or discussed. Section 6 Environmental Risk Assessment: Application of a qualitative method for assessing the environmental risk associated with the activities planned during the drilling operations. Accidental and emergency events are also assessed. The environmental risk assessment is used to differentiate between the potential causes of impact and risk that: (a) merit further detailed assessment within the EIA process because of their potential to cause severe impact, have a requirement for strict control, are of concern to stakeholders or are not well understood; and (b) are excluded from further investigation because of the low level of impact and risk. Section 7 to 14 Assessments of Potential Impacts: A description of the potential sources of significant impact from the project, and an estimate of the scale of the emissions, discharges and disturbance factors connected with the project. The sections cover: Seabed Disturbance (Section 7); Discharges to Sea (Section 8); Underwater Noise (Section 9); Atmospheric Emissions (Section 10); Interactions of Vessels with Seals (Section 11); Interactions with Users of the Marine Environment (Section 12);
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Accidental Hydrocarbon Release (Section 13); and Summary of Impacts and Mitigation Measures (Section 14). Section 15 Environmental Management: An outline of the arrangements that will be put in place to ensure that the control and mitigation measures identified in the Environmental Statement are implemented. The section also provides a statement of Suncor’s environmental commitments for the drilling operations. Section 16 Conclusions: A summary of the findings of the EIA. Section 17 References: Source details of all referenced documentation. Appendices: Supporting information relevant to the EIA covering Environmental Legislation (Appendix A), Non-significant Impacts (Appendix B), Atmospheric Emissions (Appendix C) and Coastal Sensitivities (Appendix D).
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2.0 METHODOLOGY The methodology used in the EIA systematically identifies and assesses the environmental impacts and risks (potential impacts) of the proposed project, evaluates the requirement for risk-reduction measures and provides a statement of Suncor’s Environmental Commitments which will facilitate the adoption of these measures throughout the drilling operations. This assessment aligns with the requirements set out in the Schedule to the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended), and associated Guidance Notes on the interpretation of the regulations (DECC, 2011). Figure 2.1 illustrates the principal stages in the EIA process. In the present context, a significant environmental risk can be defined as one that could potentially have a significant adverse impact. The purpose of the EIA is to identify any likely significant risks and establish that the management action to be taken will be sufficient to: avoid or minimise potentially adverse consequences for the environment, the public or the project; resolve the concerns of stakeholders; and fulfil the requirements of environmental legislation and company policy. Management actions will include: controls, i.e. methods for reducing the likelihood of the events that will lead to environmental impact (e.g. vessel collision); mitigation, i.e. methods for eliminating or reducing adverse environmental consequences; and other actions (e.g. awareness and training). The approach has been adapted from the Oil and Gas UK Guidelines on Risk Assessment (UKOOA, 1999, 2000) and the international environmental management standard BS EN ISO 14001:2004 (BSI, 2004). The sections in the remainder of the ES provide individual method statements for the processes used in the EIA for data gathering and interpretation, consultation, risk assessment, evaluation of significant impacts and mitigation, and the evaluation of the environmental management framework to be used throughout the drilling operations.
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Consultation throughout EIA with: • Recognised environmental and technical Justification for Project specialists • Organisations with statutory responsibility Project and for the environment Environmental Options considered • Individuals and organisations with a Context • Justification for proposed legitimate interest in the environment of alternative the project • Elimination of less appropriate alternatives
Project Description Environmental Description • Identification of potential causes of • Identification of sensitive components in the environmental impact and risk physical, chemical, biological and socio-economic • Highlight critical data gaps environment • Highlight critical data gaps
Environmental Risk Assessment Risk Identification • Application of defined assessment criteria and Assessment • Justification for the assessment made
Exclusion of insignificant impacts and Focus investigation on significant Elimination from the project of risks from further investigation in the EIA impacts and risks unacceptable impacts and risks
Detailed Detailed assessment of: • Causes and consequences of environmental impacts Assessment of from planned activities • Causes and potential consequences of oil spills and Significant other unplanned events Impact and • Proposed environmental safeguards • Response to concerns and issues raised by consultees Risks • Temporary and lasting environmental impact and risks
Environmental Management Systems for: • Assuring compliance with environmental legislation and Suncor Energy UK Ltd requirements • Maintaining environmental awareness • Implementing project-specific safeguards • Prevention and contingency planning • Monitoring and assurance of environmental performance • Providing feedback to interested parties
Project-Specific Environmental Management Plan: • Checklist specifying the environmental management actions to be implemented during the project
Balanced conclusions on: • Adequacy of EIA as a basis for decision making • Benefits, impacts and risks • Confidence in project techniques and safeguards • Resolution of the concerns of consultees • Implementation of systems and safeguards during the project Figure 2.1: Principal stages in the Environmental Impact Assessment process
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3.0 PROJECT DESCRIPTION This section describes the proposed drilling programme for Suncor’s Niobe Exploration Well (Exploration Well 12/27-KA).
3.1 Background and Location The Niobe Exploration Well is located in the UKCS Block 12/27 in the Outer Moray Firth of the North Sea (Table 3.1; Figure 1.1).
Table 3.1: Proposed co-ordinates for the Niobe Exploration Well Co-ordinates1 58° 06’ 42.821” N; Latitude and Longitude 02° 41’ 43.398” W 517 950 E; Eastings and Northings 6 441 355 N
1 ED50 International 1924, UTM Zone 30N CM 3°W Block 12/27 will be operated by Suncor, with joint ownership between Trap Oil and NORECO (Section 1). Suncor plan to drill Exploration Well 12/27-KA to fully evaluate the Niobe prospect for hydrocarbon-bearing potential. The primary objectives of the well are to: establish the presence of productive, hydrocarbon bearing reservoirs in the primary target, Upper Jurassic Burns sandstones; and determine the economic viability of the hydrocarbon volumes entrapped within the structure through the identification of reservoir properties of the primary target. Suncor are expecting the hydrocarbons at the Niobe reservoir to be Group III oil with the following properties: reservoir temperature 92°F (33.3°C) to 116°F (46.7°C); Group III (ITOPF), with an API of 24°; and gas-oil-ratio of 200 scf/stb. Suncor anticipates from the data available that Well 12/27-KA will be conventional, normal pressure/ normal temperature well.
3.2 Project Options The purpose of the Niobe Exploration Well is to determine reservoir thickness, and the quantity and pressure of any hydrocarbon accumulations detected, rather than for potential development as a production well. Based on Suncor’s experience, there are no realistic alternatives to drilling the Niobe Exploration Well in the manner described below. The main options in the selection of drilling muds are water-based muds (WBM) and low toxicity oil-based muds (LTOBMs). Where technically feasible, WBMs are most commonly used in the North Sea. It has been decided that the Niobe Exploration Well will be drilled mainly using WBM which have been successfully used to drill previous offset wells in the vicinity of Niobe. Water-based mud and cuttings will be discharged to sea, which is normal practice in the UKCS. LTOBM will be used to enable the lower section of the well to be drilled efficiently under geological conditions that would be
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difficult if WBM were to be used (Section 3.5). The LTOBM mud and cuttings will be recovered and taken to shore for treatment and disposal. The selection of a drilling rig and timing of the operations strongly depends on the technical requirements of the operation and the availability of a suitable drilling rig. In Block 12/27 all year round drilling restrictions have been identified in the licence conditions. As restrictions are imposed all year round, rig availability will be the main factor in deciding when the well will be drilled (Section 4). In the current market, rig availability is restricted due to high demand, especially during the summer which is the preferable time to drill due to improved weather conditions. Suncor are proposing to drill the well in the spring to summer months (Q2/ Q3). On account of the shallow water depth at the well location (approximately 55 m), no alternative was considered to using a jack-up rig. No well test will be conducted and the well will be plugged and abandoned (P&A), in accordance with Oil and Gas UK Guidelines on the Suspension and Abandonment of wells. Based on the above, the following drilling options have therefore been selected by Suncor for the Niobe Exploration Well: a jack-up drilling will be used; drilling operations will take place between Q2 and Q3 2015; WBM and LTOBM will be used to drill the well; and the well will be plugged and abandoned. The geotechnical borehole locations are listed in Table 3.2 and the proposed location for the jack-up legs is shown in Figure 3.1.
Table 3.2: Geotechnical Borehole Locations
Name Easting (m) Northing (m) Latitude Longitude
KRA14-B01 517905.00 6441355.00 58°06’42.8275” N 002°41’46.1475” W KRA14-B02 517950.00 6441400.00 58°06’44.2759” N 002°41’43.3860” W KRA14-B03 517887.00 6441418.00 58°06’44.8671” N 002°41’47.2298” W KRA14-B03A 517892.00 6441418.00 58°06’44.8663” N 002°41’46.9243” W
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Figure 3.1: Proposed jack-up Spud Can / leg location.
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3.3 Drilling Schedule As discussed, drilling operations for the Niobe Exploration Well are currently scheduled to commence between Q2 and Q3 2015, continuing for a period of up to 45 days, inclusive of additional days to cover rig availability and operational delays.
3.4 Drilling Rig The Niobe Exploration Well will be drilled from a jack-up drilling rig. At this stage, it is not known which drilling contractor or jack-up drilling rig will be used. Suncor will ensure that the specific rig used is fully compliant for use in the North Sea and designed for drilling in the appropriate water depth. Technical, safety and environmental audits will be undertaken as part of the rig tendering process, including ensuring that the rig is suitable for handling LTOBM and that the crew are provided with environmental awareness training. The ability of the rig and drilling contractors to manage well control scenarios will also be assured. The Niobe Exploration Well wellhead will be located on the drilling rig (a surface wellhead).
3.4.1 Mobilisation and vessel requirements The jack-up drilling rig will be towed out to the drilling location by a maximum of three tugs. The route will be selected in consultation with other users of the sea to minimise interference and risk of collision with other vessels. Once the rig arrives at the field, it will be positioned at the Niobe drilling location and maintained on station by its three legs which will be jacked-down onto the seabed. A standby vessel and dedicated supply vessel will be used throughout the drilling operations. A statutory 500 m safety zone will be established around the rig. This will not be marked with buoys but local shipping traffic will be informed of its position and a standby vessel will monitor shipping traffic at all times. A warning will be issued to the appropriate authorities before any rig moves, as required by the Health and Safety Executive (HSE) Operations Notice 6 (HSE, 2002). A Notice to Mariners will also be issued through the Hydrographer of the Navy for the establishment of a rig on location.
3.4.2 Positioning of the drilling rig The Contractor’s Rig Safety Case and the Marine Operations Manual will detail the procedures for the jacking-down and jacking-up operations. The drilling rig will be manoeuvred over the well location in a predetermined configuration. The configuration will be based on site data from a geotechnical survey undertaken in September 2014 (Table 3.2). The legs will then be jacked-down and the rig will be jacked-up until clear of the sea. The ballast tanks located around the rig will be filled with seawater to settle the rig in position. This ballast loading will be held for approximately one hour before being discharged back to the sea.
3.4.3 Rig operational wastes Under the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto MARPOL and as implemented by UK legislation, it is a legislative requirement that all discharges and wastes from the rig and attendant vessels are managed.
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Where required, machinery, chemicals, fuel and lubrication oil storage areas on the rig will be bunded in order to contain drips and spills, and minimise the risk of overboard discharge. For safety reasons, however, it is usually required that any spillage of helifuel during the refuelling of helicopters on the rig, will be directed to sea, where it will rapidly disperse and evaporate. Engine room machinery space drainage containing quantities of oily waste will drain to the bilge. The contents of the bilge will be passed through an oil/ water separator. The separated oil will be initially stored in an oily waste tank, then back loaded to shore for recycling. The separated water will be discharged to sea at oil concentrations of less than 15 mg/l, in accordance with regulatory requirements. The drill floor will be a fully contained area and all oily discharges will drain to a collection tank. This will be pumped out and back loaded to shore for treatment and disposal with any other liquid drilling wastes. Non-hazardous wastes (e.g. packaging, scrap metal and galley waste) and special wastes (e.g. chemicals, out-of-date medicines, contaminated dressings from the sick bay, and chemical and lubrication oil containers) will be categorised and segregated on board the rig and then back loaded to a dedicated waste reception terminal for disposal by recycling, incineration or landfill onshore according to the “Duty of Care” requirements of waste management legislation. Sewage and “grey water” will be treated on board the rig before being discharged to the sea in accordance with regulatory requirements.
3.4.4 Simultaneous operations Routine crane lifts of materials to and from supply vessels will be conducted while the rig is at the drilling location. There is the potential for simultaneous operations to occur, which will be governed by Sim-Ops (Simultaneous Operations) procedures. When assessing simultaneous operations, Suncor will take into consideration well shut-in requirements.
3.4.5 Hazardous materials The storage and use of hazardous materials on the rig will be carefully planned and controlled. Storage will only be allowed in designated areas and a detailed inventory of hazardous materials will be kept. Materials categorised as hazardous on the drilling rig may include: diesel, lubrication oils and base-oil, supplied by boat using clearly marked hose connections, or in dedicated containers; aviation fuel for refuelling helicopters, stored in a dedicated, clearly marked, helifuel tank (refuelling will only be carried out by trained personnel); limited quantities of compressed gases (oxygen, nitrogen and acetylene), stored separately in well-ventilated, clearly marked locations, away from any heat sources; radioactive materials used for well logging to be stored in special handling containers located in a clearly-marked position and normally bolted or welded to the rig structure (handling will be closely monitored and undertaken only by specially trained staff); paint and thinners to be stored in a dedicated locker; and
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drilling chemicals to be held in tanks, hopper and sack storage areas in dedicated storage areas. These will be handled and used strictly according to procedures. Rig procedures for the containment of oil and chemicals, and handling and transfer of hydrocarbons and chemicals, will be reviewed during the environmental management interface process of well planning.
3.5 Well Design The final well design for Niobe will be as simple as possible and within proven industry practice, and will be based on lessons learned from wells previously drilled in the area. A drilling permit application will be submitted to the DECC prior to the commencement of the drilling operations and will identify, quantify and assess the risks associated with drilling operations. Figure 3.2 presents a schematic of the proposed well design for the Niobe Exploration Well. The preliminary well design, mud system, estimated cuttings and disposal for the Niobe Exploration Well are presented in Table 3.3. As detailed in the table below, the well design incorporates four sections. No geological sidetrack is planned.
Table 3.3: Proposed well design for the Niobe Exploration Well Hole Section Weight of Cuttings disposal Mud System size (“) length (m) cuttings (tonnes) route 36 76 Seawater/ GEL sweeps 135 Seabed 17½ 625 WBM 262 Overboard 12¼ 921 LTOBM 189 Skip and ship Contingency *8½ 366 LTOBM 36 Skip and ship * If an 8-1/2” section is required it would result in the shortening of the length of the 12-1/4” section – i.e. not extra length, but replacing a portion of the hole that is planned to be drilled in 12- 1/4” hole size, in the primary case.
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Figure 3.2: Proposed well design for the Niobe Exploration Well
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3.6 Mud System Drilling mud is used to lubricate and cool the drill bit, maintain well pressure stability and remove drill cuttings from the bottom of the well as it is drilled. Different mud formulations are required at different stages in the drilling operation because of variations in pressure, temperature and the physical characteristics of the rock being drilled. Detailed mud chemicals formulation will be finalised during detailed well design and the relevant permit application for the drilling operation will be submitted to the DECC for approval prior to the commencement of drilling. Low toxicity oil based muds (LTOBM) will be required to drill the lower sections because: drilling risk, resulting from the long section lengths, will be reduced. If WBM was utilised then there is a significantly higher risk that the casing could not be run to the correct target depth due to sticky chemical sensitive shales; and drilling torque and drag will be reduced. The use of LTOBM therefore significantly reduces the risks potentially associated with drilling and completing the well using only WBM. Contingency chemicals are the chemicals that will be kept on the drilling rig but used only if specific problems occur during drilling. The most common problems encountered are: stuck pipe: fluid is required to help free the drill pipe if it becomes stuck in the well bore; loss of circulation: fibrous, granular and flaked material is added to the mud to reduce losses through porous or fractured formations penetrated by the well bore; bridging: the flow of drilling mud in the annulus is blocked due to an excess of solid material; and side-tracking: contingency plans are enacted if the well trajectory is misaligned or the reservoir target is not encountered. Regulation of offshore chemical use and discharge in the UK is administered under the Offshore Chemicals Regulations 2002 (as amended). These regulations require that the chemicals or products to be used during the drilling operation are assessed prior to use and discharge. This chemical risk assessment will be carried out as part of the chemical permit and drilling application for the Niobe Exploration Well. The risk assessment applies for both routine and contingency chemicals in the mud formulation.
3.7 Drill Cuttings Approximately 135 tonnes of seawater and GEL sweep cuttings will be discharged directly onto the seabed from the 36” top-hole section. The 17½” section will be drilled with a WBM system and will produce approximately 262 tonnes of WBM (Table 3.2). Approximately 225 tonnes of LTOBM and cuttings will be generated from drilling the 12¼” section and possible 8½” contingency section (Table 3.2). The cuttings from the 17½” section will be brought to the rig via the riser from the well, processed to remove the majority of the mud and then discharged overboard. Recovered WBM will be drained back into the mud pits and will be recycled back down the hole by
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the mud pump. The circulating system will be a closed loop system; where the mud will be continually recycled throughout the drilling programme. The contaminated LTOBM mud and cuttings from the 12¼” and contingent 8½” sections will be returned to the drilling vessel through the mud return line where they will be totally contained within the rig’s closed loop OBM system. After initial processing to separate drilled solids from liquid mud the recovered mud will be drained back to the mud pits and drilled solids/ cuttings will be contained in enclosed skips filled on the rig. As with the WBMs recovered mud will be recycled back down the hole via the closed loop mud circulating system so that mud is continually recycled throughout the drilling programme. Constituents will be added where needed to make up for losses to formation, adjust the mud’s properties or overcome difficult conditions (e.g. a stuck drill pipe). Oil contaminated cuttings will be back-loaded onto the rig’s supply vessel and taken to shore for processing. Once onshore, the drill cuttings will be treated to remove residual oil to very low levels before being transported to a licensed landfill disposal site. The recovered oil will be recycled and whole LTOBM will be returned to the suppliers for treatment and reuse.
3.8 Cement System In order to anchor the well casing within the hole, cement will be pumped down via the casing and then up the outside to fill the annulus between the casing and the wall of the hole. The well design will incorporate practices to minimise the use and discharge to sea of cement and additive chemicals. During well planning, data from previous wells in the area will be reviewed to provide estimates of the size of the hole and therefore the amount of cement required. During cementing of the 30” conductor, an excess of cement will be pumped, which will return to the seabed. This excess is pumped to ensure that the conductor remains stable and accounts for the variance in the drill bit size and the actual hole size that is a result of the rotary drilling process. For subsequent cementing operations there may be a small discharge of chemicals when the cementing unit is cleaned. It is anticipated that the majority of the cement will be mixed and used as required and as a result there should be limited discharges of cement mix water or spacers. The cement formulation will be finalised during well design with cement chemical risk assessment carried out as part of the chemical permit and drilling applications for the Niobe Exploration Well.
3.9 Well Control Well control at the Niobe Exploration Well will be maintained through the use of drilling fluid at a density that will maintain the hydrostatic pressure greater than the pore pressure of the formations being drilled. A limited amount of barite (a weighting agent) will be stored on the rig to enable the density of the active mud system to be increased as necessary. A blow-out preventer (BOP) will be installed for secondary well control, on completion of the top-hole sections.
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The BOP comprises a series of robust sealing elements (or valves) located on top of the wellhead during drilling. In the event of an influx of oil, gas or water from the well the BOP closes off the annular space between the pipe and the hole through which the mud normally returns to the surface. This forces the mud and/ or formation fluids to flow through a controllable choke and separate kill line which will allow the pressure to be controlled and a balanced system to be restored. The BOP will be function and pressure tested on installation and at intervals thereafter, in accordance with the rig’s written procedures. Responsibilities during a BOP closure will be documented in the Well Control Manual. Relevant staff will be experienced and fully trained to the appropriate level in well control principles, procedures and equipment operation. In the event of a well control incident, the rig contractor’s Well Control Manual will take primacy. This will be clearly stated as part of the bridging documentation between Suncor and the rig contractor.
3.10 Well Logging Electric logs will be run to fully evaluate the formations found. During drilling operations Measurement While Drilling (MWD) tools will be used to provide directional and formation information. The primary data collection will be by Logging While Drilling (LWD) tools, but wireline logs may also be run if the reservoir target is found to contain hydrocarbons. MWD, LWD and wireline logging evaluation will include the use of several types of down- hole instruments to log the well and determine hole and formation conditions. A combination of resistivity, natural gamma ray, density, neutron porosity and sonic measurements will be taken. If the reservoir is hydrocarbon bearing a further suite of wireline tools will be run which will include the above, with the addition of formation pressure, borehole calliper, imaging logs and formation fluid sampling. Vertical Seismic Profiling (VSP) logs may also be required and this will be determined based on the result found during the drilling phase (LWD logs). Should VSP be required Suncor will ensure that the appropriate permit applications are submitted. In addition mitigation measures, to avoid adverse impact to marine mammals, would be discussed with the Joint Nature Conservation Committee (JNCC) before any VSP is carried out. The safe use of these logging tools, including any radioactive sources, will be covered by the relevant statutory, interface and contractor procedures.
3.11 Well Abandonment The Niobe Exploration Well will be Plugged and Abandoned (P&A’d) in accordance with the UKOOA Guidelines for Suspension and Abandonment of wells (or applicable guidance at the time). The well programme will have been reviewed by the Offshore Safety Department as required under the Offshore Installations (Safety Case) regulations 2005. As part of the suspension and abandonment activities, Suncor will displace the cased hole volume of LTOBM from the well and circulate the well to seawater. The waste water
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generated will be of two types: visibly oily and visibly clean. These will be kept separate and disposed of appropriately. The clean-up pills and any contaminated seawater returns (visibly oily seawater and any residual cuttings solids) will be fully contained and routed to a designated pit on the drilling rig. All solids from the clean-up will be disposed of via skips and shipped to controlled onshore disposal sites. Seawater will continue to be circulated into the well until the returns from the well are clean at which point, returns will be discharged to the sea. Samples of discharged water will be taken at regular intervals for analysis in accordance with The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended) regulations. The well location will be notified to the Hydrographic Office and the position of the Niobe Exploration Well will be marked in the Admiralty Charts and Kingfisher Charts.
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4.0 ENVIRONMENTAL SETTING AND DESCRIPTION This section presents a description of the environmental setting of the proposed Niobe Exploration Well, located in UKCS Block 12/27 within the Outer Moray Firth (Figure 4.1). The Niobe Exploration Well is located, approximately, 45 km from the Moray coastline to the south and, approximately, 40 km from the Caithness coastline to the northwest.
Figure 4.1: Location of the proposed Niobe Exploration Well in the Outer Moray Firth
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Potentially sensitive physical, chemical, biological, social and economic components within the study area are identified. These are used to inform the EIA for the Niobe Exploration Well as reported within subsequent sections of this ES document. All publically available data and information, at the time of writing, have been used to derive the baseline description. These have been supplemented by project specific survey data.
4.1 Data Sources A number of Environmental Baseline Surveys (EBS) are available to inform this EIA, including both project specific surveys commissioned by Suncor and those available from adjacent oil and gas, and renewable energy projects. Summary descriptions of these are provided in subsequent sections.
4.1.1 Niobe Exploration Well site survey Table 4.1 identifies the project specific surveys which have been undertaken on behalf of Suncor.
Table 4.1: Surveys undertaken at the Niobe Exploration Well site Surveyor Survey title Description of survey data collected Gardline Seafloor/ HR Seismic Hazard Geophysical survey of the proposed well site Survey and Habitat Assessment, and potential relief well locations, comprising July 2014 2DHR seismic, seabed mapping and sidescan sonar work and shallow sub-bottom profiling. In addition environmental baseline survey sampling and video and stills data will be collected and habitat mapping and assessment was undertaken., Fugro Geotechnical survey, September Geotechnical survey of the jack-up location GeoConsulting 2014 comprising composite and PCPT Boreholes at Limited the spud can locations. Anatec Ltd Consent to locate and Collision Vessel traffic survey, collision frequency Risk Management plan, October assessment and review of effect on navigation. 2014
4.1.2 Offshore wind farm surveys Two offshore wind farm (OWF) developments are located within the Outer Moray Firth: the Moray Offshore Renewables Limited (MORL) and Beatrice Offshore Windfarm Limited (BOWL) (Figure 4.1). The Niobe Exploration Well is located within the MORL development boundary and approximately 15 km from the BOWL development boundary. Table 4.2 provides summary details of surveys undertaken for the MORL wind farm development.
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Table 4.2: Surveys undertaken for MORL EIA within the Outer Moray Firth Survey Survey title Description of survey data collected contractor Partrac 10/02/2010 to date Metocean. Five AWAC sites. Current speed, water levels, wave height, wave direction, suspended sediment (OBS). Grab samples at AWAC locations. Osiris 01/04/2010 – 21/05/2010 Geophysical. High resolution swath bathymetric survey. Gardline Mid-2011 Side scan sonar survey. Sub-bottom seismic profiling survey. Fugro 02/11/201 – 14/12/2010 Geotechnical. 25 boreholes, including six bumpover boreholes. EMU 12/10/2010 – 16/10/2010; Benthic. August 2011 (OWF cable route) Benthic ecological information. CMACS 12/10/2010 – 14/10/2011 Sediment sampling. Photographic and video information of seabed. Partrac 09/04/2010 – 10/04/2010 Trawl sampling. Sandeel survey. Natural Power 2009 to 2010 Ornithological. Survey methods include: boat-based, aerial, migration, seabird tracking Natural Power 2009 to 2010 Marine Mammal. Boat based survey to provide distribution and relative abundance. Utilised long-transect methods and collected effort data as function of transect distance surveyed. Chartwell April to July 2010 (38 days; Shipping. summer) AIS and radar tracks by ship type. Gargano November 2010 to January 2011 Seasonal surveys. (31 days; winter)
Source: information taken from relevant MORL ES chapters
4.1.3 Oil and gas installations There are a number of oil and gas installations in the vicinity of the Moray Firth. Ithaca Energy (UK) Limited has submitted several ESs relating to exploration and appraisal wells in blocks 11/29, 12/21c, 12/26c and an ES for the Jacky Development in Block 12/21c (Table 4.3). The results of the environmental baselines assessments have been considered in context when assessing the baseline for this project.
Table 4.3: Oil and Gas Environmental Statements submitted by Ithaca Energy (UK) Limited. DECC Reference Project Description Year Block Number
Appraisal Well 2006 12/21c W/3451/2006 Exploration Well 2007 11/29 W/3483/2006 Exploration Well 2007 12/26c W/3788/2007 Jacky Development 2008 12/21c W/3964/2008
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4.2 Physical Environment The form and function of the physical environment (e.g. hydrodynamics, geology) within the study area will exert some influence upon the biological characteristics of the habitats and species present. The design parameters for the offshore infrastructure will also be determined by the physical environment as will the resultant properties and fates of any associated emissions and discharges (including spills).
4.2.1 Bathymetry The Moray Firth seabed is generally smooth, with water depths to the west reaching 50 to 70 m, deepening to about 150 m in the east over the Witch Ground (DECC, 2004). A number of seabed features, including sandbanks, sand waves and deep water channels are present within the Moray Firth (DECC, 2004). Of these seabed features, the most notable is the Smith Bank. The Niobe Exploration Well is situated on the outer edge of this bank. Lying along a southwest to northeast axis, the Smith Bank is approximately 35 km long and 20 km wide, with water depths ranging from 35 to 55 m CD (below Chart Datum) (MORL, 2012a). The seabed is predominantly flat with an average gradient of <0.5° throughout; there is some gentle shoaling to the north of the well location. There are a number of shallow depressions in the immediate vicinity of the well location, the closest of this is 450 m south-southeast and exhibits a depth of 0.8 m. There is a maximum seabed gradient of 3.3° occurring along the edge of this ridge (Gardline, 2014). No significant bathymetric features have been identified during the Niobe geophysical survey at the well location. The area is indicative of a low- energy regime, in terms of sediment transport, and as further supported by modelling results of maximum bed shear stress (JNCC, 2010a). The water depth at the Niobe well location is 53 m Lowest Astronomical Tide (LAT) (55 m Mean Sea Level) (Gardline, 2014). Figure 4.2 illustrates the seabed bathymetry in the vicinity of the Niobe Exploration Well.
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Source: Gardline (2014) Figure 4.2: Seabed bathymetry at the Niobe Exploration Well, as provided by the project specific geophysical survey
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4.2.2 Hydrodynamics
Tidal regime The Outer Moray Firth is classified as a meso-tidal regime, with a mean spring tidal range of less than 3 m. At a regional scale, the main inflow of water to the northern North Sea consists of Atlantic water which follows the 200 m depth contour to the north of the Shetland Islands before passing southwards along the western edge of the Norwegian Trench. Some of this water may pass southwards into the northern North Sea, close to the eastern border of the Shetland Islands. A smaller flow, the Fair Isle Current, follows the 100 m depth contour, entering the North Sea between the Shetland and Orkney Islands. This flow is a mixture of coastal and Atlantic water that crosses the northern North Sea along the 100m contour in a narrow band known as the Dooley Current, before entering the Skagerrak. Circulation in the North Sea is enhanced by south-westerly winds; thus, circulation is normally stronger in winter than in summer (NSTF, 1993). On a local scale and within the Moray Firth, the flow of water is typically directed towards the south or southwest during the flood tide and to the north or northeast during the ebb (MORL, 2012a). A very weak clockwise current is present along the shoreline which may be enhanced during periods of heavy water run-off (Ithaca, 2007). Both broad-scale modelling (BERR, 2008) and site specific measurements (MORL, 2012a) indicate a relatively benign tidal regime within the Outer Moray Firth where the water flows are topographically constrained (Adams and Martin, 1986) and reduce with distance into the Moray Firth: broad-scale: neap and spring peak flow range between 0.11 and 0.5 m/s, respectively (BERR, 2008); and site specific: depth-averaged spring current speeds typically less than 0.5 m/s, with neap values being approximately half that of the spring speed. Current speeds decrease from surface to bed (taken from AWAC 3c; MORL, 2012a). These low current speeds support the observation of a low energy sediment transport regime. Enhancement of the tidally-driven current speeds may occur as a result of storm surges and storm waves (high energy, low frequency events) and it is under these conditions that the majority of the sediment transport occurs.
Wave regime The wave regime within the Outer Moray Firth is characterised by both locally generated wind waves and swell waves originating further afield in the northern North Sea. Short-term observational data (less than 1 year) are available from monitoring studies undertaken for the MORL Development (MORL, 2012a) and are supported by data from the medium-term measurement buoy located within the Inner Moray Firth, operated within the Cefas WaveNet network. An additional data source is the Beatrice Alpha oil platform, which allows for a seasonal analysis of the wave climate from a one year record (ABPmer, 2012). These data sources allow for a characterisation of the wave regime relevant to the Niobe Exploration Well. Table 4.4 presents the key observations made from both data sources.
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Table 4.4: Wave data results for the Niobe Exploration Well area Short-term (3 months) Beatrice Alpha oil platform Cefas WaveNet buoy (3 years) observational results (< 1 year) results results Waves originating from a During the summer, the Waves originating from a northeast direction dominate. modal wave height was northeast direction dominate. Wave heights are frequently 1 m, and the maximum 3 m; The maximum wave height is between 1 and 1.5 m. During the winter, the 5.5 m, originating from the The maximum wave height is modal wave height was east-northeast. 6.29 m, originating from the 1.5 m, and the maximum east-southeast. 8 m; The frequent mean wave Higher period waves, period is between 7 and 8 approximately, 5 seconds seconds, indicative of swell occur in the winter period. waves.
Source: MORL (2012a), ABPmer (2012) These records illustrate that the wave height reduces with distance into the Moray Firth and that the larger wave heights will occur during the winter periods. The characteristics of extreme events can only be accurately derived from long-term data sets; a 20 year modelled time series data set was used to report on selected return periods within the MORL development area (MORL, 2012a). These are given in Table 4.5.
Table 4.5: Return periods within the Moray Firth Return Period (years) Significant Wave Height (Hs – m) 1 6.7 10 8.0 50 8.9 100 9.2
Source: MORL (2012a) Work undertaken within the MORL development area confirmed that larger wave conditions act to enhance seabed mobility, even given the relatively large depths within the Outer Moray Firth (MORL, 2012a). At the MORL measurement site, located at a depth of 49 m and 6.7 km WNW from the Niobe Exploration Well, waves of 3 m in height will mobilise the medium sands. The surficial sediments at the Niobe site, as indicated by the geophysical survey, are variably loose to very dense shelly sand, present to a depth less than 1 m. Based upon these results, it can be assumed here that waves will mobilise the seabed in a similar way at the Niobe Exploration Well. The hydrodynamic regime is further enhanced by currents induced by storm surges. Within the Outer Moray Firth, the 1 in 50 year storm surge is of the order of 1 to 1.25 m (+0.05 m), increasing in magnitude from west to east (Flather, 1987).
Sea temperature and salinity Within the Outer Moray Firth, seasonal stratification occurs in response to temperature induced density differences between the warmer surface waters and the deeper cooler waters. Thermal stratification is common place within the northern and central North Sea, developing during spring and becoming fully established during the summer months (DECC, 2004). During winter months increased frequency of storms and a reduction in
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solar heating breaks down the summer stratification developed during spring, resulting in a well-mixed water column. Vertical thermal fronts have been reported within the Moray Firth representing the boundary between weakly seasonally stratified water and well mixed water inshore (OSPAR, 2000). Within Block 12/27, seasonal variability is apparent with average sea temperatures (UKDMAP, 1998): ranging from 12.5 °C at the sea surface, to 11.5 °C at the seabed during the summer; and approximately 6.0°C throughout the entire water column during the winter.
Salinity in the waters in the vicinity of the Niobe Exploration Well is shown to (UKDMAP 1998): range from 34.75 ppt at the sea surface, to 34.90 ppt at the seabed during summer; and range from 34.50 ppt at the sea surface, to 34.80 ppt at the seabed during winter.
4.2.3 Meteorology Low pressures travelling from the North Atlantic, passing between Scotland and Iceland and onwards to northern Scandinavia typically dominate the meteorological conditions within the Moray Firth. As reported in MORL (2012b), ‘the area is dominated by a westerly flow, giving windy and unsettled weather with frontal passages most of the year’. High pressure systems, typically occurring during April and May, manifest as a south-easterly flow. Analysis of measured and modelled wind data undertaken for the MORL Development area provides an indication of the wind regime that will occur at the Niobe Exploration Well location. The data indicate that average annual wind speeds over the ten year hindcast period are less than 12 m/s, with seasonal variability (MORL, 2010). During the summer there is a greater frequency of calm conditions, with wind speeds less than 3 m/s, and wind may originate from a wide range of directions. However, these conditions are only likely to occur during 9 to 10% of the year. During the winter months, winds may reach up to 25 m/s and tend to originate from a south-westerly through to a northerly direction (MORL, 2010). Figure 4.3 illustrates the average annual wind speeds over the ten year hindcast period recorded at the MORL Development area (MORL, 2012b).
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Source: MORL (2012b) Figure 4.3: Average annual windrose for Niobe Exploration Well area over a ten year hindcast period
4.2.4 Seabed characteristics The composition of the seabed (surficial) sediments is dependent upon a range of factors including sediment availability and the local hydrodynamic conditions. The seabed sediments will support a certain range of flora and fauna, providing habitats and a food source for benthic infauna which, in turn, are preyed upon by other species such as demersal fish and shellfish. Whilst gravelly sediments are important to bottom-spawning fish species, muddy sediments are favoured by burrowing shellfish species such as Norway lobster (Nephrops norvegicus) (Rees et al., 2007). Particles of various types and sizes, notably the silt/ clay fraction, can adsorb petroleum hydrocarbons from seawater and through this pathway, hydrocarbons can become incorporated into the sediment system. Organic matter within the sediment matrix is also likely to adsorb hydrocarbons and heavy metals, providing a means of transport and incorporation into sediments. The bioavailability of contaminants that are adsorbed to sediments or organic matter is poorly understood, but in general terms, prolonged contact between hydrocarbons and sediment may result in stronger bond formation and a subsequent reduction in bioavailability (Van Brummelen et al., 1998). This phenomenon is referred to as ageing and is especially important for sediments with historic contamination such as the discharge of drill cuttings.
Shallow geology Broad scale mapping demonstrates that the offshore surface geology in the Outer Moray Firth is predominately composed of Cretaceous rocks with Jurassic and Permo-Triassic rocks present along the inner and southern margins of the Firth. Quaternary deposits
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varying in thickness and up to 70 m in depth are present over the entire Moray Firth (MORL, 2012a). The geophysical survey (Section 4.1.1) undertaken for the Niobe Exploration Well identified that the predominant seabed surface sediments are variable loose to very dense shelly sand to a depth of <1 m. Beneath this, the sediments consist of very soft clay, which extends to depths between one and 41m below seabed. This base of clay is flat over the proposed well area, although no obstructions or hazards to rig emplacement or drilling were identified, caution should be exercised with regards to localised variations in soil strength and lithology of shallow sediments in the area (Gardline, 2014).
Surficial sediments Much of the seabed of the Moray Firth consists of bedrock overlain by gravelly moraine deposits. Most of the Smith Bank, located to the west of the exploration well, consists of these types of sediments. These sedimentary units are widely overlain by relatively thin, 1 to 2 m, layers of Holocene sediments, comprising mainly of sands and gravels and shell material, in varying proportions. In deeper channels fine muddy sediments are recorded (Gardline, 2014). Broad scale sediment mapping demonstrates that, according to Folk Classification (Folk, 1954) the seabed at the proposed Niobe Exploration Well is Sandy gravel (Sg) (MAREMAP, 2010). Survey results from the adjacent MORL Development support the predominance of sandy material and specifically the presence of Sand (S) and slightly gravelly Sand ((g)S) (MORL, 2012a) (Figure 4.4).
Source: MORL (2012c) Figure 4.4: Surficial seabed sediment images for sample sites of close proximity to the Niobe Exploration Well site
Recent seabed mapping of hard substrate within the Outer Moray Firth does not indicate the occurrence of this substrate at, or in the vicinity of, the proposed Niobe Exploration Well (Gafeira, et al, 2010). The geophysical survey (Section 4.1.1) undertaken for the Niobe Exploration Well demonstrates the presence of medium sands with shell fragments and occasional whole shells. The survey also indicated the presence of megaripples consisting of bands of whole shells and shell fragments interspersed with bands of sandy sediment. There were
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also occasional areas of cobbles/ boulders observed (Gardline, 2014), as illustrated in Figure 4.5.
Source: Gardline (2014) Figure 4.5: Surficial seabed sediments at the Niobe Exploration Well, as provided by the project specific geophysical survey
Seabed features and obstructions During the Gardline survey, there were numerous sonar contacts representing cobbles/ boulders observed within the survey area, some of these were observed to reach heights of 0.6 m. There is only one obstruction which lies within 100 m radius of the proposed well location (Figure 4.8), this has a height of 0.3 m and is located 35 m south of the well location. No significant bathymetric features have been identified during the Niobe geophysical survey at the well location (Gardline, 2014).
Biotope A marine biotope classification system for British waters has been developed by Connor et al. (2004) from data acquired during the JNCC’s Marine Nature Conservation Review. The classification system has been developed to be compatible with the European Nature Information Service (EUNIS) which has compiled habitat information from across Europe into a single database. The two classification systems developed by EUNIS and Connor et al. (2004) are both based around the same hierarchical analysis. Initially abiotic habitats are defined at four levels, and biological communities are then linked to these (at two lower levels) to produce a biotope classification. For the purposes of this ES, the EUNIS coding system was used for classification of biotopes. The most probable biotope identified within the location for the proposed Niobe Exploration Well is given in Table 4.6 and illustrated in Figures 4.6 and 4.7.
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Table 4.6: Predicted EUNIS habitats at the location of the proposed Niobe Exploration Well Broad Habitat Habitat Biotope Complex A5.1 Circa littoral coarse A5.14 Circa littoral coarse sediment sediment A5.15 Deep circa littoral coarse sediment A5.25 Circa littoral fine sand A5 Sub littoral sediment A5.2 Sublittoral sand A5.26 Circa littoral muddy sand A5.27 Deep circa littoral sand A5.3 Sub littoral mud A5.37 Deep circa littoral mud Source: JNCC (2010a)
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Source: Gardline (2014) Figure 4.6: Biotope types around the Niobe Exploration Well
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Source: Gardline (2014) Figure 4.7: Biotope types and features around the Niobe Exploration Well
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Sediment chemistry Trends in the concentration and distribution of contaminants, particularly hydrocarbons, in the different parts of the North Sea sediments are broadly similar (DTI, 2004). However, there are some notable exceptions. In the southern North Sea the concentrations of certain metals (e.g. lead, vanadium, copper and iron) appear higher compared to the northern North Sea (DTI, 2004). Background hydrocarbon concentrations are generally higher in fine sediments (muds and silts) than in coarser sediments (sands and gravels) owing to their greater surface area and adsorptive capacity (CEFAS, 2001a). Sediment sampling from within the MORL Development site concluded that contamination was below CEFAS Action Levels and Canadian Interim Sediment Quality Guideline (MORL, 2012c). Contaminant concentrations below CEFAS action levels are of no environmental concern and are considered safe for sea disposal (CEFAS, 2014). Results of the sediment contaminant analyses for those samples closest to the Niobe Exploration Well are given in Table 4.7.
