Environmental Management and

Monitoring

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 iii

Table of Contents

21 ENVIRONMENTAL MANAGEMENT AND MONITORING 21-4

21.1 Introduction 21-4 21.2 Environmental management system 21-4

21.2.1 Safety and sustainability policies 21-4 21.2.2 Our approach to sustainability 21-5 21.2.3 The Statoil management system 21-5 21.2.4 Technical standards 21-6 21.2.5 Performance monitoring 21-6

21.3 Environmental management 21-6 21.3.1 Environmental commitments 21-7

21.4 Environmental monitoring 21-13 21.5 Interface with contractors 21-13 21.6 Environmental awareness and training 21-13 21.7 Summary 21-13

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-4

21 ENVIRONMENTAL MANAGEMENT AND MONITORING

21.1 Introduction

The previous chapters of this Environmental Statement (ES) outline the environmental studies and assessments carried out as part of the EIA and navigation risk assessment (NRA). The purpose of this chapter is to provide a summary of environmental mitigation, monitoring and management measures and that will be taken forward through the next phase of the Project. It also provides an overview of approaches to environmental management, monitoring, interfacing with contractors, and environmental awareness and training.

21.2 Environmental management system

As a company, Statoil has a clear goal to ensure sustainable development and is committed to minimising environmental impacts. This section introduces Statoil’s Safety and Sustainability policy, the Management System and how this will be implemented within Hywind Scotland Pilot Park project.

21.2.1 Safety and sustainability policies

Statoil’s Safety and Sustainability policies are two of several policies included in the Statoil Book, which forms the foundation of how we conduct our business. We will ensure safe operations which protect people, the environment, communities and material assets. We believe that accidents can be prevented.

We are committed to:

Integrating safety in the way we do business;

Improving safety performance in all our activities;

Demonstrating the importance of safety through hands-on leadership and behaviour; and

Openness on all safety issues and active engagement with stakeholders.

How we work:

We take responsibility for the safety and security of ourselves and others;

We work systematically to understand and manage risk;

We provide our people with the necessary resources, equipment and training to deliver in accordance with their designated responsibilities;

We cooperate with our contractors and suppliers on the basis of mutual respect;

We stop unsafe acts and operations;

We aim for a safe and attractive working environment characterised by respect, trust and cooperation;

We monitor risk related to the working environment, and we monitor the occupational health of our people;

We establish work processes as well as goals and performance indicators to control, measure and improve these processes;

We run safety improvement processes based on surveys and risk assessments, and we involve our people in this work;

We build robust installations/plants and maintain them to prevent accidents;

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-5

If accidents occur, our emergency response organisation will do its utmost to reduce injury and loss. Saving lives is our highest priority; and

We transform lessons learned into improved safety measures through continuous learning.

21.2.2 Our approach to sustainability

We contribute to sustainable development through our core activities wherever we work. We use natural resources efficiently, and provide energy which supports sustainable development.

We are committed to:

Integrating sustainability in the way we do business;

Contributing to the development of sustainable energy systems and technology;

Making decisions based on the way they affect our interests as well as the interests of the societies and the ecosystems in which we operate;

Respecting human rights and labour standards;

Ensuring anti-corruption and transparency on all sustainability issues and active engagement with stakeholders; and

Contributing to local content by developing skills and opportunities in the societies in which we operate.

How we work:

We identify and manage environmental and social risks and opportunities based on stakeholder dialogue, as well as risk and impact assessments;

We apply clean and efficient technologies to reduce the negative environmental impact of existing operations;

We work to limit greenhouse gas emissions;

We respect international labour standards and the rights of indigenous peoples;

We promote transparency through support for international industry standards, and by publishing our income, expenditures and taxes in all the countries in which we operate;

We hire and develop local people and promote local sourcing;

We ensure that local suppliers comply with applicable laws and meet our expectations and standards;

We work with others to help establish sustainable local enterprises and support the efforts of our suppliers to close gaps in order to meet our standards;

We exchange experience with national partners and support education and skill building in oil- and gas-related disciplines to build lasting capacity; and

We undertake sustainable social investment projects in affected communities so that they can share in the benefits provided by our activities.

