Consultation outcome

MGN 372 update feedback – comments received during the second consultation and MCA responses

Updated 7 November 2022

MGN 372 update – comments received during the second consultation and MCA responses

Stakeholder 1

Section	Stakeholder Comment	MCA Response
General	With regards to the below consultation, I wonder if there is scope to include some reference to materials/services supplied by Seafish to aid with safe passage/fishing? In terms of fishing operations, this would include: • KIS-ORCA – the availability of electronic charts, wind farm chart in pdf form and a webmap (www.kis-orca.org) highlighting renewable energy structures and associated hazards. • Kingfisher Bulletin – automated alerts of ongoing development activities, new hazards and schedules of works via www.kingfisherbulletin.org	Added to list of useful websites

Stakeholder 2

No Amending Comments

Stakeholder 3

Section	Stakeholder Comment	MCA Response
1.2	Whilst 4coffshore is a good resource it does include sites that have no lease or are speculative so it does give a false impression of the likely future case scenario. For UK developments we would recommended the respective Crown Estate website as a resource.	Amended to TCE and CES
2.1	‘a yellow transition piece section not less than 15 metres high measured above the Highest Astronomical Tide (HAT)’ – typically not less?	Amended
2.1	The blades tips are coloured red and the blade’s leading edge have three red dots. Typically tips painted (as some are not) and dots or stripes?	Amended to say older OWF may not have painted blade tips.
2.1.1	Fixed turbines are found in water depths of less than 60m and are secured to the seabed using one of several available types of foundation (e.g. monopile, gravity base or suction bucket) or a jacket (pin pile or suction bucket) depending on the characteristics of the seabed and water depth. Above the sea surface they appear as either a single structure connecting to the foundation or a jacket structure that has three or four legs.	Jacket referenced in next sentence.
2.1.2	Floating turbines foundations are found in water depths of more than 50m and can consist of either a semi-submersible spar or platform supporting the one or more wind turbine generators which is secured to the seabed using mooring lines / chains and anchors	Amended
General	Maybe worth a caveat that this is a very brief overview and mariners should look to kingfisher or NtoM for detailed site by site info.	Paragraph 1.8 amended to include reference to developer websites, local notification, KIS-ORCA and kingfisher
2.2	and mariners should be aware of the likely presence of foundations without a yellow Transition piece or scour works/protection	Reference to scour protection added to 2.1.1
General	Any mention of operational buoyage?	Reference to permanent cardinal buoys and special marks under 2.2
2.7.1	500m is relatively small minimum spacing these days.	Amended to say “at least 500m apart” and subsequent sentence amended to be clearer.
2.8.4	Should it be clear that this study was desk top and written from a specific angle? General question - Is this MCA acceptance this document is reliable source?	Reference to desk-top added. The USCG was involved in the report’s development and MCA is content it is a reliable source.
3.1	Too much detail maybe?	Most of these types of designs are in differing stage in the development pipeline and it’s not thought to be too much detail.
4.4	Is it worth mentioning that where safety zones aren’t applicable a vessel may ask for a ‘advisory safe passing distance’ and that these will be promulgated by GVs or NtoM?	Added as a new paragraph (4.5)
4.5	Permanent Safety Zones or operational phase safety zones?	Paragraph amended.
4.9.4	Typo in section	Amended
4.10.5	Or guard vessels, marine coordination centres?	reference to marine coordination centres added to 4.4
In the consultation responses 4.7.4	Question on what we are saying in terms of nacelle rescue.	Typo identified and corrected.

Stakeholder 4

Section	Stakeholder Comment	MCA Response
-	Track Changes in document	Considered and appropriate amendments made

Stakeholder 5

Section	Stakeholder Comment	MCA Response
2.2	“In certain cases, cardinal marks may also be permanently placed adjacent to wind farms”. This should be amended to “Cardinal and/or Special Mark buoys may also be permanently placed adjacent to wind farms”.	Amended
-	Reference should also be made to short range (2nM) flashing yellow lights that may be installed temporarily on unfinished foundation structures. These are not required by the IALA guidelines, and are installed at the discretion of the developer to aid navigation within the array for designated construction vessels.	Added as a new paragraph (2.2.5)
2.5	“Fixed red aviation lights on the top of nacelles may be visible to surface craft (flashing Morse-W.” This statement provides ambiguity as to whether the aviation lights are either fixed or flashing. The Morse-W requirement is a UK GLA recommendation only.	Fixed’ removed. Now reads “Red aviation lights…”. Morse-W was agreed with the CAA and requirement added to MGN654 Annex 5.
4.8.2 & 4.8.4	Section 4.8.2 states “internal access to the turbine tower will not be possible”. Section 4.8.4 then appears to contradict this by stating “Mariners will be able to access the internal structure.	4.8.4 amended