Table 4.7: Contaminant concentrations in surface sediments for locations closest to the Niobe Exploration Well and within the MORL Development boundary Sample Site (distance THC PAH Cr Ni Cu Zn Cd Hg Ba to Niobe Well, km) C6 (9.7km) - 0 4.8 1.8 2.0 - <0.1 <0.1 16 C7 (7.5km) - 0 11.5 3.0 2.2 - <0.1 <0.1 13 C8 (12.9 km) - 17 11.1 3.9 2.9 - <0.1 <0.1 18 C10 (10.8 km) - 3 11.0 3.4 2.3 - <0.1 <0.1 12 Guideline Levels (where levels are provided) CEFAS Action 1 - - 40 20 40 - 0.4 0.3 - Level 2 - - 400 200 400 - 0.5 3 - ISQG - - 52.3 - 18.7 - 0.7 0.13 - Canadian PEL - - 160 - 108 - 4.2 0.7 - Given in mg/kg, with the exception of PAH which is given in ng/g dry weight Key: - information is not provided ISQG – Interim Sediment Quality Guidelines PEL – Probable Effect Level
Source: MORL (2012c) For comparative purposes the concentrations of contaminants (hydrocarbons and heavy metals) reported for this region in the central North Sea are shown in Table 4.8.
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Table 4.8: Contaminant concentrations in surface sediments from the central North Sea area.
Reference THC PAH Cr Ni Cu Zn Cd Hg Ba Central North Sea (µgg-1 dry weight) (Min- Max range) Estuaries (CEFAS, - 0.2-28 ------2001a) Offshore (CEFAS, 17-120 0.2-2.7 - 9.5 3.96 20.87 0.43 0.16 - 2001a) Oil and Gas 0.02- 10-450 - 17.79 17.45 129.74 0.85 0.36 - Installations (CEFAS, 74.7 2001a) Background 348.47 9.41 0.068 9.1 11.46 6.32 21.28 0.76 0.76 (720.0 Concentration (40.10) (0.237) (31) (21.75) (18.00) (43.40) (1.00) (1.00) (UKOOA, 2001) 0) Background Concentration (OSPAR, - - 60-81 30-36 20 90 0.2 0.05 - 2005)* Notes: *OSPAR (2005) - maximum expected background concentration (BC), normalized to 5% aluminium if the environment were pristine; (-) means no data currently available and UKOOA (2001); values are mean (95th percentile in brackets).
Source: CEFAS (2001a); UKOOA (2001); OSPAR (2005)
4.3 Biological Environment This section presents the different characteristics of the marine environment of the Outer Moray Firth and with respect to the location of the Niobe Exploration Well (Figure 4.1).
4.3.1 Plankton Plankton consists of organisms that drift with the ocean currents, and can be divided into phytoplankton (plants) and zooplankton (animals). During spring, an increase in day length and temperature, coupled with the supply of nutrients released to the water column during winter storms, results in the rapid growth of the phytoplankton population. The phytoplankton bloom is followed by a similar rapid increase in the zooplankton population. Phytoplankton levels then drop as nutrients in the surface water become depleted and as a result of zooplankton grazing. This initial bloom is often followed by a second, smaller peak in autumn. The most frequently recorded taxa in the central North Sea surface waters are dinoflagellates (Ceratium), in line with the rest of the North Sea where there is an increasing trend of dinoflagellate dominance. The zooplankton community in the region is dominated in terms of biomass and productivity by copepods, particularly Calanus species, which constitute a major food resource for many commercial fish species (Brander, 1992). The zooplankton in the vicinity of the Niobe Exploration Well is expected to be dominated by oceanic calanoid copepods, in particular Calanus helgolandicus and C. finmarchicus, (Beaugrand, 2003).
4.3.2 Benthic fauna Benthic fauna is comprised of species which live either within the seabed sediment (infauna) or on its surface (epifauna). Such species may be sedentary or motile. They
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are representative of a variety of different feeding types (for example, filter-feeding, predatory or deposit-feeding) and occupy a variety of different ecological niches. Epifaunal and infaunal species are particularly vulnerable to external influences which alter the physical, chemical or biological characteristics of the sediment. These organisms are largely sedentary and are thus unable to avoid unfavourable conditions. Benthic fauna are typically divided into various categories, principally according to size. The largest are the megafauna and this comprises animals, usually living on the seabed, which are large enough to be seen in bottom photographs and caught by trawl (for example, brittle stars, sea urchins, sea cucumbers, sea spiders, sponges and corals). Macrofauna are defined as those animals with a lower size limit of around 0.5 µm. Meiofauna are the small interstitial animals (mainly nematode worms and harpacticoid copepods) with a lower size limit of between 0.045 µm and 0.063 µm (Kennedy & Jacoby, 1999). Colonisation of sediments by different species is largely dependent on the type of sediment present and its characteristics. Physical and biological factors including seabed depth, water movements, salinity, temperature and available oxygen are important in determining species abundance and distribution. The species composition and relative abundance in a particular location provides a reflection of the immediate environment, both current and historical (Clark et al., 1997), as every benthic species has its own response and degree of adaptability to changes in the physical and chemical environment. Determination of sediment characteristics is of particular importance, therefore, in the interpretation of benthic environmental survey data.
Characteristic benthic communities Benthic fauna at the Niobe Exploration Well can be expected to comprise communities typical of that area of the North Sea and coastal areas. Seabed surveys undertaken in support of this ES found that visible fauna were sparse. These consistied of Polychaete worms, Arthropoda (including Pagurus sp., Pagurus bernhardus, Pagurus prideaux, Inachus sp., Liocarcinus sp. and Munida sp.), Bryozoa (Flustra sp.,), Chordata (including Gobiidae, Pleuronectiformes, Scorpaeniformes and Callinoymus lyra), Cnidaria (Actiniaria, Alcyonium sp., Hydrozoa, Pennatula phosphorea, Virgularia sp.), Echinodermata (Ophiuroidea, Asterias rubens, and Luidia sarsi), Foramnifera (Astrorhiza sp.) and Mollusca (bivalvia including siphons potentially belonging to Arctica islandica, a OSPAR (2008) listed species)(Gardline, 2014). Although seapens Virgularia sp. and P. phosphorea were present, there were observations of individual seapens rather than areas of high abundance that would constitute good examples of the OSPAR defined habitat of ‘Seapens and burrowing megafauna communities’. This was consistent with surveys undertaken in the Moray Firth for the MORL and BOWL Developments (MORL, 2012d, BOWL, 2012).
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4.3.3 Fish and shellfish Adult and juvenile stocks of finfish and shellfish are an important food source for seabirds, marine mammals and other fish species. Fish and shellfish are categorised into groups with the following characteristics: pelagic species occur in shoals swimming in mid-water, typically making extensive seasonal movements or migrations between sea areas. Example species include herring (Clupea harengus), Norway pout (Trisopterus esmarkii), lemon sole (Microstomus kitt), mackerel (Scomber scombrus), blue whiting (Micromesistius poutassou) and sprat (Sprattus sprattus); demersal species live on or near the seabed. Example species include cod (Gadus morhua), haddock (Melanogrammus aeglefinus), plaice (Pleuronectes platessa), sandeel (Ammodytes spp.), sole (Solea solea), ling (Molva molva), anglerfish (Lophius piscatorius), spurdog (Squalus acanthias), European hake (Merluccius merluccius) and whiting (Merlangius merlangus); and shellfish species live on the seabed and comprise molluscs, such as mussels and scallops, and crustaceans, such as shrimps, crabs and Nephrops norvegica (Norway lobster). Whilst there is limited interaction between fish species and offshore oil and gas developments, some fish and shellfish species are vulnerable to these activities and associated discharges to sea (CEFAS, 2001b). The most vulnerable periods for these species are at the egg and juvenile stages. Fish that lay their eggs on the sediment (e.g. herring and sandeel) or live in intimate contact with sediments (e.g. sandeel and most shellfish) are susceptible to smothering by discharged solids and disturbance to the seabed (Coull et al., 1998). Other ecologically sensitive fish species include cod, the majority of flatfish including plaice and sole, and whiting as, within the North Sea, these stocks are considered to be outside ‘safe biological limits’ (WWF, 2001; SeaFish, 2012). Spawning and nursery grounds have been previously identified for a number of species at the Niobe Exploration Well location. These are based on data provided by the industry-commissioned Fisheries Sensitivity Maps in British Waters, SEA2 Technical Report on North Sea Fish and Fisheries, and studies conducted by CEFAS (Coull et al., 1998; CEFAS, 2001b; Ellis et al., 2010). Table 4.9 presents the spawning and nursery ground information for recorded species throughout an annual period, and this information is also illustrated in Figure 4.9. The Niobe Exploration Well is located within the spawning grounds for cod, lemon sole, Nephrops, plaice, sandeel, sprat and whiting (Table 4.9 and Figure 4.8).Cod, lemon sole, plaice, sprat and whiting have pelagic eggs that are released into the water column. Sandeel are benthic spawners laying their eggs on the seabed. Niobe Exploration Well is considered to be within a main spawning area for sandeel, with a relative high intensity spawning recorded from International Council for the Exploration of the Seas (ICES) fish survey data (Ellis et al., 2010; Coull et al., 1998). A sandeel survey undertaken for the MORL Development found a relatively low abundance of this species within the wind farm site adjacent to the proposed Niobe Exploration Well. The study concluded that this area did not support extensive sandeel populations (MORL, 2012d). The surficial sediments which support sandeel populations (sand, slightly
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gravelly sand, gravelly sand and sandy gravel) are characteristic of the Moray Firth seabed. The distribution of Nephrops is limited by the extent of suitable muddy sediment in which the animals construct their burrows. Populations exist in the North Sea and in waters west of Scotland (in open water and sea lochs) at depths ranging from 5 m to 500 m. Nephrops spend most of their life in burrows only exiting to feed or to mate. They are opportunistic in their feeding habits, primarily feeding on crustaceans, molluscs and polychaetes. Nephrops mate in early summer, spawn in September and carry their eggs until they hatch, usually the following spring (Marine Scotland, 2014). The surficial sediments at the well location are sand, slightly gravelly sand, gravelly sand and sandy gravel rather than muddy sediment. The Moray Firth is considered an important area for the commercial squid species Loligo forbesi. Although spawning grounds have not yet been documented, analysis of spatial patterns in the increasingly important squid fishery suggests that L. forbesi move from the West Coast of Scotland into the North Sea to spawn. It is likely that the Moray Firth includes spawning grounds for this species (Young et al, 2006). The Niobe well location also coincides with nursery grounds for anglerfish, blue whiting, cod, European hake, haddock, herring, lemon sole, ling, mackerel (Scomber scombrus), Nephrops, plaice, sandeel, spotted ray (Raja montagui), sprat, spurdog (Squalus acanthias), thornback ray (Raja clavata) and whiting (Table 4.9 and Figure 4.8). Further detail on the biological characteristics of the fish species shown to have a high intensity of nursery or spawning in the vicinity of the Niobe Exploration Well is provided in Table 4.10.
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Table 4.9: Block spawning and nursery periods in the vicinity of, and including, the Niobe Exploration Well
Seasonality of Spawning (Peak spawning *)
Species
Nursery
Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec Anglerfish √ Blue whiting √ Cod * * √ European hake √ Haddock √ Herring √ Lemon sole √ Ling √ Mackerel √ Nephrops * * * √ Plaice * * √ Sandeel √ Spotted ray √ Sprat * * √ Spurdog √ Thornback ray √ Whiting √
Source: Coull et al. (1998); Ellis et al. (2010)
Chondrichthyans Chondrichthyans include sharks, rays and chimaeras, which typically have slow growth rates, late age at maturity and low reproductive output. Available data suggest that the distribution of Chondrichthyans, spotted ray, spurdog and thornback ray coincide with the Niobe Exploration Well location. Chondrichthyans are generally considered to be vulnerable to human activities (for example, overfishing). These species require a suitable substratum for the deposition of their eggs together with a preference for a habitat which includes species such as sponges, bryozoans, hydroids and dead man’s fingers (soft coral) (Ellis et al., 2004). Nursery grounds are used throughout the year, potentially making it impossible for an operation to avoid coinciding with the presence of juvenile fish, but as yet there is no direct evidence to suggest that these activities cause significant disturbance to nursery areas (CEFAS, 2001b).
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Table 4.10: Fish species showing a high intensity of nursery or spawning in the area of the proposed Niobe Exploration Well Sandeel (Ammodytes spp.) Sandeel are demersal and their eggs and larval stages are pelagic¹ Adults feed on planktonic prey¹ Key dietary component of birds (kittiwakes, razorbills, puffins, etc.), piscean predators (herring, salmon, sea trout, cod, haddock, marine mammals³
Cod Predominantly demersal fish but are pelagic during the first six months of larval (Gadus morhua) stage¹ Typically lay their eggs in upper 30 m of water column, with peak concentration between 10 and 20 m¹ Are included on the OPSAR Initial List of Threatened and/or Declining Species and Habitats²
Whiting (Merlangius merlangus) Adult fish feed on benthos and small fish¹ Whiting are benthopelagic and both its eggs and larvae are planktonic¹
Both larval and adult forms of herring are pelagic, but eggs are benthic¹ Herring Undergo metamorphosis after 2 to 7 months depending on spawning time¹ (Clupea harengus) Once hatched, the herring larvae become pelagic and are distributed by the prevailing currents1 Herring play a key role in the North Sea’s food-web and is predated by several fish species (e.g. salmon, sea trout, whiting, cod), seabirds and several marine
mammals³. Anglerfish (Lophius piscatorius) Anglerfish are bathydemersal although their larval stages are pelagic¹ Half buried on the seabed and attract their prey with a fishing filament¹
Source: ¹FishBase (2011); ²OSPAR (2008); ³BOWL (2012)
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Figure 4.8: Spawning and nursery grounds in the vicinity of the Niobe Exploration Well
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4.3.4 Anadromous fish and freshwater shellfish Three freshwater fish species with conservation importance have been cited as primary reasons and qualifying features for three rivers (Evelix, Oykel and Spey) that flow into the Moray Firth (Table 4.15):
Sea lamprey (Petromyzon marinus); Atlantic salmon (Salmo salar); and Freshwater pearl mussel (Margaritifera margaritifera). Further information on conservation designations is provided in Section 4.4.
Sea lamprey This is a parasitic anadromous migratory species, which spawns in a number of riverine habitats within the Moray Firth area. Their presence in the marine environment is dependent upon the host, which can be both marine mammals and fish species. This species has a limited capture rate in both coastal and estuarine waters, suggesting that they are solitary hunters and widely dispersed at sea (ABPmer, 2011).
Atlantic salmon This is an anadromous migratory species present both in riverine and marine habitats. This species spawns in freshwater (OSPAR, 2010) which is a requirement that necessitates their return to suitable areas to reproduce. The Salmon (Fish Passes and Screens) (Scotland) Regulations 1994 attempts to ensure that salmon, sea trout and other migratory species have physical access to their spawning natal rivers and burns (OSPAR, 2010). Whilst the Atlantic salmon can be found throughout the EU, UK Waters hold a significant proportion of the known stock, with Scottish waters being recognised as a European stronghold (JNCC, 2010b). The major rivers of the Moray Firth are among the important salmonid rivers in Scotland. The migratory routes of the Atlantic salmon cross the Moray Firth. Tagging studies have shown that the migratory paths tend to follow the coastal orientation, with initial migration using inshore areas (Malcolm et al., 2010). Migratory rates are reported to be rapid between the open sea at shallow depths (less than 15 m) (Malcolm et al., 2010). Whilst the commencement of the migratory period is dependent upon a range of environmental factors (temperature, river flow), within the Moray Firth it typically occurs from April to June (MORL, 2012e).
Freshwater pearl mussel The lifecycle of this species is reported to be closely linked to the Atlantic salmon, such that any impacts upon the salmon may indirectly impact the freshwater pearl mussel (MORL, 2012e).
4.3.5 Marine mammals Marine mammals include whales, dolphins and porpoises (cetaceans), and seals (pinnipeds). They may be vulnerable to the effects of oil and gas activities and can be impacted by noise, contaminants, oil spills and any effects on prey availability (SMRU,
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2001). The abundance and availability of prey, including plankton (Section 4.3.1) and fish (Section 4.3.3), can be of prime importance in determining the abundance and distribution of marine mammals and can also influence their reproductive success or failure. Changes in the availability of their principal prey species may be expected to result in population level changes of marine mammals but it is currently not possible to predict the extent of any such changes (SMRU, 2001). The Moray Firth is recognised as an important area for marine mammals for both cetaceans and pinnipeds, with international and national designations afforded for both bottlenose dolphins and harbour seal populations.
Cetaceans Cetaceans can be divided into two main categories: Baleen whales (Mysticeti), which feed by sieving water through a series of baleen plates; and Toothed whales (Odontoceti), which have teeth for prey capture. In comparison with the continental shelf and deep waters to the west of Shetland, the North Sea does not support particularly large or diverse populations of cetaceans (whales, dolphins and porpoises). Harbour porpoise (Phocoena phocoena), white- beaked dolphin (Lagenorhynchus albirostris), minke whale (Balaenoptera acutorostrata), long finned pilot whale (Globicephala melas), killer whale (Orcinus orca) and bottlenose dolphin (Tursiops truncatus) are the most common cetacean species in the vicinity of Quadrant 12. Sightings of humpback whale (Megaptera novaeangliae) and fin whale (Balaenoptera physalu) have also been recorded in Quadrant 12 (Table 4.11).
Table 4.11: Density of marine mammals in the quadrant containing the proposed Niobe Exploration Well
Seasonality of Density
Species
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Bottlenose dolphin Fin whale Harbour porpoise Humpback whale Killer whale Long finned pilot whale Minke whale White-beaked dolphin
Key: Low (0.01-0.09 animals/ km) Medium (0.10 – 0.19 animals/ km) High (0.20 – 0.49 animals/ km) Very high (>0.49 animals/ km)
Source: UKDMAP (1998); Reid et al (2003)
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Observations from surrounding quadrants reveal sightings of other cetacean species in low density such as white-sided dolphin (Lagenorhynchus acutus) in Quadrants 13 and 19, common dolphin (Delphinus delphis) in Quadrant 13 and Risso’s dolphin (Grampus griseus) in Quadrant 19. Cetacean distribution may be influenced by a variety of natural factors such as water masses, fronts, eddies, upwelling, currents, water temperature, salinity and length of day. A major factor likely to influence cetacean distribution is the availability of prey, mainly fish, plankton and cephalopods (Stone, 1997).
Bottlenose dolphins The Moray Firth Special Area of Conservation (SAC) has been designated as a result of its resident population of bottlenose dolphins, which is the only known resident population of bottlenose dolphins in the North Sea. There are, approximately 195 individuals (95% highest posterior density intervals, 162 to 253 individuals) present in the Scottish East Coast population (Cheney et al., 2012a, b). Survey work undertaken within the Moray Firth from a variety of sources (as reported in MORL, 2012d) indicates that whilst dolphin species may be encountered within the entire Firth, the bottlenose dolphins are most likely to be located along the coastal area. This suggests that this species is unlikely to be located at the site of the proposed Niobe Exploration Well. Further data regarding bottlenose dolphins are detailed in Section 4.4.2.
Harbour porpoise The harbour porpoises are the most common cetaceans in UK waters (DECC, 2009). They occur in most of the North Sea throughout the year, with higher numbers occurring between May and October. The harbour porpoises are generally described as a coastal species, but there have been numerous sightings in deep, offshore waters (Hammond et al., 2002; MacLeod et al., 2007; Northridge et al., 1995; Rogan and Berrow, 1996). Harbour porpoise have been observed throughout the entire Moray Firth. The SCANS II, which included the Moray Firth, indicated a smoothed porpoise density of 0.4 to 0.6 animals per km2 (SCANS II, 2006). Survey work undertaken within the Moray Firth from a variety of sources (as reported in MORL, 2012d) indicates that harbour porpoises have a preference for intermediate water depths with higher proportions of sand and gravel substrate, such as the Smith Bank. Observed numbers are reported to be low in coastal waters and density estimates are comparable to those predicted within the SCANS II study. Further data regarding harbour porpoise are detailed in Section 4.4.2.
Minke whale Minke whale occur throughout the central and northern North Sea, particularly during summer months. Minke whale are present in the North Sea from May until October. During the SCANS II survey in July 2005, minke whales were recorded throughout the North Sea, west of Britain and Ireland and on the Celtic Shelf. The highest densities of minke whale occurred in the northern part of the central North Sea. SCANS II study estimated 0.022 minke whale per km2 for the combined areas of the Moray Firth, Orkney and Shetland (SCANS II, 2006). The minke whale is the most abundant of all other species recorded within the Moray Firth, with a preference for sandbank environments (MORL, 2012d). In the Southern
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Trench located, approximately 25 km to the southeast of the proposed Niobe Exploration Well, there is has a high confidence in the presence of minke whales and white-beaked dolphins, based on data from the Joint Cetacean Database (Reid et al., 2003; SNH, 2012) (Table 4.10). Southern Trench was classified as a possible Marine Protected Area (pMPA) until July 2014. However, it was not included on the designated MPAs list (Scottish Government, 2014).
White-beaked dolphin White-beaked dolphin are distributed over the continental shelf, and in the North Sea they tend to be more numerous within about 200 nm of the Scottish and northeast English coasts. The white-beaked dolphins are present year-round in the North Sea, with most sightings recorded between June and October. The abundance of white-beaked dolphin in the north and central North Sea is estimated at approximately 9,443 animals (SCANS II, 2006).
Killer whales Killer whales have a worldwide distribution and are widely distributed in the deep North Atlantic and in coastal waters of northern Europe, particularly around Iceland, the Faroe Islands and western Norway. In UK waters they are most common off northern and western Scotland and occur in all months of the year. The species is regularly recorded from November to March between Shetland and Norway. A small number of sightings have been made in the Outer Moray Firth (less than 6.15 animals per standard hour) (Reid et al., 2003).
Humpback whale The humpback whale has a global distribution. Global observations indicate a preference in waters over and along the edge of continental shelves and oceanic islands (Reid et al., 2003). Within the UKCS, the greatest number of sightings has occurred at the Northern Islands, the Irish Sea, Firth of Clyde, Celtic Sea and Western Channel. The species is more regularly observed between May and September when a small number of sightings have been made in the Outer Moray Firth (less than 0.19 animals per standard hour) (Reid et al., 2003).
Pilot whale Pilot whales are commonly distributed in the deeper waters of the northeast Atlantic and have also been observed over the UKCS (Seawatch Foundation, 2012). Within the Moray Firth, sightings are classified as ‘occasional’ and with the number of sightings estimated at less than 9.9 animals per standard hour (Reid et al., 2003).
Fin whale Whilst the fin whale has a global distribution, preference is shown for temperate and polar seas and in deeper waters (400 to 2,000 m). Isolated populations have been observed in shallower waters of, approximately, 200 m deep. The greatest number of sightings has occurred close to the UKCS edge, and around northern Scotland these have occurred between June and August. A small number of sightings have been made in the Outer Moray Firth (less than 0.5 animals per standard hour (Reid et al., 2003).
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Information relating to the abundance of fin whales within Block 12/27 is currently not available.
Pinnipeds (seals) Two species of seal are resident in UK waters and have been recorded within the Moray Firth, the grey seal (Halichoerus grypus) and the harbour or common seal (Phoca vitulina), both occurring regularly over large parts of the North Sea (Stone, 2001; SMRU, 2001). Both species breed in the UK, with harbour seals pupping in June and July and grey seals pupping between October and December.
Grey seal The northeast Atlantic contains approximately half of the world’s population of grey seals with approximately 40% occurring in the UK. The population size within UK waters is estimated at 130,000, with an estimated growth of around 2.5% per annum (DECC, 2009). Approximately 90% of the UK population of grey seals breed in Scotland, largely in the Hebrides and Orkney. Major colonies are also present on Shetland and the east coast of Scotland (DECC, 2009). Grey seals spend most of the year at sea and travel long distances between haul out sites and range widely in search of prey (DECC, 2009). The majority of the grey seal population will be on land for several weeks from October to December during the pupping and breeding seasons, and again in February and March during the annual moult. Densities of grey seals offshore are likely to be lower during these periods (DECC, 2009). Grey seals may be present in the well area as they travel between sites and to and from foraging areas. Analysis of at-sea distribution data indicates that their occurrence at the proposed Niobe Exploration Well is likely to be low with between 5 and 10 grey seals per 25 km2 at any one time (Jones et al., 2013) (Figure 4.9). Survey work undertaken within the Moray Firth (as reported in MORL, 2012d) indicates that this species regularly travel outside the Moray Firth, with the Dornoch and Pentland Firths identified as areas of highest usage. Within the consented MORL boundary, usage is of the order of one to five animals per 16 km2 which is similar to that provided by Jones et al (2013). Given the proximity of the proposed Niobe Exploration Well, a similar usage can be inferred for the current interest.
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Figure 4.9: Grey seal density in relation to the proposed Niobe Exploration Well
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Harbour seal Harbour or common seals are one of the most widespread pinnipeds with almost circumpolar distribution in the Northern Hemisphere. Within UK waters they belong to a European sub-species, which mainly occur in UK, Icelandic, Norwegian, Swedish, Danish, German and Dutch waters; with approximately 33% of this population occurring in UK waters (DECC, 2009). Harbour seal counts in the UK are estimated at a minimum of 28,000 animals, the vast majority of which are found in Scotland (DECC, 2009). Harbour seals haul out on tidally exposed areas of rock, sandbanks or mud. Pupping occurs on land between June and July, and the moult between August and September (DECC, 2009). Harbour seals are widespread throughout coastal waters and their abundance at sea is constrained by the need to periodically return to shore (DECC, 2009). Analysis of at-sea distribution data indicates that their occurrence at the proposed Niobe Exploration Well is likely to be moderate with between 10 and 50 grey seals per 25 km2 at any one time (Jones et al., 2013) (Figure 4.10). Areas in the Inner Moray Firth have been designated as a SAC with the harbour seal as the conservation feature. Whilst recent surveys indicate a reduction in numbers within the SAC, there has been an increase in numbers within the entire Moray Firth. Surveys have found that the seals typically remain within 30 km of their haul-out sites and modelling as part of the MORL Development indicates a density of up to 0.5 animals per km2 (MORL, 2012d).
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Figure 4.10: Harbour seal density in relation to the proposed Niobe Exploration Well
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4.3.6 Seabirds Planned offshore oil and gas operations do not normally affect seabirds (DTI, 2001), however, they are vulnerable to oiling from surface oil pollution. This occurs either by direct toxicity through ingestion or hypothermia as a result of the birds’ inability to waterproof their feathers. Certain species become flightless during the moulting season (e.g. Guillemot (Uria aalgae), Razorbill (Alca torda) and Puffin (Fratercula arctica)), consequently spending a large amount of time on the water surface. This will make them particularly vulnerable to surface oil pollution (DTI, 2001). Seabird vulnerability to surface pollution varies throughout the year with peaks in late summer after breeding, when the birds disperse into the North Sea, and during the winter months with the arrival of over-wintering birds. The relative risk for different species to the threat of oil pollution can be assessed using the Offshore Vulnerability Index (OVI) as developed by the Seabirds at Sea Team (SAST) at JNCC. The OVI is derived from the following four factors (Williams et al., 1994): the amount of time spent on the water; total biogeographic population; reliance on the marine environment; and potential rate of recovery. The seasonal vulnerability of the seabirds at the well location (UKCS Blocks 12/27) is derived from the JNCC block-specific vulnerability data (JNCC, 1999). As shown in Table 4.12 the seabird vulnerability for the block 12/27 and surrounding blocks is “very high” throughout the year. This is as a consequence of the: near-shore location of the site; activity of breeding birds in the late summer months; arrival of over-wintering birds in the winter months; and location of the Moray Firth as a migratory route during the spring and winter months. A number of internationally important bird areas, Special Protection Areas (SPAs) and one draft SPA (dSPA) are present within the Moray Firth (Figure 4.11; Section 4.4), designated for a range of breeding seabird species: East Caithness Cliffs SPA: designated for Guillemot, Herring Gull, Kittiwake, Razorbill and Shag, in addition to a seabird assemblage including Puffin, Great Black-Backed Gull, Cormorant and Fulmar; North Caithness Cliff SPA: designated for Guillemot and an assemblage including Puffin, Razorbill, Kittiwake and Fulmar; Cromarty Firth and Inner Moray Firth SPAs: designated for Common Tern; Troup, Pennan and Lion’s Heads SPA: designated for Guillemot and an assemblage including Razorbill, Kittiwake, Herring Gull and Fulmar; and Moray Firth dSPA: qualifying bird species include the Annex 1 species Great Northern Diver, Red-throated Diver, and Slavonian Grebe and several migratory species, including Scaup, Common Eider, Long-tailed Duck, Common Scoter, Velvet Scoter, Common Goldeneye, Red-breasted Merganser and European Shag.
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Further, the East Caithness Cliffs MPA has been designated on the basis of the Black Guillemot population and habitat provided within the MPA (Figure 4.11; Section 4.4).
Table 4.12: Seabird vulnerability in Block 12/27
Block Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec All
12/27 1 1 1 1 1 1 1 1 1 1 1 1 1
Key: 1 Very high seabird vulnerability to oil pollution 2 High seabird vulnerability to oil pollution 3 Moderate seabird vulnerability to oil pollution 4 Low seabird vulnerability to oil pollution
Source: JNCC (1999) Ornithological surveys using different methods of sampling (boat-based, aerial, migration and tracking) were undertaken over a four year period for the MORL Development (MORL, 2012d). Table 4.13 presents the abundance and density estimates for observed species recorded at MacColl site of the MORL surveys.
Table 4.13: Seabird abundance and density estimates during summer and winter in the Niobe Exploration Well area Species Count Summer Winter Abundance 272 69 Fulmar Density 2.18 km2 0.55 km2 Abundance 53 12 Gannet Density 0.42 km2 0.10 km2 Abundance 46 0 Great Skua Density 0.37 km2 0 Abundance 910 121 Kittiwake Density 7.30 km2 0.97 km2 Abundance 3 19 Herring Gull Density 0.03 km2 0.15 km2 Abundance 123 48 Great Black-Backed Gull Density 0.99 km2 0.39 km2 Abundance 104 0 Artic Tern Density 0.83 km2 0 Abundance 2,926 430 Guillemot Density 23.48 km2 3.45 km2 Abundance 842 452 Razorbill Density 6.76 km2 3.63 km2 Abundance 0 69 Little Auk Density 0 0.55 km2 Abundance 839 197 Puffin Density 6.74 km2 1.58 km2 Source: MORL (2014d)
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4.4 Offshore Conservation Areas Biodiversity within the European Union (EU) is safeguarded using the: Habitats Directive: The European Community (EC) Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Flora and Fauna. Birds Directive: EC Directive 79/409/EEC on the Conservation of Wild Birds. These Directives provide for the protection of animal and plant species of European importance and the habitats which support them, particularly through the establishment of a network of protected sites. The Habitats Directive includes a requirement to establish a European network of important high quality conservation sites that will make a significant contribution to conserving the habitat and species identified in Annexes I and II of the EU Directive respectively. Habitat types and species listed in Annexes I and II are those considered to be in most need of conservation at a European level (JNCC, 2002, 2014a). The UK government, with guidance from the JNCC and the Department of Environment, Food and Rural Affairs (DEFRA), has statutory jurisdiction under the EC Habitats Directive to propose offshore areas or species (based on the habitat types and species identified in Annexes I and II) to be designated as SAC. These designations have not yet been finalised, but will be made to ensure that the biodiversity of the area is maintained through conservation of important, rare or threatened species and habitats of certain species: SACs are sites that have been adopted by the European Commission (EC) and formally designated by the government of each country in whose territory the site lies; Sites of Community Importance (SCIs) are SAC sites that have been adopted by the EC but not yet formally designated by the government of each country; and Candidate SACs (cSACs) are sites that have been submitted to the EC, but not yet formally adopted. cSACs are considered in the same way as if they had already been classified or designated, and any activity likely to have a significant effect on a site must be appropriately assessed. In relation to UK offshore waters, four habitats from Annex I and four species from Annex II of the Habitats Directive are under consideration for the identification of SACs in UK offshore waters (Table 4.14; JNCC, 2002, 2014a).
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Table 4.14: Annex I habitats and Annex II species occurring in UK offshore waters Annex I habitats considered for SAC selection Species listed in Annex II known to occur in UK in UK offshore waters offshore waters Sandbanks which are slightly covered by Grey seal. seawater all the time. Harbour or common seal. Reefs (bedrock, biogenic and stony). Bottlenose dolphin. . Bedrock reefs – made from continuous Harbour porpoise. outcroppings of bedrock which may be of various topographical shape. . Stony reefs – these consist of aggregations of boulders and cobbles which may have some finer sediments in interstitial spaces. . Biogenic reefs – formed by cold water corals (e.g. Lophelia pertusa) and Sabellaria spinulosa. Submarine structures made by leaking gases. Submerged or partially submerged sea caves.
Source: JNCC (2002, 2014a)
4.4.1 Annex I habitats None of the Annex I habitats listed in Table 4.15, occur at the Niobe Exploration Well location. However, there are a number of coastal SACs with marine components that occur in the vicinity of the Niobe Exploration Well. Several of these coastal SACs contain Annex I habitats (subtidal sandbanks and reefs). The locations of the coastal SACs in relation to the well location are illustrated in Figure 4.12.
Table 4.15: Coastal SACs with marine components of relevance to the Niobe Exploration Well Main conservation interest (marine Approx. distance Site Name Area (ha) components) from well (km) Subtidal sandbanks. Moray Firth 15,1347 50 Bottlenose dolphins. Reefs. Subtidal sandbanks. Dornoch Firth and Estuaries. 8,700 79 Morrich More Intertidal mudflats and sandflats. Harbour seal. Berriedale and Atlantic salmon. 58 48 Langwell Waters Sea lamprey. River Spey Atlantic salmon. 5,729 55 Freshwater pearl mussel. River Evelix Freshwater pearl mussel. 20 90 Atlantic salmon. River Oykel 960 110 Freshwater pearl mussel.
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4.4.2 Annex II species Annex II of the Habitats Directive lists species that are defined as “species of community interest whose conservation requires the designation of Special Areas of Conservation (SAC)”. Four Annex II species are known to occur in UK waters for which selection of offshore SACs will be considered: grey seal, harbour seal, bottlenose dolphin and harbour porpoise (Table 4.14). As with all marine mammals, these four species can be impacted by a number of activities associated with the offshore oil and gas industry (SMRU, 2001; DECC, 2009). All the Annex II protected species listed in Table 4.14 have been recorded in the area of the Niobe Exploration Well.
Bottlenose dolphin The Moray Firth SAC extends from the inner firths to Helmsdale on the north coast and Lossiemouth on the south coast (Figure 4.12). As a result of this designation, Scottish Natural Heritage (SNH) has responsibility to report on the conservation status of the bottlenose dolphin populations within the SAC every six years. The current condition status assessment for the population is “Unfavourable (recovering)”. This is based on a number of conservation targets for the interest feature (i.e. bottlenose dolphins) for this SAC, for example, maintaining or increasing population of dolphins using this SAC (Thompson et al., 2006; Thompson et al., 2009). Previous work showed that there was a reduction in the use of the SAC by dolphins during the late 1990s, followed by a slight increase during the previous 2002 to 2004 reporting period (SNH, 2006). The drilling operations are scheduled to occur in Q2/ Q3 2015 (Section 3), which coincides with low sightings of bottlenose dolphin recorded in the well area during August (Section 4.3.5; Table 4.11).
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Figure 4.11: Location of Niobe Exploration Well in relation to designated sites
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Harbour porpoise Harbour porpoises are a highly mobile species, with a UK wide distribution and have been observed throughout the entire Moray Firth. The SCANS II survey indicated a smoothed porpoise density of 0.4 to 0.6 animals per km2. There is currently a limited understanding of the seasonal movements and migratory patterns of harbour porpoises within both the Northeast Atlantic and North. Whilst porpoises may reside within an area for an extended period of time, onshore/ offshore migrations and movements parallel to the shore are also thought to occur (Bjørge and Tolley, 2002). In the North Sea there may be a general westward movement from the eastern North Sea and possibly from the very northern areas of the North Sea into the western edge of the northern North Sea (along the east coast of Scotland) during April to June, and a further influx to the northern North Sea during July to September (Northridge et al., 1995). These seasonal movements are thought to coincide with the calving and mating seasons, respectively. At present, not enough is known about harbour porpoises to determine whether some parts of their range are more important for breeding than others. Potential calving grounds have been identified in the German North Sea (Sonntag et al., 1999), but there is currently no evidence of specific habitat requirements for mating and calving in UK waters (JNCC, 2002). The Skerries and Causeway SCI on the Northern Ireland coast has been identified to protect harbour porpoises in the UK. And further 34 other sites have been identified where they are included as a non-qualifying feature. In 2013 JNCC contracted further work, after previous analysis failed to identified sites that would meet protected site selection criteria, to identify high density areas for harbour porpoises. Those results are currently being assessed (JNCC, 2014). Harbour porpoises are present throughout most of the North Sea, with higher numbers generally occurring between May and October (Section 4.3.4). Harbour porpoise numbers in the proposed well area occur predominantly between April and December, with sightings varying from low to high (Table 4.11). The drilling operations are scheduled to occur in Q2/ Q3 2015 (Section 3), which coincides with medium to high sightings.
Harbour and grey seals The vulnerability of seals from the Niobe Exploration Well could be caused by an oil spill. The potential and probable impacts are discussed in Section 14. For characteristics of seals, refer to Section 4.3.5.
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4.4.3 Marine Protected Areas (MPAs) network In Scotland, Nature Conservation MPAs are a new national designation under the Marine (Scotland) Act 2010 for inshore waters and the Marine and Coastal Access Act 2009 for offshore waters, where Scottish Ministers have executive devolution of authority for the designation of MPAs for the conservation of important marine biodiversity and geodiversity out to 200 nm (JNCC, 2014b). There are three types of MPA designations within Scottish territorial waters: Nature Conservation MPAs; Historic MPAs; and Research/ Demonstration MPAs (JNCC, 2014b). The new MPA powers allow Scotland to contribute to the UK’s European and International marine conservation commitments, such as those laid out under the Marine Strategy Framework Directive, the OSPAR Convention and the Convention on Biological Diversity (JNCC, 2014b). Marine Conservation MPAs are intended to complement existing site-based measures by protecting nationally important marine habitats, species and features of geological/ geomorphological interest in the seas around Scotland that are not currently afforded protection through existing measures. The Scottish MPA network will therefore consist of European Marine Sites (for example, SACs and SPAs), the marine component of SSSIs, and the new Nature Conservation MPAs (Scottish Government, 2014). Thirty Nature Conservation MPAs have recently (July 2014) been formally designated (Scottish Government, 2014). The closest MPAs to the Niobe Exploration Well are (Figure 4.11): East Caithness Cliffs, located, approximately, 35 km to the southwest of the well. This MPA extends 2 km from the coast, and extends between Helmsdale and Wick. The qualifying features of conservation are the Black Guillemots, together with their adjacent feeding grounds (SNH, 2014a); and Noss Head MPA located, approximately, 40 km to the south of the well. This MPA covers an area of approximately 8 km2 off the coast at Wick. The qualifying feature of conservation is Scotland’s largest known horse mussel bed (SNH, 2014b).
4.5 Socioeconomic Environment In addition to considering the potential impacts that the proposed Niobe Exploration Well may have upon the physical and biological environments, it is important to consider the potential impacts upon other marine users.
4.5.1 Commercial fisheries An assessment of fishing activity in the well area has been derived from ICES fisheries statistics, provided by Marine Scotland Science Division (Marine Scotland, 2013). Oil and gas exploration operations have the potential to interfere with fishing activities, for example as a result of the exclusion of fishing vessels from around subsea wellheads (CEFAS, 2001b). It is important to quantify the fishing activity and intensity in the Niobe area, to evaluate the potential impacts associated with the drilling operations on the fishing industry. For management purposes, ICES collates fisheries information for individual rectangles measuring 30 by 30 nm. Data have been obtained for ICES rectangle 45E7 which coincides with the Niobe Exploration Well. Statistical data from ICES rectangles provides
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information on the UK fishing effort and live weight of demersal, pelagic and shellfish caught by all UK vessels (Marine Scotland, 2013). Data on the economic value of fishing in this area have been produced based on UK catches and landings (Marine Scotland, 2013). The overall value of the different species by area (financial yield per ICES rectangle) is an indication of the differential worth of areas and is used as a method of expressing commercial sensitivity (Coull et al., 1998). The three main factors which determine the types of fishing gear and techniques used are the: fish species of interest, whether demersal, pelagic or shellfish (Section 4.3.3); local water depth and presence/ absence of any significant seabed features (Section 4.2.1); and surficial seabed sediment (Section 4.2.4).
Fishing gears Fishing effort in ICES rectangle 45E7 has reduced from 680 days in 2010 to 490 days in 2012 (Table 4.16). Demersal fishing methods, such as boat dredges and bottom otter trawling, dominated the fishing effort in ICES rectangle 45E7 between 2010 and 2012 accounting for 87% and 91% of effort, respectively (Marine Scotland, 2013).
Table 4.16: UK fishing effort (sum of days fished and percentage) using different gear types in ICES rectangles 45E7 in the period 2010 to 2012 2010 2011 2012 Gear Effort Effort Effort % effort % effort % effort (Days) (Days) (Days) Boat dredges 275 40 150 33 296 60 Danish seines 0 0 3 1 8 2 Otter trawls (not specified) 0 0 0 0 1 0 Otter trawls - bottom 322 47 230 51 152 31 Otter trawls - midwater 0 0 0 0 0 0 Otter twin trawls 18 3 26 6 8 2 Pair trawls - bottom 2 0 2 0 0 0 Pots 0 0 4 1 4 1 Nephrops trawls 0 0 0 0 0 0 Scottish seines 63 9 39 9 7 2 Seine nets (not specified) 0 0 0 0 14 3
TOTALS 680 100 453 100 490 100 Source: Marine Scotland (2013) Pelagic species are fished using techniques that do not interact with the seabed, whereas demersal and shellfish species are generally fished on or near the seabed and there is therefore the potential for the gears to interact with structures placed on the seabed.
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Relative fishing effort The UK relative fishing effort provides an indication of the fishing effort for each gear type in comparison to other areas of the UK offshore waters. The relative fishing effort in ICES rectangle 45E7 for all vessels (by different gear) in 2012, expressed in kW/days (days at sea multiplied by the power of the vessel in Kilowatts at the voyage landing date) was very low for pots and creels, low for whitefish and Nephrops gears and moderate for dredges (Marine Scotland, 2013) (Figure 4.12).