21.2.3 The Statoil management system

The Statoil management system defines how we work and describes how we lead and perform our activities. Commitment to and compliance with our management system are a requirement.

Our management system has three main objectives:

Contribute to safe, reliable and efficient operations and enable us to comply with external and internal requirements;

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-6

Help us to incorporate our values, our people and our leadership principles in everything we do; and

Support our business performance through high-quality decision making, fast and precise execution, and continuous learning.

Sustainability in Statoil means responsible environmental, social and economic performance enabling business resilience. The sustainability function in Statoil includes these elements:

Balance reliable energy supply and climate impact;

Aim for outstanding resource efficiency;

Prevent harm to local environment;

Create lasting local value;

Respect for human rights; and

Lead an open and transparent business. The Statoil environmental management system (EMS) is fully compatible with recognised environmental management standards including ISO 14001.

21.2.4 Technical standards

Statoil’s governing documents stipulate technical and professional requirements which apply to all projects. These include, for example TR1011 – Technical Environment Standard for Design, Modifications and Operation for Offshore Plants, which defines the group’s technical environmental requirements for offshore developments and operations, including the Hywind Scotland Pilot Park. The guiding principles of this document include:

Alternative concepts and technologies shall be identified and evaluated. Technology selection shall be prioritised in the following order: prevent, minimise, mitigate and compensate;

Best Available Techniques (BAT) is the overriding principle. BAT assessments shall be performed and documented for the design and operation of each facility;

BAT assessments shall include cost/benefit calculations;

National laws and requirements; and

Corporate goals and requirements shall be met.

21.2.5 Performance monitoring

Monitoring in Statoil is conducted to manage risk, and drive performance and learning. The process ensures quality, effectiveness and assures compliance with the management system and provides a basis for improvement. Monitoring is performed by internal and external parties.

21.3 Environmental management

Environmental assessment for the Project, including consultation with stakeholders, is an on-going, iterative process through final option selection, engineering design and through project execution. The primary mechanism for ensuring environmental assessment continues and that all environmental issues are addressed is through the Project Operational Management System. This management system will ensure that ES mitigation commitments, consent conditions and environmental monitoring requirements are taken through to implementation.

Where the EIA has identified potentially significant impacts that cannot be avoided, mitigation measures have been proposed. Such measures should remove, reduce or manage the effect to a point where the residual significance of that impact is reduced to an acceptable level. Mitigation has also been recommended tin order that impacts

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-7

remain ‘not significant’. Table 21-1 summarises all mitigation and management measures identified during the EIA process on a topic by topic basis.

These commitments will be integrated into the Project Environmental Management Plan (EMP). The full EMP will be implemented in agreement with the relevant Regulator and statutory advisors following successful award of Project consents. It will consist of a working document which details:

Roles, responsibilities and chain of command for HSL personnel, and any contractors or sub-contractors in respect of environmental management for the protection of environmental interests during the construction and operation of the Project;

Mitigation measures to prevent significant adverse impacts to environmental interests (as identified in the commitments register), and include a Construction Method Statement (CMS);

Pollution prevention measures and contingency plans;

Measures to minimise, recycle, reuse and dispose of waste streams; and

Reporting mechanisms that will be used to provide the Regulator and relevant stakeholders with regular updates on construction activity, including any environmental issues that have been encountered and how these have been addressed.

The EMP will be submitted to and agreed with the Regulator prior to the commencement of construction and updated as required as the Project progresses.

21.3.1 Environmental commitments

A commitments register has been developed to address each aspect of the Hywind Scotland Pilot Park (Table 21-1). This register will form part of an Environmental Management Plan and will be integrated into the relevant project execution and operational phases.

The commitments register provides a summary of key management and mitigation measures identified during the EIA process. The commitments register will be updated as each element of the project continues into detailed design, execution and subsequent operational phases.