Stakeholder 6

Section	Stakeholder Comment	MCA Response
2.2	It may be beneficial to have a simple plan view diagram showing the SPS range distance between SPS, lights, additionally the IPS. This could clearly show the basic requirements to the navigator.	An image is included in the Annex on marking and appearance of OREIs. Range of SPS/ IPS and distance between SPS and IPS covered.
2.6	Image of charted windfarm could be for both a fixed and a floating windfarm	Added
1.2	“In May 2022, 42 offshore wind farms were operational, with a further fifteen were in the post-consent or construction phases.” to amend fifteen to 15.	Amended
2.1.2	Image asked for by MCA (item 15 above), I have asked the OWA if we can pass on the image and will revert.	Noted with thanks
2.2	“Transition piece” to amend upper case T.	Amended
2.7.7	“Transformer stations: In or adjacent to larger wind farms offshore electrical transformer-stations may be present. “ to add in these are referred to as Offshore Sub-Stations (OSS).	Amended
4.10.2	The choice will also be influenced by the type of OREI (tidal, wave) and it’s characteristics (OREI type, whether above/partially/submerged below the waterline, static or dynamic).	Amended
1.2	Would the position of current and future windfarms be more easily digested by the reader via a diagram. Perhaps one could be provided in an annex and reference made to it in this sections?	A4 layout is too small for a clear depiction and won’t be long before it is out of date. External references to TCE and CES given within document.
2.1.1	Is the manner in which a foundation is secured to the seabed (monopile, gravity base, suction bucket) of relevance to safe navigation?	Yes, paragraph to remain. No amendment
2.1.2	No reference made to Tension Leg Platform (TLP)	Included in the image
2.7.2	Is reference to Hywind required?	An example was felt useful, however since there are only two sites at present reference to Kincardine added
2.7.5	Glad to see reference to USVs. It might be helpful to provide a diagram showing a selection of USVs. Many marineers will have never seen one and might not be aware what to look for or how to respond should one be encountered.	Out of scope of this document. Details and how to respond to encounters will be available through separate publications.
4.6	Alhtough reference is made to catenary moorings and floating wind turbines in section 2.1.2 it might be helpful to the reader to directly associate that mooring type with floating wind in this section also.	As it is mentioned in 2.1.2 not amended to avoid duplication.
4.9.4	Second sentence - considr changing text from “Mariners will be be able” to “Marineers will not be able”	Amended
-	Construction and major servicing of floating offshore wind trubines will require these turbines to be towed to and from deep water ports. I think this would be useful information to include given the number of floating wind sites expected in Scotwind and the relatively few numbers of ports capable of servicign these structures	Reference to towing floating turbines added to 2.7.5
-	It might be helpful to illustrate the various types of vessel used to construct and maintain offshore windfarms. Consider including this as an annex?	Considered to be out of scope of this document.
2.7	Due to decarbonisation of vessels and the “DfT Operation Zero”. Windarms may have mooring buoys, charging buoys or charging points from the assets. Kindly consider adding a section to capture this with wording similar to: “ For smaller vessels navigation within a windfarm array, please be aware of any potential mooring buoys within the boundary. These may be conventional mooring buoys or be electrical charging buoys for vessels with hybrid technology. Vessels that are operationally asscocated with a windfarm may also moor to an asset for the same reasons.”	Added as a new paragraph (2.5), with thanks.

Stakeholder 7

Section	Stakeholder Comment	MCA Response
2.8.6	We note that paragraph 2.8.6 provides guidance on the appropriate passing distance for larger vessels clear of turbine fields. This appears to be at odds with paragraph 4.10.4 which states “these notes do not provide guidance on the safe distance at which to pass an OREI”. We consider that there is a need for clarity on this matter, particularly as the information in the MGN may be relied upon if there is an incident and the terms of the guidance could encourage unsafe practice of the passing of OREI if not appropriately framed. We do consider that clear guidance on this point would be merited so as to be of greatest use for the sector.	Section 2.8.6 states prudent action during the passage planning phase and not a guidance towards safe distance for all vessels. Section 4.11.4 amended to provide clarity. The document provides information the issues when transiting around or through OREIs but the MGN would not outweigh the established and required practices of seamanship in conducting safe passage in accordance with COLREGS.
4.9.5	Paragraph 4.9.5 provides that mariners are unlikely to be able to use wave or tidal turbines as a place of refuge in an extreme emergency. This appears to be incorrect as there are floating and wave devices available which can provide refuge for mariners if necessary.	Wave and tidal devices are not designed to allow vessels to use them as a place of refuge. Additional clarification added.
General	In addition, we are aware that there is extensive industry practice and differing technical standards across the sectors involved in the delivery and operation of offshore wind, for example shipping, offshore wind developers, oil & gas sector. There is an incoherent approach across all of the sectors and cross-sector engagement would be merited so as to ensure a joined-up approach to the issues faced.	Noted with thanks