Figure 4.12: Relative fishing effort in the vicinity of the Niobe Exploration Well
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Relative annual value The relative annual value gives an indication of sensitivity, where damaging events such as oil spills, would be of more concern in an area of higher fisheries value than a similar spill in less productive waters (Marine Scotland, 2013). As such, this represents a method of expressing commercial sensitivity (Coull et al., 1998). The Moray Firth has a very productive commercial Cephalopod fishery, the main target species being squid (Loligo forbesi). This species is thought to be present all year round; however, fishing patterns indicate clear peaks in catch yields during October and November (Ithaca, 2007; MORL, 2012c). It is thought that squid catches from the Moray Firth may contribute to over 90% of the total cephalopod landings from ICES area of the northern North Sea (Ithaca, 2007). Although historically a by-catch fishery the target fishery has developed over the last decade in the southern Moray Firth between Fraserburgh and Nairn in late summer and autumn (Ithaca, 2007) and continues to increase as further restrictions are applied to the commercial fishing fleet and regulated demersal fisheries (MORL, 2012c). The relative annual value of commercial fisheries for ICES rectangle 45E7 in 2012 was very low for pots and creels, moderate for whitefish and Nephrops gears and high for dredges.
Catch composition Between 2010 and 2012 the annual total live weight of fish landed from ICES rectangle 45E7 ranged from 629 tonnes (2011) to 992 tonnes (2010) (Table 4.17). Over the three years analysed shellfish species represent the majority of fish species landed, accounting for 56% (2010), 34% (2011) and 54% (2012) of the total catch landed (Marine Scotland 2013; Table 4.17). Table 4.17: Total landings of demersal, pelagic and shellfish species caught in ICES rectangle 45E7 by UK and foreign vessels2008
2010 2011 2012 Species Type Quantity Quantity Quantity Value (£) Value (£) Value (£) (tonnes) (tonnes) (tonnes) Demersal 407,988 434 327,521 276 346,994 343 Pelagic 452 1 19,596 16 8,431 9 Shellfish 1,257,072 557 1,044,382 336 1,505,722 538
TOTAL 1,665,511 992 1,391,499 629 1,861,148 890
Source: Marine Scotland (2013) Over the three years analysed, the total quantity of fish species landed within ICES rectangle 45E7 (Figure 4.12; Marine Scotland, 2013) were dominated by: Scallops, accounting for 40% of fish species landed in 2010; Monks or anglers, accounting for 83% of fish species landed in 2011; and Scallops, accounting for 49% of fish species landed in 2012.
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500 2010 450 2011 400 2012
350
300
250
200 Quantity (tonnes)Quantity 150
100
50
0
Species (top ten)
Figure 4.13: Catch composition of UK landings (from UK and Foreign vessels) between 2010 and 2012, within ICES rectangle 45E7
4.5.2 Shipping Shipping density within Block 12/27 is expected to be very low (DECC, 2014b). The results of a dedicated shipping study commissioned by Suncor at the Niobe Exploration Well location (Anatec, 2014) indicate there are eight shipping routes passing within 10 nm of the Niobe well location (Figure 4.14), with an estimated 326 ships per year (Table 4.18). This corresponds to an average of less than one vessel per day.
Table 4.18: Summary of shipping routes passing within 10 nm of Niobe Exploration Well Route CPA Bearing Ships % of Description No. (nm) (°) per year total 1 Gullfaks Term. – Moray Firth* 1.6 147 20 6 2 Wick – Immingham 4.1 49 38 12 3 Moray Firth – N Norway/ Russia 5.2 316 13 4 4 Beatrice – Peterhead* 5.8 210 104 32 5 Moray Firth – Marstein 6.8 154 15 5 6 Faroes – Humber B 7.4 60 6 2 7 Athena – Inverness* 8.8 159 30 9 8 Buckie – Beatrice/ Jacky 9.2 270 100 31 TOTAL 326 100 *Where two or more routes have identical Closest Approach (CPA) and bearing they have been grouped together. In this case, the description lists the sub-route with the most ships per year. Source: Anatec (2014)
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Source: Anatec (2014) Figure 4.14: Shipping routes positions with 10 nm of Niobe Exploration Well
The overall breakdown of traffic by vessel type indicate that 63% were offshore support vessels, 23% tankers and 14% cargo vessels, mainly in the size range 1,500 to 5,000 Deadweight Tonnage (DWT) (Anatec, 2014). Fishing vessels were not included in the above study, as they are classed as non-routine activity. Figure 4.16 presents tracks of fishing vessels recorded on Automatic Identification System (AIS) with 10 nm of the Niobe Exploration Well during four months of 2014. The AIS is mandatory for majority of fishing vessels 15 m in length and over. Majority of those vessels were steaming on passage. There is, however, an increased fishing activity apparent 7 nm south of the Niobe Exploration Well.
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Source: Anatec (2014) Figure 4.15: Fishing vessels recorded on AIS within 10 nm of Niobe Exploration Well
4.5.3 Oil and gas industry Oil and gas activity within the Outer Moray Firth is relatively high. With respect to the proposed Niobe Exploration Well there are nine developments of relevance of which six are operational, one is under development and two are not currently active. Table 4.19 summaries these developments, while Figure 4.16 illustrates their locations relative to the well location.
Table 4.19: Oil and gas fields/ development in the vicinity of the Niobe Exploration Well Approximate distance Hydrocarbon Field name Operator Status (km) and direction to/ Type from the well Atlantic Condensate Nexen Production suspended 105 E Beatrice Oil Ithaca Producing 20 W Blake Oil BG Group Producing 75 E Buzzard Oil Nexen Producing 105 ESE Captain Oil Chevron Producing 55 NE Cromarty Gas Hess Production ceased 95 E Golden Eagle Oil Nexen Producing 105 E Jacky Oil Ithaca Producing 15 NW Ross Oil Talisman Producing 70 E
Source: UK Oil and Gas Data (2014)
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Figure 4.16: Oil and gas infrastructure in the vicinity of the Niobe Exploration Well
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In addition, the following oil and gas infrastructure are located approximately 0.3 km to the northwest of the Niobe Exploration Well (Figure 4.17): Beatrice AP to Jacky power cable; Jacky to Beatrice AP production pipeline; and Beatrice AP to Jacky water line.
4.5.4 Communications No telecommunication cables are present within Block 12/27. The active SHEFA-2 Telecoms cable is located approximately 25.4 km to the east of the Niobe Exploration Well (Figure 4.17).
4.5.5 Military activities The Ministry of Defence (MOD) conducts both surface and sub-surface activities in the Moray Firth. The proposed Niobe Exploration Well site, in addition to other areas of the Inner and Outer Moray Firth, is used by the Royal Air Force for radar training, high and low-angle gunnery and air-to-sea or ground firing. The well site is located (Figure 4.17): within the large Air Force Department Area D809D, used for high energy manoeuvres and air combat training at an altitude of 22,000 to 55,000 ft; and adjacent to the now withdrawn (MORL, 2012c) Air Force department Area D807, previously used for bombing, firing and radar training from the surface to an altitude of 1500 ft (Ithaca, 2007). The MORL ES notes the presence of two unexploded ordnances to the east of the Niobe Exploration Well, based on the location within a MOD practice area there may be the potential for unexploded ordinance on the wind farm site (MORL, 2012a).
4.5.6 Gas storage and Carbon Capture activities One Carbon Capture development is located within the Moray Firth, approximately 16 km to the south west of the proposed Niobe Exploration Well. This is being developed by Shell on the depleted Goldeneye reservoir.
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Figure 4.17: Military practice areas and offshore subsea cabling in the vicinity of the Niobe Exploration Well.
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4.5.7 Marine renewables, including offshore wind Two OWF developments have been granted consent within the Moray Firth (Figure 4.18): MORL (The Niobe Exploration Well is located within the MORL array boundary); and BOWL (The Niobe Exploration Well is located approximately 15 km from the BOWL development boundary).
MORL This development comprises Eastern and Western Development Areas (EDA and WDA, respectively). Only the EDA has been granted consent for up to 1,116 MW and has been further subdivided into three sites: Telford; Stevenson; and MacColl. The Niobe Exploration Well is located within the MacColl site. The EDA will comprise of: a maximum of 186 three-bladed horizontal axis Wind Turbine Generators (WTGs). The associated foundations will either be a mix of or one design of: o concrete gravity bases with ballast and gravel/grout beds; and o steel lattice jacket with pin piles. ancillary infrastructure in the form of inter-array cabling, export cable to shore and a variety of Offshore Substation Platforms. Surveys for MORL are proposed for 2015, with construction proposed to commence in Q1 2016 and first power expected by Q3 2020.
BOWL This development has been granted consent for a maximum generating capacity of 750 MW and will comprise of: a maximum of 140 wind turbine generators which will be either be a mono-tower or tubular jacket structure. The associated foundations will either be pin piled, suction piled or gravity base structure; and ancillary infrastructure in the form of inter-array cabling, export cable to shore and up to three meteorological masts. Construction is expected to take between three and five years and is likely to commence in 2015/ 2016.
4.5.8 Wrecks and archaeological sites Three wrecks are located within 5 km of the Niobe Exploration Well (SeaZone Wrecks, 2013). These are HMS Lynx (part of) (4.2 km SE), the Minsk (2.6 km E) and the Charkow (4 km E). HMS Lynx is a designated vessel under The Protection of Military Remains Act 1986 (Designation of Vessels and Controlled Sites) Order 2002. It is not anticipated that the drilling of the proposed well and the rig location will impact the integrity of these wreck sites.
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Figure 4.18: Offshore Wind farms in the vicinity of the Niobe Exploration Well.
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4.6 Summary of Environmental Sensitivities The Niobe Exploration Well is located in UKCS Block 12/27, in the Outer Moray Firth. The baseline environmental characteristics relevant to the proposed drilling include: The Niobe Exploration Well is located at a water depth of 55 m MSL. The Smith Bank, a large-scale bathymetric feature, is located 1.3 km to the west of the proposed project. There are no small-scale features, for example sand waves, located at the well site. The tidal regime is benign, with high-energy, infrequent wave events (storms) contributing to sediment transport. Waves predominately originate from the north-east, with wave heights generally being between 1 and 1.5 m. Maximum recorded wave heights are of the order of 6.3 m. Wind characteristics show a strong seasonality with the greater speeds occurring during the winter periods. Average annual wind speeds are approximately 12 m/s and direction is variable dependent upon season. Surficial seabed sediments are composed of predominately sandy sediments (sand, gravelly sand) of varying, but typically limited thickness. Underlying geology Firth is predominately composed of Cretaceous rocks with Jurassic and Permo-Triassic rocks present along the inner and southern margins of the Firth. The Outer Moray Firth has a number of other marine users, as detailed in Table 4.20, including: o Commercial fishing – moderate activity. o Shipping – low shipping density. o Oil and Gas - nine developments, of which six are operational and one is under development. The closest located 15 km from the Niobe Exploration Well. o Offshore wind – two consented projects exist in the vicinity of Niobe MORL (Niobe is within the wind farm) and BOWL (20 km to the west). o Military – both surface and sub-surface activities occur in the Moray Firth. The key environmental sensitivities arising from this review of the baseline environmental conditions with respect to the proposed drilling are summarised in Table 4.21. In the context of this report environmental sensitivity is defined as the capacity of a habitat or organism to respond positively or negatively to the cause of an environment impact. On this basis, it can be concluded that there are sufficient data available for an adequate assessment of the physical, chemical, biological and socioeconomic components of the environment and its sensitivities in the proposed development area. Table 4.21 also identifies the potential cause of impacts (i.e. environmental aspects) associated with the drilling, to which these receptors could be vulnerable. The environmental risk assessment (Section 6) identifies and assigns significance to the potential impacts and risks associated with routine, abnormal and emergency events. The evaluation takes account of the activity causing the impact or risk and the sensitivity of the receptor as summarised in Table 4.21.
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Table 4.20: Other marine users of relevance to the proposed Niobe Exploration Well Closest Requires Section Marine User Type distance to Description consideration? Reference well (km) Commercial Moderate activity recorded, n/a 4.5.1 Fisheries though potential high Shipping n/a Very low shipping density 4.5.2 Nine developments, of which six are operational and one is Oil and Gas Industry 15 under development. In 4.5.3 addition, three pipelines are within the Moray Firth. SHEFA-2 Telecomms Cable Communications 25.4 4.5.4 to the east, outwith block. Both surface and sub-surface At same activities occur. Military Activities 4.5.5 location as well Two unexploded ordnances have been noted to the east Overlapping Marine Renewables, with well Two consented wind farms, including Offshore location earliest construction expected 4.5.7 Wind 2015.
Wrecks and One known wreck to the east 2.6 4.5.8 Archaeological Sites (MINSK Cargo Steamer) No marine waste disposal sites within the Moray Waste Disposal Sites X n/a Firth Gas Storage and Carbon Capture 16 Saline aquifer site 4.5.6 Activities Marine Aggregate X No marine aggregate sites within the Moray Firth n/a Extraction Activities
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Table 4.21: Summary of environmental conditions and sensitivities in the vicinity of the proposed Niobe Exploration Well Physical environment Bathymetry: The seabed at the Niobe Exploration Well is typically flat with no adjacent large scale features The water depth is 55 m. Hydrodynamics: Benign tidal conditions, with dominant waves and winds originating from the North Sea. Salinity and Temperature: The water column is prone to stratification in the summer due to solar heating. Sediments type and features: The surficial seabed is predominately composed of sand sized sediments with occasional shell fragments. Gravel sized sediment is also present at certain locations. Chemical environment Seabed chemistry: Surface sediments are variable loose to very dense shelly sand to a depth of <1 m. The sands are mostly medium sands with shell fragments and occasional whole shells. Occasional bands of whole shells and shell fragments interspersed with bands of sandy sediment and areas of cobble or small boulders also occur. Between 1 and 41m below the seabed, the sediments consist of very soft clay. Biological environment Plankton: Plankton community and seasonality is typical for the Moray Firth Benthic Fauna: Seabed surveys undertaken in support of this ES found that visible fauna were sparse Habitats Directive: Annex I Habitats: No Annex I habitats have been found at the location of the Niobe Exploration Well. Habitats Directive: Annex II Species: All four species have been identified at the location of the Niobe Exploration Well. Designated Marine Protected Areas: Two sites have been designated as MPA’s: Noss Head and East of Caithness Cliffs. The conservation features are the horse mussel bed and Black Gannet population, respectively. Finfish and shellfish populations: Nursery grounds for anglerfish, blue whiting, cod, European hake, haddock, herring, lemon sole, ling, mackerel, Nephrops, plaice, sandeel, spotted ray, sprat, spurdog, thornback ray and whiting. Spawning grounds for cod (January to April), lemon sole (April to September), Nephrops (all year), plaice (January to March), sandeel (November to February), sprat (May to September) and whiting (February to June). Seabirds: Vulnerability is very high for the entire year; A number of seabird species are listed as interest features in designated sites (SPA) within the Moray Firth: Fulmar, Shag, Cormorant, Peregrine, Kittiwake, Herring Gull, Great Black–backed Gull, Guillemot, Razorbill and Puffin. Marine Mammals: Most sensitive periods are April through to September and November. Species present: bottlenose dolphin, fin whale, harbour porpoise, humpback whale, killer whale, long finned pilot whale, minke whale, white-beaked dolphin, harbour seal and harbour seal.
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5.0 CONSULTATIONS Consultation with stakeholders is an important part of the EIA process, as it enables the issues or concerns of stakeholders to be recorded, addressed and communicated within the ES. Where applicable, this information can be acted upon during the subsequent planning and implementation stages of the project.
5.1 Purpose and Method During the preparation of this ES, consultations were undertaken with the statutory consultees regarding the drilling of the Niobe Exploration Well. An informal consultation meeting was held on 18 June 2014 between Suncor, DECC and the JNCC. The informal consultations undertaken by Suncor allowed the statutory consultees to express any operational or environmental concerns regarding the proposed drilling operations.
5.2 Concerns and Issues Table 5.1 summarises the main issues and concerns raised by the stakeholders during the consultation process and provides Suncor’s response on how these were addressed.
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Table 5.1: Summary of the Niobe Exploration Well ES consultations Consultee comment/ concern Suncor response to comment/ concern DECC and JNCC comments in response to the informal consultation meeting held with Suncor on 18 June 2014 DECC and the JNCC advised Suncor that the ES should include: Suncor can confirm the following: Only the proposed drilling operation no further field developments. The ES is a single subject ES. Recommendations made in the DECC Guidance Notes. The latest DECC EIA Guidance Notes have been used to prepare the ES. Nearby wind farm development stage and schedule in relation to the proposed period of drilling Nearby wind farm development stage(s) and schedule(s) are presented in Section 4. operations. Details of a well test, if it is to be undertaken. Suncor do not plan to undertake a well test as part of the Niobe Exploration Well. Details on any vertical seismic profile (VSP) operations, if they are to be undertaken. Should VSP be required Suncor will ensure the appropriate permit applications are Information on sensitive habitats and species at the drilling location. submitted (Section 3). Information on seabed habitats at the drilling location from seabed survey results. Sensitive habitats and species information is presented in Section 4. A seabed habitat map detailing the proposed jack-up layout plan. Seabed habitats and survey information is presented in Section 4 Ministry of Defence Activity (MoD) details in relation to the drilling location. A seabed habitat map detailing the proposed jack-up layout plan is presented in Section 4. Broad coverage of Notice to Mariners. MOD details are presented in Section 4. The most recent references where available. Notice to Mariners information is presented in Sections 7 to 13. Where available, the most recent references have been used. JNCC comments in response to the informal consultation meeting held with Suncor on 18 June 2014 The JNCC specifically advised Suncor that: Suncor can confirm the following: Marine mammals and associated impacts such as noise and corkscrew injuries are adequately Marine mammals and associated impacts are presented in Sections 9 and 11. covered in the ES. Cumulative impacts covered in the ES should include the worst case scenario. Wind farms Cumulative impacts have been included with Sections 7 to 13. impacts do not need to be included if they are out with any slippage of the drilling operations. They did not foresee the requirement of an Appropriate Assessment for the proposed drilling operations. They were looking for details on impacts, mitigation and residual impact with the ES, and not too much detail on background information on species that is already known. Draft guidance on marine mammals and drilling operations should be addressed when completing the ES. They could provide Suncor with relevant documents to be included within the ES.
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6.0 ENVIRONMENTAL RISK ASSESSMENT This section identifies and ranks the environmental and societal impacts and risks (potential impacts) that could arise directly or indirectly from routine and emergency situations during the drilling operations for the Niobe Exploration Well. For clarity, the project has been split into two stages: drilling and decommissioning. The environmental risks of decommissioning the well are not fully assessed in this document. As required under The Petroleum Act, 1998, they would be formally assessed towards the end of field life if a development goes forward or prior to P&A whenever it is scheduled. Such an assessment would be undertaken in accordance with the legislation and policy in force at that time. For these reasons, only a high level assessment of the potential impacts from decommissioning has been carried out within the ES.
6.1 Risk Assessment Methodology The purpose of the risk assessment process is to identify: those potential impacts and risks that may be significant in terms of the threat that they pose to particular environmental receptors; the need for measures to manage the risk in line with industry best practice; and requirement to address concerns or issues raised by stakeholders during the consultation for this ES. Separate assessments were undertaken for any potential risks associated with planned (Section 6.1.2) and unplanned (Section 6.1.3) events. In this section of the ES, the scope of the risk assessment is confined entirely to the proposed drilling operations. Tables 6.6 and 6.7 show the outcome of this assessment, and Sections 7 to 13 provide a more detailed evaluation of those impacts and risks that were assessed to be significant. Appendix B gives a justification for those risks that were deemed to present a low risk.
6.1.1 Overview of the assessment process The general definition of risk is:
The probability that a A measure of the consequence The overall risk posed by X casual event will occur of the event occurring = an activity
In terms of environmental impact assessment this can be defined as:
The likelihood that the The likelihood The magnitude/ Significance of event will have an that a causal X X severity of the effect = the impact/ impact upon a particular event will occur on the receptor risk environmental receptor
For the purpose of this EIA, to ensure a transparent, robust, yet fit-for-purpose assessment, this method was applied differently for the planned events in the drilling operations and for the unplanned/ accidental events which might occur. The environmental risk assessment applied the criteria presented in Tables 6.1 and 6.2, while considering the sources of potential impact identified from Section 3 and the
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sensitivity of the receptors identified in Section 4, to judge the significance of each environmental risk. The risk assessment was undertaken by working through a series of individual tables (Tables 6.6 and 6.7), with one table for the drilling operations and one table for decommissioning.
6.1.2 Assessment of planned activities The risk assessment for the planned activities was derived by reducing the definition to:
The likelihood that an event will have an impact The magnitude Significance of X upon a particular environmental receptor(s) of the effect = the impact/ risk
For planned events, it is certain that the event will occur; therefore, the first term can be set as equal to one and effectively ignored. The primary driver for the risk assessment is then the likelihood that a particular environmental receptor(s) will be affected by the planned activity. This is governed by the receptor’s sensitivity to the causes of impact, its location in relation to the source of the impact, the timing of the impact and the ability of the receptor to recover. Criteria for assessing “the likelihood of occurrence of the impact upon a particular receptor” and the “magnitude/ consequence of the environmental impact” for each activity are presented in Tables 6.1 and 6.2, respectively.
Table 6.1: Guidelines for assessing likelihood of occurrence of an impact upon a particular receptor resulting from the planned activities Frequency of planned activity impacting receptors during drilling Likelihood operations A Definite Impact observed every time; might occur once a year or more on site
B Likely Impact often observed; could happen several times in site’s life
C Possible Impact occasionally observed; might happen in site’s life ood
D Unlikely Impact rarely observed; has occurred only several times in industry
likelih ← Decreasing E Remote Impact almost never observed; few if any events in industry
These factors were combined using a risk assessment matrix (Table 6.3) to determine what level of risk the proposed activity could pose to groups of receptors (or related attributes such as use of resources, use of disposal facilities, integrity of conservation sites, etc.) in the physical, chemical, biological and socioeconomic receiving environments. The overall significance for a particular activity was determined by taking the highest level of risk associated with the project activity against any one of these receptors/ attributes. The results of the assessment are presented in Tables 6.6 and 6.7.
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Table 6.2: Guidelines for assessing the magnitude/ consequence of the impacts on the environment Magnitude/ Characteristics consequence Adverse permanent impacts on key ecosystem functions in larger natural 5 Catastrophic habitats or social and economic resources/ assets, uses or activities. Scale typically widespread (national or greater level). Adverse long term impact on ecologically valuable natural habitats (e.g. restitution time >10 years), or social and economic resources, uses or 4 Severe activities. Scale typically regional to national level. Adverse medium term impacts on a significant part of habitats (e.g. restitution 3 Major time 1 to 10 years) or social and economic resources, uses or activities. Scale typically local to regional level. Adverse short term impact on natural habitats, social and economic activities 2 Moderate or resources, or social and economic resources, uses or activities. Scale typically localised. Very limited adverse impact on natural habitats or social and economic resources, uses or activities. No impact on population, only on individual 1 Minor level. Scale typically transient and highly localised.
Table 6.3: Environmental risk assessment matrix
Magnitude/ consequence of impact (Table 6.2) Planned Accidental 1 2 3 4 5
Minor Moderate Major Severe Catastrophic
Low Medium Medium High High .4)
6 A Definite Likely
A1 A2 A3 A4 A5 .1 and .1and
6 Low Medium Medium High High B Likely Unlikely B1 B2 B3 B4 B5
Low Low Medium Medium High C Possible Very unlikely C1 C2 C3 C4 C5
Extremely Negligible Low Low Medium Medium D Unlikely unlikely D1 D2 D3 D4 D5
Almost Negligible Negligible Low Low Medium E Remote unheard of
Likelihood of occurrenceLikelihood (Table of E1 E2 E3 E4 E5
Although drilling the Niobe Exploration Well will create employment and other direct and indirect benefits, these positive impacts of the project were not considered further in the assessment that follows.
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6.1.3 Assessment of unplanned/ accidental events The risk assessment for unplanned/ accidental events was derived by reducing the definition to:
The likelihood that an event will Significance of the X The magnitude of the effect = occur impact/ risk
The, assessment is therefore focussed on the magnitude of any impact and the probability that the causal event will occur. As outlined in Section 6.1.2, the magnitude of impact was assessed for each receptor and recorded in the tables. The definitions for “the magnitude/ consequence of the environmental effects” and “the likelihood of occurrence of the unplanned or accidental event” for each activity are provided in Tables 6.2 and 6.4, respectively.
Table 6.4: Guidelines for assessing likelihood of occurrence of an impact resulting from unplanned/ accidental activities Frequency of an unplanned or accidental event occurring and Likelihood impacting receptors during drilling operations A Likely Might happen once a year on site; 1 per year
B Unlikely Could happen several times in site life; 1 per 10 years C Very unlikely Might happen in site life; 1 per 100 years
D Extremely unlikely Has occurred several times in industry; 1 per 1,000 years likelihood Decreasing E Almost unheard of Few if any events in industry; 1 per 10,000 years
These factors were combined using a risk assessment matrix (Table 6.3) to determine what level of risk the proposed activity could pose to the physical, chemical, biological and socioeconomic receiving environments. The overall significance for a particular activity was determined by taking the highest magnitude of impact associated with the project activity against any one receptor/ attributes of the receiving environment and compared with the likelihood of the causal event from Table 6.4.
6.2 Risk Assessment Findings The results of the risk assessment are shown in Tables 6.6 to 6.7. The left-hand column of the tables identifies the aspects of the project that will cause or have the potential to cause impacts to sensitive receptors. These environmental aspects (EN ISO 14001: 2004) include routine, abnormal and emergency events. The remaining columns of the tables identify the potential physical, chemical, biological and societal receptors. The four right-hand columns of the tables present the transboundary effects, stakeholder concerns, the overall assessment of significance (i.e. the highest assessed risk), and the sections of the report that give a detailed justification of the assessment made. Taking the effects of planned mitigation into account, no “high” environmental risks have been identified during the assessment. The risk assessment, however, identified the following activities associated with the proposed drilling operations as having the potential to be of “medium” risk, which are assessed further in Sections 7 to 13: interaction with other users of the marine environment (Section 7); seabed disturbance (Section 8);
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atmospheric emissions (Section 9); discharges to sea (Section 10); physical interactions between vessels and seals (Section 11); and underwater noise (Section 12). In addition, the potential for a significant accidental hydrocarbon release is discussed in relation to the activities associated with the drilling operations: accidental hydrocarbon release (Section 13).
6.3 Summary of Risk Assessment The total numbers of “low” and “medium” environmental risks associated with each activity are presented in Table 6.5. As stated in the previous section, impacts or risks classified as “medium” are discussed further in Sections 7 to 13. Section 14 provides a summary of the impacts or risks classified as “medium” and Suncor’s proposed mitigation measures. For the impacts or risks that were considered to be “low”, Appendix B provides the justification for the assessment made and for excluding these impacts and risks from further investigation in the EIA.
Table 6.5: Summary of the risk assessment conducted for the Niobe Exploration Well Risk
Negligible Low Medium High
Project Stage
event event event event event event
event event
Planned Planned Planned Planned
unplanned unplanned unplanned unplanned
Accidental/ Accidental/ Accidental/ Accidental/
Drilling activities 0 0 7 1 6 3 0 0 Decommissioning 0 0 3 1 5 1 0 0 TOTAL 0 0 10 2 11 4 0 0
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Table 6.6: Risk assessment of the drilling activities
Physical and chemical Biological Socioeconomic
*These impacts may represent a cumulative impact from the exploration well
Key
High risk
Medium risk
boundary effects
Low risk -
Trans concerns Stakeholder significance Overall section justification Impact reference
Sediment structure / / structure Sediment chemistry quality Water resources Use of disposal Use of facilities (local) Airquality biology Sediment (benthos) column Water (plankton) shellfish and Finfish Seabirds Sea mammals of Integrity sites conservation fishing Commercial Shipping operations Military users Other Drilling: Planned events Physical presence of the jack-up drilling rig and vessels A2 7 Installation and removal of the jack-up drilling rig B2 8 Gaseous emissions from the jack-up drilling rig and vessels B2 9 Aqueous discharges from the jack-up drilling rig A1 B Ballast water discharge from the jack-up drilling rig A1 B Discharge of sewage and macerated waste A1 B Permitted discharge of WBM cuttings B2 10 Skip and ship of LTOBM cuttings C1 B Onshore disposal of solid waste (rig &vessels) C1 B VOCs from mud usage and fuel transfer C1* B Cement discharge A1 10 Permitted discharge of drill chemicals A1 B Physical interaction between vessels and seals, i.e. ‘corkscrew’ deaths C2 11 Underwater noise from drilling and vessels C2 12 Drilling: Accidental/ Unplanned events Well blow out of oil and gas C4 13 Hydrocarbon spill or release, e.g. from vessel collision C3 13 Spills of chemicals and muds B3 13 Objects dropped into the sea A1 B
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Table 6.7: Risk assessment of the decommissioning activities associated with the Niobe Exploration Well
Physical and chemical Biological Socioeconomic
*These impacts may represent a cumulative impact from the exploration well
Key
High risk
Medium risk
boundary effects
Low risk -
quality (local) quality
Trans concerns Stakeholder significance Overall justification Impact reference section
Sediment structure / / structure Sediment chemistry quality Water resources Use of disposal Use of facilities Air biology Sediment (benthos) column Water (plankton) shellfish and Finfish Seabirds Sea mammals of Integrity sites conservation fishing Commercial Shipping operations Military users Other Decommissioning: Planned events Physical presence of the vessels A2 7 Gaseous emissions from the vessels B2 9 Physical interaction between vessels and seals, i.e. ‘corkscrew’ deaths C2 11 Underwater noise from the vessels C2 12 Discharge of sewage and macerated waste A1 B Plug and abandonment of well A1 B Mechanical cutting of casing A1* B Presence of cuttings piles A3 10 Decommissioning: Accidental/ Unplanned events Hydrocarbon spill or release, e.g. from vessel collision C3 13 Objects dropped into the sea A1 B
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7.0 INTERACTION WITH OTHER USERS OF THE MARINE ENVIRONMENT This section focuses on the potential impacts of the proposed drilling activities on other users of the marine environment. The temporary and long-term physical presence of vessels or any subsea structures at the sea surface or on the seabed could potentially interact with users of the marine environment surrounding the Niobe Exploration Well. The drilling rig and associated vessels will remain at the well location for a period up to 45 days and therefore could potentially result in a temporary impact to users of the surrounding sea area. The Niobe Exploration Well will be P&A’d in accordance with the UKOOA Guidelines for Suspension and Abandonment of wells (or applicable guidance at the time). From the socioeconomic description in Section 4, other users of the sea include those involved in or responsible for commercial fisheries, shipping, submarine cables, oil and gas installations and infrastructure, military operations, marine archaeological sites and renewable energy installations and infrastructure. The section also describes the measures taken or planned by Suncor to minimise disturbance to the other users of the marine environment.
7.1 Regulatory Context The physical presence of the drilling rig and associated vessels and the resultant disturbance to other users of the marine environment, will be managed in accordance with the provisions under The Coast Protection Act 1949 (as extended by the Continental Shelf Act 1964), which have been transferred to Energy Act 2008 Part 4A by the Marine and Coastal Access Act 2009 (MCAA) and the Marine (Scotland) Act 2010 (MSA) to cover navigation considerations. Under the Energy Act 2008, Suncor will require consents (Consents to Locate) from DECC prior to the commencement of the planned drilling activities. Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
7.2 Basis for Assessment The approach in this section is to provide an assessment of the temporary physical presence of vessels that will occur as a result of the proposed drilling operations, and that could potentially impact other users of the marine environment.
7.3 Sources of Potential Impacts During the proposed drilling operations the following vessels will be temporarily located at the Niobe Exploration Well: a jack-up drilling rig for a period of up to 45 days; a maximum of three tugs to tow the jack-up rig to the site; one standby vessel on location for up to 45 days; and one supply vessel on location for up to 45 days.
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A temporary 500 m radius safety exclusion zone (0.79 km2) will be in place around the jack-up drilling rig. This exclusion zone will result in other users of the marine environment being temporarily unable to access the sea area within the immediate proximity to the drilling rig. Once the drilling operations have been completed, the well will be plugged and abandoned. The drilling rig and associated vessels will depart from the well location, leaving no permanent physical presence or obstruction on the seabed or sea surface.
7.4 Impact on Sensitive Receptors The receptors assessed in this section include commercial fisheries, commercial shipping, offshore renewables energy, Ministry of Defence (MoD), and marine archaeology. These are described in detail below.
7.4.1 Commercial fisheries Oil and gas exploration activities have the potential to impact commercial fishing activities, primarily as the result of either direct or indirect exclusion of fishing vessels from around surface and subsea structures. Other potential issues can arise from damage to fishing gear from seabed debris and obstacles either dropped or left behind once activities have finished. The main impact associated with the drilling of the Niobe Exploration Well would be the exclusion of fishing vessels from the 500 m radius of the drilling rig safety exclusion zone, equating to a total area of approximately 0.79 km2. The 500 m radius exclusion zone and the standby vessel will ensure that fishing vessels will be unable to access the sea area and seabed within the immediate proximity of the drilling rig for the duration of drilling operations. The ‘relative’ UK fishing value and effort in the 3,087 km2 seas area defined by ICES rectangle 45E7 (which includes the well location) were assessed to be of ‘moderate’ value (£250,000 to <£1,250,000) (Section 4). From the information provided in Section 4, the main fisheries present in the vicinity of the Niobe Exploration Well are scallop dredging, Nephrops and demersal otter trawling, and squid fishery. The most intensely fished and most valuable of these fisheries are the squid and scallop fisheries. The scallop fishery is targeted mainly by a ‘nomadic’ fleet of scallop vessels, >15 m in length, this fishery is the most prolific in the firth. The squid fishery is a seasonal fishery but in recent years has been growing in importance. Figure 4.12 in Section 4 illustrates the main fishing effort within the Moray Firth in relation to the proposed Niobe Exploration Well. Although there will be some small scale localised displacement of commercial fishing vessels during the proposed drilling operations, from the information presented in Section 4 it is clear that there are a multitude of fishing grounds for the key species targeted. For the most valuable species there are large areas of suitable scallop grounds within close proximity to the well location and in the wider Moray Firth. Due to the small scale footprint associated with the drilling rig’s 500 m safety exclusion zone (0.79 km2), it has been assessed that there will be no significant impact on the commercial fisheries. Navigational issues relating to commercial fishing are governed by the same mitigation measures that apply to commercial shipping (with the addition of a fisheries liaison
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officer, as appropriate). They are also governed by the operational controls to minimise the risk of impedance to fishing, which are discussed below.
7.4.2 Commercial shipping The Niobe Exploration Well is located in an area of very low shipping density (Section 4). The main vessels servicing the area are cargo vessels, fishing vessels, tankers and offshore service vessels. Suncor have undertaken a collision risk assessment for the exploration well location. This assessment estimates a collision frequency for a jack-up drilling rig at the Niobe well location to be 3.4 x 10-5, this corresponds to a collision return period of 30,000 years. This is below the historical average ship collision frequency for offshore installations on the UKCS, reflecting the relatively low traffic levels within 10 nm of the Niobe well (Anatec, 2014). The capacity of the proposed drilling activities to interact with commercial shipping would be relatively limited by applying the mitigation measures discussed in Section 7.7. These measures would enable commercial vessels to be aware of Suncor’s operations and thereby to navigate around the exploration well site. The closest route to the proposed well location, Route 1 with an average of 20 vessels per year, contributes the most to the overall collision frequency (Anatec, 2014).
7.4.3 Offshore renewable energy As described in Section 4, the Niobe Exploration Well is located within the MORL wind farm boundary, while the consented BOWL wind farm is located approximately 15 km west of the well. MORL have been undertaking various surveys to further define and support their licence conditions and these are anticipated to continue through 2015. Construction is not anticipated to commence until Q1 2016. Similarly, construction activities at the BOWL wind farm development are not anticipated to commence until 2016. The capacity of the proposed drilling activities to interact with the MORL and BOWL wind farms would be limited by applying the mitigation measures discussed in Section 7.7. These measures would enable the wind farm vessels to avoid Suncor’s operations.
7.4.4 Ministry of Defence (MoD) activities Section 4 identified that the Niobe Exploration Well is located within an area used by the Air Force Department (D712D) for high energy manoeuvers and air combat training at an altitude of 22,000 to 55,000 ft. The well is also located adjacent an Air Force Department area (D807) that was previously used for radar training, bombing and firing practice. This Air Force area has been withdrawn. Suncor will notify the MoD of the proposed activities, types of vessels and schedule, and will work with the MoD should they have any concerns regarding the drilling of the exploration well.
7.4.5 Marine archaeology and wrecks There were no known wrecks within the immediate vicinity of the proposed Niobe well location; however three wrecks lie within 5 km of the Niobe Exploration Well (SeaZone Wrecks, 2013). These are HMS Lynx (part of) (4.2 km SE), the Minsk (2.6 km E) and
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Charkow (4 km E). HMS Lynx is a designated vessel under The Protection of Military Remains Act 1986 (Designation of Vessels and Controlled Sites) Order 2002. Suncor does not anticipate the proposed drilling activities will impact site integrity of the designated HMS Lynx wreck, the Minsk or Charkow wrecks.
7.5 Cumulative and Transboundary Effects Cumulative impacts arising from the proposed drilling activities have the potential to act additively with existing and planned developments or other human activities. The Niobe Exploration Well will be located in an area for the development of wind farm (BOWL and MORL). Construction activities at the MORL wind farm are not expected until 2016, whereas various surveys will continue to occur through 2015. Suncor communicate on a regular basis with MORL and will work with the developer, where feasible, to minimise any disturbance to survey schedules. The proposed drilling activities are expected to be completed well in advance of any construction works commencing at the MORL wind farm. As a result, cumulative impacts with other users of the marine environment are not anticipated. These impacts would all be localised within UK coastal waters, so there will be no transboundary impacts. No global impacts are anticipated.
7.6 Consultee Concerns During the preparation of this draft ES, comprehensive consultations were undertaken with the statutory consultees regarding the drilling of the Niobe Exploration Well. The consultations conducted are summarised in Section 5. During the consultations, JNCC raised concerns regarding the cumulative impacts of wind farm activity (Section 7.5). DECC also raised concerns regarding the proximity of wind farms and commented on the necessity for the inclusion of broad coverage in the Notice to Mariners (Sections 4 and 7.7).
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7.7 Mitigation Measures The planned mitigation measures that Suncor will undertake to minimise any potential impacts are detailed in Table 7.1.
Table 7.1: Potential sources of impact and planned mitigation measures Potential source of impact Planned mitigation measure Interaction of drilling rig and associated Notification of drilling activities on the Kingfisher vessels with other users of the sea fortnightly bulletin. Notification of drilling activities to the HM Coastguard and UK Hydrographic Office. The drilling rig will be highly visible and have the appropriate navigational lighting and warning systems, alerting all vessels of its presence. A 500 m safety exclusion zones will be in place around the drilling rig. A standby vessel will be on location during the drilling period to warn other users to the presence of the drilling rig. A 24 hour lookout on the standby vessel (using visual observation, radar and AIS). The watch keeper will monitor all passing traffic within radar range and identify any vessels, which may present a threat to the drilling rig, and provide warnings, as required, to allow appropriate actions to be taken to avoid any incidents. Suncor will continue to dialog with offshore wind farm developers.
7.8 Conclusions From the assessment of potential impacts the following conclusions can be made. There will be some small scale localised displacement (0.79 km2) of fishing effort, primarily scallop dredges and the seasonal squid fisheries. These fisheries, however, have other suitable and productive grounds in close proximity, which could be utilised during the short duration of the drilling activities. Once the drilling operations have been completed, the well will be plugged and abandoned. The drilling rig and associated vessels will depart from the well location, leaving no permanent physical presence or obstruction on the seabed or sea surface. Drilling activities will be completed several months before any construction work is anticipated to commence at the MORL wind farm development.
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8.0 LOCALISED DISTURBANCE TO THE SEABED ARISING FROM THE DRILLING AND INSTALLATION ACTIVITIES This section discusses the localised disturbance to the seabed associated with the drilling of the Niobe Exploration Well. Potential impacts to the seabed from drilling discharges are discussed in Section 10, Discharges to Sea. This section also describes the measures taken or planned by Suncor to minimise disturbance to the seabed and the associated environmental receptors.
8.1 Regulatory Context Any physical disturbance arising as a result of the proposed drilling operations will be managed according to, but not limited to, the following legislation: Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (as amended) govern the protection of habitats and species (under the European Habitats and Wild Birds Directives) in relation to oil and gas activities, such as the drilling of the Niobe Exploration Well, are implemented in all UK waters. The Offshore Marine Conservation (Natural Habitats &c.) Regulations 2007 (as amended 2010) implement the Birds Directive and Habitats Directive in relation to UK marine areas beyond the territorial sea. These Regulations make provision for the selection, registration and notification of European Offshore Marine Sites in the offshore marine area and for the management of these sites. Marine & Coastal Access Act 2009 and the Marine (Scotland) Act 2010 Suncor need to ensure protection for the marine environment and biodiversity in relation to a number of activities associated with the Niobe Exploration Well, such as the removal of materials from the seabed, and disturbance of the seabed. Environmental Liability European Directive (2004/35/EC) 2009 and the Environmental Liability (Scotland) Regulations Directive 2009, Suncor have liability for the prevention and remediation of environmental damage to ‘biodiversity’, water and land from specified activities and remediation of environmental damage for all other activities through fault or negligence. Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
8.2 Basis for Assessment In order to assess and quantify the physical impacts arising from the placement of structures on the seabed, assumptions have been made and are presented in the following sections regarding the activities associated with the placement of the jack-up drilling rig on the seabed.