Each commitment will be assigned an owner within the Marine Area Development team and will be reviewed periodically to ensure that the commitment is being met. During implementation of the project, objectives and targets will be co-jointly developed and used by Statoil and the contractors, to set goals for continuous improvement in performance. In this way, environmental management is an ongoing iterative process, continuing beyond the identification of mitigation measures during this EIA process. It also ensures that the development will remain responsive to continual improvement and changing regulatory requirements.

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Table 21-1 Commitments register

Topic Mitigation commitment

Physical environment

The base case for the cable landfall is an HDD solution. In the unlikely event this should not be feasible, necessary actions will be taken to avoid/reduce adverse impacts:

Ensure suitable measures are put in place to protect the seawall during export cable installation.

Ensure suitable measures are put in place to protect the Scottish Water outfall during export cable installation.

Benthic

All vessels involved in all stages of the project will adhere to all relevant guidance (including the IMO guidelines) regarding ballast water and transfer of non-native marine species.

Fish ecology

No significant impacts are expected, and no specific mitigations are deemed necessary.

Ornithology

The mitigation measures that will be implemented to reduce the risk of and limit the consequence of spills are detailed under hydrocarbon and chemical spills (see below).

Marine mammals

The mitigation measures that will be implemented to reduce the risk of and limit the consequence of spills are detailed under hydrocarbon and chemical spills (see below).

Aviation and radar

The MOD has confirmed that the mitigation proposal for the Buchan military air defence radar is acceptable and that they would expect to see a consent condition.

The mitigation solution proposed for the Perwinnes radar impact is radar blanking. NATS has confirmed that this solution is applicable and the contract to secure its implementation. An agreement has been drafted.

Local helicopter operators will be notified about the project development.

Commercial fisheries The following mitigation measures based on the FLOWW(Note 1) guidelines will be implemented, including:

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-9

Topic Mitigation commitment

A Fisheries Liaison Officer (FLO) has already been appointed for the Project and will continue in this role during construction to ensure fishermen are informed in advance of installation plans and to promptly answer any queries from fishermen; and

Details of the Project will be included in updated Kingfisher fishermen’s awareness charts and FishSAFE.

Additional mitigation measures for all shipping and navigation have been identified in shipping and navigation Chapter (see below).

Note 1 - The Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) was set up in 2002 to foster good relations between the fishing and offshore renewable energy sectors and to encourage co-existence between both industries. The FLOWW Best Practice Guidance for Offshore Renewables Developments: Recommendations for Fisheries Liaison was published in January 2014. http://www.thecrownestate.co.uk/media/5693/floww-best-practice-guidance-for-offshore-renewables-developments-recommendations-for-fisheries-liaison.pdf.

Shipping and navigation

HSL will follow standard industry practice with regards to the management and mitigation of shipping and navigation activities. Standard mitigation measures are presented below.

Adverse Weather: There will be adverse weather working policies and procedures for periods of construction and maintenance;

Cable Protection: Appropriate cable protection to be installed along the cable route, informed by a Burial Protection Index (BPI) study which will be submitted to the MCA prior to installation;

Chart Marking: The Project will be depicted on Admiralty Charts produced by the UKHO;

Emergency Response Cooperation Plan: An ERCoP will be prepared for the Project following the template provided by the MCA in MGN 371. This will be submitted to the MCA for approval prior to construction;

Equipment and Training for Site Personnel: Site personnel will be suitably equipped and trained for work offshore including in firefighting, first aid and offshore survival;

Fisheries Liaison Officer (FLO): A FLO has been appointed for the Project and will continue in this role during construction;

Guard Vessel during Construction: When there are work vessel(s) on site, one vessel will be nominated as a guard vessel with appropriate procedures for traffic monitoring and collision risk management;

Inspection and Maintenance: There will be appropriate inspection and maintenance procedures in place for all elements of the Project;

Kingfisher Charts and FishSAFE: Details of the Project will be included in updated Kingfisher fishermen’s awareness charts (paper and electronic) and on FishSAFE electronic safety devices which give and audible alarm when vessels are close to hazards;

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Topic Mitigation commitment

Maritime Safety Information (MSI) Broadcasts: HM Coastguard will be informed of work at the site to allow them to issue MSI broadcasts as appropriate;

Marking and Lighting: The Project will be marked and lit according to NLB requirements;

Minimum Air Clearance: There will be a minimum air clearance of 22 m from sea level in all tidal states due to the floating nature of the turbines. This is designed to help minimise the risk of rotor blade / yacht mast interaction in accordance with MCA and RYA guidance;

Notice to Mariners: Notices to Mariners will be issued prior to the start of construction and where necessary during work at the site;

Safety Management System (SMS): Statoil will have in place an SMS throughout the project; and

Safety Zones during Construction: Safety zones of 500 m radii will be applied for around each WTG Unit once installed until the construction phase has ended.

In addition to the above standard industry practice, additional project specific (enhanced) mitigation measures identified during consultation and at the Hazard Review workshop will also be implemented. These are listed below:

AIS Traffic Monitoring: Live 24/7 shipping traffic monitoring on AIS by Statoil Marine in Bergen during the operational phase with procedures to follow in the event a vessel is identified to be heading on a potential collision course;

AIS on Work Vessels: All vessels working at the site will broadcast on AIS;

Lessons Learned: Experience and lessons learned from incidents, accidents and near-misses at other marine renewables projects will be taken into account. Statoil is a member of the G9 Offshore Wind Health and Safety Association, and is proactive in sharing incident data and lessons learned within the offshore wind industry. The Project will also benefit from experience gained at the Hywind Demo Project in Norway which has been operational since 2009;

Passage Plans for Construction Vessels: Passage plans will be developed for vessels routing between the Project and the onshore base;

Sailing Directions and Almanacs: Details of the Project will be circulated to relevant organisations for inclusion in updated Sailing Directions and Almanacs;

Targeted Circulation of Information: Information on the Project will be circulated directly to local ports, ship operators (including the Marine Safety Forum representing oil industry vessels), fishermen and recreational organisations (including relevant international

Hywind Scotland Pilot Park Project – Environmental Statement Assignment Number: A100142-S35 Document Number: A-100142-S35-EIAS-001-015 21-11

Topic Mitigation commitment

organisations);

Operational Safety Zones: Further consultation will be carried out with the MCA and DECC regarding safety zones, or other methods of protecting against collision and fishing gear interaction during the operational phase. The agreed strategy, whether mandatory or advisory, will be implemented and notified to UKHO for suitable depiction on Admiralty charts;

Towing Vessel Availability: The Project is located in an area of above average towing vessel activity due to the oil and gas industry bases at Peterhead and Aberdeen. This will be given consideration within the ERCoP to ensure benefit is obtained in the event of a drifting scenario;

Excursion Alarm: The positions of the WTG Units will be monitored with an automatic emergency alarm to notify excursion from the central location;

Mooring System Integrity: Speciality study carried out to examine in detail the risk of mooring system failure leading to impairment of the BP Forties Pipeline; and

Third Party Verification of Mooring System: Design and third party verification of the mooring system will be carried out by a competent organisation.

Marine historic environment

Wherever possible HSL will avoid impacts on marine historic interests and avoidance of geophysical anomalies of uncertain importance and high or medium potential.

If avoidance is not possible, sites will be surveyed by diver, drop down camera or Remote Operated Vehicle (ROV) and the data assessed by a marine archaeologist. This work will provide a basis for devising appropriate management and mitigation strategies where necessary.

The following mitigation will also be applied:

o Implementation of a reporting protocol for the accidental discovery of cultural remains in line with The Crown Estate (2014) Protocol for Archaeological Discoveries: Offshore Renewables Projects, prepared by Wessex Archaeology Ltd for The Crown Estate.

Other sea users

Cable crossing agreements will be put in place (including for NorthConnect should this interconnector go ahead) prior to works to ensure no impact on cables.

Where cable owners have not been traced cable crossings will be designed assuming cables are live.