8.3 Sources of Potential Impact In order to encompass a maximum disturbance to the seabed, a worst case scenario is considered when there is uncertainty in the method(s) to be used. At this stage, it is not known which specific mobile drilling facilities will be used at Niobe. Suncor anticipate the selected jack-up drilling rig will be positioned over the well location by three separate legs. The jack-up legs are supported on the seabed by three separate spud cans. Typically, spud cans have a maximum diameter of 50 feet (15 m) (Hartley Anderson Ltd., 2001).
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The jack-up rig legs will be positioned around the central drilling location by placing the three spud cans on the seabed. The placement of the three spud cans may result in a total seabed footprint of 0.00053 km2 (an area of 0.00018 km2 per spud can) (Table 8.1). This impact would be confined to the area of seabed within the perimeter of the jack-up’s legs.
Table 8.1: Seabed footprint from the placement of the jack-up drilling rig at the Niobe Exploration Well site Activity Area Calculation Footprint area (km2) Jack-up placement on the seabed (3 spud cans) (0.015 km / 2)2 x 3.14 x 3 0.00053 Total area of seabed disturbance from the jack-up drilling rig 0.00053
The jack-up drilling rig will remain on site only for the duration of the pre-drilling programme (45 days). Thereafter, the drilling rig will be demobilised and removed from its offshore location. The removal of the spud cans when the three legs of the rig are jacked-up will re-suspend the underlying sediments into the immediate water column. The drill cutting pile created from the pre-drilling activities (i.e. drilling the top hole section of the well) will result in a localised ‘doughnut’ shaped mound of cuttings which is expected to be contained within the limits of the drilling rig legs. Therefore, the removal of the three spuds is not expected to disturb the drill cuttings pile.
8.4 Impact on Sensitive Receptors The potential impacts associated with the seabed disturbance can be grouped as follows: impacts to the benthic environment; impacts to the fish and shellfish; and. impacts to protected habitats and species. Potential impacts for these groups are discussed below, and impacts to fisheries and other users of the sea from the presence of the drilling rig are discussed in Section 7.
8.4.1 Impacts to the benthic environment Placement of the jack-up drilling rig will cause direct impacts to species living on and in the sediments as a result of physical disturbance to the sediments. The estimated total area of seabed impact is approximately 0.00053 km2 (Table 8.1). Subsea installation operations could also result in indirect impacts through disturbance or re-suspension of any contaminants on the seabed or buried beneath the surface sediments. Sediments that are re-suspended will drift with seabed currents before settling out over adjacent areas of seabed. These re-suspended sediments could have a minor impact on the local benthic community, resulting from some localised smothering. It is expected that sediment disturbance will be similar in effect to the natural process of sediment transport caused by currents and wave action. In the Moray Firth the currents are very weak (Section 4) and, therefore, it is expected that the re-suspended sediments will settle quickly in close proximity to the source of disturbance. Analysis of sediment samples from the adjacent MORL site indicated that hydrocarbon or heavy metal concentrations across the development area are well below the reported
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background concentrations found in the northern North Sea, therefore no indirect impacts from chemical contaminants are expected to arise as a result of the re- suspension of sediments caused by the proposed drilling (Section 4). The benthic community in the area can be expected to comprise communities typical of that area of the North Sea and coastal areas. Samples collected as part of the habitat assessment and environmental baseline survey for this project (Gardline, 2014) indicates the following benthic habitats and community may be present at the Niobe Exploration Well location (Section 4): medium sand with shell fragments and occasional whole shells; and fauna, although sparse, is typically characterised by polychaetes (Hyalinoecia tubicola), Arthropoda (Ebalia sp, Amphipoda), Cnidaria (Hydrozoa), Echinodermata (Ophiuroidea), Foramnifera (Astorhiza sp.) and Mollusca (Buccinum undatum, scaphopoda, bivalvia including siphons possibly belonging to A. islandica). The geophysical survey and habitat assessment show no indication of any habitat listed under Annex I of the Habitats Directive (1992), as implemented by the Offshore Marine Conservation (Natural Habitat, &c.) Regulation (2007(as amended)). Nor were there any species or habitats present that were listed on the Scottish Biodiversity List (2013). Siphons potentially belonging to the ocean quahog Arctica islandica were observed across the survey area. However no specimens were collected in the sediment grabs. This species is listed on the OSPAR list of threatened or declining species (2008) and is also listed by the Scottish Government as a priority marine feature which warrants protection. Once the subsea operations are completed, both disturbed and resettled sediment will be recolonised by benthic fauna typical of the area. This will occur as a result of natural settlement by larvae and plankton and through the migration of animals from adjacent undisturbed benthic communities (Dernie, et al., 2003). In areas of soft sediments, such as those at the Niobe site, the soft bottom fauna may be expected to recolonise within a year or two (OSPAR, 2009).
8.4.2 Impact to fish and shellfish Drilling activities are scheduled to occur over a 45 day period within Q2 and Q3 (April to September) 2015. Therefore, they have the potential to coincide with the spawning periods for cod, lemon sole, Nephrops, sprat and whiting (Coull, et al., 1998; Ellis, et al., 2010; Ellis, et al., 2012) (Section 4). Pelagic spawning species including cod, lemon sole, sprat and whiting, release their eggs into the water column, and therefore are unlikely to be affected by disturbance to the seabed. Nephrops are the only demersal species found at the Niobe Exploration Well site during the proposed drilling period. Nephrops are demersal living shellfish, with restricted and particular habitat preferences confined to fine grained muddy sands (Holland et al., 2008). Seabed sediments predominantly comprise shelly sand, confirmed by client acquired geophysical and environmental habitats data. Areas of shelly sand with poorly defined gravel and cobbles are observed across the survey area (Gardline, 2014). Due to the sediments present and the small scale of disturbance likely to be caused by the siting/ removal of the spud cans, there is unlikely to be any significant impact to fish or shellfish from the proposed activities.
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Although, the drilling operations may cause temporary and localised disturbance to the seabed spawning species, fish are likely to return to the area once the drilling operations have ceased.
8.4.3 Impacts to protected habitats and species The closest area of protection to the Niobe Exploration Well is the East Caithness Cliffs MPA/ SAC/ SPA, which is located 35 km west of the proposed well site. The protected area extends 2 km from the Caithness coast from Helmsdale and Wick, conserving the black guillemots and their adjacent feeding grounds. Given the localised, temporary nature of impacts associated with the placement of the drilling rig on the seabed, it is unlikely that there will be any impacts to protected habitats or species.
8.5 Cumulative and Transboundary Impacts Installing the jack-up drilling rig would result in a small area of localised physical disturbance of the seabed sediments and associated fauna directly below the subsea structures, however these are short term and the seabed would be expected to recover. The proposed drilling activities are expected to be completed well in advance of any construction works commencing at the MORL wind farm. As a result, cumulative impacts with other users of the marine environment are not anticipated. These impacts would all be localised within UK coastal waters, so there will be no transboundary impacts. No global impacts are anticipated.
8.6 Consultee Concerns During the consultations in preparation of this draft ES, JNCC raised concerns regarding the cumulative impacts of wind farm activity (Section 7.6). DECC also raised concerns regarding the proximity of wind farms and commented on the necessity for the inclusion of information on sensitive habitats and species and information on seabed habitats (Sections 4 and 8.4).
8.7 Mitigation Measures The planned mitigation measures that Suncor will undertake to minimise the impact of the drilling activities are detailed in Table 8.2.
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Niobe Exploration Well Environmental Statement W/4171/2014
Table 8.2: Potential sources of impact and planned mitigation measures Potential source of impact Planned mitigation measure Installation of the drilling rig on the seabed. Suncor have recently undertaken seabed surveys to inform their knowledge of the nature of the seabed at the well location and to identify seabed areas that may not be suitable for the drilling rig. The installation of the jack-up drilling rig will be a temporary activity, with the drilling rig only remaining in position on the seabed for a period of 45 days. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL wind farm in 2016.
8.8 Conclusions Residual impacts are defined as impacts that could potentially remain after mitigation measures have been adopted as a part of the project. No residual impacts are expected to arise from the installation activities associated with the drilling of the Niobe Exploration Well. During the initial installation phase, re-suspended sediment material is expected to rise in the water column during the placement of the jack-up drilling rig, and the removal of the jack-up rig after 45 days. Disturbed sediments are expected to settle relatively quickly and in proximity to the areas disturbed and benthic species are likely to recolonise disturbed areas in a relatively short time. No significant contamination of the sediments has been recorded in the vicinity of the well location (MORL, 2012a; MORL, 2012d) during the baseline surveys and therefore a lateral spread of contaminants in the wider area is unlikely (Section 4.2.4).
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Niobe Exploration Well Environmental Statement W/4171/2014
9.0 ATMOSPHERIC EMISSIONS Atmospheric emissions as a result of fuel combustion on board the jack-up drilling rig, associated support vessels and helicopters were identified as a potential impact to the environment during the risk assessment. Atmospheric emissions generated by offshore operations are primarily associated with combustion for power generation, flaring of hydrocarbons and, to a lesser extent, venting of gases during tank loading and incidental releases from firefighting and refrigeration equipment. The main exhaust gases that will be emitted during the proposed drilling operations are carbon dioxide (CO2), together with small quantities of carbon monoxide
(CO), oxides of nitrogen (NOX) and sulphur (SOX), and trace quantities of volatile organic compounds (VOCs), nitrous oxide (N2O) and methane (CH4). The emissions involved are implicated in atmospheric pollution on both local and global scales. This section quantifies the atmospheric emissions that will arise from the sources identified and provides an estimate of emissions during the drilling activities for the Niobe well. It also describes the measures that will be put in place to minimise emissions.
9.1 Regulatory Context Gaseous emissions generated as a result of the proposed drilling operations will be managed in accordance with current legislation and standards, as summarised below. Under the Merchant Shipping (Prevent of Air Pollution from Ships) Regulations 2008 (as amended), all vessels, including the drilling rig will require an International Air Pollution Certificate. In addition, the 2010 amendments to these regulations specify the maximum sulphur content for marine fuel. The reporting and maintenance requirements, including leak detection, specified by the Environmental Protection (Controls on Ozone Depleting Substances) Regulations 2002 (as amended) and the Fluorinated Greenhouse Gases Regulations 2009 must be adhered to for all refrigeration, heat pumps, air conditioning and fire protection systems. Though not directly linked to UK legislation the Environmental Emissions Monitoring System (EEMS) database was established by UKOOA in 1992 to provide a more efficient way of collecting data on behalf of the UK oil and gas industry. Atmospheric data from the EEMS system is reported on an annual basis and can be used to show trends in UK offshore oil and gas activity greenhouse gas emissions. Suncor will report atmospheric emissions through this system following completion of the drilling program. Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
9.2 Basis for Assessment The approach used in this section has been to provide a worst case assessment of emissions that could potentially arise from the proposed drilling activities. These worst case emissions are compared against atmospherics emissions from all oil and gas activities on the UKCS, in order to provide an evaluation of the scale of the proposed drilling emissions.
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Niobe Exploration Well Environmental Statement W/4171/2014
The methodology estimates atmospheric emissions from vessel operations on the basis of the numbers and types of vessels, the duration and type of operations, the average daily consumption of fuel based on vessel type, and published conversion factors for the unit amounts of various gases emitted when fuel is burnt (EEMS, 2008; UKOOA, 2002; IoP, 2000). Emissions from flaring of production fluids are estimated on the basis of the total masses of gas and oil burnt and published factors for the combustion of those fluids. The gases produced from the planned drilling operations are known to have the potential to contribute to a number of environmental processes and impacts including global warming (greenhouse gases), acidification (acid rain), the formation of low level ozone, and local air pollution. The most commonly used general indicator of atmospheric emissions is the global warming potential (GWP), expressed in tonnes of CO2 equivalents. GWP is a measure of the radiative effect of a given gas relative to that of CO2, integrated over a chosen time horizon (often a 100-year time period). Simply stated, the GWP of a specific gas is a measure of its climate change impact relative to CO2 (AEA, 2007). All gaseous substances that contribute towards global warming (for example, CO2, CH4, N2O, CO, and NOx) have a GWP factor that allows the conversion of individual emissions into CO2 equivalents. As such, GWP can be used to estimate the potential future impacts of gaseous emissions upon the climate system. The GWP factor of each of the most common combustion gases is given in Table 9.1. Greenhouse gases (GHG) can be divided into direct and indirect greenhouse gases. Direct greenhouse gases have an effect on the balance of energy entering and exiting the atmosphere (radiative forcing) and include combustion gases such as CO2, CH4 and
N2O, as well as naturally occurring gases such as tropospheric ozone (O3). Reactive gases, such as carbon monoxide (CO), VOCs, nitrogen oxides (NO and NO2) and SO2, are termed indirect greenhouse gases. These pollutants are not significant as direct greenhouse gases but, through atmospheric chemistry, they impact upon the abundance of the direct greenhouse gases thereby increasing the overall greenhouse effect. The environmental effects of the most common combustion gases are summarised in Table 9.1.
9.3 Sources of Potential Impact Several activities associated with the drilling operations will release gases to the atmosphere, which have the potential to affect air quality at a local level and contribute to global greenhouse gas emissions. The consumption of diesel fuel by the vessels and the jack-up drilling rig during the drilling activities, and aviation fuel by helicopters used for transport of personnel and materials were assessed in the risk assessment (Section 6) as sources of atmospheric emissions.
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Niobe Exploration Well Environmental Statement W/4171/2014
Table 9.1: Environmental effects of atmospheric emissions 100-year Gaseous emission Environmental effect GWP factor* Direct greenhouse gases
CO2 is a greenhouse gas, meaning that it inhibits the Carbon dioxide (CO2) radiation of heat into space, which may increase 1 temperatures at the Earth’s surface.
Methane (CH4) May contribute to climate change. 23
Nitrous oxide (N2O) May contribute to climate change. 296 Indirect greenhouse gases Direct effects upon human health (asphyxiate). May Carbon monoxide (CO) 3 contribute indirectly to climate change.
NO2 has direct effects upon human health and vegetation - causes respiratory illness and irritation of the mucous membranes. NOx acts as a precursor to low-level ozone Oxides of nitrogen (NO ) 5** x formation. It also contributes to acid deposition (wet and dry) which can impact freshwater and terrestrial ecosystems. Volatile organic compounds (VOCs), which include non- methane hydrocarbons (NMHC) and oxygenated NMHC (alcohols, aldehydes and organic acids), have short atmospheric lifetimes (fractions of a day to months) and small direct impact on radiative forcing. VOCs influence Volatile organic climate through their production of organic aerosols and n/a compounds (VOC) their involvement in photochemistry — production of ozone (O3) in the presence of NOx and light. Generally, fossil VOC sources have already been accounted for as release of fossil C in the CO2 budgets and therefore are not counted as a source of CO2.
SO2 has direct health effects - causes respiratory illness. It Sulphur dioxide (SO2) also contributes to acid deposition (wet and dry), which can n/a impact freshwater and terrestrial ecosystems. Other The environmental effect of particulate matter is mainly determined by the size (and shape) of the particles. Particles emitted from modern diesel engines (commonly referred to as Diesel Particulate Matter, or DPM) are Particulate matter (PM) typically in the size range of 100 nanometers (0.1 n/a micrometer) and can penetrate the deepest part of the lungs. In addition, these soot particles also carry carcinogenic components. In high concentrations particulate matter can also affect plant growth. *GWPs are from IPCC (2001) and refer to the 100 year horizon values. **The GWP factor of 5 is for surface emissions. Higher altitude emissions (from aircraft) have greater impacts both because of longer NOx residence times and more efficient tropospheric O3 production, as well as enhanced radiative forcing sensitivity. NOx emissions from aircraft can therefore have GWPs in the order of 450 for considering a 100-year time horizon. It must be noted however that these numerical values are subject to large quantitative uncertainties.
Appendix C presents the detailed results of the emissions calculations. Table 9.2 provides a summary of the estimated gaseous emissions from the support vessels, the drilling rig and helicopters to be used for the Niobe Exploration Well drilling operations. The atmospheric emissions generated from the drilling operations are estimated to generate approximately 4,490 tonnes CO2 per annum (Table 9.2).
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All exploration and production operations on the UKCS in 2010 (including drilling, production, flaring and well testing) along with all offshore shipping activities generated a total of 16,393,119 tonnes of CO2 (Table 9.2). Compared to this value, the potential CO2 emissions generated from the Niobe drilling operations will account for 0.03%, a minor proportion of the overall annual offshore emissions for the UK.
Table 9.2: Summary of estimated gaseous emissions from support vessels, drilling rig and helicopters during the drilling operations Emissions (tonnes) Activity CO2 CO NOx N2O SO2 CH4 VOC Total emissions from drilling operations 4,440.00 11.10 81.86 0.31 5.55 0.37 3.33 Total emissions from helicopter flights 50.21 0.08 0.20 0.00 0.06 0.00 0.01 Total vessel emissions from the drilling operations 4,490.21 11.18 82.06 0.31 5.61 0.38 3.34 Emissions from UKCS Offshore Exploration and Production Activities* Total emissions from UKCS offshore exploration and 16,393,119 24,649 55,837 1,006 2,628 50,476 54,050 production during 2010* Total vessel emissions from the drilling operations as a percentage of 2010 UKCS 0.03 0.05 0.15 0.03 0.21 0.00 0.01 emissions from offshore oil and gas activities Notes: *Total emissions for offshore activities includes emissions arising from: diesel, gas and fuel oil consumption, flaring, venting, direct process emissions, oil loading and fugitive emissions. This includes emissions from production and mobile drilling rigs. The data does not include emissions produced by support vessels or helicopters. Source: Oil and Gas UK (2012)
9.4 Impact on Sensitive Receptors The gases produced from the drilling operations are known to have the potential to contribute to a number of environmental processes and impacts including global warming (greenhouse gases), acidification (acid rain), the formation of low level ozone and local air pollution.
9.4.1 Localised impacts Combustion emissions have the potential to reduce local air quality through the introduction of contaminants such as NOX, VOCs and particulates which contribute to the formation of local low level ozone and photochemical smog. However, seafaring vessels, such as ships and mobile drilling units, are built and operate to standards and procedures that minimise the exposure risks to crews. Environmental receptors could potentially be in the vicinity of the operations, but tend to be sparsely distributed and/ or mobile in their distribution, for example, marine mammals and seabirds. Local impacts are further mitigated by the open and dispersive nature of the offshore environment. Any impacts at this level would therefore be difficult to measure and distinguish from background variation. On this basis, localised impacts from combustion emissions during the proposed drilling operations will likely be negligible.
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9.4.2 Wide scale impacts It is acknowledged that on a larger scale, emissions derived from the fossil fuel combustion at the well location may contribute to cumulative worldwide environmental impacts such as global climate change, but the individual impact will be impossible to assess as these emissions will only form a very small part of the overall global air emissions. The estimated atmospheric emissions associated with the Niobe Exploration Well are, therefore, only provided here to allow for generic comparison with typical values of emissions for the UK exploration and production industry and overall national emissions. All UK operators report atmospheric emissions from exploration activities and production installations to the EEMS on an annual basis. The EEMS dataset does not include emissions from supporting vessels such as the standby vessel, which are associated with the Niobe Exploration Well. Greenhouse gas emissions from all industrial processes, energy production, agriculture, and others, are collated into emissions inventories for each UK member state on behalf of DEFRA, in accordance with the UN Framework Convention on Climate Change (AEA, 2007). The most recent, available version of this inventory covers the period 1990 to 2007. In this inventory, emissions from offshore sources are not allocated to any country, and are reported separately within an unallocated inventory category. Statistics for shipping, the other major source of offshore emissions, are reported separately in DEFRA’s UK Ships Emissions Inventory (Entec, 2010). In combination, these data sources provide an indication of total UK annual offshore emissions and UK emissions in general, against which the drilling operations can be compared. All exploration and production operations on the UKCS in 2010 (including drilling, production, flaring, and well testing) along with all offshore shipping activities generated a total GWP of 18,204,975 tonnes CO2 equivalents (Table 9.3). As stated previously, drilling operations at Niobe are estimated to generate approximately 4,490 tonnes CO2, which accounts for 0.03% of the overall annual offshore emissions for the UK (Table 9.2). In this wider context, the potential atmospheric emissions generated during the drilling of the Niobe Exploration Well are not considered to be significant.
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Table 9.3: Summary of estimated GWP emissions from support vessels, drilling rig and helicopters during the drilling operations GWP emissions (tonnes)* Activity CO2 CO NOx N2O SO2 CH4 VOC Total GWP Total GWP emissions from 4,440.00 33.30 409.30 91.76 - 8.51 - 4,982.87 drilling operations Total GWP emissions from 50.21 0.24 1.00 0.00 - 0.00 - 51.45 helicopter flights Total GWP vessel emissions 4,490.21 33.54 410.30 91.76 - 8.51 - 5,034.32 from the drilling operations Emissions from UKCS Offshore Exploration and Production Activities Total GWP emissions from UKCS offshore 16,393,119 73,947 279,185 297,776 - 1,160,948 - 18,204,975 exploration and production during 2010 Total GWP vessel emissions at the drilling operations as a percentag 0.03 0.05 0.15 0.03 - 0.00 - 0.03 e of 2010 UKCS emissions from offshore oil and gas activities Notes: * GWP is a relative measure of how much heat a greenhouse gas traps in the atmosphere. It compares the amount of heat trapped by a certain mass of the gas in question to the amount of heat trapped by a similar mass of carbon dioxide. A GWP is calculated over a specific time interval, commonly 20, 100 or 500 years. GWP is expressed as a factor of CO2 (whose GWP is standardised to 1). For example, the 20 year GWP of methane is 72, which means that if the same mass of methane and CO2 were introduced into the atmosphere, that methane will trap 72 times more heat than the CO2 over the next 20 years. Source: Oil and Gas UK (2012)
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9.5 Cumulative and Transboundary Impacts The assessment of the impacts of atmospheric emissions, as discussed above, is unchanged by the consideration of other emission sources local to the Niobe Exploration Well drilling operations. Emissions from the drilling operations will have the potential to combine with those from local shipping, existing wind farm activities or existing oil and gas infrastructure in the region. Construction activities at the MORL wind farm are not expected until 2016, whereas various surveys will continue to occur through 2015. The proposed drilling activities are expected to be completed well in advance of any construction works commencing at the MORL wind farm. Cumulative impacts with these and other activities in the marine environment are not anticipated. As indicated in Section 9.4.2, on a wider scale, the additive contribution to the emissions of the overall UK oil and gas industry from the proposed operations can be viewed as of low significance and, therefore, its cumulative effect is also expected to be minimal. It would be impossible, however, to assess the cumulative impact of atmospheric emissions from the proposed operations in relation to potential global environmental impacts, such as global climate change. Local wind conditions may result in the transboundary transport of atmospheric emissions generated from the Niobe Exploration Well drilling operations. However, as the quantities involved are minimal in relation to national scale emissions and of a relative short duration, the resulting incremental effects of transboundary emissions on other nations’ total emissions levels are not expected to be detectable.
9.6 Consultee Concerns During the consultation process (Section 5) Suncor were advised, by DECC and the JNCC, to include any information regarding a well test within the ES and include details on potential impacts, mitigation and residual impact with the ES. Suncor do not plan to undertake a well test as part of the drilling programme for the Niobe Exploration Well. DECC and the JNCC also requested that Suncor include cumulative impacts, where the schedule of the wind farms and the drilling operations coincide (Section 5).
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9.7 Mitigation Measures The planned mitigation measures that Suncor will undertake to minimise the impact of atmospheric emissions arising from the Niobe Exploration Well are detailed in Table 9.4.
Table 9.4: Potential sources of impact and planned mitigation measures Potential source of impact Planned mitigation measure Consumption of fuel (diesel and aviation) by Fuel consumption will be minimised by operational the support vessels, jack-up drilling rig and practices and power management systems for helicopters engines, generators and other combustion plant and maintenance systems. Vessels will use ultra-low sulphur fuel in line with MARPOL requirements. Work programmes will be planned to optimise rig and vessel time in the field. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL development wind farm in 2016.
9.8 Conclusions From the emissions quantification and impact assessment conducted here, the following conclusions are made: Emissions from the Niobe Exploration Well will have only a localised effect on air quality. The impact on air quality is unlikely to affect any receptors in the project area as the impact is expected to be limited to the immediate vicinity of the operations. Emissions from the Niobe Exploration Well will be a relatively small-scale, short-term contributor to global greenhouse gas emissions. In this wider context, the atmospheric emissions generated during the drilling of the Niobe Exploration Well are not considered to be significant.
BMT Cordah Limited 9-8 November 2014
Niobe Exploration Well Environmental Statement W/4171/2014
10.0 DISCHARGES TO SEA Drilling operations at the Niobe location may generate environmental impacts arising from the discharge of WBM cuttings and cement to the marine environment. Oil contaminated cuttings will be taken to shore for processing. Once onshore, the drill cuttings will be treated to remove residual oil to very low levels before being transported to a licensed landfill disposal site. This section also describes the measures taken or planned by Suncor to minimise the impact of the drilling discharges to sea on the environmental receptors.
10.1 Regulatory Context Discharges to sea that arise from the installation, commissioning and production operations will be managed in accordance with current legislation and standards. The main regulatory requirement is summarised below and Appendix A provides further detail. Under the Offshore Chemicals Regulations 2002 (as amended), which implements the OSPAR Decision (2000/2) and OSPAR Recommendations (2000/4 and 2000/5), Suncor are required to apply for permits and submit relevant applications for all planned and potential discharges of chemicals during the Niobe drilling programme. Suncor will submit the relevant applications to DECC through the Portal Environmental Tracking System (PETS). Chemicals will only be used in accordance with the corresponding chemical use and discharge permit. Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
10.2 Basis of Assessment In order to assess and quantify the impacts arising from the discharge of cement, WBM and cuttings to the marine environment, assumptions have been made and are presented in the following sections.
10.3 Sources of Potential Impact There are two general sources of drilling discharges to sea from the proposed drilling operation: discharge of seawater/ water based muds and cuttings directly to the seabed; and cement discharges from the wells.
10.3.1 Muds and cuttings As detailed in Section 3 (Table 10.1) approximately 135 tonnes of seawater/ GEL sweep cuttings will be discharged directly onto the seabed from the 36” top-hole section, while 262 tonnes of WBM cuttings will be discharged to the marine environment from the 17½” section. Ithaca Energy (UK) Ltd have undertaken cuttings dispersion modelling for several wells they have drilled in blocks adjacent to the proposed Niobe Exploration Well (Blocks 21/21 and 21/26) (Table 10.1; Ithaca, 2006; 2007 and 2008).
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The drilling discharges that were modelled for these three wells are slightly higher than estimates for the proposed Niobe Exploration Well (Table 10.1). However, the modelled results provide an indication of the expected fate and potential outcome of the drilling discharges from the Niobe Exploration Well in Block 12/27.
Table 10.1: Summary of the Niobe and Ithaca well drilling discharges Mud and cuttings(tonnes) per section Total WBM Block Well discharge to sea 36” 17½” 12¼” 8½” (tonnes) 12/27 Niobe Exploration 135* 262** 189*** 36*** 262 12/21c Jacky Development 128* 325** 252*** none 325 12/26 Ithaca Exploration 125* 338** 312*** none 338 12/21c Ithaca Appraisal 128* 325** 252*** none 325 Note: *Seawater/ GEL sweeps discharged directly to the seabed. **WBM cuttings discharged to sea from drilling rig/ platform. ***LTOBM cuttings. Skipped and shipped for onshore disposal.
The modelling was undertaken using the BenOss particle tracing model, originally developed to simulate carbon deposition from sewage discharges, but applicable for the dispersion of particulate material in the coastal waters of the Outer Moray Firth (Ithaca, 2006; 2007 and 2008). Each model used a 20 by 20 km bathymetric grid produced from GEBCO data and one dimensional current velocity from Admiralty tide tables. Cuttings dispersion modelling was undertaken by Ithaca for the section (17½”), where the cuttings were to be discharged to sea from the drilling rig/platform. The modelled volume of WBM and cuttings that were to be discharged by this means at each of the Ithaca wells ranged from 252 to 312 tonnes (Table 10.1). Modelling was not required for the other sections. Cuttings from the 36” tophole section were to be discharged directly to the seabed, while the cuttings from the 12¼” section were to be skipped and shipped for onshore disposal. All primary and contingency drilling mud chemicals to be used, and potentially discharged, will be detailed in the respective permit application which will be submitted to DECC for approval prior to the commencement of drilling, in accordance with the Offshore Chemicals Regulations 2002 (as amended).
10.3.2 Cement Cement and cementing chemicals will be used during the drilling operations. The exact chemical constituents required to formulate the cement will be confirmed during the final stages of well design. The majority of the cement will be left downhole but a minimal quantity may be discharged onto the seabed around the top of the casing. The chemicals used will be contained within inert cement. Careful estimates of the final volume of the hole will be made during drilling and the volume of cement used will be adjusted accordingly to minimise the risk of excess cement being squeezed out of the hole onto the seabed. Excess dry cement will be shipped back to shore.
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10.4 Impact on Sensitive Receptors Impacts associated with discharges potentially generated by drilling operations vary depending on several factors, including the masses, particle sizes and chemical compositions of the muds and cuttings in the discharged material. The main environmental impacts that could arise from the discharge of the WBM and cuttings are: the possible creation of a localised cuttings mound, which would result in the smothering of benthic fauna and habitats, nursery or spawning ground for fish or shellfish; and the release of drilling and cementing chemicals to the water column, which could be hazardous to organisms within the near field marine environment. In general, effects of mud and cuttings discharges on the benthic environment are related to the total mass of drilling solids discharged and the relative energy of the water column and benthic boundary layer at the discharge site (Neff, 2005). In high energy environments, little drilling waste accumulates on the sea floor and adverse effects of the discharges cannot be detected. However, in low energy environments, such as at the Moray Firth (Section 4), mud and cuttings solids may accumulate on the seafloor and may adversely affect bottom communities within a few hundred metres of the discharge (Neff, 2005). WBM and cuttings have a fine particle size distribution and are known to have slow settling velocities. The modelling studies predicted that for the WBM and cuttings discharged to sea, a large proportion of the discharged material was predicted to be located within distances of 5 km ENE and WSW of each well location (Ithaca, 2006; 2007 and 2008). These results were found to be consistent with residual current velocity (0.009 m/s) and median settling velocity (~10-4 m/s) for the area (Ithaca, 2006; 2007 and 2008). Predicted peak settling rates (43.5 to 91.7 g/m2) for each study were found to be comparable to natural erosion/ deposition rates recorded in the coastal North Sea (20 to 200 g/m2/year) (Ithaca, 2006; 2007 and 2008). These were considered unlikely to have significant ecological effects through smothering or physical disturbance. Drilling mud comprises a base fluid, viscosifiers, dispersants, flocculants, emulsifiers, surfactants, foaming and weighting agents and contingency chemicals to make it as efficient and safe as possible to drill a well under the given conditions. The effects of WBM that do not contain petroleum-derived base fluids are well documented (Daan and Mulder, 1996; Davies et al., 1983; Ferm, 1996; Kroncke et al., 1992; Olsgard et al,.1997; Plante-Cuny et al., 1993) and the impacts of these discharges on the marine environment would be expected to be minimal and of short duration (Neff, 2005). The exact formulation of the drilling chemicals has not yet been determined, but all primary and contingency drilling mud chemicals, to be used and potentially discharged during the drilling phase of the well, would be detailed and subjected to a risk assessment in the chemical permit application that will be submitted to DECC for approval before drilling commences. Discharge of cement slurry into the sea has the potential to cause localised alteration of the sediment structure and smothering of seabed organisms in the immediate area.
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Neither deterioration in water quality nor any significant impact on benthos or fish is expected from the release of cement during drilling.
10.4.1 Water column communities Water column communities are unlikely to be harmed by WBM and cuttings discharges, because discharges are intermittent and of short duration during the drilling operations and are subject to dispersion. Dilution of dissolved and particulate components in the discharge is also rapid (Neff, 2005). Where solids accumulate in a cuttings pile, direct deposition of mud and cuttings may cause chronic ecological change to a small area of the seafloor. This response is believed to most likely be a result of the burial of benthic fauna and/ or an adverse change in sediment composition and texture (Neff, 2005).
10.4.2 Benthic communities The effect of discharging WBM cuttings directly to the seabed will be to smother a localised area of bottom sediments and its associated fauna, and to potentially release of pollutants, such as organic chemicals and heavy metals into the sediments and the water column. The discharged materials may cause mortality to some benthic organisms by creating an area of altered habitat resulting from the temporary covering of the seabed sediments (Neff, 2005). Hypoxia caused by organic enrichment from WBM cuttings piles can also affect benthic communities (Neff, 2005). Bacteria and fungi living in marine sediments degrade organic matter, which leads to oxygen depletion in near-surface sediment pore waters. Potentially toxic concentrations of hydrogen sulphide and ammonia can be generated (Wang and Chapman, 1999; Gray et al., 2002; Wu, 2002), particularly at the start of, and immediately after, drilling activities. Ecological recovery of the benthos occurs by recruitment of new colonists from planktonic larvae and by immigration from adjacent undisturbed sediments. Recovery begins as soon as the discharge of drilling wastes is completed and is often well advanced within a year; however, it may be delayed until concentrations of biodegradable organic matter decrease through microbial biodegradation to the point where surface layers of sediment become oxygenated (Hartley et al., 2003; Neff, 2005).
10.4.3 Impact to fish and shellfish Fish disturbed by drilling operations are likely to return to the area once drilling operations have ceased. However, there may be localised disturbance to seabed spawning species. Cod, lemon sole, Nephrops, sprat and whiting are known to spawn at the well location during the proposed drilling period (Section 4). Nephrops are the only demersal spawning species likely to spawn at the Niobe Exploration Well site during the proposed drilling period. Nephrops are demersal living shellfish. These species have restricted and particular habitat preferences confined to fine grained muddy sands (Holland et al., 2008). Sediment at the Niobe Exploration Well is expected to be comprised of shelly sand. Areas of shelly sand and poorly defined gravel and cobbles are observed across the area (Gardline, 2014). These species could potentially be at more risk from activities that disturb the seabed as a result of the proposed drilling activities. However, due to the localised spread of the cuttings, it is unlikely that there will be a noticeable impact on the Nephrops population from the discharge of the WBM and cuttings.
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Cod, lemon sole, sprat and whiting are less susceptible to discharges of mud and cuttings, as they release their eggs into the water column. These species have a widespread distribution over the central North Sea (Section 4). Hence the spawning populations of fish species are unlikely to be at risk from discharges of mud and cuttings from the Niobe Exploration Well.
10.4.4 Protected habitats and species The closest conservation area of to the Niobe Well is the East Caithness Cliffs MPA/ SAC/ SPA, which is located 35 km west of the well and extends 2 km from the Caithness coast between Helmsdale and Wick. Given the localised, temporary nature of impacts associated with the discharge of the WBM and cuttings, it is very unlikely that there will be any impacts to protected habitats or species.
10.5 Cumulative and Transboundary Impacts Sediment movement, action of burrowing organisms and the effects of currents would cause the cuttings, particularly the finer fractions, to migrate over time and the chemicals associated with the cuttings to gradually disperse. It is unlikely that this effect will be distinguishable from the overall background movements of sediment. Coarser material is likely to remain closer to the wells. The chemicals within the mud and cuttings would gradually be incorporated within the sediments and result in a small, and for some chemicals, a temporary addition to the background chemical levels of the North Sea. The discharge of WBM and cuttings from the well would cause a localised smothering of the natural seabed sediments and associated benthic communities. The smothering effects are anticipated to be confined to a relatively small area around the release site, and the main drill cuttings pile is not likely to extend beyond 5 km in an ENE to WSW orientation (Ithaca, 2006; 2007 and 2008). Though the area has undergone numerous exploration drilling programs it is not anticipated that the WBM and cuttings discharge will have a cumulative effect on sediment quality for the area. The closest of these wells is approximately 4 km to the South. As these wells are all several kilometres apart there will be no cumulative impacts linked to these wells or any potential small scale contamination in the immediate vicinity of individual wells. Cement released to the seabed during the drilling operations will be kept to a minimum by careful planning of the quantities required and shipping to shore of any excess dry cement. It is not expected that there would be a significant impact to the marine environment from the release of cement to the seabed. These impacts would all be localised within UK coastal waters, so there will be no transboundary impacts. No global impacts are anticipated.
10.6 Consultee Concerns During the consultations undertaken with the statutory consultees, JNCC raised concerns regarding the cumulative impacts of wind farm activity (Section 10.5). DECC also raised concerns regarding the proximity of wind farms and commented on the necessity for the inclusion of information on sensitive habitats and species and information on seabed habitats (Sections 4 and 10.4).
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10.7 Mitigation Measures The planned mitigation measures that Suncor will undertake to minimise the impact of the drilling discharges are detailed in Table 10.2.
Table 10.2: Potential sources of impact and planned mitigation measures Potential source of impact Planned mitigation measure Drilling discharges to the marine The drilling operation will be planned, managed and environment monitored so as to minimise the volume of cuttings and residual mud that will be discharged. Detailed records will be kept of the types and volumes of mud chemicals used, lost downhole (lost into rock strata), and discharged. The seawater/ GEL sweeps used to drill the tophole, riserless section will be composed of chemicals benign to the marine environment. All chemicals for the WBM sections will be assessed and submitted to DECC for approval as part of a chemical risk assessment prior to commencement of drilling. The use of substitute chemicals will be avoided unless there is no other viable alternative. Surplus muds will be collected and returned to shore. Excess dry cement will be shipped to shore and not discharged to sea. Cement volumes will be calculated and the possibility of excess cement will be minimised by following good operating procedures. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL development wind farm in 2016.
10.8 Conclusions Discharges to sea of WBM and cuttings will result in localised impacts, which will not significantly impact the wider marine environment. The effects are anticipated to be confined to a relatively small area around the release site, with the main drill cuttings pile unlikely to extend beyond 5 km in an ENE to WSW orientation (Ithaca, 2006; 2007 and 2008).
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11.0 PHYSICAL INTERACTIONS BETWEEN VESSELS AND SEALS This section describes the potential interactions between seals and vessels with dynamic positioning (DP) capability undertaking activities during the proposed drilling operations, which could potentially result in ‘corkscrew’ seal mortalities. The Jack-up rig will need to be towed to its drilling location; it is assumed that the tug vessels will be utilising DP thrusters during these operations.
11.1 Regulatory Context Grey seals and harbour seals are offered protection under the Habitats Regulations 1994 (as amended in Scotland) and are classified as European Protected Species under Schedule 3 of those regulations. It is an offence to disturb, kill or injure species listed within these regulations. Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
11.2 Basis for Assessment In order to assess the potential impacts of ‘corkscrew’ seal mortalities associated with seals interacting with any vessels using DP systems, assumptions have been made and are presented in the following sections, regarding the vessel presence and seal activity at the Niobe Exploration Well location.
11.3 Sources of Potential Impact In order to encompass a maximum disturbance to the seals, a worst case scenario for vessel operations is considered. Various vessels (tugs, supply vessel and standby vessel) will be on site during the 45 day drilling period for varying amounts of time (Section 3). For this assessment, it is assumed that all vessels will be onsite for the whole drilling period. Analysis of at-sea distribution data indicates that the occurrence of grey seals at the well locations is likely to be low (5 to 10 grey seals per 25 km2 at any one time), while harbour seal occurrence is likely to be moderate (10 to 50 grey seals per 25 km2 at any one time) (Section 4; Jones et al., 2013).
11.4 Impact to Sensitive Receptors Since 2008, there has been an increasing concern from JNCC and Scottish Natural Heritage over the number of seal carcases washed up at various locations along the UK coastline. These carcases have been exhibiting the same fatal injury. The carcases have mainly been grey seals and adult female harbour seals. The fatal wounds to the seals are consistent with a single, smooth edged cut starting at the head and spiralling around the body. The neat edge to the wound strongly suggests the effects of a blade with a smooth edge applied with considerable force, while the spiral shape is consistent with the rotation about the longitudinal axis of the animals (JNCC, 2012). Between 1985 and late 2012, a total of 80 seals in Scottish waters have suffered deaths due to ‘corkscrew’ injuries, of which 48 were grey seals and 32 were harbour seals. This number however is thought, almost certainly, to be under reported and/ or misidentified,
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with recordings being made only in the following years: 1985, 1998, 2004, 2008, 2009, 2010, 2011 and 2012. In the Moray Firth seal carcases have been predominantly of harbour seals (SMRU, 2013). Expert opinion suggests these injuries are consistent with those one might expect to see if seals were drawn through a ducted propeller, although there is no definitive evidence to confirm this. These ducted propellers and azimuth thrusters are used by vessels with DP capability to maintain position. This involves the rapid rotation of the propellers and thrusters to counteract the movement of the vessel. There are several theories as to what may attract the seals to the propeller openings. However, the leading theory is that the noise produced, when the propeller is in operation, is of a similar frequency to the calls of males seals (SMRU, 2013), leading to attraction by inquisitive seals that are subsequently drawn through the propeller or thruster duct. There appears to be some correlation between seals’ breeding season and the number of ‘corkscrew’ seal deaths recorded. In some months the victims are predominantly harbour seals. These deaths are more often associated with haul-out sites. In the winter months, juvenile grey seals are the main victims off Norfolk and Scotland coasts; these juveniles have been shown to be attracted by conspecific calls with a pulsing rhythmic pattern. It may be that these juvenile grey seals are responding inappropriately to innate attraction to these sounds (SMRU, 2013).
11.5 Cumulative and Transboundary Impacts The presence of DP vessels at the site may increase the risk to seals and add to the cumulative effect from the busy vessel traffic in the Moray Firth. Should there be a number of deaths, this may put increased pressure on the local population and potentially in neighbouring areas in Orkney and the Firth of Forth. These impacts would all be localised within UK coastal waters, so there will be no transboundary impacts. No global impacts are anticipated.
11.6 Consultee Concerns Suncor have undertaken discussions with MORL and have been provided with information regarding the wind farm development schedule (Section 3). This information indicates that there will be no construction activities taking place during Suncor’s proposed drilling schedule, therefore there are no anticipated cumulative impacts associated with the drilling activities and any construction of the neighbouring wind farm.