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Topic Mitigation commitment

Should items (or suspect items) of UXO be encountered during any upgrade and/or maintenance work, specific risk management advice will be sought and implemented to address this potential risk. In such circumstances HSL will consult a UXO specialist as appropriate to conduct a risk assessment and explore the options available. There are too many variables involved in such a scenario to make a rigid strategy at this stage.

SLVIA

No significant impacts are expected, and no specific mitigation measures deemed necessary.

Hydrocarbon and chemical spills

With regards to vessels:

o Vessels associated with all Project operations will comply with IMO/MCA codes for prevention of oil pollution and any vessels over 400 GT will have onboard SOPEPs;

o Project specific emergency plans will be in place and cover potential pollution events;

o Vessels associated with all Project operations will carry onboard oil and chemical spill mop up kits;

o Where possible and practicable vessels with a proven track record for operating in similar conditions will be employed; and

o Vessel activities associated with installation, operation and routine maintenance will occur in suitable conditions to reduce the chance of an oil spill resulting from the influence of unfavourable weather conditions.

Bunkering procedures will be in place to ensure the risk of a spill during bunkering will be minimised.

With regards to the turbines:

o Only recognised marine standard fluids and substances will be used in the turbine hydraulic systems;

o Hydraulic fluids will be mostly water based, biodegradable and be of low aquatic toxicity; and

o Turbine sensors will detect loss of fluid and leaks, enabling maintenance operatives to reduce the risk of further leaks.

In the event of any unplanned discharge to sea during HDD activities, the drilling contractor would activate its emergency response plan to ensure discharges were minimised.

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21.4 Environmental monitoring

Monitoring is an important activity for measuring performance against the environmental regulatory and corporate requirements. Monitoring enables the assessment of progress against goals as well as the gathering of information to track overall environmental performance, from initial design work to installation, operation, and eventual decommissioning. There are three inter-related drivers in such monitoring:

Statutory requirements e.g. the disposal of waste;

Corporate and Project expectations and goals; and

Validation of assessments conducted in the EIA process.

Monitoring can therefore be split into two broad categories: performance monitoring and potential environmental effects monitoring.

Performance monitoring involves the monitoring of emissions, discharges, and waste generations. This is required for a number of purposes:

Monitoring data for compliance with consent conditions;

Environmental data required by the Regulator; and

To track performance against HSL corporate and Project requirements and expectations.

Environmental effects monitoring, if required, will be used to validate the findings of the EIA. All monitoring requirements will be the subject of a Project Environmental Monitoring Programme (PEMP), which will be submitted and agreed with the Regulator prior to the commencement of construction and updated as required as the Project progresses.

21.5 Interface with contractors

Contractor management is an important element of the Project and HSL expects contractors to demonstrate a high level of environmental awareness, including suitable management.

The EMP and responsibilities for environmental standards and procedures will be included as part of all contract invitations to tender. This will ensure all contractors adhere to the requirements of the EMP.

Pre-mobilisation audits will be carried out as standard for any vessels, vehicles or equipment that will be used in the Project. This will ensure appropriate procedures and documentation are in place to meet measures identified during the EIA process and HSL’s statutory obligations.

Environmental commitments, objectives and targets identified for the Project through the EIA and NRA processes will be communicated to all contractors through contractual conditions. Contractor performance will be measured against these commitments.

21.6 Environmental awareness and training

HSL understands that trained and knowledgeable staff can help prevent or reduce potential environmental impacts. HSL is therefore committed to ensuring all personnel who perform or manage Project work that may have the potential to have a significant impact on the environment are trained appropriately.

All personnel including contractors engaged in work which has the potential to impact on the environment will be audited and/or monitored to ensure they have procedures in place to manage their environmental responsibilities.

21.7 Summary

Mitigation and environmental management is an iterative process and has been informed by the EIA and NRA processes, and consultation with stakeholders including Regulator. Mitigation measures will be monitored to enable HSL to track and assess the performance of the EMP, ensuring improvements can be made if necessary.

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With regards to environmental monitoring, measures will be the subject of a PEMP which will be agreed with the Regulator and updated as required throughout the Project.