11.7 Mitigation Measures Until further research is undertaken to further identify the possible causes and specific circumstances which result in these injuries to seals, a precautionary approach should be taken in sensitive areas. Where feasible, Statutory Nature Conservation Bodies (SNCBs) recommend that technical solutions be included in any mitigation plan to help prevent injuries, while enabling activities to go ahead as planned (JNCC, 2012). The harbour seal population is in serious decline on the east coast of Scotland and Northern Isles. Due to the potential significance of these injuries to the seal population, in particular harbour seals, the SNCBs have developed guidance on potential mitigation
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based on the potential risk to seals associated with the location of potential sites to SAC locations (Table 11.1).
Table 11.1: Assessment of the risk of injury to seals and proposed mitigation recommendations
Risk Recommendations
High
Activity proposed to take place within 4 nautical Consider alternatives to using ducted propellers miles of a harbour seal SAC and areas where the or, 1 harbour seal population is in significant decline . Avoid the breeding season. If avoiding the breeding season or using alternatives to ducted propellers are not possible then a Seal Corkscrew Injury Monitoring Scheme should be considered.
Medium
Activity proposed to take place between 4 and 30 Consider alternatives to using ducted propellers. nautical miles of a harbour seal SAC and not Avoid the breeding season if possible. covered above. Activity proposed to take place within 4 nautical Consider alternatives to using ducted propellers. miles of a grey seal SAC. Avoid the breeding season if possible.
Low
Activity proposed to take place beyond 30 nm None. distance from a seal SAC. Activity proposed to take place beyond 4nm None. distance from a grey seal SAC. 1 Please refer to the most recent report for information pertaining to the current status of seal populations Source: JNCC (2012)
11.8 Conclusions Based on the information provided in the SNCB guidance document (Table 11.1), the Niobe Exploration Well would fall into the low risk categories for both harbour and grey seals. The well location is located 80 km NE of the nearest harbour seal SAC and there are no grey seal SACs in the Moray Firth. Moderate numbers of harbour seals utilise the Niobe well area for foraging; however the main risk to harbour seals from DP vessels is during the breeding season (June to July). Deaths are related to behaviour most likely linked to reactions to noises misinterpreted as calls from breeding male harbour seals (SMRU, 2013). Although the Niobe Exploration Well is to be drilled during Q2 and Q3 which spans the breeding season, harbour seals may tend to stay nearer to the onshore the haul-out sites and forage close to shore. As a result, no significant impacts are anticipated between the proposed drilling operations and harbour seals. There is minimal risk to these animals outside the breeding season (SMRU, 2013),
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Due to the distance from shore and the well location being situated in an area of known low grey seal density, no significant interactions between the proposed drilling operations and grey seals are anticipated.
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12.0 UNDERWATER NOISE Sound is important to many marine organisms, with marine mammals, fish and certain species of invertebrates having a range of complex mechanisms for both the emission and detection of sound (Richardson, et al., 1995). Underwater noise may cause animals to become displaced from activities, potentially interrupting feeding, mating, socialising, resting and migration. Subsequently, this may impact body condition and the reproductive success of individuals or populations (Southall, et al., 2007; Richardson, et al., 1995). Feeding may also be affected if noise disturbs prey species (Southall, et al., 2007; Richardson, et al. (1995)). During the operations for the Niobe Exploration Well, noise will be generated by a number of sources including: the jack-up drilling rig; the three tugs which tow out the jack-up drilling rig to the drilling location; supply vessels and a standby vessel; helicopters; and mechanical cutting during well abandonment/ suspension. These sources will emit low frequency noise to the air as well as into the water column. The introduction of additional man-made sound into the environment has the potential to affect the behaviour and, in extreme cases, even injure local wildlife. The potential noise impacts associated with the various Niobe Exploration Well activities are assessed in this section.
12.1 Regulatory Context The control of underwater noise is driven by the Conservation (Natural Habitats &c.) Regulations 1994 (as amended) and the Offshore Marine Conservation (Natural Habitats, &c.) Regulations 2007 (as amended), which include a specific reference to the disturbance, injury or death of European Protected Species (EPS). According to these regulations, it is an offence to: deliberately capture, injure or kill any wild animal of an EPS; and deliberately disturb wild animals of any such species. Disturbance of animals is defined under the Regulations and includes in particular, any disturbance which is likely to impair their ability to: survive, breed, rear or nurture their young; hibernate or migrate (where applicable); and significantly affect the local distribution or abundance of the species to which they belong. In a marine setting, EPS include all the species of cetaceans (whales, dolphins and porpoises) (JNCC, 2010c). As underwater noise has the potential to cause injury and disturbance to cetaceans, an assessment of underwater noise generated by the activities associated with a proposed development is required in line with guidance provided by the JNCC (JNCC, 2010c).
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Appendix A summarises the legislation listed above and the legislative requirements with which Suncor will comply.
12.2 Basis of Assessment The overall approach followed in this assessment includes the identification of potential noise sources, an evaluation of their levels and frequencies, and an impact assessment on the marine species in the area.
12.3 Characteristics of Noise Sources
12.3.1 Vessels It is likely that most forms of oil and gas activities are typically dominated by vessel noise which is continuous. Broadband source levels for these activities rarely exceed 190 dB re 1 μPa m, even for a vessel using dynamic positioning (DP), and typically are much lower (Hannay and MacGillivray, 2005; Genesis, 2011). Whilst continuous noise can mask biologically relevant signals such as echolocation clicks, the sound levels are below the threshold levels for Temporary Threshold Shift (TTS) in cetaceans, according to the Southall et al. (2007) criteria (Genesis, 2011). The level and frequency of sound produced by vessels is related to vessel size and speed, with larger vessels typically producing lower frequency sounds (Richardson et al., 1995). Noise levels depend on the operating status of the vessel and the number of vessels present on site and can therefore vary considerably with time. In general, vessels produce noise over the range 100 Hz to 10 kHz, with strongest energy over the range 200 Hz to 2 kHz.
12.3.2 Jack-up drilling rig Underwater sound levels from all types of drilling platforms increase during drilling periods in comparison to non-drilling periods. Drill ships are considered to produce the highest sound levels compared to jack-ups, semi-submersibles and fixed platforms (Genesis, 2011), with sound pressure levels throughout the entire frequency spectrum, i.e. 20 Hz to well above 10 kHz, and with clearly discernible peaks in the range below 500 Hz (e.g. 100 Hz to 400 Hz). Source levels can be as high as 195 dB (rms) re 1 μPa m for a drill ship, but are more typically lower for semi-submersibles and jack-up platforms, up to about 162 dB (rms) re 1 μPa m. The Niobe Exploration Well operations will be undertaken using a jack-up drilling rig along with a standby vessel and a supply vessel. It is likely that the sound transmission pathway from the jack-up drilling rig would be mainly through air because the body of the jack-up (and all of the noisy machinery) is above the water level, and transmission to sea would be via the three legs and drill string/marine riser which are relatively thin structures (lattice in the case of the legs). No studies evaluating the sound levels measured from jack-up drilling rigs are available, although it is expected that generated sound levels would be comparable with those arising from steel production platforms (Genesis, 2011).
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12.3.3 Helicopters Helicopter noise originates from both the disturbance of the sea surface by the downwash from the rotor blades, and the transmission of engine and blade noise directly into the sea. The downwash noise is very similar to wind noise in its frequency characteristics, and is greatest in the 2 to 20 kHz region. Additional strong tonals in the 10 to 100 kHz range are associated with rotors and turbine operation, respectively (Harland et al., 2005). When sound travels from air to water, the energy is largely reflected from the water surface and only a small fraction of the sound produced by the helicopter is actually transmitted into the sea. Although helicopter sound is fairly broad band (0 to 20 kHz), the lower frequency sound, up to 200 Hz, is much more pronounced (Berrow et al., 2002). The dominant tones in the noise spectra from helicopters are generally below 500 Hz (Richardson et al., 1995). The angle at which sound from the aircraft intersects the water surface is also important. At angles greater than 13° from the vertical, much of the incident sound is reflected and does not penetrate into the water (Richardson et al., 1995). Levels and durations of sounds received underwater from a passing aircraft depend on its altitude and aspect, receiver depth and water depth. In general, the peak received sound level in the water from aircraft directly overhead decreases with increasing aircraft altitude (Richardson et al., 1995).
12.3.4 Mechanical cutting Underwater noise from any mechanical cutting during well abandonment or suspension is expected to be limited and short-term. It may be expected that animal species may be temporary disturbed.
12.4 Species which may be Affected by Underwater Noise Underwater noise can affect the behaviour of, or may cause injury to, several different marine taxa, in particular fish and marine mammals such as pinnipeds and cetaceans.
12.4.1 Cetaceans Cetaceans use sound for navigation, communication and prey detection. Anthropogenic underwater noise has the potential to impact on marine mammals (JNCC, 2010c; Southall, et al. 2007; Richardson, et al. 1995). Several species of cetacean have been recorded in the quadrant containing the proposed Niobe Exploration Well. In particular, bottlenose dolphin, fin whale, harbour porpoise, humpback whale, killer whale, long-finned pilot whale, minke whale and white- beaked dolphin are expected to be present in the area and immediate surrounding blocks during the scheduled period of Niobe Exploration Well operations (Section 4.3.5).
Characterisation of hearing sensitivities of marine mammals There are major differences in the hearing capabilities of the different marine mammal species and, consequently, vulnerability to impact from underwater noise differs between species. Southall, et al. (2007) established a classification based upon the hearing types of different marine mammal species (Table 12.1).
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Table 12.1: Functional cetacean hearing groups
Cetacean functional hearing Estimated auditory bandwidth Species sighted in the Niobe Well group Exploration area Minke whale Fin whale Low-frequency 7 Hz – 30 kHz Long-finned pilot whale Humpback whale White-beaked dolphin Mid-frequency 150 Hz – 160 kHz Bottlenose dolphin Killer whale High-frequency 200 Hz – 180 kHz Harbour porpoise Sources: Southall, et al. (2007); UKDMAP (1998); NOAA (2013)
Thresholds for injury and disturbance to marine mammals The noise level perceived by an animal (the “received noise level”) depends on the level and frequency of the sound, when it reaches the animal, and the hearing sensitivity of the animal. In the immediate vicinity of a high sound level source, noise can have a severe effect causing a permanent threshold shift (PTS) in hearing, leading to hearing loss and ultimately, with increasing exposure, to physical injuries which may be fatal. However, at greater distance from a source the noise decreases and the potential effects are diminished (Nedwell, et al. 2005; Nedwell and Edwards, 2004), possibly causing the onset of only a temporary shift in hearing thresholds (TTS-onset). Southall, et al. (2007) undertook a review of the impacts of underwater noise on marine mammals and used this to define criteria for predicting the onset of injury and behavioural response in marine mammals with different hearing characteristics (Table 12.1), when subjected to different types of noise (Table 12.2).
Table 12.2: Noise types and activities associated with the Niobe Exploration Well Noise type Definition* Activities There are no single pulse Brief, broadband, atonal, transient, single discrete noise Single-pulse events anticipated for the events; characterised by rapid rise to peak pressure Niobe Exploration Well There are no multiple pulse Multiple-pulse Multiple pulse events within 24 hours events anticipated for the Niobe Exploration Well Intermittent or continuous, single or multiple discrete Non-pulse acoustic events within 24 hours; tonal or atonal and Vessel activity, drilling without rapid rise to peak pressure *Source: Southall, et al. (2007) The proposed precautionary threshold, for zero-to-peak Sound Pressure Levels (SPL) that are likely to lead to injury (PTS) in each of the three functional hearing groups of cetaceans, is 230 dB re 1 µPa (Southall et al., 2007). Comparison of these sound thresholds with the potential sound levels expected to be generated by the Niobe Exploration Well operations suggests that no cetaceans will be injured. It is likely that marine mammals will exhibit some avoidance behaviour up to approximately 100 m from the centre of operations (BMT Cordah, 2014); however, the impact is not expected to be significant.
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12.4.2 Fish Many species of fish use sound for location of prey, avoidance of predators and for social interactions. The inner ear of fish including elasmobranchs (sharks, skates and rays) is very similar to that of terrestrial vertebrates, and hearing is understood to be present among virtually all fish (NRC, 2003). The sensory systems used by fish to detect sounds are very similar to those of marine (and terrestrial) mammals and hence sounds that damage or in other ways affect marine mammals could have similar consequences for fish (Popper, 2003). The Niobe Exploration Well is located within the spawning grounds for cod, lemon sole, Nephrops, plaice, sandeel, sprat and whiting (section 4.3.3). The Niobe well location also coincides with nursery grounds for anglerfish, blue whiting, cod, European hake, haddock, herring, lemon sole, ling, mackerel, Nephrops, plaice, sandeel, spotted ray, sprat, spurdog, thornback ray and whiting (section 4.3.3). A comprehensive review by Popper and Hastings (2009) on the effects of anthropogenic sound on fishes concluded that there are substantial gaps in the knowledge that need to be filled before meaningful noise exposure criteria can be developed. However, fish exhibit avoidance reactions to vessels and it is likely that radiated underwater noise is the cue. For example, noise from research vessels has the potential to bias fish abundance surveys by causing fish to move away (De Robertis and Handegard, 2013; Mitson and Knudsen, 2003, Genesis 2014). Reactions include diving, horizontal movement and changes in tilt angle (De Robertis and Handegard, 2013; Genesis 2014).
12.4.3 Pinnipeds Pinnipeds (seals, sea lions and walruses) produce a diversity of sounds within a bandwidth from 100 Hz to several tens of kHz. Their sounds are used primarily in critical social and reproductive interactions (Southall et al., 2007). Available data suggest that most pinniped species have peak sensitivities between 1 and 20 kHz (NRC, 2003). However, the data available on the effects of anthropogenic noise on pinniped behaviour are limited. As discussed earlier there are two seal species recorded within the Moray Firth, the grey seal and harbour seal (section 4.3.5). There is little information regarding the impact of underwater noise sources on pinnipeds however it is expected that disturbance of these mobile species during drilling operations is the most likely worst case outcome.
12.5 Cumulative and Transboundary Impacts Cumulative impacts are possible during the Niobe Exploration Well drilling operations if seismic surveys were to take place at the same time in close proximity to the drilling rig. Suncor will liaison with the wind farm developers to ensure that the potential for cumulative impacts is avoided or minimized. The Niobe Exploration Well is located approximately 245 km from the UK/ Norwegian median line. At this distance, noise levels associated with the Niobe Exploration Well activities would attenuate to a level lower than that likely to cause injury or disturbance to any cetacean species and hence there are unlikely to be any transboundary impacts.
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12.6 Mitigation It is worth noting that JNCC (2010c) do not consider noise from vessel activity to pose a risk of injury to marine mammals (JNCC, 2010c). The noise impact assessment undertaken supports this view, showing that there is unlikely to be any significant impact. It is therefore considered unlikely that further mitigation measures will be required outside of those identified in Table 12.3.
Table 12.3: Potential sources of impact and planned mitigation measures Potential source of impact Planned mitigation measure Noise from drilling operations Machinery and equipment will be in good working order and well- maintained. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL development wind farm in 2016. Noise from helicopters Helicopter maintenance will be undertaken by contractors in line with manufacturers and regulatory requirements. Noise from vessels The number of vessels utilising DP will be minimised and restricted to supply vessels.
12.7 Conclusions Records from the study area indicate previous sightings of eight cetacean species throughout all year. These species are all subject to regulatory protection from injury and disturbance. Broadband source levels for vessels associated with decommissioning activities rarely exceed 190 dB re 1 μPa m and are typically much lower. This does not exceed the thresholds for injury to cetaceans (Southall et al., 2007). Depending on ambient noise levels, sensitive marine mammals may be locally disturbed by noise from a vessel in its immediate vicinity. Although there is a degree of uncertainty associated with the noise levels generated by each vessel and activity, the sound levels for the Niobe Exploration Well operations are proportional to the number of vessels on site at any one time. Overall, the potential impacts to marine mammals from Niobe Exploration Well operations are not assessed to be significant and will, at worst, result in temporary disturbance.
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13.0 ACCIDENTAL HYDROCARBON RELEASE Suncor are committed to minimising the likelihood of accidental spills from all of their operations, including those for the Niobe Exploration Well. This section evaluates the impact of accidental spills and describes Suncor’s planned prevention measures to reduce their probability of occurrence. It also discusses proposed contingency measures and mitigation strategies in the event of a significant hydrocarbon release. As part of the ES process it is necessary to: identify the likely sources of a hydrocarbon or chemical release; estimate the extent and impact of an unplanned release of the hydrocarbons; critically assess the effects of such an unplanned event on key sensitive receptors; and identify monitoring, prevention and effective response measures. The key regulatory drivers that assist in reducing the consequences of potential hydrocarbon or chemical releases are summarised below: International Convention on Oil Pollution Preparedness, Response and Cooperation 1990 requires that Operators of offshore installations under UK jurisdiction have oil pollution emergency plans, which are coordinated with UK National Contingency Plan. Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998 (as amended 2001) require that every offshore installation and oil handling facility must have an approved Oil Pollution Emergency Plan (OPEP). It should set out arrangements for responding to incidents, which cause or may cause marine pollution by oil, with a view to preventing such pollution or reducing or minimising its effect. The regulations also require that personnel with responsibility for the oil pollution incident response must be competent, both in oil pollution incident response and in the use of their OPEP. Offshore Installations (Emergency Pollution Control) Regulations 2002 require OPEPs to contain arrangements for the potential involvement of the Secretary of State’s Representative for Maritime Salvage and Intervention in an incident. EC Directive 2004/35 on Environmental Liability with Regard to the Prevention and Remedying of Environmental Damage enforces strict liability for prevention and remediation of environmental damage to “biodiversity”, water and land from specified activities.
13.1 Likely Magnitude and Duration All offshore activities carry a potential risk of a hydrocarbon or chemical spillage to sea. During the period 1975 to 2005, a total of 17,012 tonnes of oil were discharged from 5,826 individual spill events on the UKCS (UKOOA, 2006). Analysis of spill data between 1975 and 2005 shows that 46% of spill records related to crude oil, 18% to diesel and the other 36% to condensates, hydraulic oils, oily waters and other materials. During 2012 on the UKCS, a total of 248 oil spills were reported to DECC, of which 8% were greater than 455 litres, and a total of 229 chemical spills, 49 of which were greater than 1 tonne (ACOPS, 2013). The impact that may be caused by a hydrocarbon release is dependent on: location of the spill; its size;
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the properties of hydrocarbon or chemical that is spilt; prevailing weather and metocean conditions at the time of the spill; environmental sensitivities that could be impacted by the spill and success of the contingency plans. Hydrocarbon releases can occur from a range of sources and can result in a number of different hydrocarbon types or chemicals being spilt to the marine environment. The main potential sources of spillages of hydrocarbons at the Niobe Exploration Well location are: operational spills of aviation fuel from helicopter fuelling; operational topsides spills from process and utilities (such as small spills of crude, kerosene, lubes, diesel from the drains systems, produced water upsets, gasket failure, valve failure etc.); spillages of diesel fuel or lubricants during the proposed drilling operations; spills from vessels during transfer operations; spills due to vessels collision; low toxicity oil based mud (LTOBM) spills; and well blow-out. Serious accidental events, such as vessels collision could cause a loss of inventory. However accidents leading to the total loss of inventory are extremely rare events. In the event of an accidental spill of diesel fuel from a vessel, a diesel slick would form on the sea surface. The slick would be localised and would disperse and degrade rapidly as a result of waves action, currents, evaporation, and microbial and photolytic actions. Typically, the worst case hydrocarbon spill scenario for a UKCS offshore development would be a well blow-out during the drilling programme.
13.2 Behaviour of Oil at Sea When oil is released in the sea it is subjected to a number of processes including: spreading, evaporation, dissolution, emulsification, natural dispersion, photo-oxidation, sedimentation and biodegradation (Table 13.1). The physical and chemical changes that spilled oil undergoes are collectively known as ‘weathering’ (ITOPF, 2012). The processes of spreading, evaporation, dispersion, emulsification and dissolution are most important early on in a spill; oxidation, sedimentation and biodegradation are more important later. The behaviour of crude oil releases at depth will depend on the immediate physical characteristics of the release and on subsequent plume dispersion (DTI, 2001). The Niobe oil is expected to range around a specific gravity of 0.94 and an American Petroleum Institute (API) gravity of 24˚, which is often categorised as a medium oil. Figure 13.2 illustrates the processes discussed above for a spill of a typical medium crude oil under moderate sea conditions. This figure highlights the observation that a significant release of Niobe crude oil will likely spread over a large area and persist for several weeks.
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Table 13.1: Overview of the main weathering fates of oil at sea Weathering process Description Evaporation Lighter components of oil evaporate to the atmosphere. Waves and turbulence at the sea surface can cause a slick to break up into Dispersion fragments and droplets of varying sizes which become mixed into the upper levels of the water column. Emulsification is the process by which the spilt oil takes up water and occurs as a result of physical mixing promoted by wave action. The emulsion formed is usually very viscous and more persistent than the original oil and formation Emulsification of emulsions causes the volume of the slick to increase between three and four times in turn delaying the other processes which cause the oil to dissipate. Some compounds in oil are water soluble and will dissolve into the Dissolution surrounding water. Oils react chemically with oxygen either breaking down into soluble products Oxidation or forming persistent tars. This process is promoted by sunlight. Sinking is usually caused by the adhesion of sediment particles or organic Sedimentation matter to the oil. In contrast to offshore, shallow waters are often laden with suspended solids providing favourable conditions for sedimentation. Sea water contains a range of micro-organisms that can partially or Biodegradation completely breakdown the oil to water soluble compounds (and eventually to carbon dioxide and water).
Source: ITOPF (2012) Figure 13.1: Schematic representation of the fate of a medium crude oil spill showing changes during the weathering process. The width of each band indicates the importance of the process.
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13.3 Oil Spill Modelling for the Niobe Exploration Well Based on DECC’s revised guidance (DECC, 2012b), oil spill modelling has been undertaken to examine the fate of a large hydrocarbon release within the Niobe Exploration Well. Use of oil spill modelling output provides a very conservative assessment but allows for an evaluation of the probability of oil beaching and the potential time for the crude oil to reach land from a hypothetical catastrophic well blow-out, which would have been described as the worst case scenario. The oil spill modelling was conducted using SINTEF’s Oil Spill Contingency and Response (OSCAR) V6.5 software. An essential aspect of any oil spill model is the ability to accurately represent the environment into which oil may be released. The geography, topography, oceanography and meteorology are all important in modelling the transport and fate of oil released to the marine environment. OSCAR is an oil spill model supporting several model types but are generally characterised as either deterministic (trajectory) or stochastic: Deterministic modelling simulates a point source spill scenario under a single set of metocean conditions. The model provides output on a map indicating the trajectory of the oil, the area of the slick and beaching location of the spill after a specified period. Stochastic modelling allows the simulation of a point source spill under a specified number of different probable metocean conditions, defined as percentage frequencies of wind speed and direction. This model type provides output as contour plots showing the probability of surface oiling and potential locations of beached oil. The OSCAR model simulates the fate, weathering and dispersion of oil in three dimensions. Stochastic and deterministic scenarios run with OSCAR combine: weathering algorithms to determine changes in slick physical properties as it spreads; three-dimensional transport processes acting on the oil due to the current, wind, waves, diffusion and buoyancy in the ocean surface layer; and changes due to evaporation, emulsification and natural dispersion of hydrocarbons. The modelling scenario assessed a well blow-out at the Niobe well as a catastrophic loss of crude oil released from the seabed, which subsequently dispersed and reached the surface, and takes into account loss of oil into the water column or deflection of oil by subsurface currents. In addition it was assumed that no oil spill response had been undertaken, which would not be the case in a real incident. Deterministic scenarios were run in support of the stochastic modelling, to provide further detail on the potential for beaching and interaction with the UK and European coastlines. Stochastic and deterministic scenarios were considered as well for a surface loss of diesel inventory corresponding to a collision of vessels.
13.3.1 Environmental parameters and oil characteristics Metocean parameters and data sources Air and sea surface temperature data were sourced from the National Oceanic and Atmospheric Administration (NOAA) Physical Sciences Division, Earth System Research Laboratory, ICOADS 2 x 2 degree databases via http://www.esrl.noaa.gov/psd/. North Sea wind field data and 3-D hydrodynamic current data are from 01 January 1991 to 31
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December 1992 records inclusive, as supplied by SINTEF and sourced from the Norwegian Meteorological Institute. Oil type In order to consider weathering of oil within its model, OSCAR contains a database of physical and chemical information for over 100 oil types. A matching of the oil characteristics of the expected Niobe crude (specific gravity, API, viscosity, pour point wax an asphaltene contents) has been done with the oils from the OSCAR oil database. Skrugard 2011 oil matched at 86.6% with the expected Niobe crude and has been used for the well blow-out modelling scenario (Table 13.2).
Table 13.2: Characteristics of crude and diesel oils used for stochastic and deterministic modelling Wax Asphaltene Specific API Pour Viscosity Oil type content content Source gravity (°) point (CP) (%) (wt %)
C&C Niobe Crude Oil 0.94 24° -32 50 1.6 0.16 Reservoir*
Analogue crude: OSCAR 0.871 31 -36 32 1.89 0.05 Skrugard 2011 database
OSCAR Marine Diesel 0.843 36.4 -36 - - - database *Source: C&C Reservoirs (www.c&creservoirs.com)
13.3.2 Modelling scenarios In total, two stochastic scenarios (Scenarios S01 and S02) and four deterministic scenarios (Scenarios D01a, D01b, D02a and D02b) (Table 13.3) have been modelled. The total numbers of runs chosen for stochastic simulations were 155 for the well blow- out scenario and 188 for the loss of inventory from a vessels collision scenario. The simulation period chosen corresponds to the release duration plus 10 days of contingency.
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Table 13.3: Stochastic and deterministic oil spill scenarios modelled for the Niobe Exploration Well Spill Characteristics
Scenario Description Oil Type Total Release Release Quantity Released Rate Duration
Stochastic modelling scenarios
84,000 bbls 700 bbls/day S01 Well blow-out spill Crude oil equivalent to equivalent to 120 days 13,355 m³ 111 m³/day Loss of inventory from a collision 2,000 S02 Diesel 2,000 bbls 1 hour of vessels bbls/day
Deterministic modelling scenarios
700 Well blow-out spill with a 30 84,000 bbls bbls/day D01a knots wind blowing towards the equivalent to equivalent 120 days UK coastline 13,355 m³ to 111 m³/day Crude oil 700 Well blow-out spill with a 30 84,000 bbls bbls/day D01b knots wind blowing towards the equivalent to equivalent 120 days UK/ Norwegian median line 13,355 m³ to 111 m³/day Loss of inventory from collision of vessels with a 30 knots wind 2,000 D02a 2,000 bbls 1 hour blowing towards the UK bbls/day coastline Diesel Loss of inventory from a collision of vessels with a 30 knots wind 2,000 D02b 2,000 bbls 1 hour blowing towards the UK/ bbls/day Norwegian median line
13.3.3 Stochastic modelling results A limitation to the modelling is that a probability plot (stochastic output) represents the chance (as a percentage) of an area of sea surface experiencing contamination from a spill and is not a true reflection of the extent that a potential spill would cover. Any comparison of stochastic outputs should be made after consideration of both, the time period/ duration of the scenario and the quantity of oil that is potentially beached. It also has to be noted that the deterministic scenarios have been run with a 30 knots wind blowing every day during the simulation times (130 days for the well blow-out spill scenario and 10 days for the loss of inventory from a vessels collision scenario). It is improbable that the wind will blow at this speed and in only one direction during these periods of time. Well blow-out The quantity and spill persistence of the released hydrocarbons suggests a large surface signature of contamination (Figure 13.3). Hydrocarbons would not only cross the UK/ Norway median line, but also beach in Scotland (Moray Firth and Aberdeenshire coastlines) and on the Orkney Islands coastline (Figures 13.3 and 13.4).
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In Scotland, there are high chances of beaching from Fraserburgh to Cullen coastlines (mainly > 90%) and from Helmsdale to Duncansby Head coastlines (mainly >85%) (Figure 13.4). The maximum amount of oil that is shown to come ashore in any one simulation is 2,840 m³ (Table 13.4). The shortest arrival time calculated in any one simulation is 19 hours (Table 13.4). Loss of inventory from a collision of vessels The low quantity and persistence of released hydrocarbons suggests an extended surface signature of contamination. However, the probabilities of sea surface contamination are low (mainly <20%) (Figure 13.5). Hydrocarbons would not cross the UK/ Norway median line but would beach in Scotland. Of note here is that the probabilities of shoreline contamination around Wick and between Fraserburgh to Cullen are very low (approximately 5–15%) (Figure 13.6). The maximum amount of oil shown to come ashore in any one simulation is 1,443 m³ (Table 13.4). The shortest arrival time calculated in any one simulation is 13 hours (Table 13.4).
Table 13.4: Stochastic modelling results Minimum arrival Maximum volume Impact to Scenario Description time in a accumulating on shore shore simulation hours in a simulation (m³)* Beaching in mainland S01 Well blow-out spill 19 2,840 Scotland and Orkney Islands Loss of inventory from Beaching in S02 13 1,443 a collision of vessels Scotland
*OSCAR gives output in unit weight metric tonnes so an oil converter tool has been used based on a conversion using the following assumptions: for crude oil, API: 32.6˚ for 60F; adjusted density: 0.871 (OSCAR analogue – Skrugard 2011) and for diesel oil adjusted density: 0.843 at 15˚C (OSCAR Marine diesel oil). Source: http://www.thecalculatorsite.com/conversions/substances/oil.php
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Figure 12.3: Probability plot of sea surface contamination from oil release under a well blow-out spill at Niobe Well location
Figure 13.3: Probability plot of shoreline beaching from a well blow-out spill at Niobe Well location
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Figure 13.4: Probability plot of sea surface contamination from oil release under a loss of inventory from a collision of vessels at Niobe Well location
Figure 13.5: Probability plot of shoreline beaching from a loss of inventory from a collision of vessels at Niobe Well location
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13.3.4 Deterministic modelling results Well blow-out spill The oil persistence suggests that the hydrocarbons will become entrained in the water column at a slow rate. Consequently, if a blow-out occurs the modelling indicates that beaching will occur in both scenarios. The hydrocarbons on the sea surface will beach before the amount of oil remaining on the sea surface becomes insignificant (Figures 13.7 and 13.8; Table 13.5). A 30-knot wind blowing towards the UK/ Norway median line will result in surface oil crossing the median line after 18 days and 6 hours. After 130 days, beached hydrocarbon volumes of 300 m³ (D01a) and 21 m³ (D01b) were predicted. The amount of surface oil became insignificant after 5 days and 6 hours (D01a) and after 8 days and 9 hours (D01b). Loss of inventory from a collision of vessels Large wave heights generated by 30 knot winds (worst case), quickly transferred hydrocarbons from the sea surface to the water column resulting in a small surface spill trajectory in both scenarios. The results suggest that hydrocarbons on the sea surface will not beach or cross the UK/ Norway median line for both scenarios D02a and D02b (Figures 13.9 and 13.10; Table 13.5). After 10 days, no beaching volumes were predicted for scenarios D02a and D02b. The amount of surface oil was insignificant after 12 hours and 15 hours, respectively, for scenario D02a and D02b.
Table 13.5: Results from deterministic model for well blow-out spill and loss of inventory from a vessels collision scenarios. Volume of Time until Time until Minimum oil surface oil surface oil is arrival beached crosses Impact Scenario Description insignificant* time to at the end UK/Norway to shore (d/h) shore of the median line (d/h) simulation (d/h) (m³)** Well blow-out spill with a Beaching 30 knots wind blowing D01a N/A 5d 6h 3d 21h 300 in towards the UK Scotland coastline Well blow-out spill with a Beaching 30 knots wind blowing D01b 18d 6h 8d 9h 23d 6h 21 in towards the UK/ Scotland Norwegian median line Loss of inventory from a collision of vessels with No No No D02a a 30 knots wind blowing N/A 0d 12h Beaching Beaching Beaching towards the UK coastline Loss of inventory from a collision of vessels with No No No D02b a 30 knots wind blowing N/A 0d 15h Beaching Beaching Beaching towards the UK/ Norwegian median line *Time until amount of oil at sea became insignificant (<5% of oil mass remaining on the sea surface). **OSCAR gives output in unit weight metric tonnes so an oil converter tool has been used based on a conversion using the following assumptions: for crude oil, API: 32.6˚ for 60F; adjusted density: 0.871 (OSCAR analogue – Skrugard 2011) and for diesel oil adjusted density: 0.843 at 15˚C (OSCAR Marine diesel oil). Source: http://www.thecalculatorsite.com/conversions/substances/oil.php
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Figure 13.6: Scenario D01a - Loss of crude from a well blow-out spill at Niobe Well towards UK coastline at the end of the simulation (130 days). Surface oil thickness <0.003 mm in pink and hydrocarbon droplets (diameter 0 -10 µm) in water column (in white) and dissolved particle (in black).
Figure 13.7: Scenario D01b - Loss of crude from a well blow-out spill at Niobe Well towards UK/ Norway median line at the end of the simulation (130 days). Surface oil thickness <0.003 mm in pink and hydrocarbon droplets (diameter 0-10 µm) in water column (in white) and dissolved particle (in black).
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Figure 13.9: Scenario D02a - Loss of inventory from a vessels collision at Niobe Well towards UK coastline at the end of the simulation (10 days).Surface oil thickness <0.003 mm in pink and hydrocarbon droplets (diameter 0-10 µm) in water column (in white) and dissolved particles (in black).
Figure 13.10: Scenario D02b - Loss of inventory from a vessels collision at Niobe Well towards UK/ Norway median line at the end of the simulation (10 days). Surface oil thickness <0.003 mm in pink and hydrocarbon droplets (diameter 0-10 µm) in water column (in white) and dissolved particles (in black).
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13.3.5 Oil spill response Suncor is an associate member of Oil Spill Response Limited (OSRL), which provides assistance in responding to an oil spill in the UKCS. OSRL will provide aerial surveillance and dispersant spraying and containment recovery capabilities for oil spills on the UKCS. OSRL is retained to provide an effective Tier 2 and Tier 3 oil spill response to support Suncor. Should an active response be required, OSRL will work with the Emergency Response Team and Suncor representatives to provide services and equipment in the field as required. Suncor also subscribes to the Petrofac Emergency Response Service Centre (ERSC) which provides a facility and personnel to enable onshore response and support to offshore operations. Personnel in this team have received the appropriate level of DECC training to ensure a competent response to oil spills. Suncor has contracted Briggs Marine Environmental Services and Wild Well Control on an ongoing basis to provide firefighting, well control, engineering and training services to oil and gas operators around the world and could be called upon to assist Suncor in responding to any well control incident during the Niobe Exploration Well drilling operations. Suncor will hold primacy for oil spill response and the facilities of the Petrofac ERSC will be used as the Primacy Response Centre. In the event of an ongoing spill response, communication with regulatory bodies will be carried out by the onshore support team.
13.4 Impact on Sensitive Receptors Although the likelihood is remote, there is a potential risk to organisms in the surrounding marine environment in the event of a large crude spill were to occur. These include seabirds, marine mammals, fish, plankton and nekton, coastal habitats and resources, habitats protected under Annex I of the European Habitats Directive and species protected under Annex II of the Directive. No Annex I habitats have been found in the surveyed area. The four Annex II species (grey seal, common seal, harbour porpoise and bottlenose dolphin) known to occur in UK waters are expected to be seen in the area of the proposed Niobe Exploration Well. Recently 30 Nature Conservation MPAs have been formally designated (Scottish Government, 2014). With respect to the Niobe Exploration Well the closest MPA’s are: East Caithness Cliffs MPA, located, approximately, 35 km to the southwest of the well. This MPA extends 2 km from the coast, and extends between Helmsdale and Wick. The qualifying features of conservation are the black guillemots, together with their adjacent feeding grounds (SNH, 2014a); and Noss Head MPA, located, approximately 41 km to the south of the well. This MPA covers an area of, approximately, 8 km2 off the coast at Wick. The qualifying feature of conservation is Scotland’s largest known horse mussel bed (SNH, 2014b). Coastal environmental sensitivities, including designated conservation sites that may potentially be impacted by a catastrophic release of crude oil at the Niobe Exploration Well are discussed further in Appendix D. An accidental release of chemicals from the deck of the drilling rig could result in a localised impact immediately around the discharge point. Those organisms that would be
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at risk include planktonic organisms (i.e. those drifting in the near-seabed currents) and pelagic species. The effects would be localised and temporary, abating once the chemicals had dispersed, diluted and degraded naturally. Table 13.5 summarises the potential effects of oil and chemical spills to marine life from offshore installations. The mitigation measures in place during the proposed operations (Table 13.6) will ensure that the risk to these sensitive receptors is as low as possible.
Table 13.4: Potential effects of oil spills in the offshore marine environment Environmental Potential effect receptor Plankton Localised effects due to toxicity. Usually only localised effects from toxicity and smothering, and only if oil reached the Benthic fauna seabed. Benthic communities may be affected by gross contamination, with recovery taking several years. Adult fish are expected to avoid the affected area, but if they are affected, the hydrocarbons may result in tainting of fish. Eggs and larvae may be affected, but such Fish effects are generally not considered to be ecologically important because eggs and larvae are distributed over large sea areas. A chemical release may result in an acute toxicity to eggs and larvae in the immediate vicinity of the release. Physical fouling of feathers and toxic effects of ingesting hydrocarbons can result in fatalities. Effects will depend on species present, their abundance and time of year. Seabirds Birds are identified as being very vulnerable in the Niobe Exploration Well area throughout the year. No obvious effects are known for adult cetaceans or seals. Fouling of the fur of young Marine seals reduces their resistance to cold. Few direct impacts to marine mammals from a mammals local chemical release.
13.4.1 Seabirds The potential risk to seabirds is from oil and diesel pollution through damage to feathers resulting in loss of mobility, buoyancy, insulation and waterproofing. Birds may also be at risk from toxicity through ingestion of hydrocarbons and may face starvation through depletion of food sources. The birds most affected are Guillemots, Razorbills and Puffins, as they spend large periods of time on the water, particularly during the moulting season, when they become flightless (DTI, 2001). Seabird vulnerability to oil pollution in the Niobe Exploration Well area is “very high” throughout the year (JNCC, 1999; Section 4.3.6). This is as a consequence of the: near-shore location of the site; activity of breeding birds in the late summer months; arrival of over-wintering birds in the winter months; and location of the Moray Firth as a migratory route during the spring and winter months. Any release throughout the year, will be responded to in an appropriate and timely manner.
13.4.2 Marine mammals Major oil spills can result in direct mortality to marine mammals, although, generally, they are less vulnerable than seabirds to fouling by oil. Cetaceans have smooth hairless skin over a thick layer of insulating blubber, so oil is unlikely to adhere persistently or cause
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breakdown in insulation. However, they are at risk from chemicals evaporating from the surface of an oil slick at sea, especially within the first few days of the spill. They may inhale vapours given off by spilt oil, their eyes may be vulnerable and individuals may drown as a result of associated symptoms. Neonatal (very young) seal pups are particularly at risk from oil coming ashore. In addition, a major release of oil or diesel may deplete the food sources of marine mammals (SMRU, 2001). Several cetacean species occur regularly in the Niobe Exploration Well area, including bottlenose dolphin, fin whale, harbour porpoise, humpback whale, killer whale, long- finned pilot whale, minke whale and white-beaked dolphin, although only a few individuals are ever present at any one time (Section 4.3.5). Therefore, it is not considered that the viability of any particular species would be significantly impacted in the unlikely event of a hydrocarbon spill associated with the Niobe Exploration Well operations.
13.4.3 Fish The Niobe Exploration Well is located within the spawning grounds for cod, lemon sole, Nephrops, plaice, sandeel, sprat and whiting (Section 4.3.3). The well also coincides with nursery grounds for anglerfish, blue whiting, cod, European hake, haddock, herring, lemon sole, ling, mackerel, Nephrops, plaice, sandeel, spotted ray, sprat, spurdog, thornback ray and whiting (Section 4.3.3). Excluding a catastrophic hydrocarbon release, an accidental oil or chemical release could directly impact fish and their eggs and larvae. However, the effects would be localised, and there would be no significant threat to the populations of these species. The species spawn over wide areas of the North Sea and spawning areas are not rigidly fixed, and may vary from year to year depending on the individual species response to changes in the surrounding environment (Coull et al., 1998; CEFAS, 2001).
13.4.4 Plankton and nekton With regard to the impacts on plankton and small nekton (organisms that swim in the water column), these organisms are widely distributed in the water masses that flow over large areas of the North Sea (Section 4.3.1). Consequently, the accidental discharge would not threaten the viability of these species.
13.5 Transboundary and Cumulative Impacts Although the proposed Niobe Exploration Well lies approximately 245 km from the UK/ Norwegian transboundary line, a worst case catastrophic well blow-out of crude oil would be likely to have a transboundary impact (Figures 13.3 and 13.4). However, an incident of this magnitude would have a very low probability of occurrence. In the event of an oil spill entering Norwegian waters it may be necessary to implement the NORBRIT Agreement (the Norway-UK Joint Contingency Plan). The NORBRIT Agreement sets out command and control procedures for pollution incidents likely to affect both parties, as well as channels of communication and available resources. The Agreement is largely oriented towards major spills; however, it is not confined to such events and will apply as necessary to any spills within the NORBRIT regions which are of sufficient severity to warrant joint action. The NORBRIT Agreement becomes operational
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by agreement with the Action Co-ordinating Authority (ACA) of the country on whose side of the median line a spill originated. For oil spills crossing into either Danish or German waters, responsibility for operational activities in response to oil spill and disaster incidents lies with the Director Coastguard (dependent upon the Coastguard agreement). The coastguard in charge of the waters reached has the role to combat oil spill incidents in accordance with the Combating Accidents in the North Sea Act (BONN) Act and the Contingency Plan for the North Sea 2000. An accidental release of chemicals from the drilling rig would result in a localised impact immediately around the discharge point and is unlikely to have transboundary effects. Other than a catastrophic release of crude oil, any hydrocarbon discharge as a result of the Niobe Exploration Well operations would be expected to disperse rapidly in the immediate environment without the potential to combine with other discharges. Therefore, any significant cumulative impacts are unlikely. Closure of fishing grounds affected by the spill could occur in the event of a major release for several months. However, fishing activities would be expected to recover in a relatively short period following a spill (Perry, 1993).
13.6 Consultee Concerns DECC emphasised the importance of leak prevention and detection in an unmanned situation during well suspension.
13.7 Proposed Mitigation Measures Suncor are aware of the risk of hydrocarbon spill occurring during the proposed Niobe Exploration Well drilling operations. Mitigation measures will include prevention and minimising the probability of an accidental release through competency and training.
13.7.1 Competency and training To ensure implementation of control and mitigation measures the following aspects of competency, training and documentation will be in place with an emphasis on: trained and competent offshore crews and supervisory teams; approved OPEP in place prior to any activities being undertaken; OPEP commitments (i.e. training, exercises) captured by environmental audit; co-ordinated industry oil spill response capability; and enhanced sharing of industry best practice via the OGUK (ex-OSPRAG) Working Groups.
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13.7.2 Prevention and mitigation Table 13.6 details the additional prevention or mitigation measures that Suncor will undertake to minimise the impact of the main risks of hydrocarbon spills arising from the Niobe Exploration Well.
Table 13.6: Potential sources of impact and planned mitigation measures Potential source of Planned Mitigation Measures impact Documented procedures for the transfer of crude, base oil, diesel, lubricants and drilling mud to ensure containment and to minimise the risk of loss during fuel transfer. Preventive and reactive maintenance programmes. Bunkering during daylight hours whenever possible. Personnel to supervise the offloading and bunkering operations and Spill of fuel, base oil, monitor the hoses throughout bunkering. diesel, lubricants, drilling Visual inspection of hoses and offloading before each use. Replacement of mud and chemicals all damaged and worn hoses. Self-seal hoses with flotation collars to keep hoses on the surface and visible at all times and prevent the hoses becoming twisted in the propellers. Spill response exercises in line with the requirements detailed in OPEP. Adoption of the best practice methods as set out in the Bulk Hose Best Practice Guidelines (NWEA/ OGUK/ Step change and MSF guidelines). The jack-up drilling rig fitted with all relevant navigational and communication aids on board. Collision risk assessment and vessel management plans for field Loss of drilling rig operations. inventory (collision with another vessel) Simultaneous operations procedures governing concurrent operations in the Niobe Exploration Well area. A standby vessel to monitor the exclusion zone around the jack-up drilling rig. The contractor’s well procedures in place during well operations. Well control at the Niobe Exploration Well will be maintained through the use of drilling fluid at a density that will maintain the hydrostatic pressure greater than the pore pressure of the formations being drilled. Loss of well control A Blow Out Preventer (BOP) installed on the well as the secondary means of well control and this will be tested regularly. Located above the wellhead, the BOP consists of a series of heavy duty valves designed to isolate the well contents from the marine environment. Staff to receive standard industry well control training and certification. Drilling operations at the Niobe Exploration Well will be covered by the drilling specific OPEP. All spills Suncor has access to specialist emergency response services provided by Oil Spill Response Limited (OSRL), Briggs, Wild Well Control and Petrofac’s response centre. Suncor is a member of the Oil Pollution Operator’s Liability Fund (OPOL).
13.8 Conclusions From the impact assessment undertaken, the following conclusions are made. although unlikely to occur, a catastrophic hydrocarbon release of crude oil from a well blow-out of the Niobe Exploration Well could potentially result in significant impacts in mainland Scotland and Orkney Islands coastlines;
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the preventative measures proposed by Suncor would be sufficient to minimise the risk of accidental hydrocarbon release to a level that is as low as reasonably practicable (i.e. in line with industry best practice) and to control and mitigate the effects in the event of their occurrence; and the overall risk to the environment, from unplanned/ emergency events is considered to be low. The integrity of statutory conservation sites designated or likely to be designated under the Habitats Directive or as MPAs is not considered to be at risk.
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14.0 SUMMARY OF IMPACTS AND MITIGATION MEASURES As described in Sections 7 to 13, drilling activities at the Niobe well location could result in an impact to the surrounding environmental receptors. This section provides a summary of the potential impacts that were described in Sections 7 to 13, that could arise as a result of the proposed Niobe drilling operations. Table 14.1 summarise the drilling activities, the potential impacts to environmental receptors during the proposed drilling period (Q2/ Q3 2015) and Suncor’s proposed mitigation measures.
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Table 14.1: Summary of the potential impacts to the environment and Suncor’s planned mitigation measures ES Sources of Potential Environmental Receptors Suncor’s Planned Mitigation Measure Section Environmental Impact
1. Commercial fisheries.
2. Commercial shipping. Notification of the drilling activities on the Kingfisher fortnightly bulletin. 3. Offshore renewable energy: Notification of the drilling activities to the HM Coastguard and UK Hydrographic Office. 7 Other users of the sea MORL wind farm. A 500 m safety exclusion zone will be in place around the drilling rig. BOWL wind farm. A standby vessel will be in place to warn other users of the sea to the presence of the drilling rig. Continued dialog between Suncor and the offshore wind farm developers (MORL and BOWL). 4. MOD. 5. Marine archaeology and wrecks
1. Benthic environment: Sediments. 2. Fish and shellfish: Suncor have recently undertaken a seabed survey to inform their knowledge of the nature of the seabed at the well location and to identify seabed areas that may not be suitable for the drilling rig. Nephrops. Installation of the drilling The installation of the jack-up drilling rig will be a temporary activity, with the drilling rig only remaining 8 rig on the seabed. 3. Protected habitats and species: in position on the seabed for a period of 45 days. East Caithness Cliffs MPA/ SAC/ Suncor will undertake all drilling operations in 2015, prior to the scheduled construction of the adjacent SPA. MORL wind farm development in 2016. 4. Cumulative and transboundary: MORL wind farm development. The support vessels and drilling rig will be audited as part of selection and pre-mobilisation and Atmospheric emissions 1. Local air quality. management system requirements. from the consumption of Fuel consumption will be minimised by operational practices and power management systems for fuel from: 2. Global climate change. engines, generators and other combustion plant and maintenance systems. 9 Jack-up drilling rig. 3. Cumulative and transboundary: Vessels will use ultra-low sulphur fuel in line with MARPOL requirements. Support vessels. MORL wind farm development. Work programmes will be planned to optimise rig and vessel time in the field. Helicopters. Norwegian waters. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL wind farm development in 2016.
Table 14.1: Summary of the potential impacts to the environment and Suncor’s planned mitigation measures
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ES Sources of Potential Environmental Receptors Suncor’s Planned Mitigation Measure Section Environmental Impact
1. Water column communities: Plankton. The drilling operation will be planned, managed and monitored so as to minimise the volume of residual 2. Benthic communities: mud that will be discharged. Benthic fauna. Detailed records will be kept of the types and volumes of mud chemicals used, lost downhole (lost into 3. Fish and shellfish: rock strata), and discharged. Cod. The seawater/ GEL sweeps used to drill the tophole, riserless section will be composed of chemicals benign to the marine environment. Lemon sole. All chemicals for the WBM sections will be assessed and submitted to DECC for approval as part of a Drilling discharges to the 10 Nephrops. chemical risk assessment prior to commencement of drilling. The use of substitute chemicals will be marine environment. Sprat. avoided unless there is no other viable alternative. Whiting. Surplus muds will be collected and returned to shore. 4. Protected habitats and species: Excess dry cement will be shipped to shore and not discharged to sea. Cement volumes will be calculated and the possibility of excess cement will be minimised by following good operating East Caithness Cliffs MPA/ SAC/ procedures. SPA. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL 5. Cumulative and transboundary: wind farm development in 2016. MORL wind farm development. Norwegian waters.
1. ‘Corkscrew’ seal mortalities to: Consider alternatives to using ducted propellers or, Grey seal. Avoid the seal breeding season if possible (if avoiding the breeding season or using alternatives to Vessel interactions with ducted propellers are not possible then a Seal Corkscrew Injury Monitoring Scheme will be considered) 11 Harbour seal. seals Presence of a MMO on the drilling rig during VSP should VSP be required. 2. Cumulative and transboundary: Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL MORL wind farm development. wind farm development in 2016.
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Table 14.1 (continued): Summary of the potential impacts to the environment and Suncor’s planned mitigation measures ES Sources of Potential Environmental Receptors Suncor’s Planned Mitigation Measure Section Environmental Impact
1. Fish. 2. Pinnipeds. Grey seal. Harbour seal. 3. Cetaceans: Machinery and equipment on the drilling rig and the support vessels will be in good working order and Bottlenose dolphin. will be well-maintained. Underwater noise from: Fin whale. Helicopter maintenance will be undertaken by contractors in line with manufacturers and regulatory Jack-up drilling rig. 12 Harbour porpoise. requirements. Support vessels. Humpback whale. The number of vessels utilising DP will be minimised. Helicopters. Killer whale. Suncor will undertake all drilling operations in 2015, prior to the construction of the adjacent MORL Long-finned pilot whale. wind farm development in 2016. Minke whale. White-beaked dolphin. 4. Cumulative and transboundary: MORL wind farm development.
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Table 14.1 (continued): Summary of the potential impacts to the environment and Suncor’s planned mitigation measures ES Sources of Potential Environmental Receptors Suncor’s Planned Mitigation Measure Section Environmental Impact Documented procedures for the transfer of diesel, lubricants and drilling mud will be in place to ensure containment and to minimise the risk of fuel loss during transfer. Suncor will endeavour to undertake bunkering operations during daylight hours, whenever possible. Personnel will at station to supervise the bunkering operations and monitor the hoses throughout the bunkering operations. Visual inspection of hoses before each use. Replacement of all damaged and worn hoses. Self-seal hoses with flotation collars to keep hoses on the surface and visible at all times and prevent 1. Plankton. the hoses becoming twisted in the propellers. Adoption of the best practice methods as set out in the Bulk Hose Best Practice Guidelines 2. Fish and shellfish: (NWEA/OGUK/Step change and MSF guidelines). Cod. The jack-up drilling rig will be fitted with all relevant navigational and communication aids. Lemon sole. A collision risk assessment and vessel management plans for field operations will be undertaken prior Nephrops. to the commencement of operations. Accidental hydrocarbon Sprat. Simultaneous operation procedures will be in place governing concurrent operations in the Niobe well 13 release Whiting. area. 3. Seabirds. A standby vessel will be onsite during the 45 day drilling period to monitor the exclusion zone around the jack-up drilling rig. 4. Marine mammals. The contractor’s well procedures in place during well operations. 5. Cumulative and transboundary: Primary well control achieved through well engineering and the use of drilling mud formulations with MORL wind farm development. weighting agents. Norwegian waters. A BOP will be installed on the well as the secondary means of well control and this will be tested regularly. Located above the wellhead, the BOP consists of a series of heavy duty valves designed to isolate the well contents from the marine environment. Staff to receive standard industry well control training and certification. Drilling operations at the Niobe Exploration Well will be covered by a drilling specific OPEP. Suncor has access to specialist emergency response services provided by OSRL, Briggs, Wild Well Control and Petrofac’s response centre. Suncor is a member of the OPOL.
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15.0 ENVIRONMENTAL MANAGEMENT As detailed in Section 1, Suncor are the Licence Holder and Operator of Block 12/27, with a 49.5% working interest in the Licence P1889.
15.1 Environmental Principles and Policy One of Suncor’s priorities is to reduce the environmental impact of their operations. In support of this Suncor: conduct their activities consistent with sound environmental management and conservation practices; strive to minimise the environmental impact of their operations; and seek opportunities to transfer expertise in environmental protection to host communities through their operating, hiring, training and contracting practices. Suncor has an integrated Environment, Health and Safety (EHS) Policy Statement approved by their President and Chief Executive Officer (Figure 15.1). This policy statement is adopted and fully supported by the entire organisation and governs the business and operations of the company through a set of underlying goals, including the following: avoiding, minimising or safely managing the impacts of their operations on the natural environment and on the communities in which they operate; supporting research on the health and environmental effects of their products, processes and wastes; avoiding waste and conserving energy and natural resources; setting and reviewing prudent environmental, health and safety targets; and establishing appropriate programmes aimed at compliance with applicable regulatory standards.
15.2 Suncor Corporate Standards Suncor conducts operations within the constraints of an Operational Excellence Management System (OEMS). The framework to meet the requirements of an environmental management system (EMS) is clearly developed within the OEMS. The OEMS was verified as being in accordance with the international standard EN ISO140001:2004 by Lloyds Register during an EMS/OSPAR verification audit undertaken in August 2014. The framework includes Suncor’s corporate standards that set out the systematic approach to the management of loss, integrating reliability and quality with the reduction of risk, to people, the environment, assets and production. Suncor’s corporate standards consist of 18 elements (Figure 15.2).
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Figure 15.1: Suncor’s integrated Environmental, Health and Safety Policy Statement
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Element 1: Leadership and Element 10: Contractor Management. Accountability. Element 11: Data, Document and Element 2: Risk Management. Information Management. Element 3: Legal Requirements and Element 12: Emergency Management. Commitments. Element 13: Communications and Element 4: Goals, Targets and Planning. Stakeholder Relations. Element 5: Management of Change. Element 14: Quality Assurance. Element 6: Structure, Responsibility and Element 15: Incident Management. Authority. Element 16: Audit and Assessments. Element 7: Learning and Competency. Element 17: Corrective Actions. Element 8: Asset Life Cycle. Element 18: Management Review. Element 9: Operations & Maintenance Controls.
Figure 15.2: The 18 elements within Suncor’s corporate standards
The OEMS framework defines the integrated management functions that are required to develop the corporate culture desired by Suncor and the EHS function is fundamental in supporting this work. The OEMS framework of controls includes consistent standards, processes and procedures. It enables Suncor too consistently and effectively: manage risk; operate safe and reliably; mitigate environmental impacts; develop and share best practices; and support continuous improvement. Control of the environmental effects of Suncor’s operations is achieved through adherence to the environmental documents within Elements 1 to 18 (Figure 15.2). Element 2 (Risk Management) identifies management accountabilities necessary to: 1. Identify, assess and monitor the impact of Suncor’s proposed operations on the environment. 2. Reduce As Low As Reasonably Practicable (ALARP) the risk of adverse impact on the environment. 3. Apply prevention of pollution and continual improvement practices.
15.3 Environmental Management System Protection of the environment is a core value within Suncor. It is recognised that effective environmental management can contribute significantly to long-term business success and that minimising the effects on the environment is an integral part of management’s duties and has equal standing with other business objectives.
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To ensure that environmental management is conducted in a planned, controlled and effective manner, Suncor have developed an integrated management system covering Health, Safety and Environment. The system applies to Suncor’s offshore operations in the UKCS and to their offices in the UK. The environmental component of the integrated management system was independently verified in 2014, according to Annex 2 of the Oslo-Paris Convention 2003/5 to promote the Use and Implementation of Environmental Management Systems by the Offshore Industry.
15.4 Niobe Exploration Well Commitments Suncor is committed to environmental protection in this and all its offshore operations. The activities associated with drilling the Niobe Exploration Well will be conducted in accordance with Suncor’s EHS Policy and EMS. The procedures that support this environmental management system will put robust environmental safeguards in place as detailed in this ES. The Niobe Exploration Well specific commitments are listed in Table 15.1.
Table 15.1: Niobe Exploration Well commitments Commitments 1. The mitigation measures identified within this ES, where possible, will be incorporated into operational work programmes. 2. Production of an Environmentally Critical Elements (ECE) Report and Register which: defines the project’s environmental thresholds based on environmental regulation/ risk of environmental incident; identifies environmental hazards and systems that interact with these hazards; and provides a risk and reliability assessment, which identifies ECEs where system failure could potentially lead to threshold exceedance. 3. Development of planned programmes (with performance criteria and validation checks) for the drilling period to ensure the effectiveness of: systems for the routine transfers of diesel, chemicals, wastes and other materials; routine inspection, repair and maintenance systems; systems for reactive (rather than planned) intervention offshore; and plans and systems for the management of spills and other accidental events.
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16.0 REFERENCES ABPmer (2012). Beatrice Offshore Wind Farm Physical Processes Baseline Assessment. For Beatrice Offshore Windfarm Limited. Report R.1795, January 2012. ABPmer (2011). Appendix 7: Anadromous Fish Baseline Review for the DRAFT OWE Plan HRA. Taken from Habitats Regulations Appraisal of Draft Plan for Offshore Wind Energy in Scottish Territorial Waters: Appropriate Assessment Information Review. ACOPS (Advisory Committee on Protection of the Sea, (2013). Annual Survey of Reported Discharges Attributed to Vessels and Offshore Oil and Gas Installations Operating in the United Kingdom Pollution Control Zone 2012. Cambridge, March 2013. Adams, J.A., and Martin, J.H.A. (1986). The hydrography and plankton of the Moray Firth. Proceedings of the Royal Society Edinburgh. 91B, 37 – 56. AEA (Association of European Airlines) (2007). Climate Change Consequences of VOC Emission Controls. A report by AEA Energy & Environment for The Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland. AEAT/ENV/R/2475 - Issue 3. Anatec (2014). Consent to Locate – Niobe Well (Technical Note). Anatec Limited. Document reference: A3464-SUN-CR-1. October 2014. Beaugrand. G. (2003). Long-term changes in copepod abundance and diversity in the north-east Atlantic in relation to fluctuation in the hydroclimatic environment. Fisheries Oceanography. 12 : 270-283. BERR (UK Department for Business, Enterprise and Regulatory Reform) (2008). Atlas of Marine Renewable Energy Resources. http://www.renewables-atlas.info. [Accessed: July 2014]. Berrow, S., Whooley, P., & Ferriss, S. (2002). Irish Whale and Dolphin Group Cetacean Sighting Review (1991-2001): Irish Whale and Dolphin Group. Bjørge, A. and Tolley, K.A. (2002). Harbour Porpoise. In Encyclopedia of Marine Mammals. Perrin, W.F., Würsig, B. and Thewissen, J.G.M. (eds.), pp. 549-551, San Diego, Academic Press. BMT Cordah (2014). Fyne Field Development Environmental Statement. D/4164/2013. Version A. BOWL (Beatrice Offshore Wind Limited) (2012). Environmental Statement – Beatrice Offshore wind farm. Submitted to Marine Scotland, April 2012. Brander, K. (1992). A re-examination of the relationship between cod recruitment and Calanus finmarchicus in the North Sea. ICES J. mar. Sci. Symp. 195: 393-401 BSI (British Standards Institute) (2004). BS EN ISO14001: Environmental management systems – specification with guidance for use. British Standards Institute, London. CEFAS (Centre for Environment, Fisheries and Aquaculture Science) (2014). Use of Action Levels in Dredged Material Assessments. http://www.cefas.defra.gov.uk/media/562541/cefas%20action%20levels.pdf [Accessed October 2014]. CEFAS (2001a). Contaminant Status of the North Sea Centre for Environment, Fisheries and Aquaculture Studies (Technical report TR_004 produced for Strategic Environmental Assessment – SEA2).
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CEFAS (2001b). North Sea Fish and Fisheries. Technical report TR_003 produced for Strategic Environmental Assessment – SEA2. Cheney, B., Thompson, P.M., Ingram, S.N., Hammond, P.S., Stevick, P.T., Durban, J.W., Culloch, R.M., Elwen, S.H., Mandleberg, L., Janik, V., Quick, N.J., Villanueva, V.I., Robinson, K.P., Costa, M., Eisfeld, S.M., Walters, A., Phillips, C., Weir, C.R., Evans, P.G.H, Anderwald, P., Reid, R.J., Reid, J.B. and Wilson, B. (2012a). Integrating multiple data sources to assess the distribution and abundance of bottlenose dolphins (Tursiops truncatus) in Scottish Waters. Marine Mammal Review. Cheney, B., Corkrey, R., Quick, N.J., Janik, V.M., Islas-Villanueva, V., Hammond, P.S. & Thompson, P.M. (2012b). Site Condition Monitoring of bottlenose dolphins within the Moray Firth Special Area of Conservation: 2008 - 2010. Scottish Natural Heritage Commissioned Report No.512. Clark, R.B. (1997). Marine Pollution (4th Edn). Oxford: Clarendon Press. Connor D.W., Allen, J.H., Golding, N., Howell, K.L., Louise, M., Lieberknecht, O., Northen, K. and Reker, J.B. (2004). The Marine Habitat Classification for Britain and Ireland Version 04.05 JNCC, Peterborough. Coull, K.A., Johnstone, R. and Rogers, S.I. (1998). Fisheries Sensitivity Maps in British Waters. Published and distributed by UKOOA Ltd. Crown Estate (2014). Energy and infrastructure shapefiles. http://www.thecrownestate.co.uk/energy-and-infrastructure/downloads/ [Accessed October 2014] Daan, R. and Mulder, M. (1996). On the Short-term and Long-term Impacts of Drilling Activities in the Dutch Sector of the North Sea. Journal of Marine Science. Davies, J., Addy, J., Blackman, R., Blanchard, J., Ferbrache, J., Moore, D., Sommerville, H., Whitehead, A. and Wilkinson, T. (1983). Environmental effects of oil based mud cuttings. Aberdeen, Scotland: UKOOA. DECC (Department for Energy and Climate Change) (2014a). UK Offshore oil and gas infrastructure. https://www.gov.uk/oil-and-gas-offshore-maps-and-gis-shapefiles [Accessed October 2014] DECC (2014b). Licensing information. https://www.gov.uk/oil-and-gas-licensing-rounds [Accessed October 2014] DECC (2012a). http://og.decc.gov.uk/en/olgs/cms/data_maps/field_data/oil_discharged/oil_dischar ged.aspx [Accessed December 2012]. DECC (2012b). Guidance Notes to Operators of UK Offshore Oil and Gas Installations (including pipelines) on Oil Emergency Plan Requirements. July 2012. DECC (2011). Guidance Notes for the Industry. Guidance notes on the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended, 2011). Version No: 2011/0. DECC (2009). Seal at-sea distribution, movements and behaviour. SMRU report to DECC, March 2014. DECC (2004). Physical and Chemical Environment, SEA 5. https://www.gov.uk/government/publications/strategic-environmental-assessment- 5-environmental-report. [Accessed October 2014].
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Dernie, K.M., Kaiser, M.J. and Warwick, R.M. (2003). Recovery rates of Benthic Communities Following Physical Disturbance. Journal of Animal Ecology, 72, 1043- 1056. De Robertis, A. and Handgard, N.O. (2013). Fish avoidance of research vessels and the efficacy of noise-reduced vessels: a review. ICES Journal of Marine Science 70(1):34-45 DTI (Department of Trade and Industry) (2004). Report to the Department of Trade and Industry. Strategic Environmental Assessment of the Mature Areas of the North and Central North Sea SEA5. Consultation Document, September 2001, British Geological Survey. DTI (2002). Strategic Environmental Assessment of the Mature Areas of the Offshore North Sea - SEA 3 Report to the Department of Trade and Industry. Consultation Document, August, 2002. DTI (2001). Strategic Environmental Assessment of the Mature Areas of the Offshore North Sea – SEA 2. Consultation document. DTI, London. EEMS (Environmental Emissions Monitoring System) (2008). EEMS Atmospheric Emissions Calculations. Updated for public area of EEMS replica of Root-5 Version 1.8. Issue 1.89. Ellis, J.R., Milligan, S.P., Readdy, L., Taylor, N. and Brown, M.J. (2012). Spawning and nursery grounds of selected fish species in UK waters. Sci. Ser. Tech. Rep./ CEFAS Lowestoft. 147: 56pp. Ellis, J.R., Milligan, S.P., Readdy, L., Taylor, N. and Brown, M.J. (2010). Spawning and nursery grounds of selected fish species in UK waters. Report to the Department of Environment, Food, and Rural Affairs from CEFAS Ellis, J.R., Cruz-Martínez, A., Rackham, B.D. and Rogers, S.I. (2004) The distribution of Chondrichthyan fishes around the British Isles and implications for conservation. Entec (2010). UK Ships Emissions Inventory. Report on behalf of Defra. November 2010. Ferm, R. (1996). Assessing and managing man-made impacts on the marine environment - The North Sea example. Science of the Total Environment, 186(1-2), 3-11. FishBase (2011). FishBase Databse http://www.fishbase.org/home.htm [Accessed October 2014] Flather, R.A. (1987). Estimates of extreme conditions of tide and surge using a numerical model of the north west European Continental Shelf. Estuarine Coastal and Shelf Science 24: 69 – 93. Folk, R.L. (1954). The distinction between grain size and mineral composition in sedimentary rock nomenclature. Journal of Geology 62 (4), 344-359 Gafeira, J., Green S., Dove, D., Morando, A., Cooper, R., Long, D. and Gatliff R.W. (British Geological Survey) (2010). Developing the necessary data layers for Marine Conservation Zone selection – Distribution of rock/ hard substrate on the UK Continental Shelf. MB0103 Final Report, May 2010. Gardline (2014). UKCS Block 12/27 Kratos Site Survey. Seafloor / HR Seismic Hazard Survey and Habitat Assessment. Report for Suncor Energy UK Limited. Genesis (2014).Underwater sound impact assessment – Kratos site survey. Technical Note. June 2014.
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Genesis (2011). Review and Assessment of Underwater Sound Produced from Oil and Gas Sound Activities and Potential Reporting Requirements under the Marine Strategy Framework Directive. Genesis Oil and Gas Consultants Report for DECC, J71656. Gray, J. S., Wu, R. S. S., & Or, Y. Y. (2002). Effects of hypoxia and organic enrichment on the coastal marine environment. Marine Ecology Progress Series, 238. Hammond, P.S., Berggren, P., Benke, H., Borchers, D.L., Collet, A., Heide-Jorgensen, M.P., Heimlich, S., Hiby, A.R., Leopold, M.F. and Oien, N., (2002). Abundance of harbour porpoises and other cetaceans in the North Sea and adjacent waters. Journal of Applied Ecology 39: 361-376. Hannay, D.E. and MacGillivray, A. (2005). Comparative Environmental Analysis of the Piltun-Astokh Field Pipeline Route Options: Sakhalin Energy Investment Company Ltd. Harland, E., Jones, S. and Clarke, T. (2005). Sea 6 Technical Report: Underwater Ambient Noise. Report by Qinetiq to Department of Trade and Industry (Dti) for the Sixth Offshore Energy Strategic Environmental Assessment (Sea6) Programme (No. Report reference: QINETIQ/S&E/MAC/CR050575). Hartley Anderson Ltd (2001). An overview of offshore oil and gas exploration and production activities. Report prepared for DTI SEA by Hartley Anderson Ltd. Hartley, J., Trueman, R., Anderson, S., Neff, J., Fucik, K. and Dando, P. (2003). Drill cuttings initiative: food chain effects literature review. Aberdeen, Scotland: UKOAA. Holland, K.T. and Elmore, P.A. (2008) A Review of Heterogeneous Sediments in Coastal Environments. Earth Science Reviews, Vol. 89 (3-4), pp 116-134. HSE (Health and Safety Executive) (2002). Hazard Assessment of well operations from vessels. Team Energy Resources Limited for the Health and Safety executive Research report 013. ISBN 0 7176 2553 2. IoP (Institute of Petroleum) (2000). Guidelines for the Calculation of Estimates of Energy Use and Gaseous Emissions in the Decommissioning of Offshore Structures. ISBN 0 85293 255 3. IPCC (Intergovernmental Panel on Climate Change) (2001). The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, Tignor, M., and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 996 pp. Ithaca (Ithaca Energy (UK) Limited) (2008). Environmental Statement of the Jacky Development in Block 12/21c. BERR Project Reference D/3964/2008. Submitted April 2008. Ithaca (2007). Environmental Statement – Exploration Well Block 12/26c. Ithaca Energy (UK) Limited. September 2007. Project reference number: W/3788/2006. Ithaca (2006). Environmental Statement for the Appraisal Well in Block 12/21c. DTI Project Reference Number W/3451/2006. Submitted November 2006. ITOPF (International Tanker Owners Pollution Federation Limited) (2012). Response to Marine Oil Spills. 2nd Edition. Jones, E., McConnell, B., Sparling, C. and Matthiopoulos, J. (2013). Grey and Harbour Seal density maps. Marine mammal scientific support research programme (MMSS/001/11). Sea Mammal Research Unit report to the Scottish Government.
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JNCC (Joint Nature Conservation Committee) (2014a). Annex I and II species occurring in the UK. http://jncc.defra.gov.uk/page-1523 [Accessed October 2014]. JNCC (2014b). Marine Protected Areas. http://jncc.defra.gov.uk/marineprotectedareas [Accessed October 2014]. JNCC (2014c). http://jncc.defra.gov.uk/ [Date Accessed: October 2014] JNCC (2014d). Protected site shapefiles. http://jncc.defra.gov.uk/protectedsites/SACselection/gis_data/terms_conditions.asp [Date Accessed: November 2014] JNCC (2012). Marine Renewables – Ducted Propellers and Seal Interactions Guidance Document. per comms, Sonia Mendes: email dated 21/07/2014. JNCC (2010a). UKSeaMap – Energy at seabed due to combined effects of currents and waves. http://jncc.defra.gov.uk/page-2117 [Accessed October 2014]. JNCC (2010b). Atlantic salmon. http://www.jncc.gov.uk/ProtectedSites/SACselection/species.asp?FeatureIntCode= S1106. [Accessed October 2014]. JNCC (2010c). The Protection of Marine European Protected Species from Injury and Disturbance. Guidance for the Marine Area in England and Wales and the Uk Offshore Marine Area. JNCC (2002). Natura 2000 in UK Offshore Waters: Advice to support the implementation of the EC Habitats and Birds Directives in UK offshore waters. JNCC Report 325. JNCC (1999). Seabird vulnerability in UK waters: Block specific vulnerability. JNCC Report, No. 297 Kennedy, A.D. and Jacoby, C.A. (1999). Biological indicators of marine environmental health: Meiofauna — a neglected benthic component? Environmental Monitoring and Assessment, 54, pp. 47–68. Kroncke, I., Duineveld, G.C.A., Raak, S., Rachor, E. and Daan, R. (1992). Effects of a former discharge of drill cuttings on the macrofauna community. Marine Ecology Progress Series, 91(1-3), 277-287. MacLeod C.D, Santos M.B, Reid R.J, Scott B.E and Pierce G.J. (2007). Linking sandeel consumption and the likelihood of starvation in harbour porpoises in the Scottish North Sea: could climate change mean more starving porpoises?. Biol. Lett 3, 185– 188. Malcolm, I.A., Godfrey, J. and Youngson, A.F. (2010). Review of migratory routes and behaviour of Atlantic Salmon, Sea Trout and European Eel in Scotland’s coastal environment: Implications for the Development of Marine Renewables. MAREMAP (2010). Marine Environmental Mapping Programme. http://www.maremap.ac.uk. [Accessed October 2014] Marine Scotland (2014a). Various environmental baseline shapefiles. http://www.scotland.gov.uk/Topics/marine/science/MSInteractive [Date Accessed: November 2014] Marine Scotland (2014b). Nephrops: http://www.scotland.gov.uk/Topics/marine/marine- environment/species/fish/shellfish/nephrops [Accessed October 2014] Marine Scotland (2013). Relative value and effort maps for demersal, pelagic and shellfish fisheries based on all landings into the UK and all landings abroad by UK vessels in 2010. Produced by the Marine Scotland Science Division.
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Mitson, R.B. and Knudsen, H.P. (2003). Causes and effects of underwater noise on fish abundance estimation. Aquatic Living Resources 16:255-263 Moray Firth Partnership (2014a). Information on aquaculture in the Moray Firth. http://morayfirth-partnership.org/695.html [website accessed: August 2014] Moray Firth Partnership (2014b). Information on Moray Firth coastal fisheries. http://morayfirth-partnership.org/fisheries.html [website accessed: August 2014] Moray Firth Partnership (2014c). Information on Moray Firth coastal heritage and archaeology. http://morayfirth-partnership.org/archaeology.html [website accessed: August 2014]. Moray Firth Partnership (2011). Towards sustainable recreation, tourism and conservation of the Moray Firth. A report looking at culture and future issues facing the Moray Firth. MORL (Moray Offshore Renewables Limited) (2012a). Environmental Statement. Technical Appendix 3.4A – Metocean and Coastal Processes Baseline. MORL (2012b). Environmental Statement. Project Details, Chapter 2. MORL (2012c). Environmental Statement. Technical Appendix 4.2A – Benthic Ecology Characterisation Study (Wind Farm Sites). MORL (2012d). Environmental Statement. Biological Environment Baseline, Chapter 4. MORL (2012e). Environmental Statement. Technical Appendix 4.3B – Salmon, Sea Trout and Fisheries Technical Report. MORL (2010). Eastern Area Scoping Report for the Moray Offshore Renewables Limited Windfarm. Moray Offshore Renewables Limited. Nedwell, J.R., Workman, R. and Parvin, S.J. (2005). The Assessment of Likely Levels of Piling Noise at Greater Gabbard and Its Comparison with Background Noise , Including Piling Noise Measurements Made at Kentish Flats . Nedwell, J.R. and Edwards, B. (2004). A Review of Measurements of Underwater Man- Made Noise Carried out by Subacoustech Ltd , 1993 – 2003. Subacoustech Ltd Report Ref 534r0109. Neff, J.M. (2005). Composition, environmental fates, and biological effects of water based drilling muds and cuttings discharged to the marine environment. Petroleum Environmental Research Forum (PERF) and American Petroleum Institute. NOAA (National Oceanic and Atmospheric Administration) (2013). Draft Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammals. Draft 23 December 2013. Northridge, S.P., Tasker, M.L., Webb, A. and Williams, J.M. (1995). Distribution and relative abundance of harbour porpoise (Phocoena phocoena L.), white-beaked dolphins (Lagenorhynchus albirostris Gray), and minke whales (Balaenoptera acutorostrata Lacepede) around the British Isles. ICES Journal of Marine Science 52: 55-56. NRC (National Research Council) (2003). Ocean Noise and Marine Mammals. (No. National Reasearch Council of the National Academies, Washingon DC). NSTF (North Sea Task Force) (1993). North Sea Quality Status Report 1993. North Sea Task Force. Oslo and Paris Commissions, London. Oil and Gas UK (2012). EEMS Annual Report, 2010. Key UK Oil and Gas Industry Environmental Data. (April 2012).
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Olsgard, F., Somerfield, P.J. and Carr, M.R. (1997). Relationships between taxonomic resolution and data transformations in analyses of a macrobenthic community along an established pollution gradient Marine Ecology Progress Series OSPAR (OSPAR Commission) (2010). Background Document for Atlantic Salmon Salmo salar. Biodiversity series report. OSPAR Commission. OSPAR (2009). Assessment of impacts of offshore oil and gas activities in the North- East Atlantic. Offshore Industry Series Report. OSPAR Commission. OSPAR (2008). List of Threatened and/or Declining Species and Habitats Reference Number: 2008-6. OSPAR (2005). Agreement on background concentrations for contaminants in seawater, biota and sediment. OSPAR Commission. OSPAR (2000). Quality Status Report 2000, Region II Greater North Sea. OSPAR Commission Perry, R. (1993). The Braer oil spill. Proceedings of the 1995 International Oil Spill Conference, Long Beach California. Plante-Cuny, M.R., Salen-Picard, C., Grenz, C., Plante, R., Alliot, E. and Barranguet, C. (1993). Experimental field study of the effects of crude oil, drill cuttings and natural biodeposits on microphyto- and macrozoobenthic communities in a Mediterranean area. Marine Biology, 117(2), 355-366. Popper, A.N. and Hastings, M.C. (2009). The Effects of Anthropogenic Sources of Sound on Fishes. Journal of Fish Biology, 75(3), 455-489. Popper, A.N. (2003). Effects of Anthropogenic Sounds on Fishes. Fisheries, 28(10), 24- 31.
RAMSAR (2014). Information on the purpose of RAMSAR. http://www.ramsar.org/cda/en/ramsar-home/main/ramsar/1_4000_0__ [website accessed: August 2014] Rees, H.L., Eggleton, J.D., Rachor, E. and Vanden Berghe, E. (2007). Structure and dynamics of the North Sea benthos. ICES Cooperative Research Report No. 288 Reid, J.B., Evans, P.G.H. and Northridge, S.P. (2003). Atlas of Cetacean Distribution in Northwest European Waters. JNCC, Peterborough. Richardson, W.J., Greene Jr., C.R., Malme, C.I. and Thomson, D.H. (1995). Marine Mammals and Noise. Academic Press, San Diego. Rogan, E. and Berrow, S.D. (1996). A Review of harbour porpoises, Phocoena phocoena, in Irish waters. Report of the International Whaling Commission 46, 595-605. SCANS (Small Cetaceans in the European Atlantic and North Sea) II (2006) SCANS II: Small Cetaceans in the European Atlantic and North Sea, Quarterly Newsletter Issue 7: June 2006. SCOS (Special Committee on Seals) 2009. Scientific advice on matters related to the management of seals. SCOS Report 2009. Scottish Government (2014). Marine Protected Area Designations. http://www.scotland.gov.uk/Topics/marine/marine- environment/mpanetwork/developing/DesignationOrders [Accessed: October 2014). SeaFish (2012). Sustainable sourcing guide – Cod. Information based on ICES 2012 advice.
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Seawatch (Seawatch Foundation) (2012). Long-finned pilot whale in UK Waters. http://seawatchfoundation.org.uk/wp-content/uploads/2012/07/Long- finned_Pilot_Whale.pdf. [Accessed October 2014]. SeaZone Wrecks (2013). SeaZone Wrecks http://www.seazone.com/dataCatalogue.php © British Crown Copyright, 2013. All rights reserved. [Accessed October 2014] SMRU (Sea Mammal Research Unit) (2013). Current State of Knowledge of the Extent, Causes and Population Effects of Unusual Mortality Events in Scottish Seals. Thompson, D., Culloch, R. and Milne, R. Sea Mammal Research Unit Report to Scottish Government. April 2013. SMRU (2001). Background information on marine mammals relevant to SEA2. Strategic Environmental Assessment - SEA2 Technical Report 006 - Marine Mammals. SNH (Scottish Natural Heritage) (2014a). East Caithness Cliffs MPA. http://www.snh.gov.uk/protecting-scotlands-nature/protected-areas/national- designations/mpas/mpa-ecc/ [Accessed October 2014]. SNH (2014b). Noss Head MPA. http://www.snh.gov.uk/protecting-scotlands- nature/protected-areas/national-designations/mpas/mpa-noh/ [Accessed October 2014]. SNH (2014c). Information on Scottish MPAs. http://www.snh.gov.uk/protecting-scotlands- nature/protected-areas/national-designations/marine-protected-areas-(mpa)/ [website accessed: August 2014]. SNH (2014d). Information on National Nature Reserves. http://www.snh.gov.uk/protecting-scotlands-nature/protected-areas/national- designations/nnr/in-scotland/ [website accessed: August 2014]. SNH (2014e). Information on RAMSAR. http://www.snh.gov.uk/protecting-scotlands- nature/protected-areas/international-designations/ramsar-sites/ [website accessed: August 2014] SNH (2014f). Information on SSSIs. http://www.snh.gov.uk/protecting-scotlands- nature/protected-areas/national-designations/sssis/ [website accessed: August 2014] SNH (2014g). Information on biogenetic reserves. http://www.snh.gov.uk/protecting- scotlands-nature/protected-areas/international-designations/biogenetic-reserves/ [website accessed: August 2014] SNH (2014h). Protected areas shapefiles. https://gateway.snh.gov.uk/natural- spaces/index.jsp [Date Accessed: November 2014] SNH (2012). Scottish MPA Project, Data confidence Assessment – Southern Trench MPA Search Location. Scottish Natural Heritage. October 2012. SNH (2010). Otters and Development. Scottish Wildlife Series. http://www.snh.org.uk/publications/on-line/wildlife/otters/law.asp [Accessed November 2013] SNH (2009). Citation for Special Protection Area (SPA), Troup, Pennan and Lion’s Heads (UK9002471) Including Marine Extension. SNH (1994). Special Protection Area (SPA) Citation for Public Issue, Loch of Strathbeg, Banff & Buchan. Sonntag, R.P., Benke, H., Hiby, A.R., Lick, R. and Adelung, D. (1999). Identification of the first harbour porpoise (Phocoena phocoena) calving ground in the North Sea. Journal of Sea Research 41: 225-232.
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Southall, B.L., Bowles, A.E., Ellison, W.T., Finneran, J.J., Gentry, R.L., Greene, C.R., et al. (2007). Marine Mammal Noise Special Issue: Exposure Criteria: Initial Scientific Recommendations Aquatic Mammals. Stone, C.J. (2001). Marine Mammal Observations during Seismic Surveys in 1999. JNCC Report No. 316. Stone, C.J. (1997). Cetacean Observations during Seismic Surveys in 1996. JNCC Report No. 228. Strachan, R. (2007). National survey of otter Lutra lutra distribution in Scotland 2003–04. Scottish Natural Heritage Commissioned Report No. 211 (ROAME No. F03AC309). Thompson, D. and Härkönen, T. (2008). Halichoerus grypus. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.1 http://www.iucnredlist.org/details/9660/0 [Accessed October 2014]. Thompson, P.M., Corkrey, R., Lusseau, D., Lusseau, S., Quick, N., Durban, J.W., Parsons, K.M. and Hammond, P.S. (2006). An assessment of the current condition of the Moray Firth bottlenose dolphin population. Scottish Natural Heritage Commissioned Report No. 175 (ROAME No. F02AC409). Thompson, P.M., Cheney, B., Ingram, S., Stevick, P., Wilson, B. and Hammond, P.S. (Eds) (2009). Distribution, abundance and population structure of bottlenose dolphins in Scottish waters. Scottish Natural Heritage Commissioned Report. UKDMAP (United Kingdom Digital Marine Atlas) (1998). United Kingdom Digital Marine Atlas – An Atlas of the Sea around the British Isles. 3rd Edition Software by the British Oceanographic Data Centre, Birkenhead. UK Oil and Gas Data (2014). UK Oil and Gas infrastructure shapefiles. https://www.ukoilandgasdata.com/dp/pages/apptab/ITabManager.jsp [Accessed October 2014] UKOOA (UK Offshore Operators Associaton) (2006). Report on the analysis of DTI UKCS oil spill data from the period 1975 – 2005. October 2006. A report prepared by TINA Consultants Ltd. UKOOA (2002). Environmental emissions monitoring system (EEMS). Guidelines for compilation of an atmospheric emissions inventory. UKOOA, December 2002. UKOOA (2001). An Analysis of U.K. Offshore Oil and Gas Environmental Surveys 1975- 95. Available from Oil and Gas UK. UKOOA (2000). Guidelines for Quantitative Risk Assessment Uncertainty – Iss.1. UKOOA (1999). A frameworks for risk related decision support—industry guidelines. UK Offshore Operators Association. Van Brummelen, T.C., Van Hattum, B., Crommentuijn, T. and Kalf, D.F. (1998). Bioavailability and ecotoxicity of PAHs. In: The handbook of environmental chemistry Springer-Verlag, Berlin. Wang, F. and Chapman, P.M. (1999). Biological implications of sulfide in sediment : A review focusing on sediment toxicity (Vol. 18). Pensacola, FL, ETATS-UNIS: SETAC. Williams, J.M., Tasker, M.L., Carter, I.C. and Webb, A. (1994). A Method of Assessing Seabird Vulnerability to Surface Pollutants. Seabirds and Cetaceans Branch, Joint Nature Conservation Committee. Ibis 137: S147-S152. Wu, R.S.S. (2002). Hypoxia: from Molecular Responses to Ecosystem Responses. Marine Pollution Bulletin, 45(1–12), 35-45.
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WWF (World Wildlife Fund) (2001). Now or Never. The Cost of Canada’s Cod Collapse and Disturbing Parallels with the UK. A WWF report, Malcolm MacGarvin. Young, I.A.G., Pierce, G.J., Stowasser, G., Santos, M.B., Wang, J., Boyle, P.R., Shaw, P.W., Bailey, N., Tuck, I. and Collins, M.A. (2006). The Moray Firth directed squid fishery. Fisheries Research, 78, 39-43.
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Appendix A
Summary of Relevant Petroleum and Environmental Legislation
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A.1: General Regulatory Body Legislation Summary of Requirements The MARPOL Convention is the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes and covers pollution by oil, chemicals, harmful substances in packaged form, sewage and garbage. The MCA has regulatory authority over those aspects of the offshore oil and gas industry that fall under the MARPOL Convention 73/78, including machinery space discharge, sewage discharges and garbage at sea. The Convention currently includes six technical Annexes: Maritime and Annex I Regulations for the Prevention of Pollution by Oil (entered into force 2 October 1983) Coastguard Agency MARPOL 73/78 Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk (entered into force 2 October 1983) (MCA) Annex III Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form (entered into force 1 July 1992) Annex IV Prevention of Pollution by Sewage from Ships (entered into force 27 September 2003) Annex V Prevention of Pollution by Garbage from Ships (entered into force 31 December 1988) Annex VI Prevention of Air Pollution from Ships (entered into force 19 May 2005)
A.2: Atmospheric emissions Regulatory Body Legislation Summary of Requirements Annex VI is concerned with the control of emissions of ozone depleting substances, NOx, SOx, and VOCs and require ships (including platforms and drilling rigs) to be issued with an International Air Pollution Certificate following survey. This annex set limits on sulphur oxide and nitrogen oxide emissions from ship exhausts as well as particulate matter and prohibit deliberate emissions of ozone depleting substances. MARPOL 73/78 Annex VI the Prevention of Air MCA Emissions arising directly from the exploration, exploitation and associated offshore processing of seabed mineral resources are exempt from Annex VI, including the following: Pollution from Ships emissions resulting from flaring, burning of cuttings, muds, well clean-up emissions and well testing; release of gases entrained in drilling fluids and cuttings; emissions from treatment, handling and storage of reservoir hydrocarbons; and emissions from diesel engines solely dedicated to the exploitation of seabed mineral resources.
Petroleum Act 1998 The objective of this Act is to conserve gas, as a finite energy resource, by avoiding unnecessary wastage during the production of hydrocarbons in the UKCS.
The actual Model Clause may vary depending on when the Block Licence was granted, but in recent licences flaring is covered by Paragraph 3 of Model Clause 23, and this states Petroleum Licensing (Production) (Seaward Areas) that the Licensee shall not flare any gas from the licensed area or use gas for gas lift except with written consent. If intending to flare gas during the operational phase of the field, Regulations 2008 (2008/225) flare consent will need to be obtained. Requires operators to obtain consent for venting of gas. Some flaring which has not been permitted under the licence model clauses is covered by this legislation, although it is The Energy Act 1976 mostly used for issue of vent consents. These regulations transpose EC Directive on national emission ceilings for certain atmospheric pollutants 2001/81/EC into UK law and set national ceilings and a requirement for The National Emission Ceilings Regulations 2002 the development of a reduction programme for SOx, NOx and VOCs and set out the UK government commitment for achieving a reduction of atmospheric emissions by 2010 and DECC thereafter not to exceed the amounts specified in the Schedule of that pollutant. These regulations implement Annex VI of MARPOL (the International Convention for the Prevention of Pollution from Ships 73/78) in the UK. The Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008 (as amended 2010) The 2010 Amendments primarily implement provisions concerning the sulphur content of marine fuels contained in Council Directive 1999/32/EC. The Directive sets maximum sulphur content for fuel including heavy fuel oil and gas oil including marine fuel. The Act sets up a framework for the UK to achieve its long-term goals of reducing greenhouse gas emissions and to ensure actions are taken towards adapting to the impact of Climate Change Act 2008 climate change. The Act enables a number of elements, including amongst others; setting medium and long-term emissions reduction targets in statute, introduction of a system of carbon budgeting which constrains the total amount of emissions in a given time period, a new reporting framework for annual reporting of the UK’s greenhouse gas emissions, Climate Change (Scotland) Act 2009 creation of an independent advisory body (the Committee on Climate Change). As a result of the Act and the 2009 Order, the current legally-binding targets for the net UK carbon account are: 34% reduction by 2020 and 80% reduction by 2050, against a 1990 baseline.
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A.2 (continued): Atmospheric emissions Regulatory Body Legislation Summary of Requirements Offshore Combustion Installations (Prevention and The 2013 regulations transpose the relevant provisions of the Industrial Emissions Directive 2010/75/EU in respect to specific atmospheric pollutants from combustion installations Control of Pollution) Regulations 2013. with a thermal capacity rating in excess of 50 MW on offshore platforms undertaking oil and gas production and gas and CO2 unloading and storage. In this context, the obligations of the 2013 regulations on the offshore oil and gas industry basically mirror those of the Offshore Combustion Installations PPC Regulations 2001 (as amended). The aim of the PPC is to consider environmental impacts holistically and to achieve a higher level of environmental protection. The regulations apply only to combustion installations with a combined rated thermal input exceeding 50 MW(th) and a PPC Permit will be required in order to operate a qualifying offshore installation. The permit will be granted with conditions that include provisions based on best available techniques, emission limits, and monitoring requirements. The 2009 Regulations revoke and replace the 2008 Regulations and prescribe offences and penalties applicable to infringements of EU Regulation 842/2006 on certain fluorinated The Fluorinated Greenhouse Gases Regulations 2009 greenhouse gases (F gases), amongst others, as well as dealing with other requirements relating to leakage checking, reporting and labelling, together with proposed powers for DECC (as amended) authorised persons to enforce these Regulations. The Environmental Protection (Controls on Ozone The 2011 regulations revoke and replace the previous regulations. These Regulations make provision in the UK for EC Regulation 1005/2009 which controls the production, impact, Depleting Substances) Regulations 2011 export, placing on the market, recovery, recycling, reclamation and destruction of substances that deplete the ozone layer. The Act implements the IPPC Directive into UK law. It is written so as to enable the prevention or, where not possible, the reduction of pollution by means of an integrated The Pollution Prevention and Control Act 1999 (as permitting process based on the application of Best Available Techniques (BAT). The aim is to achieve a high level of environmental protection with the requirement of pollutant amended) emissions to air, water and land; energy efficiency; consumption of raw materials; noise/vibration; heat/light; pollution prevention; waste management; and site restoration to be taken into account.
A.3: Environmental Impact Assessment Regulatory Body Legislation Summary of Requirements Council Directive on the Assessment of the Effects of The EIA Directive (85/337/EEC) has been in force since 1985 and applies to a wide range of defined public and private projects, which are defined in Annexes I and II: Certain Public and Private Activities on the Annex 1: all projects listed in Annex I are considered as having significant effects on the environment and require a mandatory EIA. Typical projects include, for example: Environment - 85/337/EEC (the EIA Directive) as Extraction of petroleum and natural gas for commercial purposes where the amount extracted exceeds 500 tonnes/day in the case of petroleum and 500,000 cubic metres/day in amended by Directives 97/11/EC, 2003/35/EC the case of gas. and2009/31/EC. Pipelines with a diameter of more than 800 mm and a length of more than 40 km:
for the transport of gas, oil, chemicals; for the transport of carbon dioxide (CO2 ) streams for the purposes of geological storage, including associated booster stations. Installations for storage of petroleum, petrochemical, or chemical products with a capacity of 200,000 tonnes or more. DECC Annex 2: EIA is discretionary where the national authorities decide whether an EIA is needed. This is done by the "screening procedure", which determines the effects of projects on the basis of thresholds/criteria or a case by case examination.
EC Directive 2011/92/EU on the assessment of the The EC Directive 2012/92/EU revokes the 85/337/EEC and the 97/11/EC Directives and amends the 2003/35/EC directive. The 2012/92/EU lists two classes of project to which the effects of certain public and private projects on the Directive applies: Annex 1 Projects for which environmental assessment (EA) is mandatory; and Annex 2 projects for which EA is discretionary. Under 2012/92/EU, oil and gas environment developments are listed as Annex 1 projects. OSPAR Recommendation 2010/5 on assessments of The purpose of this Recommendation is to support the protection and conservation of species and habitats on the OSPAR List of threatened and/or declining species and habitats, environmental impact in relation to threatened and/or through assessments of environmental impacts of human activities. When assessments of environmental impacts of human activities that may affect the marine environment of the declining species and habitats OSPAR (Oslo and Paris Conventions) maritime area are prepared, Contracting Parties should ensure they take account of the relevant species and habitats on the OSPAR List of threatened and/or declining species and habitats (OSPAR Agreement 2008/6).
A.4: Access to Environmental Information and Public Participation Regulatory Body Legislation Summary of Requirements Directive 2003/4/EC of the European Parliament and This Directive transposes the first pillar of the Aarhus convention on access to information into EU legislation. This Directive requires all public authorities to provide members of of the Council of 28 January 2003 on public access to the public with access to environmental information, and to actively disseminate the environmental information they hold. The information must be provided to any person at their environmental information and repealing Council request, without them having to prove an interest and at the latest within two months of the request being made. The Directive is implemented in Scotland by The Environmental Directive 90/313/EEC Information (Scotland) Regulations 2004. DECC The Environmental Information (Scotland) Regulations 2004 Public Participation Directive (PPD) 2003/35/EC Provides for public participation in the preparation of environmental plans, programmes and projects with significant environmental impacts. See section on environmental impact assessment.
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A.5: Conservation and Biodiversity Regulatory Body Legislation Summary of Requirements These Regulations make provision for implementing the Birds Directive and Habitats Directive in relation to marine areas where the United Kingdom has jurisdiction beyond its territorial sea. The Regulations make provision for the selection, registration and notification of sites in the offshore marine area (European Offshore Marine Sites) and for the management of these sites. Competent authorities are required to ensure that steps are taken to avoid the disturbance of species and deterioration of habitat in respect of the The Offshore Marine Conservation (Natural Habitats, offshore marine sites and that any significant effects are considered before authorisation of certain plans or projects. Provisions are also in place for issuing of European Protected &c.) Regulations 2007 as amended (2010) Species (EPC) licences for certain activities and for undertaking monitoring and surveillance of offshore marine sites. The 2010 Amendment Regulations make various insertions for The Offshore Petroleum Activities (Conservation of new enactments (e.g. new Birds Directive) and also devolve certain powers to Scottish Ministers. Most recent amendments to the 2007 and 2010 regulations are: Habitats) Regulations 2001 (as amended 2007) The Conservation (Natural Habitats, &c.) Amendment (Scotland) Regulations 2011. The Conservation of Habitats and Species (Amendment) Regulations 2011.
The Conservation (Natural Habitats, &c.) Regulations 1994 (and all amendments) transpose the Habitats and Birds Directive into UK Law. These Regulations provide for the designation and protection of 'European Sites'. The protection of 'European Protected Species' (EPS) and the adoption of planning and other controls for the protection of European The Conservation of Habitats and Species Sites only as far as the limit of territorial waters (12nm from the coastline). Regulations 2010 (as amended 2012) and the
Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) The Conservation of Habitats and Species Regulations 2010 consolidate all amendments made to the 1994 regulations in England and Wales. Whereas, in Scotland, the Habitats and Birds Directives are transposed through a combination of the 2010 and 1994 regulations. The Conservation of Habitats and Species Regulations 2010 also implement aspects of the Marine and Coastal Access Act (2009). The Marine Strategy Regulations 2010 The Marine Strategy Framework Directive (MSFD) has been transposed into UK domestic legislation by The Marine Strategy Regulations 2010. These set out that Scottish Ministers are the competent authority for the Directive out to 200 nautical miles. They also set out the framework of co-operation and consent that exists between the UK administrations in terms of developing a UK-wide Marine Strategy. From a Scottish perspective, this can be summarised as follows: Each element of the Marine Strategy formally submitted by UK Ministers (2012) will be led by the UK with strong input from Scottish Ministers (in practice this means Scottish policy makers, scientists and stakeholders). Scottish Ministers will take the lead in developing a monitoring programme and establishing and reviewing the programme of measures for Scottish waters. Each UK Administration has a duty to co-ordinate activity to ensure consistency in developing a Marine Strategy. DECC, JNCC, SNH, The UK Government must obtain the consent of Scottish Ministers before adopting any element of the Strategy which affects or is likely to affect the exercise of any devolved DEFRA function. Such consent must also be sought when exercising functions for the purpose of implementing the Directive. Scottish Ministers must seek the consent of the relevant UK Minister if making any proposals which affect or are likely to affect reserved functions. Such consent must also be sought when exercising functions for the purpose of implementing the Directive. Scottish Ministers must co-operate in exercising any relevant function to implement the strategy. UK Ministers must do likewise. Marine and Coastal Access Act 2009 As of 24 July 2014, 30 MPAs have been designated under the Marine (Scotland) Act and the UK Marine and Coastal Access Act. These will be incorporated into the National Marine (Scotland) Act 2010 Marine Plan and represented in National Marine Plan interactive alongside existing protected areas. Of the 30 MPAs, 17 fall under the Marine (Scotland) Act 2010 in Scottish territorial waters and 13 under the Marine and Coastal Access Act 2009. These 30 have been recommended by Scottish Natural Heritage (SNH) for inshore waters and the Joint Nature Conservation Committee (JNCC) for offshore waters. These designations fulfil duties in the Marine (Scotland) Act and the UK Marine and Coastal Access Act 2009, as well as furthering commitments to form part of the wider UK contribution to the OSPAR North-East Atlantic MPA network. In Scotland, the coasts and seas provide food, energy sources (wind, wave and tidal power, minerals and fossil fuels), routes and harbours for shipping, tourism and recreational opportunities and sites of cultural and historical interest. They also contain distinctive and important habitats and support a diverse range of species which we need to protect, conserve and enhance. These all need to be managed effectively. The introduction of the Marine (Scotland) Act means better management of the competing demands on marine resources is key and Marine Scotland is involved at various levels: A national level, by creating Scotland's first National Marine Plan A regional level, by creating Scottish Marine Regions and Sectoral Planning, for offshore renewable energy More widely, by working with a range of others within UK and Europe Wildlife and Countryside Act 1981 (as amended 1991) JNCC delivers the UK and international responsibilities of the four country nature conservation agencies - Council for Nature Conservation and the Countryside, Natural Resources Wales, Natural England and Scottish Natural Heritage. JNCC, originally established under the Environmental Protection Act 1990, was reconstituted by the Natural Environment Wildlife and Countryside Act 1981 (Amendment) and Rural Communities Act 2006. JNCC, working with the nature conservation agencies, is the focus for the guidelines for the selection of biological Sites of Special Scientific (Scotland) Regulations 2001 Interest (SSSIs) and a statutory consultee for oil & gas ESs.
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A.6: Emergency response Regulatory Body Legislation Summary of Requirements These Regulations entered into force in July 2002 and implement the recommendations from Lord Donaldson's review of “Salvage and Intervention and their Command and The Offshore Installations (Emergency Pollution Control” insofar as they relate to the oil and gas industry. The Regulations give the Representative of the Secretary of State for Energy and Climate Change (SOSREP) powers to Control) Regulations 2002 intervene in the event of an incident involving an offshore installation where there is, or may be, a risk of significant pollution, or where an operator is failing or has failed to DECC implement effective control and preventative operations. The Offshore Petroleum Activities (Oil Pollution Under these Regulations, it is an offence to make an unlawful release of oil, i.e. a release of oil other than in accordance with the permit granted under these Regulations for oily Prevention and Control) Regulations 2005 (as discharges (e.g. produced water etc.). However, it will be a defence to prove that the contravention arose because of something that could not have been reasonably prevented, or amended 2011) that it was undertaken as a matter of urgency for the purposes of securing the safety of any person. This recommendation came into force in September 2010 and establishes a process for assessing the relevance of the results of the US and EC reviews of the Macondo well incident with a view to taking additional action by the OSPAR Commission if needed and within the scope of the Convention. Under the recommendation, contracting parties are required to: OSPAR Recommendation 2010/18 on the prevention As a precaution continue or, as a matter of urgency, start reviewing existing frameworks, including the permitting of drilling activities in extreme conditions; and continue to of significant acute oil pollution from offshore drilling evaluate this on a case by case basis and prior to permitting; activities Take extra care to apply all relevant learning from the Deepwater Horizon accident; Report on this ongoing activity to OSPAR; and DECC Based on the reviews undertaken, contracting parties should individually and jointly, if needed, take further action within the scope of the OSPAR Convention. The Merchant Shipping Act 1995 implements in the UK the OPRC Convention. The aim of the OPRC Convention is to increase the level of effective response to oil pollution Merchant Shipping Act 1995 incidents and to promote international co-operation to this end. The Convention applies to ships and offshore installations and requires operators to have in place Oil Pollution Emergency Plans (OPEP), which are approved by the body that is the National Competent Authority for the Convention. The Merchant Shipping (Oil Pollution Preparedness, The Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998 introduce into UK law the oil spill planning requirements and legal Response and Co-operation) Regulations 1998 (as oil spill reporting requirements of the OPRC Convention. amended 2001)
A.7: Environmental Liability Regulatory Body Legislation Summary of Requirements The Environmental Liability Directive enforces strict liability for prevention and remediation of environmental damage to ‘biodiversity’, water and land from specified activities and remediation of environmental damage for all other activities through fault or negligence. Directive 2004/35/CE of the European Parliament and The EC has published a communication (the Communication) on "facing the challenge of the safety of offshore oil and gas activities". the Council of 21 April 2004 on environmental liability The European Commission is set to review the liability regime applicable to offshore petroleum activities and is: with regard to the prevention and remedying of Proposing amendments to the Environmental Liability Directive (2004/35/EC, as amended by Directive 2006/21/EC) so that it covers environmental damage to all marine waters DEFRA environmental damage. (as defined in the Marine Strategy Framework Directive 2008/56/EC). The Environmental Damage (Prevention and Re-considering introducing a mandatory requirement for operators to provide financial security in the event that a major accident occurs. Remediation) Regulations 2009 Considering, in a guidance document interpreting existing legislation, the applicability of the Waste Framework Directive (2008/98/EC) to oil spills. The Regulations supplement existing environmental protection legislation such as the Environmental Protection Act 1990, the Water Resources Act 1991 or the Wildlife and Countryside Act 1981 and the Control of Major Accident Hazards Regulations 1999. SEPA, MS and SNH The Environmental Liability (Scotland) Regulations These Regulations implement the EC Environmental Liability Directive in Scotland. The regulations oblige operators of certain activities to take preventative measures where there 2009 (as amended 2011) is an imminent threat of environmental damage, and to remediate any environmental damage caused by their activities.
A.8: Chemicals, drainage and oily discharges Regulatory Body Legislation Summary of Requirements The Offshore Chemicals Regulations 2002 implement the OSPAR Decision (2000/2) and OSPAR Recommendations (2000/4 and 2000/5) introducing a Harmonised Mandatory Control System for the use and reduction of the discharge of offshore chemicals. The Regulations introduced a permit system for the use and discharge of chemicals offshore and include a requirement for site specific risk assessment. Chemicals used offshore must be notified through the Offshore Chemical Notification Scheme (OCNS) and chemicals are The Offshore Chemicals Regulations 2002 (as ranked by hazard quotient, using the CHARM model. Applications for permits are made via the submission of the relevant permit to DECC (i.e. chemicals for drilling: DRA; DECC, Marine amended) pipelines: PLA; production: PRA; decommissioning: DCA; and workovers and well interventions: WIA). Scotland, CEFAS Amendments in 2011 to the Offshore Chemicals Regulations and the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2010. The principal aim is to make unlawful unintentional releases of chemicals and oil that arise through accidents / non-operational discharges by broadening accordingly the definitions of "offshore chemical" and "discharges" and incorporating a new concept of "release". Convention for the Protection of the Marine The OSPAR Convention (in particular Annex III) is the main driver for reductions in oily discharges to the North Sea. The UK as a contracting party to the Convention is therefore
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Regulatory Body Legislation Summary of Requirements Environment of the North East Atlantic 1992 (OSPAR obliged to implement any Decisions and Recommendations made by the Commissions. Certain decisions made under the earlier Paris Convention also still stand. Convention) OSPAR Decision 2000/3 that came into effect on 16 January 2001 effectively eliminates the discharge of organic phase fluids (OPF) (oil based (OBF) or synthetic based (SBF) OSPAR Decision 2000/3 on the Use of Organic-Phase drilling fluids) or cuttings contaminated with these fluids. Use of OPF is still allowed provided total containment is operated. The use of diesel-oil-based drilling fluids is prohibited. Drilling Fluids (OPF) and the Discharge of OPF- The discharge of whole OPF to the sea is prohibited. The mixing of OPF with cuttings for the purpose of disposal is not acceptable. The discharge of cuttings contaminated with oil Contaminated Cuttings based fluids (OBF) (includes OBF and SBF) greater than 1% by weight on dry cuttings is prohibited. The use of OPF in the upper part of the well is prohibited. Exemptions may be OSPAR Recommendation 2006/5 on a Management granted by the national competent authority for geological or safety reasons. Regime for Offshore Cuttings Piles. The discharge into the sea of cuttings contaminated with synthetic fluids will only be authorised in exceptional circumstances. Authorisations to be based on the application of BAT/BEP. Best Available Techniques described within the Decision include recycling, recovery and reuse of muds. The OSPAR 2006/5 Recommendation sets out measures to reduce pollution from oil or other chemicals from cuttings piles. These Regulations give effect to Annex I of MARPOL 73/78 (prevention of oil pollution) in UK waters and have been amended by the Merchant Shipping (Implementation of Ship- Source Pollution Directive) Regulations 2009 described above. They address oily drainage from machinery spaces on vessels and installations. The North Sea is designated a The Merchant Shipping (Prevention of Oil Pollution) “Special Area”, within which the limit for oil in discharged water from these sources is 15ppm. Vessels and installations are required to hold a valid UKOPP (UK Oil Pollution Regulations 1996 (as amended 2000) Prevention) or IOPP (International Oil Pollution Prevention Certificate). Vessels and drilling rigs are also required to hold a current, approved Shipboard Oil Pollution Emergency Plan (SOPEP) which is in accordance with guidelines issued by the Marine Environment Protection Committee of the International Maritime Organisation (IMO). Arrangements for Survey and Certification Part VI of the Merchant Shipping Act, 1995 makes provision for the prevention of pollution from ships. It implements in the UK the Merchant Shipping Act 1995 requirements of the International Convention for the Prevention of Pollution from Ships (MARPOL) 73/78. MARPOL defines ships to include offshore installations and relevant provisions of MARPOL are applied to offshore installations. Annex 1 of MARPOL relates to prevention of oil pollution and has provisions for machinery space drainage that are International Convention for the Prevention of applied to offshore platforms: Pollution from Ships (MARPOL) 73/78 Vessels of 400 GT or above are permitted to discharge processed water (i.e. Oily Drainage Water) from Machinery Space Drainage as long as the oil content without dilution, does not exceed 15 ppm of the oil in water. PARCOM Recommendation 86/1 of a 40 mg/l The PARCOM Recommendation 86/1 provision of a 40 mg/l performance standard for platforms is applicable, and remains in force for discharges of displacement water, drainage Emission Standard for Platforms water and ballast water, which are not covered under MARPOL. The maximum concentration of dispersed oil must not exceed 100 mg/l at any time. These enforce Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals The REACH Enforcement Regulations 2008 (REACH) which require chemical users to demonstrate the safe manufacture of chemicals and their safe use throughout the supply chain. Under REACH, the users of chemicals as well as their manufacturers and importers have a responsibility to ensure that the risks to both human health and the environment are adequately assessed. These Regulations replaced the Prevention of Oil Pollution Act 1971 (“POPA”) and are a mechanism to continue implementation on the UKCS of OSPAR Recommendation 2001/1. DECC, Marine Discharges of reservoir oil associated with the Niobe Exploration Well drilling operations must be covered by an OPPC Term Permit. Operators are required to regularly report Scotland, CEFAS actual oil discharge in order that adequate monitoring can be achieved. All permit applications are to be made via the Oil Portal System, and the application should include: Amendments in 2011, via the Offshore Chemicals Regulations 2002 (as amended) and the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2010 introduced the new concept of “release “ and “ offshore installation” which encompasses all pipelines . The concentration of dispersed oil in produced water discharges from well testing must not exceed 30 mg/l, whereas the maximum permitted concentration must not exceed 100 mg/l at any time. The quantity of dispersed oil in produced water discharged must not exceed 1 tonne in any 12 hour period. Legislation is pending following the submission of implementation plans on Recommendation 2012, for undertaking risk-based approach for the management of produced water The Offshore Petroleum Activities (Oil Pollution discharges from offshore installations. Prevention and Control) Regulations 2005 (as An assessment of BAT and BEP. Drainage sampling feasibility study. amended) Oil treatment process and operations description. Produced water meter uncertainty report. Relevant schematic/ process diagrams. Environmentally Critical Elements (ECE) Management. The Permit Holder is legally responsible for ensuring that the conditions in the Permit are adhered to. These OPPC regulations do not apply to discharges regulated under the Offshore Chemicals Regulations 2002 (as amended), the Merchant Shipping (Prevention of Oil Pollution) Regulations 1996 (as amended) or the Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2008. Discharges/ activities not requiring a permit under the OPPC regulations include: “Oils” regulated under the Offshore Chemicals Regulations 2002 (as amended). Domestic wastes. Machinery space discharges regulated under. Incidents resulting in a release of oil to sea.
A.9: Territorial Waters Regulatory Body Legislation Summary of Requirements Hydrographic Office Territorial Sea Act 1987 Defines the extent of the territorial sea adjacent to the British Islands. Territorial Waters Order
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A.10: Ballast water Regulatory Body Legislation Summary of Requirements Objective to prevent, minimise and ultimately eliminate the transfer of harmful aquatic organisms and pathogens though control and management of ships’ ballast water and International Convention for the Control and sediments. Helsinki and OSPAR Commissions General Guidance on the Voluntary Interim has set out an application of the D1 Ballast Water Exchange Standard. MCA Management of Ships' Ballast Water and Sediments Under this regulation, all tankers > 150 GRT and all ships > 400 GRT in the UK are required to have in place United Kingdom Oil Pollution Prevention Certificate (UKOPP) or IOPP (BWM) – adopted 2004 Certificate and Ballast Water Exchange Management plan. It is required all vessels entering the North East Atlantic to exchange the ballast water at least 200 nm from the nearest land and at least 200 metres deep.
A.11: Waste handling and disposal Regulatory Body Legislation Summary of Requirements International Convention for the Prevention of Annex V: Prevention of pollution by garbage from ships (entered into force December 1998). Deals with the different types of garbage and specifies the distances from land and the MCA Pollution from Ships (MARPOL) 1973 Annex V, as manner in which they may be disposed of. The Annex also designates Special Areas (including the North Sea) where the disposal of any garbage is prohibited except food wastes. amended 1978 The dumping of plastics at sea is also prohibited by this Annex. This Act, and associated regulations, introduces a “Duty of Care” for all controlled wastes. Waste producers are required to ensure that wastes are identified, described and labelled accurately, kept securely and safely during storage, transferred only to authorised persons and that records of transfers (waste transfer notes) are maintained for a Environmental Protection Act 1990 minimum of two years. Carriers and waste handling sites require licensing. This Act and associated Regulations brought into effect a system of regulation for “controlled waste”. Although the Act does not apply to offshore installations, it requires operators to ensure that offshore waste is handled and disposed of onshore in accordance with the “Duty of Care” introduced by the Act. The European Parliament introduced a new Directive, 2008/98/EC, on waste and repealing certain Directives. The Directive lays down measures to protect the environment and Directive 2008/98/EC of the European Parliament and EA / SEPA human health by preventing or reducing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving efficiency of the Council of 19 November 2008 on waste and of such use. repealing certain Directives.
The Waste (Scotland) Regulations 2011 The 2011 Scotland Regulations make a number of amendments to a variety of Scottish waste legislation to transpose aspects of Directive 2008/98/EC on waste into Scottish law. The Environment Protection (Duty of Care) Under these Regulations any person who imports, produces, carries, keeps, treats or disposes of Controlled Waste has a duty to take all reasonable steps to ensure that their Regulations 1991 waste is handled lawfully and safely. Special/Hazardous Waste is a sub-category of Controlled Waste (see also Special Waste Regulations). This legislation does not strictly apply offshore. However, because the offshore disposal of garbage is prohibited then all wastes must be transferred to shore for disposal. Once The Controlled Waste Regulations 1992 (as amended onshore, the wastes must meet the requirements of onshore legislation when being disposed of. These regulations must therefore be considered offshore to allow onshore SEPA 1993) requirements to be met, for example the identification and appropriate documentation of these wastes. These regulations define household, industrial and commercial waste for waste management licensing purposes. A licence is required under FEPA for any waste disposal in the sea or under the seabed. However, the Deposits in the Sea (Exemptions) Order 1985 exempts from FEPA licensing DECC Food and Environment Protection Act 1985 the deposit on site or under the seabed of any chemicals and drill cuttings. However, export of cuttings to another field for re-injection will require a licence under FEPA. These Regulations implement Directive 2005/35/EC of the European Parliament and of the Council of 7th September 2005 on ship-source pollution and on the introduction of The Merchant Shipping (Implementation of Ship- penalties for infringements. The Directive aims to achieve better enforcement of the requirements of the International Convention for the Prevention of Pollution from Ships, 1973 Source Pollution Directive) Regulations 2009 (MARPOL 73), as modified by the Protocol of 1978 (MARPOL 73/78).
DECC / MCA These Regulations implement the requirements of MARPOL 73/78 Annex IV in the UK. The Merchant Shipping (Prevention of Pollution by These regulations apply to vessels including fixed or floating platforms which operate in the marine environment and came into force on 01 February 2009. They lay out the Sewage and Garbage from Ships) Regulations 2008 requirements for sewage system surveys and certification and the requirements of sewage systems with an exception for fixed installations at a distance of more than 12 nautical (as amended) miles from the nearest land. They also identify the requirements for a garbage management plan, garbage record books and prohibit the disposal of various types of garbage into the marine environment and define enforcement action. The 2010 Amendments correct drafting errors. The Special Waste Regulations 1996 as amended These Regulations make provision for handling special waste and for implementing Council Directive 91/689/EEC of 12 December 1991 on hazardous waste. The Regulations 2001, 2012) require controlled wastes that are also considered to be special waste because of their hazardous properties, to be correctly documented, recorded and disposed of at an The Special Waste (Scotland) Regulations 2004 appropriately licensed site. Whilst strictly speaking the Regulations do not apply offshore, waste consignments must be compliant as soon as the waste is offloaded at an onshore facility. In Scotland, The Special Waste Amendment (Scotland) Regulations 2004 amend the Special Waste Regulations 1996. They implement the revised European hazardous SEPA waste list, (incorporated into the European Waste Catalogue). They introduced new consignment note, segregation, packaging and labelling requirements. In England and Wales the Special Waste Regulations 1996 were repealed by The Hazardous Waste (England and Wales) Regulations 2005.
The Waste (Scotland) Regulations 2012 (draft legislation) The pending Waste (Scotland) Regulations 2012 amend the Environmental Protection Act 1990. Changes include requirements to keep both dry recyclable waste and food waste separate from other kinds of waste. These Regulations transpose the requirements of the Waste Electrical and Electronic Equipment Directive (WEEE Directive 2002/96/EC) which came into force in January 2007. The Waste Electrical and Electronic Equipment The Regulations define new responsibilities for users and producers of Electrical and Electronic Equipment depending on whether the equipment was purchased before or after SEPA Regulations 2006 (as amended) 13/08/05. The 2010 Amendments modify various definitions and realign dates.
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A.12: Low specific activity (LSA) contaminated waste (sand, sludge and scale) and Radioactive waste Regulatory Body Legislation Summary of Requirements Radioactive Substances Act 1993 Onshore and offshore storage and disposal of naturally occurring radioactive materials (NORM) is regulated under the Radioactive Substances Act. Operators are required to hold, The Environmental Permitting (England and Wales) for each relevant installation, an Authorisation to store and dispose of radioactive waste such as low specific activity scale (LSA) which may be deposited in vessels and pipe-work. Regulations 2012 The authorisation specifies the route and methods of disposal. Records of disposal are required. The offshore use, storage and disposal of radioactive sources are regulated under the same legislation. A Registration Certificate is required to keep; transport and use sources and records must be kept. Additionally, different radionuclides have different activity thresholds over which the containing sources qualify as a High Activity Sealed Source (HASS). As of January 2008, and if applicable, HASS records must be reported to SEPA or the EA and maintenance of an inventory is required. The keeping, storage and disposal of
SEPA radioactive waste requires authorisation.
The Radioactive Substances Act 1993 Amendment The Radioactive Substances Act 1993 has been superseded by the Environmental Permitting (England and Wales) Regulations 2010 in England and Wales but it has remained in (Scotland) Regulations 2011 place in Scotland. However, in Scotland there have also been consultations regarding a future exemptions regime under The Radioactive Substances Act 1993. These consultations have resulted in the Radioactive Substance Exemption (Scotland) Order 2011. This order will revoke and replace a series of exemption orders (in Scotland) made under the Radioactive Substances Act 1993 (“the Act”) and its predecessor (the Radioactive Substances Act 1960) in order to rationalise the current system of exemptions and bring it into line with the structure and terminology used in the Basic Safety Standards Directive.
A.13: Licensing Regulatory Body Legislation Summary of Requirements These Regulations consolidate with amendments the provisions of the Petroleum (Production) Regulations 1982 (as amended) in relation to (a) applications to the Secretary of State for petroleum production licences in respect of seaward areas and (b) applications to the Secretary of State for petroleum exploration licences in respect of seaward areas Petroleum Act, 1998 (as amended by the Energy Act and landward areas below the low water line. 2008) This Act vests all rights to the nation's petroleum resources to the Crown and provides the basis for granting licences to explore for and produce oil and gas. Production licences The Petroleum Licensing (Exploration and Production) grant exclusive rights to the holders to “search and bore for and get petroleum” in specific blocks. Licences generally contain a number of environmental restrictions and conditions. (Seaward and Landward Areas) Regulations 2004 (as Under the terms of a Licence, licence holders require the authorisation of the Secretary of State prior to conducting activities such as installing equipment or drilling of wells in the amended 2006) licence area. Consent to flare or vent hydrocarbons is also required from DECC under the terms of the Model Clauses incorporated into Production Licences. The Petroleum Licensing (Production) (Seaward Licence conditions will include environmental issues e.g. time constraints in sensitive areas. The model clauses of the licence require the licensee to appoint a fisheries liaison Areas) Regulations 2008 DECC officer.
Marine Licensing (Exempted Activities) (Scottish These two Acts introduce a framework for the development of a new planning system for the marine area and ensure greater protection for the marine environment and biodiversity. Inshore and Offshore Regions) Amendment Order However, oil and gas activities are generally exempted from the Act(s) since an environmental regime/regulator is already in place under DECC. The Act(s) will apply to a number 2012 of activities e.g.: removal of materials from the seabed (including structures), deposit of materials during decommissioning, disturbance of the seabed, use of explosives and installation of certain types of cables. DECC will retain responsibility for offshore installation enforcement activities, and the Marine Management Organisation & Devolved Authorities will take responsibility for "at sea" enforcement of oil and gas activities. The Amendment Order details a number of activities exempt from the requirement for a MCAA licence.
A.14: Transboundary Impacts Regulatory Body Legislation Summary of Requirements The 1991 UNECE Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo Convention) requires any country that has ratified the convention to Convention on Environmental Impact Assessment in a consider the transboundary environmental effects of industrial projects and activities, including offshore hydrocarbon exploration activities. DECC Transboundary Context (Espoo, 1991) (as amended 2004) The Convention requires that if the activity is found to cause a significant adverse transboundary impact then the party undertaking the activity shall, for the purpose of ensuring adequate and effective consultations, notify any potentially affected country as early as possible.
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A.15: Location of Structures Regulatory Body Legislation Summary of Requirements The issue of a ‘Consent to Locate’ (CtL) to an individual or organisation by the DECC Secretary of State under Part 4A of the Energy Act 2008 (EA) indicates that the impact of the proposals with respect to navigation has been considered, and that no significant obstruction or danger is anticipated as a consequence of the proposed offshore structure or operations providing they are undertaken in accordance with the consent conditions. It allows DECC to insist upon the provision of navigational markings that are considered Energy Act 2008 (Part 4a) appropriate for the proposed offshore structure or operations. The installation of offshore infrastructure, or the undertaking of certain types of offshore operations, may only be undertaken in accordance with any conditions set out in the consent. The consent, however does not confer exclusive rights to the location applied for, nor prevent other individuals or organisations from applying for consent at the same location. Nor does it relinquish the rights of navigation in a given area. DECC Continental Shelf Act 1964 This act extends the UK government’s right to grant licences to explore and exploit the UKCS. The Continental Shelf (Designation of Areas) This Order consolidates the various Orders made under the Continental Shelf Act 1964 which have designated the areas of the continental shelf within which the rights of the (Consolidation) Order 2000 United Kingdom with respect to the sea bed and subsoil and their natural resources are exercisable. Marine and Coastal Access Act 2009 and Marine The Marine and Coastal Access Act (MCAA) and Marine (Scotland) Act will replace and merge the requirements of FEPA Part II (deposits to the sea) and the Coast Protection Act (Scotland) Act 2010 1949 (navigation). The licensing provisions of these Acts enter into force in April 2011. See also Marine & Coastal Access Act 2009 & The Marine (Scotland) Act 2010.
A.16: Environmental Management System Regulatory Body Legislation Summary of Requirements All Operators controlling the operation of offshore installations on the UKCS are required to have in place an independently verified Environmental Management System designed OSPAR Recommendation 2003/5 to Promote the Use to achieve: the environmental goals of the prevention and elimination of pollution from offshore sources and of the protection and conservation of the maritime area against other DECC and Implementation of Environmental Management adverse effects of offshore activities and to demonstrate continual improvement in environmental performance. OSPAR recognises the ISO 14001: 2004 & EMS international Systems by the Offshore Industry standards as containing the necessary elements to fulfil these requirements. All operators are also required to provide a public statement of their environmental performance on an annual basis.
A.17: Decommissioning Regulatory Body Legislation Summary of Requirements The Petroleum Act 1998 sets out requirements for undertaking decommissioning of offshore installations and pipelines including preparation and submission of a Decommissioning Petroleum Act 1998 Programme. Part III of the Energy Act 2008 amends Part 4 of the Petroleum Act 1998 and contains provisions to enable the Secretary of State to make all relevant parties liable for the Energy Act 2008 decommissioning of an installation or pipeline; provide powers to require decommissioning security at any time during the life of the installation and powers to protect the funds put aside for decommissioning in case of insolvency of the relevant party. DECC, MMO , Marine Scotland The Marine and Coastal Access Act (MCAA) and Marine (Scotland) Act will replace and merge the requirements of FEPA Part II (deposits to the sea) and the Coast Protection Act Marine (Scotland) Act 2010 (navigation). FEPA Part II remains in force in Scottish territorial waters to cover reserved activities (within 3 nm). Marine and Coastal Access Act 2009 Many offshore sector activities are exempt from the acts; however certain activities including deposits of substances or articles in the seabed during abandonment and decommissioning operations are covered. OSPAR Decision 98/3 on the Disposal of Disused Decision that requires operators to remove the whole installation. However large structures are possible exceptions from derogation. Offshore Installations
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Appendix B
Justification of Low Environmental Risks
This Appendix provides the justification for the environmental risks that were considered to be “low” during the Environmental Risk Assessment (Section 6) and were excluded from further investigation within the main Environmental Statement.
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Table B.1: Justification for the exclusion of non-significant (low risk) environmental effects from further investigation in the EIA: Drilling Aspect Environmental Impact or Risk Proposed Control and Mitigation Justification Drilling: Planned operations Non-hazardous drains, by their design, discharge only non-hazardous Any possible deterioration of water quality will be short-term. Slight deterioration in seawater quality around point of rainwater which may be slightly contaminated with oily deposits. The permitted discharge of low volumes of fluids will be dispersed in the offshore Aqueous discharges discharge. Access points for non-hazardous deck drains are controlled, so any environment and there will be no cumulative or transboundary effects. from drilling rig Potential effects on marine fauna inhabiting the upper spillages on deck will not enter the drainage system, but will be cleaned up. Any possible effects on water quality and marine fauna inhabiting the upper water water column (plankton, fish and marine mammals). Non-hazardous drains are designed to take storm and rain water run-offs column (plankton, fish and marine mammals) will therefore be confined to the immediate from the decks. vicinity of the discharge point. Localised increase in biological oxygen demand (BOD) Sewage will be treated prior to disposal at sea, or contained and shipped to Sewage and macerated food waste (organic material only) will be broken down and around the point of discharge (caused by bacterial shore. readily dispersed in the offshore environment. degradation of the sewage). Vessels will be audited to ensure compliance. Discharge of sewage The particles of food waste will be <25 mm in diameter, and will be rapidly and widely Input of organic nutrients results in localised increase in and macerated waste Food waste will be macerated as required by MARPOL and The Merchant dispersed in the water column offshore. productivity in fish, plankton and micro-organisms. Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Total quantities discharged over the proposed drilling programme from the rig will be Slight deterioration in seawater quality around point of Regulations 2008; this will aid its dispersal and decomposition in the water small in relation to other natural and anthropogenic sources of nutrient enrichment. discharge. column. All cuttings will be contained and shipped to shore for reprocessing at a All LTOBM mud and cuttings will be contained and will therefore present no risk to the Transportation of cuttings to shore will add to the use of licensed landfill site. Skip and ship of marine environment. landfill disposal facilities for their treatment which will Transfer operations will be governed by loading and unloading procedures. LTOBM cuttings contribute to slight deterioration of air quality. Onshore treatment and disposal of LTOBM will have a negligible effect on the existing The cuttings will be stored in covered skips to minimise emissions and risk onshore facilities and infrastructure. of spill. Waste generation will be minimised. All waste will be segregated to allow maximum reuse/recycling. The waste The treatment and disposal of solid wastes at onshore will be contained, then shipped to shore for recycling or disposal by a Onshore disposal of Documentation will be in place to ensure that contractors segregate, store, transport, waste treatment and landfill sites could result in impacts licensed company in full compliance with UK waste legislation and Duty of solid waste( rig treat and dispose of waste in accordance with all relevant regulations and Suncor’s to the air quality, hydrology, flora and fauna, and Care. &vessels) requirements. socioeconomic aspects of such sites. Use of designated licensed onshore waste disposal / transfer /handling facilities only. Auditing of waste management contractor to ensure compliance. Chemicals will have been approved by the DECC and risk assessments will indicate the All chemicals will be risk-assessed and presented in the appropriate permit/ Some associated deterioration of water quality. potential for any environmental impact. Permitted discharge of application for statutory approval from the DECC. Potential effect on plankton, fish, shellfish and marine Discharges will be rapidly dispersed and diluted in the offshore environment and will not drill chemicals Chemicals will be selected in order to minimise hazards to the environment mammals. be expected to significantly impact the benthos, water column, fish or marine mammals. in accordance with Offshore Chemicals Regulations 2002 (as amended). The quantity used will be minimised as far as practicable. Drilling: Unplanned events Accurate accounting for all casing and flow line sections (which have individual test certificates and records) and major items of equipment. Major items will be recovered from the seabed, therefore no long-term impact would be Disturbance to the seabed, water quality and benthos. Objects dropped into Adherence to lifting and handling procedures and use of certified equipment anticipated. Potential obstruction to commercial fishing and other the sea for lifting. Loss of individual hand-tools and other minor items of equipment will not constitute a commercial users of the sea. Requirement to retrieve major items of debris from the seabed after threat to species, habitats or fishing. operations, in compliance with relevant legislation.
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Table B.2: Justification for the exclusion of non-significant (low risk) environmental effects from further investigation in the EIA: Decommissioning Aspect Environmental Impact or Risk Proposed Control and Mitigation Justification Decommissioning: Planned events Discharge of sewage Refer to Table B1 and macerated waste Potential for temporary deterioration of water quality and effects on plankton The area of seabed that will be disturbed as a result of decommissioning activities will Plug and Disturbance to sediments and potential for debris to Post-decommissioning a debris survey will be undertaken to remove any be localised and very small. Re-colonisation will occur after operations have ceased. abandonment of wells remain on the seabed. objects remaining on the seabed. Any possible deterioration of water quality will be rapidly dispersed and diluted. Temporary alteration of sediment structure and All impacts will be temporary not permanent. smothering of seabed organisms. Decommissioning: Unplanned events Objects dropped into Refer to Table B1 the sea
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Appendix C
Atmospheric Emissions Calculations This Appendix provides a breakdown of the calculations presented in the Atmospheric Emissions Assessment (Section 10).
Contents C.1 Global Warming Potential ...... 3 C.2 UKCS Emissions from Offshore Oil and Gas Activities ...... 3 C.3 Drilling and Installation Activities ...... 4
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C.1 Global Warming Potential The GWP factor of each of the most common combustion gases is given in Table C.1.
Table C.1: GWP factors for combustion gases Gaseous emission 100 year GWP factor* Direct greenhouse gases
Carbon dioxide (CO2) 1
Methane (CH4) 23
Nitrous oxide (N2O) 296 Indirect greenhouse gases Carbon monoxide (CO) 3
Oxides of nitrogen (NOx) 5** Volatile organic compounds (VOC) -
Sulphur dioxide (SO2) - Other Particulate matter (PM) - *GWPs are from IPCC (2001) and refer to the 100 year horizon values. **The GWP factor of 5 is for surface emissions. Higher altitude emissions (from aircraft) have greater impacts both because of longer NOx residence times and more efficient tropospheric O3 production, as well as enhanced radiative forcing sensitivity. NOx emissions from aircraft can therefore have GWPs in the order of 450 for considering a 100-year time horizon. It must be noted however that these numerical values are subject to very large quantitative uncertainties.
C.2 UKCS Emissions from Offshore Oil and Gas Activities
Table C.2: Total UKCS emission and total GWP emissions from UKCS offshore oil and gas activities Emissions (t) Activity CO2 CO NOx N2O SO2 CH4 VOC Total Total emissions from UKCS offshore exploration and 16,393,119 24,649 55,837 1,006 2,628 50,476 54,050 16,581,765 production activities during 2010 Total GWP emissions from UKCS offshore exploration and 16,393,119 73,947 279,185 297,776 - 1,160,948 - 18,204,975 production activities during 2010* *GWPs are from IPCC (2001) Source: Oil and Gas UK, 2012
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C.3 Drilling and Installation Activities For the Drilling Activities, each table (Tables C.2 to C.5) presents: Suncor’s estimates of the duration of use and operating status of each vessel.
The estimated fuel use per day as provided by Institute of Petroleum (2000) or Suncor.
The total fuel use for each vessel.
The associated gaseous emissions calculated using factors provided by UKOOA (2002).
The GWP emissions for the drilling activity calculated using the factors provided in Table C.1.
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Table C.2: Estimated gaseous emissions from vessels during the drilling operations Fuel consumption Emissions (tonnes) Activity Days t/day tonnes CO2 CO NOx N2O SO2 CH4 VOC Marine diesel factors (tonne/ tonne) 3.2 0.008 0.059 0.00022 0.004 0.00027 0.0024 Tugs (x3) Mob/ demob to jack-up to drill location 15 15 225 720.00 1.80 13.28 0.05 0.90 0.06 0.54 Jack-up drilling rig Mob/ demob to jack-up to drill location 5 12.5 62.5 200.00 0.50 3.69 0.01 0.25 0.02 0.15 Drill and complete exploration well 40 12.5 500 1,600.00 4.00 29.50 0.11 2.00 0.14 1.20 Standby vessel Mob/demob to drill location 5 8 40 128.00 0.32 2.36 0.01 0.16 0.01 0.10 Drilling operations 40 5 200 640.00 1.60 11.80 0.04 0.80 0.05 0.48 Supply vessel Mob/demob to drill location 5 8 40 128.00 0.32 2.36 0.01 0.16 0.01 0.10 Drilling operations 40 8 200 1,024.00 2.56 18.88 0.07 1.28 0.09 0.77 Total emissions from drilling operations 4,440.00 11.10 81.86 0.31 5.55 0.37 3.33 Source: Marine diesel factors from Oil and Gas UK (2012)
Table C.3: Estimated gaseous emissions from helicopter operations Fuel consumption Emissions (tonnes) Activity hours t/day tonnes CO2 CO NOx N2O SO2 CH4 VOC Aviation fuel factors (tonne/ tonne) 3.2 0.0052 0.0125 0.00022 0.004 0.000087 0.0008 Helicopter flights to jack-up drilling rig Helicopter flights* 30 0.523 15.69 50.21 0.08 0.20 0.00 0.06 0.00 0.01 Total emissions from helicopter operations 50.21 0.08 0.20 0.00 0.06 0.00 0.01
Note: based on a helicopter flight duration of 2 hours and a fuel consumption rate of 615 litres/ hour (0.523 t/hour), and 15 flights over the drilling period Source: Aviation diesel factors from Institute of Petroleum, 2000; learnIT, 2006; OSPAR, 2005.
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Table C.4: Summary of estimated emissions from the support vessels, drilling rig and helicopters during the drilling operations Emissions (t)* Activity CO2 CO NOx N2O SO2 CH4 VOC Total emissions from drilling operations 4,440.00 11.10 81.86 0.31 5.55 0.37 3.33 Total emissions from helicopter flights 50.21 0.08 0.20 0.00 0.06 0.00 0.01 Total vessel emissions from the drilling operations 4,490.21 11.18 82.06 0.31 5.61 0.38 3.34
Table C.5: Summary of estimated GWP emissions from the support vessels, drilling rig and helicopters during the drilling operations GWP emissions (t)* Activity CO2 CO NOx N2O SO2 CH4 VOC Total GWP** Total emissions from drilling operations 4,440.00 33.30 409.30 91.76 - 8.51 - 4,982.87 Total emissions from helicopter flights 50.21 0.24 1.00 0.00 - 0.00 - 51.45 Total vessel emissions from the drilling 4,490.21 33.54 410.30 91.76 - 8.51 - 5,034.32 operations
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Appendix D
Coastal Environmental Sensitivities
This Appendix provides a summary of the coastal environmental sensitivities that could potentially be impacted by oil from a hydrocarbon release incident at the Niobe Exploration Well as described in Section 13.
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D.1 Introduction The purpose of this appendix is to describe the coastal sensitivities in areas that may be impacted by oil from a pollution incident, including the worst-case scenario, at the proposed Niobe Exploration Well site. The key sites of conservation designated under international, European and UK legislation will then be highlighted for the UK (specifically the Moray Firth coastline).
D.1.1 Scenario upon which coastal sensitivities have been assessed Worst case scenario oil spill modelling (Section 13) has indicated that crude oil from a continuous release of crude oil from the Niobe Exploration Well has the potential to affect the following stretches of UK coastline (Figure D.1):
East coast of Orkney; Coast of Nairnshire;
East coast of Caithness; Coast of Moray;
East coast of Sutherland; Coast of Banffshire;
East coast of Ross and Cromarty; Coast of Aberdeenshire.
Inverness-shire;
Figure D.1: Probability plot of shoreline beaching from a well blow-out spill at the Niobe Exploration Well location
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D.1.2 Summary of key UK coastline features The Moray Firth coastline is rich in invertebrates and plant species, contains internationally important populations of migratory and resident wildfowl and waders. The marine environment of Moray Firth provides a habitat for one of only two known resident populations of bottlenose dolphins in UK waters. Approximately 40% of the area forms part of the Natura 2000 network of protected areas (Moray Firth Partnership, 2011). The coast of firth represents 20% of Scotland’s coastline, and its landscape offers constant variety and diversity in terms of scenery, habitats, wildlife population and land uses. The coastal landscape includes: dunes and beaches; salt marsh, sand banks, intertidal mudflats; extensive broad and long firths; cliffs and rocky shorelines; raised beaches; woodland and coastal forests; and river mouths.
D.2 Coastal Conservation Areas There are a large number of sites, along the coastline of Scotland potentially impacted, that are designated as conservation areas under international and national legislation. For clarity, these sites have been included in Table D.1 below, with additional information on the purpose of the conservation site, whether the site is protected by statute law or otherwise and if the site is present in the Moray Firth or along the coastline.
D.3 Potential Shoreline Impact Areas of International and National Conservation Concern This section highlights the potential conservation sites with international and national designation status that may be impacted by oil from the modelled instantaneous release of crude oil from the Niobe Exploration Well within UKCS Block 12/27. Figures D.2a and D.2b show the conservation designations in proximity to the Niobe Exploration Well that could be impacted by a potential oil spill. Table D.2 includes more site-specific information for the sites displayed within the figure. For clarity RAMSAR sites have not been illustrated on the figure, nor described within the table, as these conservation designations are also protected under SPA and SAC designations in Scotland.
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Table D.1: National and international conservation designations International Statutory Present in Moray Protected Area or National protection Firth or Assessed Purpose Other Information Designation Designation or other Coastline MPAs are recognised globally as one way to support our marine On the 24th July 2014, Scottish Ministers designated 30 Nature environment. A well-managed network of MPAs will protect important Conservation Marine Protected Areas to conserve some of Marine marine habitats and species, deliver benefits for our marine Scotland's most important marine wildlife, habitats and Protected Area National Statutory Yes environments, support coastal communities, help sustain marine geodiversity, of which 13 are offshore MPAs. Covering over 10% (MPA) industries and provide for recreational uses (SNH, 2014c). of our seas, Nature Conservation MPAs will play an important role in delivering a healthy, productive and biologically diverse marine environment for Scotland (SNH, 2014c). NNRs contain examples of some of the most important natural and There are currently 47 promoted National Nature Reserves in National Nature semi-natural terrestrial and coastal ecosystems in Great Britain. Scotland. These special places, showcasing the very best of Reserves National Statutory Yes They are managed to conserve their habitats or to provide special Scotland's nature, cover less than 1.5% of Scotland (SNH, (NNR) opportunities for scientific study of the habitats communities and 2014d). species represented within them (JNCC, 2014c). The purpose of National Parks is to conserve and enhance There are two national parks in Scotland - Loch Lomond and The landscapes within the countryside whilst promoting public enjoyment Trossachs, established in 2002, and the Cairngorms, established National Parks National Statutory No of them and having regard for the social and economic well-being of in 2003. those living within them. Natura 2000 is the name of the European Union-wide network of Not applicable nature conservation sites established under the EC Habitats and Birds Directives. This network will comprise Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). Marine Not NATURA 2000 International Not applicable Natura 2000 sites contribute to our ecologically coherent network of applicable marine protected areas.
The RAMSAR Convention's mission is "the conservation and wise There are currently 51 RAMSAR sites designated as use of all wetlands through local and national actions and internationally important wetlands in Scotland, covering a total international cooperation, as a contribution towards achieving area of about 313,000 hectares. sustainable development throughout the world" (RAMSAR, 2014). *RAMSAR International Statutory Yes All RAMSAR sites in Scotland are also either Special Protection Areas (SPAs) or Special Areas of Conservation (SACs) (Natura 2000 sites), and many are also Sites of Special Scientific Interest (SSSIs), although the boundaries of the different designations are not always exactly the same (SNH, 2014e).
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Table D.1 (continued): National and international conservation designations International Statutory Present in Moray Protected Area or National protection Firth or Assessed Purpose Other Information Designation Designation or other Coastline Sites of Special Scientific Interest (SSSI) are those areas of land and Please see entry for RAMSAR sites above. water (to the seaward limits of local authority areas) that Scottish Natural Heritage (SNH) considers to best represent our natural Site of Special heritage - its diversity of plants, animals and habitats, rocks and Scientific National Statutory Yes landforms, or a combinations of such natural features. Interest (SSSI) SNH designates SSSIs under the Nature Conservation (Scotland) Act 2004. SSSIs are protected by law. It is an offence for any person to intentionally or recklessly damage the protected natural features of an SSSI (SNH, 2014f). SACs are designated under the EC Habitats Directive. The Directive Please see entry for RAMSAR sites above. applies to the UK and the overseas territory of Gibraltar. SACs are areas which have been identified as best representing the range and variety within the European Union of habitats and (non-bird) species Special Area of listed on Annexes I and II of the Directive. SACs in terrestrial areas Conservation International Statutory Yes and territorial marine waters out to 12 nautical miles are designated (SAC) under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended). Beyond 12 nautical miles they are designated under the Offshore Marine Conservation (Natural Habitats &c.) Regulations 2007 (as amended) (JNCC, 2014c). SPAs are classified by the UK Government under the EC Birds Please see entry for RAMSAR sites above. Directive. The Directive applies to the UK and the overseas territory of Gibraltar. SPAs are areas of the most important habitat for rare Special (listed on Annex I of the Directive) and migratory birds within the Protected Area International Statutory Yes European Union. SPAs in terrestrial areas and territorial marine (SPA) waters out to 12 nautical miles are designated under the Wildlife and Countryside Act 1981 and beyond 12 nautical miles are designated under the Offshore Marine Conservation (Natural Habitats &c.) Regulations 2007 (as amended) (JNCC, 2014c). World Heritage Sites are designated to meet the UK's commitments Scotland has one natural world heritage site, also our only joint under the World Heritage Convention. The UK's ratification of the natural and cultural world heritage site - the islands of St Kilda Convention also extends to its Overseas Territories and Crown (JNCC, 2014c). World Heritage International Statutory No Dependencies. These sites are designated for their globally Sites important cultural or natural interest and require appropriate management and protection measures. Natural properties may be terrestrial or marine areas (JNCC, 2014c).
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Table D.1 (continued): National and international conservation designations International Statutory Present in Moray Protected Area or National protection Firth or Assessed Purpose Other Information Designation Designation or other Coastline There are many areas where the scenery is highly valued locally, Local landscape designations are shown in local development and local authorities often give these landscapes a local designation. plans, and have associated policies to safeguard their valued This is to ensure that the landscape is not damaged by inappropriate features. Special Local development, and in some cases encourage positive landscape Landscape National Yes Scottish Natural Heritage and Historic Scotland have now jointly Authority management. These designations play an important role in Areas published guidance to assist local authorities to refresh their developing an awareness of the landscape qualities that make approach to landscape designations. particular areas distinctive, and promote a communities sense of pride in their surroundings. Biogenetic Reserves act as 'living laboratories' and are Biogenetic Reserves were first established to accommodate representative examples of various types of natural environment in biological research. Their purpose has since been overtaken by Europe. They can consist of natural or semi-natural habitats and that of Scotland's national nature reserve network. their selection is based on their value for nature conservation and Biogenetic Non- International Yes protected status based on four criteria: 'typical', 'unique', 'rare' and/ Reserves statutory or 'endangered', which can be applied to habitats or species. The protected status must be adequate to ensure the conservation or management of the sites in the long term in accordance with fixed objectives (SNH, 2014g). Biosphere Reserves are areas of terrestrial and coastal ecosystems Currently there are two biosphere reserves in Scotland : Biosphere Non- promoting the conservation of biodiversity with sustainable use. Beinn Eighe, in Wester Ross. International No Biosphere reserves serve to demonstrate integrated management of Reserves statutory Galloway and Southern Ayrshire Biosphere Reserve land, water and biodiversity. external site. Designation of geological and geomorphological features in Sites of There are currently (June 2012) 895 GCR sites in Scotland. Special Scientific Interest (SSSIs) is underpinned by the Geological Of these, 204 (23%) have no protective Site of Special Scientific Conservation Review (GCR). The GCR, undertaken by the Joint Interest (SSSI) designation status. These are termed 'unnotified Nature Conservation Committee (JNCC), selected the very best and GCR sites'. most representative geological and geomorphological features of Significant areas of a further 28 sites (3%) also have no Geological Statutory Britain. protective SSSI designation status. National Park Authorities and Conservation National and Non- Not applicable some Local Authorities treat these unnotified GCR sites as Review (GCR) statutory candidate SSSIs and afford them the same protection. Sites Some unnotified GCR sites are also Local Geodiversity Sites (LGS), and as such they are afforded levels of protection appropriate to locally important sites (though they areal so considered to be of national or international importance). The remaining unnotified GCR sites have no statutory protection.
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Table D.1 (continued): National and international conservation designations International Statutory Present in Moray Protected Area or National protection Firth or Assessed Purpose Other Information Designation Designation or other Coastline A Geopark is a territory, which includes a particular geological In Scotland there are 3 UNESCO European Geoparks, in the heritage and a sustainable territorial development strategy supported North West Highlands, Lochaber and Shetland. Non- by a European programme to promote development. Geoparks International No statutory It must comprise a certain number of geological sites of particular importance in terms of their scientific quality, rarity, aesthetic appeal or educational value. The purpose of the National Scenic Area (NSA) designation is both There are 40 NSAs in Scotland, with their outstanding scenery, to identify our finest scenery and to ensure it is protected from represent Scotland's finest landscapes. They include spectacular National Scenic Non- National Yes inappropriate development. This is achieved through the local mountain areas such as the Skye Cuillins, Ben Nevis and Area (NSA) statutory authority planning system. Glencoe, and dramatic island landscapes within the Hebrides and the Northern Isles. *Note that as RAMSAR sites in Scotland serve a dual purpose as either a SPAs or SACs, many are also classes as SSSIs, therefore no further information on these designated areas will be provided.
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Figure D.2a: Offshore, inshore and terrestrial forms of conservation designation associated with the Niobe Exploration Well
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Figure D.2b: Offshore, inshore and terrestrial forms of conservation designation associated with the Niobe Exploration Well
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Table D.2: Conservation sites within the Moray Firth and along the Moray Firth coastline Figure/ inset Site Name Location Protected features / conservation interest(s) reference Marine Protected Areas (MPAs) East Caithness Territorial waters Black guillemot (Cepphus grille) Figure C.2a; Cliffs Inset A Noss Head Territorial waters Horse mussel beds Figure C.2a; Inset A Firth of Forth Offshore Ocean quahog aggregations Figure C.2b; Banks Complex Offshore subtidal sands and gravels Inset B Shelf banks and mounds Moraines Wyre and Rousay Territorial waters Kelp and seaweed communities on sublittoral sediment Figure C.2b; Sounds Maerl beds Inset A Marine geomorphology of the Scottish Shelf Seabed Northwest Orkney Offshore Sandeel Figure C.2b; Sand banks, sand wave fields and sediment wave Inset B fields Special Areas of Conservation (SAC) East Caithness Terrestrial Vegetated sea cliffs Figure C.2a; Cliffs Inset A Moray Firth Territorial waters Subtidal sandbanks Figure C.2a; and offshore area Bottlenose dolphin Inset B Dornoch Firth and Territorial waters Reefs Figure C.2a; Morrich More Subtidal sandbanks Inset B Atlantic salt meadows Glasswort and other annuals colonising mud and sand Estuaries Intertidal mudflats and sandflats Otter (Lutra lutra) Harbour seal (Phoca vitulina) Dunes with juniper thickets Shifting dunes Culbin Bar Territorial waters Atlantic salt meadows Figure C.2a; Shifting dunes Inset B Coastal shingle vegetation outside the reach of waves Lower River Spey Territorial waters Alder woodland on floodplains Figure C.2a; – Spey Bay Coastal shingle vegetation outside the reach of waves Inset B River spey Terrestrial Sea lamprey (Petromyzon marinus) Figure C.2a; Atlantic salmon (Salmo salar) Inset B Otter Freshwater pearl mussel (Margaritifera margaritifera) Buchan Ness to Terrestrial Vegetated sea cliffs Figure C.2b; Collieston Coast Inset B Sanday Territorial waters Reefs Figure C.2b; Subtidal sandbanks Inset A Intertidal mudflats and sandflats Harbour seal Sands of Forvie Terrestrial Lime-deficient dune heathland with crowberry Figure C.2b; Humid dune slacks Inset B Shifting dunes Shifting dunes with marram
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Garron Point Terrestrial Narrow-mouthed whorl snail (Vertigo angustior) Figure C.2b; Inset B Special Protected Areas (SPAs) East Caithness Terrestrial Cormorant, breeding Figure C.2a; Cliffs Guillemot, breeding Inset A Herring Gull (Larus argentatus), breeding Puffin, breeding Razorbill, breeding Shag (Phalacrocorax aristotelis), breeding Fulmar, breeding Peregrine (Falco peregrinus), breeding Seabird assemblage, breeding Great Black-backed Gull (Larus marinus), breeding Kittiwake , breeding North Caithness Terrestrial Peregrine, breeding Figure C.2a; Cliffs Seabird assemblage, breeding Inset A Fulmar, breeding Guillemot, breeding Kittiwake, breeding Razorbill, breeding Puffin, breeding Dornoch Firth and Territorial waters Osprey (Pandion haliaetus), breeding Figure C.2a; Loch Fleet Waterfowl assemblage, non-breeding Inset A Curlew, non-breeding Dunlin (Calidris alpina alpina), non-breeding Greylag Goose, non-breeding Wigeon, non-breeding Bar-tailed Godwit, non-breeding Teal (Anas crecca), non-breeding Oystercatcher (Haematopus ostralegus), non-breeding Inner Moray Firth Territorial waters Common Tern, breeding Figure C.2a; Osprey, breeding Inset A Bar-tailed Godwit, non-breeding Curlew, non-breeding Goldeneye, non-breeding Greylag Goose, non-breeding Redshank, non-breeding Wigeon, non-breeding Goosander (Mergus merganser), non-breeding Teal, non-breeding Red-breasted Merganser, non-breeding Waterfowl assemblage, non-breeding Cormorant, non-breeding Oystercatcher, non-breeding Scaup (Aythya marila), non-breeding Moray and Nairn Terrestrial Osprey, breeding Figure C.2a; Coast Common Scoter (Melanitta nigra), non-breeding Inset A Long-tailed Duck (Clangula hyemalis), non-breeding Oystercatcher , non-breeding Bar-tailed Godwit, non-breeding Wigeon, non-breeding Pink-footed Goose, non-breeding Red-breasted Merganser, non-breeding
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Redshank, non-breeding Velvet Scoter (Melanitta fusca), non-breeding Waterfowl assemblage, non-breeding Greylag Goose, non-breeding Dunlin, non-breeding Troup, Pennan Terrestrial Seabird assemblage, breeding Figure C.2a; and Lion's Heads Razorbill, breeding Inset C Fulmar, breeding Guillemot, breeding Kittiwake, breeding Herring gull, breeding Loch of Strathbeg Terrestrial Sandwich Tern, breeding Figure C.2a; Greylag Goose, non-breeding Inset C Pink-footed Goose, non-breeding Waterfowl assemblage, non-breeding Teal, non-breeding Svalbard Barnacle Goose, non-breeding Whooper Swan, non-breeding Buchan Ness to Terrestrial Seabird assemblage, breeding Figure C.2b; Collieston Coast Kittiwake, breeding Inset B Shag, breeding Fulmar, breeding Guillemot, breeding Herring Gull, breeding Ythan Estuary, Terrestrial Common Tern, breeding Figure C.2b; Sands of Forvie Little Tern, breeding Inset B and Meikle Loch Sandwich Tern, breeding Waterfowl assemblage, non-breeding Lapwing (Vanellus vanellus), non-breeding Eider, non-breeding Pink-footed Goose, non-breeding Redshank, non-breeding Fowlsheugh Terrestrial Fulmar, breeding Figure C.2b; Guillemot, breeding Inset B Kittiwake, breeding Razorbill, breeding Seabird assemblage, breeding Herring Gull, breeding Pentland Firth Territorial waters Arctic Tern, breeding Figure C.2b; Islands Inset A Auskerry Territorial waters Arctic Tern, breeding Figure C.2b; Storm Petrel, breeding Inset A East Sanday Territorial waters Turnstone, non-breeding Figure C.2b; Coast Purple Sandpiper, non-breeding Inset A Bar-tailed Godwit, non-breeding Sites of Special Scientific Areas (SSSIs) Duncansby Head Terrestrial Fulmar (Fulmarus glacialis) Figure C.2a; breeding Kittiwake (Rissa tridactyla) Inset A Seabird colony, breeding Guillemot (Uria aalge), breeding Geomorphology of Scotland Maritime cliff
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Castle of Old Terrestrial Maritime cliff Figure C.2a; Wick to Craig Inset A Hammel Craig Hammel to Terrestrial Kittiwake , breeding Figure C.2a; Sgaps Geo Razorbill (Alca torda), breeding Inset A Seabird colony, breeding Guillemot, breeding Maritime cliff Dunbeath to Terrestrial Maritime cliff Figure C.2a; Sgaps Geo Inset A Berriedale Cliffs Terrestrial Fulmar , breeding Figure C.2a; Razorbill , breeding Inset A Kittiwake , breeding Seabird colony, breeding Guillemot, breeding Shag (Phalacrocorax aristotelis), breeding Maritime cliff Ousdale Burn Terrestrial Upland birch woodland Figure C.2a; Inset A Helmsdale Coast Terrestrial Mesozoic Palaeobotany Figure C.2a; Kimmeridgian Inset A Inverbrora Terrestrial Mesozoic Palaeobotany Figure C.2a; Bathonian Inset B Callovian Oxfordian Dunrobin Coast Terrestrial Hettangian, Sinemurian, Pliensbachian Figure C.2a; Inset B Loch Fleet Terrestrial Eider (Somateria mollissima), non-breeding Figure C.2a; Breeding bird assemblage Inset B Native pinewood Saltmarsh Eelgrass beds Sand flats Sand dunes Vascular plant assemblage Dornoch Firth Terrestrial Whooper Swan (Cygnus cygnus), non-breeding Figure C.2a; Wigeon (Anas penelope), non-breeding Inset B Bar-tailed Godwit (Limosa lapponica), non-breeding Saltmarsh Eelgrass beds Sand dunes Vascular plant assemblage Morrich More Terrestrial Bar-tailed Godwit, non-breeding Figure C.2a; Teal (Anas crecca), non-breeding Inset B Wigeon, non-breeding Curlew (Numenius arquata), non-breeding Breeding bird assemblage Coastal Geomorphology of Scotland Saltmarsh Invertebrate assemblage Sand dunes Vascular plant assemblage
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Tarbat Ness Terrestrial Coastal Geomorphology of Scotland Figure C.2a; Non-marine Devonian Inset B Maritime Cliff Rosemarkie to Terrestrial Notified feature Figure C.2a; Shandwick Coast Upland birch woodland Inset B Mesozoic Palaeobotany Callovian Moine Maritime cliff Sand dunes Purple Oxytropis (Oxytropis halleri) Munlochy Bay Terrestrial Wigeon, non-breeding Figure C.2a; Greylag Goose (Anser anser), non-breeding Inset B Saltmarsh Mudflats Longman and Terrestrial Goldeneye (Bucephala clangula), non-breeding Figure C.2a; Castle Stuart Redshank (Tringa totanus), non-breeding Inset B Bays Wigeon, non-breeding Cormorant (Phalacrocorax carbo), non-breeding Red-breasted Merganser (Mergus serrator), non- breeding Saltmarsh Eelgrass beds Mudflats Whiteness Head Terrestrial Bar-tailed Godwit, non-breeding Figure C.2a; Knot (Calidris canutus), non-breeding Inset B Coastal Geomorphology of Scotland Saltmarsh Sandflats Sand dunes Shingle Culbin Sands, Terrestrial Hydromorphological mire range Figure C.2a; Culbin Forest and Fungi assemblage Inset B Findhorn Bay Coastal Geomorphology of Scotland Lichen assemblage Saltmarsh Invertebrate assemblage Mesotrophic loch Shingle Sand dunes Vascular plant assemblage Masonshaugh Terrestrial Permian - Triassic Reptilia Figure C.2a; Permian Triassic (red beds) Inset B Clashach – Terrestrial Permian - Triassic Reptilia Figure C.2a; Covesea Permian Triassic (red beds) Inset B Lossiemouth Terrestrial Permian Triassic (red beds) Figure C.2a; Shore Inset B Spey Bay Terrestrial Wet woodland Figure C.2a; Small blue (Cupido minimus) Inset B Dingy Skipper (Erynnis tages) Hydromorphological mire range Coastal Geomorphology of Scotland Saltmarsh
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Shingle Vascular plant assemblage Cullen to Stake Terrestrial Lowland dry heath Figure C.2a; Ness Coast Springs (including flushes) Inset B Saltmarsh Quaternary of Scotland Dalradian Shingle Whitehills to Terrestrial Dalradian Figure C.2a; Melrose Coast Inset B Gamrie and Terrestrial Guillemot, breeding Figure C.2a; Pennan Coast Kittiwake, breeding Inset C Seabird colony, breeding Razorbill, breeding Puffin (Fratercula arctica), breeding Fulmar, breeding Gannet (Morus bassanus), breeding Quaternary of Scotland Dalradian Maritime cliff Rosehearty to Terrestrial Curlew, non-breeding Figure C.2a; Fraserburgh Purple Sandpiper (Calidris maritima), non-breeding Inset C Coast Turnstone (Arenaria interpres), non-breeding Eider (Somateria mollissima), non-breeding Dalradian Cairnbulg to St Terrestrial Dalradian Figure C.2a; Combs Coast Inset C Loch of Strathbeg Terrestrial Goldeneye, non-breeding Figure C.2a; Greylag Goose, non-breeding Inset C Whooper Swan, non-breeding Pink-footed Goose (Anser brachyrhynchus), non- breeding Breeding bird assemblage Fen meadow Open water transition fen Coastal Geomorphology of Scotland Saltmarsh Eutrophic loch Pentland Firth Territorial waters Arctic Tern (Sterna paradisaea), breeding Figure C.2b; Islands Vascular plant assemblage Inset A Ward Hill Cliffs Terrestrial Maritime cliff Figure C.2b; Inset A Copinsay Territorial waters Guillemot, breeding Figure C.2b; Seabird colony, breeding Inset A Kittiwake (Rissa tridactyla), breeding Auskerry Territorial waters Arctic Tern, breeding Figure C.2b; Storm Petrel (Hydrobates pelagicus), breeding Inset A East Sanday Territorial waters Purple Sandpiper , non-breeding Figure C.2b; Coast Sanderling (Calidris alba), non-breeding Inset A Ringed Plover (Charadrius hiaticula), non-breeding Turnstone, passage Bar-tailed Godwit, non-breeding Turnstone, non-breeding
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Figure/ inset Site Name Location Protected features / conservation interest(s) reference Rocky shore Sand flats Harbour seal Vascular plant assemblage Central Sanday Terrestrial Coastal Geomorphology of Scotland Figure C.2b; Saltmarsh Inset A Machair Sand dunes Sands of Forvie Terrestrial Common Tern (Sterna hirundo), breeding Figure C.2b; and Ythan Eider, breeding Inset B Estuary Little Tern (Sternula albifrons), breeding Arctic Tern, breeding Sandwich Tern (Sterna sandvicensis), breeding Pink-footed Goose, non-breeding Eider, non-breeding Breeding bird assemblage Coastal Geomorphology of Scotland Saltmarsh Sand dunes Vascular plant assemblage Foveran Links Terrestrial Coastal Geomorphology of Scotland Figure C.2b; Sand dunes Inset B Cove Terrestrial Maritime cliff Figure C.2b; Dickie's bladder-fern (Cystopteris dickieana) Inset B Garron Point Terrestrial Northern brown argus (Aricia artaxerxes) Figure C.2b; Ordovician Igneous Inset B Narrow-mouthed whorl snail (Vertigo angustior) Silurian - Devonian Chordata Dalradian Maritime cliff St Cyrus and Terrestrial Breeding bird assemblage Figure C.2b; Kinnaber Links Small blue Inset B Saltmarsh Lowland neutral grassland Moths Shingle Sand dunes Vascular plant assemblage
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Niobe Exploration Well Environmental Statement W/4171/2014
D.4 Priority Bird Species of Conservation Concern The following section briefly describes sensitive and priority bird species, for which the major designations are implemented. From the SPAs listed within Table D.2a, the following have been outlined as SPAs more susceptible to impacts from a potential spill from the Niobe Exploration Well: Moray and Nairn Coast; Troup, Pennan and Lions Heads; and Loch of Strathbeg. The above designated sites stretch along the Nairnshire, Moray, Banffshire and Aberdeenshire coastline. Moray and Nairn Coast SPA regularly supports over 20,000 wintering waterfowl. The site also supports internationally important wintering populations of Icelandic/ Greenland Pink-footed Goose, Icelandic Greylag Goose and Redshank. The Troup, Pennan and Lion’s Heads SPA stretches 9 km along the sea cliffs of the Aberdeenshire coast and support large colonies of breeding seabirds (over 20,000 individual breeding seabirds). In 1995 the site supported 150,000 individual seabirds from 9 species. The site also qualifies as a SPA, as it regularly supports internationally important breeding populations of the migratory Black-legged Kittiwake and Common Guillemot. Breeding assemblages include the Northern Fulmar, Herring Gull and Razorbill (SNH, 2009). The Loch of Strathbeg SPA contains a shallow freshwater loch with surrounding wetland, dunes and grassland communities. The site is contained within the Loch of Strathbeg SPA and provides a wintering habitat for a number of important wetland bird species, particularly Wildfowl. The site qualifies as a SPA, as it regularly supports in summer a nationally important breeding population of Sandwich Tern. A wintering population of Whooper Sawn is also protected under this site designation (SNH, 1994).
D.5 Coastal Marine Mammals Marine mammals that are resident along the potentially affected coastlines are grey seals (Halichoerus grypus), harbour or common seals (Phoca vitulina) and Eurasian otters (Lutra lutra). Grey seals feed in the open sea and regularly return to “haul out” sites on land to rest, breed and moult. Grey seals spend more time hauled out during their moulting season between February and March, and during their breeding season between October and December (Thompson and Härkönen, 2008). Harbour seals haul out in sheltered waters, on sandbanks, in estuaries or in rocky areas. Pups are born in June and July, and moulting occurs between August and September (DECC, 2009).
D5.1 UK seal populations The Scottish coast provides breeding habitat for internationally important numbers of grey seals. Around 40% of the world grey seal population breeds in the UK, 90% of
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Niobe Exploration Well Environmental Statement W/4171/2014
which breeds in Scotland (DECC, 2009). The main breeding areas of grey seals in Scotland are the Outer Hebrides, Orkney, Shetland and the north and east coasts of the mainland. The abundance of UK grey seals, estimated via pup counts, has steadily increased since the 1960s and is now levelling off. Female grey seals often return to the same colony to breed each year. Around 33% of the total population of European harbour seals breed in the UK, 85% of which occur in Scotland. The main areas of population in Scotland are the Hebrides, Shetland and Orkney, the Firth of Tay and the Moray Firth. Shetland accounts for around 15% of the Scottish harbour seal population. The Scottish harbour seal population has decreased by 50% since 2002 (SCOS, 2009).
D5.2 UK otter populations The Eurasian otter are largely solitary, semi-aquatic mammals that depend on lochs, rivers and sea for their habitat. They feed largely on fish but also amphibians, crustaceans, molluscs, birds and mammals (SNH, 2010). Suitable habitat for otters must have a supply of freshwater, so that otters can wash the salt out of their fur, which otherwise prevents it from being insulated. Otters also require rocky or vegetated areas to shelter and ground to dig their holts. Otters occur throughout the UK along the eastern UK coastline, but approximately 90% of the population (around 8,000 animals) occurs in Scotland (SNH, 2010). Surveys of Scottish otter abundance were carried out by the Vincent Wildlife Trust between 1977 and 1994, and by SNH from 2003 onwards (Strachan, 2007). These surveys have shown that otters’ population abundance and range increased, over the survey period, and is now ubiquitous throughout Scotland. Therefore, otters are likely to occur along the potentially impacted areas of coastline. The Scottish otter population is unusual, around 50% of the population dwells on the coast and feeds mainly in the sea (SNH, 2010). Coastal otters are commonly active in the day, feeding on benthic fish, crustaceans and molluscs, and tend to favour shallow inshore rocky areas with dense seaweed cover.
D.6 Coastal Fisheries and Aquaculture Within the Moray Firth there are no licenced fish farms. In 2002 a fish farm based at Avoch in the Inverness Firth was closed. A lease for a fish farm site at Red Nose, near the South Sutor, was never developed and the lease expired in 2005. There is one shellfish farm but currently it is not operational (Moray Firth Partnership, 2014a).
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The inshore fishery is much smaller than that of the offshore in the Moray Firth in terms of volume and monetary value. The target species, methods of fishing and vessel size all differ significantly from that of its offshore counterparts. The primary landing ports are located at Buckie, Burghead, Wick, Lybster and Fraserburgh. However, there are many smaller ports that are used to land fish. The inshore fisheries are dominated by squid and Nephrops (Moray Firth Partnership, 2014b).
D.7 Tourism and Recreation Tourism and leisure activities are important for the UK mainland coastline. Attractions include dramatic scenery, its variety of wildlife and sites of historical interest. Key leisure and tourism activities include walking, sailing, golf, sea angling and water sports. No attempt has been made to quantify the impact of a potential oil spill on tourism and recreation in the study area. It is assumed that the industry would experience loss of custom in the affected areas for a period during and after major oil spill (DTI, 2002; DTI, 2004).
D.8 Coastal Heritage and Archaeology There is evidence of human activity within Moray Firth and settlement throughout the area, dating back over 6,000 years. These span through the Neolithic, Bronze Age, Iron Age, Medieval, Post-Medieval and Modern periods. There are many fine examples of built forms from each of these periods, and many hundreds of archaeological sites, most as yet unexplored (Moray Firth Partnership, 2014c). The heritage of the Moray Firth is closely tied the fishing industry. In the past few years a collection of the traditional fishing boats including fifies, scaffies, zulus and yoles has been restored. Although these boats are remembered by the older generations, they are not very well known among the younger and more recent inhabitants of the Moray Firth area. The Moray Firth Flotilla was organised as part of the Highland 2007 celebrations with the original idea to remind people about the importance of the Moray Firth and to educate youngsters, incomers and visitors about its rich fishing culture and heritage (Moray Firth Partnership, 2014c).
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